Chemical Facility Security News

The DHS helpdesk people have been busy this week. This is three days running that they have added another entry to their FAQ page. The latest entry is:

• 1406. If have already submitted a Top Screen and later determine that I need to re-submit, what do I do?

This is an interesting question and one that DHS has not addressed previously. It is certainly not covered in either of their Top Screen manuals (see: "Updates of CSAT Top Screen Manuals").

As I have mentioned in other blogs, facilities that have successfully submitted a Top Screen are not necessarily done with that tool in CSAT. There are a couple of reasons that a new Top Screen might be required:

• Addition of a new chemical to the facility that is on the COI list., or
• Increased maximum inventory of a COI previously reported, or
• Significant decrease in maximum inventory of a COI previously reported.

There may be additional reasons that are out of the ordinary. The general rule of thumb is that any change at the facility (or in its surroundings) that might impact it rating (or lack thereof) as a high-risk facility could require a re-submission of the Top Screen.

The procedures for re-submitting the Top Screen are provided in the answer to the new FAQ. They are:

• "Log in to CSAT at http://click.csat.ornl.gov/csat/ and click on the "CSAT Application" link. You will now see a list of your facilities and their survey status. Facilities with a submitted Top Screen survey will have a button titled "Replace Top-Screen" to the right of the submitted survey. Click on this button and you will be asked to input your name and the reason for the new submission. After entering this information click on "Create Additional Top Screen" and your new Top Screen survey will be created."

All of the standard procedures for completing a Top Screen apply. The Preparer may fill out the form on-line, but the Submitter is the only one that can actually push the button to send it to DHS. Print a copy of the completed Top Screen before pushing the submit button.

There are quite a few new questions and some other changes that will make the process look different than when Top Screens were submittedin January. You will certainly want to down load the two new manuals before starting the re-submission process.

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