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Chemical Security Assessment Tool
Frequently Asked Questions

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Additional Resources
654Where can I get additional information about the regulations?
1262How do I offer a product or the services of my company to DHS?
1271Is there a set format or checklist for audits the companies can use? How often would the companies be checked for compliance?
1390I have searched the FAQs but still need additional assistance. Where can I get additional assistance?
1487Where can I locate a copy of the downloadable PDF file with Top-Screen questions?

Appendix A
1158What changes have been made in the Final Appendix A?
1159Why were changes made to Appendix A?
1160Why were security issues listed in the Final Appendix A?
1161What are the categories for the security issues?
1162Why does the Release category have three subcategories?
1163Why does the Theft and Diversion category have three subcategories?
1164Why were the listed chemicals chosen to be placed on the Appendix A list?
1165Will DHS change or update the Chemicals of Interest list?
1189Are mixtures going to be included in CFATS?
1211How is the STQ for Schedule 1 Chemicals calculated?
1269Please explain how to report individual chemicals as neat chemicals or as part of a mixture.
1280Is Appendix A offered in any other format? I would like to see Appendix A by CAS #.
1291How do I determine whether or not I need to complete a Top-Screen for my aluminum powder?
1367What particle size needs to be considered when looking at aluminum shavings?

Area of Highest Quantity
415Is there an example available of how to assemble information for reporting Area of Highest Quantity?
425How do I enter the total amount of an explosive chemical within the Area of Highest Quantity?
1534What is the Area of Highest Quantity (AHQ)?
1535If the Total On-site Quantity and the Area of Highest Quantity are the same, do I enter the same number for the Distance of Concern?

CFATS Regulation
41What is conflict pre-emption?
42Is DHS seeking to pre-empt State chemical security regulations with the new Federal regulations?
43What is Inherently Safer Technology (IST)?
54What role did private industry play in developing this rule?
55Will there be fees involved for the chemical companies?
56Who will be doing the security screens and reviewing the security site plans?
57Is the background check process consistent with TWIC? If not, why? Why did we choose this process?
203Why is DHS only interested in suppliers to these critical infrastructure sectors?
616What types of facilities are covered under this regulation?
636How did DHS develop its chemicals of interest list?
641When does a facility need to submit a CSAT Top Screen?
648How will DHS communicate with facilities?
653What will DHS do with the information it obtains?
657Will people who have "free" or "public" e-mail accounts be granted access to CSAT?
1157Where can I find information regarding the Finalized Appendix A?
1169What is the definition of a chemical of interest?
1170What is the definition of a security issue?
1174What is the definition of a "technically qualified individual"?
1179We are already regulated by other federal entities. Shouldn't our current chemical regulations exempt us from CFATS?
1180What if people are not aware of this new regulation?
1181How do facilities know they must comply with CFATS?
1192My facility does not presently have a COI listed on the Finalized Appendix A, but may have a COI in the future. How should this be handled?
1193How does a college define itself if there are multiple buildings but only a select few have COIs that fall under the regulation?
1194Are there any special accommodates extended to colleges and universities for completing Top Screen?
1198How did DHS determine COI as listed on the Release Toxics and Release Flammables list?
1232What is the primary difference between the way EPA's regulatory basis and that of DHS regarding release chemicals?
1238How do I comply with the CFATS regulation if my facility does not have Internet access?
1253How do I request a DHS speaker to come to my facility?
1275Does a facility have to resubmit a TS after a sale or transfer of ownership?
1368Are background checks required for fire department personnel (firefighters and fire protection engineers)? If so, would the background check used for initial employment be acceptable?
1377Doesn't §27.320(b) conflict with the ex parte prohibition in §27.320(a)?
1378What "other persons" could file a Notice of Application for Review per §27.310(b)? It seems that only the particular chemical facility would be interested in this.
1379What is the meaning of the verb "toll" in the second sentence of §27.120(c)?
1380How do I request an extension of the Top-Screen filing deadline?
1536What does "risk-based" mean?
1537Why is DHS using risk-based performance standards?
1542What is "CSAT"?
1543How will a facility know whether it is required to complete a CSAT Top Screen?
1546Does a facility have to go through the CSAT process if it has already implemented security measures?
1552Are chemicals in transit regulated under the Chemical Facility Anti-Terrorism Standards (CFATS)?
1553Does DHS have the authority to enforce the use of Inherently Safer Technology (IST) at a facility?
1555I'm not sure how this whole CSAT thing works. Can you explain it in a few sentences?
1578What is the definition of a "technically qualified individual" under CFATS?
1579How does a college define itself if it has multiple buildings but only a select few have COI's that fall under the regulation?

