Chemical Facility Anti-terrorism Standards
(CFATS)
In June of 2007, the Department of Homeland Security (DHS) published a new rule establishing risk-based performance standards for the security of the nation’s chemical facilities. Recently, DHS has finalized Appendix A, detailing a list of “Chemicals of Interest” under this rule. In this issue of Microbial Control Talk, the impact of this ruling on the purchase, storage and use of FMC’s Microbial Control Products will be discussed. Please note that the following is provided for information purposes only. You should consult your own advisors regarding the compliance of your facility or site with CFATS rules and regulations.
Appendix A of the Chemical Facility Anti-terrorism Standards (CFATS) identifies chemicals and their Screening Threshold Quantities (STQs). If a facility or site possesses, or later comes into possession, of a chemical of interest at or above the specified STQ, further assessment must be made to determine if the facility or site poses a significant risk to public safety. This first stage of this assessment requires the facility or site to complete an assessment tool, known as Top-Screen, which can be completed on-line at DHS. Note that many facilities that fill out the Top-Screen may not be subject to further regulation under CFATS. Appendix A and the Top-Screen will allow DHS to make a preliminary determination about whether the facility presents a high-level of security risk. If a facility has on-site a chemical of interest at or above the STQ, then the facility is required to file a Top-Screen on or before January 22, 2008, or within 60 calendar days of coming into possession of a chemical of interest at or above its STQ. If your site or facility is determined to be a “high risk facility”, then you will be notified by DHS in writing, and may be required to submit further documentation, such as a Site Vulnerability Assessment (SVA) and a Site Security Plan (SSP).
Impact on Purchasing, Storing and Using FMC’s Microbial Control Products
Peracetic Acid:
The DHS Final Appendix A list of “Chemicals of Interest (COI)” was issued. This list includes peracetic acid (PAA) in concentrations 1% and greater of quantities 10,000 pounds and greater under the “Release—Flammables” category. These amounts are called the “Screening Threshold Quantity” (STQ) for the material.
Since FMC’s 5%, 15%, and 35% PAA has a NFPA flammability rating less than 4, you need only consider the amount of PAA in the solution when determining whether or not you exceed the STQ of 10,000 pounds and greater. You do not count the total weight of the mixture but only the weight of that part of the solution constituting PAA (i.e. a 500 pound drum of 5% PAA equals 25 pounds towards the STQ).
Facility or site must count all peracetic acid solutions stored in a vessel (defined as any reactor, tank, vat, kettle, boiler, pipe, hose, and cylinder) and in DOT (Dept. of Transportation) transportation packaging (defined as carboy, drum, IBC, and tote) to determine if the STQs have been exceeded and a Top-Screen submitted. Please contact FMC for further details on the assessment of the quantity of peracetic acid in concentrations of 1% or greater of quantities 10,000 pounds or greater for regulation under CFATS.
For further information on the DHS CFATS regulation, please visit www.dhs.gov and type in CFATS under the search feature. Contact the FMC Microbial Control Team for questions regarding our microbial products.