OCS Publishes Updated FAQ Responses – 2-28-23

Today, CISA’s Office of Chemical Security (OCS) published an updated response a FAQs on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center. The revised FAQ response was for FAQ #1275.

FAQ #1275 What needs to be done with the facility ID in the Chemical Security Assessment Tool (CSAT) when a covered chemical facility is bought or sold?

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.

I cannot find any difference between this new version and the version that was updated on February 17^th, 2023.

NOTE: Corrected date in Title, 06:26 EST 3-1-23

NOTE: Corrected cut/paste errors in first paragraph, 22:07 EST 3-1-23

ISCD Updates FAQs on CFATS Knowledge Center – 05-11-16

This afternoon the DHS Infrastructure Security Compliance Division (ISCD) updated the responses to 12 Frequently Asked Questions (FAQ) on the CFATS Knowledge Center. A quick check of each of the FAQ responses indicates the ISCD is updating URLs for a number of their web sites. The revised FAQs and the affected URLs are shown below.

#1275 What needs to be done when a facility is bought or sold? Corrected URL for chemical security landing page.

#1405 How will I know the agricultural extension has been lifted and what to do next? Corrected URL for chemical security landing page.

#1407 I recently received an e-mail from DHS informing me that my Top-Screen appears to be inactive because it was begun over 60 days ago and has still not been submitted. What should I do? Corrected URL for CSAT Web Portal.

#1450 What is the URL to the CSAT Web Portal? Corrected URL for CSAT Web Portal.

#1485 What do I need to have available in order to complete Top Screen? Corrected URL for chemical security landing page.

#1551 Can individuals who are not US Citizens be CVI Authorized Users? Corrected URL for CVI training.

#1557 What should I do if I think my facility was incorrectly determined to be high-risk or received an incorrect preliminary risk-based tier determination?  Corrected URL for chemical security landing page.

#1606 I recently received an e-mail telling me there is a CSAT letter available for me to access and print. How do I go about accessing this letter? Corrected URL for CSAT Web Portal and CVI training.

#1618 How do I access and acknowledge CSAT letters (for example, my facility's tiering letter)? Corrected URL for CSAT Web Portal and CVI training.

#1654 Would disapproval of an SSP and/or receipt of a guidance letter from DHS be a good time to ask for inspector assistance? Corrected URL for chemical security landing page.

#1662 I have received an email notification that a CSAT Letter is available for viewing. How do I access this letter? Corrected URL for CSAT Web Portal and CVI training.

#1756 What action is required if a facility needs to change owner and/or operator names when it is not related to a transfer of ownership? Corrected URL for chemical security landing page.

The CVI Training landing page was also updated today to show the new URL for the actual CVI Training program.

NOTE 1: The old URLs are still linking to the correct pages. No telling when DHS will cut-off the old URLs.

NOTE 2: There are currently some difficulties connecting to the CSAT Web Portal and the CVI Training Program. I expect that they will both be working tomorrow.

ISCD Updates a CVI FAQ Response

Today the folks at DHS Infrastructure Security Compliance Division (ISCD) updated one of the frequently asked question (FAQ) responses on the CFATS Knowledge Center web site. It was a relatively minor change to the response to FAQ #516 dealing with the on-line training program for the Chemical-terrorism Vulnerability Information (CVI) program.

The latest revision to that FAQ response in December failed to include the “https:” in the description of the link to the CVI training web site. The older link worked perfectly well, but without the “https:” the reader did not know to expect that it was a secure website. Neither link accurately reflects the actual destination of the link which is https://csat.dhs.gov/dana/home/index.cgi.

BTW: While this change is relatively minor it does continue an apparent change in policy on the CFATS Knowledge Center of not announcing changes or additions to FAQs. This has apparently been in effect since December.

ISCD Updates CFATS Knowledge Center – Minor FAQ Correction

Yesterday the folks running the CFATS Knowledge Center updated one of the responses to a frequently asked question (FAQ). It was a minor correction (removing an inappropriate ‘mail to’ link from FAQ #1544), but it does show a willingness to keep the minor details straight. There’s no telling how the discovered the error and it is on a question that is not probably accessed that often any longer (it deals with CSAT registration issues), but good quality control does required the correction of even seemingly inconsequential mistakes.

CFATS FAQ Update 06-30-11

Earlier today the folks that take care of the CFATS Knowledge Center web site updated one of the frequently asked questions listed on that site. It was a minor change to the response to FAQ # 1445 that was last updated in May, 2009. The change corrected a typo, substituting ‘DHS’ for ‘SHA’. This type of attention to detail reflects positively on the folks that take care of this valuable web site.

A similar attention to detail resulted in the link to the SSP Questions Manual found in the ‘Documents’ section of the CFATS Knowledge Center taking a surfer to the new manual even though there is no mention of the new manual in the ‘News’ section of that page. The updated link is attention to detail while the lack of a mention or explanation about the release of the new manual is either a questionable editorial decision or a communications oversight on the part of management.

