Wednesday, July 5, 2017

ISCD Updates Two FAQs, Almost

A ‘Latest News’ item dated 7-4-17 was published on the DHS Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center web page stating that the Infrastructure Security Compliance Division (ISCD) had updated the responses to two frequently asked questions (FAQ) on that page. It goes on to note that the second FAQ response changed (FAQ #1780) had actually been deleted and replaced by FAQ #1784. I have already reported about the other FAQ update (FAQ #81) as it was actually published on June 29th, 2017.

The replaced FAQ was actually Article # 1780 which was originally published on April 17th, 2017. That article provided a much more detailed and nuanced discussion of the specific types of facilities (and parts of facilities) exempted from coverage under the CFATS rule than does the much shorter response in the response to FAQ #1784.

The FAQ #1784 is much closer to the response to FAQ #1740 that was originally published on July 13th, 2015. Unfortunately, that FAQ was discarded without notice sometime between June 23rd, 2016 and September 26th, 2016. The major difference between the new FAQ response and the one for #1740 is that the new one includes links to defining regulations.

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