A recent article in the Dallas Morning News describes a problem that is not unique to Texas, the existence of public schools near chemical facilities. It seems that many zoning codes do not include restrictions on the placement of educational institutions in or near industrial zones.
For obvious reasons, DHS will not disclose the details of their evaluation tool that they use to determine whether or nor a facility is considered to be at high-risk of terrorist attack or how they assign risk levels to those facilities. One thing that must increase the probability of placement on the high-risk list would be a location near large concentrations of children.
While most chemical facilities tend to shy away from involvement in local politics, high-risk chemical facilities have a responsibility to their owners and their community not to increase their risk from a terrorist attack. The placement of a school near the facility will certainly increase the probability that such a facility will attract the attention of terrorist planners.
School Exclusion Zone
Chemical facilities have a readily available tool to help them convince their local zoning and planning organizations of where not to place educational facilities, the RMP*Comp program used by both the EPA and Homeland Defense to calculate the ‘distance of concern’ for toxic chemicals. Drawing a circle around the facility with a radius of the longest ‘distance of concern’ should provide local planners with an ‘exclusion zone’ around the facility. That zone should prevent the construction of schools, daycare facilities, public parks or other facilities that would unnecessarily place children at risk from an accidental or terrorist related chemical release.
If local politicians refuse to use such a tool in their planning process, chemical facilities owe it to themselves and their neighbors to publicly oppose the placement of such child related facilities within their exclusion zone. Facilities need not mention terrorism or the CFATS regulations in this public opposition; mentioning those would probably violate the CVI rules. Simply mentioning the risk of exposure to toxic chemicals in an accidental release should ensure public opposition to such siting.
Existing Schools in the Exclusion Zone
Facilities that already exist in the toxic exclusion zone require special treatment in the facility emergency response plan and site security plan. Schools, daycare facilities and parks should receive special consideration for prompt notification in the event of a release-related incident. They should also be included in the planning for and conducting of emergency response drills.
Chemical facilities might also want to consider the public relations value of donating chemical detection equipment related to their chemical inventory to those child-centered facilities. This would include training school personnel in the proper use of such equipment. The presence of a management representative on site during any incident would also leave a positive impression on the local community.
High-risk chemical facilities must consider the area surrounding their facility when planning for either terrorist or accidental related chemical releases. Keeping their exclusion zone free of concentrations of children should be an active part of their planning.