I wanted to share a suggestion I learned from Secretary Chertoff at the Chemical Sector Security Summit this Tuesday, June 12. He advised all facilities thinking they might be required to fill out a top screen assessment to go ahead and do so instead of waiting for the Department of Homeland Security to contact the facility first. Top screen’s will not be required to be completed until 60 days after Appendix A is published in the Federal Register, but he impressed on the audience the idea of working ahead by filling top screens out and submitting them as early as this week.
All the tools you need are available online. If your facility anticipates you’ll be on the list, feel free to begin the analysis early. DHS has stated that it is committed to helping facilities at each step of the regulation requirements by providing clear guidance, making facility visits to assist in assessment and be available to answer questions anytime. It also stands by the opinion that clarity is the most valued element of regulatory schemes.