&EPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA-K-550-FOO-002
February 2000
www.epa.gov/ceppo/
Chemical Accident
Prevention: Site Security
The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing effort to
protect human health and the environment by preventing chemical accidents. EPA is striving to
learn the causes and contributing factors associated with chemical accidents and to prevent their
recurrence. Major chemical accidents cannot be prevented solely through regulatory
requirements. Rather, understanding the fundamental root causes, widely disseminating the lessons
learned, and integrating these lessons learned into safe operations are also required. EPA
publishes Alerts to increase awareness of possible hazards. It is important that facilities, SERCs,
LEPCs, emergency responders, and others review this information and take appropriate steps to
minimize risk. This document does not substitute for EPA's regulations, nor is it a regulation
itself. It cannot and does not impose legally binding requirements on EPA, states, or the regulated
community, and the measures it describes may not apply to a particular situation based upon
circumstances. This guidance does not represent final agency action and may change in the future,
as appropriate.
PROBLEM
Facilities that handle chemicals are
actively engaged in managing risks to
ensure the safety of their workers and
the community. Most of their efforts
focus on ensuring that the facility is
designed and operated safely on a day-
to-day basis, using well-designed
equipment, preventive maintenance,
up-to-date operating procedures, and
well-trained staff. Because of today's
increased concern about terrorism and
sabotage, companies are also paying
increased attention to the physical
security of facility sites, chemical
storage areas, and chemical processes.
All companies, big and small, should
have some measure of site security in
place to minimize crime and to protect
company assets. This is especially
true for facilities that handle extremely
hazardous substances.
Under section 112(r) of the Clean Air
Act (CAA), EPA developed Risk
Management Program (RMP)
regulations that require facilities to
examine their chemical accident risk
and develop a plan to address it. The
increased concern for the physical
security of facilities that handle
extremely hazardous substances
is also reflected in recent government
actions. Highlighting site security, the
Chemical Safety Information, Site Security
and Fuels Regulatory Relief Act contains a
major provision that requires the
Department of Justice to prepare reports to
be submitted to Congress describing the
effectiveness of RMP regulations in
reducing the risk of criminally caused
releases, the vulnerability of facilities to
criminal and terrorist activity, and the
security of transportation of listed toxic and
flammable substances.
This Alert is intended as a public service.
It highlights security areas that companies
may want to review to ensure that
appropriate measures are being
implemented. More importantly, it
provides sources of information and help to
assist facilities that routinely handle
chemical substances in their efforts to have
secure and accident-free operations.
EXAMPLES
The following examples illustrate the range
of damage that can occur at facilities
handling hazardous substances because of
criminal activity:
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• A manufacturer uses flammable naphthalene
to produce mothballs. Received in molten
form, the naphthalene solidifies when cooled
and looks similar to candle wax.
Trespassing teenagers found the vats of
naphthalene that were left outside to cool.
They ignited the naphthalene and started an
uncontrollable fire. Approximately 40 acres
of industrial property burned, at an
estimated cost of $100 million.
• Every few weeks, EPA receives reports that
thieves, looking for ammonia to use to make
illegal drugs, have broken into fertilizer
dealers, refrigerated warehouses, or ice
manufacturing facilities, frequently leaving
valves open. In some cases, the thieves have
been overcome by the ammonia and needed
to be rescued; in other cases, the community
has been evacuated, and there have been
injuries to the general public and to law
enforcement personnel from exposures to
the released ammonia.
• There are cases where vandals have
attempted unsuccessfully to break into
chlorine tank cars. Fortunately, the design
of the chlorine tank car includes a heavy
steel dome and additional lock out devices
that discourage even well-equipped vandals.
These examples illustrate the need to examine
security measures at a facility, especially those
handling highly hazardous substances, to guard
against criminal acts, including vandalism.
AREAS OF CONCERN
Threats may come in different forms and from
different sources. Threats from outside the
facility could affect people and the facility itself,
and may involve trespassing, unauthorized entry,
theft, burglary, vandalism, bomb threats, or
terrorism.
