Wednesday, May 21, 2008

Reader Questions 5-20-08

I got an email from a reader yesterday who had some questions about Chemical Facility Security. Since they were not posted to the blog, I will not reveal much information about the reader except that he is in the security industry and is looking to expand his product line sales into the chemical facility market. Two of his questions deserve a more general discussion than I gave him in my email reply.

  • Do you see the chemical industry increasing its investment in perimeter security in response to CFATA? The requirements of the act seem very vague.
  • What's the best way to reach the people in charge of security in this industry?

Perimeter Security Investment

As I told the reader in my email, most chemical facilities have a 6’ chain-link fence for perimeter security; some topped with an 18" barbed wire outrigger. Few of those fences are patrolled or observed. In short, they are more in the way of perimeter markers than perimeter security. The sad thing is that most facility managers honestly think that these fences provide adequate security. I’m not faulting them; chemical engineering curriculums at most universities do not include any classes in facility security.

When site security plans are submitted, I’m sure that DHS will find fault with perimeter security measures {6 CFR Section 27.230(a)(1)} that do not keep the perimeter fence under constant surveillance. Obvious observation of the perimeter is a key part of deterring an attack; constant observation is the key to detecting an attack.

There are a wide variety of techniques for keeping the perimeter under observation. Old fashioned guard patrols are low on capitol costs, but they certainly drive up the payroll, especially if there are enough personnel to keep the fence under constant observation. Closed circuit television systems are getting to be relatively inexpensive, but the monitors require observation. There are a wide range of motion detector systems that provide an intrusion alarm, but they require a response team to check out the inevitable false alarms.

It takes someone with security training to analyze the particular situation at a facility and to then recommend an appropriate combination of technology and personnel that will provide an optimum security solution. The one thing that is certain is that an unwatched fence line will not be adequate perimeter security for a high-risk chemical facility. So yes, for the industry, there will be an increase in spending on perimeter security.

People in Charge of Security

As I told my reader in my reply email, only the largest chemical companies have trained security professionals on staff. For the vast majority of facilities the security management job at the facility level has been given to someone as an additional job. Most often this is given to the EH&S Manager; that is the person with the most experience in dealing with government regulations.

As we get deeper into the CFATS process, it is going to be painfully obvious to most facility managers that the lack of formal security training on the plant staff is going to make compliance very complicated. More and more facilities are going to have to resort to using consultants for advice in how to proceed with Security Vulnerability Assessments and developing Site Security Plans.

Security equipment suppliers are going to have to decide how they want their advertising dollars spent. Will they target the people writing the checks or will they target the people making the recommendations? Most will target both sides of the deal.

Limits to Spending

One thing that is going to make corporate decision makers slow to make any decisions on capital or personnel expenditures on facility security is the uncertain regulatory situation. CFATS is the current regulation that everyone is attempting to deal with. Unfortunately, that expires in less than 18 months. The way that the implementation of that regulation is preceding no one will be paying any fines for failing to comply with those regulations. They will expire first.

The comprehensive legislation that will replace CFATS, Chemical Facility Anti-terrorism Act of 2008, has yet to have had any hearings in the second committee given responsibility for review in the House of Representatives. The bill that would give continuing authority for CFATS is waiting for a sub-committee chairman to be appointed before it can start to be reviewed (see: "Alternative to HR 5577").

In short, why should any chemical facility spend any serious money on additional security measures when the regulatory landscape is so flaky? Most facilities will continue with their current security plans until Congress gets its collective act together and gives industry some solid regulations to implement.

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