“(R)equire the facility to arm its security personnel, “(P)ut security/facility personnel and the general public at risk, “(C)reate potential criminal and civil liabilities for the individuals engaged in the such actions as well as the facility itself, and “(F)orce the facility to assume the roles and responsibilities performed by public law enforcement agencies or the military.”Shell’s opposition is not unique. Their comments echoed those of many industry commentors that had posted comments to the Draft Guidance. DHS has heard the same objections in many venues. Interestingly, many water treatment facilities that use large amounts of Chlorine adopted the use of armed guards without the Federal government telling them to do so; they are not covered by comprehensive security regulations. Limited Number of Facilities First off, there is no reason for every high-risk chemical facility to have an armed security force capable of interdicting an armed assault. Only those facilities that would experience an immediate adverse impact on the surrounding community from a successful terrorist attack need to consider having such a force. High-risk facilities that only possess theft/diversion COI will probably not need to have such a robust security force. The risk at those facilities is that terrorists would take those chemicals to some other site and then convert them to weapons. Interdiction by law enforcement at any time before that conversion takes place would be adequate. Security forces at these facilities need to concentrate on detecting and reporting, not interdicting. Facilities that are deemed to be high-risk facilities because of their possession of release COI will almost certainly require robust security forces capable of interdicting a terrorist attack force. For Tier 1 facilities the immediate effects of a successful attack on such a facility on the surrounding community would be catastrophic. For lower-tiered release-COI facilities there may be adequate time to evacuate innocent civilians before the effects of the release reach them. In those cases the ability to identify and report such an attack is may more important than interdicting the attackers. Consequences The problem is that there really isn’t a viable alternative to having an armed security force for the high-risk, immediate consequence facility. Barriers and surveillance by themselves will not slow a well trained force enough to allow for an off-site police or military response before the terrorists reach critical areas of the facility. Once the terrorists gain access to the critical areas of the facility it will be too late. The collateral damage from an armed response to re-take the facility will be as bad as a successful terrorist attack. No response will allow the attackers the time to prepare their demolitions perfectly for the maximum effect. Negotiating with the terrorists will, as shown by the Mumbai attacks, just allow for more press coverage, and more killing. One final consequence issue, one of little interest to the potential victims of the successful attack on a high-risk chemical facility, but one management needs to consider. At the inevitable Congressional hearing reviewing why there was a successful attack on XYZ Chemical Facility that resulted in thousands of deaths in the surrounding community, how is the CEO of the owning company going to explain that he did not want armed guards at his facility. That he thought that armed guards were too dangerous to have on site. That he thought that armed guards were too expensive. I certainly would not want to explain that and hear it repeated hundreds of time on prime time news for years to come.
Friday, January 16, 2009
Purpose of Security Forces
Earlier this week I noted that Shell Oil Company objected to the requirement that facilities be able to interdict an armed attack on the facility. I didn’t delve into the consequences of that comment in that blog. I knew that an appropriate discussion would add too many words to that already lengthy blog. Besides, the Shell comments were not unique in this regard; they were representative of a number of commentors. That discussion deserved a blog of its own. Actually, I have discussed the issues surrounding facility security forces on a number of occasions. At the request of some people in DHS I did a series of blogs on these issues. This link is to the last posting in the series; that blog contains links to all of the other blogs in the series. Today I would like to look at the consequences of industry opposition to a robust security force capable of interdicting armed intrusions at high-risk chemical facilties. Shell Opposition Shell stated in their comments to the Draft RBPS Guidance Document that they felt that “interdiction of an armed attack force by a private security force is an action of such an extreme nature that it is not realistic nor is it an appropriate role for private industry to assume”. They list four reasons for their opposition; such ability would: