Today the folks at the DHS Infrastructure Security
Compliance Division (ISCD) updated a response to a frequently asked question
(FAQ) and published a new FAQ on their Chemical Facility Anti-Terrorism Standards
(CFATS) Knowledge Center. Both FAQ’s
deal with the submission of Top Screen reports.
Actually, what ISCD did was to separate the response to the
original FAQ #641 into two cases. The first case deals with initial Top Screen
submissions; that remained in #641. The requirements for facilities already in
the CFATS program to resubmit a Top Screen were put into the new FAQ #1793.
Interestingly, there is one Top Screen submission situation
that has not been addressed in any of the FAQ’s to date. If a facility submits
a Top Screen and is notified by DHS that it is not a covered facility, does the
facility have to submit another Top Screen when it acquires a new DHS chemical
of interest (COI) in quantities above the Screening Threshold Quantity, or the
originally reported COI at a higher inventory level?
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