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Navigating CFATS in Academia

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by

Robin Izzo

on 29 September 2016

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Transcript of Navigating CFATS in Academia

Now what?
Expect Notice of Proposed Rulemaking in October 2016
A Little History
Why labs?
The best place to steal chemicals is a college. Many state schools have all of their chemicals out on the shelves in the labs, and more in their chemical stockrooms. Evening is the best time to enter lab buildings, as there are the least number of people in the buildings, and most of the labs will still be unlocked. One simply takes a bookbag, wears a dress shirt and jeans, and tries to resemble a college freshman. If anyone asks what such a person is doing, the thief can simply say that he is looking for the polymer chemistry lab, or some other chemistry-related department other than the one they are in.
Current Status
DHS has
Received > 50,000 Top Screens
Reviewed > 9,000 SVAs
~2600 Site Security Plans
Approved ~2200

Concerned about how few colleges and universities completed Top Screens
Did not want negative reports, but...

Colleges and Universities (preliminary)
Tier 1: 5
Tier 2: ~30
Tier 3: ~50
Tier 4: ~100


Revisions Expected
August 2014
: Advanced Notice of Proposed Rulemaking
Sought comments on all aspects of the rule

October 2014
: Deadline for comments
72 comments, including CSHEMA
ACS supported CSHEMA comments

November 2014
: Listening sessions in Atlanta and Chicago - three attendees, one testified on behalf of propane and petroleum industry


Navigating CFATS in Academia
Thank you!
Enforcement Guidance Memorandum 98-004
Increased Control Order 2005

2002 Edition
Appendix F: Security
Department of Homeland Security Appropriations Act of 2007
~ October 4, 2006

With
6 months
, must establish risk based performance standards for chemical facilities
December 2006
: Proposed Rule

April 2007
: Final Rule, Proposed Appendix A

May 2007
: Establish University Working Group
Campus Safety Health and Environmental Management Association (CSHEMA)
American Council on Education (ACE)
American Public and Land Grant Universities (APLU)
Association of American Universities (AAU)
National Association of College and University Business Officers (NACUBO)

November 2007
: Final Rule
~ The Terrorist's Handbook
CFATS in 6 Easy Steps
Survey Your Campus
~ 300 chemicals in Appendix A

Determine if above Screening Threshold Quantities (STQs)
Complete Top Screen
Web-based application
Chemical Security Assessment Tool (CSAT)
Register to gain access
Need to register for each “Facility”
Identify Preparer, Submitter and Authorizer Complete Top Screen
DHS estimates 30 hours per Facility, including time to learn how to use the CSAT
Create pdf form. Sign and submit to DHS

NOT
REGULATED
MAY BE
REGULATED
Conduct Security Vulnerability Assessment
DHS Assigns Risk Tier
Campus Develops Site Security Plan
Potential impacts (
consequences
)
Likelihood of success (
vulnerabilities
)
Likelihood of occurrence (
threats
)
HIGHEST Risk
LOWEST Risk
Chemicals of Interest
Three Categories
Theft
Release
Sabotage
Security Issues
Seven Categories
Basis for Security Vulnerability Assessments (SVA)
Release
- Toxic, Flammable, Explosive

Theft
- Chemical weapons, precursors, weapons of mass effect, explosives, improvised explosive device precursors

Sabotage
or Contamination

RELEASE Chemicals
Excludes laboratory chemicals

Main concern
: Release from containers
THEFT Category
Does include laboratory chemicals

Only materials in “transportation packaging”
Excludes materials in beakers, equipment, etc.
Excludes materials in tanks, stationary containers, etc.

Cumulative across the facility

CUM 100 grams
Chemical Weapons and Precursors

For each
facility
, add together the total quantities of all of these materials

Example:
25 g sulfur mustard + 40 g chlorosarin + 50 g tabun
=115 g


Exceeds STQ CUM 100g

SABOTAGE Chemicals
Include only chemicals
shipped
by the institutions
Does not include those that are only received and used

STQ is the DOT placarded amount
1001 lbs or “
any amount
”, depending on the material
See DOT Table in 49 CFR 172
RCRA Hazardous Wastes

Excluded for Release, Theft and
Sabotage

P and U listed wastes are not exempt

Potential issue:
Shipping P or U listed wastes above STQ
Aluminum phosphide (P006) – any amount
Acetone cyanohydrin (P069) – any amount
Phosphorus pentasulfide (U189) – any amount

The Big Issues for Labs
Facility
Inventory
Security
Updating
Definition of Facility is Vague
Campus
Complex
Building
Lab
DHS encourages BUILDING
Inventory
Inventory system in place?

Point in time reporting - last 60 days

No specific timeframe for inventory

Purchasing controls
Keeping inventory below STQ
Purchasing controls

Refusal to ship certain chemicals of interest
No easy way to update...

Must submit a new Top Screen
Top Screen - what was there in past 60 days
Can change status
Security Plan Requirements
Apply to entire facility
Once a chemical is reported, security applies EVERYWHERE it is, independent of quantity
Requirements do not work for a college campus
Open concept
Multiple use buildings
Shh.....
Chemical-terrorism Vulnerability Information
(CVI)
Status of CFATS
Sunset 2009
Reauthorized, sunset 2014
Dec 2014, president signed
Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2014
Extends CFATS indefinitely
Public Roundtable Discussion and Listening Session
October 27, 2015, Washington, DC
Robin Izzo and Keri Moss Stearns (ACS Public Affairs) attended in person
Participated in Q&A
Testified on behalf of laboratories
Exempt labs

OR

Allow
Facility
to be a laboratory
Make it easier to update Top Screen
Provide examples of Alternative Security Plans for Academic Institutions
Raise the STQ of Sabotage Chemicals from "any quantity" to an actual number
Perhaps 2.2 lb or 1 kg
Secure your chemicals - show DHS that we do not need regulation
It's okay to talk about what you're doing as part of peer review/sharing...using good judgment
Control your inventory
Full transcript