Date: Thu, 26 Jul 2007 11:43:26 -0400
Reply-To: "Wawzyniecki Jr, Stefan" <stefan.w**At_Symbol_Here**UCONN.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Wawzyniecki Jr, Stefan" <stefan.w**At_Symbol_Here**UCONN.EDU>
Subject: Chemical Security Rule
In-Reply-To: A<7FCB95300E34CD46831A79E87C3B148A8E5639**At_Symbol_Here**NYHCBMSG04.NA.NGRID.NET>

In anticipation of the finalized Appendix A to be published by Homeland Security (probably sooner rather than later), have any of you established a method for the assessment procedure? Specifically- 1. Will EH & S oversee it, solely? 2. Will it be a simple process of simply putting out a request to all owners of chemicals to submit a list of the chemicals on their inventory which match & meet the threshold level? And then having one office fill out the final form? 3. Have you formally designated the roles (see below) of the Responsible Parties as established by DHS? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ (From DHS web site) In completing the user access request form, your facility must designate Preparer(s), Submitter(s), and Authorizer(s). The Preparer is authorized to enter the required data into the CSAT on-line screening tool (but is not authorized to formally submit the data on the company's behalf) and should therefore be a qualified individual familiar with the facility in question. The Preparer must also be domiciled in the U.S. The Submitter is the individual certified by the company or corporation to formally submit the regulatory required data to the Department. The Submitter must be domiciled in the U.S. and must also be an Officer of the Corporation or designated by an Officer of the Corporation. To gain user access, each Preparer and each Submitter require the signature of an "Authorizer." The Authorizer is empowered by the facility parent company to provide assurance that the user account request for the Preparer and Submitter is valid. The Authorizer must also be domiciled in the U.S. and an Officer of the Corporation or designated by an Officer of the Corporation. -Stefan Wawzyniecki, CIH, CHMM NRCC-CHO University of Connecticut

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