Threats from inside the facility may arise from
inadequate designs, management systems,
staffing or training, or other internal problems.
These may include theft, substance abuse,
sabotage, disgruntled employee or contractor
actions, and workplace violence, among others.
Threats are not restricted to people and property,
but could also involve sensitive facility
information. Both facility outsiders and
employees or contractors could pose threats to
data storage and data transmission of, for
example, confidential information, privacy data,
and contract information. They could also pose a
threat to computer-controlled equipment. These
threats may include breaches in data access and
storage, uncontrolled dissemination of
information, destruction of information or threats
to automated information systems.
COMMON SECURITY MEASURES
Most security measures are intended to prevent
intruders from gaining access to the site or to
limit damage. The following sections present a
number of design and procedural approaches that
facilities have successfully implemented. The
appropriateness of any one of these depends on
site-specific conditions that you would need to
consider in assessing any security needs for your
facility.
PREVENTING INTRUSION
Most facilities have some measures that are
intended to prevent intruders from entering the
grounds or buildings. These measures may
include fences, walls, locked doors, or alarm
systems. The location of the facilities and the
types of structures will determine how much and
what type of protection a facility needs.
In addition to basic measures, some facilities also
provide physical protection of site utilities at the
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fence perimeter. Security lighting (good lighting
around buildings, storage tanks, and storage
areas) can also make it very difficult for someone
to enter the facility undetected.
Some facilities augment these measures with
intrusion detection systems — video surveillance,
security guards at fixed posts, rounds/mobile
patrols, alarm stations, and detectors for
explosives and metal. If you have guards, it may
be useful to consider their training in detection
and response and the availability to them of
equipment for appropriate protective force.
To protect against unauthorized people coming in
through normal entrances, security clearances,
badges, procedures for daily activities and
abnormal conditions, as well as vehicular and
pedestrian traffic control, can provide efficient
access for employees while ensuring that any
visitors are checked and cleared before entering.
Most facilities have procedures to recover keys
from employees who leave and to immediately
remove the employee's security codes from
systems. At times it may be wise to consider
additional measures, such as changing locks,
when a disgruntled employee leaves.
LIMITING DAM A GE
In addition to protecting a facility from intruders,
it is important to limit the damage that an
intruder (whether physically at the site or
"hacking" into the company's computers) or an
employee could do. Most of the steps to limit
damage are probably things you already do as
part of good process safety management, because
they also limit the loss of chemicals if
management systems or equipment fails or an
operator makes a mistake. These steps can be
related to either the design of the facility and its
processes or to procedures implemented.
Facility Design
A well-designed facility, by its layout, limits the
possibility that equipment will be damaged and,
by its process design, limits the quantity of
chemical that could be released. Facility and
process design (including chemicals used)
determine the need for safety equipment, site
security, buffer zones, and mitigation planning.
Eliminating or attenuating to the extent
practicable any hazardous characteristic during
facility or process design is generally preferable
to simply adding on safety equipment or security
measures.
The option of locating processes with hazardous
chemicals in the center of a facility can thwart
intruders and vandals who remain outside the
facility fenceline. Transportation vehicles, which
are usually placarded to identify the contents,
may be particularly vulnerable to attack if left
near the fenceline or unprotected. However, for
some facilities and processes, the option of
locating the entire process at the center of the site
may not be feasible. You may need to consider
external versus internal threats, such as the threat
to workers if an accidental release occurs, or the
access to the process in case of an emergency
response.
Where feasible, providing layers of security will
protect equipment from damage. These layers
could include, for example, blast resistant
buildings or structures. Enclosing critical valves
and pumps (behind fences or in buildings) can
make it less likely that an intruder will be able to
reach them, a vehicle will be able to collide with
them, or that releases are compounded because of
damage to neighboring equipment.
