Friday, April 28, 2017

ISCD Updates Three FAQ Responses

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) updated the response to three frequently asked questions (FAQ) on it CFATS Knowledge Center web site. One was a minor revision for clarification, but two were complete rewrites.

The revised responses were for the following FAQs:

FAQ #1272

This was the minor revision. It added the words “of interest” to make the first sentence of the response read:

“Whether a landlord or tenant is responsible for submitting a Top-Screen will depend on which party is responsible for security of the chemicals of interest.”

FAQ #1392

This was a complete re-write of a FAQ that was changed just last month. The new verbiage is much more succinct and the new response provides a link to the new CSAT 2.0 manual. Unfortunately, the link does not work. Somehow the words “Section 10” were inadvertently included in the link. The working link should be

Actually, the ‘Section 10’ reference is misleading. That section only discusses changing the Authorizer role. Changing (adding or deleting) the Submitter, Preparer, or Reviewer role is covered in Section 8 of the manual.

This FAQ is also being added back to the “All FAQs and Articles” .PDF document that can be downloaded at the bottom of the CFATS Knowledge Center. It stopped showing up in that document sometime after March 20th.

FAQ #1554

This rewrite takes a very short response and provides much more detail, including links to both the appropriate regulation and the new US Code section dealing with the issue. That US Code entry is important because it extended the enforcement authority of DHS to include the ability to sanction facilities that do not complete a required Top Screen. That authority had been overlooked in the original CFATS rule.

The new response also includes the new maximum daily penalty $33,333 that DHS can assess for a failing to comply with a compliance order. That amount was recently increased to reflect inflation and will be subject to periodic review and adjustment.

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