Why Should Nations Vow not to Use Chemical Weapons

July 3rd, 2009
Dr.Badruddin Khan asked:


Chemical warfare involves the use of natural or synthetic substances to disable or kill an enemy or to deny them the use of resources such as agricultural products or foliage in which to hide. The effects of the chemicals may last only a short time, or they may result in permanent damage and death. Most of the chemicals used are known to be toxic to humans or plant life. In some cases, normally harmless chemicals have also been used to damage an enemy’s environment. Such actions have been called ecocide and are one method for disrupting an enemy’s economic system. The deliberate dumping of large quantities of crude oil on the land or in the ocean is an example of ecocide. The appeal of chemicals as agents of warfare is their ability to cause mass casualties or damage to an enemy with only limited risk to the forces using the chemicals. Poisoning a town’s water supply, for example, poses almost no threat to an attacking army. Yet the action could result in the death of thousands of the town’s defenders. In many cases, chemicals are not detectable by the enemy until it is too late for them to take action.

Chemical warfare dates back to the earliest use of weapons. Poisoned arrows and darts used for hunting by primitive peoples have also been used as weapons in battles between tribal groups. For example, in 431 B.C., the Spartans used burning sulfur and pitch to produce clouds of suffocating sulfur dioxide in their sieges against Athenian cities. When the Romans defeated the Carthaginians of North Africa in 146 B.C., they destroyed the city of Carthage and spread salt on surrounding fields to destroy the agricultural capability of the land. The Romans’ intent was to prevent the Carthaginians from rebuilding their city.

 

Chemical agents can be classified into several general categories, ranging from those that cause relatively little harm to those that can cause death. One group includes those that produce only temporary damage. As an example, tear gas tends to cause coughing, sneezing, and general respiratory discomfort, but this discomfort passes within a relatively short period of time. Other agents cause violent skin irritation and blistering and may result in death. Still other agents are poisonous and are absorbed into the victim’s bloodstream through the lungs or skin, causing death. Nerve agents attack the nervous system and kill by causing the body’s vital functions to cease. Finally, other agents cause psychological reactions including disorientation and hallucinations. Another group of chemical agents include those that attack vegetation, damaging or killing plants. Some examples include defoliants that kill a plant’s leaves, herbicides that kill the entire plant, and soil sterilants that prevent the growth of new vegetation.

 

 The first large-scale use of poisonous chemicals in warfare occurred during World War I (1914–18). More than 100,000 tons (90,000 metric tons) of lethal chemicals were used by both sides in an effort to break the stalemate of endless trench warfare. The most commonly used chemicals were four lung-destroying poisons: chlorine, chloropicrin, phosgene, and trichloromethyl chloroformate, along with a skin-blistering agent known as mustard gas, or bis (2-chloroethyl) sulfide. These poisons caused about 100,000 deaths and another 1.2 million injuries, almost all of which involved military personnel. In 1925, many of the world’s nations signed an agreement, called the Geneva Protocol, to discontinue production of chemical agents for military use. Despite this agreement, the United States, Britain, Japan, Germany, Russia, and other countries all continued development of these weapons during the period between World War I and World War II (the 1920s and most of the 1930s). This research included experimentation on animals and humans. Although chemical weapons were not used very widely during World War II (1939–45), the opposing sides had large stockpiles ready to deploy against military and civilian targets.

During the civil war in Vietnam, the U.S. military used a “harassing agent” during many of its operations. (The United States sided with and supplied the South Vietnamese in the early 1960s and joined their military efforts against the North in 1964.) The agent was a tear gas known as CS or o-chlorobenzolmalononitrile. CS was not regarded as toxic to humans and was intended only to make an area uninhabitable for 15 to 45 days. A total of about 9,000 tons (8,000 metric tons) of CS were sprayed over 2.5 million acres (1.0 million hectares) of South Vietnam. Although CS was classified as nonlethal (not deadly), several hundred deaths were later reported when the gas was used in heavy concentrations in confined spaces such as underground bunkers and bomb shelters.

