DOD Chemical Consequence Management Force

There is an interesting post over on the Armchair Generalist blog today. It deals with some recent training by DOD’s new CBRNE Consequence Management Response Force. This ‘unit’ is a joint force that will assist in responses to chemical, biological, radiological, nuclear or high-yield explosive (CBRNE) incidents. One would assume that a terrorist attack on a high-risk chemical facility would be an incident to which this force might respond. Would that be appropriate?

 

Response Force

 

The Armchair Generalist makes his view of this military force quite plain:

 

• “You may know from past posts that I am not a fan of the DOD response forces. From the small WMD Civil Support Teams through the CERF-Ps to these CCMRFs, I think they're a waste of time and not any use unless prepositioned at a major event where a terrorist WMD incident occurs. Better if we were to give the money to the states and locals for "all-hazard" emergency response needs.”

The main problem with these DOD forces is their response time. Even the WMD Civil Support Teams (one in each state) are unlikely to be able to get to an incident site within three hours of an attack. This is not soon enough to prevent any but a very small fraction of the causalities that one would expect to see from such an attack. Most of the chemicals released in such an attack would not be persistent, so there would be little immediate need of the chemical detection and decontamination capabilities of such a unit. There might be a few incidents where their chemical reconnaissance capabilities might be beneficial for mapping contaminated zones, but that would be very unusual.

 

Training Cadre

 

These units would probably be much more valuable if they were used as a training cadre for local fire, EMS, and hospital personnel. Their technical capabilities would be invaluable for helping these personnel plan an emergency response for such a terrorist attack on a local chemical facility. They could also conduct training and plan/supervise drills in support of those plans.

 

Local Response

 

Any response to a local incident is going to have to be handled by local agencies. They are the only ones that are going to have an adequate response time and the necessary familiarity with the local facilities and community. What these agencies lack is training and equipment. Helping them by identifying the needed equipment and providing the required training is something that could be done by a Federal response force

Tags: Chemical Facility Security, CBRNE Consequence Management Response Force

2008 Chemical Sector Security Summit Page Update 09-15-08

DHS updated their 2008 Chemical Sector Security Summit web page today. There is now a link to a second page, the Summit Presentations Page. That page contains links to .PDF copies of some of the presentations made at the summit.

 

Chemical Sector Summit Presentations

 

There are only links to seven presentations on the new page, much fewer than were actually presented at the conference. Since many of the presentations were made by people not affiliated with the Federal Government, there may have been difficulties getting the necessary releases to post all of their presentations on this web site.

 

The presentations provided do come from a couple of government agencies (DOT, DHS, and Coast Guard) with the Coast Guard having the widest representation. There is even a presentation from a chemical company, the Potash Corporation. Here is a complete list of the presentations listed on the web site:

 

• Captain Mark O'Malley, The Marine Transportation Security Act (MTSA) of 2002 & the Chemical Facility Anti-Terrorism Standards (CFATS)
• Captain Mark O'Malley, Transportation Worker Identification Credential (TWIC) and the 33 CFR Subchapter H Update Project
• Robert Ross, There are so Many Information Protection Rules: PCII, CVI, SSI, SAFEGUARD
• Katherine Sinniger, How is SSI Used by the U.S. Coast Guard
• Meghan Ludtke, Protected Critical Infrastructure Information (PCII) Program
• Deborah Allen, Training
• Wade Townsend and J. Travis Walker, CFATS Inspections Process

Limitations of PowerPoint® Presentations

 

It is quite obvious that all of these presentations were produced as PowerPoint® slides before they were converted to .PDF files. This means that the ‘presentations’ posted to this web site are really just the outlines not the actual presentations. There is some valuable information provided in those outlines, but the meat of the presentation is missing.

 

It would have been more interesting and informative if there had been audio files posted with these ‘presentations’ so that we could have heard what the presenters had to say. It would have been even better if the presentations had been web cast live. This would have allowed the presentations to have reached an even wider audience. Copies of the web cast could have been posted to the site for a more permanent record of the proceedings.

 

Perhaps next year, DHS will bring their information sharing technology up to the standards of the 21st century. A web cast or even a podcast of the presentations would provide much more information to the vast number of people connected with chemical facility security that could not make it to the physical event. Heck, even Congressional Hearings are web cast.

Tags: Chemical Facility Security, Chemical Sector Summit Update

American Chemistry Council Addresses Cyber Security

The American Chemistry Council is having their annual ChemITC (Chemical Information Technology Center) Conference at the end of this month. According to the conference web site there will be substantial coverage of cyber security issues for chemical facilities. This year’s conference is being sponsored by IBM and SAP. It will be held at the SAP’s Americas headquarters in Newton Square, PA from September 30th thru October 2nd.

 

Cyber Security Program

 

Some of the security issues that will be covered in the conference’s Cyber Security Program will include:

 

• Preventing Insider Threats: Lessons Learned from Actual Attacks
• Cyber Storm II and Related After Actions (ACS)
• CFATS Risk-Based Performance Standards (ACS)
• Deploying Information-Centric Security
• Chemical Sector Roadmap (DHS)
• CFATS - Next Steps, Auditing and Information Security (DHS)
• Cyber Security Program Work Team Updates (ACS)

Tags: Chemical Facility Security, Cyber Security

HR 5577 and Congressional Charades

Speaker Pelosi and the Democratic House Leadership continue to play silly games with HR 5577, the bill that that House Homeland Security Committee has designed to make the current CSAT regulations permanent while correcting some of the earlier legislative mistakes. On last Friday the Speaker gave the House Committee on Energy and Commerce another extension to complete their work on the bill.

