“An active shooter is an individual actively engaged in killing or attempting to kill persons in a confined and populated area. In most cases, active shooters use firearms with no apparent pattern or method to select their victims.”We have seen these types of incidents take place at all sorts of facilities; it is only a matter of time before one happens at a chemical facility. This guidance document was developed based upon a number of table top exercises that DHS held with a variety of chemical facilities across the nation. The guidance in the document is written with a broad brush reflecting the reality that each facility is going to have their unique situation that will have to be dealt with in their emergency response plan. The booklet does briefly address arguably the most important part of an active shooter plan; how to recognize the warning signs of an employee on the edge of breaking and becoming an active shooter. The ‘red flags’ that it identifies may be predictors of potential for violent behavior, but I don’t think that it adequately addresses the fact the vast majority of people exhibiting these factors never take up a gun to threaten much less shoot their co-workers. Over reacting to these indicators could do serious damage to the morale and cohesiveness of the facility work force. Pre-Planning The one of the strong points in this document is the section dealing with pre-planning guidance. The pre-planning section provides a list of things that the facility management needs to do during the development of their plan. The actions listed are not targeted specifically at chemical facilities; they could be used by just about any civilian facility in developing an active shooter plan. For example, the document advises:
“Invite all emergency services responders to tour your site and provide details about the facility that will help responders to adjust their protocols if necessary.”This is certainly good advice for any facility, but it fails to address many of the special situations involved at chemical facilities. I would have liked to see this statement followed by a list of some of those chemical specific situations, including:
HAZMAT storage locations; Locations where flammable atmospheres might be expected; Listing of hazardous chemicals on site, to include MSDS; and Chemical release evacuation procedures.If the active shooter remains in the office areas of the facility there would be no problems for the responders. As soon as the shooter moves to production or storage areas, the law enforcement personnel are going to have to take many more factors into account in their shoot/no shoot decision making process. Without significant prior training, they are going to make poor and potentially catastrophic decisions. Incident Response The section on the planning for the actual response to an active shooter incident switches to a slightly different format. It poses a number of questions that management needs to take into consideration in planning what should take place during an incident. Once again, most of these questions would apply to any facility. Three very good questions, however, target chemical specific situations. These are
“Are there any safety concerns as emergency responders enter process areas?” “What are the personnel procedures for safely securing operations that include hazardous materials?” “At what point do site emergency procedures dictate process shutdown?”This section also provides a brief listing of the ways that a relatively ‘simple’ active shooter scenario can get really complicated. In addition to the typical problems potentially found in any facility (hostages, explosive devices, etc) this section identifies a “chemical release” as a potentially complicating situation. Someone is going to have to start thinking about how an active shooter could complicate the chemical release emergency response plan. Incident Recovery This guide continues the question format into the section on what needs to be done after the active shooter is killed/detained. I am really happy to see that this important part of the situation is addressed. Most planning operations fail to take into account what happens after the active portion of the operation is completed. There is a nice balance in the questions posed in this section. Safety, security, and business continuity are all at least briefly addressed. Two questions have special significance for chemical facilities:
“Who will make re-entry decisions?” “Who will provide safety and security debriefings?”Again, I would have liked to see more chemical facility specific details provided for both of these questions. Re-entry decisions will require taking into account legal (crime scene), psychological (clean up of blood etc), and chemical safety issues. A number of people will provide input on the decision, but who will have the responsibility and training to make the decision needs to be identified in advance. And don’t forget to take into account that the selected individual may be in the hospital or the morgue; identify multiple backups. The safety debriefing is particularly important at a chemical facility. Every attempt must be made to identify all shots fired in, around or at process areas of the facility. Then every bullet must be traced to see what equipment may have been damaged before start up begins. Actual shutdown activities need to be reviewed to see what was done and what wasn’t; inadequate shut down procedures could have catastrophic consequences if not identified and addressed in a timely manner. Employee Response There is a section of this guide that specifically addresses individual employees responses in an active shooter incidet. It addresses issues that need to be considered prior to an active shooter incident occurring, actions to take initially during an incident and, very importantly, how to respond to law enforcement personnel entering the facility during an incident. The guidance is good for general facility type response but, once again, does not adequately address the complicating factors that are found in chemical facilities. Tabletop Exercises The final section of the guidance document very briefly addresses the importance of conducting tabletop exercises of the facility’s emergency response plan for active shooters. The opening paragraph of this short section is one of the best descriptions of the importance of exercises in general.
“Proactive chemical facility managers and emergency responders use facilitated tabletop exercises to simulate security incidents or natural disasters and engage in interactive discussions on how to prepare for, respond to, and recover from such events. Interactive tabletop exercises allow participants to test critical thinking skills, learn how the public and private sectors will react to a security breach, and identify areas for improvement.”DHS, through the Chemical Sector office, has worked with state chemical industry councils to “develop the voluntary Security Seminar and Exercise Series”. These facilitated exercises can help facilities and local responders work out the bugs in their emergency response plans before they actually have to be implemented. The DHS Chemical Sector-Specific Agency can be contacted for further information about these exercises. Recommendation When I requested this booklet from DHS I was hoping to see a guide on how to prepare for an active shooter terrorist attack where a team of terrorists attacks a facility with small arms and limited size explosive devices. While I was slightly disappointed that it didn’t address that scenario, this document is probably more valuable since the probability of the type of disgruntled ex-employee active shooter described in the guidance is a much higher probability event. High-risk chemical facilities will have many counter-terrorist security measures that reduce the chance of an active shooter incident, but the chance of a gun toting employee getting past those security measures can be way too high to prevent these types of attacks. An emergency response plan for these situations needs to be developed for all chemical facilities regardless of their risk for a terrorist attack. While I have some concerns that there is not enough information in this guide specifically tailored to chemical facilities, I think that this guide is well worth the time and energy needed to read and consider the implications for your facility. The price (did I mention that it is free?) obviously can’t be beat. And there is an awful lot of valuable information in the 16 page booklet. I fully recommend that every chemical facility manager should have a marked-up, well read copy of this booklet on his desk. Contact the DHS Chemical Sector-Specific Agency today to get your copy.