Dhs Publishes Top Screen Requirements - Toxic Chemicals

Epa Regulations - Dhs Publishes Top Screen Requirements - Toxic Chemicals

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On Friday, June 8, 2007, the group of Homeland safety (Dhs) published the guidelines that organizations will need to supervene to submit the Top Screen information to the Dhs Chemical safety evaluation Tool (Csat). The information submitted straight through this fetch web site will be used by Dhs to decide if the chemical factory is a high-risk factory requiring supplementary regulation under 6 Cfr part 27, Chemical factory Anti-Terrorism Standards (Cfats).

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The first habitancy that will be required to submit information to the Top Screen module will be those facilities previously identified by Dhs as probably being high-risk facilities, whether based on a facilities single condition (being settled in an urban area for example) or as a class due to the type of chemicals being institute (Chlorine for example). These organizations will be contacted by direct letters from Dhs or by a observation being published in the Federal Register.

Two Pdf documents show up on the Dhs Top Screen study page: Csat Top Screen Questions and Csat Top Screen Users Manual. While both of these documents are rather long (80 pages and 66 pages respectively), it is inevitable that Dhs has worked hard to make this data collection attempt as painless as possible. Facilities that will be required to submit information to the Top Screen Module will indeed want to print out the Top Screen Questions document and use it to report the information that they will be required to submit. This will help them to fetch and institute the information in a way that will be indeed accessible when they go online.

To make things easier to enter the essential data on the chemicals of interest, Dhs has taken the 300+ chemicals listed in Appendix A and grouped them into nine groups. Those groups are:

1. Toxic Chemicals,

2. Flammable Chemicals,

3. Explosive Chemicals,

4. Improvised Explosive expedient (Iep) Precursor Chemicals,

5. Weapons of Mass supervene (Wme) Chemicals,

6. Chemical Weapons/Chemical Weapon Precursor (Cw/Cwp) Chemicals,

7. Sabotage/Contamination Chemicals,

8. Mission essential Chemicals,

9. Economically essential Chemicals.

Each of these nine groups of chemicals will wish responses to dissimilar kinds of questions based on they types of chemicals. In each category, however, there will be a preliminary list of chemicals from Appendix A for that category, with Yes and No checkbox beside the chemical. The default response will be No. The submitter will check the Yes box only for those chemicals on site or that had been on site within the last 12 months, and the quantity was equal to or in excess of the Screening Threshold Quantity (Stq) listed.

When determining how much of a chemical is thought about to be on site, the factory Submitter must take into observation how much is in warehouse tanks, other containers, process equipment, and piping and in rail cars, both on site and in sidings immediately adjacent to the site. If there are documented procedures limiting the quantity on site, those can be taken into account. If there are no documented procedures, the maximum quantity potential in the varied containers will be used to decide how much may be on site.

The Top Screen guidance introduces other thought that they use to value the hazard linked with chemicals on site, the Ahq (Area of highest Quantity). The Ahq tries to take into inventory the fact that if a chemical is distributed over a wide area in a factory it will probably be less of a risk while a terrorist attack, because it will be harder to release all of the chemical. To decide the Ahq you must decide where the largest attentiveness of the chemical is within a circle of a diameter of 170 feet. Thus, if there were a whole of warehouse tanks on site, but were widely scattered you would use the largest tank or aggregate of tanks that would be in a single 170 foot diameter circle to decide the Ahq amount.

There are 50 separate chemicals listed on the Toxic Chemical list. Dhs has superior these 50 chemicals to be on the Toxic Chemical list because Dhs believes that, if released, they have the potential for essential acute adverse consequences for human life or health. To value the level of risk these chemicals pose in the facilities single situation Dhs will use a process similar to the Epa's Risk management Program's (Rmp) worst case scenario assessment. This will wish supplementary information for the factory in general and for each of the chemicals on site that are being reported. This information will include:

1. Topography for the area where the factory is sited (Urban/Rural).

2. Total (maximum) onsite quantity.

3. Distance of concern from the Epa's Rmp*Comp calculator for that chemical.

4. Quantity in Ahq

5. Distance of concern for quantity in Ahq.

This will be a time interesting process to perfect all of the Top Screen information, but it will not have to be done at a single sitting. The incomplete information will be saved between multiple sessions. Many facilities will not have to perfect the entire 80 page process. There are many places, where depending on the answers to varied questions, the Top Screen will acquaint the Submitter that the factory is not a high-risk factory and no supplementary operation is needed under 6 Cfr part 27 until something changes at the facility. Some facilities will be told at the end of the submission that they are preliminarily designated a high-risk factory and must perfect a safety Vulnerability evaluation (Sva) within 90 days. Most facilities, however, will have to perfect the entire Top Screen only to be told that they might be declared a high-risk facility, but that measurement will be made after supplementary recap at Dhs. Those facilities will have to wait for a letter telling them what the preliminary out come will be.

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