On Friday, DHS added a large number of questions to its FAQ page. I usually try to at least list each of the questions, but this time, with 42 new questions posted, it does not appear to be reasonable to do so. Instead, this time any way, I will list categories under which the questions are listed.
- Sabotage Contamination
- Top Screen Resources
- Top-Screen Navigation and Troubleshooting
- Total On-site Quantity
- Total Production Value
- Toxic Chemicals
- User Registration Process
- User Roles
There are a few of the questions or answers that are interesting, either from the point of view of new information or highlighting unusual situations.
Facilities Directed to Provide Top Screen Information
- 1441: I do not have any chemicals of interest (COI) in an amount at or above the applicable Screening Threshold Quantities. However, I received an email from DHS requesting that I complete a Top-Screen. Do I need to complete a Top-Screen?
The answer notes that Section 27.200 of 6 CFR provides the Secretary with the Authority not notify individual facilities or classes of facilities to submit information to be used to determine if they are high-risk facilities. One reason for DHS to do this would be if a given industry appears to be under represented in the Phase II Top Screen Submissions. For example:
- Industry B is known to typically use large refrigeration systems that use anhydrous ammonia as the coolant. If there are known to be 1000 facilities across the country in that industry and there were only 300 Top Screens completed by those facilities. DHS might ask the other 700 facilities to complete a Top Screen to get a better picture of how many those facilities actually did have an STQ amount of anhydrous ammonia on site and just failed to submit a Top Screen for some reason.
- 1451: When I log in to the Top-Screen, I get a message that my passwords has expired and that I need to create a new one. However, when I enter a new password, I get an "invalid" error. What do I do next?
Apparently some people are having problems changing their password. One problem is that the requirements for the password are a little more complex than most internet require. An acceptable passwordmust:
- Contain at least 8 characters, and
- Contain at least one uppercase letter, and
- Contain at least one lowercase letter, and
- Contain at least one number, and
- Contain at least one special character, e.g., !@#$%&*).
DHS has used a peculiar system. It requires that the password is entered three times instead of the normal two times. After the each of the first two entries the system apparently shows a bogus ‘invalid’ message instead of a prompt for a re-entry of the new password. Now wonder someone got confused….