Wednesday, July 21, 2010

Knowledge Center Update 07-21-10

DHS has updated their CFATS Knowledge Center web page today. They announced a personnel change in ISCD management and provided additional information on the Agricultural Survey that I wrote about last night. ISCD Personnel Change In the ‘Latest News’ section of the page, ISCD posted the following notice:
“On July 19, 2010, Ted Cromwell became acting CFATS Senior Compliance Officer, replacing Laurie Boulden who takes over as Technical Analysis Branch Chief. Rest assured that during the transition and forward, ISCD compliance policies, actions, and branch staff—including the Help Desk—will continue to implement CFATS in a consistent, seamless manner. As always, we are eager to hear from you with questions and concerns.”
I talked with Laurie Boulden when I did an article for the Journal of Hazmat Transportation on her Corporate Reporting Tool. She is a very well spoken and informative woman who was very helpful in providing information about the program that she had worked so hard on to develop. I’m sure that she’ll do well as the Technical Analysis Branch Chief. Congratulations Laurie. Agricultural Survey
The ‘Latest News’ section also includes this notice about the Agricultural Survey:
“DHS is requesting information from approximately 1274 CFATS high-risk covered facilities that may sell, transfer or commercially apply COI-containing products (e.g., pesticides, fertilizers) used in agricultural activities by agricultural production facilities (e.g., farms, ranches, dairies, equine facilities, parks). Recipients must complete and submit the Agriculture Survey by Monday, September 20, 2010. DHS indefinitely extended the Top-Screen submission due date for agricultural production facilities in December 2007. The survey will provide DHS with additional information on potential risks, vulnerabilities and consequences related to facilities throughout the agricultural COI distribution chain – including manufacturers, distributors and retailers, commercial applicators and end users – and help the Department determine its next steps regarding the Top Screen extension.”
Additionally, there are 10 new frequently asked questions (and responses, of course) directly targeting this new CSAT tool. Those questions are:
1671: I sell pesticides, but only deliver them to customers on an "as needed" basis. How do I answer the questions regarding delivery of my pesticide products? 
1672: For purpose of completing the Agriculture Survey, how will I know if a pesticide includes an agricultural chemical of interest (COI) at or above the minimum concentration? Where can I find the EPA Registration Number for the pesticide? Where can I find the percent by weight of a COI in the pesticide? 
1673: Where can I read about the current indefinite extension to the Top-Screen deadline for agricultural facilities? 1674: Do the Appendix A minimum concentrations apply to the Agriculture Survey? What about the Appendix A screening threshold quantities (STQ)? 
1675: I sell fuels that are Appendix A COI or that include COI, such as propane, to agricultural facilities. Should I include these fuels in the Agriculture Survey? 
1676: Will my responses to the Agriculture Survey be protected as CVI? 
1677: What is an “agricultural facility” as regards the Agriculture Survey? 
1678: What are “agricultural activities” in terms of the Agriculture Survey? 
1679: What does the term “COI-containing products” mean in the Agriculture Survey? 1680: When is the Agriculture Survey due? 
1681: What CFATS covered facilities will receive the Agriculture Survey?
What is clear from reading these responses is that DHS will be mailing letters to those CFATS facilities that will be required to complete the Agricultural Survey and they are currently targeting fewer than 1300 facilities. If your facility receives one of those letters you certainly need to read each of the FAQ. If your facility services the agriculture sector I would think that it would also be a good idea to read these FAQ.

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