BACKGROUND:
The Department of Homeland Security (DHS) has issued the Chemical Facility Anti-terrorism Standard (6 CFR 27) LINK for any facility that manufactures, uses, stores or distributes “listed” chemicals above specified threshold quantities. All facilities, including colleges and universities, in possession of the “listed” chemicals shown on the Appendix A LINK must complete a consequence assessment known as a “Top Screen” which will allow DHS to make preliminary determinations about the level of risk the facility presents.
In order to limit the time and effort required for you to prepare and submit the required information for your labs/locations, EH&S has done the following:
a) Converted Appendix A to an excel table (FORM 2) LINK
(b) Provided you with an inventory template (FORM 1) LINK
We estimate that updating the inventory for your laboratory and including the information required by DHS should take no more than 60 to 90 minutes. If your laboratory is currently out of compliance with regard to maintaining an inventory of chemicals, this task will take you somewhat longer.
It is important to know that there are some rigorous requirements related to mixtures and those labs having any of the chemicals that have been flagged by DHS as high priority will be contacted about mixtures you may have on hand. We sincerely hope that you respond by December 21, 2007 as EH&S will require adequate time to collate the information submitted from more than 300 locations/labs.
IMPORTANT! Please keep a copy of the forms submitted readily accessible. EH&S will post the answers to Frequently Asked Questions as we receive these questions, and share information with our colleagues at other colleges and universities who are also working furiously to comply with this mandate. |