Facilities that possess any chemicals of interest (COI) listed in Appendix A at or above the specified screening threshold quantities (STQ) and concentration are considered chemical facilities of interest under the Chemical Facility Anti-Terrorism Standards (CFATS) program and must report their chemical holdings to the Cybersecurity and Infrastructure Security Agency (CISA) within 60 days of possession by filing a Top-Screen survey.
The Top-Screen is an online, easy-to-use survey available through the Chemical Security Assessment Tool (CSAT).
CISA uses the Top-Screen information to determine if the facility presents a high level of security risk and is, therefore, subject to the CFATS regulation. For more information, visit the CFATS Process webpage.
Please note that if your facility makes a material modification or comes into possession of additional COI listed in Appendix A at or above the STQ and concentration after submitting a Top-Screen, your facility must complete and submit an updated Top-Screen to CISA within 60 calendar days of possession. If the chemical holdings at your facility will be fluctuating within a business cycle, see Top-Screen Submission Tips for more information.
How To Submit a Top-Screen?
The Top-Screen survey is housed in CSAT—a secure, online portal used by covered chemical facilities and CISA to submit and receive CFATS-related applications and documents. CSAT is only accessible to Chemical-terrorism Vulnerability Information (CVI) certified individuals.
After completing CVI training, facilities should register for a CSAT user identification and password. CISA will validate a facility's registration and notify the facility on how to access CSAT.
Facilities can then log into CSAT and submit a Top-Screen survey to CISA for review.
Note: If you have been provided a registration code from CISA, please enter it when prompted when registering your facility.
Facilities Excluded from CFATS
Certain facilities are excluded from the CFATS regulation by statute if they are:
- Regulated by the Maritime Transportation Security Act. Facilities regulated under 33 CFR Part 105 – Maritime Security are excluded from CFATS. For facilities where only a portion of the facility is regulated under MTSA, and the facility possesses a threshold level of a COI in the portion of the facility not covered under MTSA, then the facility is only partially excluded and must complete a Top-Screen for the portion of the facility not subject to MTSA.
- A public water system, as defined in 42 U.S.C. § 300.
- A treatment works, as defined in 33 U.S.C. § 1292.
- Owned or operated by the Department of Defense or Department of Energy
- Subject to regulation by the Nuclear Regulatory Commission (NRC) (42 U.S.C. § 2021). The exclusion does not apply to NRC-licensed facilities that only have a few radioactive sources and for which NRC security requirements are not imposed. The scope of exclusion has been formalized in a memorandum of understanding between CISA and the NRC including waste in combined storm water and sanitary sewer systems.
An agricultural production facility that uses the COI on crops, feed, land, livestock, or poultry may also be granted an indefinite extension from reporting COI to CISA. Read more in Federal Register Vol. 73, No. 6, page 1640.
- Download a printer-friendly CFATS Agricultural Production Facilities fact sheet to understand the agricultural extension and which facilities may be required to report their chemical holdings under CFATS.
The Transportation Security Administration is the lead component within the Department for regulating the security of transportation facilities such as railroads and natural gas pipelines. CISA does not currently require railroad facilities and truck terminals that possess COI at or above STQ to complete a Top-Screen. See FAQs 1178 and 1789 on the CFATS Knowledge Center for more information.
The CFATS regulation does require the reporting of COI that meets or exceeds the STQ found within any rail car that is detached from motive power. However, if the COI is attached to motive power, the COI does not need to be reported. The regulation requires the reporting of threshold quantities of theft/diversion and sabotage COI within any rail car at the facility, whether or not the rail car is attached or detached from motive power.
Covered chemical facilities with a pipeline within their boundaries must also identify the pipeline as an asset and address it, as appropriate, in the facility's Security Vulnerability Assessment (SVA)/Site Security Plan (SSP).
Top-Screen Submission Tips
Based on the review of tens of thousands of Top-Screen submissions, CISA has identified helpful tips to assist with completing and submitting your Top-Screen.
Enhanced Tiering Methodology
In September 2016, CSAT 2.0 was released in conjunction with the CFATS enhanced tiering methodology to improve integration between surveys and to more appropriately identify and tier high-risk chemical facilities.
All chemical facilities of interest and CFATS-covered chemical facilities that previously submitted a Top-Screen to CISA had to resubmit a Top-Screen in CSAT 2.0 to be run through the new tiering engine.
In April of 2017, CISA began sending tiering determination letters to chemical facilities based on the new methodology. Tiering notifications continue as new Top-Screens are processed.
- Learn more about the enhanced tiering methodology by visiting the CFATS Tiering Methodology webpage.
- Learn more about the CSAT 2.0 updates by visiting the CSAT SSP Revisions webpage.
- CSAT 2.0 Top-Screen Instructions
- CSAT 2.0 Portal User Manual
- CSAT 2.0 Survey Application User Manual
Visit the CFATS Knowledge Center for an online repository of frequently asked questions, articles, and the latest CFATS program news.
For technical assistance with CSAT, please call the CSAT Help Desk at 866-323-2957 Monday through Friday (except federal holidays) from 8:30 a.m. to 5 p.m. (ET).