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DHS publishes requirements top Screen – Toxic Chemicals
On Friday, June 8, 2007, the Department of Homeland Security (DHS) has published guidelines that organizations need to follow to submit the information screen at the Top DHS Chemical Security Assessment Tool (CSAT). The information presented on this secure website will be Used by DHS to determine if the facility is a high risk chemical facility regulations requiring under 6 CFR Part 27 chemical mechanism of anti-terrorism Standards (CFATS).
The first people who will be required to submit information to Top Module will display facilities previously identified by DHS as probably the high-risk facilities, is based on a circumstance facilities (Being located in an urban area for example) or as a class because of the type of chemical manufacturing (eg chlorine). These organizations will be contacted by letter direct the DHS or by a notice published in the Federal Register.
Two PDF documents are displayed on the page DHS Top Screen instruction: CSAT Top Screen Questions and CSAT Top Screen User Manual. Although these two documents are quite lengthy (80 pages and 66 pages respectively), it is clear that DHS has worked hard to make this effort to collect data as painless as possible. Facilities that will be required to submit Top Module information screen will certainly want to print the document Top questions of the screen and use it to save the information they will required to submit. This will help them collect and organize information in a manner that will be easily accessible when they go online.
For make it easier to enter the necessary data on chemicals of interest, the DHS has taken the 300 + chemicals listed in Annex A and grouped them into nine groups. These groups are:
1. Toxic chemicals,
2. Flammable chemicals,
3. Chemicals explosives
4. IEDs (IEP) of chemical precursors,
5. Weapons of Mass Effect (WME) Chemicals
6. CW / Precursors of chemical weapons (CW / CWP) Chemicals
7. Sabotage Chemical Contamination /,
8. Essential Chemicals mission,
9. Economically Critical Chemicals.
Each of these nine groups of chemicals will require answers to different types of questions based on these types of chemicals. In each category, however, there will be a preliminary list of chemicals in Annex A to this class with Yes and No box next to the chemical industry. The default is No. The applicant tick the Yes box only for Products chemicals on site, or who had been on the site over the past 12 months, and the amount was equal to or greater than the amount of testing Threshold (STQ) listed.
When determining the amount of a chemical is considered the site, the installation author must consider how much is in storage tanks, other containers, process equipment and piping and in cars, both on site and sidings immediately adjacent to the site. If there are documented procedures to limit the quantity on site, they can be taken account. If there are no documented procedures, the maximum amount possible in the different containers are used to determine how measure may be on the site.
The Top Screen orientation introduces another concept that they use to assess risks associated with chemicals on the site, the AHQ (Area of highest amount). The AHQ tries to take into account the fact that if a chemical is distributed a large area in a facility, it will probably be less risk during a terrorist attack, because it will be difficult to release all the chemicals. To determine the AHQ you must determine where the greatest concentration of chemical in a circle with a Diameter of 170 feet. Thus, if There were a number of storage tanks on site but were scattered you need to use the largest tank or combination of tanks that would be in a single circle 170 feet in diameter to determine the amount AHQ.
There are 50 chemicals listed on the special list of chemicals toxic. DHS has selected these 50 chemicals to be on the list of toxic chemicals because DHS believes that, if released, they have the potential for significant Acute adverse consequences to human life or human health. To assess the level of risk these chemicals pose in DHS facilities particular situation using a process similar to that of the EPA Risk Management Program (RMP) worst-case assessment. This requires information additional installation in General and for each chemical on the site that are reported. This information includes:
1. Topography the area where the facility is located (urban / rural).
2. Total (maximum) quantity on site.
3. Distance concern of the EPA RMP * Comp simulator for the chemical.
4. Quantity AHQ
5. Distance concern for the quantity AHQ.
This will be a process very Long to complete all the information at the top of the screen, but it will not be done in one sitting. Incomplete information will be saved between multiple sessions. Many institutions will not have to complete the entire process 80 page. There are many places where The responses to various issues, the top screen will notify the author that the installation is not plant high-risk and no further action is required under 6 CFR part 27 to the system modifications. Some institutions will be informed at the End of the argument that they are temporarily designated a high risk facility and must complete an assessment of the security vulnerability (VAS) in 90 days. Most institutions, however, must meet all the Top of the screen to be told that they could be declared installation of a high risk, but this decision will be Made after further notice to DHS. These facilities will wait for a letter telling them that the preliminary future will be.
About the Author
Patrick J. Coyle has 15 years experience with the US Army, including a stint as a Physical Security NCO in Europe. He has also spent 12 years working as a Process Chemist is a specialty chemical manufacturing company.
Further information about the new regulations concerning protecting chemical plants from terrorist attack can be found at http://www.members.aol.com/ChemPlantSec/ChemPlantSecurity.htm
DHS Top Screen Guidelines: http://www.dhs.gov/xprevprot/programs/gc_1169501486197.shtm
February 17th, 2010
Cedrick
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