Capacity Utilization
181What is refinery capacity?
451Relating to Mission Critical Chemicals, what is the Capacity Utilization Rate?
452Relating to Mission Critical Chemicals, what is the Survey of Plant Capacity Utilization?
1261How do I figure out the Capacity Utilization Rate? The same equi,emt produces multiple listed chemicals.

Chemical Storage
430What is a bulk transportation container?
431What is a bulk storage container?
1166What is the definition of "vessel" as it relates to the CFAT rule?
1173What is the definition of a transporation container as it related to CFATS?
1176What is the definition of packaging as related the CFATS?
1197What containment units are included in calculating for release COIs?
1209Are transportation containers that are detatched from the motive power considered in calculating the STQ?
1256How do we register mixtures and/or blends?

Chemical-terrorism Vulnerability Information (CVI)
52How will DHS protect the data it collects?
304How do I move past the CVI Authorizing Statements?
321Where can I locate a copy of the CVI manual?
515Can you tell me where I can find additional information on CVI data?
516Where can I take CVI training?
755Will I receive notification that I have completed the CVI training?
1115I have completed the CVI Training and would like to know how long it will take to get my certificate.
1144Is it possible for co-located facilities of a new company that is a spin-off of two existing corporations to share their Top Screen, SVA, and SSP with their parent companies?
1547Is the fact that a facility is a covered facility under 6 CFR part 27 considered CVI?
1548Is the preliminary tier determination of a covered facility by DHS considered CVI?
1549May a covered facility disclose its preliminary tier level to another entity or individual (e.g. a trade association or another facility)?
1550Does DHS need to be notified when a CVI Authorized User at a covered facility shares CVI (e.g., its preliminary tier determination) with another CVI Authorized User, who has a "need to know", within the private sector?
1551Can individuals who are not US Citizens be CVI Authorized Users?

EPA
1339What is the definition of Minimum Concentration?
1340What is the definition of an Article?

Economically Critical
208How do I find out what the facility domestic market share is?
343Where can I find guidance for economically-critical chemical production questions?
455Relating to Mission Critical Chemicals, how do I determine the estimated replacement cost?
456If my facility qualifies as producing an economically critical chemical, what information will I need to complete in this portion of the Top Screen?
471Would you explain which chemicals are included as Production of Economically Critical Chemicals?

Emergency Production and Replacement Cost
215Where do I get information on the replacement cost of units at my facility?
453Relating to Mission Critical Chemicals, what is the National Emergency Production Rate?
454Relating to Mission Critical Chemicals, what is the Total Annual Production, and how do I enter it?

Explosive Chemicals
341Where can I find guidance for questions about chemical manufacturing, use, storage, or distribution?
422What is an Explosive Chemical?
1206How does a facility count the amount of a release-explosive chemical?
1217What is the STQ for COIs under the security issue of Theft/Diversion-EXP/IEDP?
1218How is the STQ for theft/diversion-EXP/IEDP chemicals calculated in a mixture?
1227Why are there two entries for Ammonium Nitrate listed on Appendix A?
1228How is the STQ calculated for Ammonium nitrate as an explosive?
1229How is the STQ calculated for Ammonium nitrate as a solid with a nitrogen concentration of 23% or greater?
1230How is the STQ calculated for Ammonium nitrate as a solid with a nitrogen concentration of 23% or greater if it is in a mixture?
1383Is Ammonium Nitrate Fuel Oil, also known as ANFO, included on Appendix A?

Facility Information
168How do I proceed if I am a state, municipality or other government entity?
1143My company is a spin-off of two separate corporations. As a result several of the new company's facilities are co-located. That is, the facilities either share a fenceline or are completely imbedded within a common facility. What will be required of us in regards to CFATS? Do both companies need to develop a Top Screen, SVA, and Site Security Plan? Is it possible for our imbedded plants to share the Top Screen, SVA, and Site Security Plan with the host company? If this is possible, what would be required by both companies to accomplish this and be compliant under 6 CFR Part 27?
1295What is the Facility Name?
1296What is an Alternate Facility Name?
1297How do I report the NAICS Code for the Facility?
1298How do I enter the facility Data Universal Numbering System (DUNS)?
1299How do I choose the facility type that best describes the facility?
1300How do I enter the Facility Location Address?
1301How do I enter the facility latitude and longitude?
1302How to I enter the Facility County(ies) information?
1303What is the difference between a facility owner and a facility operator?
1314Does the facility operate any U.S. Environmental Protection Agency Risk Management Plan (EPA RMP)-covered process(es) — Program 1, 2, or 3?
1318How do I enter the number of full-time employees and contractors?
1319How do I enter the Parent Company Name and Data Universal Numbering System (DUNS)?
1376Client has questions about 1.2-78 in Top Screen. He wants clarification of the owner/operator ramifications. Client is a 3rd party logistics company who runs a company for a 2nd party client that leases the building from an owner. What if client cannot obtain owner information for facility? Who do they list in this question block?
1394How does the Statutory Exemption Section apply?
1559How do I enter the facility Data Universal Numbering System (DUNS) identification code in the Top-Screen?
1560How do I determine and enter the facility latitude and longitude in the Top-Screen<
1561How does the Statutory Exemption Setion of the Top-Screen work?
1562How do I know if my facility is a Public Water System as defined by Section 1401 of the Safe Drinking Act?
1563How do I know if my facility is a Treatment Works as defined in Section 212 of the Federal Water Pollution Control Act?

