Saturday, August 11, 2007

First Security Vulnerability Assessments to be done soon

On June 8th of this year the new Chemical Facility Anti-Terrorism Standards (CFATS) went into effect. Three days later, according to congressional hearing testimony by Col. Bob Stephan, Assistant Secretary Infrastructure Protection, the first notifications went out to fifty facilities to complete a Top Screen with additional facilities being notified on the 13th. The sixty-day deadline to complete those first Top Screens was over yesterday with the remaining to be completed by Sunday. This means that notifications to start completing Security Vulnerability Assessments (SVA) should start going out in the next week or so to the highest risk facilities, Tiers 1 and 2.


We should be seeing additional changes to the DHS web site with explanations about how the SVAs will be completed in the Chemical Security Assessment Tool (CSAT). There is also the possibility that the revised Appendix A, DHS Chemicals of Interest, will be released soon, along with changes to the Top Screen. Those changes would effect those facilities not already notified to complete a Top Screen that have (or plan to have) chemicals on site listed in the revised Appendix A at levels above the STQ.


Additional information provided by Col. Stephan indicated that there would be significant revisions to Appendix A with changes to some of the Screening Threshold Quantities (STQ) and the addition of blend rules for some chemicals. This would require some changes to the Top Screen including revisions of the two .pdf downloadable files supporting the Top Screen on the CSAT web page; CSAT Top-Screen Questions and CSAT Top-Screen User Manual. It would have been very inappropriate to change the Top Screen during the middle of the initial 60 day filing period.


It will be interesting to see if DHS publishes any data about these initial entries into the CSAT system. While no one expects them to provide any site specific data, a brief press release about the number of facilities that provided data, and were subsequently declared to be High-Risk Facilities would be interesting as would information about the Tier ratings. Because of the way these facilities were selected for providing Top Screen information we should expect that a very high ratio would be declared to be at high risk for terrorist attack.

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