University of Iowa

Regulatory Programs

Department of Homeland Security - Chemicals of Interest (DHS COI)

Purpose and Applicability

The Chemical Facility Anti-Terrorism Standards (CFATS) Interim Final Rule, published April 9, 2007, establishes a risk-based approach to screening and securing chemical facilities determined by Department of Homeland Security (DHS) to be “high risk.” In order to make that determination, CFATS requires facilities in possession of specific quantities of DHS defined Chemicals of Interest (COI) to complete a Top-Screen questionnaire.

According to CFATS, any facility processing COI has 60 days to report when the amount of any COI meets or exceeds the Screening Threshold Quantity (STQ). EHS runs a report on all chemical inventories to monitor levels of COIs. Chemicals inventories must be updated at least annually to assist EHS in preventing any COI that is close to the STQ from exceeding it, or report to DHS within the 60 day limit any COI that is over the STQ.

Section 550 of the DHS Appropriations Act of 2007 grants DHS the authority to regulate chemical facilities that “present high levels of security risk.” Under the CFATS regulation, DHS may issue a violation and require that corrective actions be taken to correct any noncompliance issues. Violation of such a compliance order may result in civil penalties of $25,000 per day or to cease operations.

Facilities that are required to comply with at least some provisions of the CFATS regulation will largely fall into the following categories:

  • chemical manufacturing, storage, and distribution;
  • energy and utilities;
  • agriculture and food;
  • paints and coatings;
  • explosives;
  • mining;
  • electronics;
  • plastics;
  • universities and research institutions; and
  • healthcare and pharmaceuticals.

Definitions:

Chemicals of Interest: chemicals that give rise to one or more security issues, namely: release, theft/diversion, and/or sabotage/contamination. Appendix A of the CFATS Final Rule contains a list of all COIs with their pertinent information including: STQ, type of threat, CAS #, synonyms etc.

Screening Threshold Quantity; the amount at or above which the possession of a DHS COI must be reported to DHS using the CFATS rule. Each STQ is different for every COI and a COI may have several STQs dependent upon its use or category.

Facility: A facility is any establishment that possesses or plans to possess a quantity of a DHS COI at or above the established STQ. The University defines a facility as any University owned or leased building.

Top Screen: The Top-Screen is a questionnaire that gives DHS detailed information regarding any facility that has any of the DHS COI at or above the applicable STQ.

Consequences

Any facility that manufactures, uses, stores or distributes any of the DHS COI at or above the applicable STQ, and does not fall into an exemption, must complete and submit a Top-Screen questionnaire as a first step in complying with CFATS. The facility must complete and submit a Top-Screen to DHS within 60 calendar days of coming into possession of the COI. EHS will submit this after working with the relevant department.

Also each facility will be required to submit a Security Vulnerability Assessment (SVA), Site Security Plan (SSP) and Risk Based Performance Standards (RBPS). EHS will work with the department to prepare and submit the required information to DHS. A department or building representative will need to be appointed to work with EHS to prepare these submittals.

External Links

USAMRMC (Army) Grant

Purpose and Applicability

The USAMRMC requires grant recipients to follow specific safety standards and notification requirements.  The following links should be used by investigators who need to prepare safety and environmental documents for Army or DoD grant applications, and for managing USAMRMC grant compliance requirements. 

External Links