 |
Chemical Security
Department of Homeland Security (DHS) Requirements
U.S. Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) are aimed to prevent potential misuse of certain chemicals. The rule’s broad definition of “chemical facility” makes colleges and universities subject to its requirements. The DHS’s list has 325 Chemical of Interest (COIs) and a reporting threshold limit for each. MIT EHS Office has worked hard to narrow this list down to approximately 130 chemicals that might be present in our labs in an effort to make your burden as low as possible. We have developed the following program to satisfy MIT’s DHS reporting requirements:
- Full DHS COI Reporting in February 2010:
- Immediately following the SARA reporting period each lab needs to report on whether or not any of the 130 chemicals is present in the lab, and if so, in what amount/s using the online form provided.
- If your lab maintains its full chemical inventory* using the online ChemTracker inventory tool, indicate this when you submit your report using the online form. (EHS will extract your DHS COIs from there).
- If you have an Excel spreadsheet of your full chemical inventory* and would like to have it uploaded to ChemTracker, please upload it using the online form. EHS staff will then contact you to discuss inventory data requirements: PI, DLC, Room#, Chemical Name, Physical State, # Containers, Amount, and Units – see ChemTracker Inventory Template (Note – providing CAS #s is highly recommended).
- If your lab does not maintain its full chemical inventory* electronically, take a moment to familiarize yourself with the 130 DHS COIs using the DHS Chemical Inventory Worksheet, then survey your lab for these materials, complete the worksheet and upload it via the online form. (Note: you might consider gathering the DHS COI information for your lab at the same time you gather your information for your lab’s annual SARA report (from early December to mid January).
- Ongoing Monitoring of Low Threshold DHS COIs
- 40 chemicals on the DHS COI list have very low reportable threshold amounts. Under the leadership, advice and counsel of the Committee on Toxic Chemicals, the EHS Office determined the best way to assess the presence of these 40 chemicals is to require that lab personnel notify the EHS Coordinator for their department, lab or center any time you purchase or use any of these 40 COIs. In addition, EHS will periodically survey all labs on whether they have purchased or intend to purchase any of these 40 COIs.
- EHS Reps should make lab personnel familiar with this list of 40 COIs with low threshold limits and the requirement to notify your EHS Coordinator.
*Please note also, as specified in the updated Chemical Hygiene Plan template, each laboratory working with chemicals is now required to have an inventory of the chemicals it uses. Although not mandated by the Institute, if you are interested in learning more about MIT’s online chemical inventory application, ChemTracker, please contact the EHS Office (environment@mit.edu or call x2-3477). ChemTracker is provided by the EHS Office at no charge. |
