Chemical Facility Security News

Last Thursday afternoon DHS added two new FAQ to their FAQ Page. The questions were:

• 1531. My circumstances have changed from my original Top-Screen submission. What do I base my SVA on—my original submission, or the material modifications I have made?
• 1532. How may I request an extension of my facility's SVA deadline?

Any time a facility has material modifications to the COI on hand, the maximum amount of a current COI on hand, or surrounding infrastructure, the facility is required to submit a new Top Screen within 60 days of the change. If an SVA has not yet been submitted, the facility has a couple of options:

• Submit the currently required SVA. If the revised Top Screen causes DHS to modify the security issues involved (or the Tiering assignment), they will issue a new SVA notification letter with a new SVA completion date. A revised SVA will then need to be submitted
• Request an extension request for the current SVA with a note that a new Top Screen will be/has been submitted. DHS will then decide whether to require that the current SVA will be submitted before or after the revised Top Screen is submitted and reviewed.

Extension requests will be mailed to:

C/O Dennis Deziel
Infrastructure Security Compliance Division
Office for Infrastructure Protection
U. S. Department of Homeland Security
Mail Stop #8100
Washington, DC 20528

The answer to the second question provides the same address but adds a neat new twist to the answer that I had not considered. In order to justify the extension request, the facility must provide as much information as possible. If the justification is the one described in the previous answer, the information being provided will almost certainly fall under the CVI rules.

The facility needs to be careful that they follow the rules for document marking, packaging and mailing (see para 8.2 of the CVI Procedure Manual for mailing rules).

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