Poisonous chemicals were also used during the Iran-Iraq War of 1981–87, especially by Iraqi forces. During that war, both soldiers and civilians were targets of chemical weapons. Perhaps the most famous incident was the gassing of Halabja, a town in northern Iraq that had been overrun by Iranian-supported Kurds. The Iraqi military attacked Halabja with two fast-acting neurotoxins, sarin and tabun. Sarin and tabun cause rapid death by interfering with the transmission of nerve impulses. Muscular spasms develop and a person dies when he or she is no longer able to breathe. About 5,000 people, mostly civilians, were killed in this incident.

Herbicides are chemicals that were originally developed to kill weeds. However, they are just as effective at killing agricultural crops as they are at killing weeds. During the Vietnam War, in addition to tear gas, the U.S. military relied heavily on the use of herbicides as a weapon of war. The purpose of using herbicides was two fold: first, to destroy enemy crops and disrupt their food supply and second, to remove forest cover in which enemy troops might hide. Between 1961 and 1971, about 3.2 million acres (1.3 million hectares) of forest and 247,000 acres (100,000 hectares) of Vietnamese croplands were sprayed at least once. This area is equivalent to about one-seventh of the total land area of South Vietnam. The most commonly used herbicide was called Agent Orange, a blend of two herbicides known as 2,4-D and 2,4,5-T. Two other herbicides, picloram and cacodylic acid, were also used, but in much smaller amounts. In total, about 25,000 tons of 2,4-D, 21,000 tons of 2,4,5-T, and 1,500 tons of picloram were utilized as a result of U.S. military actions during the war.

In particular, Agent Orange was sprayed at a rate of about 22.3 pounds per acre (25 kilograms per hectare). This rate is equivalent to about 10 times the rate at which those same chemicals are used for plant control purposes in forestry. The higher spray rate was used in Vietnam because the intention of the U.S. military was the ultimate destruction of Vietnamese ecosystems (its communities of plants and animals). The ecological damages caused by the military use of herbicides in Vietnam were not studied in detail. However, a few casual surveys have been made by some visiting ecologists. These scientists observed that coastal mangrove forests (tropical trees and shrubs that form dense greenery) were especially sensitive to treatment with herbicides. About 36 percent of the mangrove ecosystem of South Vietnam was sprayed with herbicides, a total of about 272,000 acres (110,000 hectares). Almost all of the plant species of mangrove forests proved to be highly vulnerable to herbicides, including the dominant species of tree, red mangrove.

 

Severe ecological effects of herbicide spraying were also observed in the biodiverse upland forests of Vietnam, especially its rain forests. Mature tropical forests in this region have many species of hardwood trees. These forests are covered by a dense canopy consisting of complex layers. As a result, a single spraying of herbicide typically kills only about 10 percent of the larger trees. However, the goal of the U.S. military was to achieve a more extensive and longer-lasting defoliation. Hence, they sprayed many areas more than once. In fact, about 34 percent of Vietnam was treated with herbicides more than once.

The effects on animals of herbicide spraying in Vietnam are not well documented. However, there are many accounts of reduced populations of birds, mammals, reptiles, and other animals in the mangrove forests treated with herbicides. In addition, large decreases in the yield of near shore fisheries have been attributed to the spraying of mangrove ecosystems, which provide spawning and nursery habitat for the fish. The effects on wild animals were probably caused mostly by habitat changes resulting from herbicide spraying. However, there have also been numerous reports of domesticated agricultural animals becoming ill or dying. Because of the constraints of warfare, the specific causes of these illnesses and deaths were never studied properly by veterinary scientists. However, these ailments were commonly attributed to toxic effects of exposure to herbicides, mostly ingested by the animals with their food.

 Large quantities of petroleum are often spilled at sea during warfare, mostly as the result of damage to oil tankers or other facilities such as offshore production platforms. During the Iran-Iraq War of the 1980s and the Persian Gulf War of 1991–92, however, oil spills were deliberately used to gain military advantage, as well as to inflict economic damages on the enemy’s postwar economy.

