Monday, January 14, 2008

The Deadline Approaches

The deadline for the Top Screen submissions grows ever closer; it is just eight days away. DHS realizes this as well. Last Saturday they opened their CSAT Help Desk from 10:00 a.m. to 4:00 p.m EST to help facilities solve problems with their CSAT registrations and Top Screen Submissions. Next Saturday they will be doing the same thing. This was announced on their Chemical Security Assessment Tool web page last Friday.


The Help Desk is normally open 9 to 5 during weekdays. DHS is going the extra mile to ensure that chemical facilities get the best chance to submit a timely Top Screen. If you had signed up for DHS’s notification of web page changes on their Critical Infrastructure: Chemical Security page you would have received an email telling you that that page had changed. By tracking the changes on there you would have discovered that the CSAT page had a notice on it about the Saturday operating hours.


Well, their heart was in the right place. It still takes more effort than most users would exert to find the web page changes. If DHS wants to improve their change notification process, the email they send out could include a brief description of the change. That would make it easier for more people to keep trackof what was going on.


What would have been more effective would have been if they had sent an email to each of the Preparers and Submitters that were registered in the CSAT. This would have ensured that most of the people that might need the extra assistance were notified. Of course, they may have done that. Since I am not registered as either a Submitter or Preparer, I would not have received such notification. If any reader did receive such an email, please let me know.


Of course, that sort of email would never have reached those facilities that have not yet registered in CSAT. While it seems to be a little late to worry about getting facilities registered, I think that DHS needs to make that outreach effort. There are almost certainly a large number of facilities that have chemicals listed in Appendix A on hand that would never think of themselves as “Chemical Facilities”. As such many of them have not paid sufficient attention to the new CFATS rules.


What might be effective would be a press conference by Secretary Chertoff or Assistant Secretary Stephan describing the approaching deadline and discussing the types of facilities that might be covered. This might get some of the general press coverage for this issue that seems to be lacking to date.

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