Research & Commercialization News
DHS Chemical Standards
By Carol Blum
Director,
Research Compliance & Administration
Council on Government Relations
In a briefing on Mon., June 23, 2008, with representatives of colleges and universities, the Department of Homeland Security’s Office of Infrastructure Protection (OIP) announced the completion of the review of the Top Screens of Chemicals of Interest submitted in response to the Chemical Facility Anti-Terrorism Standards (CFATS) regulations.
Of the 30,000+ Top Screens submitted, approximately 7,000 are tiered at a level of risk that requires the submission of a Security Vulnerability Assessment (SVA). Larry Stanton, OIP Director, noted that “dozens, not hundreds” of colleges and universities are within the group of tiered facilities and scattered among all tiers – Tier 1 of highest risk through Tier 4, lowest risk.
Tiered facilities will receive an express mail letter identifying the level of risk (tier), the Chemicals of Interest that resulted in being tiered, and requesting the submission of the SVA. The letter will be sent to the individual submitting the Top Screen. Tiered facilities will be required to complete the SVA. Those institutions that do not represent a significant level of risk (not tiered) will receive a letter by regular mail notifying them of their status. Institutions not tiered do not have to complete a SVA and have nothing further to do with the DHS CFATS program at this time.
The SVA is designed to provide DHS with a greater understanding of the risk associated with the facility’s use of the chemicals of interests. For colleges and universities, the type of risk will be, in general, theft and diversion – the type of risk is related to the chemical and quantities held by the facility.
Stanton emphasized that the SVA is the next step in the DHS’ assessment and does not require the institution to do anything beyond submitting the SVA – institutions are not expected to change procedures, invest resources, etc. The SVA is a description of facility assets, security controls and vulnerability analysis – a snap shot of what’s in place. In response to questions concerning planned changes to the facility’s management of its chemicals, Stanton urged institutions to describe current practice and to include changes that will be implemented in the very near-term – not planned changes that will be implemented over the next academic year for example.
The next step, if necessary, will be the development of a Site Security Plan that is negotiated with DHS. At that time, new practices or procedures that will be implemented over the course of the next year can be described and integrated into the facility’s response.
Tiered institutions are cautioned not to discuss the process – institutions can disclose that they have received a tiered ranking but not the tier level or chemicals identified as of interest.
More information is available on the DHS web site. DHS Critical Infrastructure: Chemical Security Program (under Prevention and Protection from the DHS homepage) is available at: http://www.dhs.gov/xprevprot/programs/gc_1169501486179.shtm