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Chemical Facility Anti Terrorism Standards
Principle Subject Matter Expert: Jack McCann
McCann Global can help to prepare you for the upcoming regulatory mandated surveys and “red team” testing that will be required to be CFATS compliant. With over 100 chemical security enforcement officers already deployed and over 200 more to come, CFATS is not going away. At McCann Global we believe the enforcement and associated regulations will be more extensive then the private petro chemical industry has ever seen. The regulations and the associated required security programs, policies, systems, and testing may end us very similar to regulations and requirements in the nuclear regulatory arena.
CFATS 101: Overview by Daniel Weiss, McCann Global CFATS Expert
Even before, September 11th, 2001, the federal government was aware of the risk that our nations private critical infrastructure presented for our long term national interests. As far back as the Clinton Administration, the executive branch began to ask what critical infrastructure is and how should we best address both domestic and international terror threats to our critical infrastructure. Of course, 9/11 put all of these discussions and proposed legislative initiatives in a new light and on a fast track.
The first move came with Presidential Directive 7 which encouraged the private and public sector to work together to address these critical facilities. What became clear was that 85-90% of all critical infrastructure is not public, but private. What also became clear is the most critical of these assets are our nation’s petrochemical infrastructure, this being our refineries, chemical blending facilities, tank farms, and pipelines.
For years we had focused across the oceans to the Middle East and Africa to ensure that the raw oil could come out of these troubled regions and make it to the safe harbor our refineries and production facilities. In the post 9/11 world we now had to worry if the raw oil was safe in our former safe harbor. By 2002, it seemed clear that the petrochemical industry would be the first target of new government regulations that were growing out of the newly formed Department of Homeland Security (DHS).
The nation hosts at least 40,000 “meaningful” chemical manufacturing and storage sites, and many of them can be used not only as secondary weapons, but would cause economic instability and damage if destroyed or crippled. The government and the petrochemical industry, lead by the American Petroleum Institute (API), National Petrochemical and Refiners Association (NPRA), and the Energy Security Council (ESC) worked with the new DHS craft meaningful and doable legislation. The response was a legislative act called the Chemical Facility Anti Terrorism Standards (CFATS).
On June 8, 2007, the DHS CFATS became a Federal Regulation under 6CFR27. These new regulations attempted to put in place a uniform set of rules to analyze the nation’s chemical and petro chemical facilities. These facilities had to be assessed against Risk Based Performance Standards (RBPS).
By January 2008, companies that either manufactured or stored chemicals of interest were required to submit top screens to DHS, known as the Chemical Security Assessment Tool (CSAT) Top-Screen. Over 40,000 companies submitted top screens, about 7,000 were picked as being significant enough to warrant regulation. These 7,000 facilities were rated one through four, with one being the highest risk and four being still at-risk, but to a lesser degree, however still requiring regulation.
The CFATS regulations impact the petrochemical industry by requiring over 7,000 facilities to implement security systems/upgrades in order to meet the performance based standards, set forth by the Department of Homeland Security (DHS). These new regulations are not suggestions, but hard regulations that have regulatory teeth, with over 300 plus enforcement agents coming into the field. If the facilities fail to meet the new standards, they face shutdown.
Facilities were required to submit plans to assess and address security vulnerabilities. This process is known as the SVA process. For security venerability assessment DHS required the impacted companies and their facilities to use a DHS SVA tool, known as Chemical Security Assessment Tool Security Vulnerability Assessment (CSAT-SVA), to analyze their risk.
Facilities, based on their Tier Classification, have between 90-180 days to submit the CSAT-SVA. This is from the date they receive the formal Tier Classification letter, most of which have been sent out, as of February 2009. Post the SVA stage, the facilities have to submit a SSP, or Site Security Plan (SSP). The SSP identifies that which the sites plan to do to address the security issues identified in the SVA process.
The SSP stage begins to unfold for the impacted facilities after the SVA process. The SSP goes back to DHS for review and comment before a final plan is approved. This will be taking place in the next 8 months.
The regulations call for continued assessment, continual improvement, and will expand to other like facilities. It has already spawned add-on legislation to include facilities with “meaningful chemical storage.”
The new CFATS regulations will cause hundreds of millions, if not billions, to be spent protecting Class One through Class Four chemical facilities, much of which will spent on perimeter detection and defense, CCTV systems, access control, and general intrusion detection. It will also include hundreds of millions to be spent on an annual basis for compliance, review and continual assessment and upgrades.
The "go time" for the implementation of the first stage of CFATS upgrades begins at the end of 2009. However, the legislation is growing an becoming more complex.
Chemical Facility Anti-Terrorism Standards Interim Final Rule, effective June 8, 2007
Appendix A: Final Rule (PDF, 41 pages - 2.12 MB), effective November 20, 2007
Chemicals of Interest List (PDF, 16 pages - 2 MB)
Read the Draft Risk-Based Performance Standards Guidance (PDF, 178 pages - 853 KB)
CSAT Top-Screen Questions (PDF, 165 pages - 12.29 MB)
CSAT Top-Screen User’s Manual (PDF, 87 pages - 1.17 MB)
CFATS FAQ
Review CSAT SVA Questions (PDF, 107 pages - 1.26 MB)
Review CSAT SVA Instructions (PDF, 92 pages - 1.78 MB)
Principle Subject Matter Expert: Jack McCann
McCann Global can help to prepare you for the upcoming regulatory mandated surveys and “red team” testing that will be required to be CFATS compliant. With over 100 chemical security enforcement officers already deployed and over 200 more to come, CFATS is not going away. At McCann Global we believe the enforcement and associated regulations will be more extensive then the private petro chemical industry has ever seen. The regulations and the associated required security programs, policies, systems, and testing may end us very similar to regulations and requirements in the nuclear regulatory arena.
