The COVID-19 Pandemic has changed the future of the United States supply chain and how companies who have been utilizing just-in-time inventory recognize the vulnerabilities that business approach exposes. The need for warehouse space has increased, which could mean more chemical storage of industrial chemicals for various industries. Additional chemical inventory storage means additional environmental, health & safety, and security regulations. Chemical security covered by the Department of Homeland Security Chemical Facility Anti-Terrorism Standards (CFATS). Here is how additional warehousing increases the need for chemical security.
First, we saw the shortage in PPE of face masks, ventilators, gowns and hospital beds. Then there were shortages of consumer products like toilet paper, cleaning supplies, and hand sanitizer and E-Commerce skyrocketed as families quarantined and businesses closed. Our traditional supply chain model showed many vulnerabilities and we had to change our focus. The logistics demand from the pandemic changed from short-term (just-in-time) to an increase in maintaining higher stock levels in every region of our country. Enter “reshoring” – essentially the opposite of off-shoring and resulting with the conversion of current U.S. based real estate space (e.g. buildings, enclosed malls/shopping centers, commercial offices, blighted buildings), to warehousing and distribution space.
Regardless of whether shipments are just in-time or temporary storage, warehouses and storage facilities serve a critical role for safe storage, security and distribution of various critical or important chemicals. Although these chemicals have legitimate uses, some of these are compressed gases, toxics, oxidizers, corrosives, water-reactive substances, explosives and flammables – all of which can be used by individuals and/or domestic and international terrorist groups with intent to harm, destroy or kill our citizens.
This is why the U.S. Department of Homeland Security (DHS) developed the Chemical Facility Anti-Terrorism Standards (CFATS) program: to keep dangerous substances out of the hands of terrorists who could use them to unleash death and destruction in an attack.
CFATS regulates the security of any chemicals deemed to be of interest to terrorists. Its program requirements apply to facility owners and operators that possess, consume, sell or create some 300 various chemicals of interest (COI) that could be used in an act of terror. Many of these facilities do not think of themselves as a “chemical facility” per se, but under CFATS many seemingly innocuous facilities are regulated. These facilities include everything from food production and storage plants, swimming pools, golf courses, research labs, universities, office buildings, farmers’ co-ops, paint/coatings manufacturing and even some breweries.
What Chemicals of Interest are frequently found in warehouses?
COI are listed in the CFATS regulation in Appendix A (see below in next section). The Appendix A list includes the listed chemical, screening threshold quantity (STQ), minimum concentration and type of security issue it exhibits from a terrorism perspective. The security issues are Release – toxic, flammable and explosive; Theft (to be weaponized), and Sabotage.
Common COI found in warehouses, storage, and distribution facilities include, but are not limited to:
- Aluminum (powder)
- Ammonia (anhydrous)
- Butane (flammable)
- Chlorine
- Hydrogen Peroxide (conc. of at least 35%)
- Nitric Acid
- Potassium Nitrate
- Propane
- Sodium Nitrate
- Sulfur dioxide (anhydrous)
How Do I Know if I am subject to CFATS at my warehouse?
If you possess a COI at or greater than the screening threshold quantity in Appendix A, you must submit a notification to DHS called Top Screen, within 60 days of coming into possession of the COI. Review the Appendix A COI list at the following link:
How TRC Can Help
If your business handles, stores or intends to store COI on-site, TRC can provide the expert security consulting and engineering guidance you need to comply with the CFATS regulations TRC has expertise across the security spectrum, and our subject matter experts have developed approaches, programs, plans, training and designs that have helped a wide range of facilities across the United States adhere to CFATS guidelines and other security-related regulations.
Our in-depth knowledge of regulatory requirements and industry best practices means that TRC can help you develop individualized compliance strategies to reduce, mitigate or manage risks, whether we lead the development and implementation of these strategies or augment your in-house teams.
Melissa Hart
Melissa Hart has over 30+ years of experience in private industry and consulting. Her environmental experience is focused on air pollution regulatory compliance; EPCRA/SARA compliance (including Tier II inventory, TRI reporting, and auditing); due diligence; air permitting; civil penalty calculations and enforcement negotiation; and Department of Homeland Security Chemical Facility Anti-Terrorism Standards (CFATS). Ms. Hart has worked in multiple industrial sectors, including aircraft and automotive assembly/manufacturing; automotive parts; food and beverage operations; miscellaneous metal fabrication; fertilizer plants; air filter fabrication; and miscellaneous surface coating operations. She holds a BS in Chemical Engineering from University of Missouri – Columbia.