The DHS Infrastructure Security Compliance Division (ISCD)
has been busy over the last week or so making changes to their extensive
Chemical Facility Anti-Terrorism Standards (CFATS) web site. These changes
include:
• Updating two Chemical Security
Assessment Tool (CSAT) user manuals;
• Publishing two new program fact
sheets;
• Updating a third fact sheet; and
• Updating various web pages to point out the above
changes.
Updated Manuals
On November 3rd, ISCD updated the CSAT Top Screen page to include
a link to the newest version of the Top
Screen Instructions. Yesterday the CFATS landing page revision included a
link to the newest version of the CSAT
Survey Application User Manual. Both manuals now have a publication date of
October 31st, 2017.
Long ago (regulatorily speaking) ISCD (or maybe DHS?)
stopped putting revision notes in their manuals. The latest version of these
two manuals now remove version numbers. This means that the average user has no
idea about the scale, extent or details about the changes made to these
manuals.
Closely looking at the 5-page Table of Contents for the
Application manual I do not see any changes between this latest version and the
March 29th, 2017 version. A similar check of the Top Screen manuals
also reveals no changes on their Table of Contents (the earlier version here
was also dated March 29th). Unfortunately, I do not have time to do
a line-by-line check to see exactly what changes have been made. I suppose that
we just have to assume (there is an old military saying about that; something
about ‘making an ass out of you and me’) that ISCD is continuing their CSAT 2.0
manual tradition of just making minor, clarifying word-changes to their
manuals.
New Fact Sheets
On November 3rd, ISCD updated their Top Screen web page to include a
link to a new
fact sheet concerning the “temporary time extension” for farmers needing to
submit a Top Screen because they possess DHS chemicals of interest (COI) in
quantities above the screening threshold quantity (STQ). That ‘time extension’
was granted
in 2008, briefly looked
at again in 2010, but it is still in effect for apparently an indefinite
future.
Typically, these ISCD fact sheets are simply documents that
can be circulated summarizing information that is readily available elsewhere
on the CFATS web site. That is not the case with this fact sheet. It provides
an interesting list of chemical uses by agricultural organizations that do not
qualify for the ‘extension’; in other words, agricultural facilities using COI
in these cases in quantities that exceed the STQ have 60 days to submit a Top
Screen. Those exemptions include:
· If a facility uses a COI
for fuel, storage, or distribution purposes.
· If a commercial
application service is using COI for distribution.
· If the facility is a
fishery and/or hatchery, as fish are not considered livestock.
· If an agricultural
facility stores and/or distributes a COI.
· If a park uses chlorine
for an onsite pool.
· If an agricultural
facility uses propane for heating.
· If a facility uses
chlorine, hydrogen peroxide, or sulfur dioxide for the cleaning and treatment
of equipment and products, such as at wineries, breweries, or food
manufacturers.
· If a facility utilizes
phosphine or other COI for fumigation purposes.
Most of these exceptions seem to be a reasonable set of COI
uses that are not specifically covered under the 2008 letter, though I can see
lawyers having fun with the fumigation example. I would bet, however, that a
significant number of agricultural facilities will look at this list with
dismay. If they see it; it was not prominently mentioned on the CFATS web site.
Perhaps ISCD is directly sharing the fact sheet with the agricultural
community; I hope so.
Yesterday ISCD provided links to another new fact sheet on
the CFATS landing page, the Top Screen page and the CFATS Knowledge Center. This fact sheet
outlines the fact that nitromethane is a DHS chemical of interest and thus
requires reporting when it is held in quantities in excess of 400-lbs (in
transportation packaging since it is a theft/diversion COI; not mentioned in
the fact sheet). This is a more typical ISCD fact sheet with no really new
information.
I would assume that ISCD has concluded that there are a
significant number of folks holding STQ quantities of nitromethane (in the
racing world in particular since it is frequently used as a fuel additive in
that realm) and have not reported that fact on a Top Screen. Again, those folks
are not going to be visiting the CFATS web site, so I would expect the ISCD
outreach efforts would include making this fact sheet visible in appropriate
places.
Updated Fact Sheet
Yesterday’s update of the CFATS landing page also included a
link (without fanfare or notice) to a revised version of the CFATS
Fact Sheet (now called the CFATS Overview to distinguish it from the
monthly updates). This is a complete rewrite of the original
version that was published in October 2016.
The new version provides more details (and more links) about
the CFATS program, but there is still nothing new here that folks familiar with
the program (or this blog) have not heard or read dozens of times. Still it is
a good outreach document and deserves wide dissemination.
BTW: Both the CFATS landing page and the CFATS Knowledge
Center now have links to the November 2017 CFATS update that I discussed
earlier.
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