New CFATS Top Screen Coming

Late Friday afternoon I received notification from DHS Infrastructure Security Compliance Division (ISCD) that they were holding a meeting on Tuesday, February 9^th, 2016, at 1:00 pm EST. The meeting is entitled: “Chemical Security Assessment Tool (CSAT) Top-Screen Industry Demonstration”. It is too late to register for physically attending the meeting but it will be web cast on HSIN.

HSIN Registration

The registration for the web cast is done here. Now HSIN has a number of different levels of access. Fully public webinars usually allow signing in as ‘Guest’; that is not the case here. You have to have (or register for) an HSIN log on. I have one from a number of years ago and I can’t remember if it required DHS sponsorship (approval) or not.

Now I am pretty sure that registered CSAT users have received the same notification that I did; certainly facility security officers and submitters were notified.

Why Top Screen

There is nothing in the notification that I received that provides any specific information about what changes have been made or why. I do know that ISCD, at congressional behest, has been working on updating their risk assessment process by which they determine which facilities that submit a Top Screen are to be covered by the CFATS program. I would expect that changes to the Top Screen would be necessary to support that new risk analysis process.

There are a couple of other possible program changes that might be in the works that could also result in changes in the Top Screen. I don’t know if any of these are actually going to be put into place and certainly don’t know if they are included in this upgrade. These are just things that have been under discussion.

First, from an industry perspective, is the petition from the International Liquid Terminal Association (ITLA) that was filed back in 2009 (and re-submitted with the Appendix A RFI). The ITLA wanted above ground gasoline storage tanks exempted from Top Screen submissions. They have repeatedly made the point that the risk of off-site consequences from a fuel tank fire is too low to make them a real terrorist target. I have seen nothing that indicates that ISCD has changed their stance on this topic, but it is possible.

Another possibility is that ISCD could, in some way, incorporate the temporary agriculture exemption to Top Screen submission that was published in December 2007. Since agricultural producers are typically in relatively isolated locations, off-site consequences of releases of agricultural chemicals on the DHS chemicals of interest (COI) list are going to be relatively low. Theft-Diversion chemicals are not typically stored for any length of time on these facilities so their risk would also be relatively low. Again, there has been no specific indication that this change would be made, but it could be possible.

Recently there were changes in the EPA’s RMP*Comp program that were apparently driven (at least in part) by changes in chlorine gas dispersion modeling. I am not sure if these require any changes to the CFATS Top Screen, but there is a possibility.

Moving Forward

I am trying to find out more information about the Top Screen changes that may be included, but I’m pretty sure that I won’t be told (or maybe be allowed to share) any information until the webinar. I will probably try to TWEET® comments about the webinar (using #TopScreen hashtag). I certainly expect to have at least one tweet about the meeting and probably more on the Top Screen change details in subsequent posts (depending on the complexity of the change).

If anyone has additional information that they can share feel free to post as a comment to this post or contact me directly.