Monday, July 26, 2010

Ag Survey Template

For facilities that are required to complete the DHS CFATS Agricultural Survey (you will have received a letter from DHS notifying you to complete the survey) there is an interesting article at CropLife.com that might be of interest to you. It is a short article that briefly addresses this new program. There is very little information in the article (about what I included in my first blog on the subject) but they do provide an interesting link in the article. They have produced a .PDF document showing the actual CSAT pages (WARNING: this is a very large download file) from an Ag Survey for a generic facility. Someone has set up a dummy facility in CSAT, Mike’s Dev Facility 4, that services customers in the Oil Seed and Grain Farming NAICS. They then answered some of the initial questions for that facility and then printed a summary screen for that facility’s survey. They then recommend “printing the Ag Survey Screen Captures and completing a draft of the survey before inputting information into the CSAT system”. Typically ISCD folks have provided a similar service by producing a ‘Questions’ manual to accompany the ‘Users Guide’ manual. In this case they have only made the Users Guide manual available on their web site. This makes the document made available at CropLife.com a valuable tool for completing the survey. Facility Specific Information There is a potential problem with this tool, there is no way of knowing for sure that all of the pages that a facility will see on their Ag Survey are included in this file. DHS has designed their tool so that a facility will see only the questions that apply for their site. The preparers of Mike’s Dev Facility 4 answered the initial questions about their facility and those answers will not be the same as the answers produced by any other facility. Using a document like this will certainly make the on-line completion of the survey easier. It will allow facilities to identify the specific information that they will need to complete the survey and will organize that information in a readily useable manner. While the provided screen prints would be a valuable addition to the Users Guide, I think that there is a better way to develop a facility specific ‘questions’ manual. I would suggest that a facility should develop their own tailored questions document by completing the first three sections of the Ag Survey (use the first 8 pages of the CropLife.com document as an information collection template to prepare for this). After saving the Survey at this point the facility preparer can print a facility specific version of the survey questions by using the ‘View Summary Report’ link on the left side of most Survey pages and following the subsequent instructions. There may still be pages on which the facility will have to answer questions that do not appear in the summary document as the default answers on the various questions shown may not provide access to all possible pages. These CSAT tools are very complicated documents (which is one of the reasons that they take so long to produce), but there is a very generous time limit on getting this survey completed (September 20th, 2010). Facilities should certainly plan on taking multiple sessions to complete this survey. CVI Note Technically speaking the document provided by the CropLife.com folks is a violation of the CVI rules. Anytime that there is any facility information provided on the Ag Survey, the printed (electronic or paper) copy of the survey becomes Chemical-terrorism Vulnerability Information. It must be marked in accordance with the requirements of the Chemical-terrorism Vulnerability Information Procedures Manual. I’m sure that DHS will take cognizance of the fact that this isn’t an actual facility and ignore the technical violation.

Facilities, on the other hand can expect that they will be required to protect any working copies of their Ag Survey as CVI. As soon as any facility specific information is added to the Survey it becomes CVI. This certainly includes working copies of the ‘blank’ survey found at CropLife.com.

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