Chemical Security Requirements
The Department of Homeland Security (DHS) is charged with keeping US citizens safe and secure from chemical terrorism. The Chemical Facility Anti-Terrorism Standards (CFATS) are a comprehensive risk-based security regulation enforced by DHS.
These regulations provide guidance for securing certain Chemicals of Interest (COI) that could be used directly or indirectly for terroristic purposes. DHS requires Colleges and Universities in the possession of COI to:
- Report possessions above regulated threshold amounts
- Implement appropriate security measures
DHS has the authority to inspect facilities for compliance with CFATS, impose civil penalties up to $25,000 per day, and shut down facilities that fail to comply with these regulations.
As a leading research institution, UNC-Chapel Hill conducts research where COI may be regularly used, stored, or even produced.
Chemicals of Interest (COI)
COI are organized by specific security and vulnerability concerns. They are categorized in Appendix A by the following types:
- Theft/Diversion: steal, divert, or otherwise acquired to use as a weapon at another time and place
- Sabotage: sabotage or contaminate to explode or release in transit
- Release: release as an explosive or to form a flammable or toxic cloud
The potential type of security and vulnerability issue at UNC-Chapel Hill would be related to Theft/Diversion. The following chart lists specific Theft/Diversion COI taken from DHS CFATS Appendix A.
Inventory Management of COI
The EHS chemical inventory system is an essential component of compliance with the CFATS regulations. All inventories should be updated with EHS at least annually. Users of COI must check their inventories frequently to ensure no theft or diversion has occurred.
Purchasing of COI
Cooperation by the University community to purchase COI through the University’s purchasing protocol is necessary to maintain compliance. COI can only be purchased through the University’s ePro system. Do not use Procurement Cards (P-Cards).
To help facilitate compliance, EHS strongly encourages that COI purchases are limited to the amount of material needed for the experiment/operation.
Security of COI
Multiple layers of security are required for COI stored in University facilities/property. Examples of security layers include:
- locked cabinet within a locked room
- access controlled room with locked cabinet
- access controlled area with a gated storage shed
Immediately report any suspect activity or loss of COI to the Department of Public Safety at 911.