Thursday, August 2, 2018

ISCD Updates FAQ Response – 08-02-18


Today the DHS Infrastructure Security Compliance Division (ISCD) updated the response to one of the frequently asked questions (FAQ) on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center. The FAQ in question is #1398; “ Are Chemicals of Interest (COI) in hazardous waste to be counted towards a Screening Threshold Quantity (STQ)?” There was no notice given on the site that this FAQ had been updated.

I cannot find any substantive difference between the two versions of the FAQ response and this is not unusual when no notice is provided. Some time the differences are very hard to find. What I think may have happened here, though, is that ISCD noticed (or someone complained) that the link to the EPA document provided in the response takes you to the EPA hazardous waste landing page, not the listed .PDF document. This is probably because of recent changes to the EPA web site.

After some pretty extensive searching of the EPA sites (and the EPA sites are very difficult to search), I think I found the document in question on the EPA Archive web site: https://archive.epa.gov/epawaste/hazard/web/pdf/listing-ref.pdf.

This is not the first time that ISCD has had problems with links to EPA web sites in its FAQ responses. The federal government does not do a good job of maintaining their web sites and communicating changes made to those sites to interested parties. To be fair, I do not think that anything short of a web site AI could keep track of all of the changes made to this information monstrosity.

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