New customer who is not from local area. Refusing to provide address where fertilizer will be used or delivered. Acting nervous or impatient. Possessing little knowledge of crops, soil composition, field size, application methods, or fertilizers. Purchasing large quantity of pesticides, combustibles, or fertilizers containing ammonium nitrate out of season or with cash. Appearing to be interested only in ammonium nitrate; displaying no interest in alternative fertilizers or fertilizer combinations. Seeking chemicals with weight in excess of fertilizer distributor capacity. Making suspicious inquiries regarding equipment (e.g., tank size, spray range). Asking about acquiring vehicles equipped for spraying or hauling (e.g., crop dusters, crop sprayers, fuel tankers). Failing to state legitimate agricultural use for product. Storing agricultural supplies in unusual containers. Using a rental vehicle or a vehicle with an out-of-state or temporary license plate to transport items such as fertilizers containing ammonium nitrate (particularly 34-0-0) or other combustible materials in large proportions. Using cash for large transactions or a credit card in someone else’s name. It is important to remember that just because someone’ s speech, actions, eliefs, appearance, or way of life is different, it does not mean that he or ...more
The Fertilizer Institute (TFI) has been notified by the Department of Homeland Security (DHS) that final tier ranking letters have been sent to 544 facilities. Site security plans will be due to DHS no later than June 1, 2010. DHS also advised it is checking the Environmental Protection Agency's (EPA) database of Tier II and Risk Management Plan (RMP) facilities for any facilities that may have triggered the reporting requirements under CFATS. If a facility is on either the Tier II or RMP list, and has not submitted a top screen to DHS, a letter warning of potential enforcement action will be sent. Penalties can be as much as $50,000 per day and/or a shutdown order.
IFCA Manager of Regulatory Services Kevin Runkle recently attended a meeting hosted by The Fertilizer Institute (TFI) to discuss compliance with the Chemical Facility Anti-Terrorism Standards (CFATS). As a member of the TFI Security Task Force, Kevin has been able to attend several meetings hosted by TFI in order to assist IFCA members with compliance. Although a majority of IFCA ag retial members fell out of the requirements after registering with the Department of Homeland Security (DHS) and submitting Top Screen information, there are a few retailers as well as manufacturers and distributors who still must comply with the CFATS regulations. Tier 1, 2 and 3 facilities have received their final Tier determination letters from DHS, but Tier 4 letters have not been sent yet. Tier 1-4 facilities must submit a Site Security Plan (SSP) or Alternative Security Plan (ASP) to DHS adhering to a strict guideline of Risk Based Performance Standards (RBPS) outlined by DHS to prevent a terrorist attack at facilities. Compliance with the RBPS depends on a company's assigned tier level and may include instalation or upgrading of fencing, closed circuit TV (CCTV) monitoring, armed guards, patrol ...more
With the enactment of the 2008 Farm Bill, the Ag Retailers Association (ARA) initiated the chemical security tax credit for agricultural retailers, distributors and other eligible agribusinesses. Expenditures on certain security upgrades at your facility after May 22, 2008 are now eligible to receive tax credits of $100,000 per facility or $2,000,000 per company. Locks on ammonia nurse tanks are one an example of an eligible expense. Attached is the tax form required to claim the expense as well as a more detailed explanation of the types of security upgrades that are eligible for the tax credit. IFCA would like to thank ARA for working on this issue and helping to get it passed into law. If you have any further questions, please contact the IFCA office.
The IFCA office recently received a phone call from an FBI agent that we work with asking us to please keep an eye out for anything suspicious or out of the ordinary. FBI Special Agent Steffan Nass, Weapons of Mass Destruction (WMD) Coordinator has informed the IFCA office that several lawn & garden facilities and ag retail facilities in the Midwest have experienced theft of ammonium nitrate based fertilizers. Although no thefts have yet to be reported in Illinois, Special Agent Nass asks that you contact him directly if a theft has occurred at your facility no matter how big or small the theft. Special Agent Nass can be reached at 309.743.0067 or by e-mail at firstname.lastname@example.org.
