On November 20, 2007 the Department of Homeland Security published the final Appendix A in the Federal Register. The deadline in the Chemical Facilities Anti-Terrorism Standard (CFATS) interim final rule for submission of "Top Screens" is January 19, 2008.
On April 9, 2007, the US Department of Homeland Security (DHS) issued the Chemical Facility Anti-Terrorism Standards (CFATS). Congress authorized and directed DHS to identify, assess and ensure effective security at high-risk chemical facilities. Program details are outlined in the Federal Register Part III, Department of Homeland Security, 6 CFR Part 27, Chemical Facility Anti-Terrorism Standards; Final Rule.
Identify: In order to identify high-risk chemical facilities, DHS developed the Chemical Security Assessment Tool (CSAT) which consists of 4 parts: CSAT Registration, CSAT Top Screen, CSAT Security Vulnerability Assessment and CSAT Site Security Plan. The CSAT Top-Screen consists of a questionnaire and list of DHS Chemicals of Interest. Any facilities that have identified chemicals at or above the listed Screening Threshold Quantities (STQ) will have to complete and submit the CSAT Top-Screen.
Assess: Based on the results of the CSAT Top-Screen, DHS will place facilities into Tiers 1 - 4. Those in Tiers 1 - 3 will be required to complete a CSAT Security Vulnerability Assessment (SVA). Those in Tier 4 may submit a CSAT SVA or and Alternate Security Plan.
The facilities must then develop a CSAT Site Security Plan (SSP) which meets the corresponding Risk Based Performance Standards (RBPS) that have been developed for each of the Tiers. Those in Tiers 3 and 4 may submit an Alternate Security Plan in lieu of the CSAT SSP.
Ensure Effective Security: DHS will review and approve the Site Security Plan (SSP). The SSP describes the security measures (both physical and procedural) in place as well as the measures a facility plans to implement in order to fulfill the applicable RBPS. DHS will then inspect high-risk chemical facilities at regular intervals or on an as needed basis.
Penalties: The Act authorizes DHS to enforce compliance with the security regulations, including conducting audits and inspections of high-risk facilities, imposing civil penalties of up to $25,000 per day, and shutting down facilities that fail to comply with the regulations.
ARM Services:
- Process Compliance and Planning Services
- Review CSAT Top Screen
- Prepare CSAT Security Vulnerability Assessment (SVA)
- Prepare CSAT Site Security Plan (SSP) based on applicable Risk Based Performance Standards
- Prepare Procedures for Chemical-Terrorism Vulnerability Information (CVI) assurance
- Conduct Pre Inspection Reviews and Audits
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