ISM e-Digest: Chemicals

The implications of these sweeping regulations are that all covered facilities will have to assess if they exceed the threshold quantity for any Chemical of Interest and collect background information to sufficiently address the Top Screen registration requirements. For many facilities that are typically perceived as low-risk, such as universities, hospitals and distribution facilities, this effort will be labor-intensive and costly. Under the current regulation, facilities not traditionally characterized as "chemical plants" will have to implement a comprehensive site vulnerability assessment taking into account threat scenarios developed by the DHS, and develop a site-specific security plan that includes physical, operational, personnel and IT security controls that may not already exist. Many facilities will need to review their storage requirements and, if possible, implement alternative supplier operations to decrease on-site quantities and avoid classification as a covered facility.

Companies should engage early on this issue to ensure that all relevant management is aware of the implications of these regulations and can make informed decisions about the compliance impacts and strategies for their operations. A strategic plan should be developed that meets the objectives of the regulation in a manner that is balanced with operational, financial and business objectives.

-- Neal Drawas