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Trinity recently participated in a Department of Homeland Security (DHS) Authorization Site Visit at a Tier 4 facility. Some of the key takeaways from that experience include:

  • Facilities can tell their employees that they are subject to the Chemical Facility Anti-terrorism Standards CFATS Compliance(CFATS) program; this knowledge does not trigger the need for Chemical-terrorism Vulnerability Information (CVI) training. In some instances, DHS encourages letting employees know that certain chemicals require additional security measures under CFATS to help promote awareness of the security concerns associated with those chemicals (i.e., encourages employees to say something if a potential security issue is observed).
  • DHS has two types of compliance strategies to meet the Risk-Based Performance Standards (RBPS): “facility-based” and “asset-based”. Facility-based refers to meeting the RBPS (including restricting, deterring, detecting, and delaying access) on a facility-wide basis (e.g., controlling access to the facility perimeter or facility buildings), whereas asset-based compliance focuses on where the chemical of interest (COI) is stored. Facility-based compliance is ideal for companies that store COI in multiple locations throughout their property. Asset-based compliance is more practical for facilities that store their COI in one or two locations. Keep in mind that any employee with access to a COI requires a background check under the Personnel Surety Program (PSP), so limiting access to the COI can make the PSP requirements less burdensome.
    • Example: If a facility stores a COI on a rack in a warehouse, then it is easier to install security measures on the rack (e.g., install a locked-cage around the rack and assign keys to the appropriate personnel) and complete background checks on the employees with access to the COI, rather than installing access control measures on the entire warehouse building and completing background checks on all employees with access to the warehouse.
  • On July 9, 2019, DHS announced that the PSP applies to all covered chemical facilities, including Tier 3 and 4 facilities. Based on the four options available to meet the PSP requirements, DHS has noticed that Option 1 has been the most practical option for Tier 3 and 4 facilities. The four options include:
    • Option 1 - Direct Vetting
    • Option 2 - Use of Vetting Conducted under Other DHS Programs
    • Option 3 - Electronic Verification of Transportation Worker Identification Card (TWIC)
    • Option 4 - Visual Verification
  • Tier 4 facilities must monitor COI storage areas at least once every 24 hours, including on the weekends and holidays. Monitoring can be achieved by completing visual inspections, installing intrusion detection systems (e.g., mechanism to alert employees if a door is forced open without the proper key inserted), using security cameras, etc.
  • DHS inspectors have used Tier II reports to screen CFATS applicability at facilities.
  • DHS typically gives a 30-day notice before a Compliance Inspection (CI) and these inspections typically last three hours. A facility's first CI typically focuses on implementation of any planned measures identified during the Authorization Inspection.