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The Department of Homeland Security (DHS) requires any facility that has manufactured, used, stored, or distributed chemicals listed in the "
6 CFR Part 27 Appendix A - DHS Chemicals of Interest" at or above the screening threshold quantity (STQ) to submit an Internet-based "Top-Screen" analysis using the DHS Chemical Security Assessment Tool (
CSAT).
The "DHS Chemicals of Interest" consists of over 400 chemicals, including:
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Nitric Acid - 2,000 pounds
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Hydrochloric acid (>
37%) - 11,250 pounds
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Isopentane - 7,500 pounds
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Butane - 7,500 pounds
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Anhydrous Ammonia - 7,500 pounds
DHS estimates approximately 40,000 facilities will need to complete the initial Top-Screen user registration. Within 60 calendar days of the finalization of Appendix A or the facility coming into possession of any Chemical of Interest
at or above the STQ, a Top-Screen must be submitted.
The following steps need to be taken in order for a facility to submit a Top-Screen Analysis:
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Determine if they maintain any chemical above the STQ;
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If above the STQ, then the facility must:
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Identify a Preparer, Submitter and Authorizor;
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All of those people must receive Chemical Terrorism Vulnerability Information (
CVI) Training;
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The facility must be
registered to use the CSAT Top-Screen Software; and
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Once a facility is registered, the Top-Screen must be prepared, authorized and then submitted.
Once DHS reviews the Top-Screen, the facility will be categorized into one of four tiers by DHS (Tier 1 highest to Tier 4 lowest). Facilities that are determined to represent a "High Risk" will notified by DHS if it must evaluate the 19
elements of vulnerability and complete a Security Vulnerability Assessment or if the facility can develop an Alternative Security Program.
The DHS will oversee the facility's development of acceptable layering of measures used to meet the standards of the risk-based tier assigned to the facility. The facility will need to develop appropriate countermeasures and policies to
meet DHS risk standards and complete a Site Security Plan. DHS will assign an agent to work with each facility to develop a schedule to implement site-specific measures.
Failure to complete a CSAT Top-Screen within the timeframe provided may result in civil penalties of $25,000 per day.
If you have any questions regarding this requirement,
please contact Christopher Mazur
(email)
or Jesse Zahn, CHMM
(email)
at 1-888-823-6427.
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