December 14, 2007
Dear Valued Customer:
Please forward this letter to the person who is responsible for regulatory affairs or security.
The Department of Homeland Security (DHS) has issued the Chemical Facility Anti-Terrorism Standards (6 CFR Part 27). Since you have anhydrous ammonia or ammonium hydroxide (aqua ammonia) on site, you may have to comply with this regulation. The regulation contains penalties from fines to a cease operations order for non-compliance.
If you have 10,000 pounds or more of anhydrous ammonia or 20,000 pounds or more of ammonium hydroxide (20% or greater concentration, based on contained pounds of ammonia) on site (not just in the storage tank), you must comply with the regulation. There are several steps.
First, each affected site must register online. Second, each site must file a Top-Screen on-line. Third, DHS will tell you if you have to submit a Security Vulnerability Assessment and, following DHS approval, a Site Security Plan that addresses nineteen risk-based performance standards. Finally, DHS will inspect the site and issue its approval.
If you have not registered, you should do so at once. The Top Screen is due within 60 calendar days of the Federal Register publication (due date is January 22, 2008) or within 60 calendar days of coming into possession of any Chemicals of Interest above the threshold quantities.
Here is the DHS website you can access to get further information on the standard, covered facilities, and chemical list.
We hope this letter has made you aware of this important security regulation. You can contact John Post at 215-322-1238, ext 239, if you have any questions.
Tanner Industries, Inc.