Today the folks at DHS ISCD have updated their CFATS Knowledge Center by revising the response to one of the frequently asked questions on the site. According to the ‘Latest News’ section of the landing page: “The answer to FAQ 1579 regarding colleges and university facilities was updated to provide greater clarity and an updated link.” Actually, there was no link on the previous version (dating to 7-1-09) of the FAQ response.
FAQ # 1579 asks:
“How does a college define itself if it has multiple facilities, yet only a few select facilities possess Chemicals of Interest (COI) that are subject to being regulated by the Chemical Facility Anti-Terrorism Standards (CFATS)?”
The new response explains:
“All facilities, including colleges and universities, have the flexibility to define the parameters of their facilities. CFATS requirements are facility-specific. As such, an institution of higher learning can, if appropriate, submit a Top-Screen on a facility-by-facility basis or on a campus-wide basis. However, the Department will evaluate whether or not the facility or facilities, if determined to be high-risk, have complied with CFATS and, specifically, the Risk-Based Performance Standards (RBPS). Guidance, options and exclusions are presented in Chemical Facility Anti-Terrorism Standards (CFATS); Final Rule, Section III (B)(1) Colleges and Universities 6 C.F.R. pt.27 (2007), available at: http://www.dhs.gov/xlibrary/assets/chemsec_appendixafinalrule.pdf.”
NOTE: Once again, sorry about the lack of a link to the FAQ or it’s response, but the FAQ listing does not use permanent links.
It would have been a tad bit more helpful if the link had been to the actual Federal Register entry and included the page number (65411) for the actual information.