As I have mentioned before, about 34,000 facilities have submitted "Top-Screens" to the Department of Homeland Security (DHS) to determine if their facility is considered at risk and subject to the Chemical Facility Anti-Terrorist Standards (CFATS). So, many companies and facilities are already very familiar with a Top-Screen and what it entails. For the uninitiated, I thought I would give a quick overview of what a "Top Screen" is with some general background on how it works.
Many chemical facilities were notified by DHS that they needed to conduct a Top-Screen. But the lack of notification does not necessarily mean that your organization is off the hook - the CFATS mandate may still apply. If your facility uses, makes or stores any of the Chemicals of Interest (COIs) in quantities above a STQ (Screening Threshold Quantity) as determined by DHS you will need to conduct a Top-Screen. The COIs and thresholds are listed in Appendix A of the CFATS legislation and are posted online.
DHS developed an online tool called the Chemical Security Assessment Tool (CSAT) to help facilities and businesses maneuver through the CFATS process - from company registration to a template for the final Security Site Plan. Company registration is the first step in the process followed by the Top-Screen whichis a series of questions to help determine if your facility is at risk. The questionnaire asks about your facility and the chemicals it manufactures, uses and stores.
Do remember that the person filling out the Top-Screen questionnaire must be Chemical-terrorism Vulnerability Information (CVI) authorized. I will devote another blog to this, but it means someone who has had training by DHS on the handling of sensitive material and information. Once the Top-Screen questionnaire is completed it is submitted online to DHS. The Top-Screen information is part of what is used to determine if the facility is at risk and needs to comply with the CFATS mandates.
Top-Screens were supposed to be completed and submitted to DHS by January 22, 2008. But, as we have mentioned before, industry experts believe there are many companies out there that may not realize they are subject to the mandates. DHS has estimated in the past that it expects as many as 45,000 Top-Screens to be submitted by the time the process iscompleted.
Ryan Loughin is Director of Petrochemical & Energy Solutions for the Advanced Integration division of ADT- Petrochemical Security - ADTBusiness. He provides security education to CFATS and MTSA-affected companies and is a member 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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