Security of Hazardous Materials

Many violent individuals can make effective use of modern technology to devise extremely dangerous devices from the materials under your control.

IN 1941, the people of the United States believed they were safe behind a two-ocean barrier. They were proved wrong by the attack on Pearl Harbor. That attack was conducted by the armed forces of a hostile nation. In 2001, the people of the United States believed that, as the world's only superpower, they were safe from attack. Again, they were wrong.

On 9/11/01, a hostile ideology attacked the United States by converting jet airliners into weapons of mass destruction. Unfortunately, the conversion of non-weapons material into weapons by terrorists had been demonstrated by the Oklahoma City bombing. It had been an item of concern but had become a priority for businesses using hazardous materials. Providing for the security of hazmats is an area not usually associated with the duties of hazardous materials management, but the events of Sept. 11, 2001, must change that perception.

With terrorism and workplace violence increasing, those responsible for the management of hazardous materials must apply security as one of the methods to ensure the safety of workers, the public, and the environment. Often, this person is the environmental health and safety manager, but because many titles may apply, the term hazardous material manager will used from this point on. The intent of this article is not to transform a hazardous material manager into a security specialist. The objective is to bring to the attention of hazardous material managers that these materials require security in addition to confinement, spill plans, and process controls. The following paragraphs offer a brief synopsis on the threats that have made security plans necessary, some security planning concept information, and where additional information or expertise may be obtained.

Threats to Your Facility
Why must the hazardous material manager be concerned with the security of materials under their control? In addition to what happened on 9/11, a number of issues over the past two decades have attracted radical elements that have formed an extremist militant core prepared to resort to threats, violence, and destruction of property to achieve their ends. These causes can be religious, environmental, animal rights, or political. Additionally there is a real threat from the actions of disgruntled or disturbed employees at your facility.

The threat to your facility can come from one of the following groups:
1. Criminals
2. Disaffected persons (insider threat)
3. Paramilitary forces (militias, hate groups)
4. Protesters (political, environmental, animal rights)
5. Terrorists (political, religious, single-issue such as environment or animal rights)

For the most part, legitimate organizations disown the violent fringe. However, some of these organizations actively support militants or assist them tacitly by failing to condemn extremist activities. The various issues that have generated this threat will continue to attract individuals ready to use extremist tactics for selfish or believed-to-be-altruistic reasons. Many of these individuals are highly competent and capable of making effective use of modern technology to devise extremely dangerous devices from the materials under your control.

As a hazardous material manager, you must understand that the hazmats under your control may be used by terrorists to create weapons of mass destruction. It is important to note that the first poison gas used in warfare was chlorine gas, and that fertilizer mixed with fuel oil became a devastating explosive device that destroyed the Murrah Federal Building in Oklahoma City. More recently, in 2002 a truck used to transport natural gas was turned into a bomb in Tunisia that destroyed a synagogue and killed 17 people. All of these materials and many others that can be converted into weapons are found in large quantities throughout the United States.

In dealing with this reality, it is imperative for those responsible for hazardous materials to implement a security program. Security programs are normally divided into physical security and personnel security. Physical security is those measures implemented to prevent hazardous material from damage or diversion. Personnel security is those measures used to prevent unauthorized personnel from having access to hazardous materials and to ensure those granted access are people who should be granted access to hazardous materials.

Security is often a facility manager's program. Most often in the past, it focused on loss prevention. Many large facilities have a security program in place with personnel assigned to this task full time. In many other operations security is assigned to someone as an additional duty, although frequently this person has no experience in security. When loss prevention was the key issue, responsibility for security could be found assigned to Human Resources, Plant Operations, or Environmental Health & Safety when the operation did not have a dedicated person.

If your facility contains large enough quantities of hazardous material that requires an emergency plan under the EPA's Risk Management Program or OSHA's Process Safety Management, then preventing malevolent acts from releasing that material needs to be addressed urgently. However if your facility does not fall within the requirements of these programs, you should evaluate the potential from an unmitigated release of hazardous material from your facility and decide what level of hazard your facility poses.

Remember, these programs do not cover all hazardous materials. Another evaluation is if your facility has enough hazardous material to require the submittal of a Tier II report each year under the Emergency Planning Community Right-to-Know Act (EPCRA, found in 40 CFR Part 355). If you have enough to submit a Tier II, consider how the material may be diverted to another purpose and what hazard it poses.

