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The Department of Homeland Security (DHS) promulgated the Chemical Facility Anti-Terrorism Standards (CFATS) on April 9, 2007. This rigorous new program was designed to secure the nation's chemical infrastructure by identifying high risk chemical facilities and requiring them to implement risk-based performance standards (RBPS) and other requirements. Facilities that manufacture, use, store or distribute the following types of chemicals can expect to be covered by the new requirements:
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RMP Chemicals |
CFATS Acronym List  |
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Explosives |
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Poison inhalation hazards |
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Chemical weapon and IED precursors |
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Water reactives |
Does This New Regulation Apply to Your Facility?
| Facilities with such chemicals at or above screening threshold quantities and are not otherwise exempted must register and submit a “Top-Screen” consequence questionnaire through the secure DHS Chemical Security Assessment Tool (CSAT) web site. The list of chemicals and threshold quantities are contained in Appendix A of the rule. Appendix A was posted to the DHS website on November 7, 2007 and was published in the Federal Register on November 20, 2007. Facilities had 60 days from the date of publication to submit their Top-Screen (due date November 22, 2008). If your facility is required to submit a Top-Screen you should register to get a user ID and password. If you haven't completed your facility registration, you may find the DHS Registration Users Guide helpful. AcuTech can also provide assistance to facilities to prepare and complete their Top-Screen. |
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DHS evaluates Top-Screen submissions to identify, by Tier, those facilities that will be required to:
Prepare and submit a Security Vulnerability Assessment (SVA) using CSAT-SVA (Tiers 1,2,3) or alternate (Tier 4)
Prepare, submit, and implement a Site Security Plan (SSP) to address both the SVA and applicable risk based performance standards (RBPS)
DHS will review the submissions and follow-up with site inspections before issuing final approvals. DHS may request revision and resubmission of the SVA and site security plan to assure that they adequately meet the requirements of the new rules. Noncompliance may result in fines and even facility shut-down.
CVI Training Required
The information submitted to DHS for the Top-Screen (and subsequent submissions) will be protected as Chemical Terrorism Vulnerability Information to prevent release to the public. DHS has posted the Chemical-Terrorism Vulnerability Information (CVI) user training on its web site at http://www.dhs.gov/xprevprot/programs/gc_1181835547413.shtm . Anyone who is required to submit a Top-Screen needs to go through the on-line CVI training (takes about 30 minutes). All AcuTech staff have completed CVI training are prepared to assist facilities with submissions.
CSAT-SVA and Tiering Assignments
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DHS released Tiering assignments the week of June 24, starting the clock on CSAT-SVAs. Over 7,000 facilities were sent an assignment of Tier level 1 through 4. Approximately 25,000 facilities have been tiered out of the program and will not need to submit further information. Facilities in Tiers 1-4 will need to submit a CSAT-SVA via the on-line DHS tool according the the following schedule:
Tier 1 219 Facilities 90 Days
Tier 2 756 Facilities 120 Days
Tier 3 1,712 Facilities 150 Days
Tier 4 4,319 Facilities 180 Days
DHS will review the CSAT-SVA submissions then finalize the Tier assignments for site to then submit a site security plan (SSP).
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AcuTech Uniquely Qualified to Assist Facilities
AcuTech can assist sites with preparing the SVA and SSPs. AcuTech provided subject matter expertise to the Department of Homeland Security (DHS) in the development of the new CFATS regulation. AcuTech was a prime contractor for the CCPS Guidelines document for analyzing security vulnerability at chemical sites. In addition, AcuTech developed the API/NPRA SVA Methodology, and has been selected as the exclusive API provider for SVA and Facility Security Officer (FSO) training. We offer a full spectrum of security related services including complete CFATS compliance strategies assistance, Security Vulnerability Assessments, security plan development, CFATS and SVA training and software for SVAs (SVAPro).
AcuTech is the market leader in conducting SVAs and is recognized by industry and government agencies as a subject matter expert in security. Our staff includes recognized experts in the field with both industry and government security experience. We have assisted numerous companies in developing security management systems as well as security and safety regulatory programs, including sites subject to the NJ State Prescriptive Order.
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