Chemical Distributors' Group Wants 'Facility' Redefined in DHS's Anti-Terrorism Rule

The National Association of Chemical Distributors filed comments yesterday asking the Department of Homeland Security to modify the definition of "chemical facility" in Appendix A of DHS's proposed Chemical Facility Anti-Terrorism Standards. Appendix A is the list of chemicals and quantities that trigger the requirement to fill out a "Top Screen" questionnaire that determines whether a facility would need to complete a Security Vulnerability Assessment and Site Security Plan.

NACD cited what it called the low threshold amounts for many chemicals on the list, how blends or mixtures should be handled, and the format of the appendix. It said the facility definition should be modified to clarify the requirements applying to distributors who do not store chemicals on site or store them for only limited periods. DHS also should specify quantities that experts believe would be necessary to produce an off-site consequence to the public, the association said.

As written, Appendix A requires for many chemicals that a facility possessing "any amount" would have to complete a Top Screen. NACD said DHS should align screening threshold quantities with EPA threshold quantities and also issue the list in Appendix A in a Chemical Abstract Service numerical sequence along with the current alphabetical listing.

Download Center

HTML - No Current Item Deck
  • Free Safety Management Software Demo

    IndustrySafe Safety Management Software helps organizations to improve safety by providing a comprehensive toolset of software modules to help businesses identify trouble spots; reduce claims, lost days, OSHA fines; and more.

  • Easy to Use Safety Incident App

    Record incidents on the go with IndustrySafe’s mobile app. Collect data for multiple types of incidents including including near misses, vehicle and environmental incidents, and employee and non-employee injuries; at job sites and remote locations—with or without web access.

  • Safety Training 101

    When it comes to safety training, no matter the industry, there are always questions regarding requirements and certifications. IndustrySafe is here to help. We put together a resource that’s easy to digest so you can get answers to your training questions and ensure you're complying with OSHA's standards.

  • Conduct EHS Inspections and Audits

    Record and manage your organization’s inspection data with IndustrySafe’s Inspections module. IndustrySafe’s pre-built forms and checklists may be used as is, or can be customized to better suit the needs of your organization.

  • Track Key Safety Performance Indicators

    IndustrySafe’s Dashboard Module allows organizations to easily track safety KPIs and metrics. Gain increased visibility into your business’ operations and safety data.

  • Industry Safe
comments powered by Disqus