Colleges and universities across the nation are preparing to comply with a new risk assessment program set in motion by the Department of Homeland Security.

The program calls for chemical facilities to document the amount of chemicals possessed by the department. If labs have chemicals in excess of the mandated quantity, they will be required to submit an inventory to the department, called a Top-Screen.

In a letter to the department, the Campus Safety Health and Environmental Management Association estimated it could take thousands of hours to complete the Top-Screen,

many more than the department’s estimate of 30 to 40 hours.

In another letter, the American Council on Education requested the department exempt colleges and universities from being required to comply with the program.

ACE said the current version of the rule might expose officials to criminal sanctions because the person submitting must be identified by the department and attest to his or her findings. According to the letter, the submitter faces up to eight years in prison if information submitted is found to be incorrect.

Andrew Phelan, assistant director and hazardous waste officer for the University Department of Environmental Health and Safety, said as currently written, the University would be required to complete a Top-Screen.

“We would have to come up with a system to inventory all our labs, which we don’t have an easy way to do,” he said. “It’s incidental to any student, but it’s going to be a challenge to the University.”

Phelan estimates that completing the inventory could cost the University $250,000 in labor and $25,000 per year to buy into an inventory system.

Phelan said some chemicals on the current list are very common. Acetone, a flammable chemical on the list, is found in many labs and can be bought at home improvement stores.

If the University is deemed a risk by the department, the security plan could be costly, Phelan said.

“I think it’s less likely that universities are going to be held to high security, but if they were, card access, biometrics, thumb prints and all those things, then the cost can go up and

up,” he said. “It might cost on the order of $25,000 per room, depending on the standards they set.”

Phelan said once the final rule is published, facilities will have 60 days from the effective date to complete their Top-Screen, which has not yet been announced.

“We have some shortcuts that might allow us to work with some accuracy within that timeframe, but it will be a challenge in any case, and there will be a continuing cost to the University,” he said.

According to Phelan, much of the preliminary plans about security policies are not compliant with a campus environment.

“They’re talking about fencing out facilities, and that kind of language doesn’t work at a university,” he said. “Part of the desire with research is to have relatively open access, so it’s going to change the way research is done.”

Anne Gross, vice president of regulatory affairs for the National Association of College and University Business Offices, said when reading the rule, many thought colleges and universities would not be affected.

“They appeared to be talking about what we think Congress was talking about, which was chemical manufacturing facilities,” she said. “The only thing that pulled in colleges and universities is the way they did the thresholds; they made them so small.”

According to Phelan, 104 of the 345 chemicals on the current list have a screening threshold quantity of any amount.

Despite the controversy, University chemistry professor Jeffrey Roberts said if these regulations are put into place, the chemistry department would conform to them.

Since chemicals like acetone are common in labs, Roberts said regulations could interfere with the chemistry department’s ability to do research and teach upper-division lab courses.

Patrick Burns, external affairs with national programs and preparedness director for the

Department of Homeland Security said the program is intended to help reduce risk, not mandate security policy.

“It’s not the department saying you’ll have to do this, have so many dogs, so many security guards. It’s ‘you guys present a certain level of risk, here’s some mitigation strategies,’ ” he said.

While no specific security plans are in place, Burns speculated as to the possible strategies the department would suggest.

“If we’re talking about a physical risk, a fixed site, we’re talking about increased physical security, hardening of the perimeter, things like that,” he said.

Burns said the department is looking to work with chemical facilities to ensure security.

“It’s ‘here’s the level of security we think you need, it’s up to you guys to figure out how to meet it,’ ” he said. “It’s not a top-down approach.”