DHS is making Changes to the Top Screen and Site Security Plan

August 29, 2016

According to a Federal Register notice filed July 20, 2016

(https://www.federalregister.gov/articles/2016/07/20/2016-16776/chemical- facility-anti- terrorism-standards#h-9) , the Department of Homeland Security (DHS) has temporarily suspended the requirement to submit Top-Screens and Security Vulnerability Assessments in order to allow for an improved tiering methodology and roll out a new Chemical Security Assessment Tool (CSAT 2.0). .

 The current tiering structure consists of 1, 2, 3, and 4. Tier 1 facilities are those that have been

determined to have significant risk; Tier 4 facilities have been determined to have lower risk.

The Federal Register notice does not reveal the new tier structure.

 The current CSAT tool requires filing of a separate Security Vulnerability Assessment (SVA) and

Site Security Plan (SSP) – the new CSAT 2.0 will combine the SVA and SSP.

If your facility has already filed Top Screen and SSP because your facility has a Chemical of Interest (COI) at or above the threshold quantity, there will be some steps to take when the CSAT 2.0 system is deployed (expected to be September – October 2016):

1. DHS will begin notifying facilities that have already submitted their programs to submit a new

Top Screen using the CSAT 2.0 tool.

2. DHS will determine the new Tier level for that facility

3. A facility may choose to file a new Top Screen prior to receiving written notification from DHS.

This could be advantageous for facilities that believe that their tier level will be lowered under the new tiering method.

If your facility has filed partial Security Vulnerability Assessments (SVA) and/or Site Security Plans (SSP), DHS will delete these and the data and will no longer be retrievable. If your facility has submitted a SSP through the current CSAT tool, the SSP application will be available and pre-populated in CSAT 2.0.

If you receive a letter from DHS and don’t believe that your facility is required to file a Top Screen, you must notify DHS by:

1. Accessing CSAT 2.0 and submitting a Top-Screen with no COI selected  or

2. Send a letter in reply to the notification letter

CSAT 2.0 is expected to reduce filing time by:

1. 90% for the completion of the Security Vulnerability

2. 70% for the completion of the Site Security Plan

Emilcott has CV-I Authorized professionals who can help with determining the Top Screen applicability for your facility.