After completing a top screen, the next step in the process to meet the Chemical Facilities Anti-terrorism Standards (CFATS) mandate for facilities using, making and storing chemicals is to wait for a letter from the Department of Homeland Security (DHS). This letter either lets facilities know that they have "tiered-out" (based on the information collected by DHS the mandates do not apply to them) or they are given a preliminary tier assignment between 1 and 4 with 1 having the most risk.
So far DHS has given a preliminary tier assignment to about 7,000 facilities and approximately 27,000 facilities have tiered-out. Those with a preliminary tier assignment had to move on to the next step which is to submit a Security Vulnerability Assessment (SVA) using the online Chemical Security Assessment Tool (CSAT). The purpose of the SVA is to determine the likelihood of an attack on a facility being successful and the amount of anticipated damage as a result.
Among the things the DHS has asked facilities to do in the SVA include:
- Identify critical assets associated with each COI listed in the tier letter
- Inventory and describe facility security equipment including access control procedures and systems, inventory and shipping and receiving procedures.
Facilities are also asked to look at series of DHS-defined attack scenarios and evaluate the response and consequence of each critical asset/COI combination. These scenarios are based on the characteristics of the COI and the security issues listed in the facility's preliminary tier letter. The facility is then asked to provide an informed judgment on how successful the attack could be and how effective the emergency response would be.
The SVA is a complex process usually requiring a team of professionals and can take several hundred hours to complete. From the date of receiving the preliminary tier letter facilities have the following amount of time to file an SVA
- Tier 1 -90 days
- Tier 2 -120 days
- Tier 3 -150 days
- Tier 4 -180 days
DHS evaluates the SVA once it is submitted and can do one of three things:
- Let the facility know that based on the SVA it is not considered at risk and not subject to CFATS at this time. If the facility's COI inventory changes then it must reevaluate and submit another Top Screen if appropriate.
- Confirm the facility's original ranking
- Change the tier ranking based on the SVA
In the last two cases, the facility will receive a letter from DHS confirming the original or altered ranking. The letter will also include a list of the COIs at the facility that concern DHS and the security issues associated with those COIs. It will also notify the facility managementof the date the Security Site Plan is due to DHS.
As we have said before, DHS has committed to having all final ranking letters by the end of summer for facilities that have submitted Top Screens and SVAs.
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