Friday, January 25, 2019

Reader Comment – CFATS and Active Shooters

Earlier this week over on LinkedIn, Michael Kennedy, a long-time reader and a lawyer active in CFATS matters, left an interesting comment about my gun shot detection post:

“I just wonder if it's cost effective, and if the juice is worth the squeeze? But, what if CFATS had active shooter classes as a requirement? Something to kick around for the next reiteration...”

His question about an ‘active shooter classes’ requirement in the next iteration of the Chemical Facility Anti-Terrorism Standards (CFATS) authorization is an interesting suggestion that deserves discussion.

Active Shooters and Chemical Facilities

Michael provided a link to the DHS Active Shooter web site (which is still up during this extended Federal Funding Fiasco; I with NIST would follow the DHS example, but that is a whole separate discussion). This site provides a wealth of information and reflects the current DHS interest in helping facilities and responders prepare for an active shooter situation. Unfortunately, it overlooks the unique planning and training requirements for addressing active shooter situations at chemical plants.

I have written about these issues a number of times over the years (see here and here for example) and even prepared a training program for a law enforcement training site (now off-line) on the topic. For this post, I will just summarize the problems potential problems associated with an active shooter response at a facility that stores, manufactures or uses industrial chemicals. For facilities with:

• Flammable chemicals on hand, flammable atmosphere situations should be expected and muzzle flashes from firearm discharges could ignite such atmospheres;
• Flammable chemicals on hand, bullets flying around should be expected to pierce storage containers producing flammable atmospheres (see above);
• Toxic inhalation hazard chemicals on hand, bullets flying around could be expected to pierce storage containers to release toxic fumes to the atmosphere, endangering personnel over a wide area;
• Chemicals with heavier-than-air vapors, bullets flying around could be expected to pierce storage containers producing locally oxygen deficient atmospheres;
Chemicals on site that are capable of reacting with one another could be released producing unexpected toxic inhalation, fire, or heavy vapor hazards; and
The release of any number of less-than-immediately toxic chemicals during such an attack could lead to unpredictable medical issues amongst responders and innocent bystanders.

Each industrial facility with chemicals on hand is going to have to analyze for the specific hazards associated with their facility in a potential active shooter incident and plan for measures to mitigate those hazards. Security responders and law enforcement personnel will need to be trained to recognize the hazards at specific facilities and modify their use of firearms as appropriate to avoid escalating a relatively simple active shooter response to an active chemical release incident with potential off-site consequences where responders are also having to deal with an active shooter.

Active Shooter CFATS Language

In keeping with the earlier set of posts that I did on potential language that I would like to see in a CFATS reauthorization bill, I would like to see the following language considered for active shooter situation planning and response:

(h) The Secretary will revise 6 CFR 27.230(a) to include a risk-based performance standard addressing planning for an active shooter incident. The language would include requirements for that RBPS would include:

(1) Identification of chemical hazards that would have to be considered during planning for an active shooter incident;

(2) Plans to limit active shooter access to areas where the identified chemicals are stored, used or produced;

(3) Training for armed facility security personnel and/or local law enforcement personnel about areas in the facility where special precautions would have to be taken when discharging firearms during an active shooter response; and

(4) Unique emergency response requirements for chemical releases during an active shooter incident.

Existing CFATS facilities would be given a reasonable deadline (6 months?) to revise approved site security plans to take into account the new RBPS requirements.

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