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Updates, Comments & Other Reports
December 2007 On December 10, ILTA, in
conjunction with API and NPRA, sent a
letter
to DHS, requesting clarification regarding the reporting and modeling of
chemicals of interest within fuels mixtures under CFATS. Specifically, the
letter requested that DHS stay the relevant provisions (§27.203
(b)(1)(v)) and extend any compliance deadlines for covered facilities.
November 2007 DHS
has published the final Appendix A to CFATS. This rule contains the list of
“chemicals of interest (COI).” Facilities that possess a screening threshold
quantity of any COI are required to submit a Top-Screen Application by January
22, 2008.
August 2007 The CFATS
help desk has developed a bulk upload registration spreadsheet for large
companies that are required to register multiple facilities with CSAT. Note,
the bulk upload process is only for the registration process, not for
answering the top-screen questions. Contact the CSAT help desk at 1-866-323-2957
for more information or to request the bulk upload spreadsheet.
June 2007 The Chemical
Facility Anti-Terrorism Standards, Interim Final Rule goes into effect June 8,
2007. If your facility is not already regulated by MTSA, AND if you could
possess a threshold quantity of any of the chemicals ultimately listed in a
final Appendix A, then you must register under CFATS using the
Chemical
Security Assessment Tool (CSAT). You are also required to complete a “top
screen” application.
May 2007 ILTA is an active member of
the Chemical Sector Coordinating Council (CSCC). On May 9, 2007, the CSCC
submitted
comments on
behalf of the chemical industry relating to Appendix A.
January 2007
On December 22, 2006, DHS
announced proposed regulations for chemical plant security. DHS requested
comments on the proposed rule by February 7, 2007. A question remains regarding
specification of facilities that will be regulated by this rule. DHS loosely
defines chemical facility as any facility that possesses or plans to possess a
quantity of a chemical substance determined by DHS to be potentially dangerous
or that meets other risk-related criterion. The rule excludes maritime
facilities regulated by the MTSA, Sec. 105. It is, however, unclear whether it
will include facilities subject to other maritime security regulations pursuant
to MTSA but NOT covered by part 105.
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