Chemical Facility Terrorism Precautions

The tragic events of September 11, 2001 served as a wakeup call to the chemical industry. Several recent studies have found security at chemical facilities unacceptable. The low level of security was a result of both apathy and the belief that large-scale terrorism within our borders was highly unlikely. However, even before September 11, terrorists released Sarin gas in a Tokyo subway, plots by the Ku Klux Klan members to blow up a gas refinery and by antigovernment militia members to blow up a 24-million gallon propane storage facility were thwarted by the FBI, and the Federal Building in Oklahoma City was bombed using an explosive made with common commercial chemicals.

Since the terrorist attacks in New York, Washington D.C., and Western Pennsylvania, several people have been charged with fraudulently obtaining commercial drivers’ licenses with hazardous materials endorsements. The threat that industrial chemicals will be used in future terrorist attacks is great. Breaching a storage tank or piping in an industrial facility may seem relatively easy to terrorist groups, making them very appealing targets. Chemical manufacturers, transporters and distributors all shoulder the responsibility of doing their part in preventing the use of chemical weapons of mass destruction.

Even if terrorist attacks are unlikely at a given facility, increasing security provides value to a chemical facility by increasing employee safety and environmental safeguards; minimizing theft of product, equipment and trade secrets; reducing vandalism and trespassing; reducing liability and insurance costs; and deterring sabotage by disgruntled employees.

Hazard Assessment

Many chemical companies conduct hazard assessments as part of their Process Safety Management (PSM), Risk Management Program (RMP) and/or general safety, health, and environmental risk management policies. Taking these assessments a step further does not require a great expense of time and resources.

First, identify the types of chemicals on-site and the consequences of their theft or release. Are chemicals distributed throughout the facility in small containers or are large volumes of hazardous materials concentrated in a warehouse or tank farm? Second, survey the surrounding landscape. Facilities in rural areas may be less attractive targets than those in urban areas or near hospitals, reservoirs, or public gathering places (sports stadiums, amusement parks, concert halls). Third, assess accessibility of the site. Is security adequate to restrict access? Older buildings with multiple, street-level windows present a greater concern than newer buildings with fewer windows or buildings located within perimeter fencing. Review the hours of operation to determine if weekend or nighttime entries are a concern.
There is no one-size-fits-all solution to security at chemical facilities. The level of security has to be based on the threat presented by site operations and the vulnerability of each site.

Physical Precautions

The physical layout and construction of a facility is critical to security. The concept of “layers of protection” should be employed. The first layer of protection should be perimeter fencing, followed by guards or receptionists, then locked doors with key card or combination access, and then control rooms located at the center. Safety, health and environmental concerns should not be pre-empted by security concerns. In terms of security, bulk chemical storage should be located in the middle of a building. This may not be the best storage procedure from a health and safety standpoint. However, there are some guidelines which should be followed based on a hazard potential.

Intrusion Prevention: Access points should be controlled. Buildings with multiple, unmanned access points enable intruders to enter the facility at their leisure. Entry into a facility should be restricted to staffed access points. Perimeter fencing should be installed whenever practical, with clear areas to eliminate hiding places. Trenches or bollards should be installed around sensitive processes.

Signs: Signage restricting access to the site should be conspicuously posted. Signage should direct visitors and vehicles to pre-determined areas.

Alarms: Facilities should have alarm systems, which may be supplemented by security guards and/or closed-circuit cameras.

Guards: Full-time guards can be a very useful component of a facility’s security program as well as assist in first aid, and CPR and help coordinate emergency procedures. Guards may be employed directly or through a security firm, full-time or off-hours only, stationed at a guardhouse or patrolling on foot or in a vehicle.

Doors: Doors should remain locked, including closets, electrical rooms, mechanical rooms, and control rooms. Ground-level or other accessible windows should be locked and provided with bars.

Lighting: Security lighting should be provided around buildings, storage tanks, and storage areas.

Backup Systems: Based on the hazard assessment, emergency electricity, cooling water or other utilities may be necessary to keep critical systems operable.

Computer Controls: Special care should be given to computerized control systems. These systems should not be connected to the Internet, as an accomplished hacker could access the control system and cause a release without physically entering the site. An educated intruder in the control room could cause considerable damage. Control rooms should be at the center of a facility’s layers of protection and access should be restricted by locked doors, combination locks, key cards, or other effective means.

Volume: Keep stocks of hazardous materials to a minimum. Keep rail and highway tanks secured within perimeter fencing.

Management Precautions

Visitors/Deliveries: All non-employee entrants to a chemical facility, including visitors, contractors, and delivery persons, should be required to sign in. Receptionists or guards should verify the identities of the visitors to the site and confirm that they have legitimate business at the site. Identification badges should be used to identify visitors and contractors. Visitors should be escorted at all times and should not be given lock combinations or keys. Company personnel should stop all truck traffic before granting access to sensitive areas within the facility.
Personnel should verify the identity of the driver, as well as confirm that the delivery/pickup is scheduled.

