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Previous by Date: Subject: FW: JOB ANNOUNCEMENT Date: Fri, 8 Jun 2007 13:44:59 -0700 Author: Regina Frasca |
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DHS had originally wanted to publish Appendix A today, but have told people that they will take "another couple of weeks." I think that means this month or next. Bill Diesslin thinks that means September. Only time will tell. We will have 60 days to do the Top-Screen after the date of publication. Today, DHS posted the Top-Screen questions and a manual. See: http://www.dhs.gov/xlibrary/assets/chemsec_csattopscreenquestions.pdf http://www.dhs.gov/xlibrary/assets/chemsec_csattopscreenusersmanual.pdf Department may also notify facilities - either directly or through a Federal Register notice - that they need to complete and submit a CSAT Top-Screen. Bill Diesslin (Iowa State) has started his registration for the Top-Screen. He said they asked for institution, location, longitude, latitude and contact information. Then you fax in a PDF form and they send back a password to access the rest of the screen. See http://www.dhs.gov/xprevprot/programs/gc_1169503302924.shtm DHS says Appendix A will change, which will provide some relief, but maybe not much. For example, if acetone has an STQ of 2,000 pounds (originally proposed) or 4,000 pounds, most of us will still have to do an inventory. Also, as of last week, DHS told SCOMA that the STQs for the ten Schedule 1 chemicals from the U.S. Chemicals Weapons Convention would remain at "Any Amount." (The two Schedule 1 chemicals regulated by the CDC have a threshold of 100 mg per Principal Investigator.) DHS public statements in the press still indicate that they believe that some universities will need to do a security program. The American Council on Education hired Barry Hartman's firm to look into the question of an exemption for university subject to NRC security orders. They conclude that "whether this exemption can be construed to apply to the entire campus.is far from clear, and we do not recommend that this construction be followed absent further research and analysis." Lawyers at several institutions are doing this further research and analysis. DHS' Chemical Security Summit is being held today through Wednesday. Some university folks are attending. We should know considerably more after they return. (Please report to the list if you go.) CSHEMA is working for change with many other higher education organizations: NACUBO, ACE, COGR, NASULGC, AAU, etc. We are discussing ways to communicate with DHS through high-level university channels and crafting an alternate proposal. I appreciate everyone's help on this, Pete Peter A. Reinhardt Director, Office of Environmental Health & Safety Yale University 135 College St., 1st Floor New Haven, CT 06510-2411 (203) 737-2123 peter.reinhardt**At_Symbol_Here**yale.edu
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