I believe the acronym CFATS (Chemical Facility Anti-Terrorism Standards) can be misleading. Some people might think that the mandate is just for chemical and petrochemical manufacturing and processing plants. But CFATS can affect any business or facility that manufactures, processes or stores chemicals. That means it can affect everything from a large petrochemical plant to a pharmaceutical manufacturer or a papermill.
Your facility could fall under CFATS mandates if it uses, makes or stores any of the more than 300 chemicals identified by DHS (Department of Homeland Security) in quantities above the thresholds set by the department. That means that the mandate can apply to research and healthcare facilities, agriculture and food processing plants and electronics manufacturers to name a few.
Just about 34,000 facilities submitted Top Screens to DHS and of those it is estimated that the department has or will notify roughly 6000 facilities that they are at risk and must ultimately submit and implement a SSP (Site Security Plan). But, many people in the industry believe that there are many more facilities that may fall under CFATS mandates and that people managing the facilities may not realize it.
There are some industries and facilities that are exempt from CFATS by DHS. They include the following:
- Facilities regulated under the Maritime Transportation Safety Act (MTSA) of 2002
- Public water systems, as defined in the Safe Drinking Water Act
- Water treatment facilities as defined in the federal Water Pollution Control Act
- Facilities owned or operated by the Department of Defense or the Department of Energy
- Facilities subject to regulation by the Nuclear Regulatory Commission (NRC)
If your facility manufactures, stores or uses chemicals it is important to double check if CFATS applies to you. DHS lists the COI (Chemicals of Interest) and STQs (Screening Threshold Quantity) online, so it is easy to check.
RyanLoughin is Director of Petrochemical & Energy Solutions for the Advanced Integration division of ADT- http://www.adtbusiness.com/petrochem. He provides security education to CFATS and MTSA-affected companies and is amember of the National Petrochemical and Refiners Association (NPRA), Society of Chemical Manufacturers and Associates (SOCMA), Energy Security Council (ESC) and American Society for Industrial Security (ASIS). Loughin has also completed multiple levels of CVI Authorized User training (Chemical- Terrorism Vulnerability Information) which was authored by the U.S. Department of Homeland Security.
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