Prior to the events of September 11, 2001, the chemical industry worried most about malicious vandalism, theft and an accidental toxic release caused by unauthorized people entering a chemical-producing facility. The threat of terrorism was perceived as a domestic problem, labeled "environmental terrorism," perpetrated by radicals who perceive the chemical industry as the enemy.
Certainly, malicious vandalism has plagued the chemical industry in the past. This writer first became aware of security issues in chemical plants long before the threat of terrorism became the primary security concern. I was called to a San Francisco Bay-area chemical facility to recommend perimeter protection measures for a tank containing a chemical used in the formulation of an agricultural compound. The chemical happens to be one of the primary ingredients in the making of methamphetamines. The plant is near a densely populated urban area where illegal drug labs are not uncommon, and they were concerned that the extremely explosive chemical could cause a conflagration if illegal drug makers accessed the tank and siphoned off a few liters of the substance.
Since then, the potential for international terrorism has drastically changed how security is perceived and implemented in America's chemical industry.
The mass media has reported that the chemical industry has done little to protect against the threat of terrorism. But the industry took immediate action to increase plant security following the terrorist attacks of September 11, 2001. The American Chemistry Council's Board of Directors adopted a new Security Code as part of its Responsible Care' program, which has been in place for more than 16 years. Since 1988, members of the American Chemistry Council (ACC) have significantly improved their environmental, health, safety and, in recent years, security performance through the Responsible Care initiative. Participation in Responsible Care is mandatory for ACC member companies, all of which have made CEO-level commitments to uphold the following requirements:
- Measuring and publicly reporting performance;
- Implementing the Responsible Care Security Code;
- Applying the Responsible Care Management System to achieve and verify results; and
- Obtaining independent certification that a management system is in place and functions according to professional standards.
Responsible Care is also a global initiative that is practiced in 47 countries that share a common commitment to advancing the safe and secure management of chemical products and processes. Specific Responsible Care practices may vary from country to country, since they are determined by each country's laws and national industry association.
The code requires every ACC member to conduct security vulnerability assessments, implement appropriate security countermeasures and have them certified by an outside party. In a 2004 report to former Secretary of the U.S. Department of Homeland Security Tom Ridge, the ACC stated that more than 1,900 ACC member facilities had completed rigorous security vulnerability assessments, the highest-priority facilities had already implemented security enhancements, and the remaining facilities were on schedule to implement security measures by the end of 2004. A number of chemical companies that are not members of ACC have similar commitments to security and uphold the principles of Responsible Care.
The American Petroleum Institute and the National Petrochemical & Refiners Association developed the Security Vulnerability Assessment methodology for its members. The tool is intended to help maintain and strengthen the security of personnel, facilities, and industry operations, thereby enhancing the security of our nation's energy infrastructure. The methodology is in concert with the goals of the Environmental Protection Agency to deter, detect, delay and respond.
Tools for Chemical Facilities
The security tools available to chemical producers have dramatically improved since the 9/11 attacks. Digital video recorders with video motion detectors allow surveillance of critical areas. Security personnel can view events in real time and re-enact events leading up to a critical point without time-consuming tape rewinding. Wireless access controls allow the installation of networked access controls on perimeter portals that previously required underground cabling or were inaccessible. Explosion-proof enclosures allow placement of electronic surveillance and intrusion detection systems in hazardous and explosive areas.
Stereo Doppler motion detectors placed at the tops of towers detect persons climbing ladders, yet they do not alarm due to normal events such as falling rain. Ram-resistant fencing with integral motion sensors give early warning of intruders while reducing the incidence of nuisance alarms. Guard tour and muster procedures have become electronic through the use of real-time wireless tour-tracking systems and biometric verification terminals. Nearly every manufacturer of security hardware and systems has an application in the chemical industry. But is technology all that's needed to harden these high-profile targets?
Ken Michaelis, CPP, CFE is the security manager of a leading chemical company with more than 25 years of experience in this field. He suggests a bold program wherein community-based policing would greatly increase security in and around chemical plants when blended with an array of new advances in technology. The basic concept is simple: Chemical plants are a neighborhood, and the facilities and the people who work in them are part of a community. Law enforcement personnel know the neighborhood. They can spot a person who does not belong to the community and investigate. Michaelis said, "If someone is perched on a hilltop with long-range photography equipment pointed toward a chemical plant, local law enforcement would want to investigate."
Michaelis cited a precedent for his faith in this system. "In the late '60s and early '70s we learned a lesson during the era of university campus riots and protests against the Vietnam War. Essentially, it was the awareness that arms-length law enforcement functions did not work in the university communities. The concept of community-based policing was tested with overwhelming success. In that setting, bicycles and lots of face time with the students and potential protestors turned the powder keg environment into a safer community. Ironically, it was safer for the law enforcement officers because they began to know the people, places and customs, and even make some friends. Eventually there were no more destroyed police cars or sniper rounds fired.
"Isn't it reasonable to think about these highly sensitive environments in a new way?" Michaelis continued. "I believe our industrial corridors are a community unto themselves. They impact neighborhoods that have grown up around them and are a significant part of the municipality, wherever they are. I believe these situations speak well for the concept of creating law enforcement substations in these areas around the country and basing a team of officers there that are seen often and can learn about us. They would soon understand what and who may look out of place. They would come to know our neighborhood alleyways and our regulars and know who to ask to verify information they may receive if they saw or heard something unusual. Community-based policing would provide long-term, enduring and meaningful preventative security in an area that is critical and of a mutual concern."
The concept of community-based policing can produce positive results. However, the first hurdle to implementing it is financial. In the face of shrinking tax revenues and governmental cost cutting, particularly at the community level, available personnel and assets available for law enforcement are already stretched to the limit. Revenue-strapped cities even resort to borrowing law enforcement personnel from neighboring communities to quell crime waves.
Legislation on the Docket
The U.S. government has wrestled with chemical plant security since the 2001 terrorist acts. Senate bill S.1602, the Chemical Security Act of 2001, introduced by Jon Corzine (D-NJ), proposed regulations to the chemical industry to protect against acts of terrorism. However, the bill included no appropriations. Further, while proposed legislation and amendments include provisions for dealing with accidental release, early warning and environmental issues, anti-terrorist security measures are nearly lost in the dialog.
Other legislative attempts that have been supported by the majority of industry groups include a bill introduced by Senator James Inhofe (R-OK), which has stalled due to partisan differences and amendments.
The Department of Homeland Security has funded programs ranging from assisting with the purchase of night goggles for local law enforcement to helping with police overtime and additional personnel. The department offers grants to states and communities to reduce the threat of terrorism. However, until such grants are available for community-based policing for the chemical industry, producers and local government should engage in cooperative efforts to accomplish this goal. Training law enforcement and granting access to previously off-limits areas are the first steps.
Ken Michaelis suggested, "To successfully implement such an idea, it would take many of us agreeing on the concept and supporting local governments to make it feasible. Local law enforcement has my utmost respect, and I believe they are best equipped to bring armed, trained, impartial, preventative and timely emergency response to the people of their communities by becoming partners with industry in protecting our neighborhoods."
Dick Zunkel is a frequent contributing writer and technical editor for ST&D.