DHS Chemical Security Assessment Tool
On April 25, 2007 the Department of Homeland Security (DHS) posted a notice in the Federal Register to let chemical companies know that the first module of the Chemical Security Assessment Tool (CSAT), the registration section, was open for business on the DHS web site. While no one is required to start using the CSAT site until June 8th when 6 CFR part 27 goes into effect, DHS is trying to convince the chemical manufacturing community to begin the registration process before that date.
When fully functional, CSAT will consist of five modules: Registration, Top Screen, Security Vulnerability Assessment (SVA) and Site Security Plan (SSP). Each of these modules is an on line utility that DHS will utilize to collect information on various chemical facilities. It will utilize this information to determine which facilities are at high risk for terrorist attack. DHS has decided to implement this secure on-line tool to collect and analyze this information in order to make the process as efficient as possible.
Companies will be notified of the requirement to enter data into CSAT for their facility by one of three means:
1. Notification by letter that DHS has reason to believe that the
facility might be at high risk for a terrorist attack.
2. Notification by a Notice posted in the Federal Register that a
class of facilities might be at high risk for a terrorist attack.
3. Self-determination that the facility has, or intends to have, on
site a chemical listed in Appendix A, Chemicals of Interest, to
6 CFR part 27, in a quantity greater that the Screening
Threshold Quantity (STQ) listed in that appendix.
Each of the modules in CSAT will be used in sequential order. The Registration module will be used first. This will establish who from the facility will be authorized to enter data into CSAT. Once the registration process is complete, DHS will send a User Name and Password to those individuals. This information will be required prior to entering data in subsequent modules.
On June 8th, DHS will begin notifying chemical facilities that have already been identified as probable high risk facilities by the department that they will have to complete the Top Screen module of the CSAT. While DHS has not said which facilities it intends to notify before Appendix A goes into effect, it is almost certain that facilities with large amounts of chemicals that are Toxic By Inhalation, or are listed as Chemical Weapons or their precursors under the provisions of the Chemical Weapons Treaty will be notified. Within 60 days of being notified those facilities will have to have completed the Top Screen process or face possible fines of up to $25,000 per day for non-compliance.
The Top Screen module has not yet been made public, so there is no current indication of how time consuming that process will be. What is clear is that the registration process for access to the CSAT system will be fairly time consuming because of the requirement to mail (or fax) in the signed registration forms that will be filled out on line. Only after the DHS has signed copies of the forms in their possession will they provide the facility with the required user names and passwords that will be required to enter the other CSAT modules to start the Top Screen Process.
What the department is trying to do with opening up this first module of the CSAT system is to get the registration process started for chemical facilities before they enter into the 60 day Top Screen time limit. The more companies that go through the registration process before prior to June 8th, the more time that will be available for the limited manpower at DCS assigned to this process to be able to spend helping people with Top Screen issues rather than Registration issues.
About the Author: Patrick J. Coyle has 15 years experience with the US Army, including a stint as a Physical Security NCO in Europe. He has also spent 12 years working as a Process Chemist is a specialty chemical manufacturing company.
Further information about the new regulations concerning protecting chemical plants from terrorist attack can be found at http://www.members.aol.com/ChemPlantSec/ChemPlantSecurity.htm
More articles by pjcoyle@aol.com
Print Article | Download PDF | 208 views | May 19 2007
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