Roberts Law Group News

DHS Extends Public Comment Period on Two CFATS Information Collection Requests

The Department of Homeland Security (DHS) has provided an additional 30 days for public comment on various updates to the Chemical Facility Anti-Terrorism Standards (CFATS) program. Comments on the two Information Collection Request (ICRs) will be accepted until August 28, 2017. The ICRs contain various tweaks to the CFATS program, including:
  • Changing the official term “Request for a Technical Consultation” to “Compliance Assistance” and changing “Notification of New Top-Screen” to “Top-Screen Update” in an attempt to clarify the functional purpose of these items;
  • Amending the “Request for Redetermination” to allow facilities to select from a list of possible reasons to support a request for tiering redetermination;
  • Adding a new reporting channel titled “Declaration of Reporting Status” to allow a facility to notify DHS that it is not required to register in the Chemical Security Assessment Tool (CSAT) or submit a Top-Screen; and
  • Changes to Chemical-Terrorism Vulnerability Information (CVI) management, including discontinuing use of the following CVI tracking documents: (1) Request for Determination of CVI; (2) Determination of a Public Official’s Need to Know Specific CVI; (3) Report of Potential Release of CVI; (4) Notification of CVI Disclosure During Emergency or Exigent Circumstances''; and (5) Tracking Log for CVI Received.