ISCD Publishes New Top Screen Instructions

Today the DHS Infrastructure Security Compliance Division (ISCD) updated the Top Screen web page for the Chemical Facility Anti-Terrorism (CFATS) program. That new web page includes a link to the new Top Screen Instruction Manual.

The old web site contained links to two different Top Screen manuals; a Questions Guide and a User Guide. A brief look at the new manual published today makes it look like ISCD has combined the two manuals. Links to the old manuals have been removed from the CFATS Knowledge Center documentation list and the link to the new manual has been added. Links to the old Top Screen Question and Top Screen User Guide are still working as of 9:00 pm EDT, 9-1-16.

COI Calculations

The new manual has been completely reformatted and is much easier to read and follow. In addition to a brief description of how to answer each of the questions that could appear on the Top Screen, the new manual includes three appendices that are supposed to provide information on how to calculate:

• The amounts of each chemical of interest (COI) that should be excluded from screening threshold quantity (STQ) calculations;

• The amounts of each COI that should be included in STQ calculations; and

• The minimum concentrations to be included in STQ calculations.

Those instructions are actually quotes from the CFATS regulations describing those calculations. No additional explanations or clarifications have been provided.

Moving Forward

The web site changes today do not include any indications that the new Top Screen tool is live. The new Top Screen page still includes the note that the Top Screen submission requirements have been suspended. I expect that we will see a formal, Federal Register notice when the Top Screen requirement is re-instated. It is possible, however, that individual facilities may receive direct notification from DHS that they need to submit a new Top Screen before the notice is published in the Federal Register.

There will be additional blog posts concerning specific questions and required responses that are included in the new Top Screen.