CFAT- Strengthening security through partnership

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June 29, 2023 - Industrial and commercial facilities handle thousands of hazardous chemicals used in multiple processes and operations, requiring compliance with many environmental, health, and safety (EHS) regulations. And yet, the critical aspect of chemical security often remains overlooked. How are these facilities ensuring the proper security and management of these chemicals to prevent misuse?

The responsibility for maintaining EHS compliance falls on the shoulders of those who monitor, inventory, report, and document the chemicals used or manufactured onsite.

Chemical security introduces an entirely new set of challenges, requiring facility EHS managers to not only grapple with their usual EHS compliance requirements but also to meet standards set forth by another regulatory agency.

Chemical security is regulated by the Department of Homeland Security’s (DHS) Chemical Facility Anti-Terrorism Standards (CFATS). This regulation primarily focuses on the secure storage and management of chemicals of interest (COI) within a facility, aiming to prevent the potential exploitation of these raw materials by domestic and international terrorist organizations in perpetrating catastrophic attacks on the United States.

The premise for CFATS is to physically secure COI present in quantities that pose a high risk of security for toxic releases, flammable releases, explosives, sabotage/contamination, and theft. Physical security includes the use of engineering controls, cameras, badge readers, locked chemical storage, inspections, specialized chemical-procurement procedures, training, drills, and documentation. In addition to physically securing chemicals, facilities subject to CFATS also need to have comprehensive cybersecurity policies and practices in place to prevent technology-based attacks or at a minimum, mitigate the impact.

The CFATS program offers a significant advantage to the chemical facility as it is built on a collaborative partnership between DHS and owners and operators of chemical facilities. This alliance fosters a proactive and cooperative approach in ensuring the effective implementation of security measures. The industry is responsible for implementing security measures that comply with the established regulations and providing critical feedback to DHS. The partnership relies on regular communication, joint training, and feedback mechanisms. Some of the key elements of the CFATS partnership with industry are:

  • Regular communication: DHS maintains regular communication with chemical facility owners and operators through various channels, including guidance documents, webinars, and outreach events. This communication helps to keep the industry informed about the latest security standards, best practices, and emerging threats.
  • Joint training: DHS and industry partners collaborate on training programs to enhance security awareness, technical skills, and emergency-response capabilities. The training covers a wide range of topics, including risk assessment, security plan development, and incident response.
  • Feedback mechanisms: DHS encourages feedback from chemical facility owners and operators on the effectiveness of the CFATS regulations. This feedback helps to identify areas for improvement and adjust the regulations to address emerging threats.
  • Industry expertise: Chemical facility owners and operators have extensive expertise in managing hazardous chemicals and implementing security measures. This expertise is critical in identifying potential security risks and developing effective solutions. By leveraging the industry's expertise, CFATS can tailor the regulations to address specific risks and promote industry best practices.
  • Public-private collaboration: The CFATS partnership with industry is a prime example of public-private collaboration to enhance national security. By working together, both parties can achieve greater efficiency, effectiveness, and mutual benefits.

Maintaining a partnership with the DHS ensures regulatory compliance and conveys an organizational commitment that the chemical facility is effectively and proactively mitigating potential catastrophic events.

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Melissa Hart

Melissa Hart

Melissa Hart is a Principal Consultant with BSI’s Professional Services practice and a subject-matter expert on CFATS compliance, including applicability, Top Screen, site security plans, CSAT, auditing, and overall compliance. She has managed and supported CFATS clients in the US in fertilizer, food and beverage, pharmaceuticals, chemical manufacturing, water utilities, and contract packaging of aerosol consumer products.

CFATS

The Chemical Facility Anti-Terrorism Standards (CFATS) program, overseen by the Department of Homeland Security's (DHS) Cybersecurity and Infrastructure Security Agency (CISA), plays a critical role in safeguarding chemical facilities from potential terrorist threats. See our CFATS consulting services page so your organization can be well-prepared to address the multifaceted security challenges posed by CFATS.

Learn more about CFATS

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