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Department of Homeland SecurityThe 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:

  • Monitor
  • 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 $33,333 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.

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 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.
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 Purchasing 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.

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.

A comprehensive chemical inventory is a component of the lab safety plan and must be reviewed twice a year and updated annually, at a minimum. Chemicals to be included are any hazardous chemicals (flammables, combustibles, corrosives, toxics and highly toxics, carcinogens, reactives, reproductive toxins and compressed gases) that are in storage or use in your laboratory. It is imperative that inventories are up to date in case of fire, chemical spills or other emergencies. Detailed instructions for using the CIS can be found in Chapter 2: Appendix 2A of the Laboratory Safety Manual.

An important aspect of the CIS is designating a storage place for each chemical and returning chemicals to their locations after each use. Store chemicals by hazard class, not the alphabet, and post storage areas to show the exact location of the chemical groups. Inspect chemical storage areas at least annually for outdated or unneeded items, illegible labels, leaking containers, etc. See Chapter 12: Management of Laboratory Wastes for advice on disposing outdated or unneeded chemicals.

Optimally, incompatible chemicals such as acids and alkalis should be stored completely separate from one another to prevent mixing in the event of an accidental spill or release of the materials. Limited storage space within the laboratories, however, may prevent this prudent practice of chemical segregation and storage. If space is limited, incompatible chemicals can be stored in the same storage cabinet if they are segregated according to their hazard class and stored in secondary containment such as tubs, trays, or buckets while in the cabinet. These secondary containers reduce the chance that incompatible chemicals will inadvertently contact each other. For more information about chemical compatibility storage groups as well as chemical storage locations see Chapter 4: Proper Storage of Chemicals in Laboratories.

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