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Department of
Homeland Security Chemical Security Assessment Tool
by Capaccio Environmental Engineering, Inc.
The DHS
Chemical Security Assessment Tool (CSAT) is a system that
DHS designed to aid in the process of gathering necessary
chemical storage-risk information from facilities that
possess certain chemicals of interest in excess of the
screening threshold quantities. The tool is comprised of
four parts:
-
Facility Registration Questionnaire;
-
Consequence screening questionnaire (Top-Screen);
-
Security Vulnerability Assessment (SVA) tool;
-
Site
Security Plan (SSP) template
Facilities must first evaluate whether their chemical
storage/shipments exceed any of the Screening Threshold
Quantities (STQ) found in the final version of Appendix A
(published November 20, 2007) for each of the three
chemical security concerns - release, theft, and sabotage.
If a facility exceeds any of these thresholds they
must at least fill the first two parts of the CSAT;
the facility registration and the consequence screening
questionnaire (Top-screen) by January 19, 2008.
The
facility registration consists of user set up for each
facility with four roles. The roles can be designated as
the same person or as different individuals.
-
Preparer
-
Submitter
-
Authorizer
-
Reviewer (optional)
General
facility information is also entered in the initial
facility registration. There is a 45 page registration
user’s guide available on the DHS website that includes
step by step directions and Frequently Asked Questions to
assist you with the completion of the registration
process.
Next, the
consequence screening questionnaire (Top-Screen) must be
submitted by anyone who has completed a registration
(which should be anyone who exceeds any STQ found in
Appendix A). The Top-screen has very recently been changed
to be consistent with the final Appendix A. If a facility
has already begun to fill out the Top-screen, the
information already filled will be transferred to the
final version of the questionnaire.
The
questionnaire consists of a general facility information
section followed by Chemical of Interest (COI) specific
questions for each security risk (Release, Theft, and
Sabotage). To complete the questionnaire as much facility
chemical storage information as possible will need to be
gathered. Information from the following sources will be
beneficial during the process:
-
Facility Chemical Inventory
-
EPA
Risk Management Plan (RMP) Submittals
-
EPCRA
Tier II Reporting Documentation
-
Chemical purchasing information
A PDF of
the questions on the Top-screen questionnaire (111 pages)
as well as a Top-screen user’s manual (71 pages) can be
found the DHS website at
http://www.dhs.gov/chemicalsecurity to aid in
the process of gathering the necessary information.
Once
submitted, the information on the Top-screen can not be
changed, therefore it is important to have the right
information and knowledgeable individuals completing and
submitting the data. Once the questionnaire has been
submitted, a screen will be displayed that either says
“May be regulated” or “Not regulated.” If the screen says
“May be regulated” the DHS will notify the facility in
writing whether it is considered a high risk facility or
not. If the screen says “Not regulated” DHS will also send
a letter confirming this determination.
If the
facility is determined to be a high risk facility the
other two parts of the CSAT tool, the Security
Vulnerability Assessment (SVA) tool and the Site Security
Plan (SSP) template, will need to be used to comply with
those provisions of CFATS.
For
more information or help with a CFATS applicability
determination, registration, or Top-screen questionnaire
contact Linda Swift
at (508) 970 0033 ext. 119.
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