Critical Infrastructure Analysis Of The Chemical Sector Business Essay

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The chemical sector has long been one of the most important assets to the American way of life. It is comprised of facilities which use, store, manufacture, or process and distribute chemicals (Suburban Emergency Management Project, 2008). It is a vital component to the United States economy and is "currently the nation's top exporter accounting for 10 cents out of every dollar" (John, Sullivant, 2007, p. 380). The chemical industry also employs approximately 1 million people and earns the United States up to $ 700 billion dollars in revenue per year (Sullivant, 2007, p. 380) As one of the countries "most innovative" sectors of critical national infrastructure, "it earns one out of every seven patents issued in the U.S." (Sullivant, 2006, p. 380). This kind of ingenuity is what enables the United States to be a top leader in international chemical production (Sullivant, 2006, p. 380).

The Chemical sector is incorporated literally into every aspect of the consumer industry, whether it is basic inorganic chemicals and fertilizers, petrochemicals, fossil fuels, industrial gases, pharmaceuticals, special chemicals and other consumer products (Sullivant, 2006, p. 380). In order to understand the infrastructure of the chemical sector a number factors must be examined: hazard level of the chemical being produced, location of chemical production, location of storage and use, and the location of chemical distribution. The chemical sector "supply chain" must also be evaluated.

Inorganic chemicals and fertilizers are "produced and purchased in large volumes as commodity chemicals and may rely on natural gas or crude oil as a feedstock" (BSCT, 2006, p. 20). They are generally not toxic; however, there are small assortments of chemicals which are corrosive (e.g. acids) and toxic (e.g.chlorine) and are harmful to humans (BCST, 2006). These chemicals are produced, stored, and distributed mainly in the Midwest and southern states (BCST, 2006).

Petrochemicals are considered to be very toxic and highly flammable and can "form explosive vapor clouds upon release" (BCST, 2006, p. 20). Many petrochemical and fossil fuel manufacturing facilities "are located along the Texas and Louisiana Gulf Coast, but significant installations are also found in the industrial areas of the East Coast, Midwest, and California" (BSCT, 2006, p. 20). That being said the location of storage and usage of these chemicals are nationwide (BSCT, 2006).

Industrial gases are produced and used for a number of things (e.g. electronics and food industries etc.) (BCST, 2006). Industrial gases are only hazardous depending "on the chemical under consideration and the quantity in which it is being used" (BSCT, 2006, p. 21). Nitrogen is an example of a hazardous chemical because it is an "asphyxiant that displaces oxygen" (BSCT, 2006, p. 21). Most industrial gases are produced, stored, and distributed along the Gulf Coast (BSCT, 2006).

Pharmaceutical chemicals include both prescription and non prescription drugs, as well as diagnostic substances, vaccines, vitamins, and preparations for both human and veterinary uses" (BSCT, 2006, p. 22). When evaluating the potential hazards of pharmaceutical chemicals, the production processes "can entail the generation of combustible dust as well as use of toxic industrial chemicals in relatively small quantities" (BSCT, 2006, p. 22).The production and distribution of pharmaceutical chemicals takes place all over the United States (BSCT, 2006).

Chemicals used for other consumer products include but are not limited to "soaps, detergents, bleaches, paints, solvents, glues, toothpaste, shampoos, cosmetics, skin care products, perfumes, and colognes intended for direct consumer use" (BSCT, 2006, p. 23). Chemicals used in consumer products "may be toxic, corrosive, or flammable; many have quick skin-bonding characteristics; or their packaging may be pressurized" (BSCT, 2006, p. 23). These chemicals are produced throughout the United States and "are used widely and are commonly found in households and retail outlets nationwide" (BSCT, 2006, p. 23).

According to the Board on Chemical Sciences and Technology (2006) the chemical sectors "supply chain" can be broken down into a series of "nodes, links, and pathways" (p. 25). A facility that produce's, stores or consumes the chemical is categorized as a node (BSCT, 2006, p. 25). The link is characterized as the mode of transportation for the chemical "(e.g. road, rail, barge, or pipeline)" (BSCT, 2006, p. 25). The BSCT (2006) characterizes the "pathway as the sequence of nodes and links by which the chemical is produced, transported, and transformed from its initial source to its ultimate consumer" (p. 25). The nodes, links, and pathways are a critical component to the infrastructure of the chemical sector because if one is disrupted then a domino effect is initiated and all other components are affected.

