Today the DHS Infrastructure Security Compliance Division (ISCD) updated the response to a frequently asked question (FAQ) on the CFATS Knowledge Center. The updated response was for FAQ # 1275; What needs to be done when a facility is bought or sold?
There was no substantive change to the requirements associated with the change in ownership. The change simply removed the Chemical-Terrorism Vulnerability Information (CVI) disclosure statement at the end of the response. That statement used to read:
“CVI Disclosure If any letters submitted to DHS for review contain any CVI information, the letter must be properly marked, packaged, and sent in accordance with the CFATS regulations for protection of CVI (see 6 CFR § 27.400). A copy of the CFATS regulation, including the CVI requirements in 6 CFR § 27.400, is available at https://www.dhs.gov/critical-infrastructure-chemical-security.”
It is not clear why the statement was removed. While one would like to assume that anyone associated with the CFATS program would understand the CVI requirements for identifying and sending CVI protected information, the whole purpose of FAQ responses is to communicate information in a new format to ensure that the affected parties understand all of the requirements.