Friday, May 2, 2014

DHS Updates CFATS Knowledge Center

Yesterday, according to a notice in the “Latest News” section of the CFATS Knowledge Center, the folks at ISCD updated the responses to 8 of their frequently asked questions on that page. The question responses updated were:

• FAQ 1178 - Are truck terminals and railroad facilities regulated under the Chemical Facility Anti-Terrorism Standards (CFATS)?
• FAQ 1180 - What if people are not aware of this new regulation?
• FAQ 1194 - Under what circumstances is a college/university exempt from submitting a Top-Screen under CFATS?
• FAQ 1196 - If DHS determines that a college or university is high risk under Chemical Facility Anti-Terrorism Standards (CFATS) and assigns a preliminary tier, must that college/university submit a Security Vulnerability Assessment (SVA) or Site Security Plan (SSP)?
• FAQ 1207 - When calculating whether a facility possesses a chemical of interest (COI) that meet the Screening Threshold Quantity (STQ) for a security issue, are there any exclusions?
• FAQ 1209 - Are transportation containers that are detached from the motive power considered in calculating the Screening Threshold Quantity (STQ)?
• FAQ 1450 - What is the URL to the CSAT Web Portal?
• FAQ 1666 - Does a facility have an obligation to notify DHS if the facility is closing? 

NOTE: Sorry about not providing links to these FAQs, but the CFATS Knowledge Center FAQ database does not include permanent links to the FAQs. You can use the ‘Search’ box on the landing page or any of the extensive search tools on the subsequent pages to find the latest version of the FAQ and response.

That note also contains a cryptic reference to “Liquefied Natural Gas” but that just looks like a typo since none of the above FAQs specifically address liquefied natural gas. Perhaps there were going to be some changes to a FAQ concerning that topic, but it did not get to the Knowledge Center today.

The note goes on to explain that the purpose of the changes is to “provide greater clarity, accuracy, and updated links”. In many cases that purpose was achieved with a large measure of success. In other cases there is more confusion now because of incorrect links or less helpful links. And in at least one case there was no apparent change made.

More Information

Most of these changes date back to early in the CFATS program. In those days most of the FAQ responses just pointed readers back to a primary document, but did not provide any direct response to the question. The new responses to FAQ #s 1178, 1194, 1196, 1207, and 1209 provide significantly more detailed information. The other three FAQ responses have essentially the same information as the old responses.

eRegulations

None of the older FAQ responses contained any specific references to the CFATS regulations in 6 CFR Part 27. Many of the newer responses do mention specific paragraphs in the regulations and provide a link to the “Electronic Code of Federal Regulations”. I personally don’t like the links provided in that electronic document because they are not ‘people readable’ and it is hard to notice and track down errors in the links.

I prefer the links at the GPO ‘Code of Federal Regulations’ web site. There when you see the link to 6 CFR 27 (http://www.gpo.gov/fdsys/pkg/CFR-2013-title6-vol1/pdf/CFR-2013-title6-vol1-part27.pdf) you can readily see that it is 6 CFR 27. At the Electronic Code of Federal Regulations the link to the same 6 CFR 27 reads   “http://www.ecfr.gov/cgi-bin/text-idx?SID=e13a020efee8d4e827252b322d60fec5&node=6:1.0.1.1.11&rgn=div5”. There is no quick way to check to visually verify that that goes to 6 CFR 27.

This confusing link address may be why three of the FAQs (1194, 1196, and 1666) have links that should point to 6 CFR 27, but actually point to 6 CFR 25. Short of clicking on the link there is no quick way to verify that it points at the right place. I supplied ‘User Feedback’ to that effect on the affected FAQs.

Rule References

Most of the FAQ responses (new and old) point to the Appendix A Final Rule as a reference in the discussion. That rule spans 39 pages of the Federal Register and if you don’t know where to find something in that document you can spend a lot of time searching. Many of the original FAQ response links contained a “#page=XX” reference at the end of the link so that searches only had to cover a single page of the document. None of the new FAQ response uses that convention. So, the ‘updated’ links to the final rule are probably not as useful as the ‘old links’.

No Changes

I can find no changes in the links or wording in the response to FAQ 1450.

Evaluation


I applaud the effort made by DHS to upgrade the explanation in the responses to FAQs 1178, 1194, 1196, 1207, and 1209. They are much more useful than the original responses. Unfortunately that ‘attaboy’ is wiped out by the ‘awshit’ for the bad links and less helpful links provided in the new responses. This is simply not up to the standards we have come to expect from ISCD.

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