Last week there were 14 new/revised FAQ answers in three categories on the DHS CSAT FAQ web page. Most of the new FAQ dealt with the new CVI Procedures Manual issued by DHS (see: “Chemical Security Page Update 09-22-08”). The three categories for the 14 new FAQ were:
- CFATS Regulation
- Chemical-Terrorism Vulnerability Information
- Web Portal Troubleshooting
None of the three questions/answers in the CFATS Regulation section of the FAQ page present any new information. In fact, the answer to a question about colleges and CFATS provides some out-dated information; it still notes that colleges and universities have 60 days from the issue of Appendix A (published last November) to request extensions for the Top Screen filing date.
Chemical-Terrorism Vulnerability Information
Because of the recent change in CVI documentation I am going to list all ten of the CVI questions and include the links to their answers. Then I will take a closer look at a couple of the answers that I find interesting.
- 1585: How will DHS protect the data it collects?
- 1586: How do I move past the CVI Authorizing Statements in the Top Screen?
- 1590: I am already a CVI Authorized User. Do I need to take the CVI training again to maintain my CVI Authorized User status?
- 1591: I am already a CVI Authotrized User. Do I need to take the CVI training again to maintain my CVI Authorized User status?
- 1592: The June 2007 CVI Procedural Manual directed public sector individuals to contact their State CVI Officer. The September 2008 CVI Procedural Manual does not. Why not?
- 1593: Will I receive a CVI Authorized User certificate after completing the CVI Authorized User training?
- 1594: May CVI be discussed with or disclosed to an Authorized User with a need to know over an unencrypted phone?
- 1595: How do I notify DHS if I am aware (1) that CVI has been released to a person without a need to know, or (2) of any request for access to CVI by persons without a need to know, or (3) that any actual or suspected misuse of or unauthorized access to CVI may have occurred?
- 1596: I have just completed the new CVI Authorized User Training module but previously completed the original CVI training. Will I receive a new CVI number?
- 1597: I just completed the new CVI Authorized User Training and realize that I have errors in the personally identifiable information (e.g. my email address) that I submitted. How can I correct this information?
I think that the single most important thing to take away from these 10 (all right there are only really 9 questions/answers because 1590 and 1591 were duplicates) FAQ responses is that DHS is not requiring that people who have already completed CVI training are not required to complete the training a second time. DHS certainly encourages individuals to go back and re-do the training, but they are not requiring people to do that.
The other interesting answer has to deal with reporting any of a variety of CVI ‘violations’ including:
- Inappropriate disclosure of CVI
- Unauthorized attempts to gain access to CVI
- Misuse of CVI
DHS has elected not to set up a ‘special’ CVI hotline or reporting number. Instead they are going to rely on the CSAT Help Desk (866-323-2957, hours of operation 7:00 a.m. to 7:00 p.m. EDT/EST) as the point of contact for reporting such problems. This saves them from having to set up another office with the attendant staffing problems.
Web Portal Troubleshooting
The final question deals with problems of printing copies of a Top Screen submission or an SVA submission. Since the facility is required to keep copies of both of these documents as part of their CFATS files, this could be a serious problem. The solution is relatively simple; save a copy of the document using the SAVE AS command on your browser. This will save the document as a .MHT file that can be viewed at any time using your browser.
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