The world’s all-time largest oceanic spill of petroleum occurred during the Persian Gulf War. The Iraqi military deliberately released almost 1 million tons (900,000 metric tons) of crude oil into the Persian Gulf from several tankers and an offshore facility for loading tankers. In part, the oil was spilled to establish a defensive barrier against an expected attack by the anti-Iraqi coalition forces. The hope was that igniting the immense quantities of spilled petroleum would create a floating inferno that would provide an effective barrier against a seaborne invasion. It is believed that the Iraqis also sought to contaminate the seawater used in desalination plants that supply most of Saudi Arabia with freshwater.

The first treaty to control the use of chemical weapons was the Geneva Protocol, agreed upon in 1925 and subsequently signed by 132 nations. This treaty was prompted by the horrible uses of chemical weapons during World War I. It banned the use of asphyxiating, poisonous, or other gases, as well as bacteriological methods of warfare. In spite of having signed this treaty, however, all major nations are known to have continued research on new and more effective chemical and bacteriological weapons. In 1993, negotiators for various nations met at a Chemical Weapons Convention and agreed to the destruction of all chemical weapons within a 10 to 15 year period following ratification of a chemical weapons treaty. By the end of 2000, 174 nations had signed, ratified, or acceded to the treaty. In the long run, its effectiveness depends upon its ratification by all countries having significant stockpiles of chemical weapons, the countries’ commitment to following the terms of the treaty, and the power of an international monitoring program to expose and discipline member countries ignoring the treaty. Part of the problem in obtaining effective chemical weapons treaty is desire. Nations have to want to destroy their stockpiles of weapons and discontinue making more of them. Another part of the problem is involvement of cost in order to safely destroy the chemical weapons of the world’s largest military powers.



Know your Pool Chemicals

June 15th, 2009
Davy Feller asked:


Think pool cleaning and the first thing that comes to mind are cleaners, most of them chemical based. Knowing the various pool chemicals available in the market can help decide on the one to pick depending on the one that is most suitable from a cost, form and effectiveness aspect. There is no point in choosing a pool chemical that fails to do the job effectively, unless the idea is to clean out the business itself. Not only is it important to assess the pool chemical constitution of these pool cleaning aids but it is also important to store and use them properly to prevent serious hazards.

It is crucial to know the problem for which the pool chemical is being chosen. One chemical does not work for all pool related issues. There is the ever threatening algae problem which can be controlled by one type of pool chemical and then there is the ph water balancing demands that are met by another pool chemical. Interestingly for ph balancing of the water, it is very important to take into consideration the disinfectant that is being used in the pool. Depending on the disinfectant and the ph level, an appropriate pool chemical maybe selected to reach the optimum ph level of the water. Therefore the first step in knowing your pool chemical is to have complete knowledge of the problem that the pool chemical is designed to solve.

The next step is to understand the various salts that make up the pool chemical constitution. This is important to ascertain if a particular pool chemical is sold by another manufacturer with a different brand name even when the salts in the pool chemical remain the same. Knowledge of the salts also helps in assessing whether the pool chemical is environmentally safe or not. Therefore, as a pool cleaner, it is crucial that you know your pool chemical constitution thoroughly before adopting it to clean the pool.

The same pool chemical salt can also be available in several forms. There are chorine tablets, liquids and powders that flood the market. Each one has its own advantages and disadvantages. Knowing which form is most suitable will help you decide on the perfect chemical constitution.

Having elaborated on the three main points that are essential to know your pool chemicals, let us proceed to identify a few pool problems and their chemical solutions.

1) Algae control – Algae tends to thrive in water and is one of the most common problems of pools. Despite the regular disinfectants being used, algae continue to grow. If this is the problem at hand, adopt an effective algaecide. These pool chemicals are highly effective in removing the algae completely.

2) Murky water – Due to water hardness and high usage, murky water tends to occur often in pools. Since it is not possible to empty the pool out each time to clear the water, choose between an effective concentrated water clarifier, granular floc or clear tablets. All three forms are effective in solving the problem. These pool chemicals shock the water of the infection.

