DEPARTMENT OF HOMELAND SECURITY OVERVIEW OF CHEMICAL SCREENING REQUIREMENTS

The Department of Homeland Security (DHS) Final Rule regarding chemical screening of facilities to determine whether they need to file a Top Screen report and conduct further chemical security activities was promulgated on Tuesday 11/20/07. http://www.dhs.gov/xprevprot/programs/gc_1169501486179.shtm

The newly promulgated regulations require that all facilities (not just manufacturing) determine within 60 days whether they exceed the specified threshold inventory amounts for a specific list of chemicals of interest (COI's).

ALL FACILITIES NEED TO CONDUCT SCREENING TO DETERMINE IF THEY EXCEED THRESHOLDS FOR THE LISTED CHEMICALS, not just manufacturing.  Universities, medical centers, agriculture, warehouses, allwill all need to conduct threshold determinations. A number of common chemicals such as propane, nitric acid, hydrogen peroxide and triethanolamine are on the list. Process intermediates are required to be included in threshold determinations, as are tank cars uncoupled from their motive power. Threshold amounts can be as low as 100 grams across the entire site for particularly hazardous chemicals, other thresholds are in the 500-10,000 pound range (just over 1 55 gallon drum to approx. 22 drums), and are for the facility as a whole, not just for particular storage locations.

Furthermore, this is an ongoing requirement; at any time that the inventory of the chemicals on the DHS list exceed their threshold amounts, the facility has 60 days in which to complete a Top Screen report that is used to determine the extent to which further security planning will be required.