This afternoon the folks at ISCD updated the response to one of the Frequently Asked Questions (FAQ) on the CFATS Knowledge Center web site. The FAQ response was changed for FAQ #1557; concerning the procedure to be used for requesting the correction of an incorrect high-risk determination or risk tier-ranking. The question reads:
“What should I do if I think my facility was incorrectly determined to be high-risk or received an incorrect preliminary risk-based tier determination?”
Alert readers might remember that this page was updated just a couple of months ago to reflect the acting appointment of William Flynn as the Assistant Secretary for Infrastructure Protection (ASIP). Today’s change is based upon a similar personnel action; Caitlin Durkovich was recently appointed to the post of ASIP. According to the White House announcement Ms Durkovich has been the Chief of Staff of the National Protection and Programs Directorate since 2009 so she certainly has some insider knowledge about NPPD. She also has some management experience with a variety of tech organizations including the Internet Security Alliance and Verisign.
There is one other minor changes to the response to FAQ #1557. The first sentence of the third-to-last paragraph was re-written to make it easier to read. The old version read:
“It will assist DHS in processing requests for consultation with the Coordinating Official and Requests for Redetermination by the ASIP if such requests include the facility ID number assigned to the facility by the Chemical Security Assessment Tool (CSAT).”
The new version reads:
“Include the facility ID number assigned to the facility by the Chemical Security Assessment Tool (CSAT[)] to assist DHS in processing requests for consultation with the Coordinating Official and Requests for Redetermination by the ASIP[.]”
You’ll notice that I have corrected two minor typos in the re-written versions. The version on the web site is missing a closing parenthesis on the abbreviation “CSAT” and the closing period for the sentence is missing. Fortunately I’ve never had problems with typos in my blog (riight). Most people will never notice the first, but the second does make it a little bit more difficult to understand what the sentence is saying. Even so it’s easier to understand than the earlier version so it is still a gain.
One other point that I would like to make about this FAQ response. It references proper marking and packaging requirements for sending Chemical-Terrorism Vulnerability information to DHS. Unfortunately it only provides a reference to the CFATS regulations as a method to determine those requirements. The details needed to mark and package CVI are not found in that document; but they can be found in the Chemical-terrorism Vulnerability Information Procedures Manual.