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.

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