Securing the Chemical Sector:

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Securing the Chemical Sector: An Implementation Overview of the Chemical Facility Anti-Terrorism Standards (6CFR §27) . Presented to: MCACHMM . William A. “Tony” Deas Cmdr. S/E Area 404-519-9128m 850-942-8337o. Chemical Facilities Anti-Terrorism Standards (CFATS).
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Securing the Chemical Sector:An Implementation Overview of the Chemical Facility Anti-Terrorism Standards (6CFR§27).Presented to: MCACHMM William A. “Tony” DeasCmdr. S/E Area404-519-9128m850-942-8337oChemical Facilities Anti-Terrorism Standards (CFATS)
  • Of the 3 major areas of activity; this briefing focuses on Field Operations:
  • Development of the Regulation and supporting tools, rules, guidelines, etc.;
  • Development of an organizational/program structure to include Field Operations that can implement the Regulation; and
  • Development of administrative structures that are necessary to support the regulatory environment established within the sector.
  • The organizational structure leverages existing DHS capabilities including FPS, USCG, and S&T capabilities.
  • FPS personnel and expertise comprise the core of the Inspections & Enforcement Branch (I&EB).
  • The regulatory structure will strike a cost-effective balance between rigorous adherence to security principles and limiting the financial and operations burden placed on owner/operators.
  • Safety Considerations Out-Weigh Security.
  • Risk Transference.
  • CFATS – Regulation Overview
  • The CFATS uses a multi-step process to:
  • Identify High-risk Chemical Facilities.
  • Assign High-risk Chemical Facilities to Risk Tiers.
  • Identify Vulnerabilities at High-risk Chemical Facilities.
  • Develop And Implement Site Security Plans.
  • Inspect Facilities to Ensure Vulnerabilities are Adequately Addressed and Verify Risk-based Performance Standards.
  • Step 1: Trigger Top Screen (STQ)Step 2: Perform Top ScreenStep 3:Receive Preliminary TieringStep 4:Perform SVAStep 5: Develop Site Security Plan Step 6:DHS Review of Site Security PlanStep 7:Inspections/AuditsStep 8: Implement Site Security PlanRisk-Based Performance Standards
  • Performance Standards (6 CFR §27.230)
  • Covered facilities must satisfy the Risk-Based Performance Standards (RBPS).
  • There are 19 RBPSs in the rule, addressing the following areas:
  • Guidance for Covered Facilities
  • DHS will issue RBPS Guidance in the near future. This guidance will assist industry – not prescribe specific security standards – in meeting the RBPS.
  • Personnel Surety
  • Elevated Threats
  • Specific Threats, Vulnerabilities, or Risks
  • Reporting of Significant Security Incidents
  • Significant Security Incidents and Suspicious Activities
  • Officials and Organizations
  • Records
  • Others as determined by DHS
  • Restricted Area Perimeter
  • Securing Site Assets
  • Screening and Access Controls
  • Deter, Detect, and Delay
  • Shipping, Receipt, and Storage
  • Theft and Diversion
  • Sabotage
  • Cyber
  • Response
  • Monitoring
  • Training
  • Exemptions
  • This Act specifically exempts those facilities already covered by certain, specified Federal laws:
  • Public water systems (as defined by sec. 1401, Safe Drinking Water Act).
  • Any facilities owned or operated by the Departments of Defense (DoD) or Energy (DOE).
  • Facilities regulated by the Nuclear Regulatory Commission (NRC).
  • Water treatment works facilities (as defined by sec. 212, Federal Water Pollution Control Act).
  • Maritime facilities regulated by the Coast Guard under Part 105 of the Maritime Transportation Security Act (MTSA).
  • Registration & HelplineRegistration- DHS encourages facilities to register on the CSAT website for a user identification and password if they believe they may be covered by this regulation. To register, facilities should go to www.DHS.gov/chemicalsecurity and follow the instructions. Once DHS validates a facility’s registration, DHS will notify the facility about how to access the other CSAR Tools.
  • Questions or Difficulty Registering with CFATS/CSAT?
  • - If you have any questions about how to register or have difficulty registering for CSAT, you may call the CSAT Helpline at 1-866-323-2957 from 7:00 a.m. – 7:00 p.m., Eastern Time, Monday thru Friday.I&EB Mission Responsibilities
  • I&EB MISSION AREAS –
  • I&EB is responsible for conducting inspections of assigned chemical facilities against performance standards developed out of CFATS.
  • I&EB is responsible for executing compliance enforcement of CFATS.
  • I&EB is responsible for chemical security focusedintelligence management.
  • I&EB is responsible for collaborating with chemical industry and federal, state, local and tribal officials to strengthen chemical site security through emergency preparedness.
  • I&EB is responsible for critical incident liaison to chemical industry and responding governmental emergency service agencies with a primary focus for determining security implications of the incident.
  • Phased Approach Impact on I&EB Activities and Resources
  • A Phased Approach Will Be Used to Implement the Regulation:
  • Phase 1 – Focus on expedited review and enhanced security of pre-identified highest risk (Tier 1) facilities and development of long-term DHS regulatory capabilities.
  • I&EB Field Inspectors Initiate and Complete about 50 Inspection Assists in Phase 1 by December 31, 2007.
  • Phase 2 – Full implementation of regulatory program; all high risk facilities not engaged in Phase 1 will be addressed, including inspection process.
