Yesterday the Pennsylvania Department of Agriculture sent out a press release reminding farmers in the state that DHS had released new chemical security regulations that might affect farmers “storing fertilizers, pesticides and other chemicals might be affected by these new regulations”. The press release lists some of the chemicals found in Appendix A to 6 CFR part 27 that might be found in an agricultural setting.
DHS has pledged to conduct an outreach program to let people that were not normally associated with the Chemical Industry that the new Chemical Facility Anti-Terrorism Standards (CFATS) might classify them as a “Chemical Facility” based on the chemicals that they might have on site. While the PA Dept of Agriculture is certainly not directly associated with DHS, it may have been contacted by DHS to spread the word; figuring that farmers would probably pay more attention to that agency than they would DHS.
This is going to be the main problem that DHS has with the CFATS; so many of the facilities that will be affected are outside the normal chemical manufacturing community that a significant number of the facilities that should respond will not even know that they are covered. Notifications to farmers, food processors and other users of chemicals are going to have to be made to get everyone into the game. Unfortunately we are almost half way through the initial 60 day Top Screen filing period, so it is a little late to start getting the word out.