Date: Mon, 7 May 2007 23:48:24 -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: FW: Chemical Facility Anti-Terrorism Standards
Comments: cc: ACSEHSTF**At_Symbol_Here**
Dear CHAS Members,

Thank you for sending comments on the Department of Homeland Security (DHS)
Chemical Facility Anti-Terrorism Standards. We are finalizing ACS comments
that will be submitted on Wednesday. Dr. Robert Rich at ACS has been in
contact with representatives of DHS and has arranged a meeting with them
this Wednesday to discuss the impact of the new standards on laboratories.
DHS has specifically asked for a list of chemicals on Appendix A that would
be commonly found in laboratories. Some of you have already replied with
lists of chemicals in labs. If you know of any Appendix A chemicals in your
labs, please send the following information to me at

Name of Chemical
Approximate Total Quantity in the Lab
Approximate Average Quantity per container
Approximate Aggregate Quantity at the Entire Institution
Typical Laboratory Use of the Chemical

Ideally, all of the above information would be provided. However, feel free
to send me partial information if something is missing. I would need the
information by Tuesday to be available for the DHS meeting on Wednesday.

Best regards,


> ______________________________________________ 
> From: 	Erik A. Talley [mailto:erikt**At_Symbol_Here**] 
> Sent:	Thursday, April 19, 2007 11:35 PM
> To:	'DCHAS-L**At_Symbol_Here**LIST.UVM.EDU'
> Cc:	'Al Hazari'; 'Robert Rich'; 'ACSEHSTF**At_Symbol_Here**LIST.UVM.EDU'
> Subject:	Chemical Facility Anti-Terrorism Standards
> 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 at:
> 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.
> Sincerely,
> 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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