The Chemical Facility Anti-Terrorism Standards - typcially referred to as CFATS - was published on April 9, 2007 to address security concerns of commonly available chemicals to domestic or foreign terrorists.
The US Department of Homeland Security (DHS) estimated that 60,000 to 70,000 facilities from all sectors of the economy will conduct threshold risk screenings under the CFATS. However less than 5000 facilities are expected to be required to perform a subsequent risk assessment and compile and implement a site security plan.
The initial DHS on-line questionnaire known as Top Screen was to be submitted by the owner/operator of a facility with inventories threshold amounts of Chemicals of Interest (frequently referred to as "Appendix A.") on or before January 22, 2008.
Ag Related Facilities Deadline Extended Indefinitely
NOTE: If your facility is agricultural related including farms (e.g., crop, fruit, nut, and vegetable); ranches and rangeland; poultry, dairy, and equine facilities; turfgrass growers; golf courses; nurseries; floricultural operations; and public and private parks - the deadline for submitting your Top Screen assessment has been submitted indefinetly. Review the letter if you believe you qualify for this exemption.
Commerical fuel distributers and/or commerical ag chemical applicators DO NOT qualify for this exemption.
The Chemicals of Interest (COI) list can be displayed by clicking on the hyperlink to the right. A link to the CFATS frequently asked questions (FAQs) and responses is also provided.
Based on experience in North Dakota, the following Appendix A chemicals will frequently trigger CFATS registration requirements in our state. This list is not complete and facility owner/operators are responsible to review the entire Appendix A list for impact to their site, especially pesticide dealers, since these chemicals are not included below. Common Chemical NameThreshold Acrolein / Mag-M (>1% concentration)5,000 lbs / 755 gal Ammonium Nitrate (> 23% nitrogen)2,000 lbs Anhydrous Ammonia (>1% concentration) 10,000 lbs / 1750 gal Chlorine (>1% concentration)500 lbs /38 gal Hydrogen Sulfide (>1% concentration)45 lbs / 6 gal Liquidified Petroleum Gas/Propane60,000 lbs / 14,200 gal Light Naphtha (pentane and butane)10,000 lbs / 1930 -2100 gal Potassium Permanganate400 lbs
If you have storage capacity at or above these threshold levels, the next step is to obtain a user ID on their website as soon as possible.The websitehttps://csat-registration.dhs.gov/dana/home/index.cgi will require you to enter the typical user specific information.Users need to apply for one or more of three roles – “preparer” or “submitter” or “authorizer.” The authorizer needs to be a corporate officer or owner of the facility.A consultant can prepare the information but may not submit it or authorize it.These roles must be satisfied by an employee and/or corporate officer/owner of the facility.A single user can act on behalf of more than one site.Time to obtain a user ID has reportedly taken anywhere from 2 hours to 2 weeks.
A hardcopy of the Top Screen questionnaire is 111 pages long.Much of the questionnaire will not apply to simple facilities – but it typically requires 2 to 4 hours to enter the data once a system ID has been assigned.Besides street address information, the facilities DUN number, EPA RMP Facility Identification number (note: not required for LPG sites), site GPS coordinates (i.e. latitude and longitude) is also required.We suggest the facility submitter review a copy of the Top Screen questionnaire and compile as much information necessary in advance of data entry.
A hardcopy of the Top Screen questionnaire can be viewed and/or printed from the link to the left. Facility owners may want to print out and compile the information in advance to submitting the information on-line.
Once the information has been submitted, the DHS will compile the initial information and assign each facility to one of 4 "tiers" of risk. The lower the number, the higher of risk level assigned. This classificaion is similar in design to the approach the US EPA took to assigning risk of release to facilities in their Emergency Planning and Community Right-to-Know (EPCRA) program. Some facilities also refer to this existing EPA program as SARA III.
The DHS will notify a facility of its initial risk based tier in writing. If classified in any of the highest three tiers (i.e. 1, 2 or 3), then facilities must use the Security Vulnerability Assessment (SVA) tool developed by DHS. Tier 4 facilities will have the option of using this tool, or another approved alternative tool. Eventually a Site Security Plan (SSP) will need to be developed and submitted for approval by the US Department of Homeland Security, including a on-site inspection by DHS staff. Physical security measures, including fencing, as well as 18 other aspects of security will eventurally be implemented at facilities.
