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Authorization Inspections During the CFATS Process

The CFATS Process is a long and complicated one. There are many steps – and rightfully so. The security of chemical plants is a serious matter that needs to be handled carefully and correctly.

There are four main steps to the CFATS Process

  1. Top Screen
  2. Security Vulnerability Assessment
  3. Site Security Plan 
  4. Authorization Inspections (AI)

The Steps to CFATSAuthorization Inspections may seem simpler than reports, but as much  preparation is required for the AI as the previous steps. For example, during Authorization Inspections, the Department of Homeland Security (DHS) presumes your security is exiting the way your Site Security Plan was written. The agency wants to see evidence that what you wrote is what you implemented. Thus, the final step relies on all the previous ones to be completed correctly.

Before the inspection, a host of items need to be prepared. This includes things like the chemical inventory list, a site layout, and the company hiring and background screening policy and practices.

On inspection day, expect the team to arrive early. The logistics of the day will be laid out to include the DHS greeting and safety briefing, durations of on-site visits, routes for the facility tour and locations for interviews, group meetings, and data reviews.

Moreover, the equipment required for the Authorization Inspection should be prepared in advance. These items include a confidential stamp for information, a projector for presentations and a camera or video recorder.

If your site has a prohibition against taking pictures, make sure to both tell the inspectors and show them a document that states that. However, be prepared to allow DHS inspectors to take pictures. You can let it be known that you are suspending your normal policies for them.

A great deal of DHS’s emphasis will be on verifying that you have policy and procedures to back up your assertions of security practice. Be sure to have all such documents ready for their review.

There’s a lot that will happen during your Authorization Inspection, and an Exit Briefing is one of the final items. Make sure to schedule enough time, anywhere from one to two hours, for the briefing. All key management personnel should be there, as retained documents and images will be discussed.

The Exit Briefing is a great time to seek input and advice on concerns, either internal or from the DHS. You have the government subject matter experts at your facility; it is important to take advantage of the opportunity.  It is also a great time to make one final good impression. Make sure to express you and your facility’s commitment to the CFATS Process and lay the foundations for future conversations with the DHS.

The CFATS Process may look worthy of hair-pulling, but that doesn’t mean it has to be. Contact Huffmaster today to get started on your CFATS Authorization Inspection planning. Our trained consultants have years of experience to ensure that your company is able to correctly navigate the CFATS waters with ease. Huffmaster offers pre-inspection audits, training sessions, consulting and other services to fit your company’s needs.

Mike Saad, CPP

Senior Director Consulting Services at Huffmaster Crisis Response, LLC
Michael Saad is Senior Director of Consulting Services, Huffmaster Crisis Response, LLC. He is responsible for the security consulting line of business for the company. In that capacity he manages security program evaluation, corporate policy and procedure development, federal security compliance initiatives, corporate investigations, security threat and vulnerability analysis, and business risk management.

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