DHS CSAT Registration Change

Last week (7-19-07) DHS made a change to their CSAT Registration instruction page of their web site. They have now included provisions for bulk uploads of registration data for people doing registrations for 50 facilities or more at one time. While there is little explanation of why this change was made other than to “accommodate the varied organizational structures” of  organizations, I can think of only one situation where this new procedure would come in handy; distributors that own storage tanks for chemicals listed on Appendix A (when finally approved) at multiple customer locations.

 

There are a number of industries where a chemical is stored on a company site that is owned and maintained by the distributor of the chemical, not the company actually using the chemical. In very many of these cases, that chemical is the only thing on the company site that could possibly come under the coverage of 6 CFR part 27. Chemicals that come to mind are Anhydrous Ammonia (agriculture), Hydrogen Peroxide (>30%, various industries for disinfection), and Propane (various industries).

 

Since the distributor owns the tank, an argument could be made that they could accept responsibility for the security of that facility (the tank) and do the filings for all of the tanks above the STQ limits for that chemical. This would relieve their customers of the administrative burden associated with registration and Top Screen filings for this single chemical. Many of these tanks would be isolated enough that they would not rise to the level of being declared a High Risk Facility, so no actions would be required beyond completing the Top Screen and possibly records maintenance of having completed that requirement.

 

I had suggested just such a solution on my MySpace blog early last month and in an article posted on ArticleDashboard.com. While I have no way of knowing if someone at DHS had actually seen my suggestion (much less took it into account when making this change), I would like to think that the suggestion provided some impetus to this change.

Tags: Chemical Plant Security, CSAT Registration, Top Screen, Propane, Anhydrous Ammonia, Hydrogen Peroxide