Chemical Insecurity: An Assessment of Efforts to Secure the Nation's Chemical Facilities from Terrorist Threats [open pdf - 1MB]
"This report identifies fundamental problems in the design, implementation, and management of the CFATS [Chemical Facility Anti-Terrorism Standards] program, finding: (1) CFATS is not reducing our nation's risk of a terrorist attack on domestic chemical infrastructure. The program focuses on the wrong threats, shifts risk to other parts of the chemical sector and supply chain, and is unable to determine if it is improving security at the facilities it regulates. […]; (2) DHS does not know whether some dangerous chemical facilities exist. Because of the way the program is structured, facility's initial reporting to DHS is largely on an honor system, with little way for DHS to identify facilities that do not report. […]; (3) CFATS regulates the wrong facilities. Designed to focus on the chemical plants at high risk of terrorist attack, the success of CFATS depends on an accurate understanding of facilities' risk. […]; (4) The CFATS program is failing to meet key deadlines, validate security plans, and conduct compliance inspections. According to the GAO [Government Accountability Office], it may be seven to nine years before CFATS catches up with a backlog of reviewing facilities' security plans and conducting inspections to verify compliance with security requirements. […]; (5) CFATS creates a massive regulatory burden for the companies it covers. Despite doing little to reduce risk, CFATS is costly to the companies it regulates, forcing them to dedicate time and money they don't have to fulfill onerous administrative requirements that dwarf those of other agencies. […]; (6) DHS is not transparent about how the CFATS program works and creates an adversarial relationship with the companies it regulates. DHS makes the process of working with companies adversarial, assuming the worst about the private sector -- that left to their own devices companies would eschew security and ignore the threat of terrorism just to increase profits."