Chemical Inventory Maintenance and DHS Notifications of Possession of Chemicals of Interest

Topic:
Chemical Security
Tags:
Standard Operating Procedure,
Chemicals of Interest

Purpose

Detail procedures to be implemented at The Ohio State University to maintain chemical inventories and submit required notifications to the U. S. Department of Homeland Security (DHS) when university facilities possess chemicals of interest (COI) at or above the standard threshold quantity. CFATS requires a facility possessing COI ≥ STQ to submit a Top-Screen report to the DHS within 60 days of acquisition.

  1. PI/ Supervisor Responsibilities

    1. OSU faculty and staff are responsible for maintaining up-to-date chemical inventories in the EHS Assistant web-based chemical inventory system; which is an online, limited access database used to maintain inventories of hazardous chemicals at OSU. EHS Assistant can be accessed at: https://ehsa.osu.edu/ehsa

    2. Changes in DHS chemicals of interest must be entered in the EHS Assistant chemical inventory system within 30 days of the change. For other hazardous materials, the inventory should be updated annually at a minimum.

    3. New OSU faculty and staff may contact EHS at (614) 292-1284 to obtain a username and password to gain access to the EHS Assistant chemical inventory system. An instruction manual is available on the EHS Assistant login page.

  2. Office of Environmental Health and Safety (EHS) Roles

    1. On a monthly basis, Office of Environmental Health and Safety Chemical Security personnel will review chemical inventories in the EHS Assistant chemical inventory system to identify DHS chemicals of interest possessed by the university and determine whether or not the COI are at or above the standard threshold quantity (STQ). When the inventory indicates a facility possesses a COI ≥ STQ, EHS will contact the responsible PI/ Supervisor to verify this information.

    2. After verifying possession of COI ≥ STQ, EHS will submit a Top-Screen to DHS to report the possession of a COI ≥ STQ.EHS will facilitate facility personnel with CFATS compliance.

    3. EHS will submit all correspondence requested by DHS for the facility, e.g., Security Vulnerability Assessment and Site Security Plan or Alternate Security Program.

    4. EHS will submit a Top-Screen to DHS within 60 days of when a facility makes materials modifications to its operations. EHS will submit a Top- Screen to DHS when a facility no longer possesses COI ≥ STQ and does not foresee a future need to possess the COI ≥ STQ.