Roberts Law Group News

CFATS Outlier Initiative

As reiterated most recently in its 2019 CFATS Outreach and Implementation Plan, the Department of Homeland Security (DHS) is actively pursuing Chemical Facility Anti-Terrorism (CFATS) “outliers” by cross-walking CFATS Top-Screen data with Environmental Protection Agency (EPA) Risk Management Program (RMP) data (among other sources) to identify facilities that have inaccurate, incomplete, or non-existent Top-Screens on file with DHS.
DHS has at least one Chemical Facility of Interest (CFOI) Analysts to help ensure Top-Screen compliance and identify possible CFATS outliers. The CFOI Analyst will contact a facility to inform it that DHS believes the facility is an outlier and direct the facility to submit (or update) a Top-Screen (or provide information as to why the facility is not required to submit a Top-Screen).