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  • Writer's pictureTom Petersen

Homeland Security Deadline Fast Approaching

Updated: Aug 29, 2023

On Tuesday, November 20, the final Appendix A to the Chemical Facility Anti-terrorism standards (CFATS) was issued in the Federal Register by the Department of Homeland Security (DHS). Facilities that possess greater than the Screening Threshold Quantity (STQ) of any listed chemical must register and file with the Department of Homeland Security using Top Screen, the DHS online tool by mid January 2008.

This topic was an article in our November post. This month we focus on the Top Screen report due in January. The data required in this report is summarized below. Because this report could potentially require data from a number of departments at your facility, we strongly recommend that you begin the data preparation NOW.

Facility data: address, NAICS code(s), location (latitude & longitude), capacity, etc. Classification type questions: affiliation with Department of Defense/Energy, Public works, co-located with other facilities, airline fuel supplier, etc.

Security Vulnerability Assessment: If your facility has completed one, you will need to supply some basic information from that assessment.

Chemicals of Interest (COI): The facility will need to identify what COIs it has at the facility and report the following:

– For COI(s) the facility manufactures, processes, uses, stores or distributes, the facility will need to determine if it is above screening threshold quantity and if so gather and report the following data: Release Toxic COIs: Report the Total On-site Quantity and the distance of concern for toxic COIs. The distance of concern can be calculated using EPA’s RMP*Comp software.

Release Flammable & Explosive COIs: Report the total On-site Quantity and the Area of Highest Quantity (AHQ). This is defined as an on-site area, with a radius of 170 feet, where the greatest aggregate amount of all release flammable/explosive COI is either currently present or has been present at any time in the past 60 days.

– Sabotage/Contamination COIs: Identify COI(s) the facility ships or has shipped in the last 60 days in a placarded amount.

Mission Critical Chemicals: Report chemicals that your facility produces more than 20% of the total domestic production that also supply critical infrastructure. Various data are required here, including cost and production data, such as annual production, replacement costs, and estimated domestic market share,

Economically Critical Chemicals: Report chemicals where your facility produces 35% or more of the domestic production. Various data are required here, including cost and production data, such as capacity utilization rates, replacement costs, and estimated domestic market share.

If you have specific questions about the regulation and the final Appendix A, feel free to contact us. We would be happy to assist your facility in the submission and the development of the plans outlined in the CFATS regulation.

Number 45 part 1



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