Date: Tue, 20 Nov 2007 14:55:42 -0800
Reply-To: Debbie Decker <dmdecker**At_Symbol_Here**UCDAVIS.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Debbie Decker <dmdecker**At_Symbol_Here**UCDAVIS.EDU>
Subject: FW: DHS Final Appendix A List of Chemicals of Interest Published
-- Top Screen due Jan 19, 2008
Comments: To: UCIH Program Management Group
Another perspective.


Debbie (who is busily composing her "please give us an extension!"
letter as we speak)



From: Jim Connolly [mailto:Jim_Connolly**At_Symbol_Here**] 
Sent: Tuesday, November 20, 2007 2:41 PM
To: dmdecker**At_Symbol_Here**
Subject: DHS Final Appendix A List of Chemicals of Interest Published --
Top Screen due Jan 19, 2008


Department of Homeland Security
Chemical Facility Anti-Terrorism Program
Final List of Chemicals of Interest Published in Federal Register 

Top Screen filings due January 19, 2008 


The final list of Chemicals of Interest

(COI), Appendix A to the Department of Homeland Security's Chemical
Facility Anti-Terrorism Standard (6 CFR 27.00) was published in the
Federal Register on Tuesday, November 20, 2007.  This means that
facilities that possess greater than Screening Threshold Quantities
(STQ) of COI must file Top Screen with the Department of Homeland
Security by January 19, 2008. 


The pre-publication version of this regulation has been available on the
DHS website since November 2. The content has not changed. 


Some key issues and questions have been resolved by DHS with the release
of Appendix A including: 

Screening Threshold Quantities (STQ) -- STQs have increased for many
compounds since the draft was published. 

Categories of Chemicals of Interest -- The categories of each Chemical
of Interest (the reason why the Dept of Homeland Security is concerned
about the chemical) are included in the final list and in some cases
there are different STQs for different categories. 

Mixtures -- The issue of mixtures has been resolved by the final list.
The list contains maximum concentration percentages, "commercial grade"
designation or a placarded amount. Many are set at a minimum
concentration of 1.00% so MSDS sheets for commercial products will need
to be checked. 

Any amount -- The designation of "any amount" has been replaced by
actual amounts ranging from "Cumulative amount of 100 grams," up to
"20,000 pounds" and even 60,000 pounds for propane. 

Propane -- The STQ for propane is 60,000 pounds (not counting propane in
containers of 10,000 pounds or less) where it had been 7,500 pounds on
the originally proposed list. 

No longer on the list -- Carbon monoxide, acetone and urea, which were
on the originally proposed Appendix A, are no longer listed. 

If you have specific questions about the regulation and the final
Appendix A
please contact me. 

Jim Connolly 
EORM, Inc. 
400 West Cummings Park, Suite 5850 
Woburn, MA 01801 

Phone: (781) 756-3820 (direct)
Fax:     (781) 729-4648


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