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Chemical standards releasedBy Randy Buhler CSU Cooperative Extension, Logan County agent, agronomy Colorado Many of you have received a letter from the Colorado Department of Agriculture concerning the Chemical Facility and Anti-Terrorism Standards. That letter refers you to a list posted in the Federal Register. It also scares you with the threat of a $25,000 fine if you fail to comply. The list that the letter refers to is 14 pages long. The list mentions only chemical names, rather than trade names. Once you find the chemical of interest, then you must determine the screening threshold quantity from their matrix to determine if reporting is required. The list will not tell you what amount is a placardable quantity for a particular product. You would have to know where to find that amount in the DOT regulations. The letter is bureaucratic over-reach based on the language of the Federal Register notification. Farmers and ranchers conducting normal production activities are highly unlikely to meet the screening threshold quantities. A couple of products may trip the requirement and you should be aware of those. Storing aluminum phosphide fumigant tablets or pellets in placardable quantities, (one case of 14-500 tablet count bottles) would require filing. Propane in excess of 60,000 pounds would require filing. Ammonium nitrate in excess of 2000 pounds would require a report. Anhydrous ammonia in excess of 10,000 pounds requires a report. Many distributors and dealers of agricultural products dropped those products from their inventory because of the expensive security issues and hassle with reporting. Insurance companies took a dim view of covering facilities with these red flag chemicals at the then current premiums. Some large-scale farms may handle such large amounts of products. In those few cases, the federal homeland security wants to know. Further information and additional requirements may be sent to those entities to provide security requirements established by the Homeland Security Department. Because the letter has a time sensitive enforcement date, be sure to keep the postmark on the envelope of your notification letter to prove your timely filing should the question come up. None of the common herbicide and insecticide products we use appears on the CFATS list. Certain fertilizer products and fuel gases in large quantities can trigger the need to file a CSAT Top-Screen report. If the trigger levels apply to your operation, you should file the report and let the Homeland Security folks decide whether they want to deal with your facility or not. Stop the presses. We just received notice from the Agricultural Retailers Association that they were successful in getting the Department of Homeland Security to modify their requirements as concerns of agricultural production entities. According to the letter, (1) Until further notice, or unless otherwise specifically notified in writing by DHS, the Top-Screens will not be required for any facility that is required to submit a Top-Screen solely because it possesses any Chemical of Interest, at or above the applicable screening threshold quantity, for use--(a) in preparation for the treatment of crops, feed, land, livestock (including poultry) or other areas of an agricultural production facility; or (b) during application to or treatment of crops, feed, land, livestock (including poultry) or other areas of an agricultural production facility; (2) This extension applies to facilities such as farms (e.g., crop, fruit, nut, and vegetable); ranches and rangeland; poultry, dairy, and equine facilities; turf grass growers; golf courses; nurseries; floricultural operations; and public and private parks. (3) This extension does not apply to chemical distribution facilities or commercial chemical application services." Therefore, for the time being, reports for the CFATS Top-Screen are only required from dealers, distributors, and commercial applicators that handle the threshold quantities of chemicals of interest.
Date: 2/14/08
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