3) Disinfection – Chlorine is the most effective chemical for pool water disinfection. There are several brands and forms available to choose from and depending on suitability one of these maybe selected for the job.

Knowing your pool chemical is the most effective way to ensure customer satisfaction. Choosing the right pool chemical can result in higher chances of converting a first time client into a regular client.



Dhs Publishes Top Screen Requirements – Flammable Chemicals

June 12th, 2009
Patrick Coyle asked:


Late on Friday, June 8, 2007, the Department of Homeland Security (DHS) published the guidelines that organizations will need to follow to submit the Top Screen information to the DHS Chemical Security Assessment Tool (CSAT). The information submitted through this secure web site will be used by DHS to determine if the chemical facility is a high-risk facility requiring further regulation under 6 CFR part 27, Chemical Facility Anti-Terrorism Standards (CFATS).

The first people that will be required to submit information to the Top Screen module will be those facilities previously identified by DHS as probably being high-risk facilities. These organizations will be contacted by direct letters from DHS or by a notice being published in the Federal Register.

Two PDF documents show up on the DHS Top Screen instruction page, CSAT Top Screen Questions and CSAT Top Screen Users Manual. While both of these documents are rather long (80 pages and 66 pages respectively), it is obvious that DHS has worked hard to make this data collection effort as painless as possible. Facilities that will be required to submit information to the Top Screen Module will certainly want to print out the Top Screen Questions document and use it to record the information that they will be required to submit. This will help them to collect and organize the information in a way that will be easily accessible when they go online.

To make things easier to enter the necessary data on the chemicals of interest, DHS has taken the 300+ chemicals listed in Appendix A and grouped them into nine groups. Those groups are:

1. Toxic Chemicals.

2. Flammable Chemicals.

3. Explosive Chemicals.

4. Improvised Explosive Device (IEP) Precursor Chemicals.

5. Weapons of Mass Effect (WME) Chemicals.

6. Chemical Weapons/Chemical Weapon Precursor (CW/CWP) Chemicals.

7. Sabotage/Contamination Chemicals.

8. Mission Critical Chemicals.

9. Economically Critical Chemicals.

Each of these nine groups of chemicals will require responses to different kinds of questions based on they types of chemicals. In each category, however, there will be a preliminary list of chemicals from Appendix A for that category, with Yes and No checkbox beside the chemical. The default response will be No. The submitter will check the Yes box only for those chemicals on site or that had been on site within the last 12 months. Subsequent questions will only be asked for those chemicals marked Yes.

When determining how much of a chemical is considered to be on site, the Facility Submitter must take into consideration how much is in storage tanks, other containers, process equipment, and piping and in rail cars, both on site and on sidings immediately adjacent to the site. If there are documented procedures limiting the quantity on site, those can be taken into account. If there are no documented procedures, the maximum quantity possible in the various containers will be used to determine how much may be on site.

The Top Screen guidance introduces another concept that they use to evaluate the hazard associated with chemicals on site, the AHQ (Area of Highest Quantity). The AHQ tries to take into account the fact that if a chemical is distributed over a wide area in a facility it will probably be less of a risk during a terrorist attack, because it will be harder to release all of that chemical. To determine the AHQ you must determine where the largest concentration of the chemical is within a circle of a diameter of 170 feet. Thus, if there were a number of storage tanks on site, but were widely scattered you would use the largest tank or combination of tanks that would be in a single 170 foot diameter circle to determine the AHQ amount.

There are 89 chemical on the Flammable Chemicals list. These chemicals made the list because DHS believes that, if released, they will form a vapor cloud and, if ignited, have the potential for significant acute adverse consequences for human life or health due to explosion and fire. After selecting which flammable chemical(s) the facility has on site at or above the STQ limit the Top Screen will require the Submitter to provide the maximum amount on site and the maximum amount within the AHQ for each chemical identified. No other questions will be asked about flammable chemicals.

