SCS Engineers Regulatory Alert: DHS Appendix A: Chemicals of Interest List

September 21, 2016

Any facility that manufactures, uses, stores, or distributes certain chemicals above a specified quantity listed on Appendix A must complete and submit a Chemical Security Assessment Tool (CSAT) Top-Screen within 60 days of coming into possession
of the Chemicals of Interest (COI) .

In developing the list, the Department looked to existing expert sources of information including other federal regulations related to chemicals. With the publication of a final Appendix A, all provisions of 6 CFR Part 27, including § 27.210(a)(1)(i), are operative and in effect. The other sources that the Department referenced in part are:

• Chemicals covered under the Environmental Protection Agency’s Risk Management Program;
• Chemicals included in the Chemical Weapons Convention;
• Hazardous materials, such as gases that are poisonous by inhalation; and
• Explosives regulated by the Department of Transportation.

Many manufacturers, food storage facilties, cold storage facilities, and industries have chemicals that fall into one or more of the listed categories. Please contact our professional staff to find out if your business is at risk of non-compliance of CFR Part 27.

What to do?  Who to contact? Jake Tilley or Lee Pyle of SCS Engineers.