Chemical Facility Security

As part of the Homeland Security Appropriations Act of 2007 (section 550), the Department of Homeland Security (DHS) was given authority to issue federal regulations to ensure the security of chemical facilities against terrorist and other criminal activities that could result in economic harm and loss-of-life. Subsequently the DHS has issued an interim final rule in 6 CFR Part 27. Those facilities that possess chemicals in the amounts specified in Appendix A of that regulation must submit a Top-Screen through the DHS’s Chemical Security Assessment Tool (CSAT). The Top-Screen is due 60 days after the final publication of Appendix A of 6 CFR 27 (final Appendix A expected by the end of June 2007) and registration in the CSAT system is required prior to submittal.

The DHS will review the submitted Top-Screen and then determine whether the facility is a high-risk for potential terrorist attacks and as such assign it to a preliminary risk-based tier. That facility will then be required (as notified in writing from the DHS) to develop and submit a Security Vulnerability Assessment (SVA) detailing multiple security facets including asset characterization, threat assessment, security vulnerabilities, risk assessment and countermeasures analysis. Once the SVA has been approved by the DHS (again, notified in writing by the DHS), the facility will then be required to detail and submit a Site Security Plan (SSP). The site security plan should address the vulnerabilities identified in the SVA and satisfy the performance standards detailed in the federal regulation (6 CFR 27.230).

Safety Management Services Inc. (SMS) is qualified to assist chemical facilities by providing support in understanding the federal regulation, assisting in drafting a site SVA and/or SSP that will satisfy the regulations specified by the Department of Homeland Security while ensuring that the chemical facility isn’t overly burdened by compliance. The process of characterizing security assets and threats and completing consequence and vulnerability analysis as part of the SVA and SSP is akin to the failure mode and effects analysis routine performed by SMS in assessing safety risks, characterizing them and identifying steps to mitigate the identified risks. SMS understands government regulations and their implementation and is recognized in the United States as an approved and authorized Examining Agency by the Department of Transportation to perform explosives and other hazardous materials examination services.

SMS personnel have been mitigating processing risks and facilitating client’s compliance with federal regulations at explosive and chemical manufacturing facilities for more than 20 years across the United States and in multiple foreign countries. SMS can help you prepare for and submit a Top-Screen, SVA, and SSP as required.