Chemical Facility Anti-Terrorism Standards (A Primer)

Any facility that comes into possession of any Chemical of Interest (COI) listed on the CFATS Appendix A above the Screening Threshold Quantity (STQ) must complete and submit a Chemical Security Assessment Tool (CSAT) called “Top-Screen.”

All facilities should review COI Appendix A list for applicability?

After reviewing the Top-Screen, Department of Homeland Security (DHS) makes a formal determination on the risk level of the subject facility. Facilities deemed a “preliminarily high risk” by the DHS are notified to conduct and submit a Security Vulnerability Assessment (SVA). Based upon the review of the SVA, DHS decides if the facility is still a high risk and assigns a final tier (Risk level) to the facility. Based upon the Risk Level of the facility, it is required to complete a site-specific Site Security Plan (SSP) which must be tailored to its risk level, security issues, risks, and circumstances.

Only authorized Chemical-terrorism Vulnerability Information (CVI) users can work on the SSP. During the SSP development and/or update, the information subject to DHS/CFATS must be disclosed on a “need to know” basis.

Security Plans can take months to complete and are costly to implement!

Unauthorized release of the SSP can be subject to civil penalties. Once the SSP is submitted to the DHS, the DHS inspects the facility before accepting the SSP. The DHS inspects high-risk chemical facilities at regular intervals and SSP are required to be renewed every three years.

Violations of CFATS regulation can be very costly, up to $25,000 per day, and can impact day-to-day operations. Contact Sam Joshi, P.E. at (215) 389-2811 if you have any questions.