Friday, August 20, 2010

ISCD Director Speaks on Preliminary Inspections

Posted by Roberts Law Group, PLLC at 3:43 PM 0 comments
The acting director of the Department of Homeland Security’s (DHS’s) Infrastructure Security Compliance Division (ISCD) Dennis Deziel offered insight into DHS’s direction on preliminary inspections while speaking at the National Association of Chemical Distributors (NACD) Operations Seminar and Trade Show in Austin, Texas this week.

Deziel stated that officials plan to increase preliminary inspections of chemical facilities regulated by the Chemical Facility Anti-Terrorism Standards (CFATS) to 30-40 facilities per month beginning in August. He stated that many of the Site Security Plans (SSPs) submitted thus far need more detail, and indicated that the Chemical Security Assessment Tool used to submit SSPs “is not perfect,” noting that “there hasn’t been a lot of guidance given to facilities.”

Speaking directly on the preliminary inspections Deziel offered the following:

“It’s almost like a real inspection. We’re there for up to a week. We walk through their draft site-security plan, get a sense of what is at the site, what they said in their plan, and making sure they add the detail they need to ... We’ve found [the preliminary inspections] are a pretty critical piece. People are now starting to understand exactly what the expectations are, which helps us get quality site-security plans.”

Tuesday, August 3, 2010

DHS Sends Agriculture Survey

Posted by Roberts Law Group, PLLC at 1:49 PM 0 comments
DHS recently sent an Agriculture Survey to nearly 1,300 covered CFATS facilities that submitted Top-Screens indicating they possessed certain COIs used in agriculture activities. DHS had indefinitely extended the Top-Screen submission due date in December 2007 for farmers and other agricultural facilities that use COI for agricultural production purposes in order to gather more information regarding agricultural operations to determine whether modification of the Top-Screen was necessary for such facilities. This Agriculture Survey represents DHS’s modification of the Top-Screen and its first step in re-evaluating agricultural facilities that possess and use Appendix A COIs.

The Agriculture Survey seeks information about COI-containing products that meet or exceed the lowest minimum concentration level established for that COI in Appendix A – whether or not the amount of the COI possessed by the facility exceeds the applicable Appendix A Screening Threshold Quantity. Therefore, a facility may need to provide information about COI-containing products that were not required to be reported on the facility’s Top-Screen submission. Those facilities notified in writing by DHS are required to complete and submit the Agriculture Survey by Monday, September 20, 2010.