Tuesday, October 27, 2015

Appendix A Roundtable Discussion

I just finished listening to the roundtable discussion about possible changes to Appendix A to 6 CFR Part 27, the CFATS regulations. I talked about this roundtable in an earlier post.

The roundtable format allowed for the private sector participants (and apparently a couple of people from some public sector agencies as well) that were able to attend the event in Washington, to provide some comments and exchange some ideas on the parts of Appendix A that might need changing. As I mentioned earlier the topics that were covered were:

• The possible addition of chemicals to, and/or the deletion or modification of COI currently listed in Appendix A;
• The applicability and/or modification of any Screening Threshold Quantities (STQ) or minimum concentrations;
• Concentration and mixtures rules associated with Appendix A, which are described in 6 CFR 27.204;
• Isotopic variants to include comments on Chemical Abstract Service (CAS) Registry Numbers and nomenclature;
• The classification of COI within different security issues, to include the potential for re-designating certain chemicals now listed solely as release flammable so they are listed solely as toxic or as toxic and flammable; and
• Criteria for “counting rules” for screening threshold quantities to include clarification on how to determine if a COI is in transportation.

DHS provided a slide for each of the topics listed above (slides will be available at some point on www.Regulations.gov; Docket # DHS-2014-0016-0071). Those slides included a couple of specific discussion points that came from the earlier public comments about Appendix A for the Advance Notice of Proposed Rulemaking (ANPRM) on the CFATS program.

The audio was poor (a problem with HSIN not ISCD) on the phone in link, but the comments that I could understand were many of the same  things that we saw eight years ago when the CFATS NPRM was published.

There will be a public comment period this afternoon for the event in Washington, but I don’t think that I will spend any time listening to that. Instead I am going to get back to work on my submission for this on the topic of toxic inhalation hazard chemicals listed in Appendix A. Needless to say readers will see it first here.

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