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Regulatory Update   |   Oct 7th, 2016 Department of Homeland Security Updates Chemical Facility Anti-Terrorism Standards

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The Department of Homeland Security (DHS) has issued a notice in the Federal Register announcing revisions to its Chemical Facility Anti-Terrorism Standards (CFATS) program, effective in October 2016.

CFATS requirements apply to facility owners and operators that possess, consume, sell, or create various chemicals that could be useful to conducting a terrorist event.

Facilities across all sectors of the US economy may be impacted and subject to upcoming compliance actions. It is important to note that facilities that have submitted Top Screen surveys before will be required to resubmit, even if a facility was previously exempted from CFATS.

Download TRC’s latest Regulatory Update for more information about the changes to CFATS.

Under the revised rule, DHS will introduce this month a new version of its Chemical Security Assessment Tool (CSAT). Regulated companies will be required to resubmit their facility data via this new platform (CSAT 2.0).

Facilities that have submitted a Top Screen survey before, including those that were previously exempt from CFATS requirements, should access CSAT and make sure all User Roles (e.g. Preparer, Reviewer, Submitter and Authorizer) are accurate and up-to-date. This will allow DHS’s initial notification of the CSAT 2.0 roll-out to go smoothly. 

DHS will begin sending notices to individual facilities every two weeks once the roll-out starts. This will include sites that have previously “tiered” out or become exempt. These sites are being included to make sure that the new methodology works as anticipated. Once notified facilities will have 60 days to submit a new Top Screen.

In addition to accessing CSAT to confirm or update user roles, and being proactive regarding resubmittal of data, facilities should review the CFATS regulatory process in detail to fully understand its background and current applicability. Areas of attention should include:

  • Compliance requirements and strategies, including risk-based performance standards
  • Data submission schedules
  • Preparation and submission of Top-Screen reports
  • Performance of Security Vulnerability Assessments
  • Implementation of Site Security Plans
  • Security system design

TRC has assisted over 100 facilities to comply or “exempt out” of the CFATS program over the past 7 years. Our teams include security planning and design staff certified in Chemical-Terrorism Vulnerability Information. With a combination of security expertise and regulatory knowledge regarding hazardous chemicals in the workplace, we provides clients with a holistic solutions for compliance across many overlapping chemical-based rules.

Please download our Regulatory Update or contact us for more information.

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