Tuesday, January 14, 2014

CFATS Knowledge Center Update 01-13-14

Yesterday the folks at DHS ISCD updated their CFATS Knowledge Center page by revising their responses to four of the frequently asked questions (FAQ) listed on that page. Three of the changes were noted in the note in the ‘Latest News’ section of the page the other was not.

Liquefied Natural Gas FAQ

The three questions referenced in the ‘Latest News’ blurb all dealt with FAQ concerning liquefied natural gas topics related to the Top Screen, Those questions were:

#340 - Where can I find information about how to answer liquefied natural gas (LNG) storage facility questions in the Top-Screen Survey?
#1331 - Where can I find information about how to enter liquefied natural gas (LNG) storage capacity in a Top-Screen Survey?
#1337 - Where can I find information about how to answer liquefied natural gas (LNG) storage facility questions in the Top-Screen Survey?

All of the changes were related to the way the response referred to locations within the CSAT Top-Screen Survey Application User Guide. The previous versions of these responses (dating from 2007 and 2008) referred to pages within an older version of the guide and were no longer correct. Yesterday’s version of the responses refer to section numbers within the Guide and, presumably, will be less likely to change when the Guide is updated in the future.

ISCD apparently only goes back and reviews these FAQ for inconsistencies when someone points out problems in the current responses. There are an awful lot of FAQ after all. In this case I went back and looked at some of the other FAQ responses around #1331 and found that the same sort of issues could be found in the responses to FAQ # 1314, 1318, 1319, 1323, and 1324. I stopped looking then.

Keeping this stuff up to date is a tedious job. Maybe ISCD can get a summer intern to do it.

Waste Water Treatment Facility FAQ

The FAQ response that was not listed in the ‘Latest News’ notice was the response to FAQ 1732:

#1732: How can I determine if my facility’s wastewater treatment operation meets the Chemical Facility Anti-Terrorism Standards (CFATS) exemption under 6 CFR 27.110(b) for the Federal Water Pollution Control Act?

The change to this response is even simpler. It corrects a simple typographic error changing “facilityƂs” to “facility’s”. This is even less of a substantive change than those noted above, which is the reason that ISCD did not report the change.

NOTE: Sorry about the lack of links to these FAQ's. The way the CFATS Knowledge Center is set up, there are no permanent links to any of the FAQ's; you have to use the search tools on the page to find them.

CFATS Fact Sheet Updates

While we are looking at the CFATS Knowledge Center, I would like to point out something that hasn’t changed, but probably should have. ISCD had been providing links on this page to each of the monthly versions of the CFATS Fact Sheet updates. Unfortunately, they stopped doing so; the latest version listed is the August 2013 version. It was handy to have the links to these historical documents.

For consistency’s sake, they should probably all be listed here, or none of them should. There is no requirement for ISCD to publicly maintain this historical record; they are almost certainly officially enshrined elsewhere.

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