Click on this link to download a FAQ sheet regarding the new TWIC requirements.
The US Coat Guard Port of Chicago is sticking with the compliance date of September 25, 2008 for river terminals handling hazardous materials to require Transportation Worker Identification Credentials at the facilities in this port district. This would include the ammonia terminals at Marseilles, Peru , Henry and Seneca. Ammonia motor carriers who do not have a TWIC card can still be loaded at the terminal, but may experience delays since their will have to escorted by facility personnel the entire time they are on the property. For information on how to obtain a TWIC card, please go to www.ifca.com and click on the fact sheet or contact Kevin Runkle.
This week, the Department of Homeland Security mailed letters, via Federal Express, placing chemical facilities into a preliminary Tier IV ranking. Some IFCA members with large quantities of anhydrous ammonia near populated areas have already received their letter this week informing them their facility is considered a Tier IV, which is the lowest level of tier ranking. Facilities placed in this level must submit a copy of their SVA to DHS by December 31, 2008. The Asmark SVA model has been determined to meet the Center for Chemical Process Safety (CCPS) security vulnerability assessment design criteria for conducting security assessments. It is recommended your SVA be updated every three years and changes be made to your facility to address weaknesses found in your facility security. If you need to update your SVA or can not locate the original, please contact Kevin at the IFCA office to receive a new username, password and instructions to complete an updated SVA.
As letters from DHS are received by IFCA members, the consensus seems to be most IFCA members will not fall into a tier ranking by DHS and therefore are no longer subject to CFATS regulations. Although the majority of retailers had to register with DHS and submit TopScreen information due to anhydrous ammonia, this fertilizer alone does not appear to be enough to trigger a facility to be placed in any of the four tier rankings. One of the Chemicals of Interest (COI) that triggers a preliminary tier ranking by DHS is phosphine which is used in grain bins as a fumigant. Some IFCA members have been placed in a preliminary Tier 2 due to having this product on site even if only for a short amount of time. If a company is given a tier ranking of one through three, they must complete a site vulnerability assessment (SVA). To gain access to the DHS SVA, go to https://csat.dhs.gov/csat and enter your username and password used to gain access and submit TopScreen information. Click on the “manage my account” link then click on SVA. Since the SVA ...more
Online registration is now available for the 2008 National Agronomic Environmental Health and Safety School (NAEHSS) held at the Interstate Center in Bloomington, IL on August 19th and 20th. The national safety school covers a wide variety of industry hot topics including presentations from DHS, USEPA, OSHA, JJ Keller & Associates, USDOT, The Fertilizer Institute and Illinois EPA. Topics of discussion include SPCC, RMP electronic submission, EPA Pesticide Container and Containment Regulations, DOT Drug and Alcohol Compliance, future of NH3 nurse tank testing and Ag-chemical facility fire prevention plan just to name a few. The safety school keynote speaker will be TFI President, Ford West. For a more detailed agenda and to register online, go to www.naehss.org and click on the registration button. The registration fee is $135 per person with lunch provided both days.
The Department of Homeland Security confirmed that letters assigned tier rankings for high risk facilities will be sent via Federal Express beginning today. Of the 32,000 TopScreen submissions, 7006 sites will be spread among Tier1-4 rankings. The breakout includes: Tier 1: 219 facilities, with a reporting deadline of Sept. 25 Tier 2: 756, reporting Oct. 24 Tier 3: 1712, reporting Nov. 24 Tier 4: 4319, reporting Dec. 31. The 25,000 sites not assigned a Tier ranking will also receive a FedEx letter notifying them of their non-regulated status. Please contact Kevin if you have questions or concerned once you determine how your facility is ranked.