CFATS 101: Overview by Daniel Weiss, McCann Global CFATS Expert
Even before, September 11th, 2001, the federal government was aware of the risk that our nations private critical infrastructure presented for our long term national interests. As far back as the Clinton Administration, the executive branch began to ask what critical infrastructure is and how should we best address both domestic and international terror threats to our critical infrastructure. Of course, 9/11 put all of these discussions and proposed legislative initiatives in a new light and on a fast track.
The first move came with Presidential Directive 7 which encouraged the private and public sector to work together to address these critical facilities. What became clear was that 85-90% of all critical infrastructure is not public, but private. What also became clear is the most critical of these assets are our nation’s petrochemical infrastructure, this being our refineries, chemical blending facilities, tank farms, and pipelines.
For years we had focused across the oceans to the Middle East and Africa to ensure that the raw oil could come out of these troubled regions and make it to the safe harbor our refineries and production facilities. In the post 9/11 world we now had to worry if the raw oil was safe in our former safe harbor. By 2002, it seemed clear that the petrochemical industry would be the first target of new government regulations that were growing out of the newly formed Department of Homeland Security (DHS).
The nation hosts at least 40,000 “meaningful” chemical manufacturing and storage sites, and many of them can be used not only as secondary weapons, but would cause economic instability and damage if destroyed or crippled. The government and the petrochemical industry, lead by the American Petroleum Institute (API), National Petrochemical and Refiners Association (NPRA), and the Energy Security Council (ESC) worked with the new DHS craft meaningful and doable legislation. The response was a legislative act called the Chemical Facility Anti Terrorism Standards (CFATS).
On June 8, 2007, the DHS CFATS became a Federal Regulation under 6CFR27. These new regulations attempted to put in place a uniform set of rules to analyze the nation’s chemical and petro chemical facilities. These facilities had to be assessed against Risk Based Performance Standards (RBPS).
By January 2008, companies that either manufactured or stored chemicals of interest were required to submit top screens to DHS, known as the Chemical Security Assessment Tool (CSAT) Top-Screen. Over 40,000 companies submitted top screens, about 7,000 were picked as being significant enough to warrant regulation. These 7,000 facilities were rated one through four, with one being the highest risk and four being still at-risk, but to a lesser degree, however still requiring regulation.
The CFATS regulations impact the petrochemical industry by requiring over 7,000 facilities to implement security systems/upgrades in order to meet the performance based standards, set forth by the Department of Homeland Security (DHS). These new regulations are not suggestions, but hard regulations that have regulatory teeth, with over 300 plus enforcement agents coming into the field. If the facilities fail to meet the new standards, they face shutdown.
Facilities were required to submit plans to assess and address security vulnerabilities. This process is known as the SVA process. For security venerability assessment DHS required the impacted companies and their facilities to use a DHS SVA tool, known as Chemical Security Assessment Tool Security Vulnerability Assessment (CSAT-SVA), to analyze their risk.
Facilities, based on their Tier Classification, have between 90-180 days to submit the CSAT-SVA. This is from the date they receive the formal Tier Classification letter, most of which have been sent out, as of February 2009. Post the SVA stage, the facilities have to submit a SSP, or Site Security Plan (SSP). The SSP identifies that which the sites plan to do to address the security issues identified in the SVA process.
The SSP stage begins to unfold for the impacted facilities after the SVA process. The SSP goes back to DHS for review and comment before a final plan is approved. This will be taking place in the next 8 months.
The regulations call for continued assessment, continual improvement, and will expand to other like facilities. It has already spawned add-on legislation to include facilities with “meaningful chemical storage.”
The new CFATS regulations will cause hundreds of millions, if not billions, to be spent protecting Class One through Class Four chemical facilities, much of which will spent on perimeter detection and defense, CCTV systems, access control, and general intrusion detection. It will also include hundreds of millions to be spent on an annual basis for compliance, review and continual assessment and upgrades.
The "go time" for the implementation of the first stage of CFATS upgrades begins at the end of 2009. However, the legislation is growing an becoming more complex.
Chemical Facility Anti-Terrorism Standards Interim Final Rule, effective June 8, 2007
Appendix A: Final Rule (PDF, 41 pages - 2.12 MB), effective November 20, 2007
Chemicals of Interest List (PDF, 16 pages - 2 MB)
Read the Draft Risk-Based Performance Standards Guidance (PDF, 178 pages - 853 KB)
CSAT Top-Screen Questions (PDF, 165 pages - 12.29 MB)
CSAT Top-Screen User’s Manual (PDF, 87 pages - 1.17 MB)
CFATS FAQ
Review CSAT SVA Questions (PDF, 107 pages - 1.26 MB)
Review CSAT SVA Instructions (PDF, 92 pages - 1.78 MB)
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