Is Ammonium Nitrate Fuel Oil, also known as ANFO, included on Appendix A?
No. As stated in the preamble to the final Appendix A to the Chemical Facility Anti-terrorism Standards (CFATS), the only explosive Chemicals of Interest (COI) listed in Appendix A (i.e., release-explosives and theft/diversion explosives) are those listed by the Department of Transportation (DOT) as Class 1, Division 1 explosives. See 72 Fed. Reg. 65402-65403, 65405 & n. 37 (Nov. 20, 2007). Although ANFO is an explosive, it is not listed by DOT as a Division 1.1 explosive, and thus it is not covered by Appendix A. However, a facility that manufactures ANFO and possesses any chemical of interest (e.g. ammonium nitrate) in a quantity at or above the applicable STQ would be required to submit a Top-Screen.
