There is an interesting addition to the DHS Chemical Security web site. Today there is a new page detailing requirements for submitting a Top Screen if your facility has fuel tanks on site. I have noted in a number of earlier blogs (see: "More information on fuel tanks") that there could be some confusion about fuels, fuel tanks, and the Top Screen. This series of web pages attempts to make the situation clearer.
Those of you that have signed up for notification of changes to the Chemical Security pages should have received an email notification of this change. The change notification email lets you know that the change involves "Added information on how to submit a Top Screen if a facility has fuels." Again, I like the new DHS change notification procedure.
New Online Tools Available
The site deals with two different situations expressed as questions that a facility might ask. Those questions are:
- My facility has fuels, do I have to complete a Top Screen? (Questions – Diagram)
- I know my facility has to complete a Top Screen, but how do I count my facility's release-flammable chemicals of interest? (Questions – Diagram)
There are two different ways of accessing the information. The facility can answer a series of questions that lead to the appropriate guidance. The second method is a flow chart diagram that leads one through the same questions graphically. Both methods provide the information in a clear concise manner.
Requirements to Re-submit Top Screen
Unfortunately, most facilities have already completed their Top Screen. Perhaps DHS expects facilities to review this new method of information presentation (there is no really new information here) to ensure that they properly completed their Top Screen. If that is the case, they should have notified all facilities by email or we might see a Federal Register notice about the new page.
If a facility incorrectly reported their Flammable Release COI information, they do have a legal responsibility to update their Top Screen. If the facility over-reported their Flammable COI inventory, re-submitting the Top Screen could be beneficial; reducing a tier level ranking or maybe removal from the High-Risk rating. Under reported facilities do not have the same advantages to re-submitting, but they are still obligated to do so.
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