Sunday, November 21, 2010

DHS CFATS FAQ Update 11-19-10

On Friday afternoon the folks at DHS ISCD updated two of the Frequently Asked Questions (FAQ) listed in the CFATS Knowledge Center. There were no substantive changes in either response. The two questions updated were:

1661: What is the definition of A Commercial Grade (ACG) for the purposes of CFATS? Specifically, under Appendix A of the Chemical facility Anti-Terrorism Standards (CFATS), 6 CFR Part 27, if a chemical facility manufactures or otherwise possesses a Theft/Diversion or Sabotage chemical of interest (COI) but does not directly offer the chemical for commercial sale, does the facility need to count the chemical toward the applicable screening threshold quantity to determine if the facility must submit a Top-Screen to DHS?

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?
The only thing that makes it worthwhile to report this particular update of the FAQ list, beyond simply accounting for a change in the date of review of the response is the fact that these changes had no affect on the downloadable listing of all of the FAQs and Articles that I discussed in my blog on Wednesday.

If this FAQ dataset is going to be of any use to the public, DHS is going to have to update it every time they update a FAQ response (and when there is no substantive change like Friday’s update, that may be a waste of time and effort to also edit this very large .PDF file) or they are going to have to note the effective date of the dataset on the CFATS Knowledge Center web page.

In my earlier post I suggested that DHS should date the .PDF document to allow users to clearly understand which version of the dataset they had in their possession. This suggestion today is not the same thing. Because of the very large size of the file, and the length of time that it will take to download (and for someone on a limited speed internet connection it will take a VERY LONG TIME to download this, DHS needs to provide the effective date of the dataset to the user before the download begins.

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