Critical Infrastructure Protection: Actions Needed to Enhance DHS Oversight of Cybersecurity at High-Risk Chemical Facilities

GAO-20-453 Published: May 14, 2020. Publicly Released: May 14, 2020.
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Fast Facts

Terrorists and others may pose a cyber-threat to high-risk chemical facilities. Control systems, for example, could be manipulated to release hazardous chemicals. The Department of Homeland Security started a program more than a decade ago to help address these security risks.

We reviewed the program. DHS guidance designed to help about 3,300 facilities comply with cybersecurity and other standards has not been updated in over 10 years. Also, its cybersecurity training program for its inspectors does not follow some key training practices.

We made 6 recommendations, including that DHS review and update guidance and improve training.

A chemical facility

A chemical facility

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Highlights

What GAO Found

The Chemical Facility Anti-Terrorism Standards (CFATS) program within the Department of Homeland Security (DHS) evaluates high-risk chemical facilities’ cybersecurity efforts via inspections that include reviewing policies and procedures, interviewing relevant officials, and verifying facilities’ implementation of agreed-upon security measures. GAO found that the CFATS program has guidance designed to help the estimated 3,300 CFATS-covered facilities comply with cybersecurity and other standards, but the guidance has not been updated in more than 10 years, in contrast with internal control standards which recommend periodic review. CFATS officials stated that the program does not have a process to routinely review its cybersecurity guidance to ensure that it is up to date with current threats and technological advances. Without such a process, facilities could be more vulnerable to cyber-related threats.

Potential Cyber-Related Threats to Chemical Facilities

The CFATS program developed and provided cybersecurity training for its inspectors, but GAO found that the CFATS program does not fully address 3 of 4 key training practices, or address cybersecurity needs in its workforce planning process, as recommended by DHS guidance. Specifically:

  • The CFATS program does not: (1) systematically collect or track data related to inspectors’ cybersecurity training or knowledge, skills, and abilities; (2) develop measures to assess how training is contributing to cybersecurity-related program results; or (3) have a process to evaluate the effectiveness of its cybersecurity training in improving inspector skillsets.
  • The program also has yet to incorporate identified cybersecurity knowledge, skills, and abilities for inspectors in its current workforce planning processes or track data related to covered facilities’ reliance on information systems when assessing its workforce needs.

Fully addressing key training practices will help ensure that CFATS inspectors have the knowledge, skills, and abilities for cybersecurity inspections, and identifying cybersecurity needs in workforce planning will help the program ensure that it has the appropriate number of staff to carry out the program’s cybersecurity-related efforts.

Why GAO Did This Study

Thousands of high-risk chemical facilities may be subject to the risk posed by cyber threat adversaries—terrorists, criminals, or nations. These adversaries could potentially manipulate facilities’ information and control systems to release or steal hazardous chemicals and inflict mass causalities to surrounding populations (see figure). In accordance with the DHS Appropriations Act, 2007, DHS established the CFATS program to, among other things, identify and assess the security risk posed to chemical facilities.

GAO was asked to examine the cybersecurity efforts of the CFATS program, including the extent to which the program (1) assesses the cybersecurity efforts of covered facilities, and (2) determines the specialty training and level of staff needed to assess cybersecurity at covered facilities.

GAO conducted site visits to observe the cybersecurity portion of CFATS inspections based on scheduled inspections, reviewed inspection documents, and interviewed CFATS inspectors. GAO also analyzed inspection guidance and training against key practices and assessed workforce planning documents and processes.

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Recommendations

GAO is making six recommendations to DHS to routinely review guidance and update, as needed; to fully incorporate key training practices; and to identify workforce cybersecurity needs. DHS concurred with the recommendations.

