DHS Chemical Screen Service

What DHS Requires

DHS requires under the Chemical Facility Anti-Terrorism Standards (6 CFR Part 27) that any facility that manufactured, used, stored, or distributed chemicals listed in “Appendix A to Part 27 - DHS Chemicals of Interest” at or above the screening threshold quantity (STQ) must complete and submit an Internet based "Top-Screen" analysis using the DHS Chemical Security Assessment Tool (CSAT). Top-Screens are due January 22th, 2008 or within 60 calendar days of coming into possession of any such Chemical of Interest at or above the STQ.

Once DHS reviews a facility’s Top-Screen, the facility will be categorized into one of four tiers by DHS and will notified by DHS if it must evaluate the 19 elements of vulnerability and complete a Security Vulnerability Assessment (SVA) or if the facility can develop an Alternative Security Program (ASP). DHS will oversee the facility’s development of acceptable layering of measures used to meet the standards of the risk-based tier assigned to the facility. The facility will need to develop appropriate countermeasures and policies to meet DHS risk standards and complete a Site Security Plan (SSP).

Our View: The first and foremost task that needs to occur is to find out if your facility(s) have any of the DHS Chemicals of Interest present at your site that meet the requirements to go to the next step (Submitting a “Top-Screen”. E&SSG has provided services that help our clients cut through the regulatory red tape of regulated chemicals to find out what regulations affect them for more than 17 years. In light of this new standard, we have developed a service, utilizing our proprietary Chemical Inventory Analysis (CIA) system, to identify the DHS “Chemicals of Interest” present at your facilities and help you determine if this regulation is applicable to you.

What We Offer

DHS Chemical Screen Service

This service is designed to virtually eliminate the amount of time you would spend studying this regulation as well as searching, cross-referencing and indexing your chemical inventory against the DHS COI list. It will alleviate you from most of the countless hours you would spend just in order to determine if you need to perform, complete and submit an Internet based "Top-Screen" required by DHS. This simple and painless service provides you with vital, “site specific”, information about your chemicals and quantities needed to determine your requirements under this standard.

After the DHS Chemical Screen Service is complete, you will either have the chemical documentation you need to submit your “Top-Screen” or the documentation you need to show that this standard is not applicable to you.

Reports
The reports that you receive will show all the chemicals and what products they are in, percentages, as well as quantities at your facility. The reports will aggregate those quantities that meet or exceed the minimum concentration given for each chemical on the COI list. Those totals are then compared to the Screening Threshold Quantities (STQ) to show if you meet or exceed the threshold(s). A worksheet with the chemicals that exceed the STQ is also sent to you with questions that may allow you to eliminate particular products and/or chemicals from the totals.

The reports and subsequent worksheets include:
DHS Release – Toxic Chemicals
DHS Release – Flammable Chemicals
DHS Release – Explosive Chemicals
DHS Theft - CW/CWP (CUM 100 grams) Chemicals
DHS Theft - CW/CWP (Minimum DHS Concentration) Chemicals
DHS Theft - WME (CUM 100 grams) Chemicals
DHS Theft - WME (Minimum DHS Concentration) Chemicals DHS
Theft/Diversion - EXP/IEDP Chemicals
DHS Sabotage/Containment Chemicals

Next Steps: There are potentially several additional steps for you to be fully compliant with this standard (i.e. Top-Screen Submission, evaluate the 19 elements of vulnerability, complete a Security Vulnerability Assessment (SVA), develop an Alternative Security Program (ASP), develop appropriate countermeasures and policies to meet DHS risk standards, and complete a Site Security Plan (SSP).

If desired…once we know what your required next steps, we can develop a quote for the service(s) to fit your needs.