Tuesday, January 22, 2019

CFATS and Gun Shot Detection Systems

I got an interesting question from a reader yesterday. I whipped out a quick reply that I still standby, but I thought that it might need some additional discussion.

Question and Response

The original question was:

“Is there a requirement for chemical plants to have gunshot detection/notification? Esp after Metcalf incident, I would think.”

My initial reply was:

“The CFATS program certainly does not include such a requirement. I would not think that this would be cost effective for most manned facilities unless they were in a high crime area.”

CFATS Requirement?

First off, there are very few ‘security requirements’ under the Chemical Facility Anti-Terrorism Standards (CFATS) program. The program was crafted with the idea that each facility is unique and would have to design their security program to fit their unique character while fulfilling 12 operationally defined ‘Risk-Based Performance Standards’ (RBPS). Those standards are outlined at 6 CFR 27.230(a) and discussed in more depth in the RBPS Guidance Document. There is no specific mention of ‘gun shot detection systems’ in either document, thus there is no ‘CFATS requirement’ to employ such a system.

The RBPS Guidance Document does make two important points about detection systems. First:

“For a protective system to prevail, detection needs to occur prior to an attack (i.e., in the attack planning stages) or early enough in the attack where there is sufficient delay between the point of detection and the successful conclusion of the attack for the arrival of adequate response forces to thwart the attempt.” [pg 50]

And second:

“Typically, when a sensor or other IDS [intrusion detection system] component identifies an event of interest, an alarm notifies security, which then will assess the event either directly by sending persons to the location of the event or remotely by alerting personnel to evaluate sensor inputs and surveillance imagery.” [pg 52]

Interior and Exterior Shots Fired

There are two general scenarios where a gunshot detection system might be of use for a CFATS covered facility; shots fired inside the facility and shots fired outside the facility (okay, I guess there are no other scenarios).

For shots fired within the facility, it is, by definition, too late to prevent the attack. Information from a shot finder could provide information to response personnel to help pin down the location of the shooter. That will be problematic for most chemical facilities that do not have armed guards (the vast majority of chemical facilities in the United States). Detailed prior coordination with local law enforcement personnel (lacking at most chemical facilities) would be required to ensure that responding officers knew about the shot detection capabilities and had timely access to the location information when (and after) they arrived on scene.

The problem for shots fired outside of the facility would be determining if the impact area or trajectory of the projectiles was inside of the facility. For incidents where there is no facility impact, the ability to determine that would be helpful to frame interior incident response (do not panic, they are shooting at someone else). For shots targeted at the facility (with malice aforethought or inadvertently), the location of the impact point could have beneficial input into the emergency response within the facility.

Unfortunately, most shot detection systems do not track trajectory or impacts (okay, I do not know of ANY that do, but I am not current on the technology so someone may have addressed this issue). Setting up a system to predict impacts or trajectory would require at least two different detection systems; one to detect the initial gun shot location and one to detect the projectile in flight at at least one position. The second portion of that problem would require multiple sensors around the perimeter of the facility to detect boundary penetration.

The Metcalf Scenario

The original question specifically mentioned the Metcalf situation; the April 16th, 2013 sniper attack on the unmanned Metcalf Transmission Substation. The sniper was firing at transformers with the apparent intent (this incident is still ‘unsolved’) of causing equipment failure through a loss-of-coolant incident.

A shot detection system at this facility would not have prevented the attack, but it may have provided timely enough notification to have allowed police to have apprehended the perpetrator. Unfortunately, this presumes a timely response to a ‘shots fired’ report without any indication of an antipersonnel attack.

There are few ‘unmanned’ chemical facilities, but many facilities are not manned 24/7 so this scenario could apply to such facilities. Again, the big problem is not being able to determine what the target of the shooting is when the shot detection system goes off. This is a big problem in rural areas where the shots may be from legitimate hunters.


If a facility is concerned with protecting critical infrastructure from gunshot attacks (and storage tanks quickly come to mind in this regards) it is probably more effective to provide some sort of ballistic protection in the form of either intermediate barriers or bullet-proof coatings (ballistic plate or fabrics) for high-risk equipment. Even if gunshot detection is employed, such protection would still be necessary if there is a high-risk for a ballistic attack; gunshot detectors (shot location or impact location) only provide for response, they DO NOT prevent damage.


In short, I stand behind my earlier conclusion that these systems are not required for CFATS facilities and I doubt that they would be cost effective if employed. If systems are available (at a ‘reasonable’ cost) for predicting impact locations for shots fired, and a facility is in an area where there are frequently shots fired, it might be worthwhile to employ such a system to alert internal response personnel for inadvertent bullet impacts on site.

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