The U.S. Department of Homeland Security (DHS) has published in the Federal Register a notice regarding the implementation of a revised tiering methodology for chemical facilities of interest regulated under the Chemical Facility Anti-Terrorism Standards (CFATS).
The notice temporarily suspends the requirement to submit Top-Screens and Security Vulnerability Assessments (SVA) in order to allow for a phased roll out of the new Chemical Security Assessment Tool (CSAT) 2.0. CSAT 2.0 consists of a more streamlined CSAT Top-Screen, SVA, and a Site Security Plan, that will allow the collection of the data necessary to process facilities through the new methodology and improve the integration between the SVA application and the SSP application.
To minimize confusion, DHS is taking a multi-step approach to this implementation. First, the Department is temporarily suspending the Top-Screen and SVA submissions requirements as outlined in the notice. Second, DHS will replace the current CSAT surveys with the revised surveys. Lastly, DHS will reinstate the Top-Screen and SVA submission requirement. DHS will individually notify facilities of the requirement to resubmit a Top-Screen using the new tool in a phased manner, however, facilities may choose to proactively resubmit a Top-Screen once the new tool is available and prior to the individual notification. Additionally, new chemical facilities of interest that come into reportable amounts of COI after reinstatement of the requirement to submit a Top-Screen and SVA must submit within 60 days.
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