Chemical Facility Anti-Terrorism Standards (CFATS)

What is this? Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) with the final updated Appendix A, published on November 20, 2007. The purpose of the standard is to determine if a chemical facility has the potential from a terrorist attack involving the facility to result in significant adverse consequences for human life or health, national security or critical economic assets.

Does this apply to me? You must look at the Appendix A. It can be found at http://www.dhs.gov/xlibrary/assets/chemsec_appendixa-chemicalofinterestlist.pdf and if you have any of the chemicals of concern on your property at any time in quantities at or above any of the Screening Threshold Quantities, then you are in this program. Most GAWDA members will not be in this program, but many of you will. Several of the gases we sell are on the list, i.e., poison gases or flammable gases like acetylene, propane and propylene.

If I’m in the program, what do I do? You must first register with DHS to receive your ID and password in order to have access to the Chemical Security Assessment Tool (CSAT). You register by clicking on the register link found on the CSAT Web page. Next, you must take the Chemical-Terrorism Vulnerability Information (CVI) authorized user training online. The CVI training will take about 30 minutes to an hour to complete the reading, six-question test and submission of information. This training and certification must be done prior to working on and submitting the Top Screen information.

After registration, you will be notified of your ID and password. Then you will have access to and must complete the online Top Screen found in the CSAT.

Helpful hint: You should print the CSAT Top Screen questions (the November 2007 version is 111 pages) and the Top Screen User Manual, then gather the required information and complete the question sheets manually first. After you have completed the questions on paper, it will be much easier to complete the online submission.

When must I do this? If you are a part of the program (you have chemicals of concern that meet or exceed the screening threshold quantities), then you must complete the Top Screen in the CSAT within 60 days. The 60 calendar-day deadline starts with either November 22, 2007 if you already have any of the chemicals of concern on your location at or above the screening threshold quantities, or within 60 calendar days if you have them in the future. Again, if you already have any of the chemicals of concern found in Appendix A that meet or exceed any of the screening threshold quantities shown, you had until January 22, 2008 to complete and submit your Top Screen in CSAT. If you missed the deadline, you can still register and submit the Top Screen.

How do I get out of this? You don’t, unless you are either below or got below the screening threshold quantities shown in Appendix A before January 22, 2008. For propane only, facilities need not include propane in tanks of 10,000 pounds or less when calculating whether a facility has a total inventory of 60,000 pounds.

What happens next? DHS will review the submitted Top Screen and then make a determination of whether you are exempted from the program (no further action necessary on your part), or if you are deemed a high-risk facility and to which of the four risk tiers you are assigned. DHS expects to have this determination back to a registered facility within 30 to 60 days after submitting a Top Screen. You may then be notified that you need to complete a Security Vulnerability Assessment (SVA, a CSAT online tool). You also may be notified at this time that you need to develop a Site Security Plan (SSP, another CSAT online tool) along with guidance and timelines. The SSP will need to address 19 risk-based performance standards that DHS has set up. The four risk tiers will have different levels of site security protection requirements. At this time, DHS has not released any information on exactly what the protection requirements will be for each of the four tiers. This is a work in progress.

Important Note: The weights are only for the product and not the package. The weights are only what are in your inventory and not based on the capacity of the storage container.

This is a very complicated program. If you determine that you have chemicals of concern on hand that meet or exceed any of the screening threshold quantities shown in Appendix A, please contact me for help on the suggested next steps.

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT & Security Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at (573) 785-5111 and at MLDSafety@hotmail.com.