Thursday, March 30, 2017

ISCD Updates 15 CFATS FAQ Responses and Adds a New One

Today the DHS Infrastructure Security Compliance Division (ISCD) updated fifteen for frequently asked question (FAQ) responses on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center. It also added a new FAQ concerning recent DHS emails requesting new Top Screen submissions.


FAQ #1441 was added to the CFATS Knowledge Center. It asks: “If a facility has not made any changes to its holdings of chemicals of interest (COI) as indicated on its most recent Top-Screen, and DHS previously determined the facility to not be high risk, why did the facility receive an email from DHS requesting that a new Top-Screen be completed?”

The response refers back to the Federal Register notice about the introduction of CSAT 2.0 and the new CFATS risk assessment methodology.

FAQ Revisions

The FAQ responses that were changed were:

There was one major response re-write, FAQ # 641. The dated original entry referred to dates and requirements that were only applicable at the start of the CFATS program. The new version reflects the on-going requirements to submit Top Screens for facilities not currently covered under the CFATS program as well as Top Screen renewal requirements for covered facilities.

One common change was the addition of links to 6 CFR 27, 6 USC 22 or some other federal regulation when the FAQ response includes reference to those publications. We see these changes in FAQ #1143, #1194, #1442, #1612, #1620, #1653, #1658, #1666, #1745 and #1751. I counted 22 other FAQ responses that included similar references where regulatory links could be added. It will be interesting to see if ISCD updates those FAQ responses as well.

Another common change was to change wording to FAQ responses reflecting the CSAT 2.0 change to submit a combined Security Vulnerability Assessment (SVA) and Site Security Plan (SSP), or as it is now called SVA/SSP. This change was made in FAQ responses #1628, #1634, #1650, #1653, and #1660.

One truly inconsequential change was made to the response to FAQ #1562. It added “(STQ)” following the words “Screening Threshold Quantity” in the second paragraph of the response.

Finally, one FAQ response (#1238) was corrected to properly reflect the original publication date.

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