Chlorine tanker valves are an example of
equipment design with several layers of security:
(1) a heavy steel dome with lid; (2) a heavy cable
sealing system that requires cable cutters to
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remove; (3) a heavy duty valve that can
withstand abuse without leaking; and (4) a seal
plug in each valve. As many as three different
tools would be needed to breach the container's
integrity.
If equipment is located where cars, trucks,
forklifts, or construction equipment could collide
with it or drop something on it, the equipment
should be constructed from materials that could
stand some abuse. In general, you should give
consideration to collision protection to any
equipment containing hazardous chemicals with,
for example, collision barriers.
The idea of layers of security may also be
applied to communications/computer security.
Some companies have developed alternate
capabilities and systems to protect receipt and
transmission of confidential information. Backup
power systems and/or conditioning systems can
be important, particularly if processes are
computer controlled. Access to computer
systems used to control processes may need to be
controlled so that unauthorized users cannot
break in; appropriate computer authentication
and authorization mechanisms on all computer
systems and remote access may prove useful;
entrance into control rooms may need to be
monitored and limited to authorized personnel.
For emergency communications, some companies
use radios and cell phones as a backup to the
regular phone system.
Well-designed equipment will usually limit the
loss of materials if part of a process fails.
Excess flow check valves, for example, will stop
flow from an opened valve if the design flow rate
is exceeded. These valves are commonly
installed on chlorine tankcars and some
anhydrous ammonia trailers, as well as on many
chemical processes. Like excess flow valves,
fail-safe systems can ensure that if a release
occurs, the valves in the system will close,
shutting off the flow. Breakaway couplings, for
example, shut off flow in transfer systems, such
as loading hoses, to limit the amount released to
the quantity in the hose.
If you store hazardous liquids, you may want to
consider containment systems (e.g., buildings,
dikes, and trenches) that can slow the rate at
which the chemical evaporates and provide time
to respond. Double-walled vessels can also
protect against attempts to rupture a tank.
The installation of chemical monitors that
automatically notify personnel of off-hour
releases could be important if your facility is not
staffed during certain periods (e.g., overnight).
Such monitors, however, are not available for all
chemicals. The appropriateness of monitors, and
any other equipment design solutions, will depend
on site-specific conditions.
Procedures and Policies
Your facility's policies and procedures can also
limit the damage caused by a release. As with
design issues, the procedural steps you routinely
take to operate safely also help protect your
facility from attacks. Maintaining good labor
relations may protect your facility from actions
by either employees or contractors. Open
negotiations, workplace policies emphasizing that
violence and substance abuse are not tolerated,
and adequate training and resources to support
these policies are important considerations. The
goal is to develop a workforce and management
capacity to identify and solve problems by
working together. Following are several
examples of specific areas where procedures and
policies can prevent or limit the damage of a
release.
As a matter of good practice, as well as site
security, you may consider disconnecting storage
tanks and delivery vehicles from connecting
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piping, transfer hoses, or distribution systems
when not in use. Leaving the tanks linked to the
process or pipeline increases the chance of a
release because the hoses or pipes are often more
vulnerable than the tanks.
In addition to accurately monitoring your
inventory, another practice you may want to
adopt is limiting the inventory of hazardous
materials to the minimum you need for your
process. This policy limits the quantity of a
hazardous material that could be released. You
could also consider actions such as substituting
less hazardous substances when possible to make
processes inherently safer.
Your written procedures are also an important
tool in protecting your facility. As part of your
regular operating procedures, you probably have
emergency shutdown procedures. These
procedures, and workers trained in their use, can
limit the quantity released. The procedures are
particularly important if you have processes that
operate under extreme conditions (high or low
pressures, temperature) where rapid shutdown
can create further hazards if done improperly.
As you review your contingency plan, consider, if
necessary, revisions to address vandalism, bomb
threats, burglary - including evaluating the
desirability of your facility as a target - working
with local law enforcement, and providing extra
security drills and audits. Many companies find
that working with local law enforcement is an
effective means of evaluating security risks.
