ISCD Updates 2 FAQ Responses – 9-9-20

Today the CISA Infrastructure Security Compliance Division (ISCD) updated the responses to two frequently asked questions (FAQs) on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center. Most of the changes are non-substantive editorial changes, but there is a new link to a relatively new CSAT web page.

Updated FAQ

The following FAQ responses were revised today:

FAQ # 387 What if my facility will be adding a chemical of interest (COI) in the future?

FAQ #1143 What is required of co-located facilities regarding the Chemical Facility Anti-Terrorism Standards (CFATS)? Do both companies need to submit a Top-Screen and Security Vulnerability Assessment (SVA)/Site Security Plan (SSP)? Is it possible for the embedded facility to share the Top-Screen and SVA/SSP with the host company? If this is possible, what would be required by both companies to accomplish this and be compliant under 6 CFR Part 27?

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 FAQs:

#387 Adds link to new CSAT Top Screen Submissions Tips page,

#1143 Changed URLS to document links

Top Screen Submission Tips Page

According to the date on the web page it was originally published this last May, but this is the first time I have seen the page. The CFATS web site is huge and ISCD does not do a good job of communicating changes to the site.

This page begins with a brief overview of the purpose of the Top Screen. It then goes on to look at five major topics:

• Resubmissions for material modifications,

• Business operations: predictive top-screen filing,

• Business planning: hypothetical top-screen filing,

• Regular resubmissions, and

• Facility closures

I followed all of the links on the page and found that the following two pages had been updated since this new page was published:

Chemical Security Assessment Tool (CSAT) Top-Screen,

CFATS Covered Facilities and Inspections

I do not see any major changes to those pages.