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Chemical Facility Anti-Terrorism Standard (CFATS)

CFATS Background

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.

Potential Revisions to CFATS

As of October 2009, Congress is working on reauthorization of CFATS with the "Chemical Facility Anti-Terrorism Act of 2009". EHS is tracking progress of this Act. The latest information and links to the resolution can be found in the tracking box below.

CFATS Survey - CLOSED

Because the time frame was so short to comply with this regulation, EHS asked our internal IT staff to design a web-based survey, to determine which, if any, of these materials is on campus. 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.

Below you will find three links. The first, was a link to the web-based tool, but that survey tool is now closed. The second link provided additional guidance about how the process worked. It included a worksheet that you can print and use to prepare for the online survey in advance. Finally, the third link contained just the worksheet of chemical of interest.

FAQs

I don’t have any of these chemicals. Do I need to do anything?
It would be helpful (but not required) if you would send an email to with your Registered User (RU) number and a note stating you have nothing to submit.

I share a space with another Registered User. Should we both report the chemicals in that space?
No. In shared spaces, please coordinate your response so that chemicals are only reported once.

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 will be submitting collected data to DHS, if required, and will be representing MU.

I’m planning a purchase of one of these chemicals. Should I report it now?
No. This survey is intended as a “snapshot” of campus to determine if compliance with the standard is required.

I have hazardous chemicals that are not on the list. Should I report them?
No. This survey is strictly to comply with the chemicals Department of Homeland Security has determined present some risk for terrorism. While DHS may change the list in the future, at this time, we are only concerned with these chemicals.

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. Why aren't you asking about that?
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 are inventorying them through different channels.

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