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National Protection and Programs Directorate
Department of Homeland Security
The Office of Infrastructure Protection
Chemical Safety Workshops
October 2015
Overview of the Chemical Facility Anti-Terrorism
Standards (CFATS) Program
UNCLASSIFIED // FOR OFFICIAL USE ONLY
Presenter’s Name June 17, 2003
The Homeland Faces a Persistent and Evolving Threat
Statutory Authority
A successful attack on some
chemical facilities could
potentially cause a significant
number of deaths and injuries.
Certain chemical facilities
possess materials that could be
stolen or diverted and used as or
converted into weapons for use
offsite.
Why Chemical Facility Security?
In 2007, Congress authorized the Department to regulate security at “high-risk” chemical facilities.
The Department developed the Chemical Facility Anti-Terrorism Standards (CFATS), 6 CFR
Part 27, to implement this authority.
In December 2014, Congress passed H.R. 4007: Protecting and Securing Chemical Facilities
from Terrorist Attacks Act of 2014.
The President signed The CFATS Act of 2014 into law on December 18, 2014.
West, Texas in 2013. Image courtesy of the Chemical Safety Board.
Death Toll in West, Texas,
Fertilizer Explosion Rises to 15NPR, April 23, 2013
French Authorities Hold Suspect in
Beheading and Explosion at Chemical Plant
NYTimes, June 26, 2015
China rocked by second deadly
chemical plant blast in two weeksReuters, April 23, 2013
Presenter’s Name June 17, 2003
Tier 1
3%
Hig
he
st
Ris
k
3
The possession of any of 322 chemicals of interest at or above screening threshold quantities triggers the need for reporting to DHS
Covered facilities are placed in 1 of 4 high-risk tiers
More than 50,000 Top-Screens received
More than 3,100 high-risk facilities
18 Risk-Based Performance Standards, including:
RBPS 4 – Deter, Detect, Delay
RBPS 8 – Cyber Security
RBPS 9 – Response
RBPS 12 – Personnel Surety
DHS approves plans, inspects facilities, and provides compliance assistance
Inspectors and facilities located in all 50 states as well as U.S. territories
Essentials of the CFATS ProgramA Non-Prescriptive Regulation
Tier 2
10%
Tier 3
26%
Tier 4
60%
Presenter’s Name June 17, 2003 4
Submit
Top-Screen
Provide aSecurity
Vulnerability Assessment
Complete
Site Security Plan (SSP)
Receive Authorization
and an Authorization
Inspection
Receive Approval of
the SSP
Implement Planned Measures and
Undergo Regular Compliance Inspections
The CFATS ProcessFacility Perspective
For a facility that is deemed high-risk under CFATS, compliance
with the program includes:
More than 3,000 facilities have eliminated, reduced, or modified their
holdings and/or processes and are no longer considered high-risk
Preliminary Tier Final Tier
Presenter’s Name June 17, 2003
At our current pace, DHS will have inspected and
approved security plans for the current population
of facilities in less than one year.
0
200
400
600
800
1000
1200
1400
1600
1800
2000
2200
2400
2600
2800
3000
3200
3400
3,183 Authorizations
2,603 Authorization
Inspections
2,104 Approvals
161 Compliance
Inspections
As of September 4, 2015
Building on Program Progress
77% of approved facilities have at least one planned
measure being implemented in order to meet DHS’s
standards
Presenter’s Name June 17, 2003 6
CFATS Regulated FacilitiesTop 10 NAICS Codes Reported to DHS
Manufacturing
Wholesale Trade
Retail Trade
Transportation and Warehousing
Mining, Quarrying, and Oil and
Gas Extraction
Utilities
Agriculture, Forestry, Fishing and
Hunting
Professional, Scientific, and
Technical Services
Educational Services
Administrative, Support, Waste
Management, and Remediation
Services
Number of Employees1 12,000
274Number of Regulated
Chemicals of Interest
per FacilityAverage: 2
Co-located facilities
Highest number of assets: 48
Lowest number of assets: 0
Average: 2
25 1
48
High Low
Presenter’s Name June 17, 2003 7
Though DHS believes most facilities holding threshold
quantities of CFATS Chemicals of Interest have met the Top-
Screen requirement, there may remain those who:
May not be fully aware of the CFATS requirements
Are willfully ignoring their reporting obligations
Ongoing initiatives to identify these facilities include:
The sharing of information and a cross-walk of lists with EPA,
ATF, and certain state agencies
Enhanced outreach efforts, especially to certain populations
Engaging State and local officials
Potentially Non-Compliant FacilitiesEfforts to identify “outlier” facilities are ongoing
Presenter’s Name June 17, 2003 8
Get to know your local or regional chemical
security inspector, who can help provide
emergency responders and law enforcement
with a greater understanding of the facilities in
their jurisdiction by bringing together the EPA,
CFATS program officials, and OSHA
Engage with your local CFATS facilities.