 

Interestingly the extension gives that committee until September 26th to ‘complete its consideration’. That is the day that Speaker Pelosi and Majority Leader Reid plan to cut off legislative work for this Congress. Even if the Committee favorably reported the bill on that date, there would be no time for any other legislative action. In other words this bill is, as I have said before (see : “Congress Back in Session 9-08-08”), dead.

 

Unfortunately, Speaker Pelosi prefers to play games. Rather than publically killing the bill and stating her reasons for opposing it, she pretends that House is still working on the bill. She owes Chairman Thompson and his committee an apology for playing games with their hard work. She owes DHS and the American chemical industry an explanation what she expects them to do about chemical facility security when the current law runs out.

Tags: Chemical Facility Security, HR 5577 Status

AWA Water Security Congress Call for Papers

The American Waterworks Associations issued a call for papers for the 2009 Water Security Congress in April 2009. Abstracts must be submitted by October 1st, 2008. It is interesting to note that one of the planned sessions for next year’s Congress will be ‘Chemical Security Protocols’.

 

According to the AWA web site:

 

• “With the rise in emergency planning issues, security has inarguably become an important facet of daily operations and a priority for today's water professionals. AWWA's Water Security Congress consistently attracts water industry professionals who are looking for the most current information on water security and how to address new and emerging challenges faced by the industry.” 

 More details about the Water Security Congress will be available in December.

Tags: Chemical Facility Security, Water Facility Security, Call for Papers

CSB to Hold Public Meeting about Propane Incident

The Chemical Safety Board last week posted a Federal Register notice that they would be conducting a public meeting in Beckley, WV about the January 2007 Little General Store propane explosion. The meeting will be held on September 25th. The Board will hear a report on the investigation. There will be a period for public comment and discussion. The Board will then vote on whether to accept the staff report on the investigation.

 

While this was an accidental propane release/explosion many of the points covered in the investigation would have a direct impact on planning for a terrorist attack on a propane storage facility. Those points include:

 

·             “Emergency evacuation,

·             “Hazardous materials incident training for firefighters,

·             “911 Call Center preparations,

·             “Propane company procedures, and

·             “Propane technician training.”

Tags: Chemical Facility Security, Chemical Safety Board, Propane Explosion

PHMSA Transportation Security Proposed Rule

Earlier this week the Pipeline and Hazardous Material Safety Administration (PHMSA) published a proposed rule governing security plans for commercial shipments of hazardous materials. This proposed rule would modify security provisions of the current The Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Comments on this proposed rule are required to be submitted by November 10, 2008.

 

PHMSA provides the following summary of this proposed rule:

 

• “PHMSA, in consultation with the Transportation Safety (sic) Administration (TSA) of the Department of Homeland Security (DHS), is proposing to modify its current security plan requirements governing the commercial transportation of hazardous materials by air, rail, vessel, and highway. Based on an evaluation of the security threats associated with specific types and quantities of hazardous materials, the proposed rule would narrow the list of materials subject to security plan requirements and reduce associated regulatory costs and paperwork burden. The proposed rule also would clarify certain requirements related to security planning, training, and documentation and incorporate and build on recent international standards governing hazardous materials security.”

Covered Chemicals

 

The major change included in this proposed rule is a reduction in the number of chemicals which required the completion of a transportation security plan. Originally the regulation required all placarded loads of hazardous chemicals to be accompanied by a security vulnerability assessment and a security plan. Industry noted that not all hazardous chemicals could be used as a terrorist weapon or could be used to make weapons of mass destruction.

 

PHMSA used the United Nations Recommendation on high consequence dangerous goods as the starting point for their list of covered chemicals. They looked at classes of chemicals included in the current rule, but not listed in the UN Recommendations to see if those chemicals would serve as a target for terrorist attack either as a release agent, a chemical that could be used to manufacture WMD, or chemicals that could be sabotaged or modified to create a chemical incident at some manufacturing facility. Those chemicals that met those criteria were retained in the proposed security regulations.

 

Clarification to Security Plan Requirements

 

PHMSA is taking the opportunity in this proposed rule to clarify some parts of the security plan requirements that have been confusing to the regulated community. These changes include clarification of the requirement to:

 

• Have a written security assessment that identifies specific risks that exist on specific routes or in specific locations.
• Identify, by job title, the senior management official responsible for the overall development and implementation of the plan.
• Review the security plan at least annually and update the plan if circumstances change.
• Provide for training hazmat employees. That training must include security duties for each position or department that is responsible for the plan's implementation and the process for notifying employees when specific elements of the security plan must be implemented.

TSA and the PHMSA Rule

 

There is a certain amount of overlap in the authority to regulate security matters in the transportation sector. The PHMSA has the authority to issue regulations covering the safe and secure transportation of hazardous material. DHS is the lead Federal agency for transportation and hazardous materials security. This rule pledges to continue to coordinate with the TSA to ensure that there are no conflicts with the security regulations issued by the two agencies.

Tags: Chemical Facility Security, Transportation Chemical Security, Proposed Rule