The U.S. Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) are comprehensive risk-based security regulations intended to prevent the intentional misuse of certain chemicals by sabotage, theft, diversion or direct attack. DHS has authority to inspect facilities to enforce compliance with CFATS. DHS can impose civil penalties up to $25,000 per day and shut down facilities that fail to comply with the regulations.
The OSU Office of Environmental Health and Safety (EHS) uses chemical inventories in the EHS Assistant web-based chemical inventory system to facilitate OSU faculty and staff compliance with CFATS. CFATS requires a facility to submit a report, which is known as a Top-Screen, to DHS after receipt of a chemical of interest (COI) at or above STQ. EHS will submit a Top-Screen to DHS for each facility at the university that has COI at or above the screening threshold quantity based upon the chemical inventories in the EHS Assistant chemical inventory system. For this reason, it is important that all OSU faculty and staff submit and maintain up-to-date chemical inventories in the EHS Assistant chemical inventory system. To ensure reports are submitted to DHS within the mandated time period, changes in COI need to be entered in the EHS Assistant chemical inventory system within 30 days of the change.
Using the Top-Screen, DHS makes a preliminarily determination of whether a facility presents a high level of security risk. If DHS determines that a facility presents a high level of security risk, then EHS will complete the required Security Vulnerability Assessment (SVA) and submit it to DHS. DHS will use the SVA to perform a final threat analysis to determine the final level of risk of the specific facility. If DHS determines that an OSU facility presents a high level of security risk during the final threat analysis, EHS will work with the facility to develop and implement an appropriate Alternate Security Program or Site Security Plan based upon DHS’s Risk-Based Performance Standards.
EHS will facilitate CFATS compliance at the university. If you need to set up an EHS Assistant user account, please contact EHS at (614) 292-1284. For more information about CFATS compliance, please contact John Sharpe at (614) 292-0619 or sharpe.56@osu.edu.
Topic: