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Department of Homeland Security reinstates CSAT “Top-Screen” Survey Requirement

The Chemical Facility Anti-Terrorism Standards (CFATS) program was promulgated by the Department of Homeland Security (DHS) on April 9, 2007 in an effort to lower the risk posed by certain chemical facilities. The program requires facilities to provide DHS with information via the Top-Screen Survey to determine whether they are required to meet certain security performance standards. DHS temporarily suspended the program in early 2016; however, on October 1, 2016, the requirement to submit Top-Screen surveys was reinstated.

Facilities that had previously submitted a Top-Screen Survey to DHS are being notified by DHS to resubmit their survey via the online Chemical Security Assessment Tool (CSAT 2.0). Facilities that had not previously filed a survey in possession of screening threshold quantities (STQs) of any listed Chemical of Interest are expected to proactively file a survey. Additionally, any facility that comes into possession of STQs of a chemical of interest is required to report their holdings within 60 days by filling out a Top-Screen survey.

Following the Department’s review of a facility’s CSAT Top-Screen submission, the facility may be notified by DHS that it is considered high-risk and assigned to Tier 1, 2, 3, or 4. High-risk facilities will be required to submit a Security Vulnerability Assessment (SVA) and Site Security Plan (SSP) through CSAT.

The CSAT web-based system can only be accessed by “authorized” individuals. Individuals can become authorized by completing the Chemical-terrorism Vulnerability Information (CVI) Authorized User Training.

In summary:

  • A facility is required to submit a Top-Screen survey if it:
    • has been contacted by DHS to submit a Top-Screen Survey;
    • has submitted a Top-Screen Survey in the past; or
    • manufactures, uses, stores, or distributes any Chemical of Interest above the STQ as listed in Appendix A.
  • Top-Screen Survey submitters are required to be CVI authorized.
  • Facilities that are considered high-risk will be contacted by DHS and required to meet certain security standards.

The requirements for submittal of a Top Screen survey can be found here:

https://www.dhs.gov/csat-top-screen

https://www.gpo.gov/fdsys/pkg/FR-2008-01-09/pdf/E8-199.pdf

The Appendix A list of Chemicals of Interest can be found here:

https://www.dhs.gov/sites/default/files/publications/appendix-a-to-part-27-508.pdf

Virginia DEQ Requires Industrial Storm Water Permit Registrations by May 2, 2014

Virginia industrial facilities are required to submit new registration statements by May 2, 2014 for coverage under the 2014 VA DEQ general permit.  The new permit is effective July 1, 2014.  Requirements for several industry sectors are different than the previous (2009) permit.  Covered facilties should not only submit the registration statement but should also evaluate the impact of the permit changes on their operations and Storm Water Pollution Prevention Plans (SWPPPs).

VA DEQ Information:  http://www.deq.virginia.gov/Programs/Water/PermittingCompliance/PollutionDischargeElimination/PermitsFees.aspx#isw

For support in addressing the new permit, contact your EPS consultant.