ISCD Updates Two FAQs

Today the DHS Infrastructure Security Compliance Division (ISCD) updated the responses to two frequently asked questions (FAQ) on their Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center page. The changes were not substantial and did not reflect any changes in policy or procedure.

The two FAQ responses that were changed are:

FAQ #1374 Does Phosphorus, which is part of a polymer, need to be counted toward the STQ? They are buying the polymer which contains the phosphorus.

FAQ #1756 What action is required if a facility needs to change owner and/or operator names when it is not related to a transfer of ownership?

Actually, I cannot see any changes in the response to FAQ #1374. The only change that I see in the response to FAQ #1756 is the addressee on the letter to be sent to ISCD. The previous version of this response had the letter addressed to “David Wulf, Director” and the new addressee is “Amy Graydon, Acting Director”.

This is not the result of some shake-up at ISCD. Back in January when the new Administration took office, the political appointees were required to submit their resignations. Pending new appointments by President Trump, various senior professional staff of the Department were bumped up in acting positions so that the management structure of the Department would be able to continue in force. David Wulf was jumped up to Acting Deputy Assistant Secretary for Infrastructure Protection, DHS and Amy was bumped up to temporarily fill his Director Position. Presumably at some point in the near future after the nomination and approval process is finally complete, all of these folks will revert back to the normal positions. This routinely happens when, for whatever reason, political appointees leave and are not immediately replaced.

I personally do not really understand why DHS includes personnel names in these official addresses. In the military they used the title of the person (ie: Commander) and the local clerks were smart enough to get the letter to the correct person. Personal mail got sent to a person’s name and official mail got sent to the office.