Friday, August 13, 2010

DHS CFATS FAQ Update 08-13-10

This week the folks at the ISCD Help Desk added four new questions (and answers) to the CFATS frequently asked questions (FAQ) list on the CFATS Knowledge Center. All four of the questions deal with the on-going Agriculture Survey. Those questions are: 1685: What is the definition of a pesticide for the purpose of the Agriculture Survey? 1686: I submitted the Agriculture Survey for my facility and, in reviewing my printed copy, found a significant error. What can I do? 1687: I didn’t identify any COI that functions as a pesticide, yet I was still asked to identify pesticide products. What do I do? 1689: I am an agricultural facility subject to the indefinite extension to the Top-Screen submission deadline, published on January 9, 2008. I purchase and apply at my agricultural facility a product containing COI from a distributor. For the purpose of the Agriculture Survey, do I “commercially apply” the COI-containing product? There is no real new information in the answers, just clarification of already available data. As I usually do, though, I recommend reading the answers, even if your facility does not have to complete the Survey. It does provide some insight into how the folks at DHS look at CFATS issues. For example, the gap in the numbers between question 3 and 4 is something that has happened fairly routinely over the last three years. The ISCD staff prepares a number of questions that they think will be asked about new programs, that way the Help Desk folks have a prepared and approved answer on hand when the questions are actually asked. Some sort of internal rule requires that the question has to be actually presented to the Help Desk before they can publish the question/response on the FAQ list. Maybe we'll see question 1688, may be not.

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