The Department of Homeland Security (DHS) has recently sent an email to several IFCA members notifying them they did not complete the required information for Top-Screen Submission. IFCA has learned some companies failed to complete the final step of hitting the submit button at the end of the Top Screen process. If your company received an e-mail from DHS earlier this week stating the information was not submitted, then all you need to do is go back into the Top Screen with your user name and password and go to the very last page of the submission process an click on the submit button. All of the information you have entered for your facility is automatically saved so there is no need to re-enter the required information. If you have any problems finding the submit button in the Top Screen program, please contact Kevin at the IFCA office. In addition, IFCA has learned within the next week, DHS will issue its tier ranking letters to affected chemical facilities. Roughly 6500 facilities are covered, out of 35,000 Top Screen submissions. These facilities will be placed in 4 tiers and submission times for their Site Vulnerability Assessment (...more
The Department of Homeland Security, through the Transportation Security Administration (TSA) and the United States Coast Guard, is implementing a mandatory program generally requiring that all workers who have unescorted access to secure areas of a covered facility must obtain and carry a Transportation Worker Identification Credential (TWIC) card. A TWIC is a tamper resistant identification credential issued by theA, containing the worker’s biometric information (fingerprint template) to allow for a positive link between the card and the individual. The TWIC regulation affects every facility covered by the Maritime Transportation Security Act (MTSA). Facilities covered under MTSA include but are not limited to facilities that offload anhydrous ammonia, propane, ammonium nitrate, ammonium nitrate fertilizers, fertilizer mixtures, or nitro carbate mixtures described and defined as an oxidizer by the regulations of 49 CFR part 173. According to the US Coast Guard, an estimated one million individuals will be required to obtain a TWIC. This includes Coast Guard-credentialed merchant mariners, port facility employees, longshoremen, truck drivers, and others requiring unescorted access to secure areas of maritime facilities and vessels regulated by MTSA. Some facilities that store fertilizer and anhydrous ammonia in separate locations may designate ...more
Chemical facilities that registered with the U.S. Department of Homeland Security (DHS) earlier this year must also complete Chemical-Terrorism Vulnerability Information (CVI) training. Any information or correspondence from DHS relating to the Chemical of Interest (COI) at your facility such as anhydrous ammonia or ammonium nitrate, which required facilities to register with DHS must also be marked as CVI and be viewed by persons who also have completed CVI training. The training is available online and takes approximately 20 to 30 minutes to complete. Once the training is complete, you can print off a certificate of completion that states you are an authorized CVI user. To access the online training, go to the IFCA website and click on regulations. Then click on ammonia or security and a link will be available which will take you to the DHS on-line training module. If you have problems accessing the training, please contact Kevin at the IFCA office.
TWIC or Transportation Worker Identification Credential is a new identification system required by people entering secure areas at our nations ports. This may include barge terminals that offload dry or liquid fertilizer and anhydrous ammonia. Click on this pdf file to get information regarding how and where to apply for a TWIC.
All facilities that register and submit Top-Screen information to DHS must also complete Chemical-Terrorism Vulnerability Information (CVI) training. This consists of an an online training module which takes approximately twenty minutes to complete. Click on this link to access the CVI training module, complete the training and print a certificate of completion.
The Fertilizer Institute (TFI) has informed us that the Department of Homeland Security's (DHS) release of tier ranking letters to Top Screen participants has once again been delayed. DHS mailed letters to twenty-two of the forty-eight Phase I facilities, however TFI does not expect Top Screen letters for Phase II facilities to be sent until mid or late May 2008. If this trend continues, letters may not be sent out to the majority of the ag retailers notifying them of their Tier level until late Summer, possibly into Fall.
The Department of Homeland Security has notified industry of the first phase of letters being mailed out to chemical facilities. High risk facilities may have already received letters from DHS notifying them of the Tier they have been assigned based upon the information they submitted in the Top-Screen. We can expect the remainder of the letters to be mailed out to chemical facilities sometime in late April. If you have any questions please contact the IFCA office.