This will be a time consuming process to complete all of the Top Screen information, but it will not have to be done at a single sitting. The incomplete information will be saved between multiple sessions. Many facilities will not have to complete the entire 80 page process. There are many places, where depending on the answers to various questions, the Top Screen will notify the Submitter that the facility is not a high-risk facility and no further action is needed under 6 CFR part 27 until something changes at the facility. Some facilities will be told at the end of the submission that they are preliminarily designated a high-risk facility and must complete a Security Vulnerability Assessment (SVA) within 90 days. Most facilities, however, will have to complete the entire Top Screen only to be told that they might be declared a high-risk facility, but that determination will be made after further review at DHS. Those facilities will have to wait for a letter telling them what the preliminary out come will be.



Comprehensive Directory Of Inorganic Chemicals

June 11th, 2009
SME Business Services asked:


Inorganic chemicals are a broad class of substance that encompassing all those that do not include carbon and its derivatives as their principal elements.

But this class includes carbides, carbonates, cyanides, cyanates, and carbon disulfide. Inorganic chemicals may occur naturally in the geology or they may be caused by mining, industry or agricultural activities.

Inorganic chemicals are also found in small quantity in water supplies. Inorganic Chemicals can be dangerous in larger amounts and can cause a variety of damaging effects to the liver, kidney, nervous system, circulatory system, gastrointestinal system, bones, and skin, depending upon the chemicals and level of exposure.

Sme.in, an online business directory provides a convenient access to Inorganic chemicals like calcium hydroxide, calcium phosphates, calcium silicates, sodium borate decahydrate, sulfur, and so on. It is a B2B directory, which brings all the sellers and buyers of chemicals inorganic on a common platform to interact.

Sellers need to get themselves registered with SME. Buyers need to enter chemicals inorganic on the SME portal search box and get all the details of any type of inorganic chemicals

Inorganic chemicals may be harmful or useful. The useful inorganic compounds find application in many fields. There is an elaborate listing of the manufacturers of useful inorganic chemicals at sme.in.

Inorganic Chemicals, Chemicals Supplier, Inorganic Chemical Manufacturers, Chemical Exporters, Wholesale Chemical, Laboratory Chemical, Calcium Hydroxide

Inorganic Chemicals - India’S Largest Online Inorganic Chemicals, Chemicals Supplier, Inorganic Chemical Manufacturers, Chemical Exporters Industry, Wholesale Chemical Supply From India



The Process of Producing Specialty Chemicals

May 31st, 2009
Stephanie Larkin asked:


Specialty chemicals have an enormous variety of uses; in fact, it’s more accurate to say that in most cases, it’s possible to produce a specialty chemical that suits whatever the needs of a particular process might be.

What are Specialty Chemicals?

Most chemicals are categorized in one of two groups: commodity chemicals, and specialty chemicals. Commodity chemicals are those that are produced in vast quantities, and are fairly basic and inexpensive to produce. These tend to be produced in a plant that produces enormous amounts of just one or two different chemicals.

Specialty chemicals are somewhat different, in that most specialty chemical manufacturers tend to produce much smaller amounts of their products. These specialty chemicals tend to be more expensive than their commodity counterparts (in part due to the effects of economies of scale), and are used less frequently for more specific and refined purposes. Specialty chemicals include inert greases, oils, and waxes, chemicals used in laboratories, water treatment chemicals, epoxies and resins, food additives, pharmaceuticals, and photographic chemicals.

How are Specialty Chemicals Designed and Produced?

A useful aspect of specialty chemicals is that they can be custom designed to meet the specifications of a particular product or process.

The important thing to understand is that every chemical is made up of molecules that are in turn made up of different combinations of atomic elements. Each element has its own special set of chemical and physical properties, and depending on the combination of elements that are used, the chemical substance will have certain chemical and physical properties of its own.

These chemical properties are, overall, dependent on one hugely important factor: the number of electrons that a single atom of a single element is made up of. Amazingly enough, for example, the sole basic difference between elemental oxygen and elemental carbon is that an atom of oxygen has eight electrons, while an atom of carbon has six. This basic difference means that each element has entirely different physical and chemical properties.

