Monday, December 17, 2007

Top Screen Questions: Sabotage/Contamination Chemicals of Interest

The last list of chemicals of interest in the Top Screen is for the Sabotage/Contamination chemicals. In the Final Rule Appendix A (pages 41-42), DHS defines Sabotage/Contamination chemicals as:


“Sabotage/contamination refers to those chemicals that, if mixed with other readily-available materials, have the potential to create significant adverse consequences for human life or health…. Sabotage/contamination chemicals currently include those chemicals that are capable of releasing a poisonous gas when exposed to water.”


There is only a single section in the Sabotage/Contamination chemicals of interest (COI) portion of the Top Screen. There is a listing of the chemical name, CAS #, minimum concentration, and the Screening Threshold Quantity (STQ) for each listed chemical. Then there are two check boxes for indicating if there is an STQ of the chemical on-site. The default value for these boxes is “No” so only the chemicals requiring an affirmative answer need to be checked.


All of the chemicals in this COI list have the same concentration limit, ACG, a commercial grade. Again, like in the explosive/IEDP COI, this means that any mixture sold under that chemical name will be counted.


The other abbreviation in this list is the “APA” listed under the STQ for each of the chemicals in the list; an abbreviation unique to this COI list. APA stands for “A Placarded Amount”, and refers to any shipment of this chemical that was required to be placarded under CFR 49 rules. If a facility ships or has shipped this chemical in an amount that was required to be placarded, the facility meets the STQ requirements for that chemical. Interestingly, the normal “in the last 60 days” verbiage that is found in each of the previously discussed chemicals of interest tables is not found in this table.


Once again there is no provision in the CSAT Top-Screen Questions shown on-line for reporting the actual amount of this chemical that the facility has on hand. This was also seen in the Theft/Diversion COI list. This poses some interesting possibilities for how DHS will treat Top Screen reports for these chemicals. Either DHS will automatically assign any facility reporting the STQ amount of any of these chemicals to a specific tier ranking as a High-Risk Facility, or DHS is only collecting information about these chemicals and will not use the presence of these chemicals in making a High-Risk Facility determination. Neither of these options appears to be particularly palatable.

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