On Guard

Guidelines for chemical terrorism preparedness

Today we live in a newly dangerous world where it is impossible to predict when and how acts of chemical and biological terrorism may occur. Preparing our organizations and communities to address these threats is vital, of course, for the consequences of not being unprepared can be devastating.

Key to being ready for terrorism is to strengthen your organization's preparedness and protections for your organization, your employees and your surrounding communities against the use of hazardous materials as weapons.

Such readiness entails broad-based corporate and organizational involvement in terrorism planning and preparedness. Here you should capitalize on recent advances in technology as well as your existing information systems. You should also re-examine your company's core organizational chemical purchasing and storage activities in light of technological advances. A bonus of your organization's improved abilities to detect and respond to chemical terrorism will be that it also may help reduce your chemical stockpiles and associated costs.

Organizational Vulnerability
Historically, planning for acts of terrorism has focused almost solely on overt attacks (e.g., bombings). More recently, public health organizations are widening their preparation efforts to include covert terrorism. However, acts of chemical terrorism are most likely to be in the "overt" category: terrorists utilizing hazardous materials as weapons of convenience or weapons of mass destruction. It helps to note that chemical agents are naturally overt due to their ability to be absorbed through inhalation or through the skin or mucous membranes. Symptoms are usually immediate and obvious.

Whatever the delivery method, hazardous-material attacks will elicit immediate response from police, fire and EMS personnel, causing significant strain on public infrastructure. It is our duty as environmental, health and safety (EHS) professionals to take every measure necessary to protect our organizations' infrastructure and chemical surpluses in an effort to avert disaster.

Focusing on Preparedness Activities
The skills and resources required to detect and investigate injuries caused by chemical sabotage are similar to those needed to identify and respond to an attack with a biological agent. However, your organization must prepare for a terrorist attack that might use combinations of agents, or employ simultaneous attacks at multiple sites. Lists of the critical chemical agents your organization uses will need to be modified as new information becomes available. Here, your organization's hazardous substance database will supply critical information.

To best protect your organization, your preparedness efforts must focus on agents within your company that would tend to have the greatest impact on local health and security, especially agents that are highly contagious or that can be engineered for widespread dissemination.

Key Focus Areas
Your organization's strategic chemical terrorism preparedness program should be based on the following three focus areas with each area integrating training, research and program redevelopment: harvesting relevant data about onsite chemicals; performing a vulnerability assessment; and instituting best practices

Harvest Data Concerning Chemicals at Your Facility
The first task is to get the data you need to help you assess your organization's vulnerability to hazardous materials used as weapons. This means you will need reliable data about your chemical stockpiles. Without good data, you won't have the information necessary to implement a reliable security and preparedness program. However, obtaining the data may not be as difficult as you imagine. Your organization's material safety data sheets (MSDSs) and indexes are the raw materials of a good preparedness program.

For most companies, a hard copy MSDS is entered into the system as full text or as an image. MSDS images are typically represented as PDF (Portable Document Format) files. They may come in other formats such as TIFF (Tagged Image File Format) files. One of the drawbacks of an "image" database is that -- while it is possible to turn PDF images into text through Optical Character Recognition (OCR) -- without human correction and quality control you will encounter text errors.

If you are relying on uncorrected OCR for full-text searches, there will be many cases where words are incorrect. The results of searches on OCR data cannot be trusted where human and environmental health is concerned. The inaccuracies in OCR data will frustrate users, possibly endanger them and may provide an excuse to not use your terrorism preparedness program.

While image-based MSDS management systems seem cheaper than text solutions in the beginning, their drawbacks may eventually cause an expensive decision to replace the inferior legacy system. Money saved on poor-quality MSDSs (the raw materials of your chemical and biological terrorism preparedness program) may result in volatile results.

