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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