Sunday, August 8, 2010

DHS CSAT FAQ Update 08-06-10

This week DHS-ISCD updated the frequently asked questions (FAQ) section of the CFATS Knowledge Center. Three new questions along with the appropriate responses were listed under the heading of ‘Agriculture Survey’, bringing the total number of questions under that heading to 14. The new questions are: 1682: May I request an extension to complete the Agriculture Survey? 1683: If, after I submit the Agriculture Survey, I make material changes to my operation that necessitates submission of a revised Top-Screen, should I submit a new Agriculture Survey in addition to resubmitting a Top-Screen? 1684: I received the Agriculture Survey for completion and submission to DHS. I sell COI-containing fertilizer in bulk – I do not have it at my facility in any type of package or container. My customers purchase it by the truck-load, shovel-full, and some supply their own containers. How do I answer the question Q:4.25-224174 that asks me to identify container sizes? As is usual for this blog, I recommend that anyone connected with a CFATS facility security program should read these questions and their answers to help gain additional insight into the CFATS process. CVI Protection I do have one small complaint about the information contained in the first response. ISCD reminds the reader that any Chemical-Terrorism Vulnerability Information (CVI) submitted as part of the process to request an extension of the filing date should be appropriately protected in accordance with 6 CFR § 27.400. That is certainly the legal cite for CVI protection requirements it does very little to provide specific insights into the procedures to use to protect the information. A much more helpful resource would be the Chemical-terrorism Vulnerability Information Procedures Manual.

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