Chemical Security Program

The overall goal of this program is to provide guidance and support services to ensure the security of hazardous chemicals used in research, academic and University support activities. The programs primary focus is to assist the University community to ensure compliance with the U.S. Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS).

Chemical Facility Anti-Terrorism Standards

The Department of Homeland Security (DHS) issued the final rule of its Chemical Facility Anti-Terrorism Standard (CFATS) on November 20, 2007. The purpose of the Standard is to determine where certain Chemicals of Interest (COI) exist and whether additional security measures are required.

Significant efforts were made during the rule-making process to exempt colleges and universities from the reporting process, but these efforts were not successful. However, the final rule does include modifications that limit the impact on many colleges and universities, all of which are subject to CFATS.

As a result of the ruling, any institution that possesses, or expects to possess chemicals listed in
the ruling in excess of its listed thresholds, must submit a detailed survey to the DHS, and may be subject to performing a security vulnerability assessment and implementing a security plan.

EHRS is coordinating the University’s compliance with the CFATS in accordance with the DHS rules.  In June, 2007, the Provost distributed a letter to the Temple Community requesting that anyone in possession of COI immediately inform EHRS that they have a COI.

The Department of Homeland Security Appropriations Act of 2007 authorizes DHS to enforce compliance with security regulations, imposing civil penalties of up to $25,000 per day, and shutting down facilities that fail to comply with the regulations.

Chemical Security Requirements

The Chemical Facility Anti-Terrorism Standards (CFATS) are comprehensive risk based security regulations enforced by DHS.  These regulations provide guidance for securing certain Chemicals of Interest (COI) that could be used directly or indirectly for terroristic purposes. DHS requires Colleges and Universities in the possession of a COI to:

• Monitor
• Reports possessions above regulated threshold amounts
• Implement appropriate security measures

Chemicals of Interest (COI)

COI are organized by specific security and vulnerability concerns. They are categorized by the following types:

• Theft/Diversion: steal, divert, or otherwise acquired to use as a weapon at another time and place.
• Sabotage: sabotage or contaminate to explode or release in transit.
• Release: release as an explosive or to form a flammable or toxic cloud.

Refer to the DHS Appendix A: Chemicals of Interest for a listing of COIs.

Inventory Management of COI

ChemInventory, the Universities campus-wide chemical tracking system is an essential component of compliance with the CFATS regulations. All inventories must be updated and verified in ChemInventory at least annually.  Inventories that contain COIs should be reviewed frequently to ensure no theft or diversion has occurred.  

Purchasing of COI

Cooperation by the University community to purchase COI through the University purchasing protocol is necessary to maintain compliance.  To help facilitate compliance, EHRS strongly encourages that COI purchases are limited to the amount of materials needed for the experiment/operation.

Labeling of COI

All containers of COIs must be labeled with a warning label to remind personnel that they are regulated and cannot be shipped off campus without prior EHRS notification.

Example-“This chemical is federally regulated and cannot be shipped without prior EHRS notification. Contact EHRS for details.”

Security of COI

Multiple layers of security are required for COI stored in University areas. Examples of security layers include:

• Locked cabinet within a locked room.
• access controlled room with locked cabinet
• access controlled with a gated storage shed

Immediately report any suspect activity or loss of COI to Campus Safety Services at 1-1234.

Resources

CFATS Homepage
Department of Homeland Security Appendix A-Chemicals of Interest (COI)
CFATS Information for Colleges and Universities
FEMA: Workplace Security Awareness
FEMA: Protecting Critical Infrastructure Against Insider Threats
FEMA: Surveillance Awareness: What You Can Do
FEMA: Critical Security: Theft and Diversion-What You Can Do
EHRS Training