Today the DHS Infrastructure Security Compliance Division
(ISCD) updated the response to a frequently asked question (FAQ) on the CFATS
Knowledge Center. The updated response was for FAQ # 1275; What
needs to be done when a facility is bought or sold?
There was no substantive change to the requirements
associated with the change in ownership. The change simply removed the
Chemical-Terrorism Vulnerability Information (CVI) disclosure statement at the
end of the response. That statement used to read:
“CVI Disclosure If any
letters submitted to DHS for review contain any CVI information, the letter
must be properly marked, packaged, and sent in accordance with the CFATS
regulations for protection of CVI (see 6 CFR § 27.400). A copy of the CFATS
regulation, including the CVI requirements in 6 CFR § 27.400, is available at https://www.dhs.gov/critical-infrastructure-chemical-security.”
It is not clear why the statement was removed. While one
would like to assume that anyone associated with the CFATS program would
understand the CVI requirements for identifying and sending CVI protected
information, the whole purpose of FAQ responses is to communicate information
in a new format to ensure that the affected parties understand all of the
requirements.
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