Tuesday, September 13, 2011

More on New CSAT Registration Manual

As I noted last week DHS has published a new version of their CSAT User Registration User Guide. I’ve now had a chance to look at the new manual and compare it to the previous version. There have been some interesting changes.

New Version Number

As you would expect the latest version has a different version number; Version 5.0. The confusing thing is that the latest version that I had in my files was Version 2.0a. I would have thought that there should have been a ‘3.0’ and a ‘4.0’ before we got to this new ‘5.0’ version. Since there is no management of change documentation included in this new version I can’t tell for sure if I maybe missed a couple of versions.

The date for the ‘2.0a’ version that I am comparing this new version to is April 2008 which was apparently published on the CSAT web site on May 8th. The current CSAT web site notes that the ‘current’ version of the manual dates from July 2008. So, there may have been at least one other version that I have missed.

It would be nice if DHS published a notice when they update their various CFATS manuals.

Lead Preparer

When the SSP tool was introduced a couple of years ago it quickly became obvious that many facilities were going to be using multiple preparers to input the information into that very lengthy on-line questionnaire. In this Registration Manual it doesn’t specifically mention that multiple preparers are authorized, but it does include a separate position of ‘Lead Preparer’. This would be the individual that is designated to turn completed documents over to the ‘Submitter’ for final review before submission.

All facilities are required to designate a ‘Lead Preparer’. The Lead Preparer can be the same person as the Submitter or Authorizer for the facility. A consultant can be designated as the Lead Preparer for a facility.

Position Pre-requisites

The new manual no longer has a detailed listing of pre-requisites that personnel meeting the various roles must meet. In the old manual the Submitter, for instance, was required to be either an officer of the corporation or designated by an officer and had to be “domiciled in the United States” (pg 21). The only restriction on selection of a Submitter listed in the new manual is that consultants “hired by a Facility to assist with the CSAT data collection process may not act as Facility Submitters” (pg 4).

The new manual does note that the following questions will be asked about Submitters and Authorizers, but it doesn’t specifically note that these are pre-requisites.

• Is the individual a U.S. Citizen?

• Is the individual an Officer of the Corporation or designated by an Officer of the Corporation?

• Is the individual domiciled in the U.S.?

The first and last questions listed above will also be asked about Preparers and Reviewers.

Bulk Uploads

The new manual indicates that DHS has made provisions for organizations that have a large number of facilities that must be registered. DHS has developed a spread sheet that can be used for uploading registration data for organizations with “50 or more Facilities” (page 12). For further information on this program contact the CSAT Help Desk.

Other Changes

I don’t see any other substantive changes in the manual but there are numerous changes in format and layout of the manual.

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