Thursday, March 10, 2011

HAZCOM and Security Response

Readers of this blog might recall that I have been working with an outfit called LEAPS.TV on a training program on CFATS for law enforcement personnel, based upon the fact that most facilities will be using local police agencies to provide tactical response to any terrorist attack on their facility. That free on-line training program has been running on their website for a while now and I expect that I’ll be writing about the response to that program in a future blog.

In developing that program I’ve had the chance to talk with some representatives from a variety of law enforcement agencies. One of the things that has come up time and again in those talks has been the surprise at some of the safety issues that I described that these agencies would need to consider in planning for any tactical operations at their local chemical facilities.

People that work at chemical facilities receive training on both generic and specific chemical hazards that they deal with on a daily basis. OSHA hazard communications (HAZCOM) regulations provide minimum standards for such training. In addition there is typically a near constant discussion about chemical safety among employees at most chemical facilities. We can discuss whether or not this training (formal and informal) is providing adequate safety levels, but it is at least taking place.

Unfortunately, there is no requirement for such training for emergency personnel that will have to respond to a safety or security event at such facilities. Most chemical facilities (certainly not all) are required to provide material safety data sheets for their hazardous chemicals to local fire fighters and emergency planning agencies, but that falls far short of providing HAZCOM training and does not address chemical safety training.

Law enforcement agencies are not included in this EPA requirement because those rules were designed for those dealing with accidental chemical releases not security related releases. Even this has proven to be inadequate in many accidents when police have been injured by chemical exposures when operating near chemical facilities during chemical release incidents.

Asking local police to respond to a terrorist attack at a chemical facility with out giving them advance training on the chemical and physical hazards associated with that facility strikes me as being criminally negligent. Not only are they being asked to put themselves at risk, but actions they take out of ignorance could place entire communities at risk.

It was nice to see that two (S 473 and HR 916) of the four current CFATS reauthorization bills do address some training requirement. Unfortunately neither of these bills directly addresses the emergency response HAZCOM training issue and both only provide for voluntary training programs. This is an issue that Congress needs to address in their consideration of any CFATS reauthorizing legislation that comes up during this session.

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