Flammable Chemicals
418What is a flammable chemical?
1202How is the COI counted for fuels that are stored in aboveground tank farms (including farms that are part of pipeline systems)?
1224How do you calculate the STQ for Propane in a mixture?
1237In footnote 33 of the Appendix A Final Rule, why does DHS refer to ethylene oxide as a “release-toxic?”
1247How do I report flammable chemicals?
1288How does a facility count the amount of release-flammable mixture with an NFPA rating of 4 if it is stored in either below or above ground tank(s)?
1289For the purposes of CSAT, what is the definition of "tank farm"?
1359Do I have to answer the fuel questions in the release-flammable COI list of the Top Screen if I do not have a release flammable COI at or above the STQ?
1370A facility possesses 100,000 pounds of a release-flammable mixture with a National Fire Protection Association (NFPA) hazard flammability rating of 4. This mixture contains several Appendix A release-flammable COI at or above 1% of the mixture. The mixture is not a fuel. How do I report this release-flammable mixture in the release-flammable section of the Top-Screen?
1371Do I need to complete a Top-Screen if I only possess fuels like diesel, jet fuel and kerosene that do not contain any Appendix A release-flammable chemicals of interest?
1372Do I have to answer the fuel questions in the release-flammable COI list of the Top Screen if I do not have a release flammable COI at or above the STQ?
1373If a mixture has multiple COIs as flammable release, does the facility need to list the entire weight of the mixture for each COI or does it only need to be listed once. Listing it multiple times would give the appearance that the facility has a lot more COIs than they actually do have.
1389Is there a specialized approach to Propane?
1540How does a facility count the amount of release flammable COI within a mixture that is not a fuel with an NFPA rating of 1, 2, or 3?
1566How does a facility calculate the Screening Threshold Quantity for propane in a mixture?
1567How does a facility count the amount of release flammable COI in a mixture that is not a fuel with an NFPA rating of 1, 2, or 3?
1568How does a facility count the amount of release-flammable mixture with an NFPA rating of 4 if it is stored in either below or above ground tank(s)?
1570Do I need to complete a Top-Screen if I only possess fuels like diesel, jet fuel and kerosene that do not contain any Appendix A release-flammable chemicals of interest?

Geocoding
167What is the reference point of the latitude and longitude of the facility?
775Where can I find my facility's latitude and longitude in decimals?
1035What if TerraServer is unable to locate my facility based on the address I provided?
1095I am unable to locate a street number for a facility. Can I register the facility with simply a street name.

LNG Storage Facilities
184What is a thermal radiation zone?
340Where can I find guidance for LNG storage facility questions?
1175What is meant by "peak shaving" facility? What is DHS's definition of "peak shaving facility?
1184When calculating the amount of a chemical of interest, do I include those stored in "peak shaving" facilities?
1331How do I enter the LNG Storage Capacity?
1332How do I enter the Regasification Rate?
1335What is an Exclusion Zone?
1337How do I enter the LNG Exclusion Details?
1571What is an Exclusion Zone?

Mission Critical
342Where can I find guidance for mission-critical chemical production questions?
444Relating to Mission Critical Chemicals, what is Mission Critical Production?
445What is considered the "Defense Industrial Base"?
446What is the "Public Health" or "Healthcare" sector?
447What is considered part of the "Energy" sector?
448What is the "Public Drinking Water" sector?
449If my facility qualifies as producing a mission critical chemical, what information will I need to complete this portion of the Top Screen?
450Relating to Mission Critical Chemicals, what is a Functional Substitute?
1572Where can I find guidance for Mission Critical chemical production questions?
1573What is the "Defense Industrial Base" for the purposes of mission critical production questions in the Top-Screen?
1574What is considered part of the "Energy" sector for the purposes of mission critical production questions in the Top-Screen?

