Roberts Law Group News

DHS Publishes CSAT 2.0 Federal Register Notice

This week, the Department of Homeland Security (DHS) published a Federal Register Notice to officially announce Chemical Security Assessment Tool (CSAT) 2.0, which incorporates elements of DHS’s new CFATS tiering methodology (i.e., the process used to identify what facilities are “high-risk” and then assign such facilities to a risk-tier (Tier 1 – Tier 4).
DHS anticipates deploying CSAT 2.0 in September, and beginning October 1, notifying both tiered and unregulated facilities to submit new Top-Screens. The process will occur in phases, with DHS notifying a cross-section of both tiered and unregulated facilities approximately every 2 weeks. Facilities will then have 60 days from receipt of DHS notification to complete and submit the new Top-Screen. Complete roll-out of the new Top-Screen tool is expected to take a full year. It is important to note that the new Top-Screen only changes how DHS collects and analyzes submitted Chemical of Interest (COI) information; in other words, the Appendix A COI list (and reporting quantities/concentrations) is not changing at this time. Changes to Appendix A will occur through a formal rulemaking (as noted below) in the future.