Vulnerabilities

Despite being the top dog, the chemical sector still remains one of the most vulnerable sectors of critical national infrastructure in the United States. After the 9/11 attacks there was a need for all aspects of the chemical sector to be re-examined. Thousands of chemical facilities were being re-evaluated to determine vulnerabilities in their security protocols. As of today, there are no regulations which mandate chemical facilities to conduct vulnerability assessments or take the appropriate security measures to protect their infrastructures and assets from an attack. However, "congress enacted legislation that requires the Department of Homeland Security (DHS) to analyze vulnerabilities and suggest security enhancements for "critical infrastructure" (Schierow, 2006, p. 2). Additionally, it is required that chemical facilities which "supply drinking water or are located in ports" conduct vulnerability assessments to determine critical infrastructure resilience (Schierow, 2006, p. 2).

Prior to 9/11 a study was conducted by the Agency for Toxic Substances and Disease Registry (ATSDR) which concluded that chemical facility security was below standard (Schierow, 2004). Likewise, interviews conducted by researchers determined that chemical facility security personnel were not confident in their ability to "deter sabotage by employees" (Schierow, 2004, p. 14). What is even more alarming is not one of the security personnel thought it would be necessary to conduct "simple background checks for key employees such as chemical process operators" (Schierow, 2004, p. 14). As stated by Ian Siperco (2006) "chemical facilities continue to suffer from serious deficiencies in facility security and basic vulnerability analyses despite having been universally assigned a high-risk designation by legislators" (p. 5). The chemical sector has also been dubbed by many in the security field as "the single greatest danger of a potential terrorist attack in our country today" (Dana Shea, 2006, p. 4).

There are several vulnerabilities which have been discovered in the chemical sector. The infrastructure of the chemical sector requires "substantial facility and equipment investment" (BCST, 2006, p. 24). Likewise a number of chemical manufacturers require special equipment; if for some reason the equipment was damaged or destroyed it could not be readily replaced (BCST, 2006, p. 24). If it is chemical facility which specializes in key chemical products and is a single supplier then this would have a significant impact on not only the chemical supply chain but on the consumer industry.

The lack of security at chemical manufacturing sites is potentially the most important vulnerability to the chemical sector. As noted earlier, there seems to be a lackadaisical attitude by chemical facilities and their security managers in regards to site security. This could be due to a number of reasons. Since a majority of the chemical sector is privately owned many chemical manufacturing facilities will not make improvements to their facilities because of the costs they would incur if they were to do so. The chemical industry has not been faced with an attack on the chemical sector infrastructure therefore; they have no reason to establish new security measures (Stephen Flynn & Daniel Prieto, 2006, p. 18). Additionally, there seems to be a general consensus among chemical manufacturers that if they were to invest in upgrading security protocols at their facilities they would be placed at a disadvantage both competitively and financially (Flynn & Prieto, 2006).

The chemical sector is also vulnerable due to the geographic location of many chemical plants. Although chemical facilities are spread out all over the United States, a majority of chemical plants are clustered together (e.g. petrochemicals in the Gulf Coast) making them vulnerable to a large scale terrorist attack (BSCT, 2006, p. 25). Likewise, many chemical facilities are located in urban areas which are heavily populated (Flynn & Prieto, 2006). An attack in one of these large urban areas would result in mass casualties and millions if not billions in infrastructure damage.

Threats

It is clear that the threat is real, many experts in the intelligence field "fear these facilities are at risk of a potentially catastrophic terrorist attack" (Shea, 2006, p. 4). Thus, it has been classified as being "one of the highest priority critical infrastructure sectors" by the Department of Homeland Security (Shea, 2006, p. 4). To analyze threats toward the chemical sector it involves identifying the sources behind a threat (Paul Baybutt, 2003). Terrorist threats against chemical facilities can be categorized as "direct attacks on facilities or chemicals on site, or efforts to use business contacts, facilties, and materials (e.g. letter head, telephones, computers ect.) to gain access to potentially harm materials" (Schierow, 2004, p. 5). That being said, a terrorist could infiltrate the facility as an employee or they could act from the outside either "alone or in collaboration with others" (Schierow, 2004, p. 5).