This might seem like a rather long-winded explanation, but it’s important for understanding how a chemist can design various types of specialty chemicals, because the ways in which various different elements react is also determined largely by the number of electrons an atom of each element contains.

Another important concept is that an atom of any element has a series of layers of electrons, called shells, and with the exception of the innermost shell, each can hold up to eight electrons. An atom that doesn’t have a filled outer shell will form chemical bonds with other atoms, if it can, to fill that outer shell.

An atom of elemental fluorine, for example, has a total of nine electrons, and has an outer shell that is ‘missing’ one electron. It’s this atomic structure that makes fluorine a highly reactive element when it’s present in its pure form. You could say that fluorine ‘wants’ to react with other chemicals so badly that it will react with almost anything in its efforts to fill up that outer shell. This makes fluorine-and other halogen gases-quite important in the production of certain specialty chemicals. These halogen gases form compounds that are highly stable, because of their special atomic structure.

This made seem like an incredibly complicated business to an ‘outsider’ who isn’t familiar with chemical processes. To the chemists who design and produce specialty chemicals, it’s second nature. Chemists have the background knowledge-the understanding of all the different properties of each element-that allows them to design specialty chemicals that have the desired properties.

With knowledge of the different chemical and physical properties of elements and molecules, specialty chemists can design and produce chemicals that are inert and non-reactive at high temperatures, chemicals that repel water or dirt, that are used as lubricants, or as pharmaceutical drugs. The key is that the designer understands how to combine elements and chemicals to come up with a finished product with the chemical and physical properties that are needed.

Applications of Specialty Chemicals

The various applications of specialty chemicals are even more diverse than the chemicals themselves. Specialty chemicals are used in a vast array of industrial processes, and are produced as finished products.

Top applications include pharmaceuticals (in fact, more than half of current pharmaceuticals can be classified as specialty chemicals, they are fluorinated during the manufacturing process, to improve the bioactivity and stability of the finished product), fertilizers and pesticides, dyes, surfactants, plastics, elastomers, and photographic chemicals. Inert lubricants are widely used in automotive industries (including aviation and marine) and in many industrial processes. Specialty chemicals are themselves very often used in the production of other chemicals and finished products.



New Chemical Security Rules Go Into Effect 6-8-07

May 30th, 2009
Patrick Coyle asked:


On June 8th, 2007 the new Department of Homeland Security (DHS) regulations (6 CFR part 27) dealing with security requirements at chemical facilities go into effect. These new rules will be used to protect High-Risk Chemical Facilities from terrorist attack. These rules specify what organizations will be required to provide data to DHS to assist that agency in determining which facilities are declared to be High Risk Facilities.

One of the important parts of this regulation is the broad definition it uses for ‘chemical facility’. Section 27.105 of the new regulation defines chemical facility this way:

“Chemical Facility or facility shall mean any establishment that possesses or plans to possess, at any relevant point in time, a quantity of a chemical substance determined by the Secretary to be potentially dangerous or that meets other risk-related criteria identified by the Department.”

The important thing here is that the definition says nothing about chemical manufacturing, or chemical warehouse. Any establishment that uses hazardous chemicals, and that includes a wide variety of businesses, can be classed as a Chemical Facility under this regulation. The regulation gives an operational definition that covers anybody that possesses a dangerous quantity of a chemical and leaves the definition of dangerous to the Secretary of Department of Homeland Security.

Additionally, DHS has the discretion to define what a ‘High-Risk Chemical Facility’ is. Section 27.105 provides the following definition of High-Risk:

“…high risk shall refer to a chemical facility that, in the discretion of the Secretary of Homeland Security, presents a high risk of significant adverse consequences for human life or health, national security and/or critical economic assets if subjected to terrorist attack, compromise, infiltration, or exploitation.”

To adequately determine which facilities are High Risk Facilities, the Department will have to collect a data from a larger number of facilities that might be high risk, conduct some analysis, and then make some decisions. Additionally, DHS intends to rank High Risk Facilities into four tiers of relative level of risk to prioritize which facilities get DHS attention. To make it easy to collect this data and then efficiently analyze the collected data DHS has established a web-based tool called the Chemical Security Analysis Tool (CSAT) with various modules into which designated facilities will be required input data.

