The Department of Homeland Security has issued a list of critical materials with threshold limits requiring a security screening survey of users maintaining inventories of these chemicals. This could impact pipeline operators, refineries, offshore platforms, petrochemical facilities, chemical plants, pulp & paper mills, trucking terminals, and others as well.
The Department of Homeland Security recently provided Appendix A of the Chemical Facility Anti-Terrorism Standards (CFATS), outlining a survey for the chemical security regulatory program. Appendix A lists approximately 300 chemicals of interest and includes common industrial chemicals such as chlorine, propane and anhydrous ammonia as well as specialty chemicals such as arsine and phosphorus tri-chloride. Facilities that possess chemicals of interest at or above the listed screening threshold quantities are required to complete the Top-Screen within 60 calendar days of the publication of Appendix A. The Appendix is the first part of larger legislative effort to document a regulatory materials risk management in much in the same way PSM and RMP do for catastrophic event program management in manufacturing/operating facilities.
When a material on the specified list of chemicals exceeds a threshold quantity, action to complete and submit to the DHS no later than 60 days following the November 20, 2007 publication of the screening tool. The screening tool is an easy-to-use, online consequence assessment tool called a Top-Screen. Using the information gathered through the Top-Screen, the department will make a preliminary determination:
- A facility presents a high level of security risk, and
- The facility will be required to comply with the requirements of CFATS.
The Department of Homeland Security requires that chemicals at or above threshold quantities to the regulatory screening process are based on the following three security categories:
- Release – quantities of toxic, flammable, or explosive chemicals that have the potential to create significant terror, danger to human life or health, if intentionally released or detonated;
- Theft and diversion – chemicals that have the potential, if stolen or diverted, to be used or converted into weapons; and
- Sabotage and contamination – chemicals that, if mixed with other readily available materials, have the potential to create significant adverse consequences for human life or health.
The department identified these chemicals in the specific amounts for preliminary screening based on their potential to create significant human life or health consequences.
For more information on chemical security or to view the Appendix A final rule of CFATS, please visit www.dhs.gov/chemicalsecurity.