Frequently Asked Questions: CFATS

What is Appendix A?
Appendix A of the Chemical Facility Anti-Terrorism Standards (CFATS) regulation lists the DHS chemicals of interest and their corresponding Screening Threshold Quantities (STQ). If a facility possesses, or later comes into possession, of a chemical of interest at or above the specified screening threshold quantity, that facility must complete an easy-to-use online consequence assessment tool, known as a Top-Screen.
It is important to note that many facilities that will fill out the Top-Screen may not be subject to further regulation under CFATS by DHS. Appendix A and the Top-Screen will allow DHS to make preliminary determinations about whether facilities present a high level of security risk.

What is the Top-Screen?
The Top-Screen is an easy-to-use online questionnaire that facility owners and operators complete to provide DHS with a basic understanding of the facility’s potential level of consequence. After answering a series of simple questions, DHS will be able to preliminarily determine whether the facility presents a high level of security risk. Not all facilities that complete the Top-Screen will be subject to further regulation by DHS.

Who will be required to complete the Top-Screen and by when?
If a facility possesses a chemical of interest at or above the listed screening threshold quantity, the facility must complete and submit a Top-Screen to DHS. A facility must do so within 60 calendar days of the publication of a final Appendix A or within 60 calendar days of coming into possession of the listed chemical of interest at or above the listed screening threshold quantity.

What kinds of chemicals does Appendix A contain and why?
To determine the type and quantity of chemicals that require a facility to complete the Top-Screen, DHS examined three security issues:

• Release: quantities of toxic, flammable, or explosive chemicals that have the potential to create significant adverse consequences for human life or health if intentionally released or detonated.
• Theft or Diversion: chemicals that have the potential, if stolen or diverted, to be used as weapons or easily converted into weapons, in order to create significant adverse consequences for human life or health.
• Sabotage or Contamination: chemicals that, if mixed with other readily available materials, have the potential to create significant adverse consequences for human health or life.

Why regulate these sites at all?
The recent events in London and Glasgow – in which the terrorists attempted to attack using propane – illustrate how important it is to appropriately secure facilities that possess potentially dangerous chemicals.

Will Appendix A affect college and university laboratories? If so, why?
Yes, some college and university laboratories may be affected. Colleges and universities that meet the Appendix A levels – that is, those that possess Appendix A chemicals of interest at or above the listed screening threshold quantities – will have to complete and submit a Top-Screen to DHS. With the information from the Top-Screen, the department will be able to make a determination as to whether the college or university laboratory might present a high level of security risk and therefore must comply with the substantive requirements of CFATS. Facilities determined by DHS not to present a high level of security risk will drop out of the regulatory program and go no further. DHS anticipates that many academic institutions will likely be found not to present a high level of security risk. Facilities determined by DHS to present such a concern, however, will have to comply with the substantive requirements of CFATS – e.g., preparing a Security Vulnerability Assessment, developing and implementing a Site Security Plan, etc. Because security across academic institutions varies dramatically, the level of measures necessary for each academic institution will likewise vary. While some academic institutions may have security measures in place that will help them meet the applicable risk-based performance standards, some may not, and DHS looks forward to helping those facilities increase their security.

Please contact Florija Ajdari at the UND Safety and Environmental Health Office with any questions or concerns at:
topscreen@und.nodak.edu
Office Phone:  777-3341