Monday, July 13, 2009

DHS CSAT FAQ Page Update – 07-10-09

This last week DHS updated five questions on their extensive CSAT FAQ web page. Actually they added three questions/answers and reviewed/updated another two. The five questions were (the last three are new): 1392: When would I have the ability to transfer my account or reassign my user role? 1472: How do I fix a typo in the user registration information I submitted? 1641: In RMP*Comp, what value do I use for the Quantity Released? 1642: I am already a CVI Authorized User. Do I need to take the CVI training again to maintain my CVI Authorized User status? 1643: How will DHS protect the data it collects? Changing Registration Information Two of the questions deal with changing user registration information; transferring accounts or changing information. The procedure is fairly straight forward when one is transferring user roles to someone else in the organization that is already registered. It becomes slightly more complicated when someone new is added because it requires the authorizer to sign and mail in a new registration document. Changing information is more difficult because of the need to make sure that only appropriate people are making changes. Chemical-Terrorism Vulnerability Information The two questions dealing CVI do not provide new information, but should probably be read by everyone involved in the CFATS process at high-risk chemical facilities. The first one deals with why old-authorized users (people who completed CVI training before October of last year) should go back and re-do their training. The second provides a decent overview of how DHS is required to treat CVI. RMP*Comp The question on the use of the EPA tool, RMP*Comp, explains that the Preparer should use the Total Onsite Quantity of toxic release COI as the ‘release quantity’ in this tool. Non-CFATS users of this tool typically use the amount in the largest storage tank for the EPA ‘worst case scenario’ calculation of the potential exposure area. DHS uses the total quantity because it must be expected that a ‘successful’ terrorist attack would target all storage containers for a nearly simultaneous release whereas an accidental release would be unlikely to affect all storage containers.

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