Terrorist see chemical facilities as an "attractive target" because they believe that "these facilities themselves can be turned into weapons of mass destruction" (Flynn & Prieto, 2006, p. 28). This realization is alarming, according to Sullivant (2006) "there are some 60,000 facilities that manufacture, use, or store hazardous chemicals in quantities that could potentially put large numbers of Americans at risk of injury or death in the event of a chemical release" (p. 380). Likewise, there are "over 15,000 facilities in various industries produce, use, or store one or more of the identified 140 toxic and flammable chemicals that pose the greatest risk to human health and environment" as stated by the EPA (Sullivant, 2006, p. 380).

One must also consider threats that are not necessarily terrorist related. According to the American Chemistry Council et at. (2001) other threats that need to be addressed include "trespassers committing vandalism or setting fires for fun and accidental disruption of cooling systems for the electronic equipment rooms which control the release of hazardous chemicals" (p. 12). Additionally, it is imperative that security personnel examine the "creation of destructive hazardous conditions through modifications of fail-safe mechanisms or tampering with valves" (ACC, 2001, p. 12).

What has been done to improve chemical sector infrastructure

Since the 9/11 attacks there has been improvements in improving the resilience of the chemical sectors infrastructure. According to Bruce Martin and Jessica Tierney (2005) "the first National Strategy for Homeland Security was issued in July of 2002, which identified the chemical industry as one of the critical infrastructure sector that must be protected" (p. 1). In 2003, The National Strategy for the Physical Protection of Critical Infrastructures and Key Assets was released by the White House (Schierow, 2006, p. 24). This document focuses on the federal governments collaboration with the private sector to secure critical infrastructure (Schierow, 2006, p. 24). Specifically the federal government is aiming to "assure supply to downstream users of chemical products, to protect and assure quality of chemical stockpiles, and to reduce the risks of malicous use of inherently hazardous chemicals" (Schierow, 2006, p. 25). That same year the "President launched Liberty Shield, a surveillance program to provide additional security for potentially threatened facilities in the critical infrastructure" (Schierow, 2006, p. 25). This program focused primarily on the chemical sector (Schierow, 2006).

The most important accomplishment the federal government has made is the "Homeland Security Presidential Directive (HSPD) 7," issued by the President in December of 2003 (Schierow, 2006, p. 26). This directive gives the DHS complete authority over "the security of chemical facilities" and the responsibility of "protecting critical infrastructure for the chemical sector" (Schierow, 2006, p. 26). The DHS is also required by the directive to "conduct or facilitate vulnerability assessments of the chemical sector and encourage risk management strategies to protect against and mitigate the effects of attacks" (Schierow, 2006, p. 26).

In recent years there have been "several states and local agencies that have begun taking steps to strengthen the security of industrial facilities, including chemical plants, within their jurisdictions" (Bruce & Tierney, 2005, p. 10). In New Jersey "the effort to conduct vulnerability assessments and implement security plans at chemical facilities is based heavily on best practices guidance developed by the Chemical Council of New Jersey" (Bruce & Tierney, 2005, p. 11).

The private sectors have also made some efforts to improve the infrastructure of the chemical sector. Shortly after 9/11, the American Chemistry Council, the Chlorine Institute, Inc., and the Synthetic Organic Chemical Manufacturers Associate issued the Site Security Guidelines for the U.S. Chemical Industry (ACC et al., 2001). This guide focuses on the security at chemical plant sites (ACC, 2001). Based on risk assessment this guide will "help managers at individual facilities make decisions on appropriate security measures" (ACC et al., 2001, p. 5). According to ACC et al. (2001) security management in terms of critical infrastructure resilience should consist of: "risk assessment and prevention strategies, periodic assessment of the security plan for physical security, including access control, perimeter protection, intrusion detection, security officers, ongoing testing and maintenance, and backup systems" (p. 6). Additionally, to improve CI resilience it is important to be more cautious during the hiring process of new employees, so as to reduce the risk of an employee sabotaging the facility (ACC et al., 2001).

The ACC approved "a Security Code of Management Practices (the Responsible Care Security Code) in 2002, which is a mandatory program that addresses site, transportation, and cyber security" in chemical facilities (Bruce & Tierney, 2005, p. 5). This program requires chemical companies to "conduct comprehensive security vulnerability assessments of their facilities, implement security enhancements, and obtain independent verification that those enhancements have been made" (Bruce & Tierney, 2005, p. 5).