In highly sensitive operations, the truck should be inspected prior to allowing entry/exit.

Employee Background Checks: If not performed already, criminal background checks should be performed for all company personnel, particularly those with access to sensitive operations.

Customer Screening: New customers should be screened to ensure they provide the services related to the materials they attempt to purchase. Existing customers who change the types or volumes of purchase should be examined further. Customer pickups should be particularly scrutinized. Any suspicious purchase should be reported to local law enforcement.

Off-Hours Procedures: Storage tanks and delivery vehicles should be disconnected from hosing, piping and manifolds when not in use, as these are the most vulnerable components of the system.

Emergency Procedures: As part of an existing emergency response policy, procedures for shutting down reactions of other sensitive operations should be developed. The existing emergency response plan should also be reviewed and updated, as necessary.

Communication: Maintain lines of communications with local, state and federal law enforcement agencies, explaining the facility’s security efforts as well as the materials and operations being protected.

Communicate with trade groups to learn about credible threats, as well as precautions similar businesses are taking. Cooperate as much as possible with the media and citizens’ groups. Instruct all personnel to direct inquiries to a specific upper-level manager or press contact. This person should take care to avoid divulging specific technical information such as process diagrams, piping, drawings, clients/supplier lists, formulations, or other information that may be useful to terrorist groups. Sensitive information should be exchanged in person or via encrypted communications. When disposed of, sensitive documents should be shredded.

Written Policy: A site security policy should be written and explained to all employees. Employees should be trained to enforce the policy. They should be encouraged to challenge people not wearing badges. They should be instructed not to leave doors open for ventilation or smoke breaks. Employees should be encouraged to report suspicious people, unusual activity, suspicious packages, or other security concerns.

The aforementioned guidelines for increasing security are certainly not foolproof. The goal of security at industrial operations is not to provide the same level of protection found at a nuclear power facility or at critical government installations. However, it is the responsibility of those involved in the chemical industry to take additional precautions to reduce the likelihood of chemicals being used as weapons against the general public. At the same time, employees other than trained and licensed security personnel should not arm themselves in an attempt to defend commodities. That work is best left to local, state and federal law enforcement agencies. In the event of an incident or suspected incident, it is better to evacuate the facility and summon appropriate emergency personnel.

What Are Chemical Weapons?

The Chemical Weapons Convention defines chemical weapons as, “...chemical substances, whether gaseous, liquid or solid, which might be employed because of their direct toxic effects…” The Chemical Weapons Convention classifies Chemical Weapons as Schedule 1, 2, or 3.

Schedule 1 chemicals are defined as having little or no known peaceful uses. Schedule 1 chemicals include Sarin, Soman, Tabun, VX, sulfur mustards, Lewisites, nitrogen mustards, Saxitoxin, Ricin, and their precursors.

Schedule 2 chemicals have some commercial uses, but can also be used as precursors to Schedule 1 chemicals. Schedule 2 chemicals include Amiton, PFIB, BZ chemicals containing a phosphorus atom to which is bonded one methyl, ethyl or propyl group but not further carbon atoms or other precursors.

Schedule 3 chemicals have broad commercial applications and include phosgene, cyanogen chloride, hydrogen cyanide, choropicrin, precursors such as phosphorus oxychloride, trichloride, and pentachloride; trimethyl, triethyl, dimethly and diethyl phosphate; sulfur monochloride and dichloride, thionyl chloride, ethyl-diethanolamine, methyldiethanolamine, and triethanolamine.

Chemical facilities not using or manufacturing Schedule 1, 2, or 3 chemicals are not without risk. Essentially, any toxic, reactive, flammable, explosive or corrosive chemical can be used as a weapon. Facilities handling explosives, ammunition, or pyrotechnics may be particularly appealing targets to terrorists. Any chemical listed in the Environmental Protection Agency’s (EPA) RMP or in the Occupational Safety and Health Administration’s (OSHA) PSM standards may be a good candidate for use as a weapon based on its hazardous characteristics. Additional concerns are presented by petroleum products excluded in the PSM and RMP programs. It is up to each facility to determine if the types and quantities of chemicals on-site can be effectively employed as a weapon.

Additional information about the Chemical Weapons Convention and scheduled chemicals can be found at the Organization for the Prohibition of Chemical Weapons web site: www.opcw.nl.

XL Environmental • Risk Control Division • 520 Eagleview Boulevard, PO Box 636, Exton, PA 19341 • Phone: 800-327-1414 • Fax: 610-458-7285 • xlenvironmental.com

XL Environmental is a division of XL Specialty Insurance Company.