Today the DHS Infrastructure Security Compliance Division
(ISCD) published a new Frequently Asked Question (FAQ) on the CFATS Knowledge Center. The question
addresses the need to submit a Top Screen for a temporary holding of a DHS
chemical of interest (COI). FAQ
# 1754 asks:
Does a facility have to report
temporary holdings of Chemicals of Interest (COI) at or above the Screening
Threshold Quantity (STQ)?
The short answer, is yes 6
CFR 27.210(a)(1)(i) requires that a Top Screen be submitted “within 60
calendar days for facilities that come into possession of any of the chemicals
listed in appendix A at or above the STQ for any applicable Security Issue”.
The response goes on to note that ISCD will work with facilities if they have “if
the facility has fluctuating COI or has known future COI holdings”.
The response probably should have included a comment about
contacting the CFATS Help Desk {(866) 323-2957} for details on how let ISCD
know about the temporary nature of their COI holdings.
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