Date: Mon, 11 Jun 2007 13:59:08 -0400
Reply-To: Peter Reinhardt <peter.reinhardt**At_Symbol_Here**YALE.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Peter Reinhardt <peter.reinhardt**At_Symbol_Here**YALE.EDU>
Subject: DHS Chemical Security rule update
DHS had originally wanted to publish Appendix A today, but have told people
that they will take "another couple of weeks." I think that means this month
or next. Bill Diesslin thinks that means September. Only time will tell.


We will have 60 days to do the Top-Screen after the date of publication.


Today, DHS posted the Top-Screen questions and a manual. See: 


Department may also notify facilities - either directly or through a Federal
Register notice - that they need to complete and submit a CSAT Top-Screen.


Bill Diesslin (Iowa State) has started his registration for the Top-Screen.
He said they asked for institution, location, longitude, latitude and
contact information. Then you fax in a PDF form and they send back a
password to access the rest of the screen. See   


DHS says Appendix A will change, which will provide some relief, but maybe
not much. For example, if acetone has an STQ of 2,000 pounds (originally
proposed) or 4,000 pounds, most of us will still have to do an inventory.
Also, as of last week, DHS told SCOMA that the STQs for the ten Schedule 1
chemicals from the U.S. Chemicals Weapons Convention would remain at "Any
Amount." (The two Schedule 1 chemicals regulated by the CDC have a threshold
of 100 mg per Principal Investigator.)


DHS public statements in the press still indicate that they believe that
some universities will need to do a security program.


The American Council on Education hired Barry Hartman's firm to look into
the question of an exemption for university subject to NRC security orders.
They conclude that "whether this exemption can be construed to apply to the
entire far from clear, and we do not recommend that this
construction be followed absent further research and analysis." Lawyers at
several institutions are doing this further research and analysis.


DHS' Chemical Security Summit is being held today through Wednesday. Some
university folks are attending. We should know considerably more after they
return. (Please report to the list if you go.)


CSHEMA is working for change with many other higher education organizations:
NACUBO, ACE, COGR, NASULGC, AAU, etc. We are discussing ways to communicate
with DHS through high-level university channels and crafting an alternate


I appreciate everyone's help on this,




Peter A. Reinhardt

Director, Office of Environmental Health & Safety

Yale University

135 College St., 1st Floor

New Haven, CT   06510-2411

(203) 737-2123




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