There are still circumstances which may require your facility to resubmit a Top-Screen today, even if you have already resubmitted using CSAT 2.0. For example, a facility must report material modifications to its chemical holdings or facility operations, as these changes may alter a facility’s tier. Material modifications may include:
- The addition or removal of COI at the STQ and concentration
- Changes to quantity, location, or packaging of a COI as previously reported on a Top-Screen
Facilities are encouraged to report the highest expected quantity and concentration of COI they anticipate possessing over the lifecycle of their operations. By taking this approach, facilities can maintain a more efficient reporting process as they will not need to resubmit a Top-Screen when the quantity or concentration of a COI is reduced through normal operations.
Additionally, CFATS-covered facilities are required to update their Top-Screens on a regular basis, as determined by their tier:
- A Tier 1 or Tier 2 facility must update its Top-Screen two years after its SSP is approved
- A Tier 3 or Tier 4 facility must update its Top-Screen three years after its SSP is approved
Let us know if we can help you prepare and submit your CFATS Top Screen and prepare your facility for a Compliance Inspection.
To read about what to expect from a CFATS CI, click here.