Thursday, May 13, 2010

Top Screen CVI

The latest posting on the Chemical Security Action Blog by Ryan Loughin takes a look at the CFATS Top Screen. While the vast majority of initial Top Screens have already been submitted, there will be a number of new facilities submitting their first Top Screens every month. This blog will be a valuable initial source of information for those first time submitters. Having said that, I do have a tiny nit to pick with one piece of information that Ryan includes in this post. He states that “that the person filling out the Top-Screen questionnaire must be Chemical-terrorism Vulnerability Information (CVI) authorized”. Then he explains that this “means someone who has had training by DHS on the handling of sensitive material and information”. It is that last statement that I have a minor, technical problem with. According to the Top Screen Users Manual, a first time Top Screen submitter must accept the “CSAT Top-Screen Authorizing Statements” found on the initial Top Screen page to become an “authorized user of CVI for access to CVI created by the completion of the CSAT Top-Screen” (pg 12). Now the Authorizing Statements summarize the information provided in the CVI training, but they are not a substitute for completing the training. If the facility is declared a high-risk facility, the Submitter and Preparer will have to complete the actual CVI training before they are allowed into the more advanced tools in the Chemical Security Assessment Tool (CSAT). DHS set the Top Screen CVI requirements up this way to avoid having to require tens of thousands of people to complete CVI training that would never require access to CVI beyond the letter from DHS stating that they are not a covered facility under CFATS. According to the Top Screen Users Manual, now that the initial surge of Top Screen submissions is complete, the CVI requirements may be changing: “DHS expects that in the near future access to the Top-Screen will be limited to only CVI Authorized Users that have completed the CVI training and received a CVI Authorized User Number.” (pg 12) When that happens Ryan’s post will be 100% correct instead of ‘just’ 99.99% correct. Besides, completing the full CVI training is probably a good idea for the first time Top Screen user in any case.

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