Monday, August 11, 2008

DHS FAQ Page Update: 08-08-08

The last two weeks I have complained about how few changes were made to the DHS FAQ page for CSAT. Well, the DHS FAQ gurus at the Help Desk heard and laughed at me. There are 29 new/updated entries on the site, all of them posted on Friday. Most of them are review/revisions of previous entries. I’ll post the categories with the number of entries per category. Then I’ll review the interesting and important ones.


·             Chemical-terrorism Vulnerability Information (1)

·             Flammable Chemicals (1)

·             User Registration Process (6)

·             User Registration System Errors (1)

·             User Roles (16)

·             Username/Passwords (2)

·             Web Portal Troubleshooting (2)


Internet Access


1238: “How do I comply with the CFATS regulation if my facility does not have Internet access?”


When Congress authorized/required DHS to regulate high-risk chemical facilities, they did not authorize an increase in the bureaucracy necessary to regulate these facilities in a paper environment. In order to have a minimum number of field inspectors DHS had to come up a way to manage the documentation necessary for any government regulation that did not require a large number of paper pushers. It became obvious that using the Internet for submissions would not only obviate the need for data entry workers, but would allow for automatic data analysis, facility classification, and prioritization of human intervention.


With this in mind, the answer to this question in the FAQ makes two blunt, succinct points:


·             “DHS will not accept Top Screens in paper format.”

·             “If a facility chooses to have a chemical of interest above the Standard Threshold Quantity, that facility must be prepared to accept the cost for doing business with that chemical. One such cost is the cost of having a computer with Internet access.”


Request for Speakers


1253: “How do I request a DHS speaker to come to my facility?”


Well, that is certainly a question that would never have crossed my mind. Though, now that I have seen it in print, it does make a certain amount of sense for the larger facilities or Tier I facilities. I am not sure how DHS is fixed for motivational or inspirational speakers, though I am reasonably sure that that is not among the primary job descriptions.


For large, complex chemical facilities with multiple COI, the CFATS process is going to be the proverbial long, hard road. A number of people are going to acquire additional new jobs and the general work load for the facility will increase until the facility completes the Site Security Plan development and implementation. Then it will start all over again when a new chemical or process is added to the facility.


It might not be a bad idea to request that a DHS speaker come out and explain to the ‘troops’ why their jobs just got harder. In any case the FAQ answer is to “submit a speaker request by contacting the CSAT help desk at” There is no indication of the likelihood of the request getting approved any time soon. DHS will also be putting in extra time and effort to get 7,000 SVA’s and SSP’s reviewed, inspected and approved. Not to mention dealing with multiple Congressional committees and writing the odd new regulation or two.


Change of Ownership


1275: “Does a facility have to resubmit a TS (Top Screen) after a sale or transfer of ownership?”


The answer to this question may not be immediately obvious. After all, a change in ownership may have no effect on chemical inventories. The DHS answer is short and succinct: “Yes, a facility has 60-days after the sale/transfer of ownership to resubmit a Top Screen.”


A more complete answer would be that all CSAT submissions would have to be re-done. DHS will need to see a new registration to ensure that the Authorizer, Submitter, Preparer, and Reviewers are all representatives of the new owner. That new registration leads logically and legally to the requirement to re-submit any other CSAT document prepared and submitted by the previous owner.


One other point not obvious in the short DHS answer; it is very likely that the old Top Screen is out of date anyway. If the facility submitted their Top Screen in the initial December/January filing, there have been a number of changes to the Top Screen Questions and Instructions since the Top Screen was submitted (see: “Updated Top Screen Manuals” for a description of the most recent change and a link to the most recent manuals).


CSAT Passwords


1282: “Can you briefly explain how CSAT passwords work?”


Because DHS is relying on a internet-based system to accept and analyze security data on tens of thousands of chemical facilities, they have to take special care to ensure that the data in their care is not compromised by crooks or terrorists posing as authorized system users. The only way to do this is to insist on good password system. This is one of the reasons for their more stringent requirements for passwords.


I’ll provide a brief summary of the DHS answer, but every CSAT user should read and copy the full ‘brief’ answer to question 1282.


·             Password: “must be at least 8 characters and contain one uppercase letter, one lowercase letter, a number, and a special character, e.g., !@#$%&*”

·             Expiration: 60 days with a one-time “grace” log-in.

·             New password must be correctly entered 3 times before it is accepted by the system.


One thing that I did not see in this new answer to this question is the notification email that the old answer said would be sent just before the email expired (see: “Potential DHS PHISHING Alert”). I’m glad to see that that idea is apparently dead.  


The CSAT Help Desk is Human After All


1283: “When can I access the Top Screen?”


The first sentence in the answer is okay; “Registered users may access the Top Screen… as soon as they receive their usernames and passwords.” The remainder of the answer dates back to last November or December; it talks about the Top Screen Deadline of January 22, 2008. There may have been an intention to change the entry, but it was never done. Oh well, with as many FAQ answers as DHS is maintaining on the site, it is inevitable that something like this will slip through.


I would like to reiterate something that I have mentioned on numerous occasions, this CSAT FAQ page is one of the most impressive documents of its type that I have seen. The amount of information included in the FAQ is truly amazing. The tools that are available for searching and accessing the information are impressive. The amount of work that goes into the updating of these answers is awe inspiring. In short, I think that the management and Indians at the CSAT Help Desk are doing a wonderful job.

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