American Coatings Association

DHS Issues Tiering Notification under CSATS 2.0


On April 4, the U.S. Department of Homeland Security (DHS) began issuing facility tiering notifications based on the results of the Chemical Facility Anti-Terrorism Standards (CFATS) enhanced risk-tiering methodology. In September, DHS launched what is known as “CSAT 2.0,” a revised CSAT (Chemical Security Assessment Tool) Top-Screen, along with a revised CSAT Security Vulnerability Assessment (SVA) application, and a revised CSAT Site Security Plan (SSP) application. The agency believes these changes could result in companies spending 90 percent less time using DHS’ Security Vulnerability Assessment (SVA) and 70 percent less time operating the Site Security Plan (SSP) application.

DHS has said that tiering letters are being prioritized based on when DHS received the facility Top-Screen, upcoming compliance inspection schedules, and to take into account workload for submitters that have a high number of covered facilities with changes. DHS will  continue, over the next 18 months, to notify facilities of the requirement to submit new Top-Screens and will issue tiering decisions on these on a rolling basis.

Under the 2006 law establishing the CFATS program, chemical facilities possessing more than a threshold amount of specific explosive, toxic, or other “chemicals of interest” have been required to complete a “top-screen,” notifying DHS that they possess such chemicals on site. Once a facility submits its top-screen, DHS can direct the facility to submit an SVA, and based on that document, then assign the facility to one of four tiers based on the potential security threat on site, an action that triggers a requirement to submit an SSP (or an Alternative Security Plan, or ASP) to DHS for authorization and approval.

ACA’s members own and operate paint, coatings, resin, and chemical manufacturing facilities that are potentially subject to the CFATS provisions, and many ACA members have previously submitted top-screens identifying chemicals of interest and have been assigned preliminary or final tiers by the department. As a result, a number of ACA member companies have become subject to the CFATS Risk-Based Performance Standards.

Approximately 1,800 facilities have already received a notification that they are not covered by CFATS. These facilities reported that they no longer have chemicals of interest that meet DHS’ thresholds; therefore, they received notice that they are untiered.

Per DHS, approximately 9,000 updated Top-Screens have been received from the 27,000 facilities that have reported holdings of chemicals of interest (COI) at the screening threshold quantity.

Based on an analysis of these initial submissions, the agency is estimating:

  • A slight increase to the overall CFATS-covered population, from 2,700 facilities to around 3,900 facilities;
  • 5% of the currently untiered population is expected to become Tier 1-4;
  • 5% of the currently tiered population is expected to become untiered;
  • 51% of the currently tiered population will see a change in tier (within Tiers 1-4); and
  • 39% of facilities will see no change.

DHS will be holding public webinars about tiering trends and plans to answer facility questions as part of that process. DHS is hosting two public webinars to discuss tiering trends and to respond to questions from facilities. Both webinars will cover the same information. Webinar info is as follows:

Advance registration for the webinars is required.

Contact ACA’s Allen Irish for more information.