Today, CISA’s Office of Chemical Security (OCS) published an updated responses to a FAQ on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center. The revised FAQ responses were for FAQ #1275. This is the same FAQ that was ‘updated’ yesterday. Yesterday’s non-update is no longer listed.
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.
For the most part the changes in the response are wording changes that clarify the status of the ‘buyer’ and ‘seller’ {for example changing the word ‘buyer’ to ‘new owner/operator (buyer)’ in the initial discussion for Option 1}.
A slightly more complex change is made in the discussion of the requirements for Option 1. It changes the sentence:
“The buyer should explain that his organization is willing to assume the ID and take responsibility for the submitted and the future surveys and should explicitly document that the COI holdings and facility operations will remain the same.”
To read:
“The buyer should explain that the new organization is willing to assume the existing ID and take responsibility for surveys submitted by the seller. The buyer should explicitly document that the COI holdings and facility operations remain the same or submit a new survey if the buyer intends to make material modifications to its operations or site.”
Finally, a new sentence is added to the end of that discussion:
“If the buyer is unable to obtain a
letter and/or contact information from the seller, then the buyer should
include a statement in their letter accounting for this.”
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