Friday, October 14, 2016

ISCD Updates Top Screen – CVI FAQ

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) updated their response to one of their frequently asked questions (FAQ) on the CFATS Knowledge Center page. The latest update to FAQ # 1586 was a change in the URL for the Chemical Vulnerability Information (CVI) training page. That minor change is the reason that there was no new ‘Latest News’ entry for this FAQ response revision.

Change in CVI Training Requirements

The real news for this FAQ should have been a discussion when it was last revised last February. The FAQ originally (published in May 2009) described the CVI Authorizing Statement that was part of the initial sign on to the Top Screen page. That Statement was the abbreviated CVI training that was required for the Top Screen; full CVI training was not required until the facility received their initial notification letter that, as a result of the review of their Top Screen, they had been designated a covered facility under the Chemical Facility Anti-Terrorism Standards (CFATS) program.

The new Chemical Security Assessment Tool (CSAT) Portal User Manual (issued as part of the CSAT 2.0 rollout) makes it clear that completion of the CVI training is required before CSAT registration can be completed. The old manual (published in 2009) did not even mention CVI, much less require CVI training before registration. Apparently, sometime between 2009 and February of this year when FAQ #1586 was last updated, there was a change in the registration process that required CVI training before the Top Screen could be completed.

CVI-CSAT Linkage

Another interesting thing is found in a note at the bottom of the response to FAQ #1586:

“Note: The email address associated with the CVI Authorized User training record must match the email address associated with the CSAT User Account in order to complete synchronization between the user’s CVI and CSAT accounts.”

This is not mentioned in the new CSAT Portal User Manual.

This could cause some problems for people who completed their CVI training before they started work at the organization for which they are requesting CSAT access. For example, I completed my CVI training in 2007 using my personal email account. Since most organizations frown on (or outright prohibit) using personal rather than corporate email accounts for conducting company business, it looks like I would have to re-do my CVI training using a new corporate email address prior to registering as a CSAT user in a new company.

It is possible that a call to the CFATS Help Desk {(866) 323-2957} could resolve the problem if it arises.

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