The CSAT Top-Screen User Manual does provide some additional information on the two sections of the Tops Screen dealing with critical chemicals; Mission Critical Chemicals and Economically Critical Chemicals. Most of this additional information deals with definitions and how to find some of the information required to complete these two sections of the Top Screen.
As I mentioned in an earlier blog, Top Screen Questions: Mission Critical and Economically Critical Chemicals, these two sections are practically identical in layout and the information they require. The difference lies in the sectors into which the chemicals are supplied. Mission Critical chemicals go into four specific critical infrastructure sectors; Defense Industrial Base, Public Health and Healthcare, Energy (electric generation only), and Public Drinking Water. The Economically Critical chemicals are sold anywhere else in the US economy.
The definitions of the four critical sectors (page 47) are very interesting. The Public Drinking Water description is very specific; “facilities that serve at least 15 service connections used by year-round residents or regularly serves at least 25 year-round residents.” I’m not sure why the two different definitions are provided, but they are specific. The Defense Industrial Base definition is very sweeping and inclusive; “Department of Defense, government, and private-sector facilities that perform research and development, design, produce, or maintain military weapon systems, subsystems, components, or parts to meet military requirements.” The other two sectors fall between those two extremes.
The questions asked about each chemical are the same in both Top Screen sections. Additional information is provided in the Mission Critical Chemical section for determining the Capacity Utilization Rate (page 49) and the National Emergency Production Rate (page 50). The Economically Critical Chemical section provides information on determining the Total Value of Products (page 51) and the Market Share (page 52). All of this information will be used for both sections.
The interesting thing about these two sections is that they have nothing to do with the list of chemicals in Appendix A, nor are they restricted to hazardous chemicals. Both sections include the following in their instructions: “Facilities should consider chemicals listed on Appendix A as well as those not on Appendix A when determining whether their chemical production meets the criteria.” This means that facilities that have none of the Appendix A listed chemicals of interest (COI) still may be required to complete one or both of these sections of the Top Screen.
I have seen no discussion of this Top Screen requirement in any of the literature that I periodically review. DHS has either decided that they only want this information from manufacturers of COI, or they are going to come back and publicize this requirement for general chemical manufacturers at some later date.
Posts
No comments:
Post a Comment