Chemical Facility Anti-Terrorism Standards Quarterly Update, October 2018

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ISCD-Quaterly

Volume 4, Issue 3

Do I Need to Resubmit a Top-Screen?

topscreen

Chemical facilities have 60 days from the time they come into possession of a chemical of interest (COI) at or above the screening threshold quantity (STQ) or concentration to report their holdings to the Department of Homeland Security (DHS) via a Top-Screen survey. The information submitted through the Top-Screen is then used by DHS to determine if the facility is high-risk and subject to the CFATS regulation. If so, it is assigned to one of four risk-based tiers.  

In 2016, DHS began implementing an enhanced tiering methodology, which more accurately determines and appropriately tiers facilities. The improved methodology considers three main elements in a facility’s high-risk determination: vulnerability, consequence, and threat.

Several factors may impact a facility’s high-risk status and, as applicable, their risk tier. The vulnerability variable considers inherent characteristics of the facility and/or assets that reduce vulnerability to a terrorist attack—for example, a COI storage container located in an underground earth formation. The consequence variable incorporates improved tools that allow the Department to more accurately calculate, through physics-based dispersion and blast modeling, the onsite and offsite impacts of COI exploitation and misuse. The threat variable includes factors informed by the intelligence community that may affect the level of threat of terrorist attack or exploitation for a facility. The enhanced tiering methodology required facilities to submit a new Top-Screen using the Chemical Security Assessment Tool (CSAT) 2.0.

There are still circumstances which may require your facility to resubmit a Top-Screen today, even if you have already resubmitted using CSAT 2.0. For example, a facility must report material modifications to its chemical holdings or facility operations, as these changes may alter a facility’s tier. Material modifications may include:

  • The addition or removal of COI at the STQ and concentration
  • Changes to quantity, location, or packaging of a COI as previously reported on a Top-Screen

Facilities are encouraged to report the highest expected quantity and concentration of COI they anticipate possessing over the lifecycle of their operations. By taking this approach, facilities can maintain a more efficient reporting process as they will not need to resubmit a Top-Screen when the quantity or concentration of a COI is reduced through normal operations.

Additionally, CFATS-covered facilities are required to update their Top-Screens on a regular basis, as determined by their tier:

  • A Tier 1 or Tier 2 facility must update its Top-Screen two years after its SSP is approved
  • A Tier 3 or Tier 4 facility must update its Top-Screen three years after its SSP is approved

Unsure of whether or not you need to resubmit or update your Top-Screen? Visit www.dhs.gov/csat-top-screen to learn more, or contact the CSAT Help Desk by calling 866-323-2957 or emailing CSAT@hq.dhs.gov.

Did you know that ISCD can help you with your Top-Screen? Read “Request a Technical Consult” below to learn more.

Request a Technical Consult

Members of DHS’s Infrastructure Security Compliance Division (ISCD), who are responsible for implementing CFATS, are available to conduct over-the-phone technical consultations (tech consult) with you and your facility.

If you have any questions on how to complete your Top-Screen or Site Security Plan, need help understanding security measures and the Risk-Based Performance Standards, or even have questions about your current tiering determination, there’s someone here to help. Just contact the CSAT Help Desk and they will direct you to the proper section within the Division to assist you along the way.

Do you need help understanding a part of the regulation? Are you opening a new facility? Or, are you planning to bring a new COI on-site in the near future? We can provide guidance on all of this and more.

We can answer any questions you may have concerning your tiering determination, provide guidance on understanding the CFATS program, and, if needed, connect you with a point of contact in the field.

Get started by contacting the CSAT Help Desk at 866-323-2957 or emailing CSAT@hq.dhs.gov.


CSAT Portal Update

As of September 30, 2018, CSAT Portal users will no longer have the ability to opt-out of the self-reset password option on the CSAT Portal. The self-reset password capability will enable users to reset your password using the “Forgot Password” option on the CSAT Portal Login page.

 Below are the steps to self-reset your password:

  • To reset your password, access the CSAT Portal Login page (csat.dhs.gov/industry) and select the Forgot Password option
  • From the Forgot Password page, you will be required to enter your username
  • After entering your username, you will be required to select your email address to receive the first passcode, and then voice or text phone number to receive the second passcode
  • Once you receive and enter both passcodes, you will be able to change your password
  • The new password must be at least 10 characters and contain an upper case letter, a lower case letter, a number, and a special character (e.g., ._!@#$%&*). You cannot use any of your 10 previous passwords

Should you have any problems resetting your password, please contact the CSAT Help Desk at 866-323-2957.

