Chemical Facility Anti-Terrorism Standards (CFATS)

Compliance with Chemical Facility Anti-Terrorism Standards (CFATS) is now a reality for not only chemical companies, petroleum refineries, and petrochemical and explosives manufacturers, but also high-risk businesses in utilities, agriculture and food, paints and coatings, mining, electronics, pharmaceuticals, academia (university laboratories), aerospace manufacturing (and suppliers), and automotive manufacturing (and suppliers), as well as healthcare providers and hospitals.

The Department of Homeland Security (DHS) issued its first series of final determinations covering the defined Tier 1 and Tier 2 facilities to date. The four tiers will eventually cover more than 7,000 high-risk facilities in the United States that use any of the more than 300 chemicals DHS has identified as a "chemical of interest".

The security planning phase will require the regulated community's most significant CFATS compliance investment to date, both from a personnel resource perspective, as well as on-going capital expenditures. Corporations will face two primary challenges:
  • Management of the near term compliance challenges encountered in addressing CFATS requirements in the coming months
  • Establishment and maintenance of the appropriate facility security programs focused on maximizing efficiencies and leveraging economies of scale throughout the regulatory lifecycle
This process may benefit from coordination from a corporate perspective, ensuring that each regulated facility follows a standard enterprise-wide schedule and method of engagement with the various stakeholders. Uncoordinated and incongruent facility-level activities can transcend localized impacts, resulting in corporate inefficiencies, and potentially significant liabilities.