Has anyone read through this, for applicability to universities & research institutions? Final Rule on Chemical Facility anti-Terrorism Standards, which was published April 9, 2007 by Homeland Security. I'd like to point out Appendix A (for which comments will be accepted until May 9, 2007) identifies the "chemicals of interest," along with what is known as the "screening threshold quantity" (STQ). One hundred and five of the chemicals of interest have a STQ of "any amount." It should be emphasized that the STQ is NOT the threshold quantity for establishing whether a given facility is a high-risk facility (and therefore subject to the substantive provisions of the Rule), but only sets a threshold to require that a facility complete and submit a CSAT Top-Screen (within 60 days of the effective date of Appendix A). Only after the DHS gathers additional information through the Top-Screen process will the Department make a determination as to whether a facility presents a high risk and therefore must comply with the regulatory requirements to ensure adequate security. This involves preparing Plans. Our chemistry stock room identified 23 chemicals on the list for which there is no STQ. Comments? ________________________________ Stefan Wawzyniecki, CIH, CHMM NRCC-CHO University of Connecticut Chemical Health & Safety ________________________________
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