CGA Regulatory Alert (RA-215): DHS CISA-Chemical Facility Anti-Terrorism Standards; Personnel Surety Program Implementation Notice

July 26, 2019

Please be advised that the Compressed Gas Association has issued a Regulatory Alert (CGA RA-215), regarding a notice issued by the Cybersecurity and Infrastructure Security Agency (CISA) of the U.S. Department of Homeland Security (DHS). On July 9, 2019, CISA provided notice to the public and chemical facilities regulated under the Chemical Facility Anti-Terrorism Standards (CFATS) that it is commencing full implementation of the CFATS Personnel Surety Program at all high-risk chemical facilities.

We recommend that all CGA members review a copy of this notice to determine its applicability to their company. Individuals who work for CGA member companies may access and download a copy of CGA RA-215 from the Association’s member portal (login required).


CFATS requires regulated chemical facilities to implement security measures designed to ensure that certain individuals with or seeking access to the restricted areas or critical assets at those chemical facilities are screened for terrorist ties. The CFATS Personnel Surety Program enables regulated chemical facilities to meet this requirement.

Notice of Full Implementation

CISA is publishing this notice to inform high-risk chemical facilities – in particular Tier 3 and Tier 4 facilities – regulated under CFATS of the full implementation of the CFATS Personnel Surety Program at all high-risk chemical facilities.

Previously, CISA implemented the Personnel Surety Program at Tier 1 and 2 facilities. The Agency will now implement the program in a phased manner at all high-risk chemical facilities, including Tier 3 and 4 facilities.

High-risk chemical facilities will be individually notified when to begin implementing risk based performance standard (RBPS) 12(iv) in accordance with its Site Security Plan (SSP). High-risk chemical facilities at which the CFATS Personnel Surety Program is already implemented are unaffected by this notice.

Copies of this notice can be found in the Federal Register on pages 32768-32777.

Effective date: This notice is applicable July 9, 2019.