The Chemical Facility Anti-Terrorism Standards (CFATS) program is a risk-based, regulatory program that sets the standards for security at the Nation’s high-risk chemical facilities. To determine if a chemical facility is high-risk and thereby a covered chemical facility under CFATS, the Department of Homeland Security (DHS) uses a dynamic risk assessment process.
DHS is committed to strengthening the CFATS program and is implementing an enhanced tiering methodology that incorporates the relevant elements of risk, taking into account threat, vulnerability, and consequence in a facility’s high-risk determination.
How DHS Identifies High-Risk Chemical Facilities
The CFATS regulation follows a risk-based approach that allows DHS to focus its resources on high-risk chemical facilities in accordance with their specific level of risk. To identify a facility’s level of risk, DHS uses information submitted by facilities through the Top-Screen, taking into account vulnerability, potential consequences, and threat of a terrorist attack.
After analyzing Top-Screen data from facilities, DHS will determine which facilities are high-risk and subject to further requirements under the regulation and assign those facilities determined to be high-risk to one of four risk-based tiers.
2016 Enhanced Tiering Methodology
Over the last several years, DHS has undertaken a thorough review of the risk-tiering methodology used to identify high-risk chemical facilities subject to CFATS. Based upon extensive analysis and feedback from experts, the CFATS program now has an enhanced risk tiering methodology that more accurately identifies and appropriately tiers high-risk chemical facilities.
The improved methodology still considers a facility’s vulnerability, consequence, and threat factors in its high-risk determination, and now also includes several new components within each of the elements of risk. While much of the risk tiering methodology is sensitive and/or classified, DHS has developed a CFATS Tiering Methodology fact sheet to provide information on some of the factors that are considered within the functions of risk. This information may help facilities better understand the types of items that may impact their high-risk status and, as applicable, assignment of their risk tiers.
Rollout of the Enhanced Tiering Methodology
In 2016, DHS began to roll out an enhanced risk-assessment methodology and the Chemical Security Assessment Tool (CSAT) 2.0 surveys. DHS is notifying chemical facilities of interest about the requirement to resubmit a Top-Screen using CSAT 2.0. The new submission is then analyzed using the enhanced risk-assessment methodology.
Facilities may choose to proactively resubmit a Top-Screen prior to receiving the individual notification from DHS. Chemical facilities that have not previously submitted a Top-Screen, but have come into possession of reportable amounts of COI, must submit the new Top-Screen in CSAT 2.0 within 60 days of possessing the COI.
Update: In April 2017, DHS began issuing tiering determination letters to facilities that were assessed using the enhanced methodology. Letters will continue to be issued as facilities submit Top-Screens to the Department.
Based on the Department’s analysis of a representative sample of tiering results, some facilities will see a change in their tiers. Some facilities that were previously not covered under CFATS will find themselves covered, and some currently-covered facilities may no longer be considered high-risk. Some of these tier changes are a result of changes to the tiering methodology, while others are the result of changes facilities have made to their businesses, such as adding new chemicals, removing chemicals of interest, or modifying storage methods.
To discuss tiering trends and to respond to questions from facilities, DHS is hosting two public webinars. Advanced registration is required.
CSAT 2.0 Demonstration Webinars
DHS has recorded three webinars that walk users through the revised CSAT tools:
- CSAT 2.0 Portal
- CSAT 2.0 Top-Screen
- CSAT 2.0 Security Vulnerability Assessment (SVA)/Site Specific Plan (SSP)
Please email CFATS@hq.dhs.gov with any questions or to request additional information on any of these CSAT 2.0 demonstrations.
Frequently Asked Questions
DHS is committed to sharing information and providing assistance throughout the process and will do our best to ensure facilities have the necessary information for a smooth transition to CSAT 2.0 and the enhanced tiering methodology. A series of frequently asked questions are being published on the CFATS Knowledge Center. If you have additional questions, please call the CFATS Help Desk at 866-323-2957.