Chemical Facility Anti-Terror Standard (CFATS) Program Update Presented at San Jose ASSE Meeting
Kathryn J. Nobrega, Senior Program Director, Amherst, MA
STC recently attended a "Chemical Facility Anti-Terror Standard (CFATS) Program Update" presented by Mr. T. Ted Cromwell at the San Jose ASSE Chapter meeting on June 8, 2010. Mr. Cromwell is the Communications Section Chief (Acting) within the Infrastructure Security Compliance Division at the US Department of Homeland Security (DHS). Finalized in June 2007, CFATS requires facilities with any of 330 chemicals of concern (COIs) above threshold quantities to submit a "Top-Screen" questionnaire to DHS to determine the facility's level of risk. The chemicals are listed in Appendix A of 6 CFR Part 27. Facilities deemed high risk must then implement security measures that meet CFATS Risk-Based Performance Standards (RBPS). High-risk facilities tend to be those located near major metropolitan centers or other sensitive areas. Regulated facilities may include: - colleges and universities
- hospitals
- warehouses
- semi-conductor manufacturing
- chemical repackaging operations
- paint manufacturers
- chemical manufacturers
- oil and gas operations
- mining industries
Facilities that may not have had chemicals above threshold quantities when CFATS was enacted, but later acquire them, must submit Top-Screens. Additionally, anticipated changes to Appendix A may also trigger submittals. Some additional facts related to this regulatory program include: -
Of the over 38,000 facilities that submitted Top-Screens, approximately 5,300 are now regulated under CFATS and are required to develop and implement site security plans.
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DHS estimates that approximately 10,000 to 15,000 facilities that should have submitted top screens have not done so.
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Highest risk facilities (Tier 1) are participating in on-site verification inspections conducted by regional DHS offices.
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DHS is in the process of notifying the Tier 4 (lowest risk) facilities of their status.
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No enforcement actions have been taken to date.
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Compliance assistance is available at www.dhs.gov/chemicalsecurity. DHS also hosts a Help Desk at 1-866-323-2957, CSAT@DHS.gov.
STC has experience assisting our clients to determine whether CFATS applies to their facilities, and to help formulate compliance strategies should they meet the Top-Screen submittal criteria.
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