Wednesday, March 12, 2008

Update on the DHS FAQ Page 03-12-08

DHS has one of the most extensive Frequently Asked Questions (FAQ) pages that I have ever seen. It is obvious that the various questions that are shown and answered on the page come from actual questions addressed to the Help Desk (CSAT Helpline at 866-323-2957). DHS is definitely trying to make this site work.


While each entry has a ‘Last modified’ date, the page as a whole does not. Even if it did, I do not see how anyone would be able to keep up with what changed. The only way that I have found to be able to do this is to periodically go back and scan down through the long list of questions, looking for the dates that have changed since the last search. That is what I am doing with today’s blog; I’ll identify the new entries and discuss some of the interesting answers. Forgive me if I miss anything; it is an awfully long list.


New FAQ Entries


407. In RMP*Comp, where do I account for controls that limit the Maximum Quantity in tanks and vessels?  February 13, 2008


657. Will people who have "free" or "public" e-mail accounts be granted access to CSAT? February 28, 2008


1191. I have a chemical of interest that appears in more than one category on the Appendix A.  How should it be counted?  February 14, 2008


1389. Is there a specialized approach to Propane?  March 04, 2008


1392. When would I have the ability to transfer my account or reassign my user role?  March 07, 2008


The FAQ # can be used to access the actual response on the web site. Simply access the FAQ web page and type the number into the ‘FAQ #’ block in the search section at the top of the page. You will then be taken to that specific FAQ. You can use the search section to find information by ‘Category’, ‘Source’, or ‘Key Word’ as well.


Facilities Are Still Completing Top Screens


The most interesting thing that you can tell from the new entries is that there are still facilities working on their Top Screens. We know from Secretary Stephan’s testimony before Congress that DHS gave out a large number of 60 day extensions on completing the Top Screen. Presumably most of these questions from form those facilities.


It would also be reasonable to assume that there are frequently new facilities that have just now fallen under the CFAT requirement to complete a Top Screen because the facility has just acquired an STQ amount of a Chemical of Interest. Of course, there are probably other facilities that are just now getting around to completing their Top Screen without benefit of an extension.


Whatever the reason facilities are still working on Top Screens and DHS is obviously working with them on that process. Only one of these questions, the one on propane, has a relatively straightforward answer; yet it is also addressed. It is nice that DHS is able to maintain its equanimity through this process and realize that there is truly no such thing as a stupid question when a person is looking for help.


Free Email Accounts


I ran into this problem when I completed my CVI training last spring. Email accounts from sources like AOL, Yahoo, MSN, or even Google are not as secure as ones from a company domain. DHS is trying to maintain the security of CSAT, their secure web site, so they deny access to people using free or public domain email accounts.


This is the only place that I have seen the subject addressed outside of the polite email I got from DHS. This should probably be addressed on the Chemical Security Assessment Tool site page. It might help to avoid a number of potential problems.

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