DOT Audits And CFATS

I received several calls and e-mails during the week of June 23, and it looks as though the Department of Homeland Security (DHS) has finally started issuing letters to companies that registered and completed the Top Screen. Many members have reported that they have been selected as a Tier 3 high risk and, therefore, need to proceed to the next step: completing a Security Vulnerability Assessment (SVA).

Security Vulnerability Assessment
DHS’s implementation of the Chemical Facility Anti-Terrorism Standards, published May 2007, entered its second stage with the launch of the secure, online SVA tool. Only high-risk facilities notified in writing by DHS are required to complete and submit the Chemical Security Assessment Tool (CSAT) SVA to DHS. Facilities that receive such a letter are initially considered high risk and preliminarily assigned to Tier 1, 2, 3 or 4 based on an analysis of the Top Screen questionnaire they submitted to DHS.

You can find the links to the CSAT SVA questions and instructions by going to this link: http://www.dhs.gov/xprevprot/programs/gc_1169501486197.shtm#content. I recommend that you print out the questions and instructions and complete the questions prior to using the online tool. Things will go much smoother this way.

The online CSAT SVA tool can be accessed only by Chemical-Terrorism Vulnerability Information (CVI) certified individuals. To get CVI certified, go to the training link found at the above link.

CSAT SVA Submission Deadlines
Deadlines to submit the CSAT SVA are specified in the initial notification letter sent by DHS to facilities initially considered high risk. In general, the deadlines are:

  • Preliminary Tier 1 facilities have about 90 days to complete and submit the SVA.
  • Preliminary Tier 2 facilities have about 120 days to complete and submit the SVA.
  • Preliminary Tier 3 facilities have about 150 days to complete and submit the SVA.
  • Preliminary Tier 4 facilities have about 180 days to complete and submit the SVA or an Alternative Security Program (ASP) in lieu of an SVA.

If a facility would like to request an extension of the SVA deadline (in accordance with 6 CFR §27.210(c) of the CFATS rule), letters can be sent via regular mail to:

Department of Homeland Security
Infrastructure Security and Compliance Division
Mail Stop 8100
Washington, DC 20528-8100

DOT Audits are Increasing
There is a definite increase in the number of Department of Transportation (DOT) audits in recent months. DOT is still doing a large number of security reviews, but I have been hearing from members in all areas of the country of more full-blown audits than in the past years.

I have put together a suggested filing system help page. It describes a hanging file and manila folder system that will help you organize your DOT records to help you stay in compliance and look very organized when DOT arrives. If you would like a copy of this help page, just ask and I’ll be glad to send it to you.

Call me whenever you are having, or are about to have, a DOT audit. I can help you with the items inspectors ask about. I can also help you with any response letters you are required to send them outlining corrections they might require. The call I hate to get is when a member has received a penalty notice, and this is the first I have heard about the audit. This is a little late to really help in reducing the penalty. It works a lot better to be proactive from the very beginning. The more you cooperate, the faster you make the corrections; and the quicker you submit the correction action plan, the more it helps to reduce the potential penalties.

It is not that difficult to look good from DOT’s viewpoint.

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT & Security Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at (573) 785-5111 and at MLDSafety@hotmail.com.