Saturday, February 15, 2020

ISCD Publishes Hatchery Advisory Opinion

This week the DHS Infrastructure Security Compliance Division (ISCD) published their 5th advisory opinion. This one deals with fish hatcheries and the ‘temporary’ agricultural exemption for filing a Top Screen. The Opinion actually dates back to 2015 when ISCD addressed this issue in response to a letter from the California Department of Fish and Wildlife.

In short, ISCD has taken the position that fish hatcheries are not ‘agricultural facilities’ in the meaning used in their exemption (73 FR 1640). This means that fish hatcheries possessing DHS chemicals of interest (COI) at or above the screening threshold quantity are required to complete a Top Screen. ISCD tangentially addressed this issue back in December 2017 when they published “Protect Your Fishery and Hatchery Chemicals from Use in a Terrorist Attack”.

I would assume that someone has recently raised this issue and that ISCD felt it was now necessary to publicly address it by publishing this Advisory Opinion.

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