The higher education collaborative
for chemical inventory management
Using the ChemTracker DHS CFATS Screening Tool
Introduction
This document is intended to serve as a guide for responsible parties at ChemTracker Consortium member
institutions using the ChemTracker CFATS Analysis Screening Tool for determining if facilities have Chemicals of
Interest (COI) exceeding Screening Threshold Quantities (STQs). This guide does not cover all aspects of the
CFATS regulations including many exemptions as specified in 6 CFR 27.203(a). Prior to using this tool, the
reader should become familiar with the ChemTracker inventory system and with CFATS regulations. Prior to
applying the screening procedures, review the attached reference guide for determining COI Screening Threshold
Quantity (STQ) and applicable exemptions and notes. Refer to
http://www.dhs.gov/files/programs/gc_1169501486197.shtm for more information.
Note: Stanford University and the ChemTracker Consortium make no warrants, either expressed or implied, that
this screening information is accurate and applicable for all uses. This information is intended to be used as a
guide for research universities and any person or organization choosing to use this information in any way
whatsoever does so entirely at their own risk.
Background
On April 9, 2007, the U.S. Department of Homeland Security (DHS) issued the Chemical Facility Anti-Terrorism
Standards (CFATS) which later became a Federal Regulation under 6 CFR 27. Facilities that are either
contacted by DHS or that possess any of the COI identified in Appendix A in quantities at or above STQs are
required to submit information (i.e., complete a “Top-Screen”) to help DHS determine if they are to be considered
a “high-risk” chemical facility. CFATS requires high-risk chemical facilities to conduct a security vulnerability
assessment (SVA) and then develop and implement a site security plan (SSP).
Summary of Steps to Screen for CFATS Chemicals of Interest
1
Ensure all chemicals have been entered in ChemTracker and SAMONSed (linked to the reference
database). Materials not linked to the reference database will be missed by the report.
2
Run the CFATS Screening Tool for all facilities.* Scan and identify the buildings that have
chemicals close to or over the CFATS thresholds. See Section IV below for detailed instructions.
3
Run the report for the buildings having chemicals close to or over the thresholds; examine the
results to determine if they are over or close to any threshold quantities. Run the report to include
the details in those buildings to find the exact location of the items that contribute to that chemical
threshold. See Section V below for detailed instructions.
4
Adjust your inventory and/or develop your security plan, and/or take appropriate security
measures.
5
As needed, make adjustments to Chemtracker chemical inventory and rerun the report.
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6
Complete DHS CFATS “Top-Screen” for any facility that has COI in excess of STQ.
*If issues are noted with the chemical reference data information provided, please email
chemtracker_support@lists.stanford.edu to request a review and evaluation.
Access and Authority
Access and authority to run the DHS CFATS Analysis Screening Tool is separate from the ability to run regulatory
reports. The Executive Contact at a ChemTracker member institution requests access for a person for this by
sending an email to chemtracker_support@lists.stanford.edu with the person’s ChemTracker User ID, First and
Last Name, email address, and phone number requesting that he or she can access the CFATS Screening Tool.
For more information about who should be allowed access, please see the Chemical-terrorism Vulnerability
Information (CVI) Procedures Manual: http://www.dhs.gov/xlibrary/assets/chemsec_cvi_proceduresmanual.pdf.
Data Sensitivity
Data produced by running these reports is sensitive and should be protected and shredded after use, if printed.
Please keep your computer secure while this data is available onscreen.
See information for DHS/CVI at http://www.dhs.gov/files/programs/gc_1181835547413.shtm.
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Instructions for Running the CFATS Screening Tool
Note: The examples in this document use fictitious data.
1. In ChemTracker version 4, select the Reports link at the top of the page. Only Users with access to run
reports will see this link.
2. Select CFATS from the Report Type pulldown menu. Only Users with CFATS access will be able to see this
selection.
3.
Select either a Building, a Group, or check Include all buildings?
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4. Change the selections to show Details, and/or the Warning Level percentage if you wish.
5.
Press the Generate and
Download button at the bottom of the screen, and then open the Excel file.
You will see that Worksheet 1 and Worksheet 2 contain Chemical-Terrorism Vulnerability Information (CVI).
Worksheet 3 contains the CFAT Inventory Summary and Worksheet 4 contains the CFAT Inventory Details,
depending on which selections you made. The Authorizer at your campus can help you determine what is CVI.
Please see the Chemical-terrorism Vulnerability Information (CVI) Procedures Manual for definitions at
http://www.dhs.gov/xlibrary/assets/chemsec_cvi_proceduresmanual.pdf.
Headings for Worksheet 3: CFAT Inventory Summary
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Headings for Worksheet 4: CFAT Inventory Details
6. Scroll down in the same report which includes total quantity of COI in buildings and identify those buildings
that have COI in excess of STQ. Note the specific material and category for which the STQ is exceeded. COI
in excess of STQ is highlighted in the report and the percentage of STQ present is noted for each COI. If a
specific building is identified that requires further follow up, then run the report for that building.