Penalties and Fines
49Does this new authority allow DHS to impose fines on non-compliant companies?
50Does this new authority allow DHS to order a facility to halt its operations if it is not complying with Federal regulation?
1554Does DHS have the authority to shut down a facility?

RMP*Comp and Distance of Concern
308I am receiving a validation error requesting additional information. How to I add additional information?
324What information is provided by the Environmental Protection Agency (EPA) Risk Management Plan (RMP) submittal?
325Why do I need a copy of RMP*Comp?
329What is RMP*Comp?
405How does RMP*Comp handle toxic liquids?
409Do I include mitigation measures when calculating Distance of Concern using the RMP*Comp Tool?
410What output is produced by the RMP*Comp Tool?
1260Can another program other than rmp be used?
1267What temperature do I need to use on the RMP*Comp tool? The highest amount or the average? What time frame does the user need to consider?
1397A facility has 2 RMP ID numbers, which one would they use?
1575Can a program other than RMP*Comp be used to calculate Distance of Concern?

Refinery Capacity
339Where can I find guidance for refinery questions?
1323How do I enter the Typical Operating Capacity of my refinery?
1324How do I enter the Maximum Design Capacity of my refinery?
1325How do I enter the potential refinery crude sources (e.g., ship, pipeline, strategic petroleum reserve (SPR), rail, and truck) as a percentage of the total barrels per day?
1326How do I enter information regarding the Regional Market Share of my refinery?
1327How do I complete information pertaining to Airport Fuel Supplies?
1329What is a Major Metropolitan Airport?
1330How do I enter the information pertaining to Military Installation Fuel Supplies?
1576Where can I find guidance for refinery questions?
1577How do I enter the Maximum Design Capacity of my refinery?
1581How do I enter the potential refinery crude sources requested in the Top-Screen?
1582What is a thermal radiation zone?

Registration Exemptions and Inclusions
170What is a Public Water System?
1178Are truck terminals and railroad facilities subject to the CFATS regulation?
1195Do colleges or universities have to register if the Chemical of Interest has a release security issue and the COI is stored in a laboratory?
1268Am I exempt from registering since I fall under FAQ 51 relating Part 105 of the Maritime Transportation Security Act?
1393Are there any facilities statutorily exempt from CFATS?
1580Do colleges or universities have to register if the COI has a release security issue and the COI is stored in a laboratory?

SVA
365What is a Security Vulnerabililty Assessment (SVA)?
1196How will DHS address the SSP and SVA requirements if a college or university is deemed regulated under CSAT?
1265Is it possible to review a copy of the SVA or SSP template prior to CSAT registration?
1401When will facilities be notified about completing the SVA?
1402When reporting a COI in the SVA, does the facility calculate the quantity of the COI in pounds?
1424My facility completed a Buffer Zone Protection Plan (BZPP) in conjunction with DHS. Does my facility get credit for the security measures I implemented as a result of that BZPP?
1432What facilities will have to complete the SVA?
1433When will I be notified if I have to complete a SVA?
1489Can a covered facility have contractors or lawyers fill out their SVA?
1490Do all of the employees involved in filling out the SVA at my facility have to be CVI trained?
1491What are "cyber control" and "monitoring systems"?
1493How much is a facility required to know about its customers’ business transactions to complete an SVA?
1495My facility uses a contracting company for some of its services. Is my facility responsible for ensuring that they conduct Background Investigations (BIs) and for following my company’s personnel surety plan? What about their shipping procedures?
1497Are we to pick only the most single probable attack mode for a COI, or are we to include all potential attack modes?
1498The SVA mentions a "point of attack" with corresponding radii. What defines the point of attack? Is it the COI vessel itself, or some other location on a site?
1499I have multiple assets on site with COI. I understand that I have to identify the asset that has the largest inventory of the COI. Do I have to identify other assets based on a greater vulnerability to attack or where the consequence of an attack is expected to be different?
1500I need help determining the number of assets I have. I have rail cars, tonnage, and cylinders. I need to know if this would be one asset or three assets.
1501I need clarification on section A12 of the SVA. I want to know if this question is asking about facility or just COI.
1503Do attack modes aircraft, VBIED, maritime, assault and standoff apply only to release COI's? Which attack modes only apply to theft/diversion COI's
1505What does a requirement to complete an SVA mean for my facility?
1506How will DHS evaluate SVAs from so many different types of facilities?
1507Can an experienced plant manager be considered a countermeasure?
1508Where can I find more thorough descriptions of the attack scenarios?
1509I have release COIs, but I don't have storage tanks. Do I still have to conduct an aircraft crash attack scenarios?
1510What about shipments being received and stolen internally as a result of an order that is unaccounted for?
1511What does DHS mean by "no credit for any facility or asset security measures" in question D.11?
1512Not many facilities have security response forces-how will they answer D.7? why can't they skip that question?
1513Regarding the outer damage radius (G.5), are you asking that my facility include only its employee population, and not account for anyone in outlying areas or collocated/neighboring facilities?
1514Which attack scenarios are applicable to my facility?
1531My circumstances have changed from my original Top-Screen submission. What do I base my SVA on - my original submission or the material modifications I have made?
1532How may I request an extension of my facility's SVA deadline?

