Monday, August 20, 2018

ISCD Publishes Anhydrous Ammonia Flyer

On Friday the DHS Infrastructure Security Compliance Division (ISCD) published a notice in the “Latest News” section of the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center that they have a new flyer for shippers of anhydrous ammonia. That notice does not provide a link to the flyer; that has to be found by scrolling down the “Fact Sheets and Flyers” list on the same page.

The intent of this flyer is very similar to the generic COI shipping flyer that was published in July 2017. It is part of the ISCD outreach program to try to ensure that all facilities that receive DHS chemicals of interest (COI) are aware of the reporting requirements for the CFATS program. ISCD is not requiring companies to send this flyer to their anhydrous ammonia customers; it is not clear that they have the legal authority to make such a demand. This may, however, be something that Congress may consider providing in the expected extension of the CFATS program.

The advantage (from the DHS perspective) of this type of chemical specific flyer over the generic flyer published earlier is that this flyer is able to include the specific screening threshold quantity (STQ) for anhydrous ammonia. It is also able to specifically address the agriculture reporting exception for some uses of anhydrous ammonia and that exception was not addressed at all in the generic flyer.

The extensive use of anhydrous ammonia as a refrigerant means that this chemical is shipped to a large number of facilities that would not normally consider themselves to be ‘chemical companies’. It would be expected that such companies might not be aware of the CFATS program, though ISCD has attempted to reach out to such facilities through a number of industry organizations that would affect such facilities. I would suspect that ISCD will also reach out to those organizations to ask them to distribute this flyer as well.

NOTE: The CFATS Resources page has not yet been updated to reflect this new flyer. I expect that will happen sometime this week.

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