Recommendations for Executive Action

Agency Affected Recommendation Status
Cybersecurity and Infrastructure Security Agency The Assistant Director of the Infrastructure Security Division should implement a documented process for reviewing and, if deemed necessary, revising its guidance for implementing cybersecurity measures at regularly defined intervals. (Recommendation 1)
Closed - Implemented
We found that Chemical Facility Anti-Terrorism Standards (CFATS) program officials had not reviewed or updated the guidance designed to help facilities comply with the cybersecurity and other performance standards for more than 10 years, despite the guidance itself acknowledging the importance of such updates and revisions. CFATS officials also stated that the program did not have a process to routinely review its cybersecurity guidance to ensure that it is up to date with current threats and technological advances. Therefore, we recommended that CISA should implement a documented process for reviewing and, if deemed necessary, revising its guidance for implementing cybersecurity measures at regularly defined intervals. In response, CISA approved an Information Guidance Directive establishing the process by which CISA will review and, as appropriate, update its guidance for implementing cybersecurity measures. The directive includes several notification and review timelines, such as: immediate notification to facilities of any vulnerabilities and threats to their cyber components; quarterly guidance updates to inform facilities on the culmination of important cybersecurity information issued by government and private entities; and long-term reviews of significant guidance, including the CFATS cybersecurity results-based performance standard. These actions are consistent with our recommendation and will help ensure that the CFATS program guidance for cybersecurity better addresses chemical facilities' potential vulnerability to cyberattacks.
Cybersecurity and Infrastructure Security Agency The Assistant Director of the Infrastructure Security Division should incorporate measures to assess the contribution that its cybersecurity training is making to program goals, such as inspector- or program-specific performance improvement goals. (Recommendation 2)
Open
DHS concurred with this recommendation and stated that CISA agrees that it is important to ensure cybersecurity training supports program goals, whether relating to inspector-specific or program-specific performance maintenance or improvement goals. According to CISA officials, as of January 2022 the CFATS inspector auditing program, which is one way CISA assesses the effectiveness of its training programs, remained on pause due to COVID-19 concerns. CISA officials anticipate resuming the audit program during fiscal year 2022. Once reinitiated, the inspector audit program will allow CISA to better assess the contributions that cybersecurity training is making to inspector and program performance goals, according to the officials. We will continue to monitor the status of CISA's efforts to address this recommendation, and the extent to which the efforts assess the contribution that cybersecurity training is making to CFATS programmatic goals.
Cybersecurity and Infrastructure Security Agency The Assistant Director of the Infrastructure Security Division should track delivery and performance data for its cybersecurity training, such as the completion of courses, webinars, and refresher trainings. (Recommendation 3)
Open
DHS concurred with this recommendation and stated that CISA agrees that process improvements to better document and evaluate the effectiveness of the training provided to CFATS staff are worthwhile. As of January 2022, CISA officials reported that the CFATS program launched a new system for managing cybersecurity and other internal CFATS training. According to the officials, the new system can track all participants, test scores, and certificates for internal cybersecurity training. CISA officials also reported that they were in the process of loading courses and training records to the new system so that course delivery and performance data could eventually be tracked. We will continue to monitor the status of actions taken to address this recommendation and the extent to which they result in the CFATS program's ability to track delivery and performance data for cybersecurity training.
Cybersecurity and Infrastructure Security Agency The Assistant Director of the Infrastructure Security Division should develop a plan to evaluate the effectiveness of its cybersecurity training, such as collecting and analyzing course evaluation forms. (Recommendation 4)
Open
DHS concurred with this recommendation and stated that evaluating the effectiveness of training is beneficial and CISA will work to ensure that all cybersecurity courses provided to CISA chemical security staff are evaluated for effectiveness. As of January 2022, CISA officials reported that the CFATS program does not have a process for conducting an overall review of the effectiveness of CFATS training and was reviewing options to support an annual review process. According to the officials, the annual review process would seek to determine: the efficacy of each course; what changes may be needed for DHS-provided courses; and whether CISA should continue to pay for external courses. We will continue to monitor the status of CISA's actions to address this recommendation and the extent to which they result in a plan to evaluate the effectiveness of cybersecurity training.
Cybersecurity and Infrastructure Security Agency
Priority Rec.
This is a priority recommendation.
The Assistant Director of the Infrastructure Security Division should develop a workforce plan that addresses the program's cybersecurity-related needs, which should include an analysis of any gaps in the program's capacity and capability to perform its cybersecurity-related functions, and human capital strategies to address them. (Recommendation 5)
Open
As of February 2022, CISA prepared two documents related to this recommendation that were under leadership review. According to CISA officials, the first document--CISA Chemical Security Workforce Planning Guide--outlines the process for workforce planning within CISA Chemical Security, and provides steps, tools and resources to plan for current and future organizational and workforce needs. The second, according to the officials, is the CISA Chemical Security Concept of Operations for Cybersecurity Workforce Planning which documents the approach CISA will use to employ the Workforce Planning Guide to conduct a workforce planning review of cybersecurity capacities and capabilities of the chemical security program. The officials stated that both documents are undergoing final review and are expected to be finalized by March 2022. We will continue to monitor CISA's efforts to address this recommendation and the extent to which the actions result in a workforce plan that addresses CFATS' cybersecurity-related needs.
Cybersecurity and Infrastructure Security Agency The Assistant Director of the Infrastructure Security Division should maintain reliable, readily available information about the cyber integration levels of covered chemical facilities and inspector cybersecurity expertise. This could include updating the program's inspection database system to better track facilities' cyber integration levels. (Recommendation 6)
Open
DHS concurred with this recommendation and stated that CISA retains information on cyber integration levels for regulated facilities, but that it is not in a readily accessible format. As of January 2022, CISA officials reported that the agency is creating a tool to automate the locating and reporting of a facility's cyber integration level data. In addition, the officials stated that CISA is updating its web portal used by chemical facility operators to include a question concerning facility cyber integration levels. Regarding inspector cybersecurity expertise, CISA officials stated that the CFATS program has begun tracking inspector cybersecurity training, but is in the process of transitioning its training information system and working to ensure that the tracking continues in the new system. We will continue to monitor these actions taken in response to our recommendation and the extent to which they result in reliable, readily available information about covered facilities' cyber-integration levels and inspector cybersecurity expertise.

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