Sabotage Contamination
1221Is there a specialized approach in determining whether a facility meets the STQ for Sabotage/contamination chemicals of interest?
1243How do I report Sabotage/Contamination Chemicals?
1434What is a sabotage/contamination chemical of interest (COI) for purposes of CFATS?
1435What is the definition of A Commercial Grade (ACG) for the purposes of CFATS?
1436What is the FR for Sabotage/contamination COIs?
1437How is the STQ for Sabotage/Contamination chemicals of interest calculated in a mixture?

Thresholds
1207Are there any exclusions when calculating whether a facility possesses a chemical of interest that meets the STQ for any security issue?
1374Does Phosphorus, which is part of a polymer, need to be counted toward the STQ? They are buying the polymer which contains the polymer.
1375I need clarification regarding ACG in relation to Sodium Nitrate.
1439Do I count chemicals I have stored in transportation containers toward the STQ amount?
1440I have a chemcial of interest (COI) that appears in more than one category on the Appendix A. How should it be counted?
1441I do not have any chemicals of interest (COI) in an amount at or above the applicable Screening Threshold Quantities. However, I received an email from DHS requesting that I complete a Top-Screen. Do I need to complete a Top-Screen?

Tiering
60Why are we tiering facilities in the national chemical sector?
301What is the process of facility regulation?
302What is the purpose of completing Top Screen?
303How will I know if I am regulated?
649How will DHS know that it is addressing the highest risk facilities first?
802Will my facility be subject to an on-site inspection?
1177When will DHS determine tier levels?
1557What should I do if I think my facility was incorrectly determined to be high-risk or received an incorrect preliminary risk-based tier determination?

Top Screen Resources
327Why do I need financial, sales and marketing information?
328Are there individuals who may be able to provide me with information and assistance in the preparation and submittal of Top-Screen?
1452What chemical inventory information do I need?
1453Why do I need the records used to prepare the annual Tier 2 report under the Emergency Planning and Community Right-to-Know Act (EPCRA)?
1485What do I need to have available in order to complete Top Screen?
1488Is there a list explaining the acronyms used in the Top Screen Questionaire?

Top-Screen Navigation and Troubleshooting
123What web browsers are supported by the CSAT applications?
307How do I go back to a previous screen?
310What is the role of the preparer?
316How do I know if I missed required information?
355I have a screen that says, "Survey Completion. You are not regulated." What do I do now?
458What missing information does the validation report NOT find?
459How can I print the completed survey?
460How does the preparer validate the information entered in the Top Screen survey?
462Do I need to keep a record before transmitting to DHS?
483I am using Windows 2000. When I log into the Top Screen, I receive a message stating "Cyrillic language download is required." After canceling the installation, I now see nothing but a blank screen.
596When will user names and passwords be distributed or how will I receive my user name and password?
1116Why am I getting a message that says "Read Only Access?"
1272Our company supplies propane to tanks that are customer-owned on customer property and company-owned on customer property. Who should register these tanks?
1363I have completed the Top-Screen and submitted it to DHS, but I discovered that I need to make some changes to the information I submitted. How can I do this?
1406If have already submitted a Top Screen and later determine that I need to re-submit, what do I do?
1407I recently received an e-mail from DHS informing me that my Top-Screen appears to be inactive because it was begun over 60 days ago and has still not been submitted. What should I do?
1442Do I have a certain amount of time to be in Top Screen before it logs me out?
1443How do I save the information I have entered?
1444What information do I have to fill out?
1445What are the final steps to complete Top Screen?
1447I am not able to access the Top Screen Application with my current password. What do I do?
1448How do I submit the finalized Top Screen questionnaire to DHS?