Question

For the facility described in !!!, you have been notified by the U.S. Department of Homeland Security that your facility is a “covered” facility in a high risk tier. List and briefly explain the actions you need to take to fully comply with CFATS? Please note, a complete response to this question requires listing each of the rules you need to review and a brief explanation of how you determined the appropriate actions you must take to keep the facility in compliance. (approximately 100 words) cite your sources

!!!) You are the EH & S manager or Environmental Engineer for a facility that uses more than 500 different chemicals at your manufacturing plant. The Plant Manager has assigned you the responsibility of maintaining full compliance with all environmental, emergency planning/preparedness, and occupational safety and health requirements. Explain the first step in the process of determining the compliance requirements under CFATS for your facility.

Answer 1

Compliance with CFATS takes place in four stages:

I. Stage One: Top Screen

The purpose of the Top Screen is to evaluate all facilities housing quantities of potentially hazardous chemicals in an effort to develop a ranking on their relative risk. All facilities that used, manufactured, stored or handled any of the roughly 322 COIs in quantities above DHS-defined threshold limits must submit a CFATS Top Screen. The Top Screen gathers information on the type and quantity of chemicals used, stored, manufactured or handled by the facility. If the facility does not have these chemicals above the threshold, then the facility is not subject to CFATS. The Top Screen essentially evaluates the potential worst-case consequences if an incident were to take place at the facility.

The Top Screen is completed online at a DHS secure website known as the Chemical Security

Assessment Tool (CSAT). The facility answers questions about the quantity, location, phase

and concentration of any of the COIs that they have had on-site during the past 60 days. In

addition, COIs that have been identified as having a Release-based Security Issue undergo further

evaluation. This evaluation uses U.S. EPA release tools to calculate the distance from the facility

that might be impacted by a release of the COI.

There are two possible results from the Top Screen. DHS may determine that the worst-case

consequences resulting from an incident at the facility do not reach the level classified as High Risk. These facilities receive a letter that informs them that they are not subject to CFATS at this time. (However, if the facility’s inventory of chemicals changes, the facility must reevaluate its need to submit a revised Top Screen and do so as required.)

If DHS’s analysis of the worst-scenario consequences do reach a level at which the facility is considered High Risk, the facility receives a letter communicating this status along with the following information:

• The names of the COIs that concern DHS.

• The Security Issues associated with these COIs (Security Issues are categorized as Release, Theft/Diversion, and Sabotage).

• The due date by which the facility must complete the next step in CFATS compliance (the submittal of a Security Vulnerability Assessment).

• The facility’s preliminary Tier ranking (1, 2, 3 or 4; DHS has divided High-Risk facilities into 4 tiers of decreasing risk.

Tier

1

is

the

highest

risk,

Tier

4

is

the

lowest

of

the

high-risk

rankings.

See

Figure

1)