Monthly Archives: April 2017

DHS Tiering Methodology

Today, the Infrastructure Security Compliance Division of DHS hosted a webinar on their new tiering methodology for CFATS facilities.

The presenters stated that the increases and decreases of theft/diversion and release-toxic chemicals of interest (COI) is due to improvements and implementation modeling data available to DHS. Facilities that possess Triethanolamine and MDEA, for example, will most likely be increased to Tier Two for theft/diversion chemical weapon precursor due to the implementation of the new modeling tools.

DHS began sending out letters to facilities earlier this month based on the new tiering methodology. Facilities are instructed to review their SSP/ASP to ensure that the existing security measures are sufficient for the tier level. If a facility determines that they need to resubmit their SSP/ASP, the facility has 30 days from the date of the letter to update the Security Vulnerability Assessment and Security Plan. Note: This deadline is not mentioned in the letters that our clients have received.

 During Compliance Inspections, inspectors will verify that the security measures are appropriate to address all tiers, security issues and COI.

Feel free to contact us if more information or support is needed.

DHS Issues Tiering Letters

Yesterday, the DHS Infrastructure Security Compliance Division began sending out tiering letters to facilities that recently submitted Top Screens using the new CSAT 2.0 tool.

You will receive an email for DHS stating that “A New CSAT Letter is Available for Your Facility Survey”. You will need to log in to your CSAT account and acknowledge receipt of the letter.

To read more about CSAT 2.0 Top Screens, click here and here.

TWIC Reader Clarification

Recently the Coast Guard shared a blog post to clarify the TWIC Reader Requirements Final Rule regarding CDC facilities.

The rule applies to facilities that are considered a Certain Dangerous Cargo (CDC) facility. These facilities are designated as Risk Group A facilities and will be expected to comply with the TWIC reader rule requirements effective August 23, 2018.

The blog post clarifies what a CDC facility is. According to PAC Decision 20-04 Certain Dangerous Cargo Facilities, in “order for a facility to be classified as a CDC facility, a vessel-to-facility interface must occur, or be capable of occurring, and involve the transfer of CDC’s in bulk”.

Blog can be read here and PAC 20-04 can be found here. To read more about the TWIC Reader Requirements Final Rule, click here.