Client Alerts

TSA’s Rail Security Regulations – Compliance Deadline 12/26/2008 – This Client Alert discusses TSA’s issuance of its final transportation security rule. It affects certain facilities that ship or receive hazardous material by rail. Contact us to receive a copy.

New Homeland Security Regulation – TSA’s Rail Security Rules – This Client Alert discusses TSA’s issuance of its final regulations regarding freight and passenger railroad security. It imposes new security obligations on facilities that ship or receive certain types and quantities of hazardous materials. Contact us to receive a copy.

CFATS/RBPS 30 Day Notice-and-Comment Period Starts Today – This Client Alert announces that the 30-day notice-and-comment period for CFATS Risk-Based Performance Standards (RBPS) Guidance starts today. Contents must be received no later than Wednesday, November 26, 2008. Contact us to receive a copy.

DHS Publishes CFATS RBPS Final Draft Guidance Document – This Client Alert announces that DHS has published the long-awaited CFATS RBPS Guidance Document in Final Draft form. The 178-page document will be open for a 30-day notice and comment period. Contact us to receive a copy. Modification of Current Security Plan Requirements for the Commercial Transportation of Hazardous Materials: Notice of Proposed Rulemaking (October 10, 2008) – This Client Alert discusses DOT’s issuance of a Notice of Proposed Rulemaking to modify current security plan requirements governing the transportation of hazardous materials, commonly known as HM232. Contact us to receive a copy.

Rail & Chemical Industries Request Interim Federal Standard for PIH Rail Cars – This Client Alert discusses a joint petition filed by the Association of American Railroads (“AAR”) and the American Chemistry Council (“ACC”), along with other organizations representing the rail and chemical companies, requesting that the Federal Hazardous Materials Regulations (“HMRs”) be amended to authorize interim standards for tank cars transporting Poisonous by Inhalation (“PIH”) materials. Contact us to receive a copy.

Important CFATS Top-Screen Change for Fuel Terminals – This Client Alert includes a draft letter from DHS regarding important, forthcoming changes for fuel terminals. It also summarizes the material aspects of the letter. Contact us to receive a copy.

DHS Publishes Revised Chemical-Terrorism Vulnerability Information (“CVI”) Procedural Manual – This Client Alert follows up from the September 2008 CVI Client Alert, giving a more detailed discussion of the revised CVI Procedural Manual, to include practical examples regarding what “is” CVI and what “is not” CVI. Contact us to receive a copy.

Rail & Chemical Industries Request Interim Federal Standard for PIH Rail Cars Pending Final PIH Rail Car Standard - This Client Alert discusses a petition jointly filed by members of the rail and chemical industries requesting the implementation of interim standards for tank cars transporting PIH materials pending issuance of a final standard. Contact us to receive a copy.

DOT Proposes Modification of Security Plan Requirements for Transport of Hazardous Materials: Notice of Proposed Rulemaking - This Client Alert reviews DOT's proposed modifications of security plan requirements presently in place under the Hazardous Materials Regulations (HMR). Contact us to receive a copy.

DHS Publishes Revised Chemical-Terrorism Vulnerability Information (CVI) Procedural Manual - This Client Alert provides a summary of the revised version of the DHS CVI Procedural Manual, which was published on September 22, 2008, and provides clearer, more concise guidelines regarding CVI use, access, dissemination, and storage. Contact us to receive a copy.

CFATS Security Vulnerability Assessments (SVAs) – This Client Alert reviews the CFATS SVA process. Contact us to receive a copy.

CFATS Requirements for Protecting Chemical Terrorism Vulnerability Information (CVI) – This Client Alert reviews significant issues associated with CVI. Contact us to receive a copy.

CFATS Top-Screen, SVA, and SSP Submission Timeline - This Client Alert approximates forthcoming due dates for submission of the SVAs and SSPs to DHS. Contact us to receive a copy.

Security Enhancements for Rail Transportation of Hazardous Materials – This Client Alert reviews the Pipeline and Hazardous Materials Safety Administration’s recent regulation on rail hazmat security. Contact us to receive a copy.

CFATS Appendix A: Managing the Top-Screen - This Client Alert provides a comprehensive overview of Appendix A that explains all key provisions of Appendix A, including the treatment of Chemicals of Interest by Security Issue and mixtures. Contact us to receive a copy.

New Law Requires Enhanced Security for Railroads; Will Affect Hazardous Material Transportation - This Client Alert describes and analyzes the new rail and hazmat security requirements that are part of the Implementing the Recommendations of the 9/11 Act of 2007. Contact us to receive a copy.

CFATS Frequently Asked Questions and Answers - This Client Alert provides answers to many CFATS frequently asked questions. Contact us to receive a copy.