Tuesday, August 15, 2017

ISCD Updates CFATS Knowledge Center

Today the DHS Infrastructure Security Compliance Division (ISCD) updated the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center by adding a link to a new CFATS fact sheet for colleges and universities and revised four frequently asked questions (FAQ) (according to the ‘Latest News’ blurb posted today on the Knowledge Center).

Colleges and Universities

The Colleges and Universities brochure is an update of a tri-fold brochure that was originally published in December 2010. The new brochure provides a brief overview of the CFATS program including a very brief description of the Top Screen reporting requirements. There is more detail in the new version and provides a number of important links to CFATS documents.

The one major shortcoming of the brochure is that, while it briefly describes chemicals of interest (COI) categories and explains that the list can be found in ‘Appendix A of the CFATS regulation’ there is no link to list of COI that is provided on the CFATS landing page, nor are the CFATS regulations actually listed (6 CFR 27).

New FAQs

The four ‘revised’ FAQ’s are:

The revised #1274 removes the mailing address [Infrastructure Security Compliance Division, Office of Infrastructure Protection, ATTN: CSAT, Department of Homeland Security, Building 5300, MS 6282, PO Box 2008, Oak Ridge, TN 37831-6282] and the messenger service delivery address [Infrastructure Security Compliance Division, Office of Infrastructure Protection, ATTN: CSAT, Department of Homeland Security, Building 5300, MS 6282, 1 Bethel Valley Road, Oak Ridge, TN 37831-6282] from the modes of contact for the CFATS Help Desk. I have no idea whether or not those old addresses are still good; but if they are, ISCD does not apparently want them used.

The revised #1288 adds regulatory references [§27.203(b) and §27.204(a)(2)] for the answer and a link to just the first reference. I have provided the link to the second.

FAQ #1606 is actually a new FAQ number, but the question and answer are very similar to an older FAQ (#1662) which is no longer on the current FAQ list (.PDF download). The new FAQ does not include any information (which was included in #1662) about a requirement to be CVI (Chemical-terrorism Vulnerability Information – the protocol for protecting the sensitive but unclassified information associated with the CFATS program) trained to be able to view/download the letter. Nor does the new FAQ mention that an Adobe Reader will be necessary to open the letter. NOTE: #1662 was still on the current FAQ list as of 8-4-17; the last time changes were made to the FAQ list.

FAQ #1785 is also a new FAQ number. There was an earlier article on the CFATS Knowledge Center (#1610) that addressed some of this information, but that article was prepared in 2010 and included copious descriptions of the old tiering process that was supplanted by CSAT 2.0 and the new Risk Assessment process. That article was removed sometime in early April of this year. The new FAQ very briefly mentions the tiering process and notes that facilities will be notified via the Chemical Security Assessment Tool (CSAT) that a tiering notification letter is available. It then briefly describes how to access that notification letter; and this time that discussion does include a mention of the CVI training requirements.

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