In an earlier Chemical Facility Security News blog I bemoaned the fact that DHS was not keeping people up to date on how many facilities had completed work on their Top Screens. Well the November 2nd press conference by Under Secretary Stephan did briefly address that issue. According to Secretary Stephan about 90 facilities were directed to complete the Top Screen when the regulation first went into effect. Additionally, another 150 or so facilities have voluntarily completed the Top Screen. On top of this about 10,000 facilities have registered in the Chemical Security Assessment Tool (CSAT) and are ready to begin or have begun the Top Screen Process.
When DHS issued the Final Interim Rule on CFATS last spring they estimated that about 40,000 facilities would be required to complete the Top Screen and that 5,000 to 8,000 of those would be designated High Risk Facilities, thus coming under the provisions of CFATS requiring the preparation of Security Vulnerability Assessments (SVA) and Site Security Plans (SSP). Secretary Stephan said that he now expects the total number of facilities required to complete the Top Screen to be about 50,000.
This means that there are about 49,000 facilities that need to complete the CSAT registration process. (Detailed instructions about the registration process can be found on the DHS web site.) These are the facilities that have had one or more chemicals found in Appendix A at or above the STQ for either the release quantity or the theft/diversion quantity listed in the appendix. There is no need for these facilities to wait for Appendix A to be published in the Federal Register to begin the registration process.
Tags: Chemical Facility Security, CFATS compliance, CSAT registration, Top Screen Completion
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