The last two areas of the Top Screen have nothing to do with the chemicals of interest listed in Appendix A to 6 CFR part 27. The other difference is that they only deal with chemical production facilities, not the more loosely defined chemical facility. These are the sections dealing with Mission Critical Chemicals and Economically Critical Chemicals. These are also the most complicated sections of the Top Screen to fill out.
Mission Critical Chemicals are those chemicals that a facility produces that go into any one (or more) of four critical infrastructure sectors: Defense Industrial Base, Energy (electricity generation only), Public Health or Healthcare, and/or Public Drinking Water. If a facility’s production accounts for 20% or more of the domestic production of one or more chemicals going into one of these sectors the facility will be required to complete this section of the Top Screen.
While this sounds like a fairly straight forward definition, there is very large number of chemicals made by specialty chemical companies that might fit this bill because of the niche market they fill. For example I know of a manufacturer that is the sole producer of a very low production volume polymer that is used by the Department of Defense as a jet fuel additive. I am not sure that this is what DHS was looking for in this section, but it surely fits the definition provided. There will probably be thousands of chemicals like this, especially going into the pharmaceutical industry.
There are twelve questions that have to be answered for each chemical that a facility produces that meets the criteria for Mission Critical Chemicals. These questions range from name and CAS# for the chemical thru Average Capacity Utilization Rate to Replacement Costs for Production Units. Two of the questions shown in the CSAT Top-Screen Questions (Capacity Utilization Rate and Emergency Production Rate) refer to additional information that will be provided in the yet to be published Top Screen User’s Guide.
The Economically Critical Chemicals section deals with production going into any other sector of the economy where the production facility accounts for 35% of the domestic production of that chemical. The same types of questions that were asked in the previous section are asked for each chemical a facility produces meeting these requirements.
Because of changes in the <?xml:namespace prefix = st1 ns = "urn:schemas-microsoft-com:office:smarttags" />US chemical industry in the last 20 years, there will be a very large number of industrial chemical producers that will produce one or more products for which they are the sole domestic producer. This is especially true of low volume specialty chemicals.
DHS has done very little to advertise these two sections of the Top Screen. They are going to miss a lot of facilities that meet the definitions for these two critical chemical sections because the producers are never going to see the requirement. Most facilities are going to scan the Appendix A chemical list and if they find that they do not have an STQ of a listed chemical on hand, they will never look at the actual Top Screen.
These sections are also going to be much harder for DHS to evaluate to determine the relative risk of the facility being the object of a terrorist attack. DHS will not only have to be able to evaluate the criticality of the end use of the chemical and the ease of quickly bringing an alternate supplier on line, but also how hard it will be for a terrorist to identify the same information.
It will be interesting to see how DHS treats these two areas of the Top Screen. Sites with large volumes of Flammable or Toxic Release chemicals will make for more spectacular terrorist targets, especially if they are near large populations. Various Theft/Diversion chemicals will allow terrorists to use chemicals to attack people physically separated from chemical facilities. Successfully attacking a few facilities manufacturing Critical Chemicals could cripple essential sectors of our economy. Which of these makes a better, higher-risk terrorist target? That remains to be seen.
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Do you have any information on the way DHS is ranking facilities meeting these Mission Critical and Economically Significant criteria?
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