  • I&EB Field Inspectors Work Toward Completion of Tier 1 and engage Tiers 2 – 4 commencing in January 2008.
  • Concurrently strengthen areas of Chemical Security Emergency Preparedness and Field Intelligence Management.
  • Phase 1 Implementation Approach
  • Purpose – Expedite assurance that RBPS is addressed at highest risk facilities by partnering limited DHS resources with Industry.
  • Facilities complete the CSAT Top-Screen within a reasonable but relatively brief period. I&EB Technical Assistance is available.
  • At the facilities request, I&EB Inspectors will be present when the facility develops the CSAT Top-Screen 
  • CSCD will begin certifying facility designated employees to handle Chemical-terrorism Vulnerability Information (CVI) materials. CVI is the new Sensitive But Unclassified information-handling protocol established under CFATS to protect information generated through the regulatory process.
  • Shortly after receipt of a completed Top-Screen, CSCD will notify the facility of its initial risk-based tier.
  • The Facilities will then complete a CSAT Security Vulnerability Assessment (SVA), in a similarly reasonable, but relatively brief period. I&EB Technical Assistance is available.
  • Field Inspections Primary Mission Structure
  • I&EB Inspector Cadre/Field Staff
  • Initial Cadre of experienced I&EB inspectors who have completed Physical Security Academy and are HAZMAT certified.
  • I&EB Inspection teams may be augmented by chemical engineering expertise.
  • Field Inspections will be integrated with I&EB Staffed Intelligence Section in HITRAC dedicated to Chemical Security.
  • I&EB Inspector roles and responsibilities vary based on facility tiering:
  • Tier 1 – I&EB Inspectors will Inspect Tier 1 facilities on a relatively short cycle – once every year.
  • Tier 2 –I&EB Inspectors will inspect Tier 2 facilities at least once every 2 years.
  • Tier 3 – Facilities will be inspected at least once every 3 years. These inspections may be carried out by I&EB and/or Third Party Inspectors.
  • Tier 4 will be inspected on a 4 year cycle..
  • I&EB Staffing Resources
  • I&EB is committing the following staffing, dedicated to IP for Chemical Security Compliance Enforcement:
  • Branch Chief
  • Deputy Branch Chief
  • Field Operations Program Coordinator
  • Training & Safety Compliance Coordinator
  • Intelligence Management Coordinator
  • Senior Operations Specialist
  • Area Commanders (6)
  • Inspectors (30)
  • Total Personnel – 41.
  • FPS Reserve Capacity.
  • Chemical Facility Security
  • Workload & Resource Distribution
  • - 1 Inspector- 2 Inspectors- 4 Inspectors- Area Commander531642Area Distribution of Personnel070126Chemical Facility Security
  • Organizational Integration
  • CSCD Simplified Organizational ChartChemical Facility Anti-Terrorism Standards
  • I&EB Administration
  • I&EB Inspector Base Line Training
  • FPS Inspectors Assigned to CSCD received the following minimal training before reporting to CSCD:
  • Basic Police Academy at the Federal Law Enforcement Training Center (FLETC) – 400hrs.
  • Physical Security Academy at FPS National Academy (an ASIS accredited program) – 160hrs.
  • HAZMAT Tech Level or Higher – 40 to 80hrs.
  • Upon Reporting to CSCD, I&EB Inspectors received the following training:
  • Certified Chemical Security Inspector Training Program – 168hrs.
  • On-Site SVA and SSP Practical Exercise – 40hrs.
  • In Total – 808 to 848 hours of training applicable or dedicated to CFATS implementation.
  • Additionally – All EMI trained in NRP, ICS, NIMS, and numerous other courses.
  • Overview of the Certified Chemical Security Inspector Training ProgramField Operations Administration
  • Span of Supervision:
  • Area Commander to Inspector Ratio 1:5.
  • All FPS personnel remain in parent regional offices.
  • Area Commanders supervise Inspectors using distance bridging techniques of teleconferencing, work product evaluation, close schedule coordination and accompanied on-site inspections.
  • Consistency in Field Execution:
  • I&EB Inspector Training and Updates are Consistent Nationwide.
  • I&EB Inspection Reports are Reviewed up a Chain of Command to CSCD HQ.
  • Areas of Disagreement Attempt Resolution at Lowest Level – Appeals are Addressed at CSCD Adjudications Branch.
  • I&EB Inspectors have Direct Links to Oakridge National Laboratory and CSCD Management Team to Quickly provide Uniform Guidance.
  • Chemical Facility Security
  • FY07 Field Operations Timeline
  • Field Operations - I&EBField Inspectors On-BoardFPS Team Leadership On-BoardNOV 06DEC 06JAN 07FEB 07MAR 07APR 07MAY 07JUN 07JUL 07ConductField Insp.TrainingLouisville,KYTraining Coordinator On-BoardInspectors SelectedField Inspectors OperationalDev. CurriculumSelect Trng SiteField Operations Team Development TimelinePhase One Operational Tempo 1st Qtr FY08user_template:Tony DeasCommander Area 2william.a.deas@dhs.govWhat are Your Questions?Joseph Trindal Branch Chiefjoseph.trindal@hq.dhs.govWade TownsendDeputy Branch Chiefwade.townsend@dhs.gov
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