DHS made a change to their web site on December 19th, they changed the CSAT User Registration User Guide, the .pdf file that provides instructions for completing the CSAT Registration. For facilities that have already completed the CSAT Registration process the changes in the new procedure will have no effect on their registration.
The only substantive change is the amount of time that the CSAT registration page can remain idle before it times out and closes (and erases any data entered) from 20 minutes to 120 minutes (pg 13). I would surmise that DHS was having complaints of having their information erased too quickly. This should make it easier for facilities to complete the registration process.
There are four other changes made to the registration instructions. DHS added clarifying instructions that consultants cannot be designated as Authorizers (pg 24) or Submitters (pg 22). They also specifically stated that consultants can be designated as Preparers (pg 33) and Reviewers (pg 41). None of these are changes to policy. The definitions and requirements for Authorizers and Submitters were pretty clear that these functions would be served by company officers or employees. There were no such restrictions for Preparers or Reviewers.
I am glad to see that DHS is being proactive in tweaking their instructions to make them clearer and more precise. As a person who has written instructions for any number of chemical processes, laboratory procedures, and SOPs I know that it is difficult to get instructions clear enough so that everyone can follow them. Listening to feedback and updating instructions is the only way to ensure that everyone understands them the same way.
My main, and continuing complaint, is that DHS is not communicating the details about what has been changed when the publish a new document.
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