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Department Of Homeland Security
Issues
Chemical Security
Regulations
by Capaccio Environmental Engineering, Inc.
On April 9, 2007 the Department of Homeland
Security (DHS) issued a new regulation (6 CFR 27 –
Chemical Facility Anti-terrorism Standards (CFAT))
regarding security screening requirements and security
planning at “chemical facilities”. A chemical facility
“shall mean any establishment that possesses or plans to
possess, at any relevant point in time, a quantity of a
chemical substance determined by the Secretary to be
potentially dangerous or that meets other risk-related
criteria identified by the Department.” In Appendix A to
the regulation, DHS has listed the chemicals of interest
and their corresponding “Screening Threshold Quantity” (STQ).
Regardless of the type of facility, if
there is or it is intended that there will be a listed
chemical at or above the STQ at your facility, you must
participate in the screening process outlined in the
regulation to determine if a Site Security Plan is
necessary.
This regulation does not just apply to chemical
manufacturing facilities. For example, facilities such as
semiconductor manufacturing facilities that have any
amount of arsine, phosphine, or hydrogen chloride gas or
7,500 pounds of silane, a warehouse that has 7,500 pounds
of propane or anhydrous ammonia, a plating company with
2,000 pounds of nitric acid or 11,500 pounds of
hydrochloric acid (with a concentration of 37% or greater)
are subject to the screening requirements of the CFAT
standard. DHS will be sending correspondences to some
facilities (such as chemical manufacturing facilities) to
be sure that they know about the new standard. However,
it is important to note that DHS expects any facility that
meets the STQs for chemicals of interest to participate in
the screening process – whether or not they receive
notification from DHS.
Although
Appendix A is not final yet it is expected that the only
potential changes will be the addition of chemicals to the
list. (DHS tells us that it may be final as early at the
week of May 14, 2007.) Some deadlines are dependent on
the finalization of Appendix A and some are not.
Click here to link to the Appendix A.
The
screening process outlined in the CFAT standard involves
four (4) steps: registration, completion of a Top Screen,
a Security Vulnerability Assessment, and Site Security
Planning.
- All
facilities subject to the CFAT standard should register
on-line with DHS by June 8, 2007. User
registration will ask the facility to designate the
preparer, submitter, and authorizer for the facility,
their contact information, general information about the
facility such as location, type, owner/operator, and
number of employees. Once this is completed on-line,
the registration form should be printed and signed by
the preparer, submitter, and authorizer and mailed or
faxed to the address or number provided on the web
site. The preparer, submitter, and authorizer can be
the same person or combination of the three. The
submitter is required to be domiciled in the US. The
preparer and submitter will be emailed user names and
passwords that will be used to access the on-line tools
used in the screening process.
-
Following registration, facilities will need to submit a
Top Screen on-line through the DHS website. The Top
Screen on-line tool is not currently available.
However, it is expected that the tool will be available
some time after June 8, 2007 and from that time a
facility will have 60 days to complete the Top Screen.
- Once
the Top Screen is submitted, DHS will review the data
provided and then notify the facility of its ranking
(i.e., Tier 1, Tier, 2, Tier 3, Tier 4) and whether the
facility needs to proceed with the next step (completion
of a Security Vulnerability Assessment).
- If
notified by DHS, facilities will need to complete a
Security Vulnerability Assessment (SVA) using the
on-line tool at the DHS website. SVAs must be completed
within 90 days of notification from the DHS.
- If
results of SVA indicate the facility is at risk, DHS
will notify the facility of the need to complete a Site
Security Plan (SSP) using the on-line tool at the DHS
website. SSPs must be completed within 120 days of
notification from the DHS.
See the
flow chart below for an overview of the screening process
required by the CFAT Standard.
At
a minimum, facilities must look at their chemical storage
inventories and determine whether they trip the STQ
thresholds for chemicals of concern and maintain records
of this review. June 8th is just around the
corner!
Our latest information from DHS indicates that you only
need to count chemicals listed in Appendix A in the pure
form towards the thresholds. If you have a mixture
containing a listed chemical, this would be exempt and the
quantity in the mixtures would not count towards the
threshold.
For
questions regarding the CFAT Standard, contact Linda Swift
at Capaccio Environmental Engineering, Inc, (508) 970-0033
ext. 119.
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