Monday, November 10, 2008

DHS CSAT FAQ Page Update – 11-07-08

This last week there were two FAQ answers reviewed/updated and a new FAQ posted. The three questions came from the Explosive Chemicals, User Roles, and Web Portal Troubleshooting areas. Interestingly, DHS uses the answer to the Explosive Chemicals question to explain an apparent policy exception to the Any Commercial Grade rule for theft/diversion explosive and release explosive COI. The three questions were:
707: How do I change the name of the Authorizer/Submitter/Preparer? 1450: What is the URL to the CSAT Web Portal? 1612: Is “wetted nitrocellulose” reportable as a COI, i.e., as nitrocellulose?
The answers to the first two questions contained no new information. The same can certainly not be said for the last question. That answer contains a policy exception to the Any Commercial Grade rule for concentrations of theft/diversion explosive and release explosive COI. Wetted Nitrocellulose The DHS answer to the nitrocellulose question notes that the nitrocellulose COI is the material classified as a Division 1.1 Explosive not the Division 4.1 Flammable Solid wetted nitrocellulose. Of course one could understand the questioner’s confusion. Nitrocellulose concentration in a mixture must meet the ACG (Any Commercial Grade) standard to be counted for the STQ calculations for Top Screen submissions. The CFATS regulation (6 CFR § 27.105) defines ACG as “any quality or concentration of a chemical of interest offered for commercial sale that a facility uses, stores, manufactures, or ships.” If wetted nitrocellulose is a special case exemption to that ACG rule, then DHS needs to make that clear in a format other than just the CSAT FAQ page. This is clearly something that is unusual enough to require the same type treatment as the propane exemption to the release flammable COI mixture rule. That exemption was detailed in a Federal Register Notice. The wetted cellulose exception needs to be detailed in the same manner.

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