Tuesday, September 21, 2010

New Top Screen Manual Reviewed

Well, as promised earlier I have had a chance to take a look at the new Top Screen Manual that DHS-ISCD published today. I kind of expected that this would be new rules for the reporting fuels at fuel terminals, but it turns out that there are no real changes in procedures provided in this manual. There are changes (including a name change), some good and some questionable, but no new policy.

First we will look at the change in names. The new manual is called the CSAT Top-Screen Survey Application User Guide. It is listed as version 1.99. The old manual was called the CSAT Top-Screen User’s Manual with a version number of 2.8. I suppose that this explains why there is no change history listed in the front of the manual to explain what changes were made from the previous version.

It is interesting that the new manual starts out with a ‘1.99’ version number. This would seem to indicate that there have been a large number of changes made in this new manual before it first saw the public light of day today. It would be interesting to know if there were policy changes proposed during the development process that were dropped for one reason or another. Too bad that kind of stuff seldom leaks.

Problems with New Manual

I only really have two minor issues with the latest version. The first deals with that name change thing. Now DHS can call these manuals anything that they want to. But it certainly looks like the change was done to avoid having to prepare an updated change history listing the changes that were made in this manual. On one hand there are significant organizational changes and it could be difficult to briefly describe those changes. But the lack of the change history makes it difficult to determine what has changed.

I have gone back and checked the two manuals against each other page by page, but it is entirely possible that I might have missed something. There were enough changes made in the order of information presentation that I may have missed some subtle changes. And there are few people in the industry who would even make the effort that I took this afternoon. A change history makes it easier to identify the differences and comply with the changes.

The second issue deals with one of the format changes made in the new manual. In the earlier version it was visually difficult to differentiate the text of the questions from the explanatory text. To give some help, the Top Screen question numbers were appended to the text of each question. The new manual physically separates the questions from the explanations in tabular form. It certainly makes it easier to distinguish the two.

Unfortunately, the question numbers are now gone (since they are not needed for clarity’s sake), but that makes it harder to track the questions in the actual Top Screen to the explanations in the manual. With a number of very similar questions found in different sections of the Top Screen, this will inevitably cause some confusion.

Positive Changes

Having started off this process with the picking of nits I have to admit that I really do think that this manual is better, easier to read and use than its predecessor. There is some stuff removed from the early sections dealing with the registration process and the roles of the various people involved in the CSAT process. But, as the new manual explains, those details are available in the CSAT User Registration User Guide. That information is really needed in the registration process not here.

In addition to abbreviating the introductory information the new manual provides a much more extensive table of contents. This allows for quick identification of the location of information that the Preparer and Submitter will need to complete the Top Screen.

The new visual layout of the pages and the tabular listing of Top Screen Questions paired with their explanation make it easier to find information on the page. Some of the screen shots in the new manual are smaller than the earlier version, but that only happens when the details on the page are less important for the explanation than the actual page layout.

Most of the wording from the earlier manual is simply cut-and-pasted into the new format. There were a couple of instances where I noticed that some clumsy wording in the original had been replaced with less confusing prose. There was only one place that I noticed that there was a significant change in the wording. During the discussion of what amounts of COI to count for release flammable COI an entire paragraph from the earlier manual was excised from this manual.

That excised material was a definition of ‘Tank Farms’ taken from the end of paragraph 5.2 on page 40 of the earlier manual. It didn’t really contribute much to the discussion in the new paragraph 7.2.1 on pages 50 and 51 of the new manual, but I was kind of surprised that it was removed. Filler material like that usually gets carried forward in cut-and-paste editing.

Missing Information

There is one important piece of information missing from the new manual that could confuse some new users of the system. There is no mention of the on-going agricultural facility ‘temporary’ exception to the Top Screen mandate. While one might assume that that is related to yesterday’s close of the Agriculture Survey, this information was also missing from the previous version of the manual.

It is also interesting that the two other web pages where the Top Screen User Manual is referenced (and linked) there is no mention of the change in manuals. The links on the CSAT Top-Screen page and the CFATS Knowledge Center page for this manual do link to the new manual simply because it retains the same URL as the old manual. The listing of the manual name is incorrect, but it is close enough that most people won’t get too confused.

Changing Manuals

If you have already completed your Top Screen submission, keep a copy of the version of the manual you used for that submission with your copy of the Top Screen. This way you can more readily understand why you made the decisions that were made in completing that submission. The subtle differences in the new wording might not lead to exactly the same conclusions.

It you have to submit a new Top Screen, down load the new version of the manual. Print it out and mark it up with your notes, questions and conclusions. It provides an excellent history of your compliance actions. But, do not print this out if you aren’t submitting a Top Screen any time soon. DHS is not bashful about updating their manuals with new information or better explanations. You always want to make sure that you are using the most up-to-date guidance available.

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