Monday, March 2, 2020

COVID19and CFATS


The ‘novel corona virus’ (COVID19) that is currently slowing down in China is starting to appear more frequently on the world stage. While it is way too early to predict its effect on the United State, the impact in China certainly provides a worst-case scenario that bears consideration. DHS and the Cybersecurity and Infrastructure Security Agency (ISCD) are not yet talking publicly about potential security implications of COVID19, but security managers should start thinking about how a worst-case scenario could affect their operations.

To be clear COVID19is not directly a security issue, the virus is not going to ‘attack’ chemical facilities and release toxic agents into the air. But large numbers of personnel out with the virus or hiding out at home attempting to avoid the virus, or, worst-case, being sent-home by the government to stop the spread of the virus could have potential effects on facility security plans. And there are various wacko groups here in the United States that could be counted upon to try to take advantage of the situation to attack the ‘oppressive, illegal government operations’ trying to stem the spread of the disease.

Facility Shutdowns


We are already starting to see supply chain effects in the United States from the shutdown of many manufacturing facilities in China. This combined with the movement of much basic chemical manufacturing to China over the last 20 years or so is beginning to have some effect on chemical manufacturing in the United States. As stockpiles of chemicals sole-sourced from China begin to dry up we are going to begin to see chemical manufacturing facilities slowing and even stopping production in the US.

While many companies will use this as an opportunity to catchup on maintenance and upgrade activities, more will begin to reduce work weeks or even shut the front gates until the supply reopens. There will even be a number of companies that will go under because of the supply chain issues. As these plants sit idle, the lack of a work force on site will reduce the number of eyes that are on the lookout for suspicious activities. Facilities will need to increase their internal guard-force patrolling to off-set this reduction of eyes-on-scene.

Security managers probably need to start talking with their guard companies about ensuring adequate coverage during sickouts. And conversations with local law enforcement agencies about increased security patrolling during reduced guard-force coverage would also be a good idea.

Closed Facilities


As facilities close due to bankruptcy or lack of business there is seldom any incentive to get rid of existing chemical inventories. In instances where facilities close with inventories of DHS chemicals of interest, specific interest should be made to properly sell or dispose of these inventories.

ISCD should take special interest where CFATS covered facilities close abruptly. Chemical inspectors should visit the site to ensure that the COI inventory is no longer on site. Where it remains on site, ISCD is going to have to figure out how to ensure that those inventories receive adequate security pending their disposal. We do not need a repeat of the Cook Slurry Company closure or the abandoned hydrofluoric acid tank. And congress might want to think about providing authority to take specific types of action at abandoned CFATS facilities when they get around to reauthorizing the program (that will be a future blog post).

Potential Threat Increase


If security issues due to manpower problems are not a big enough concern, there is a potential for an increased threat of attacks against facilities that have theft/diversion security issue COI on hand.

The whole issue of mandatory quarantines raises some interesting legal issues about freedom of assembly and habeas corpus. While this has not yet caused any problems with the isolation of returned travelers, any expansion of quarantines within the country is certain to upset people in the sovereign citizen movement and right-wing militias. The fringes of both groups are well known for employing violence to make their political statements.

With their increased frustration about the denial of liberties and the increased confusion in the communities as we potentially approach the China case, there is going to be an increased interest on the part of these groups for employing weapons of mass destruction as part of their ‘protests’. This puts facilities that house theft/diversion COI at an increased threat of attack when they are potentially having to address internal security issues due to reduced manpower.

Again, security managers are going to have to start thinking about these issues now and talking with their security companies and local law enforcement about the issue. ISCD is also going to have to think about some proactive engagement with the National Guard Bureau about the issue. Talking about this potential problem early is going to be the key to staying ahead of the issue.

Moving Forward


We are well ahead of the potential problems describe here, but they could happen sooner rather than later. It is not clear that DHS is going to be allowed to engage in any advanced planning on these issues as the Administration appears to be more concerned with preventing stock market problems than really addressing the medical issues at hand. We can only hope that advanced security planning will be allowed to proceed at the federal level.

But security managers are going to have to take a hard look at how this potential epidemic could effect their security posture and start thinking and talking about how they could deal with these issues before they actually arise.

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