Got TEA? – You may need CFATS!
The Department of Homeland Security (DHS) has established Chemical Facility Anti-Terrorism Standards (CFATS) covering sites handling over 300 Chemicals of Interest.
http://www.dhs.gov/xlibrary/assets/chemsec_appendixa-chemicalofinterestlist.pdf
The listed chemicals were identified in the Federal Register on November 20, 2007. This table lists Minimum Concentrations and Screening Thresholds for addressing Release, Theft and Sabotage concerns for these chemicals. Seven different Security Issues are contained within the list. Triethanolamine (TEA) is listed as a chemical weapons precursor when at a minimum concentration of 80% and a screening threshold quantity of 220 lb.
Triethanolamine is commonly sold in two grades of purity, 99% and 85% (the remainder of the 85% grade is diethanolamine. Both grades are offered in LFG or Low Freeze Grade versions. The LFG versions contain 15% added water to prevent them from solidifying at common storage temperature.
If you buy only TEA 85 LFG, the concentration is 85% of 85 or 72.25% thus it fails to make the 80% minimum concentration that would trigger the CFATS rules. The three remaining grades are all above the minimum concentration threshold.
500lb is the common weight for TEA in drums. All grades of TEA in drums exceed the 200# screening threshold quantity. None of the grades meet this quantity in 40# pails. Doing a little math reveals that you could have the following number of pails:
- TEA 85 5 pails
- TEA 85 LFG Any Quantity of pails or drums
- TEA 99 4 pails
- TEA 99 LFG 5 Pails
If you find that you need to comply with CFATS because you store or use TEA (or any of the additional 300 or so chemicals of Interest on the list), your first step in is to arrange to have the U.S. Department of Homeland Security’s Office of Infrastructure Protection appoint you or one of your employees as an Authorized User of Chemical-terrorism Vulnerability Information. They will then need to prepare a Top-Screen profile using the DHS Chemical Security Assessment Tool (CSAT). Once this has been done and submitted to DHS a Chemical Security Identification Number will be assigned to your facility. In our experience it appears unlikely that your facility would be classified as High-Risk if the sole reason for registering was a drum or two of TEA. It could be more of a problem if the DHS identified you as a consignee of TEA while inspecting the shipping records of a vendor.
