CSAT Web Page Update 07-19-10

Without any fan fare or explanation the CFATS people at ISCD updated the Chemical Security Assessment Tool web page today. A single change was made to the page, adding a link to another ‘Key Document’ on the right side of the page; the CSAT Agriculture Survey User Guide. This document and its associated tool in CSAT (Agricultural Survey) are part of the data collection effort to resolve the issues that lead to the issuance of the Agricultural Facilities Time Extension Notification in January 2008. What is not yet clear is how DHS intends to communicate the requirement to complete this survey to “CFATS covered facilities that sell, transfer or commercially apply COI and COI-containing products to agricultural production facilities subject to the extension of the Top-Screen due date” (pg 1). There are a couple of possible options, official letter to the targeted facilities or a notice in the Federal Register. There is no notice scheduled to be published in the July 21st Federal Register, but one could be posted at some later date. With just a quick review of this document this evening it looks like a standard CSAT tool, requiring registered users who have completed CVI certification to access the tool. The odd thing about the questions is their focus on the facility’s customers rather than on facility security. It does not appear that facilities will be required to identify specific customers. The questions appear to be targeted at the universe of customers for each Covered Facility. Another interesting provision of the Survey is that DHS is asking for information on chemical use for all chemicals that are listed DHS chemicals of interest (COI) or that contain one or more COI above the minimum concentration values listed in Appendix A, regardless of whether or not the delivered quantity is above the Screening Threshold Quantity (STQ) for that COI. This applies even if the covered facility was not required to report the COI on their Top Screen because it was below the STQ threshold. I’m sure that I’ll have more to say about this document and its associate program after I have had a chance to look over the document in more detail and do some more research on how DHS plans on using this tool and its associated information.