In April of 2007, "the DHS produced the "Interim Final Rule" which established, among other things, risk-based performance standards for the security of the nation's chemical facilities" (SEMP, 2008). As stated by the DHS the rule "requires covered chemical facilities to prepare Security Vulnerability Assessments (SVAs) that identify facility security vulnerabilities" (SEMP, 2008). It also "requires covered chemical facilities to develop and implement Site Security Plans (SSPs) that identify measures that satisfy the identified risk-based performance standards" (SEMP, 2008). Likewise, the rule "contains provisions for inspections, audits, and recordkeeping" (SEMP, 2008). This rule also protects "information that constitutes Chemical-terrorism Vulnerability Information, and provides the DHS with "authority to compel compliance through the issuance of orders, including orders assessing civil penalties and orders to cease operations" (SEMP, 2008).

In 2008, "the chemical industry worked with the Department of Homeland Security (DHS), as well as state and local governments, to identify and correct the vulnerabilities in their own infrastructure" (Toffler Associates, 2008, p. 12). According to Toffler Associates (2008) the end result "enabled DHS to provide the chemical industry with more information on how different compounds could be used elsewhere" (p. 12). Likewise, "4 levels of certification based on the type of facility and level of risk so that businesses with lower risk factors are not over-regulated" were developed (Toffler Associates, 2008, p. 12). Additionally, assessment "enabled each chemical plant to design its own protection plan" (Toffler Associates, 2008, p. 12). Furthermore, "with each unique plan, it becomes increasingly difficult for an enemy to predict security measures when making their own plans" (Toffler Associates, 2008, p. 12).

Just recently the Occupation Safety and Health Organization (OHSA) "launched its National Emphasis Program (NEP) for the chemical sector with an initial focus on facilities in New England, the Midwest, and the Pacific Northwest" (Kara Sissell, 2010, p. 1). According to Sissell (2010), "OSHA will focus on inspecting facilities that use chlorine and ammonia" (p. 1). The goal of this program is to ensure that facilities are following "OSHA's process safety management standards" (Sissell, 2010, p. 1).

Description of case study: explosion at chemical plant

Air Gas East is a chemical facility located in Salem, New Hampshire which specializes in the production of inorganic gases, specifically chlorine gas. Chlorine gas is very dangerous and people can be exposed by inhaling the poisonous gas and through skin and eye contact. On the morning of August 03, 2010 at approximately 8:23 a.m. an explosion occurred at the Air Gas East chemical facility. The explosion took place in building C-1, one of the structures which house the tanks of liquid chlorine. The warning bell only sounded for about 10 seconds leaving employees no time to evacuate. At approximately 8:32 a.m., there was another explosion in building C-4 which also houses large quantities of chlorine liquid. The initial explosion killed 92 employees and injured 103. The second explosion resulted in 209 fatalities and 321 injured. Due to the high volume of employee casualties the facility is unable to effectively execute their emergency response plan.

Once chlorine is depressurized the liquid quickly transforms to gas. That morning there had been wind gusts up to 15 miles per hour, the gas quickly spread to nearby communities within minutes of the explosion. There was not enough time to warn those who live in the areas surrounding the plant. Approximately 2162 people in nearby communities affected by the explosion. There are 682 fatalities and 1480 injured. Local and state authorities are the first to respond to the scene; however they are not properly equipped to handle such a large scale incident…

After an investigation by the Department of Homeland Security and the American Chemistry Council it was determined that both explosions were the act of a terrorist. Witness statements taken from two security guards that day described a white utility van with two men claiming to be electricians entered the premises of the chemical facility. Both men displayed badges with what appeared to be "legitimate" credentials. The men were given access to the chemical facility. The investigation also revealed that one of the system control rooms which monitor surveillance for all the chlorine storage facilities had been sabotaged prior to the explosions.

Explanation

To determine what went wrong in this situation, several factors must be examined. What kind of security check did the security guards conduct when allowing the two men access to a highly dangerous chemical facility? Were the two men being monitored either by a guard present or through video surveillance? Why were they not approached by security personnel prior to entering the system control room? How did they manage to plant explosives in two of the four chlorine storage facilities without being seen? It is clear that the security protocols at Air Gas East are lax. If these issues were addressed in an effective and efficient manner than it would greatly improve the resilience of this chemical facility.

Analysis

The chemical facilities security personnel should have had more prudent security protocols regarding those who are allowed access to the facility. If an outside individual(s) are there to conduct maintenance on the facility then there needs to be preliminary background checks conducted on each person who is attempting to gain access to the facility. This should be done at least two weeks in advance. The security guards at the front gate are the chemical facilities first line of defense to intruders.