As a matter of good practice, for both process
and response equipment, it is important to have a
program that ensures that all equipment is
subject to inspection and to corrective and
preventive maintenance. In this way, you can be
sure that the safety systems you install will
operate as designed.
SITE-SPECIFIC DECISIONS
The steps you take to operate safely will often
serve to address security concerns as well.
Considering inherent safety in the design and
operation of any facility will have the benefit of
helping to prevent and/or minimize the
consequences of any release. Before taking steps
to improve site security, you may want to
evaluate your current system and determine
whether it is adequate. Factors you might
consider include:
• The chemicals stored at your site; some
chemicals may be particularly attractive targets
because of the potential for greater
consequences if released.
• The location of the site; sites in densely
populated areas may need more security than
those at a distance from populations.
• The accessibility of the site; are the existing
security systems (e.g., fences, security lighting,
security patrols) adequate to limit access to the
site?
• The age and type of buildings; older buildings
may be more vulnerable because they have
more windows; some newer building are
designed for easy access.
• Hours of operation; a facility that operates
24-hours day may need less security than a
facility that is unoccupied at night.
Decisions about improving site security should
be made after evaluating how vulnerable your
site is to threats and what additional measures, if
any, are appropriate to reduce your vulnerability.
Each facility should make its own decision based
on its circumstances.
IT IS YOUR DUTY
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If you produce, process, handle, or store
extremely hazardous substances you have, under
the Clean Air section 112(r)(l), a general duty
"to identify hazards which may result from such
releases, using appropriate hazard assessment
techniques, to design and maintain a safe facility
taking such steps as are necessary to prevent
releases, and to minimize the consequences of
accidental releases which do occur."
INFORMATION SOURCES
Several organizations (e.g., ASTM, ANSI) have
standards for site security or include site security
issues in their codes. The National Fire
Protection Association (NFPA) has a standard
NFPA- 601, Standard for Site Security Services
for Fire Loss Prevention. The American
Petroleum Institute addresses security issues in
RP 554, Process Instrumentation and Control.
Likewise, the Chemical Manufacturers
Association addresses this issue through the
Responsible Care Employee Health and Safety
Code Site Security Management Practice.
Protocols developed under the Responsible
Distribution Process K cover security concerns.
You can contact the following websites for
additional security information:
www.energysecuritycouncil.org
The Energy Security Council is a national
industry association to assist law enforcement
agencies and energy companies in combating
all types of criminal activity.
www.nfpa.org
The National Fire Protection Association
provides standards, research, training, and
education to reduce the burden of fire and other
hazards.
www.nsc.org
The National Safety Council provides general
safety information on chemical and
environmental issues.
www.asisonline.org
www. securitymanagement.com
The American Society for Industrial Security
develops educational programs and materials
that address security concerns. Its Security
Management Magazine site provides an online
version of its magazine.
www. siaonline .org
The Security Industry Association
provides general security information.
www.atsdr.cdc.gov
The Agency for Toxic Substances and Disease
Registry site provides a 10-step procedure to
analyze, mitigate, and prevent public health
hazards resulting from terrorism involving
industrial chemicals.
www.aiche.org/ccps
The Center for Chemical Process Safety
(CCPS) is an industry-driven, non-profit
professional organization affiliated with the
American Institute of Chemical Engineers
(AIChE). It is committed to developing
engineering and management practices to
prevent or mitigate the consequences of
catastrophic events involving the release of
chemicals that could harm employees,
neighbors and the environment.
www.cdc.gov/niosh
The National Institute for Occupational Safety
and Health provides multiple resources on
workplace violence prevention.
The Complete Manual of Corporate and
Industrial Security, by Russell L. Bintliff
(Prentice Hall, 1992) provides detailed
discussions of the advantages and disadvantages
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of various security systems as well as checklists
for security inspections.
