DHS has added four new questions to their FAQ pages today. Two of the questions deal with Security Vulnerability Assessments and two deal with Top Screen issues. The questions are:
- 1432. What facilities will have to complete the SVA?
- 1433. When will I be notified if I have to complete a SVA?
- 1434. What is a sabotage/contamination chemical of interest (COI) for purposes of CFATS?
- 1435. What is the definition of A Commercial Grade (ACG) for the purposes of CFATS?
Security Vulnerability Issues
Recent news reports, both here (see: "Vulnerability Assessments are Underway") and else where, have brought the continuation of the CFATS process back into public view. That may be the reason for these two questions.
The simple answer to the first question is, of course, you have to complete an SVA if DHS tells you to. A more complete answer would be that if DHS determined that you were at high-risk for a chemical attack due to your Top Screen submission, you will be informed that you have to complete an SVA.
The DHS answer to the second question is just a little misleading. They say, in part, that: "DHS expects to review a facility's Top-Screen within 60 days of its submission. Upon completion of that review, facilities that are considered "high-risk" will be mailed a Preliminary Tier Determination letter". The implication is that the notification would be sent out within that 60 day period.
We all know that the letters have yet to go out for facilities that completed their Top Screen last December-January, much longer than 60 days ago. Realistically, DHS is still working out the bugs in their SVA module in CSAT. Live testing of that system is now being conducted by the Phase I facilities that completed their Top Screen last summer.
The answer also contains a reminder that Tier 4 facilities, the lowest-risk high-risk facilities, will have the option of submitting an alternative security plan document to DHS outside of the CSAT online tool. Tier 4 facilities that have already completed a vulnerability assessment using one of the industry standard tools may ask DHS to accept that analysis.
Top Screen Issues
The two Top Screen related questions have to do with the ‘odd balls’ of the Chemicals of Interest (COI) list, Sabotage/Contamination COI, and a definition, A Commercial Grade, used in determining a countable concentration for select COI. There is no new or interesting information in either of these answers.