Chemical Facility Anti-Terrorism Standard (CFATS)
In late 2006, the Department of Homeland Security (DHS) published a standard that appeared geared toward Chemical Plants to regulate security at these plants, so it was largely ignored by the academic community. The rule made reference to a chemical list, which wasn't included in the draft rule. When DHS finally published their draft list of chemicals (in April 2007), it became clear that Colleges and Universities were now being potentially defined as "Chemical Facilities", due to possession of chemicals on the list above the stated threshold quantities. Environmental Health and Safety (EHS) offices across the country flooded DHS with comments on the proposed final rule, which originally would have required tracking chemicals as common as acetone.
A special working group was set up with EHS colleagues on the east coast to meet and work directly with DHS to address our many concerns. In the end, while DHS responded to many of those concerns, the department ultimately believed colleges and universities presented some risk and could not be exempted from the rule. This final list of chemicals was significantly different than the one in April, delaying Mizzou's ability to begin the process to determine whether the university would have to file a notice with DHS.
Instead of asking about all 325 chemicals, EHS used historical records to determine which materials had ever been recorded at Mizzou. EHS was thus able to narrow the list to 88 chemicals. Detailed information (actual quantity) is only needed on 63 of these chemicals. Due to rules requiring facilities to report aggregate amounts of chemicals within proximity of each other, EHS needs to know the quantity and location of each of these 63 chemicals. We only need to know of the presence of the other 25.
If you did not participate in this process in 2008, you have chemicals on the the CFATS Worksheet and you have not yet reported them to EHS, please complete the worksheet and mail it to firstname.lastname@example.org . (NOTE: the worksheet refers to an online submission system that is no longer available. Just provide the form to EHS via email.)
I only have gram quantities of a chemical. Do I need to report it?
Yes. Please report quantities of 1 gram or 1 milliliter (reported as 0.001 kg or 0.001 L) or more. You do NOT need to report or round up milligram or microliter amounts.
EXCEPTION TO THIS ANSWER: Please report ANY quantity of HN2 (nitrogen mustard-2).
If I have something on this list, will my name or any personal information be reported to Department of Homeland Security?
No. EHS submits collected data to DHS, if required, and represents MU.
I'm planning a purchase of one of these chemicals. Should I report it now?
Yes. Please send an email to email@example.com or call 882-7018 and ask for HazMat.
Is "hydrogen chloride (anhydrous)" the same as hydrochloric acid?
No. "Hydrogen chloride (anhydrous)" is a gas. In fact many of the chemicals on the list of 88 are gases. To assist RUs, the following are generally sold in cylinders as either a compressed or liquefied gas.
- Boron trifluoride or Borane, trifluoro (from 26.87 percent to 100 percent)
- Boron trichloride or Borane, trichloro (from 84.7 percent to 100 percent)
- Carbonyl fluoride (from 12 percent to 100 percent)
- Chlorine (from 9.77 percent to 100 percent)
- Chlorine trifluoride (from 9.97 percent to 100 percent)
- Cyanogen or Ethanedinitrile (from 11.67 percent to 100 percent)
- Cyanogen chloride (from 2.67 percent to 100 percent)
- Fluorine (from 6.17 percent to 100 percent)
- Hexafluoroacetone (from 15.67 percent to 100 percent)
- Hydrogen bromide (anhydrous) (from 95.33 percent to 100 percent)
- Hydrogen chloride (anhydrous) (original container only)
- Hydrogen cyanide or Hydrocyanic acid (from 4.67 percent to 100 percent)
- Hydrogen fluoride (anhydrous) (from 42.53 percent to 100 percent)
- Hydrogen iodide, anhydrous (from 95.33 percent to 100 percent)
- Hydrogen sulfide (from 23.73 percent to 100 percent)
- Methyl mercaptan or Methanethiol (from 45 percent to 100 percent)
- Nitric oxide or Nitrogen oxide (from 3.83 percent to 100 percent)
- Phosgene or Carbonic dichloride or Carbonyldichloride (from 0.17 percent to 100 percent)
- Phosphine (from 0.67 percent to 100 percent)
- Sulfur dioxide (anhydrous) (from 84 percent to 100 percent)
What do you mean by "original container only"?
DHS is concerned with the possible theft of these materials in what they call "transportation packaging." Basically, if it still has the original manufacturer's label on it, and you can carry it out of the room, you should count it. Do not count these materials if they are in beakers, equipment, etc. Nor do you count them if they are in stationary tanks or other immobile containers.
I'm a USDA employee that only works in USDA controlled facilities (as opposed to facilities shared with MU). I've already reported up through USDA. Do I need to report to you too?
No. If, because of a shared appointment with a Federal Agency you've already reported on this rule, you do not need to report to MU again. If you should double-report, it won't make a big difference overall since we're concerned with aggregate amounts, not amounts at individual locations.
I see formaldehyde (or some other chemical) is on the list published by DHS, but you aren't you asking about. Why?
Chemicals listed under the "Release" heading do not apply to laboratories. If MU has large quantities of any of these chemicals in a non-laboratory use, we inventory them through a different channel.