NACD files comments on chemical security rule.June 15, 2007 -
In comments filed on Appendix A of DHS Chemical Facility Anti-Terrorism Standards, NACD requested DHS modify definition of chemical facility to clarify requirements of distributors that do not store chemicals on-site or have chemicals on-site for limited time. NACD recommended that DHS replace "any amount" with specified quantities that experts believe would produce off-site consequence to public. NACD also encouraged DHS to align screening threshold quantities with EPA threshold planning quantities.
NACD Files Comments on Interim Final Rule on Chemical Security |
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The National Association of Chemical Distributors
1555 Wilson Boulevard, Suite 700
Arlington, VA, 22209
USA
Press release date: May 9, 2007
National Association of Chemical Distributors (NACD) filed comments today on Appendix A of the Department of Homeland Security's (DHS) Chemical Facility Anti-Terrorism Standards. Appendix A is the list of chemicals and quantities that trigger being required to fill out a "Top Screen" consequence assessment questionnaire to determine whether a facility will need to complete a Security Vulnerability Assessment and Site Security Plan under the rule.
First, NACD's comments address the definition of chemical facility, the low threshold amount for many chemicals on the list, how blends or mixtures should be handled, regulatory consistency, and format of the Appendix A.
NACD requested that DHS modify the definition of a chemical facility in order to clarify the requirements of distributors that do not store chemicals on-site or have the chemicals on-site for only a limited time period.
NACD also recommended that DHS replace "any amount" with specified quantities that experts believe would be necessary to produce an off-site consequence to the public. For many of the chemicals listed in Appendix A, a facility that possesses "any amount" would be required to complete a Top Screen. NACD also asked DHS how to handle mixtures that contain both Appendix A and non-Appendix A chemicals, such as whether small amounts of Appendix A chemicals in a blends would be considered part of "any amount" that would trigger Top Screen completion.
Finally, NACD encouraged DHS to align screening threshold quantities with Environmental Protection Agency threshold planning quantities and to issue the Appendix A list by the Chemical Abstract Service numerical sequence in addition to the straight alphabetical listing. For a copy of NACD's comments, visit NACD's Web site at www.nacd.com.
NACD was the first chemical trade association to approve new security measures as part of its management program, the Responsible Distribution ProcessSM(RDP), and has developed a security vulnerability assessment that specifically addresses security issues relevant to chemical distribution facilities. NACD members have invested millions of dollars and substantial resources to safeguard their facilities and the transportation of their products.
* * *NACD and its more than 250 members have established themselves as leaders in health, safety, security, and environmental performance through implementation of the Responsible Distribution Process (RDP), established in 1991 as a condition of membership in NACD. Incorporated as a condition of membership in January 1999, NACD members undergo third-party on-site RDPV - RDP Verification. For additional information, visit NACD's Web site - http://www.nacd.com.
Contact: Kathee E. Baker 703/527-6223 kbaker@nacd.com
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