1. Homeland Security (CFATS)
Presented by
Kari Keegan
Sage Environmental
Consulting
2014 Mid-America
Environmental
Compliance
Conference

2. CFATS – What is it?
• Chemical Facility Anti-Terrorism Standards
(CFATS)
– Final Rule: 6 CFR Part 27 (April 9, 2007)
– Appendix A to CFATS: FR November 20, 2007
• Risk-based approach to screening chemical
facilities for high-risk potential
– Many RMP chemicals on the CFATS list!
• Covered facilities are required to comply with
applicable CFATS
– Top Screen (Initial Notification)
– Security Vulnerability Assessment (SVA)
– Site Security Plan (SSP)
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3. CFATS – Covered Facilities
• Chemical
manufacturing, storage, a
nd distribution;
• Energy and utilities;
• Agriculture and food;
• Paints and coatings;
• Refineries; and
• LNG;
• Explosives;
• Mining;
• Electronics;
• Plastics;
• Universities & research
institutions; and
• Healthcare and
pharmaceuticals.
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4. Appendix A - COI
• Chemicals of Interest (COI) based on security issues
– Release (toxic, flammable - HCl, Cl)
– Theft/diversion (H2O2, Cl)
– Sabotage or contamination (*KNO3)
• COI screening threshold quantity (STQ) similar to RMP
threshold planning quantity (TPQ)…for releases:
– Chlorine: Release - 2500 lbs (1%); Theft -500 lbs (9.77%)
– Propane: Release (1%) 10,000 lbs (CFATS -no exemption)
– Nitric: Release (80%) 15,000 lbs;
– Hydrogen Peroxide (≥35% conc.) – 400 lbs (< one drum)
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5. CFATS – Reporting Steps
1. Determine if COI is present at/above STQ;
2. Submit Top Screen to DHS within 60 days of coming into
possession of the COI;
3. If DHS assigns a risk level, submit an SVA within 90 days of
receiving an initial determination letter (IDL); and
4. Upon review and approval of final determination letter
(FDL), which classifies a site as a high-risk facility, DHS will
require you to submit the SSP – DHS online program or
alternate security program (ASP) within 120 days of receiving
notice from DHS.
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6. Kari Keegan
(312) 965-8038
kari.keegan@sageenvironmental.com
www.sageenvironmental.com
CFATS – Contact Us!!
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