Question: Must an assessment completed prior to the effective date of the rule have considered all applicable threats in order to be treated as a baseline assessment?
Answer: Yes. The rule requires (192.921(e)) that an assessment conducted prior to December 17, 2002, must meet the baseline requirements in Subpart O if it is to be used as a baseline assessment. A key element of those requirements is that the assessment method be based on the threats faced. Section 192.921(a) requires that an operator must select the method, or methods, that are best suited to address the identified threats.
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