1. Department of Homeland Security Chemical Facility Anti-Terrorism Standard (CFATS) Impact on Washington University Bruce Backus Environmental Health & Safety November 29, 2007

2. Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standard Purpose is to prevent chemicals that have historically been used for terrorist or mass casualty incidents from falling into the wrong hands First phase – all companies, including colleges and universities, must screen all their chemicals for 325 specific compounds and report to DHS if they exceed certain thresholds Some thresholds are any amount and some are 100 grams cumulative total for the whole institution. Final Rule published on November 20, 2007 6 Code of Federal Regulations (CFR) Part 27

3. Chemical Facility Anti-Terrorism Standard Timeline There is a very short deadline for doing the inventories and submitting required documentation to DHS Facilities have 60 days to complete the initial chemical screening process Due January 18, 2008 The 60 days must include the 40-60 hours needed for Environmental Health and Safety (EH&S) to complete the DHS “Top Screen” paperwork This requires submittal of screening results by departments to EH&S by January 4 th 2008.

4. Chemical Facility Anti-Terrorism Standard Timeline We are requesting a 60 day extension Maximum extension allowed under the regulation If the extension is granted, inventory results from departments would be due to EH&S by March 7, 2008 Until WU is granted an extension from DHS, the internal deadline for all departments to send completed screen inventories to EH&S shall be January 4, 2008 If an extension is received, an announcement will be sent all departments letting them know the new reporting deadline is March 7, 2008

5. What we need from you and your department(s) Visit EH&S website: –http://ehs.wustl.edu/cfatsrule.htmhttp://ehs.wustl.edu/cfatsrule.htm Lab, clinic, shop, art and facilities managers (anyone who has chemicals) –Compare their current chemical inventory to the list of 325 chemicals of interest (“Appendix A” list) If you have any of the 325 chemicals, complete the Chemical Inventory Tool –(coming to the web page on December 5, 2007) Business Managers or persons designated by Dean, Director or Department Head –Confirm all inventories have been reviewed and that Chemical Inventory Tool information is submitted by January 4, 2008

6. Information Collected by the Chemical Inventory Tool  Chemical names  Concentrations  Quantities  Locations (Campus, building and room #).  Responsible person for the chemicals or chemical storage area  Contact information

7.  DHS has identified that potential fines for violating the Chemical Facility Anti-Terrorism Standard could result in civil penalties up to $25,000 per day and shutting down facilities  DHS has trained third party inspectors and inspections are already underway Potential Non-Compliance Consequences

8. Where do you go for more information? http://ehs.wustl.edu/cfatsrule.htm Linda Vishino, EH&S Environmental Compliance Officer vishinol@wustl.edu 935-7864 Fax 935-5564

9. QUESTIONS?