Transcript Respirator Standard Photos

U.S. Department of
Homeland Security
Chemicals of Interest
Anti-terrorism Standard
Overview of the
Proposed Program as
it applies to
Fox Chase Cancer
Center
What is the Standard?
[ as of November 20, 2007]


Interim Final Rule that imposes
comprehensive federal security regulations
for “high risk” “chemical facilities”.
Requires “covered facilities” to prepare
Security Vulnerability Assessments and
develop and implement Site Security Plans.
Authorizing Legislation

This regulation is authorized by the
Department of Homeland Security
Appropriations Act of 2007 (Public Law
109-295, Section 550) [The Act].
What is the Standard?

Final Rule was published in the Federal
Register on December 20, 2007 and
becomes effective 60 days after, January
17, 2008.
Important Definitions

CHEMICAL FACILITY
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HIGH RISK
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COVERED FACILITY
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TOP-SCREEN PROCESS
Chemical Facility AntiTerrorism Standards
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The Department of Homeland Security
(DHS) has issued Chemical Facility AntiTerrorism Standards for any facility that
manufactures, uses, stores, or distributes
certain chemicals above a specified
quantity. The standard may apply to
hospitals and research institutions
and you may have to file a report to
DHS by 1/19/08.
Chemical Facility AntiTerrorism Standards

On November 20, 2007 DHS published an
updated Appendix A to this standard
identifying nearly 300 chemicals that
present a security risk. If a facility
possesses amounts of a chemical at or
above the threshold quantities specified in
this inventory, they are required to fill out
the “Top-Screen” questionnaire within 60
days of the publication date of 11-202007. There are three security issues
involved:
Chemical Facility AntiTerrorism Standards
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To assist you in the assessment of your
chemical inventory, ASHE has converted
the inventory list into an excel
spreadsheet that can be used as a tool to
determine your facility’s status with regard
to this Standard.
available at
http://www.ashe.org/ashe/codes/legislativ
eissues.html.
Chemical Facility AntiTerrorism Standards

If there are no chemicals present in a
facility at or above the screening
threshold, then nothing further is
required. The threshold quantities apply
to the 60 days prior to the publication
date of 11-20-2007 and anytime
thereafter.
Important Definitions

CHEMICAL FACILITY:
“…any facility that possesses or plans to
possess, at any relevant point in time, a
quantity of a chemical substance
determined by the Secretary to be
potentially dangerous or that meets
other risk-related criteria identified by the
Department.”
Important Definitions
Q: Is FCCC a Chemical Facility?
A: Yes. Initial screening phase of the
program may demonstrate that FCCC
possesses some of the regulated
chemicals in quantities greater than
the listed threshold values.
Important Definitions

HIGH RISK: “…refers to a chemical
facility that, in the discretion of the
Secretary of Homeland Security,
presents a high risk of significant
adverse consequences for human life or
health, national security and/or critical
economic assets if subjected to terrorist
attack, compromise, infiltration, or
exploitation.”
Important Definitions
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Q: Is FCCC a High Risk Facility?
A: Unlikely. DHS will designate facilities
as High Risk only after the initial
screening phase. However,
conventional wisdom, along with recent
comments by DHS officials, are not
clear if university research facilities will
not make that list.
Important Definitions

COVERED FACILITY: “…a chemical facility
determined by the Assistant Secretary to
present high levels of security risk…”
Important Definitions

Is FCCC a covered facility?
Unlikely but possible.
The initial screening phase of the
program will probably result in FCCC not
being designated a covered facility. The
result will be that we will not be required
to perform a Security Vulnerability
Assessment or develop a Site Security
Plan.
Important Definitions

TOP-SCREEN PROCESS:
“…an initial screening process identified
by the Assistant Secretary through which
chemical facilities provide information to
the department [of Homeland
Security]…”
Important Definitions


