Chemical Security Assessment Tool (CSAT) Top-Screen Tips
As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire.
Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. This means that CISA will not require facilities to report their chemicals of interest or submit any information in CSAT, perform inspections, or provide CFATS compliance assistance, amongst other activities. CISA can no longer require facilities to implement their CFATS Site Security Plan or CFATS Alternative Security Program.
CISA encourages facilities to maintain security measures. CISA’s voluntary ChemLock resources are available on the ChemLock webpages.
If CFATS is reauthorized, CISA will follow up with facilities in the future. To reach us, please contact CFATS@hq.dhs.gov.
The Cybersecurity and Infrastructure Security Agency (CISA) has reviewed tens of thousands of Top-Screens submitted by chemical facilities under the Chemical Facility Anti-Terrorism Standards (CFATS) regulation. Based on these reviews, CISA has identified helpful tips to assist with completing and submitting your Top-Screen.
Under CFATS, any facility that possesses a chemical of interest (COI) at or above a specific concentration and screening threshold quantity (STQ) listed in Appendix A of the CFATS regulation is required to submit an online Top-Screen survey via the Chemical Security Assessment Tool (CSAT) within 60 days of coming into possession of the COI. This requirement applies regardless of how long the facility is in possession of the COI. The Top-Screen is reviewed by CISA using a risk-tiering methodology to determine whether a facility is high-risk and assigns high-risk facilities to one of four risk-based tiers. High-risk facilities must develop a security plan tailored to their tier level and unique circumstances.
Resubmissions for Material Modifications
CFATS-covered facilities must resubmit a Top-Screen to report material changes or modifications to their COI holdings, facility operations, or site configuration within 60 calendar days after the modification, as this may alter their tier. Examples include:
- The addition or removal of COI at or above the STQ and concentration listed in Appendix A.
- Changes to quantity, concentration, location, or packaging of a COI as previously reported on a Top-Screen.
Facilities that have previously submitted a Top-Screen, but are determined to not be high-risk, must also resubmit a Top-Screen if the facility makes any changes to COI holdings.
As a best practice, CISA recommends that a facility include the highest expected quantity, all possible concentration levels, and all possible packaging types of COI it anticipates possessing at a given time over the lifecycle of the facility's operations to ensure more efficient reporting.
Business Operations: Predictive Top-Screen Filing
As a best practice for submitting Top-Screens, CISA recommends that a facility include the highest expected quantity, all possible concentration levels, and all possible packaging types for each COI the facility anticipates possessing at any given time over the lifecycle of the facility's operations. This ensures more efficient reporting and allows a facility the flexibility to construct a Site Security Plan (SSP) that reflects how the COI is used at the facility throughout its cycle.
For example, if the quantity of COI your facility possesses fluctuates within a business cycle (e.g., over the course of one year), it is recommended that you identify the highest amount within that cycle on the Top-Screen. This ensures the Top-Screen remains accurate through the business cycle and prevents your facility from having to file multiple Top-Screen survey updates.
Business Planning: Hypothetical Top-Screen Filing
CISA uses a risk-tiering methodology that fully accounts for all elements of risk—consequence, vulnerability, and threat—to identify and appropriately tier high-risk chemical facilities. As your facility plans potential, future business changes, you may request that CISA conduct an analysis to determine how any changes might impact the tiering of the facility. These changes may include:
- Change in quantity or concentration of COI
- Changes in location
- Changes in storage conditions
- New facility construction
Working with CISA to determine the impact of business decisions prior to completion can help your business make the most efficient and cost-effective choices and ensure we continue to work together to keep our nation and communities secure. If your facility would like to request a consultation, please email CFATS@hq.dhs.gov with a brief description of the issue you would like to discuss and your Facility ID (if the facility is already registered with the CFATS program).
CFATS-covered facilities are required to update their Top-Screens on a regular basis, as determined by their tier or based on written notification from CISA:
- A Tier 1 or Tier 2 facility must update its Top-Screen 2 years and 60 calendar days after its SSP is approved or 2 years and 60 calendar days after its most recent Top-Screen submission, whichever is later.
- A Tier 3 or Tier 4 facility must update its Top-Screen 3 years and 60 calendar days after its SSP is approved or 3 years and 60 calendar days after its most recent Top-Screen submission, whichever is later.
CISA does not have any periodic resubmission requirements for facilities that have previously submitted a Top-Screen and are determined to not be high-risk. However, if these facilities make any changes to COI holdings, a Top-Screen should be resubmitted.
A covered chemical facility that has closed must report the closure to CISA so that the facility record may be archived. Notification to CISA is accomplished by submitting a revised Top-Screen, a letter to the Agency explaining the closure and subsequent material modification, and any applicable supporting documentation via email, mail, or fax:
- Email: CSAT@hq.dhs.gov
- Mail: Chemical Security, Associate Director
CISA — CHR STOP 0609
Cybersecurity and Infrastructure Security Agency
1310 N. Courthouse Rd.
Arlington, VA 20598-0609
- Fax: 1-866-731-2728
Visit the CFATS Knowledge Center for an online repository of frequently asked questions, articles, and the latest CFATS program news.
If you have additional questions, 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).