Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standard

1. Department of Homeland SecurityChemical Facility Anti-Terrorism Standard(CFATS)Impact on Washington UniversityBruce BackusEnvironmental Health & SafetyNovember 29, 2007

2. Purpose is to prevent chemicals that have historically been used for terrorist or mass casualty incidents from falling into the wrong hands First phase – all companies, including colleges and universities, must screen all their chemicals for 325 specific compounds and report to DHS if they exceed certain thresholds Some thresholds are any amount and some are 100 grams cumulative total for the whole institution. Final Rule published on November 20, 2007 6 Code of Federal Regulations (CFR) Part 27 Department of Homeland Security (DHS)Chemical Facility Anti-Terrorism Standard

3. Chemical Facility Anti-Terrorism Standard Timeline • There is a very short deadline for doing the inventories and submitting required documentation to DHS • Facilities have 60 days to complete the initial chemical screening process • Due January 18, 2008 • The 60 days must include the 40-60 hours needed for Environmental Health and Safety (EH&S) to complete the DHS “Top Screen” paperwork • This requires submittal of screening results by departments to EH&S by January 4th 2008.

4. Chemical Facility Anti-Terrorism Standard Timeline • We are requesting a 60 day extension • Maximum extension allowed under the regulation • If the extension is granted, inventory results from departments would be due to EH&S by March 7, 2008 • Until WU is granted an extension from DHS, the internal deadline for all departments to send completed screen inventories to EH&S shall be January 4, 2008 • If an extension is received, an announcement will be sent all departments letting them know the new reporting deadline is March 7, 2008

5. What we need from you and your department(s) • Visit EH&S website: • http://ehs.wustl.edu/cfatsrule.htm • Lab, clinic, shop, art and facilities managers (anyone who has chemicals) • Compare their current chemical inventory to the list of 325 chemicals of interest (“Appendix A” list) • If you have any of the 325 chemicals, complete the Chemical Inventory Tool • (coming to the web page on December 5, 2007) • Business Managers or persons designated by Dean, Director or Department Head • Confirm all inventories have been reviewed and that Chemical Inventory Tool information is submitted by January 4, 2008

6. Information Collected by the Chemical Inventory Tool • Chemical names • Concentrations • Quantities • Locations (Campus, building and room #). • Responsible person for the chemicals or chemical storage area • Contact information

7. Potential Non-Compliance Consequences • DHS has identified that potential fines for violating the Chemical Facility Anti-Terrorism Standard could result in civil penalties up to $25,000 per day and shutting down facilities • DHS has trained third party inspectors and inspections are already underway

8. Where do you go for more information? • http://ehs.wustl.edu/cfatsrule.htm • Linda Vishino, EH&S Environmental Compliance Officer • vishinol@wustl.edu • 935-7864 • Fax 935-5564

9. QUESTIONS?