Date: Thu, 19 Apr 2007 23:35:13 -0400
Reply-To: "Erik A. Talley" <erikt**At_Symbol_Here**ETALLEY.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Erik A. Talley" <erikt**At_Symbol_Here**ETALLEY.COM>
Subject: Chemical Facility Anti-Terrorism Standards
Comments: cc: Al Hazari , Robert Rich ,
Dear CHAS Members,

As many of you are aware, the Department of Homeland Security (DHS)
published a Chemical Facility Anti-Terrorism Interim Final Rule on April 9th
that will very likely affect your workplace. The rule is available online

Appendix A contains a list of chemicals that trigger the rule. DHS is
accepting comments on Appendix A until May 9th. You will notice many
chemicals have a threshold of "any amount." If you meet the threshold
requirement, you must send a report to DHS within 60 days of the effective
date so they can determine if your facility is high risk. High risk
facilities must comply with the security requirements. In reviewing the
list, you will see most of us easily meet the minimum thresholds.

There are both technical and administrative issues with Appendix A. For
example, thionyl chloride is listed twice on the list; once with a threshold
of "Any Amount" and just below it with a threshold of "2000 lbs." Is the
"Any Amount" threshold appropriate for the level of security risk? Even the
chemicals with STQ amounts are low. How difficult is it to have 2,000 lbs of
acetone at an institution?

With the Division of Chemical Health & Safety and the Committee on Chemical
Safety, the ACS Laboratory Environment, Health & Safety Task Force plans to
prepare comments on Appendix A. However, we need your help to identify
comments. Please email comments to me directly at ert2002**At_Symbol_Here**
Comments need to be received by Monday, April 30th to be included.

I also encourage you to send your own comments on the rule to DHS. Quality
of comments is important, but quantity is also very important.


Erik Talley
Chair, ACS Laboratory Environment, Health & Safety Task Force
Member, ACS Committee on Chemical Safety
Chair-elect, ACS Division of Chemical Health & Safety

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