Components of Effective Security
To be effective, security must be integrated into the hazardous material management plan. An effective physical security program uses an approach that is methodical, deliberate, and ongoing. Managers need to periodically review the security plan and be prepared to adjust their programs to the changing threat. Part of that review is identifying hazardous materials and their properties.

If your facility has a security program, then as the hazardous material manager it is important to coordinate with the security manager to ensure all areas essential to maintain control of hazmats are identified and protected along with the hazardous material. This is similar to the emergency planning process. An excellent guide is a document developed by the American Chemistry Council, the Synthetic Organic Chemical Manufacturers Association, and The Chlorine Institute, Inc. (Site Security Guidelines for U.S. Chemical Industry). This guide is comprehensive and provides some excellent information; contact ACC by phone at 703-741-5000, fax 703-741-6000, or visit www.americanchemistry.com.

In order to determine what must be done, conduct a review of the hazmats present and identify which security measures are in place. Many of the procedures and controls used to prevent theft of goods and materials from the facility also prevent internal and external threats from having easy access to your hazardous material and their controls. The goal is to prevent easy access to large quantities of hazardous materials or significant quantities of extremely hazardous materials and their associated controls. Those who wish to gain control of hazardous materials may want to steal them and transport them to a high-value target or release them at your facility.

The security planning process uses the following steps and is similar to a risk management program:
1. Assessing the threat
2. Assigning specific physical-security duties
3. Conducting security planning (Personnel and Physical)
4. Conducting risk analysis
5. Identifying essential or vulnerable areas (EVAs)
6. Designating restricted areas
7. Coordinating security efforts
8. Establishing physical security responsibilities for the operating staff
9. Employing physical and procedural security measures
10. Conducting inspections and surveys
The goal of the security plan should be to implement measures that deter, detect, delay, or defeat the threat. Deterrence can be improved by using highly visible measures and randomness. This is cost-efficient and complicates the threatening person or group's planning.

Personnel Security
Personnel security is the methodology to determine whether an employee is to be granted access to hazardous material and how to verify that an individual has been granted access. The basic components of a personnel security program are:
1. Determine which duty positions should be granted access,
2. Conduct background checks to verify legal status and criminal record,
3. Use psychological screening to determine stability, and
4. Use identity badges with photos and access authorization.
This program has been in place for more than two decades at nuclear power plants. Remember, a personnel security program cannot protect from an insider threat; more than once, a trusted employee or soldier has betrayed the trust placed in him or her.

Physical Security
Physical security is those measures preventing or controlling access to the hazardous materials. The physical security plan must have reasonable and affordable protective measures.

Security measures should be integrated and layered by using a combination of fences, lights, electronic security systems, guards, and reaction forces. For extremely hazardous substances, some facilities use the "two man" rule--in other words, two persons are required to be present whenever access to hazardous materials or a control system that could release them is necessary. Relying on local law enforcement as the primary means of security should be a measure of last resort, with alternatives considered when possible.

A critical point to consider is the ability of local law enforcement to respond in less than 15 minutes. Associated costs in implementing should be in proportion to the value or criticality of the property being protected and the existing level of risk.

Getting Help from Local Sources
As stated in the beginning of this article, the information here will not make you a security specialist. Obtaining this expertise depends on the facility budget. The best option is to have a company that specializes in security assess your site and develop a plan. Many police departments and/or sheriffs' departments are willing to assist in assessing security needs. If your company is the member of a Local Emergency Planning Committee, the members may be able to pool resources.

Other sources of information are the Web sites maintained by the Department of Energy (www.energy.gov) or the Nuclear Regulatory Commission (www.nrc.gov), which have developed detailed procedures and guidance. Another option is to contact local National Guard or Reserve units that have security missions, such as Military Police or Air Security Police. These units may be willing to conduct a security assessment and provide recommendations as part of their training.

The issue of security needs to be addressed in your management of hazardous material regardless of the means you employ. The threat is very real. The results of inattention can be deadly. The challenge is to develop and implement a cost-effective security plan as part of the hazardous material management program.

This article originally appeared in the April 2003 issue of Occupational Health & Safety.

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