When you entrust your chemical products to a 3PL, it’s critical that you partner with an experienced provider that is compliant with modern chemical warehouse requirements. Chief among these requirements are the Chemical Facility Anti-Terrorism Standards (CFATS). In this article, we’ll examine CFATS and explain why compliance is essential to chemical warehousing operations.
What is CFATS?
Managed by the U.S. Cybersecurity and Infrastructure Security Agency (CISA), CFATS is the first regulatory program in the U.S. that is focused on the security of chemical facilities. CISA works with such facilities to reduce security risks associated with hazmat products and their potential weaponization by terrorists.
Facilities that store – or plan to store – any of the 300 Chemicals of Interest (COI) identified by CISA must comply with CFATS requirements. This first involves the completion of a ‘Top Screen Questionnaire’ to determine facility risk level.
Based on the following three criteria and other factors, a facility that stores volatile chemicals will be designated as a tier 1, 2, 3, or 4 facility. Tier 1 denotes the highest level of risk.
- Consequence – the consequence of a successful attack on a chemical facility.
- Vulnerability – the odds that an attack on a chemical facility will meet with success.
- Threat – the intent and means of an adversary (terrorist) with respect to attacking a facility.
CFATS chemical warehouse requirements
Once a facility’s tier level has been established, the company has 120 days to submit a Security Vulnerability Assessment as well as a Site Security Plan (SSP) or an Alternative Security Program (ASP) to CISA. The submitted SSP or ASP must conform to the Department of Homeland Security’s 18 Risk-Based Performance Standards (RBPS) which offer security solutions based on varying scenarios in any given facility.
- Security Vulnerability Assessment (SVA): An analysis of the facility’s security and its potential vulnerabilities (including those related to deficiencies in documentation, training or resources).
- Site Security Plan (SSP): Responses to an online questionnaire that covers existing and planned security measures based on facility characteristics and risk level.
- Alternative Security Program (ASP): Instead of completing the online SSP, a facility can create its own document that describes how it addresses each RBPS standard and facility risk factor.
The facility's SVA and SSP due dates run in parallel—both must be submitted within 120 days from the date of written notification from CISA. Tier 4 facilities may elect to submit an ASP in lieu of an SVA. Tier 1-4 facilities may submit an ASP in lieu of an SSP. Failure to meet the prescribed deadlines can result in fines of up to $25,000 daily or, ultimately, a closure of operations.
To aid with compliance, the Department of Homeland Security (DHS) invites all chemical facilities to request a Compliance Assistance Visit (CAV). As each facility has its own unique characteristics, a broad stroke of compliance regulations is not always feasible. During the CAV, compliance standards are tailor made to suit each of the risk factors that exist.
Partnering with a CFATS-compliant 3PL
Compliance with CFATS is an essential requirement for any high-risk chemical warehouse. As such, it should be one of the first things you ask a prospective 3PL about before you entrust your chemical products to its warehouse(s). Non-compliance with CFATS is not only dangerous to your products and the community at large, it is also potentially very expensive to your provider and could result in the facility closing down and leaving your products in limbo.
Weber Logistics operates CFATS-compliant chemical storage facilities within California where we store and distribute a wide range of chemical products, including flammables, corrosives, oxidizers, gases, powder coatings and non-regulated material. To learn more about our chemical logistics capabilities – and our compliance efforts – contact us today.