For those of you that have signed up for notification when the ‘Critical Infrastructure: Chemical Security’ web site page has changed, you know that DHS has added a link on that page to the Federal Register page dealing with the clarification about propane that I discussed in an earlier blog (see: “DHS Clarifies Propane Mixture Rule”). I mention this for two reasons: 1) bring the web page change to your notice, and 2) acknowledge that DHS has made yet another advance in their change notification procedures.
Let’s look at the latter first. I have been documenting the evolution of the DHS change notification procedures on their chemical security web site. The notification message that I received by email is the latest part of that evolution. They announced that the change had been made and they explained what the change was. Once again, I would like to congratulate DHS on their progressive attempts to make their web site more user friendly.
There was one small problem, the link that should have gone to the page went to an inactive site (http://service.govdelivery.com/service/view.html?code=USDHS_54) instead. That appears to be a simple error rather than a short coming in their notification system.
Now looking at the propane clarification, I would like to cover a couple points that I missed in my earlier blog.
First I have some questions about the timing of this clarification. It was issued on the 21st of March, two days after the end of the 60 day extension for completing the Top Screen. Or maybe the last day of the extension, depending on where DHS counted from (January 19th or 21st). In either case, it came too late to be of any use to anyone filing either under the original time limit or the extension. This begs the question, for who was this clarification provided?
The second is a web site issue. The Federal Register entry mentions that
“Since publication of the Appendix A Final Rule, the Department has received numerous inquiries about the STQ provisions for the COI propane and about the applicability of the release-flammable mixture provisions to products that contain the COI propane and to other products that contain some propane.”
Interestingly the FAQ web page on the Chemical Security Site lists only one question about the propane COI dealing with flammable mixtures; question 1224, “How do you calculate the STQ for Propane in a mixture?” The answer to that question (as of 3-22-08, a day after the page in the notification was changed) was dated 11-24-07 and states that “The minimum concentration and mixtures provisions for propane are the same as for all other release-flammables.”
It is odd that, if there had been ‘numerous inquiries’, that the latest question on the FAQ page is dated 11-24-07. Finally, it is disappointing that the answer to that question is the same out of date information that necessitated the clarification. I would have expected to see the information in the clarification appear first on the FAQ page.
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