CFATS Knowledge Center and FAQ Update 11-29-10

This morning DHS ISCD updated their CFATS Knowledge Center web page with a new item under the ‘Latest News’ heading and adding four new FAQ questions and responses. The news items is specifically directed at refineries and LNG facilities. The four new questions are, for the most part, predictable questions concerning the SSP Edit process.

The news item deals with the actual Top-Screen tool and does not appear to necessitate a change to the Top-Screen manuals nor the Top Screen web page. Nor does it require any new Top-Screen submissions. The news item reads:

“Attention refinery and LNG facilities: the Chemical Security Assessment Tool (CSAT) Top-Screen tool has recently been enhanced to make it easier for such facilities to enter information about Theft/Diversion chemicals of interest (COI). DHS is aware that some refinery and liquefied natural gas (LNG) facilities previously encountered some difficulty using the prior version of the CSAT Top-Screen tool to locate questions related to Theft/Diversion COI. This enhancement to the Top-Screen tool does not change those questions but will enable refinery and LNFG facilities to find and answer those questions more easily in any future Top-Screen submissions.”

The four new FAQs are:

● 1714: What administrative edits can be made to a submitted Site Security Plan (SSP)?
● 1715: What technical edits can be made to a submitted Site Security Plan (SSP)?
● 1716: How frequently can I make a change to a submitted Site Security Plan (SSP)?
● 1717: I started to edit a submitted SSP to make a technical (or administrative) change and realized the previously submitted SSP does not need revision. What should I do?

DHS Directed Edits

The only new information provided in the FAQ is found at the end of the response to FAQ # 1717. There it says: “DHS-initiated SSP survey edits may NOT be deleted at the facility’s request.” I cannot find any mention of ‘DHS-initiated SSP survey edits; in the CSAT SSP Edit Process User Guide. I would suppose that these edits could technically fall into either the administrative or technical edit categories, but I would not expect that they would apply to the limit on the frequency of technical edits. I am certain that DHS will notify facilities about such directed edits and that the notification would include instructions on how to complete the edit.

I will see if I can get some additional information on these directed edits.

DHS CSAT FAQ Page Update 09-18-09

Last week DHS revised the answer to one of the frequently asked questions on the CSAT FAQ page. The underlying question was: 1461: What resources are available to determine the total production value for an economically critical chemical? The revision was the addition of a brief description of the current version of the Top-Screen User’s Manual, “(PDF, 86 pages – 1.13 MB)”. DHS uses this description as a short hand to identify changes in the version of document. I’m not sure why they use that convention instead of a standard version number or version date, both of which are published on all CSAT reference documents. The only thing that I can think of is that it does provide some indication of how long it will take to download the documents. This is not nearly as important as it used to be with most corporate internet users having routine access to high-speed internet access.

DHS CSAT FAQ Page Update 08-14-09

Last week DHS reviewed/updated six answers to frequently asked questions (FAQ) on the CSAT FAQ web page. All six questions dealt with user roles and account transfers. The six questions were: 706 I have multiple usernames. Can I get rid of the duplicates? 707 How do I change the name of the Authorizer/Submitter/Preparer? 711 What are the responsibilities of a submitter? 724 What are the responsibilities of a preparer? 1391 When would I transfer accounts? 1392 When would I have the ability to transfer my account or reassign my user role? The only change seems to be a name change of an application/tool within the CSAT system. The new FAQ answers tell the User to use “Manage My Account application” instead of the “User Change Request System” referenced in the earlier versions of these FAQ answers. Since I am not a registered CSAT User (not being a ‘high-risk chemical facility’) I cannot access the CSAT system to see if there are any significant differences between the old and new tools. But, looking at the changes in the answers it does not seem that there are any significant differences. Interestingly, the DHS CSAT web site uses yet different terminology on the Update My Information page. It calls for using the “Update My Information” link after logging into CSAT.

DHS CSAT FAQ Page Update – 10-31-08

There was only one review/revision of FAQ answers this week. The one question dealt with an SVA question: 1433: When will I be notified if I have to complete a SVA? With only one question there is no reason not to include the complete answer provided on the FAQ page. This is especially true since this is only likely to affect facilities that have just completed their first Top Screen.

“DHS expects to review a facility's Top-Screen within 60 days of its submission. Upon completion of that review, facilities that are considered "high-risk" will be mailed a Preliminary Tier Determination letter that will notify the facility of its preliminary tier and deadline for completing a SVA that addresses the COI and security issue(s) identified by the Department. Facilities placed preliminary in Tier 4 will have the option of submitting an Alternative Security Program (ASP) to DHS in lieu of completing the CSAT SVA.”