Services
CFATS requires high risk chemical facilities to achieve a "satisfactory level" of security based on its risk profile. The facilities are required to complete a Security Vulnerability Assessment (SVA) and Site Security Plan (SVA) or submit an Alternative Security Plan (ASP).
SSPs will be reviewed by DHS based on 18 risk-based performance standards. According to DHS, the security requirements represent a potential "heavy lift" and it believes few chemical companies currently comply with all provisions.
After a SSP is completed, it is reviewed by DHS to ensure it provides appropriate security. Upon receiving preliminary approval, DHS will conduct an on-site inspection to determine if it has met the "requisite level of performance given its risk profile." If in compliance, DHS will issue a Letter of Approval.
Our experienced professionals work side-by-side with facilities through each step in the CFATS process. We provide guidance and expertise to help facilities complete SVAs and SSPs, as well as develop ASPs. When facilities make major changes in their operations, we also provide assistance in updating Top Screen questionnaires.
In preparation for completing an SSP, we can develop a security gap analysis. The document identifies potential shortfalls in security systems and procedures necessary to comply with CFATS standards.
We also provide pre-inspection preparations and government agency liaison support.
After an SSP receives DHS approval, facilities are required to implement ongoing security activities. To assist in this process, we provide:
- Training, exercises, drills and tests based on SSP provisions.
- Internal audits to determine compliance with CFATS.
Where disagreements may exist with DHS regarding interpretations of CFATS regulations and issues, we provide legal and other support to develop mutual solutions.