The value of your data does not stop with the actual MSDSs. The indexes that are created in an electronic-text-based system to help you extract information are also important to the reliability of your safety program. These include:

  • Ingredient and physical data info required for chemical reporting
  • Chemical Abstract Services (CAS) numbers and compound names for regulatory list-matching for Tier II, Form R, and other lists
  • Product synonyms
  • User-defined synonyms
  • Hazard rating determinations by the Hazardous Materials Identification System (HMIS) and/or the National Fire Protection Association (NFPA)
  • Secondary chemical product labels
  • Site locations where each chemical is being used
  • Internal part numbers

In order to match people and accurate data, high-quality MSDSs in electronic format are not a nicety; they are a necessity. If you cut corners on conversion, your organization will be at greater risk.

Perform a Vulnerability Assessment
Detection, diagnosis and mitigation of injury caused by chemical and biological terrorism is a complex issue. Meeting this challenge will require special emergency preparedness in all levels of your organization. Your EHS team has to be able to provide health guidelines, support and technical assistance to employees, as well as local and state public health agencies working to coordinate community preparedness. Therefore, you should consider providing self-assessment tools for terrorism preparedness, including a complete vulnerability assessment.

This should be one of your primary steps in terrorism preparedness. Security and EHS professionals should take the lead in developing vulnerability assessments, especially whenever the assessment includes hazardous materials. EHS professionals have the knowledge and experience to predict whether an intentionally released chemical could be used to produce a toxic or catastrophic effect.

Institute Best Practices
Best-practice processes will take advantage of the knowledge gained through your vulnerability assessment, helping you build a better chemical terrorism preparedness program -- but only if your policies are clear and precise. Best practices provide the blueprint for reducing chemicals in the workplace. You will also want to add company-specific policies to your best practices. Don't forget the personalization of the best practice policy for each individual. You may be able to tie the best-practice policies into your company's or department's mission statement. Below you will find a list of best practices you should incorporate into your plan.

  • Develop and validate a "do not use here" chemicals watch list. These are chemicals that should not be used due to their dangerous nature or their potential for creating long-term harm to users and/or the environment.
  • Identify chemical product families. Examples of these families are paints, solvents, adhesives, lubricants, etc.
  • Select approved chemicals and approved vendors for each chemical family.
  • Identify chemical product substitutions and an approved chemical list. This will help you determine which products can be safely substituted for those chemicals that are on your banned list.
  • Eliminate obsolete and out-of-date chemical products. For those partially used chemicals that are in your inventory, get them off the shelves. This should be done every six months, and products must be disposed of properly.
  • Automate the materials requisition and approval process. You will keep unwanted toxins from entering your site and consequently reduce risk; there will be fewer workplace and environmental exposures to chemicals.

Your best-practices actions will encourage the elimination of product redundancy, result in fewer vendors to manage, provide increased purchasing leverage and reduce your organization's vulnerability to becoming an agent for weapons of convenience or weapons of mass destruction.

On the process and maintenance side, you will have identified fewer acceptable products that are approved for each task, which will keep unapproved chemicals off site. With fewer chemicals, you will generate less waste, resulting in a huge economic impact. Finally, overall compliance costs will drop because you are managing less. And your administrative and operational savings will produce a better-than-hurdle-rate ROI, thus helping to internally sell a more robust chemical and biological terrorism preparedness program.

Chemical and biological terrorism preparedness, in its simplest characterization, is source reduction. The fewer hazardous materials you have on hand, the fewer chemical risks you juggle and the less hazardous waste you generate.

The combination of threats and direct use of chemical and biological agents against civilians have exposed organizational vulnerability, highlighting the need to enhance our capacity to detect and control terrorist acts. Our communities must be protected from an extensive range of critical chemical and biological agents. Investment in a robust preparedness program acts as a deterrent against hostile acts, providing the best civil defense against chemical and biological terrorism. Terrorism-preparedness activities described in this article, including developing a solid data backbone, a comprehensive vulnerability assessment and a best practices policy to reduce vulnerability, will dramatically improve our ability to reduce the threats to our employees, families, organizations, communities and environment.

This article originally appeared in the 05/01/2004 issue of Environmental Protection.

About the Author

Mark Wysong is CEO of Dolphin Software, Inc., a provider of chemical compliance and management software in Lake Oswego, Oregon. He is the author of the business book, The Nontoxic CEO.

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