How does a college define itself if it has multiple buildings but only a select few have COIs that fall under the regulation?
All facilities, including colleges and universities, have the flexibility to define the parameters of their facilities. The CFATS requirements are facility-specific. As such, an institution of higher learning can, if appropriate, submit a Top-Screen on a facility-by-facility basis or on a campus-wide basis. However, DHS will judge whether or not the facility or facilities, if determined to be high risk, have complied with CFATS and, specifically, the risk-based performance standards. Additional information on the treatment of colleges and universities under CFATS can be found in the preamble to Appendix A to CFATS at 72 FR 65412.
Related Questions
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