The module that the largest number of facilities will be required to use will be the Top Screen Module. Facilities will be required to enter basic information about the chemicals on hand, location of facility, type of facility and surrounding area information. DHS will then take that information, do some analysis and determine whether the damage to the facility would cause any of thesignificant adverse consequences specified in the definition if successfully attacked by terrorist. If DHS provides an interim designation of being a High Risk Facility, then the facility would have to do more detailed security studies (a Security Vulnerability Assessment, SVA) and report that information to the SVA module of the CSAT. DHS would analyze that data and then make a final determination if the facility was indeed a High Risk Facility. High Risk Facilities would then be required to develop a Site Security Plan to be submitted to DHS for approval.

The question then becomes, how does a facility know if it should submit a Top Screen?

On April 9th of this year DHS published a draft of a list of specific hazardous chemicals (Appendix A, Chemicals of Interest, to 6 CFR part 27) and the quantity of each chemical that they were proposing to declare as dangerous. The comment period ended in early May and the final version will be published sometime in early to mid-June. Sixty days after that list is published, any establishment that possesses or plans to possess a chemical on that finalized list in excess of the Screening Threshold Quantity (STQ) listed for that chemical, will be required to submit information to the Top Screen Module.

The STQ amounts listed in the draft appendix were surprisingly low for many chemicals. It was clear from these amounts that DHS is interested in collecting data from a wide range of chemical producers and users to ensure that as many of the potential High Risk Facilities as possible are identified in this process. While this will require a large number of facilities to submit information to the Top Screen that will have no other contact with DHS, it should capture all of the reasonable targets of a terrorist attack.

While the vast majority of facilities that will have to complete the Top Screen will do so based on their possession of chemicals listed in Appendix A, DHS has two other methods to direct facilities to complete the Top Screen. These two methods, Direct Letter Notification, and Public Notification through the Federal Register, allow DHS to contact specific facilities starting on June 8th and requiring these facilities to complete the Top Screen before Appendix A officially goes into effect sometime in August. These methods are expected to be used for two types of facilities.

The first type, the facilities that would receive individual letter notification, would be facilities that have already been tentatively identified by DHS to be at high risk for terrorist attack. These would be large chemical manufacturing or storage facilities that are in close proximity to large population concentrations. High on this list of facilities would be oil refineries, fuel storage facilities, and large manufacturing facilities of big name chemical companies. Most of these facilities will have already been working with DHS on security matters, but are the facilities that would be considered most likely targets by the public. It would be surprising if these facilities did not already know that they would be receiving one of these letters from DHS.

The second type, the facilities being notified by notices in the Federal Register, would be used to notify classes of facilities. These would be facilities that manufacture or store significant amounts of chemicals that pose specific dangers of toxicity, or could be used to easily manufacture toxic chemical weapons. Any facility that manufactures or stores quantities of chemicals that are classified as Inhalation Hazards (Chlorine, Bromine, and Anhydrous Ammonia among others), or chemicals that are used as chemical weapons or identified as precursors to chemical weapons by the Chemical Weapons Treaty, can expect to see a notice in the Federal Register to complete a Top Screen.

We can expect that DHS will not make public the names of companies to whom it sends letter notifications. DHS has no interest in publicizing potential terrorist targets if it does not have to. Likewise, while the Federal Register Notices will be public, the companies that respond to those notices will not be identified. Nor can we expect to see names of companies that do not respond to these notifications within the required sixty days, at least until DHS has the opportunity to make personal contact and do some political arm twisting to get compliance.

What we can expect to see is that DHS will announce in early August that they have made an initial assessment that a number, and they will probably announce a specific number, of facilities had been designated High Risk Chemical Facilities and were working their way through the Security Vulnerability Assessment. Meanwhile, a much larger number of presumably less high risk facilities were submitting information to DHS for determination if they are high risk facilities.