Q: Is FCCC required to participate in the
Top-screen process?
A: Possibility. If we have even one
regulated chemical in a quantity greater
than its listed threshold, we must
complete and submit a Top-screen.
Authorizing Legislation
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
The Act requires the development and
implementation of “risk-based
performance standards,” and applies
to facilities that “present high levels of
security risk.”
The Act builds on “pre-existing federal
security initiatives and chemical safety
programs.”
DHS Risk Assessment
Methodology (RAMCAP)
Developed by the American
Society of Mechanical
Engineers, RAMCAP is a
method for evaluating
consequences, vulnerability and
risk for elements of critical
infrastructure.
The initial screening segment
of RAMCAP, known as Topscreen, has been incorporated
into the Chemical Facility Antiterrorism Standard.
EPA Risk Management
Program (RMP)
Authorized by the Clean Air Act.
Requires facilities with chemicals
in amounts exceeding thresholds to
implement an accident prevention
program and an emergency
response program, and submit a
Risk Management Plan.
OSHA Process Safety
Management of Highly
Hazardous Chemicals
Standard (PSM)
Sets requirements for
management of hazards
associated with processes using
highly hazardous chemicals.
OSHA Hazardous Waste
Operations and Emergency
Response (HAZWOPER)
Standard
Covers emergency
response operations involving
the release of hazardous
substances.
Currently, only Jeff Henne
and I participate in annual
HAZWOPER training.
OSHA Hazard
Communication (HAZCOM)
Standard
Provides workers with the right
to know the hazards associated
with the chemicals with which they
work, and measures they can take
to protect themselves.
Compliance with the HAZCOM
Standard is one of the most
important, and time-intensive,
duties of the Safety Safety Office.
Phased Implementation of
the Standard
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Chemical facilities will be required to
complete and submit a Top-screen within 60
days of the publication of the final rule.
DHS will then determine which facilities will
be required to continue in the program, and
complete Security Vulnerability Assessments
and Site Security Plans.
FCCC’s participation in the program will
probably end with the submission of the
Top-screen.
The Top-screen Process

DHS considers terrorism risk
to be a function of three
variables:
– Consequence (or criticality)
– Vulnerability (or the
likelihood that an attack
would succeed if launched)
– Threat (or the likelihood an
attack would be launched in
the first place)
The Top-screen Process

DHS also believes
consequence is the initial
qualifying factor.
So it is requiring the use of
“Top-screen”, which is a
“consequence-only”
assessment tool.
The Top-screen Process
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Top-screen is a basic questionnaire that
chemical facilities will be required to
complete.
It is based on the RAMCAP model of the
same name.
It will be used to identify High Risk facilities.
It will be completed online, using the DHS
Chemical Security Assessment Tool (CSAT).
The Top-screen Process – Two
Categories of Users

PROVIDER – “…a qualified individual
familiar with the facility in question.
This person will submit the screening
tool.”
The Top-screen Process – Two
Categories of Users
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SUBMITTER – “…an officer of the
corporation (or equivalent) responsible
for the facility in question. The
Submitter will send the completed
Top-screen to DHS, and in so doing,
will attest to the accuracy of the
information provided.”
The Top-screen Process –
Segment One
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The first segment of the Top-screen will
include identifying information for the
facility, such as name, address, and
geographic coordinates.
This segment will also address issues of
criticality by asking questions regarding
potential loss of life and loss of capability
to execute critical missions as the result
of a terrorist incident.
The Top-screen Process –
Segment Two
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The second segment asks a series of
exclusionary questions to screen out facilities
that are excluded by law from the regulation.
Excluded faculties are mainly those that are
covered under the Maritime Transportation
Security Act, are owned or operated by the
Departments of Defense or Energy, or are
licensed by the Nuclear Regulatory Commission.
The Top-screen Process –
Segment Three
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The third segment addresses risk to human life
by identifying which chemicals are present.
DHS has developed, and is currently refining, a
list of chemicals and a threshold quantity (TQ)
for each.
The facility will identify in the Top-screen which
of those chemicals are present at the facility in
quantities equal to or above the TQ.
This segment addresses security issues
associated with specific chemicals and TQs.
What We Need to Do
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Register to access the Chemical Security
Assessment Tool (CSAT).
Identify a Preparer (Provider),
Submitter, and
Authorizer (can be Provider or Submitter).
What We Need to Do

Pre-plan for work required to complete the Topscreen within 60 days of the rule being
published. This will probably involve checking
existing chemical inventories against the
proposed Appendix A chemicals and scheduling
field inspections of buildings that store
chemicals.
What We Need to Do

Schedule A Chemicals of Interest
–Release
–Theft
–Sabotage
–Security Issues
What We Need to Do
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Department of Homeland Security
Chemical Facility Anti-Terrorism
Standards:
Final Rule (November 19, 2007)