Thursday, December 1, 2011

CFATS Disenrollment Tool

An interesting short article at FierceHomelandSecurity.com describes a new tool coming to the CFATS Chemical Security Assessment Tool (CSAT) that would make it easier for high-risk facilities to be removed from the CFATS program. The tool was briefly mentioned at an industry event in September by Jenifer Cannon, the acting compliance section lead of DHS's Infrastructure Security Compliance Division.

The CFATS rules have always made it possible for a covered facility to ‘opt out’ of the program by getting rid of all DHS chemicals of interest (COI) or reducing the inventory levels below the Screening Threshold Quantity (STQ) for all of the COI on site. There have just been a number of hoops that have had to been jumped through for this to happen, but a large number of facilities have completed the process.

Apparently what Cannon was describing is a single CSAT tool to use for the ‘opt out’ process. Presumably that tool would be supported at ISCD by the appropriate analysis tools and personnel support to make the ‘opt out’ process easier to accomplish.

The article notes that Cannon expected the tool to be in place by the end of the year; which is coming real quick now. Of course, ISCD has a pretty consistent history of missing their self-imposed deadlines.

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