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DHSAnti-terrorist

DHS CHEMICAL FACILITY ANTI-TERRORISM STANDARDS

Appendix A Finalized 
On April 9, 2007, the Department of Homeland Security (DHS) published the Final Rule for Chemical Facility Anti-Terrorism Standards describing three stages of compliance required for facilities that possess certain chemicals, namely:

 Initial Screening using Top-Screen program
The initial screening step must be completed by any facility (or establishment) that possesses any of the chemicals listed in Appendix A at the threshold quantities. Top Screen must be completed within 60 days of the Federal Register publication date of Appendix A. Appendix A was published in the Federal Register November 20, 2007. Top Screens must be completed by January 19, 2008. The only exceptions are for facilities regulated by the Maritime Transportation Security Act, Public Water Systems, Treatment Works, and facilities owned or operated by the Department of Defense or Department of Energy, or regulated by the Nuclear Regulatory Commission. Regulated facilities must register to gain access to the Chemical Security Assessment Tool (CSAT).  This program will require the submission of detailed information regarding the Chemicals of Interest at your facility. 

Security Vulnerability Assessment
Upon written notification by the DHS, a facility will have 90 calendar days to complete the Security Vulnerability Assessment (SVA). (This assessment will require detailed analysis of physical and cyber security against various possible threats.  Security issues such as release, theft and sabotage are to be evaluated depending on the Chemicals of Interest at the facility.) DHS believes that most facilities completing Top Screen will not be required to submit SVAs due to low levels of risk. 

Site Security Plan
A covered facility will be required to complete a DHS approved Site Security Plan within 120 days of a written notice from the DHS.  

Some better-known Chemicals of Interest listed in Appendix A include: 

   CHEMICAL OF INTEREST
 Ammonia (anhydrous)  10,000 lbs  
 Chlorine  2,500 lbs  500 lbs
 Formaldehyde (solution)  15,000 lbs  
 Hydrochloric Acid (conc. 37% or greater)  15,000 lbs  
 Hydrogen Peroxide (>35%)    400 lbs
 Nitric Acid (> 80%)  15,000 lbs  
 Nitric Acid (> 68%    400 lbs
 Nitrocellulose  5,000 lbs  400 lbs
 Propane  60,000 lbs  
 Sodium Chlorate    400 lbs
 Vinyl Chloride  10,000 lbs  

Note that this is a partial list of approximately 300 regulated chemicals. 

For professional support with the development and implementation of your Initial Screening using Top-Screen program, Security Vulnerability Assessment, and Site Security Plan call today:

Joe Hartline
770-427-8123