Thursday, July 13, 2017

ISCD Publishes CFATS Emergency Response Fact Sheet

Today the DHS Infrastructure Security Compliance Division (ISCD) posted a new fact sheet on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center.  The fact sheet deals with the implementation of Risk-Based Performance Standard (RBPS) #9, Response in developing a site security plan (SSP) for a CFATS covered facility.

Generally speaking, there not much new here that is not already covered (in slightly more detail) in the RBPS Guidance Document. The one exception is that the fact sheet stresses that there are differences between Security Response Plans and Emergency Response Plans, but that both are required portions of the response planning necessary for site security plans.

One piece of discussion is glaringly missing from the Fact Sheet, the need to plan for backup power, communications and process safeguards. Physical attacks (and natural disasters) are very likely to have negative affects upon these critical areas and any response or recovery plan is going to have to address those necessities.

Both documents fail to completely address coordination with State and local authorities. While they do mention fire, police and emergency medical services, they fail to discuss the role of Local Emergency Planning Committees (LEPCs) in emergency response planning. While not every community has an active LEPC, CFATS facilities should make a positive effort to reach out to whatever LEPC is active in their community to ensure that adequate coordination is made between all effected and affected agencies.

Finally, local hospital emergency departments (with an emphasis on multiple facilities) in the area need to be notified of any chemicals held on site that could require specific (and/or unusual) medical technologies to treat exposed individuals. Where expensive and/or short-shelf-life kits (see my discussion about cyanide kits, for example) the local medical community needs to be aware of these measures so that they can either ensure there is a local stockpile available or that  appropriate sharing agreements are initiated.

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