Risk-Based Performance Standard 9 focuses
on response. Law enforcement and emergency
responders should consider participating in
facility exercises and understand the
implications of a facility’s chemical holdings
Assist with identifying facilities that may be
high-risk --- share the CFATS fact sheet, refer
community organizations interested in learning
more, and connect DHS with local facilities
Spreading the Word about CFATSThe CFATS role of local first responders and law enforcement
Photo courtesy of
Microsoft
Presenter’s Name June 17, 2003
For more information visit:
www.dhs.gov/criticalinfrastructureInfrastructure Security Compliance Division
Carlos Vazquez, Western District Director [email protected]
(202) 302-6353
Michael Martinez, Inspector [email protected]
(202) 617-0980
Thank You for your attendance!!!!!!!!!!!!
For more information visit:
www.dhs.gov/criticalinfrastructure
Infrastructure Security Compliance
Occupational Safety
and Health Administration
www.osha.gov
800-321-OSHA (6742)
Chemical Safety Workshop for Regulated Facilities
Mike Lynham, CSP ARA-FSO
Megan Meagher, ARA-TS
Chris Lorenzo, CIH
JD Danni, Oil and Gas Specialist
John Olaechea, CAS
Todd Zenter, State Plans
October 2015
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• Employee Health and Safety
– Enforcement of Safety and Health Standards
– Resource
• Whistleblower Protections
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OSHA’s Role at Regulated Facilities
• Process Safety Management
– 29 CFR 1910.119
• Corresponds to EPA’s RMP and addresses employee safety and health
• Involves 10,000 lbs of a flammable gas or flammable liquid, or
• A highly hazardous chemical at or above the threshold quantities listed in Appendix A.
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Safety and Health Standards
Process Safety Management Elements
(a) Application
(b) Definitions
(c) Employee Participation
(d) Process Safety Information
(e) Process Hazard Analysis
(f) Operating Procedures
(g) Training
(h) Contractors
(i) Pre-Startup Safety Review
(j) Mechanical Integrity
(k) Hot Work Permits
(l) Management of Change
(m) Incident Investigation
(n) Emergency Planning and Response
(o) Compliance Audits
(p) Trade Secrets
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Process Safety Management Elements
Process Safety Analysis:• A process safety analysis should be done for all materials with a catastrophic potential, even if they are not covered by the Process Safety Standard. • Carefully review chemical hazards and incompatibilities.• Develop standard operating procedures, anticipate and identify the consequences of deviation.
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Chemical and Process Safety
Know the hazards associated with mixing, separating, or storing process materials, including:• Which chemicals are reactive or able to cause a runaway reaction.• Toxic, fire, or explosive hazards associated with your process chemicals.• What to do during an incident or unusual process condition.Be aware of equipment operation and maintenance requirements, including:• Signs of corrosion, leakage, or other signs of equipment problems.• Who to alert when you see a problem.
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Chemical and Process Safety
Know your process:
• Follow operating, safety, and emergency procedures.
• Keep up-to-date with changes to procedures, equipment, and chemicals.
• Provide feedback – report all incidents and near misses.
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Chemical and Process Safety
• Hazard Communication/Global Harmonization System (GHS)
– 29 CFR 1910.1200
• Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers.
• All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.
• The training for employees must also include information on the hazards of the chemicals in their work area and the measures to be used to protect themselves.
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Safety and Health Standards
• Hazardous Waste Operations and Emergency Response
– 29 CFR 1910.120
• Various other standards within 29 CFR 1910 addressing issues such as electrical safety, egress, machine guarding, chemical exposures, lock-out/tag-out, confined space, etc.
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Safety and Health Standards
• 1904.39(a)• Basic requirement. 1904.39(a)(1)• Within eight (8) hours after the death of any employee as a result
of a work-related incident, you must report the fatality to the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor. 1904.39(a)(2)
• Within twenty-four (24) hours after the in-patient hospitalization of one or more employees or an employee's amputation or an employee's loss of an eye, as a result of a work-related incident, you must report the in-patient hospitalization, amputation, or loss of an eye to OSHA. 1904.39(a)(3)
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What are my Reporting Requirements Under OSHA?
• PSM Covered Chemical Facilities NEP– Applicable to all PSM-covered facilities including
petroleum refineries.
– Include Explosive and Pyrotechnic Manufacturing
– Inspection targeting sources will include EPA’s Chemical Accident Prevention Provisions - Program 1, Program 2, and Program 3 RMP operator/employer submittals.
– Ammonia used for refrigeration and Anhydrous Ammonia or Propane used for sale and/or distribution at agricultural wholesale facilities.
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National Emphasis Program (NEP)
• Private-Sector and Federal Employers in Colorado, North Dakota, South Dakota and Montana.
• Within Wyoming and Utah, Private and Public Sectors are covered by State Plan OSHA and Federal Employers are covered by Federal OSHA.
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OSHA Jurisdiction
Visit our new and improved homepage at OSHA.gov
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Free OSHA e-newsletter delivered twice monthly to nearly 72,000 subscribers
Latest news about OSHA initiatives and products to help employers and workers find and prevent workplace hazards
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OSHA QuickTakes
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Recent OSHA Efforts to Improve Protection of Workers from Chemical Hazards
Transitioning to Safer Chemicals: A Toolkit for Employers and Workers
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www.osha.gov/dsg/safer_chemicals
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Contact OSHA
Megan Meagher or Mike Lynham720-264-6559 [email protected] [email protected]
OSHA Region VIII1244 Speer Blvd., Ste. 551Denver, CO 80204
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Questions??
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