Chemical security: Steps to protect your business
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August 08, 2018
Chemical security: Steps to protect your business

Dangerous chemicals necessitate adequate security to mitigate risks. If you are a facility with a chemical designated by the U.S. Department of Homeland Security (DHS) as a chemical of interest (COI), you may only have 60 days after taking possession of the COI to initiate a security screening process under the Chemical Facility Anti-Terrorism Standards (CFATS). The CFATS are risk-based antiterrorism standards that identify high-risk chemical facilities to ensure adequate security. The DHS lists over 300 COI in Appendix A of 6 CFR 27, and each has a corresponding screening threshold quantity (STQ). Possession of a COI above the STQ starts the compliance clock for you to initiate the following CFATS steps.

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Register for CSAT access. After you complete the required Chemical-terrorism Vulnerability Information (CVI) training and learn how CVI (e.g., site security plans and vulnerability assessments) is identified and safeguarded, you will register using the Chemical Security Assessment Tool (CSAT). The CSAT is an online portal used to complete the steps of the CFATS process.

Submit a survey and get a risk determination. Using the CSAT, submit your Top-Screen Survey within 60 days of initial COI possession. The Top-Screen Survey provides the DHS with information about your facility and the COIs present. Based on your survey, the DHS determines if your facility is high-risk. High-risk facilities are assigned a tier level of 1 (highest risk) through 4. Facilities that are not high-risk are removed from the CFATS process.

Complete an assessment and submit a security plan. If your facility is tiered, you must submit a Security Vulnerability Assessment (SVA) within 90 days. The SVA includes information on security vulnerabilities, anticipated effects of an attack, and your facility’s security procedures and resources. If the SVA confirms the high-risk determination, you must submit a Site Security Plan (SSP) within 120 days. If the SSP meets all requirements, a Letter of Authorization will be sent to you.

Schedule an Authorization Inspection (AI). Following the Letter of Authorization, a DHS inspector will schedule an AI to verify that the content of the SSP is accurate.

Continue compliance. After a successful AI, the DHS will send a Letter of Approval. DHS inspectors will conduct recurring inspections to ensure your facility continues to fully implement the approved security measures.

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