CFATS Knowledge Center and FAQ Update 11-29-10

This morning DHS ISCD updated their CFATS Knowledge Center web page with a new item under the ‘Latest News’ heading and adding four new FAQ questions and responses. The news items is specifically directed at refineries and LNG facilities. The four new questions are, for the most part, predictable questions concerning the SSP Edit process.

The news item deals with the actual Top-Screen tool and does not appear to necessitate a change to the Top-Screen manuals nor the Top Screen web page. Nor does it require any new Top-Screen submissions. The news item reads:

“Attention refinery and LNG facilities: the Chemical Security Assessment Tool (CSAT) Top-Screen tool has recently been enhanced to make it easier for such facilities to enter information about Theft/Diversion chemicals of interest (COI). DHS is aware that some refinery and liquefied natural gas (LNG) facilities previously encountered some difficulty using the prior version of the CSAT Top-Screen tool to locate questions related to Theft/Diversion COI. This enhancement to the Top-Screen tool does not change those questions but will enable refinery and LNFG facilities to find and answer those questions more easily in any future Top-Screen submissions.”

The four new FAQs are:

● 1714: What administrative edits can be made to a submitted Site Security Plan (SSP)?
● 1715: What technical edits can be made to a submitted Site Security Plan (SSP)?
● 1716: How frequently can I make a change to a submitted Site Security Plan (SSP)?
● 1717: I started to edit a submitted SSP to make a technical (or administrative) change and realized the previously submitted SSP does not need revision. What should I do?

DHS Directed Edits

The only new information provided in the FAQ is found at the end of the response to FAQ # 1717. There it says: “DHS-initiated SSP survey edits may NOT be deleted at the facility’s request.” I cannot find any mention of ‘DHS-initiated SSP survey edits; in the CSAT SSP Edit Process User Guide. I would suppose that these edits could technically fall into either the administrative or technical edit categories, but I would not expect that they would apply to the limit on the frequency of technical edits. I am certain that DHS will notify facilities about such directed edits and that the notification would include instructions on how to complete the edit.

I will see if I can get some additional information on these directed edits.