Frequently Asked Questions
The following summary was prepared by Sigma-Aldrich as a service to our customers. It is not intended to be a legal interpretation, and Sigma-Aldrich assumes no liability for actions taken/not taken.
On April 9, 2007, the United States of America Department of Homeland Security (DHS) published the Chemical Facility Anti-Terrorism Standard. On November 20, 2007, DHS published the final listing of chemicals (Chemicals of Interest) and their respective Screening Threshold Quantities (STQ).
The standard requires any facility that manufactured, used, stored or distributed certain chemicals above their STQs to complete and submit a CSAT Top-Screen by January 19, 2008, or within 60 calendar days of coming into possession of the listed chemicals at or above the listed STQs. The total quantity of the listed chemical at the facility (physical location), to include mixtures of the listed chemical at or above 1% by weight, must be considered in determining if a STQ is met.
To determine what facilities meet the Department's criteria for high-risk chemical facilities, the Department of Homeland Security developed the Chemical Security Assessment Tool (CSAT) Top Screen, an easy-to-use online questionnaire to be completed by facilities that possess or plan to possess any chemicals on Appendix A: DHS Chemicals of Interest list at or above the listed Screening Threshold Quantity (STQ). To register to use the CSAT Top-Screen, facilities should visit www.dhs.gov/chemicalsecurity.
All facilities that possess chemicals listed in Appendix A in quantities at or above the STQs must complete and submit a CSAT Top-Screen. The Appendix A requirements for Top-Screen may require colleges and universities to comply. In addition, as with others facilities subject to this rule, it is possible that some colleges and universities will be required to take additional steps in the CSAT process, and will be contacted by DHS with instructions on how to proceed.
It is important to note that many facilities that complete the Top-Screen may not be subject to further regulation under CFATS by DHS. Appendix A and the Top-Screen will allow DHS to make preliminary determinations about whether facilities present a high level of security risk.
Note: On November 20, 2007, the Department of Homeland Security published the final Appendix A in the Federal Register. With the publication of a final Appendix A, all provisions of 6 CFR Part 27, including § 27.210(a)(1)(i), are operative and in effect.
- Facilities regulated pursuant to the Maritime Transportation Safety Act (MTSA).
- Public Water Systems, as defined in the Safe Drinking Water Act.
- Water Treatment Facilities, as defined in the Federal Water Pollution Control Act.
- Facilities owned or operated by the Department of Defense or the Department of Energy.
- Facilities subject to regulation by the Nuclear Regulatory Commission (NRC).
Frequently Asked Questions:
What is Appendix A?
Appendix A of the Chemical Facility Anti-Terrorism Standards (CFATS) regulation lists the DHS chemicals of interest and their corresponding Screening Threshold Quantities (STQ). If a facility possesses, or later comes into possession of, a chemical of interest at or above the specified screening threshold quantity, that facility must complete an easy-to-use online consequence assessment tool, known as a Top-Screen.
What is the Top-Screen?
The Top-Screen is an easy-to-use online questionnaire that facility owners and operators complete to provide DHS with a basic understanding of the facility’s potential level of consequence. After answering a series of simple questions, DHS will be able to preliminarily determine whether the facility presents a high level of security risk. Not all facilities that complete the Top-Screen will be subject to further regulation by DHS. The Top-Screen is part of the Chemical Security Assessment Tool (CSAT). To register to use the CSAT Top-Screen, facilities should visit www.dhs.gov/chemicalsecurity.
Who will be required to complete the Top-Screen and by when?
If a facility possesses a chemical of interest at or above the listed screening threshold quantity, the facility must complete and submit a Top-Screen to DHS. A facility must do this by January 19, 2008 or within 60 calendar days of coming into possession of the listed chemical of interest at or above the listed screening threshold quantity.
What types of chemical categories are included in Appendix A?
To determine the type and quantity of chemicals that require a facility to complete the Top-Screen, DHS examined three security issues:
- Release—Quantities of toxic, flammable, or explosive chemicals that have the potential to create significant adverse consequences for human life or health if intentionally released or detonated.
- Theft or Diversion—Chemicals that have the potential, if stolen or diverted, to be used as weapons or easily converted into weapons, in order to create significant adverse consequences for human life or health.
- Sabotage or Contamination—Chemicals that, if mixed with other readily available materials, have the potential to create significant adverse consequences for human health or life.
Are there any special considerations of interest to scientific research facilities?
DHS developed a specialized approach for propane, chlorine, and ammonium nitrate.
- Propane—The screening threshold quantity for propane is 60,000 lbs, and facilities need not count propane in tanks of 10,000 lbs or less. This higher threshold quantity focuses the screening effort on high-volume propane users, shifting the focus away from non-industrial propane users.
- Chlorine—Depending on the hazard it presents, there are two screening threshold quantities for chlorine: (1) a screening threshold quantity of 500 pounds when the chemical presents a theft hazard, and (2) a screening threshold quantity of 2,500 pounds when the chemical presents a release hazard.
- Ammonium Nitrate—DHS identified Ammonium Nitrate in two forms: (1) the explosive and (2) the more common form used as a fertilizer. DHS set different screening threshold quantities for each form, depending on the hazard presented.
Will Appendix A apply to college and university facilities?
Yes, some college and university research facilities may be affected. Colleges and universities that possess Appendix A chemicals of interest at or above the listed screening threshold quantities will have to complete and submit a Top-Screen to DHS. With the information from the Top-Screen, the department will be able to make a determination as to whether the college or university laboratory might present a high level of security risk and therefore must comply with the substantive requirements of CFATS. Facilities determined by DHS not to present a high level of security risk will not be required to remain in the regulatory program. It is anticipates that many academic institutions will likely be found not to present a high level of security risk. Facilities determined by DHS to present such a concern, however, will have to comply with the substantive requirements of CFATS. Because security across academic institutions varies dramatically, the level of measures necessary for each academic institution will likewise vary. While some academic institutions may have security measures in place that will help them meet the applicable risk-based performance standards, some may not, and DHS looks forward to helping those facilities increase their security.
How can I get a summary of the chemicals listed in Appendix A that I’ve purchased from Sigma-Aldrich?
Keep in mind that Sigma-Aldrich is only one source of the chemicals of interest found in Appendix A. Simply knowing the quantities purchased from one supplier cannot help your institution determine final disposition. That being said, we have created a channel for you to obtain a summary of the Appendix A chemicals purchased from us. Simply send an email to AppendixA@sial.com including your name, account name, account number, direct telephone number, zip code, and date range of interest. A company representative will contact you to validate your request for account/data privacy purposes.
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