ISCD Publishes COI Flyer for CFATS Customers

Today the DHS Infrastructure Security Compliance Division published a new flyer for its Chemical Facility Anti-Terrorism Standards (CFATS) program. They flyer is designed to be provided to customers of CFATS facilities that receive shipments of DHS chemicals of interest (COI) from the covered facility to notify those customers that they might have CFATS reporting responsibilities.

A link to the flyer can be found on the CFATS landing page. There, ISCD explains the purpose of the flyer:

“Update (July 2017): Chemical security is a responsibility that DHS shares with chemical facility owners and operators, employees, and emergency responders. DHS created a flyer for facilities shipping, selling, or distributing a CFATS Chemical of Interest (COI) to notify their customers to report their chemical holdings to DHS. Please download, print, and distribute the Receiving a COI Flyer as a resource to increase awareness of the CFATS program to new segments of the population who hold COI.”

A different link to the same flyer can be found on the CFATS Knowledge Center. ISCD announces that link with this ‘Latest News’ entry:

“ISCD has published a flyer that facilities may choose to use when selling or shipping COI to notify customers that they may need to report their holdings to DHS. Facilities are not required to share this flyer, but are encouraged to let facilities that sell, ship, or distribute COI know about this resource during the course of a normal engagement. Please contact CFATS@hq.dhs.gov with any and all questions.”

ISCD emphasizes that the use of the flyer is completely voluntary. They are just trying to expand their outreach program to ensure that all potentially covered facilities are aware of the reporting requirements for the CFATS program.

Commentary

This is a fairly straightforward one-page flyer without a lot of graphics or bells and whistles. I think, however, that ISCD has gone a little too much on the simple side. Much of the write-up assumes that the reader has some basic understanding of the ins and outs of the CFATS program. For example, in bold type (for emphasis) the flyer states: “Facilities that come into possession of screening threshold quantities of COI must report their holdings to DHS within 60 days by filing a Top-Screen survey.” There is no real explanation of why chemicals are COI or what a ‘screening threshold quantity’ is, it simply provides a link to the Appendix A table that lists the COI’s and the complex set of regulatory data that are associated with them in the CFATS program.

It would have been much more helpful if the flyer provided links to the various parts of the CFATS web site that describe these complex topics; for example, the CFATS Covered Facility web page.

Still, I am glad to see that ISCD is continuing to look for new ways to ensure that potentially covered facilities are aware of the CFATS initial reporting requirements.