Roberts Law Group News

Top-Screen Enforcement

 

Citing 6 CFR § 27.210, which directs Tier 1 and Tier 2 facilities to submit an updated Top-Screen every two years and Tier 3 and Tier 4 facilities to submit an updated Top-Screen every three years, the Department of Homeland Security (DHS) has started issuing Top-Screen Resubmission Letters, via the Chemical Security Assessment Tool (CSAT), directing facilities to complete and submit an updated Top-Screen within 60 days of CSAT notification.
 
As a Top-Screen resubmission deadline nears (e.g., approximately one week out), DHS may issue a Top-Screen Warning Letter, also via the CSAT, reminding the facility of the upcoming deadline and the monetary penalty for failing to resubmit the Top-Screen by the required date. In addition to the CSAT Top-Screen Warning Letter, DHS may also email the CSAT Submitter directly to reiterate the upcoming deadline and the potential penalty for failing to resubmit the Top-Screen on time.