The link to both the interim final rule and appendix is 


http://www.dhs.gov/xprevprot/laws/gc_1166796969417.shtm



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-----Original Message-----

From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of

Wawzyniecki Jr, Stefan

Sent: Friday, April 13, 2007 3:00 PM

To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU

Subject: [DCHAS-L] FW: Env Alert - Interim Final Rule on Chemical

Facility anti-Terrorism Standards


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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