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Author:  Jim Kouri
Bio: Jim Kouri
Date:  November 13, 2006
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Are Chemical Plants Still Vulnerable to Terrorist Attacks?

by Jim Kouri, CPP

Terrorist attacks on chemical facilities could severely damage the US economy and public health. About 15,000 facilities produce, use, or store large amounts of chemicals that pose the greatest risk to human health and the environment. While the Environmental Protection Agency formerly had the lead role in federal efforts to ensure chemical facility security, the Department of Homeland Security is now the lead federal agency responsible for coordinating government and private efforts to protect these facilities from terrorist attacks.

In addition to the potential loss of life, a terrorist attack on a chemical facility could also disrupt the local or regional economy or impact other critical infrastructures. The chemical manufacturing industry produces the chemicals used in agriculture, pharmaceuticals, drinking water and wastewater treatment systems, and food processing.

DHS' February 2006 Interim National Infrastructure Protection Plan notes that many critical infrastructure assets are dependent on multiple elements and systems to remain functional. In some cases, a failure in one sector will have a significant impact on the ability of another sector to perform necessary functions. For example, rail transportation of many hazardous materials including chlorine was disrupted in some states following the events of September 11, 2001, because of concern about the potential for an intentional chemical release. This disruption to rail service impacted drinking water facilities that relied on chlorine delivered by rail to purify water.

Experts agree that the nation’s chemical facilities are attractive targets for terrorists. The theft or release of certain chemicals could disrupt the local economy, impact other critical infrastructures that rely on chemicals, or impact the health and safety of millions of Americans.

For example, a 2002 Brookings Institution report ranks an attack on toxic chemical plants behind only biological and atomic attacks in terms of possible fatalities. While several efforts are underway, no one has yet comprehensively assessed security at the nation’s chemical facilities.

The chemical sector includes a variety of facilities and risks. The 15,000 facilities with large amounts of the most dangerous chemicals include chemical manufacturers, water supply facilities, and fertilizer facilities, among others. Some facilities may be at higher risk of a terrorist attack than others because of the specific chemicals on site and their proximity to population centers.

According to 2003 EPA data, 123 US chemical facilities had “worst-case” scenarios where more than one million people could be at risk of exposure to a cloud of toxic gas. While EPA and DHS believe that these scenarios overstate the potential consequences of a chemical release, there are situations here an attack could have potentially more severe consequences.

Only about one-sixth of the 15,000 facilities with large amounts of dangerous chemicals are covered by federal security requirements. About 2,000 community water systems and 238 facilities that are located on waterways and handle “bulk liquid chemicals” must conduct vulnerability assessments, among other things, under the Public Health Security and Bioterrorism Response Act of 2002 and the Maritime Transportation Security Act of 2002, respectively. However, the federal government places requirements on chemical facilities to address accidental releases, which may also reduce the likelihood and mitigate the consequences of terrorist attacks.

A number of federal and industry efforts are underway to enhance chemical facility security. DHS is developing a strategy to protect the chemical sector, identify high-risk facilities, and integrate chemical sector protection efforts into a national program. With no authority to require facilities to improve security, DHS has provided the industry with financial assistance, information, and training, assessed facility vulnerability, and recommended security improvements.

About 1,100 facilities participate in a voluntary industry effort in which they assess vulnerabilities, develop security plans, and undergo a third party verification that the facilities implemented the identified physical security enhancements. The extent to which the remaining facilities are addressing security is unclear and the extent of chemical facilities’ security preparedness is unknown. In this context, a comprehensive national strategy to identify high-risk facilities and require facilities to assess their vulnerabilities, among other actions, would help to ensure that security vulnerabilities at chemical facilities are addressed.

The national strategy states that the private sector bears primary responsibility for protecting their facilities from deliberate acts of terrorism. While federal, state, and local governments work in partnership with the private sector to protect chemical facilities, before September 11, 2001, attention was largely focused on the risks of accidental, rather than intentional, chemical releases. In this regard, the Environmental Protection Agency (EPA) regulates about 15,000 facilities under the Clean Air Act because they produce, use, or store more than certain threshold amounts of specific chemicals that would pose the greatest risk to human health and the environment if accidentally released into the air.

These facilities must take a number of steps, including preparing a risk management plan (RMP), to prevent and prepare for an accidental release and, therefore, are referred to as "RMP" facilities. While EPA initially had the lead responsibility for protecting the chemical infrastructure sector, the Department of Homeland Security is now the lead federal agency. DHS is responsible for coordinating the efforts of government and private institutions to protect critical infrastructure, including the chemical sector, from terrorist attacks.    

Jim Kouri
Chief of Police Magazine (Contributing Editor)

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Biography - Jim Kouri

Jim Kouri, CPP is currently fifth vice-president of the National Association of Chiefs of Police. He's former chief at a New York City housing project in Washington Heights nicknamed "Crack City" by reporters covering the drug war in the 1980s. In addition, he served as director of public safety at a New Jersey university and director of security for a number of organizations. He's also served on the National Drug Task Force and trained police and security officers throughout the country. He writes for many police and crime magazines including Chief of Police, Police Times, The Narc Officer, Campus Law Enforcement Journal, and others. He's appeared as on-air commentator for over 100 TV and radio news and talk shows including Oprah, McLaughlin Report, CNN Headline News, MTV, Fox News, etc. His book Assume The Position is available at Amazon.Com,, and can be ordered at local bookstores. Kouri holds a bachelor of science in criminal justice and master of arts in public administration and he's a board certified protection professional.

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