Wednesday, November 21, 2007

DHS publishes new Top Screen Questions

Since the Federal Register officially published the final version of Appendix A to 6 CFR part 27, it is expected that about 40,000 chemical facilities will have to complete the Top Screen portion of the on line Chemical Security Assessment Tool (CSAT) within the next 60 days. DHS has put the revised Top Screen on line and published a PDF version of the Top Screen that facilities can use as a worksheet to make completing the online version easier. The revised instruction manual is not yet on-line.


Other than revising the Chemical of Interest List (COI) and Screening Threshold Quantities (STQ) to reflect the data in the final version of Appendix A, the Top Screen is essentially the same. The only other significant difference is that DHS added the following statement at the start of the process:


Submission Statement:

My statements in this submission are true, complete, and correct to the best of my knowledge and belief and are made in good faith. I understand that a knowing and willful false statement on this form can be punished by fine or imprisonment or both. (See section 1001 of title 18, United States Code).


One interesting observation; While the revisions to 6 CFR part 27 that go along with the final version of Appendix A {Section 27.203(b)(3)} state that; “In calculating whether a facility possesses an amount that meets the STQ for propane, a facility need not include propane in tanks of 10,000 pounds or less.”, there is nothing in the Top Screen Questions that reflects this. Unless the Top Screen Preparer/Submitter is aware of this exemption ahead of time, there is a possibility that the facility will unintentionally over-report the amount of propane on hand. This will probably be addressed in the instruction manual for the Top Screen when that is published.

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