Chemical Facility Security

On April 9, 2007, the U.S. Department of Homeland Security (DHS) published an Interim Final Rule that imposes comprehensive federal security regulations for high risk chemical facilities.  This rule establishes risk-based performance standards for the chemical facility security, by requiring facilities to prepare Security Vulnerability Assessments, which identify facility security vulnerabilities, and to develop and implement Site Security Plans, which include measures that satisfy the identified risk-based performance standards.

In order to comply with the regulations, DHS developed the Chemical Security Assessment Tool (CSAT) to collect and analyze key data from chemical facilities.  The CSAT is comprised of three secure, web-based tools:

Any facility that manufactures, uses, stores, or distributes chemicals listed in “Appendix A: Chemicals of Interest” at or above the Screening Threshold Quantity (STQ) must complete (or have completed) and submit(ed) a CSAT Top-Screen within 60 days of the regulation publication date (November 2007) or within 60 days of having received a Chemical of Interest (COI) above the STQ.  In addition, if a facility has made material modification to its operations or site since submitting its Top-Screen, an update to its Top-Screen submittal (and SVA, if already completed) may be required within 60 days.  Click here for a copy of the CSAT Top-Screen questions.

Some common chemicals such as chlorine and ammonia have threshold quantities that are identical to the EPA Risk Management Program Requirements (2,500 pounds and 10,000 pounds respectively).  Many chemicals also have different thresholds for different types of threat scenarios (e.g., 500 pounds for chlorine if there is a theft threat potential).

The following hyperlinks contain information to help you with your CFATS Program Requirements; however, please feel free to contact us at 877/532-0806 (or info@RMPCorp.com) if you have any questions:

• Thresholds and Exemptions List
• Top Screen FAQ
• CFATS Fact Sheet
• CFATS Appendix A Final Rule
• CFATS Appendix A FAQ
• CSAT Top-Screen - Questions (November 2007)
• CSAT Top-Screen - User Manual (July 2008)
• CSAT SVA - Instrutions (June 2008)
• CSAT SVA - Questions (June 2008)
• Federal Register Notice
• November 2 Press Release - "DHS Publishes Chemicals of Interest List for Chemical Facility Anti-Terrorism Standards"

Risk Management Professionals has incorporated a chemical facility security element as part of Process Hazard Analyses (PHAs) for a spectrum of chemical facility types since 1995.  In addition, while completing Security Vulnerability Assessments (SVAs) for water facilities, our professionals have pioneered the implementation of comprehensive security assessment methodologies.  Risk Management Professionals provides robust Security Vulnerability Assessment services utilizing industry standards and best practices, including the DHS CSAT SVA Methodology, AIChE CCPS Security Vulnerability Analysis Methodology, Sandia National Laboratories VAM-CF(SM), and API’s Security Vulnerability Assessment Methodology for the Petroleum and Petrochemical Industries.