Update on Revisions of Appendix A, 6 CFR part 27

Last month, during the Chemical Sector Security Summit (June 11 thru 13, 2007) in Falls Church, VA, Lawrence Stanton, Director, Chemical Security Compliance Division, took part in a discussion with Gregory Minchak the Manager of Communications and Public Relations for SOCMA (a chemical manufacturer's organization) that was podcast for SOCMA. DHS recently posted a transcript of that conversation on their web site.

One of the things that was covered in their discussion was the revision of Appendix A, Chemicals of Concern, for the new Chemical Facility Anti-Terrorism Standards (CFATS) regulation (6 CFR part 27). The draft of this appendix was published in the Federal Register on April 9, 2007 and the comment period closed on May 9, 2007. It was expected that the final revised version would be published a little after June 8, 2007. It has not yet been published.

During the comment period for the draft Appendix there were three major issues raised: The Screening Threshold Quantity (STQ) for Propane (the propane industry thought that it was way too low), lack of definition for dealing with chemical mixtures, and the 'Any Quantity' STQ for many chemicals that were related to chemical weapons manufacture. A number of legitimate questions were also made about how to deal with very small quantities of the 'Any Quantity' chemicals that were found in school and hospital labs around the country.

Early indications were that there was not going to be any major revisions to this list of chemicals or the STQ listed in the draft. This was based on the amounts listed in the Top Screen User's Manual published on June 8th. There were no changes to any of the STQs that had been listed in the draft. There was nothing dealing with mixtures. The only changes to the 'Any Quantity' STQ was that the words were missing from the tables, but they had not been replaced with any thing else.

Director Stanton made a number of points in this interview about the revised Appendix A. First he assured everyone that all of the comments were seriously considered and substantial revisions were being made to Appendix A based on many of the comments. Secondly, the revised Appendix A would be issued in the near future; no specific time was given.

In regards to the mixture questions Director Stanton replied: "...what we have done as a response in a lot of the comment we've received is we have developed a specific mixture rule for each specific chemical wherever the need for such a mixture rule was evident to us." He also indicated that if a more complex, or authoritative rule was found to be necessary, they would develop one over the next year or so.

This was the only thing that was specifically discussed about Appendix A other than Director Stanton assuring everyone that DHS had carefully reviewed the 6,000 plus pages of comments that they had received and had made appropriate changes. In his words the revised Appendix A: "...is going to be a very good, very easy to understand, very useful and very effective tool, and we think that industry is going to be quite pleased with it."

If there have been substantial changes to the STQ, the Top Screen User's Manual will have to undergo some revisions. The advent of mixture rules for selected chemicals will almost certainly require revisions. That may be what is holding up the release of the revised Appendix A. For most facilities the 60 day clock to complete their initial Top Screen starts on the day Appendix A is published. DHS may want to insure that the revised Top Screen and its manual are firmly in place before publishing Appendix A.

The original Top Screen User's Manual had to be in place on June 8th because DHS expected to direct a number of chemical companies previously identified as being potentially high risk facilities (most probably refineries, LPG facilities, and producers of Inhalation Hazard chemicals) to start the Top Screen Process. Most of those Top Screen's should have been completed by now. The new version of Appendix A should be published anytime.

Patrick J. Coyle has 15 years experience with the US Army, including a stint as a Physical Security NCO in Europe. He has also spent 12 years working as a Process Chemist is a specialty chemical manufacturing company.

Further information about the new regulations concerning protecting chemical plants from terrorist attack can be found at http://www.members.aol.com/ChemPlantSec/ChemPlantSecurity.htm

Transcript: http://www.dhs.gov/xprevprot/programs/gc_1183756213780.shtm

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