Department of Homeland Security Chemical Facility AntiTerrorism Standard CFATS Impact on Washington

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Department of Homeland SecurityChemical Facility
Anti-Terrorism Standard(CFATS)Impact on
Washington UniversityBruce BackusEnvironmental
Health SafetyNovember 29, 2007
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Department of Homeland Security (DHS)Chemical
Facility Anti-Terrorism Standard

• Purpose is to prevent chemicals that have
  historically been used for terrorist or mass
  casualty incidents from falling into the wrong
  hands
• First phase all companies, including colleges
  and universities, must screen all their chemicals
  for 325 specific compounds and report to DHS if
  they exceed certain thresholds
• Some thresholds are any amount and some are 100
  grams cumulative total for the whole institution.
• Final Rule published on November 20, 2007
• 6 Code of Federal Regulations (CFR) Part 27

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Chemical Facility Anti-Terrorism Standard Timeline

• There is a very short deadline for doing the
  inventories and submitting required documentation
  to DHS
• Facilities have 60 days to complete the initial
  chemical screening process
• Due January 18, 2008
• The 60 days must include the 40-60 hours needed
  for Environmental Health and Safety (EHS) to
  complete the DHS Top Screen paperwork
• This requires submittal of screening results by
  departments to EHS by January 4th 2008.

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Chemical Facility Anti-Terrorism Standard Timeline

• We are requesting a 60 day extension
• Maximum extension allowed under the regulation
• If the extension is granted, inventory results
  from departments would be due to EHS by March 7,
  2008
• Until WU is granted an extension from DHS, the
  internal deadline for all departments to send
  completed screen inventories to EHS shall be
  January 4, 2008
• If an extension is received, an announcement will
  be sent all departments letting them know the new
  reporting deadline is March 7, 2008

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What we need from you and your department(s)

• Visit EHS website
• http//ehs.wustl.edu/cfatsrule.htm
• Lab, clinic, shop, art and facilities managers
  (anyone who has chemicals)
• Compare their current chemical inventory to the
  list of 325 chemicals of interest (Appendix A
  list)
• If you have any of the 325 chemicals, complete
  the Chemical Inventory Tool
• (coming to the web page on December 5, 2007)
• Business Managers or persons designated by Dean,
  Director or Department Head
• Confirm all inventories have been reviewed and
  that Chemical Inventory Tool information is
  submitted by January 4, 2008

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Information Collected by the Chemical Inventory
Tool

• Chemical names
• Concentrations
• Quantities
• Locations (Campus, building and room ).
• Responsible person for the chemicals or chemical
  storage area
• Contact information

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Potential Non-Compliance Consequences

• DHS has identified that potential fines for
  violating the Chemical Facility Anti-Terrorism
  Standard could result in civil penalties up to
  25,000 per day and shutting down facilities
• DHS has trained third party inspectors and
  inspections are already underway

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Where do you go for more information?

• http//ehs.wustl.edu/cfatsrule.htm
• Linda Vishino, EHS Environmental Compliance
  Officer
• vishinol_at_wustl.edu
• 935-7864
• Fax [phone]

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• QUESTIONS?