Wednesday, September 30, 2020

ISCD Update 8 FAQ Responses – 9-29-20

Yesterday the CISA Infrastructure Security Compliance Division (ISCD) updated the responses to eight frequently asked questions (FAQs) on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center web page. None of the changes were substantive nor did they reflect policy changes.

The following FAQ responses were revised:

FAQ #1557 What should a facility do if it believes the risk-based tier determination that the Cybersecurity and Infrastructure Security Agency (CISA) has assigned it no longer reflects the actual security risk posed to the facility?

FAQ #1579 How does a facility define itself if it has multiple buildings, yet only a few select buildings possess chemicals of interest (COI) that are subject to being regulated by the Chemical Facility Anti-Terrorism Standards (CFATS) regulation?

FAQ #1612 What type of nitrocellulose is reportable as a chemical of interest (COI)?

FAQ #1735 How can a corporation with multiple facilities regulated under the Chemical Facility Anti-Terrorism Standards (CFATS) request the corporate approach and what benefits does this provide the corporation?

FAQ #1754 Does a facility have to report temporary holdings of chemicals of interest (COI) at or above the screening threshold quantity (STQ)?

FAQ #1765 What does a facility need to do to comply with the Chemical Facility Anti-Terrorism Standards (CFATS) Personnel Surety Program (PSP) requirements that are in effect now that the program has been implemented?

FAQ #1787 How have covered chemical facilities generally complied with 6 CFR § 27.230(a)(12)(iii), which requires facilities to verify an affected individual is legally authorized to work?

FAQ #1793 When does a covered facility under the Chemical Facility Anti-Terrorism Standards (CFATS) program need to submit a revised or updated Top-Screen?

NOTE: The links provided for the FAQs in this post were copied from the CFATS Knowledge Center but may not work when followed from your machine. This is an artifact of that web site. If the links do not take you to the referenced FAQ you will have to use the ‘Advanced Search’ function on the page to link to the FAQ or download the ‘All FAQs’ document at the bottom of the ‘Advanced Search’ page.

The following changes were made in the referenced responses:

#1557 Corrected typography error is question.

#1579 Editorial corrections and removes reference to CFATS final rule.

#1612 Replaces URLs with reference links.

#1735 Makes two paragraphs out of first paragraph.

#1754 Provides links to references and adds paragraph discussing fluctuating inventories.

#1765 Updated response to reflect the addition of Tier III and Tier IV facilities to Personnel Surety Program.

#1787 Replaces URLs with reference links.

#1793 Replaced ‘DHS’ with ‘CISA’ and removed red highlighting from last paragraph.

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