Department of Homeland Security DHS Chemical Facility AntiTerrorism Standards CFATS

1
Department of Homeland Security (DHS) Chemical
Facility Anti-Terrorism Standards (CFATS)

• Michael Lonon, EHS
• Manager Hazardous Materials

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Background

• Congress tasked DHS with creating this rule on a
  very short timeframe
• Original DHS proposal did not seem to apply to
  Universities
• Final CFATS rule included a proposed list of
  chemicals that makes the rule apply to us.
• University organizations commented/lobbied and
  got some changes
• The real final rule and chemical list (issued Nov
  20, 2007) requires Cornell to inventory certain
  chemicals

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What CU has to do

• DHS requires us to inventory for their chemicals
  of concern and report any above assigned
  thresholds by March 19, 2008.
• If DHS decides CU is a facility of concern, we
  will have to conduct a Security Vulnerability
  Assessment and establish a Security Plan

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What CU has to do

• Develop an inventory tool
• Inventory for certain chemicals
• Decide how to break CU down into facilities

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What CU has to do

• If we trigger a reporting threshold
• Assign DHS roles to CU staff
• Register for the DHS tool
• Request an extension (Senior Administration)
• Complete the DHS Top-screen on-line

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What CU has to do

• If DHS deems CU to be a high risk facility
• they may require CU to ether
• Submit an Alternate Security Plan (within 90
  days)
• Or
• Conduct a Security Vulnerability Assessment
  (within 90 days) and a
• Site Security Plan (within 120 days)

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The Inventory Process

• In development now
• Inventory will be via a web based interface
• Labs will have to inventory for 200 chemicals
• Most inventory chemicals will be for Original
  Manufacturers Containers only

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Chemicals of Concern

• Release concern
• Toxic
• Flammable
• Explosive
• Theft concern
• Chemical Weapons
• Mass Effect Weapons
• Explosive/IED
• Sabotage concern

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186 Release chemicals

• (Labs are exempt from this category)
• 49 Toxic release chemicals
• Any pure chemical on the list, or comprising gt1
  of a mixture with gt10mmHg partial pressure
• 88 Flam release chemicals
• All fuel tanks must be included
• Any pure chemical on the list, or comprising gt1
  of a mixture with Boiling Point lt76F and Flash
  Point lt100F
• 49 Explosive release chemicals - CU shouldnt
  have these outside of labs

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161 Theft Chemicals

• (must inventory everywhere)
• Containers that are DOT transportation containers
• 55 gal drums
• 5 gal pails
• Gas cylinders
• Palletized quantities
• Tote containers
• And Original manufacturers containers
• Note - 26 theft chemicals are chemical weapons
  with a cumulative threshold of 100 grams.

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60 Sabotage Chemicals

• Must be shipped or transported by the University
  above the threshold quantity
• Not part of this campus inventory

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Core Timeline

• Inventory Tool Development Dec 3 - Jan 11
• Announce Inventory Dec 7 - Jan 11
• Conduct Inventory Jan 14 - Feb 22
• Evaluate Data Feb 25 - Mar 7
• Facility Evaluation March 10 14
• Complete DHS Top Screen March 17 - 19

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Need a few Volunteers

• Dec 17th-21st
• Test and provide feedback on user interface for
  the inventory tool
• Jan 7th-11th
• Test data entry
• Contact Michael Lonon ML107 or 5-6995

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Other Inventory Activity

• EPCRA (Emergency Planning Community Right to Know
  Act) inventory will be conducted at the same time
  (mostly affects facilities contacts)
• Every effort will be made to avoid duplication of
  effort.

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Who will be working on this?

• EHS
• ECOS
• CU Police
• Emergency Management
• ORIA

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• Questions?