DHSChemSecurityTalks: Highlighting chemical security across the regions

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This summer, the National Protection and Programs Directorate (NPPD)’s Office of Infrastructure Protection (IP) held the first series of DHSChemSecurityTalks.

The inaugural series of three, one-day, events, held in Oakland, California, Chicago, Illinois, and Philadelphia, Pennsylvania, was designed to take the chemical infrastructure security discussion and NPPD’s largest regulatory program, CFATS, on the road.

Each event was kicked off by an ISCD Chief of Regulatory Compliance (CRC) and IP Regional Director (IP-RD). CRCs serve as the lead DHS representatives in the regions administering the CFATS regulation and serving as advisors to the IP-RDs on the program. IP-RDs lead all IP activities in their respective regions. The participation of the CRCs and RDs throughout the regions showcased our continuing private-public collaboration. Each event was also specific to the unique threat environments attendees might face within their respective regions.

Sessions focused on the CFATS program, cybersecurity resources, overviews on the IP regions, and the DHS Soft Targets Security Program. DHS officials also met one-on-one with attendees to answer specific CFATS questions.

Kelly Murray, ISCD’s Acting Compliance Branch Chief discussed CFATS lessons learned and best practices at all three events. At one of her sessions in Oakland, she emphasized the importance of the involvement of all aspects of a facility when it comes to chemical security, stating, “Facility employee involvement is an easily implemented best practice. For your inventory managers, make sure they know what chemicals are regulated by DHS and how to check for false orders. Taking a holistic approach will help ensure a strong security posture.”

A panel featuring ISCD Director Dave Wulf and Deputy Director Amy Graydon in Chicago reinforced the importance of the CFATS program. “Our critical infrastructure remains subject to ongoing threats—improvised explosive devices, chemical attacks, vehicle-ramming attacks, active shooters, and other active assailants,” said Wulf. “CFATS is vital to our nation’s counterterrorism efforts—thanks to CFATS, facilities nationwide have implemented thousands of security measures in order to make chemicals more secure.”

During opening remarks at the EAST event in Philadelphia, NPPD Deputy Under Secretary Matthew Travis talked about how the chemical sector is integral to the nation’s economy, noting, “Electricity, water power, and communications are just a few of the interconnected services the chemical industry depends on. If one system goes down, it can cause impacts across all sectors.”

The CFATS program four-year authorization expires in January 2019. The Department is currently working with lawmakers on a reauthorization bill. The CFATS program is a cornerstone of chemical security and reauthorizing this program by the end of the year is a top priority for DHS. CFATS enjoys strong bipartisan support and we appreciate the efforts by Congress to work towards reauthorization. Long-term authorization of CFATS enables the continued security of America’s high-risk chemical facilities.

The DHSChemSecurityTalks reached hundreds of facility owners and operators, government partners, and industry stakeholders. Not able to attend? Visit www.dhs.gov/publication/css-regional-events-2018 to view presentations and learn about upcoming chemical sector events.


New and updated CFATS materials

  • DHS Chemical Security Preparedness Resources Fact Sheet: DHS has made the Office of Infrastructure Protection’s suite of security preparation and preparedness resources available to all chemical facilities, regardless of whether or not they have to comply with the CFATS program. This fact sheet includes information about the programs and includes a variety of resources for facilities to get started. You can download, print, and distribute this fact sheet as a resource to learn more about the programs offered.
  • Ammonia (anhydrous) Flyer: Any site that possesses 10,000 lb. or more of ammonia (anhydrous) must report their chemical holdings to DHS. This flyer highlights information to raise awareness of the CFATS role within facilities that have ammonia (anhydrous). You can download, print, and distribute this flyer as a resource to increase awareness.

To better assist with outreach across the Nation, ISCD has translated into Spanish four fact sheets and one flyer:

spanfs

Visit the CFATS Resources page for more outreach materials you can download and print.

Request for assistance

Contact the CFATS Help Desk for timely support Monday through Friday 8:30 AM to 5:00 PM EST at 866-323-2957 or email CSAT@hq.dhs.gov

Request a CFATS presentation or a Compliance Assistance Visit: www.dhs.gov/cfats-resources 

Contact the DHS Inspector in your area by emailing CFATS@hq.dhs.gov

Web resources 

Chemical Security: www.dhs.gov/chemicalsecurity

CFATS Main: www.dhs.gov/cfats

CFATS Process: www.dhs.gov/cfats-process

CSAT SSP Revisions & Tips: www.dhs.gov/csat

CFATS Knowledge Center is a repository of FAQs, latest news, and resources: csat-help.dhs.gov/