Earlier this year, the Department of Homeland Security (DHS) temporarily suspended the requirement to submit Chemical Facility Anti-Terrorism Standards Top-Screens and Security Vulnerability Assessments (SVA) in order to allow for a phased rollout of the new Chemical Security Assessment Tool (CSAT) 2.0 surveys and enhanced risk tiering methodology. On October 1, 2016, the requirement to submit Top-Screens was reinstated. Chemical facilities of interest that have not previously submitted a Top-Screen, but which have come into possession of reportable amounts of COI, MUST submit a Top-Screen within 60 days. Additionally,
in the coming months, DHS will be reaching out directly to CFATS chemical facilities that have previously submitted Top-Screens to DHS and require that they submit a new Top-Screen using CSAT 2.0. However, facilities may choose to proactively resubmit a Top-Screen once the new tool is available and prior to receiving the individual notification. CFATS is the first DHS regulatory program focused specifically on security at high-risk chemical facilities. DHS determines a facility’s risk profile by requiring facilities in possession of specific quantities of specific chemicals of interest to complete a risk assessment, known as a Top-Screen.
Facilities determined by DHS to be high-risk must complete and submit a Security Vulnerability Assessment and a Site Security Plan for DHS approval or an Alternative Security Program that includes security measures to meet applicable risk-based performance standards established by DHS.