The security guards responsible for the facilities interior should have been more vigilant about where the two men were going. If they were "really" there to conduct maintenance in the facility then they should have been escorted to the appropriate location. Their activities should have been monitored by both video surveillance and a security guard throughout the duration of their visit.

Recommendations

To effectively mitigate the consequences which resulted in this disaster one can implement one of three approaches: "reduce vulnerability by increase security, reduce consequences through detection and response, and reduce vulnerability and consequence through inherently safer technologies" (BCST, 2006, p. 50). The facilities real time surveillance systems must be enhanced (BCST, 2006, p. 50). If this is done then it could "contribute to early detection and response to a chemical event" (BCST, 2006, p. 50). Another approach to improving critical infrastructure resilience would be to improve the designs of the storage tanks to be more resistant to terrorist attacks. There should also be improvements made to the infrastructure of the chemical facility as whole, not only to prevent the hazardous materials from being released but to protect the individuals who operate and work in the facility.

In regards to the federal government's involvement in improving critical infrastructure resilience in the chemical sector, providing tax incentives to the chemical facility would help motivate them to seek out better security measures for their facility (Flynn & Prieto, 2006, p. 38). Additionally, these "federal tax policies could enable companies to invest greater amounts of redundancy and recoverability of such systems, making the American economy and society more resilient to terrorist attacks" (Flynn & Prieto, 2006, p. 39).

From a physical security stand point, the chemical facility could invest in the "pop up bollards" used in roadways (Berger, Spring 2007, p. 7). This would prevent the threat from gaining access to the facilities parking lot. In addition to constructing stronger fences around the perimeter of the facility, planting "tall, thick thorny bushes" are also a good deterrent (Berger, Spring 2007, p. 7). Installing "better locks on doors and relocating sensitive chemical processes within the facility" are also effective in hardening physical security of the chemical facility (Schierow, 2004, p. 30). Establishing "entry alarms and proximity alarms" are also an important countermeasure in trying to deter threats to the facility (Berger, Spring 2007, p. 7). Although these recommendations would improve the critical infrastructure resilience, they are only effective if they are implemented. It is the responsibility of the chemical facility to take these recommendations into consideration and implement them accordingly.

Even though there has been improvements in the collaboration between the private sector and the federal government. There needs to be more of a focus placed on communication efforts. For example, were these two men being surveillanced by federal, state or local authorities prior to the attacks on the chemical facility? Did intelligence indicate that this chemical facility was of interest to the two men? If so, then why wasn't this information shared with the chemical facilities security personnel. This sort of information would have been very helpful in implementing more stringent security measures in the days prior to the attack.

Conclusion

If there was a successful terrorist attack against the chemical sector it would be very detrimental to both the U.S. economy and the lives of the American people. An attack on a major chemical facility could result in the shortage of key materials, such as chemicals used for pharmaceuticals. Likewise, the DHS states that an attack could result in the release of toxic, flammable or explosive materials (Monica Hatcher, 2010). The DHS has aslo determined that any chemical materials or equipment taken from a chemical facility could potentially be "used as weapons or converted to weapons" (Hatcher, 2010). Futhermore, the DHS has made clear that if a chemical facility has been breached the chemical materials could be "sabotaged or contaminated" with other "chemicals that can be deadly if mixed" (Hatcher, 2010). It would result in not only mass casualties, but it would disrupt basic infrastructure and society as whole (Scott Berger, 2007, p. 62).

Although there have been great strides made by both the private sector and the federal government more still needs to be done. As noted earlier, the federal government needs to provide incentives to privately owned chemical facilities to encourage them to improve the security of their infrastructures. Additionally improving communication efforts between both the private sector and the federal government would also improve critical infrastructure resilience. Sharing intelligence could prevent the possibility of a potentially catastrophic disaster.

Because the chemical sector is such an integral part of the United States economy and the American way of life it is important that chemical infrastructures be assessed on a continuous basis. Vulnerability assessments need to be conducted often. By doing so it allows chemical security personnel to develop better approaches to chemical risk management. It also helps improves chemical infrastructure resilience in a number of ways. It is my hope that in the next ten years that the chemical sector will be better federally regulated. Currently there are no federal regulations requiring chemical facilities to conduct these vulnerability assessments. However, I hope that the majority of the private sector will realize the importance of this issue and take into consideration the many recommendations given by both the federal government and other agencies that are invested in the safety and longevity of this sector.

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