7.
Reconcile chemicals and
have a security plan at the locations of any COI that are close to or above the STQ to validate chemicals and
quantities. You can see the Room, Department and Owner in the report.
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Appendix A: Determining if COI Exceeds STQ
1. Laboratory Exempt: For COIs exceeding STQ in the “Release-Toxics”, “Release-Flammable”, and
“Release-Explosives” categories, determine if they are used/stored in laboratories as defined in Sec.
27.203(b)(2). If so, subtract those materials from COI total and determine if the facility still exceeds STQ. If
the facility no longer exceeds STQ, then no further evaluation is required for that COI in the Release category.
2. For any COI still exceeding STQ in the "Release-Toxic" category, recalculate using the actual percentage of
COI for each container. If the COI no longer exceeds STQ, then no further evaluation is required for that COI
in the “Release-Toxic” category.
Note the “Release-Toxic” category is the only category using just the COI portion of a mixture for
calculating quantity on hand. For other categories the quantity of the entire mixture is used provided the
percentage of COI is above the minimum concentration specified in Appendix A. Within ChemTracker, the
COI chemicals are classified into a concentration range and the analysis report calculates COI quantity
using the top of each regulatory range (i.e., most conservative estimate). If the material entered is a
mixture that contains a COI, and is linked to a GDN, the amount should already be adjusted to the high
side of the range for that material.
3. For any COI exceeding STQ in the “Sabotage/Contamination” category, determine if the facility ships that
COI. STQ is only exceeded if the facility ships the COI in quantities that require placarding pursuant to the
provisions of subpart F of 49 CFR part 172 (i.e., DOT placarding requirements). If not, then no further
evaluation is required for that COI in the “Sabotage/Contamination” category.
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Appendix B: Quick Reference Guide to Determine Screening Threshold Quantity (STQ)
What counts towards STQ
Release-Toxics
Amount of the chemical of interest in the mixture
toward the STQ. For example, if a facility has 500
pounds of a toxic mixture containing five percent
(5%) acrolein, the facility should count five percent
(5%) of the weight of the mixture, or 25 pounds of
acrolein, toward the STQ of 5,000 pounds.
ReleaseFlammable
Chemicals
If present in a mixture in a concentration equal to or
greater than one percent (1%) by weight of the
mixture, and the mixture has a NFPA flammability
hazard rating of 4, the facility shall count the entire
amount of the mixture toward the STQ.
ReleaseExplosives
The total quantity of all commercial grades of
release-explosives.
Theft/DiversionCW/CWP
Unlike the STQ for Schedule 1 chemicals, these
STQs are not cumulative. For non-Schedule 1
theft/diversion-CW/CWP (Chemical
Weapons/Chemical Weapons Precursor) chemicals
of interest that are present in a mixture at or above
the minimum concentration listed in the column in
Appendix A to part 27 of the CFATS final rule, the
facility should count the entire amount of the mixture
toward the STQ. See Sec. 27.204(b)(1).
Theft/DiversionWME
The facility shall count the entire amount of the
mixture toward the STQ for WME (Weapon of Mass
Effect) unless a specific minimum concentration is
assigned in the Minimum Concentration column of
Appendix A to part 27 of the CFATS final rule, in
which case the facility should count the total
quantity of all commercial grades of the chemicals
at the specified minimum concentration.
Theft/DiversionEXP/IEDP
As provided in Sec. 27.204(b)(3), a facility shall
count toward the STQ the total quantity of all
commercial grades of a theft/diversion-EXP/IEDP
(Explosives/Improvised Explosive Devise Precursor)
chemical at the facility unless a specific minimum
Concentration is assigned in the Minimum
Concentration column of Appendix A to part 27 of
the CFATS final rule, in which case the facility
should count the total quantity of all commercial
grades of the chemicals at or above the specified
minimum concentration.
Sabotage/
Contamination
As provided in Sec. 27.204(c), a facility shall count
toward the STQ the total quantity of all commercial
grades of a sabotage/contamination chemical that it
possesses unless a specific minimum concentration
is assigned in the Minimum Concentration column of
Appendix A to part 27 of the CFATS final rule, in
which case the facility should count the total
quantity of all commercial grades of the chemicals
at the specified minimum concentration.
Exemptions and Notes
Laboratory exemption: the
facility need not include
release- toxic, releaseflammable, or releaseexplosive chemicals of interest
that a facility manufactures,
processes, or uses in a
laboratory at the facility under
the supervision of a technically
qualified individual as defined in
40 CFR 720.3.
In Sec. 27.203(c), DHS
provides that facilities shall only
count theft/diversion chemicals
of interest that are in a
transportation packaging as
defined in 49 CFR 171.8.
Section 27.203(d) provides that
``[a] facility meets the STQ for a
sabotage/contamination
chemical of interest if it ships
the chemical and is required to
placard the shipment of that
chemical pursuant to the
provisions of subpart F of 49
CFR part 172.''
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