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The United States Department of Homeland Security (DHS) has issued a new regulation, the Chemical Facility Anti-Terrorism Standards (6 CFR Part 27) for any facility that manufactures, uses, stores, or distributes any of the listed chemicals above a specified quantity. Colleges and universities must comply with this regulation in a very short time frame by reporting the listed chemicals if the regulatory screening threshold quantities are met. Since reporting requirements are based on aggregate amounts on campus, individual laboratories or other locations are not exempt from reporting as even small quantities must be factored in to the campus total. A complete list of these chemicals is available at http://www.dhs.gov/xlibrary/assets/chemsec_appendixa-chemicalofinterestlist.pdf.
The Department of Environmental Safety (DES) will begin collecting inventory information for this list of chemicals beginning on or about December 17, 2007 through a new web-based system, the University of Maryland Chemical Information Database (UMCID). Inventory information must be reported for research and teaching laboratories, storerooms and stockrooms, and other laboratory-associated locations where chemicals are used or stored. This tool will incorporate the Rule's laboratory exclusion for certain categories of chemicals and will address mixtures and types of containers where required by the regulation.
Inventory information for this list of chemicals will need to be submitted to DES through this system no later than January 25, 2008 in order to comply with Homeland Security requirements.
Since the threshold reporting quantity for certain chemicals is quite small, we recommend disposing of unwanted materials through the DES regulated waste pick up system at https://des.umd.edu/Waste/login.cfm. A list of the chemicals with these low threshold quantities is available at http://www.des.umd.edu/os/chemfac/low.html. The request must be made by January 3, 2008 to avoid DHS reporting requirements.
We recognize the challenging time frame involved and appreciate your support and cooperation in ensuring that the information is reported in a timely and accurate manner to avoid possible actions from the Department of Homeland Security. Details for accessing the UMCID and further instructions for completion of the inventory will be sent in a future message.
If you have questions, please feel free to contact me at mkotlas@umd.edu / 5-3960 or Chris Benas at cbenas@umd.edu / 5-3960.
Sincerely,
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