The Handbook of Loss Prevention and Crime
Prevention, 3rd Edition, L.J. Fennelly, Ed.,
(Butterworth-Heinemann, 1996) includes
information on conducting security surveys as
well as chapters on a broad range of security
subjects.
Guidelines for Investigating Chemical Process
Incidents. (AIChE/CCPS). These Guidelines
establish a basis for successful investigation of
process incidents to determine causes and
implement changes, which can prevent
recurrence. Primary focus is on incidents with
catastrophic potential but the concepts should
also be used for investigating environmental
incidents, minor injuries, less significant property
damage events, or near misses.
Process Plants: A Handbook for Inherently
Safer Design, by Trevor Kletz. (Taylor &
Francis 1998) illustrates the principles of
inherent safety and demonstrates the advantages
of considering safety approaches in the design
stages of a process.
Inherently Safer Chemical Processes: A Life
Cycle Approach. (AIChE/CCPS) This book
presents the principles and strategies for applying
inherently safer thinking from the start of the life
cycle to the very end.
STATUTES AND REGULATIONS
The following are a list of some federal statutes
and regulations related to process safety
management and accident prevention:
EPA
Clean Air Act (CAA)
• General Duty Clause [Section 112(r)(l) of the
Act] - Facilities have a general duty to prevent
and mitigate accidental releases of extremely
hazardous substances.
• Risk Management Program (RMP) Rule [40
CFR part 68] - Facilities that have a listed
toxic or flammable substance above a certain
threshold are required to develop a hazard
assessment, a prevention program, and an
emergency response program.
Chemical Safety Information, Site Security and
Fuels Regulatory Relief Act
• A major provision requires the Department of
Justice to submit reports to Congress
describing the effectiveness of the RMP
regulations in reducing the risk of criminally
caused releases, the vulnerability of facilities to
criminal and terrorist activity, and the security
of transportation of substances listed under
CAA Section 112(r).
Emergency Planning and Community Right-to-
Know Act (EPCRA)
• Emergency Planning [40 CFR part 355] -
Facilities that have listed chemicals above a
certain threshold must report to their Local
Emergency Planning Committee (LEPC) and
State Emergency Response Commission
(SERC) and comply with certain requirements
for emergency planning.
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)
• Under the authority of CERCLA, EPA's
Chemical Safety Audit program examines site
security as part of a standard audit protocol.
Clean Water Act (CWA) as Amended by the Oil
Pollution Act of 1990 (OPA)
• Spill Prevention Control and Countermeasures
Plan (SPCC) [40 CFR part 112] - Facilities
storing oil above a certain threshold must
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prepare and implement an SPCC plan. These
plans need to address security elements such as
locks, guards, access, lighting, and vandalism.
OSHA
• General Duty Clause [OSH Act section 654] -
Employers are required to provide a safe
workplace free of recognized hazards.
• Process Safety Management (PSM) Standard
[29 CFR 1910.119] - Facilities that have a
highly hazardous substance above a certain
threshold are required to implement a number
of actions to manage hazards including
performing a process hazards analysis and
maintaining mechanical integrity of
equipment. External threats must be
considered when conducting a process hazard
analysis.
• Hazard Communication Standard [29 CFR
1910.1200] - Facilities handling hazardous
chemicals must maintain information on the
hazards and train employees in how to handle
the chemicals safely and protect themselves if
exposed.
Other OSFiA regulations address some security
issues for specific types of hazardous materials
(e.g., flammables).
Department of Transportation
The US Department of Transportation has a
number of regulations that address security at
transportation terminals. These regulations can
be found in Titles 14, 33, and 49 of the Code of
Federal Regulations.
For More Information:
Contact the EPCRA Hotline at:
(800) 424-9346 or (703) 412-9810
TDD (800)553-7672
Monday -Friday, 9 AM to 6 PM, EST
For information on OSHA standards contact
OSHA Public Information at (202) 219- 8151 or
visit the website: www.osha.gov
Visit the CEPPO Home Page at:
WWW.EPA.GOV/CEPPO/
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