Date: Fri, 13 Apr 2007 15:00:19 -0400
Reply-To: "Wawzyniecki Jr, Stefan" <stefan.w**At_Symbol_Here**UCONN.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Wawzyniecki Jr, Stefan" <stefan.w**At_Symbol_Here**UCONN.EDU>
Subject: 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. 





Stefan Wawzyniecki, CIH, CHMM      NRCC-CHO      University of
Connecticut  Chemical Health & Safety



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