The amount of time it takes to conduct a Chemical Facility Anti-Terrorism Standards (CFATS) inspection can vary widely.
"It can be four hours. It can be an hour. It can be eight hours. It can be two days," said Steve Shedd, supervisory chemical security inspector for the Department of Homeland Security (DHS). "A lot is dependent upon the facility's preparation and the inspection team's preparation and how a facility is set up."
In order to most efficiently expedite an on-site CFATS inspection, Shedd explained, the inspection team should review the site's entire case file and determine certain aspects of the security plan that can be verified beforehand.
The inspection team may request documentation or conduct a phone interview ahead of visiting to verify particular items, Shedd added, speaking on a panel titled "What to Expect During a CFATS Inspection" at the 2017 Chemical Sector Security Summit held recently in Houston.
"We want to see what kind of cyber security policies and training measures are in place," Shedd said. "If you can provide that through a phone interview or back and forth in emails, we can clean that up before we show up on-site."
Response plans and outreach with first responders can also be addressed before the on-site visit.
"We reach out to first responders when we come out to the field to talk to facilities," Shedd said. "During our inspections we sometimes like to reach out before and invite them to the 'in brief,' or even talk to them after just to ensure that they're aware of our presence to give them the opportunity to engage and exercise with us, so that in the event of an emergency, that isn't the first time."
Background checks, elevated and specific threat planning, incident reporting and investigations, security organization and recordkeeping can also be expedited in many different ways, Shedd said, including through letter verification and certified spread sheets.
Panel moderator Josiah Hortega, branch chief of DHS' Information Technology Operations in the Infrastructure Security Compliance Division, noted a vast majority of facilities undergoing inspections are operating in compliance with CFATS requirements.
"A lot of them don't realize they already have required systems in place," Hortega said.
Be prepared
Texas Instruments' Compliance and Global Security Support Manager Gloria Griggs said it's important to develop a project plan to help expedite the CFATS inspection.
"We get that chemical inventory updated, if we haven't gotten it already," Griggs said, adding her team conducts process walkthroughs and performs almost every process.
"I got audited in June, and at the opening meeting I provided an update of where we were with the implementation of all the plan measures," Griggs said.
This is also a good time to explain to DHS any changes or enhancements to the company's security program.
Griggs added it's also important to proactively keep appropriate personnel on hand to respond promptly to inspectors' requests. She regularly prepares a list of inspection attendees to ensure every individual is Chemical-terrorism Vulnerability Information (CVI) certified.
"I can't have anybody there who is not CVI," she said. "I don't want to get that call from DHS.
"Have all the people ready. Instruct all of them to be prepared to demonstrate every piece of pertinent documentation that they have, and make sure that they bring it with them. We don't want inspectors to have to sit there and wait for us, so have all of that stuff ready. Don't sit around and try to figure out who owns what."
To help dispel any sense of nervousness employees may have during inspections, Griggs said dry runs are conducted.
"But by now, at Texas Instruments, we're just so used to it," Griggs said. "We've just ingrained everything and it's so easy now. The first time I got audited, the inspectors were there for four days. The last time I got audited, they were there for 15 minutes. It's so easy now.
"It's all about preparation. You have the processes. You know them better than anybody."
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