Chemical Facility Anti-Terrorism Standards
By: Lee Stone

Since the 9/11 terrorist attack on America many changes have been made to protect Americans against future attacks. One of these changes involves legislation that impacts the IUPUI campus.

The Department of Homeland Security (DHS) has published The Final Rule and Appendix A of the Chemical Facility Anti-Terrorism Standards (CFATS) in the Federal Register on November 20, 2007.

The list (Appendix A to Part 27 of Title 6 of the Code of Federal Regulations) categorizes chemicals by their risk—release, theft and sabotage. IUPUI will be required to complete and submit an online consequence assessment tool called Top-Screen if we possesses any chemical in appendix A in amounts greater than the Screening Threshold Quantity (STQ). The Top-Screen must be submitted within 60 days of publication of the Final Rule and Appendix A, which will make the deadline for Top-Screen submission January 19, 2008.

To determine the type and quantity of chemicals that will be subject to the preliminary screening process, DHS examined the following three security issues:

1. Release – quantities of toxic, flammable, or explosive chemicals that have the potential to create significant adverse consequences for human life or health if intentionally released or detonated.
2. Theft and diversion – chemicals that have the potential, if stolen or diverted, to be used or converted into weapons.
3. Sabotage and contamination – chemicals that, if mixed with other readily available materials, have the potential to create significant adverse consequences for human life or health. The department identified these chemicals in the specific amounts for preliminary screening based on their potential to create significant human life or health consequences.

Appendix A lists approximately 300 chemicals of interest and includes common industrial chemicals such as chlorine, propane and anhydrous ammonia as well as specialty chemicals such as arsine and phosphorus trichloride.

When you review Appendix A you will notice that there are several chemicals that we obviously do not posses sufficient quantity to trigger a Top-Screen, however, 26 chemicals have STQs of 100 grams and some chemicals have a “placarded amount” STQs, which is any amount for 21 chemicals.

To comply with this new rule, we must rely on each individual laboratory to supply Environmental Health and Safety (EHS) with information on the quantities of the chemicals listed in Appendix A that they may have in their laboratory. EHS is creating a refined list of chemicals from Appendix A that are applicable because of the possibility of exceeding the STQ on campus, while removing the chemicals that are not applicable because of the high STQ level . Once this list is compiled, we will create an on-line submission form that each lab can use to identify if they have any of the chemicals on the list, and if so, how much.

Please keep an eye out for more information as it becomes available. Once we have everything in place, we will notify the Laboratory Safety Coordinators and departments with laboratories of the inventory submission process.

I realize that this may be a time consuming process, but it is a requirement that we must meet and if we all work together, we can make the process as painless as possible. For more information on chemical security or to view the Appendix A final rule of CFATS, please visit www.dhs.gov/chemicalsecurity.