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There are few areas of our economy that have been affected more by terrorism — both internal and external — than the petrochemical industry. Those plants and facilities that produce, process and transport volatile substances have drawn the attention of lawmakers and law enforcement officials who have an interest in keeping these chemicals out of the hands of terrorists.
In 2006, Congress created the Chemical Facility Anti-Terrorism Standard (CFATS) for facilities considered to be at high risk. In addition to petrochemical plants, CFATS may impact any industry, manufacturing facility, government agency or college and university dealing with potentially volatile chemicals.
For a closer look and an update on CFATS, we recently spoke with Ryan Loughin, Director of Petrochemical & Energy Solutions for the Advanced Integration division of ADT Security Services.
Q. What is the latest news on CFATS?
Loughin: The original CFATS legislation was set to expire in October 2009, so in September, Congress passed a bill extending the current regulations for one year. With so many major issues facing Congress now, this gives the politicians and industry the time to develop permanent legislation.
Q. What chemicals and how many facilities has CFATS affected?
A. More than 320 chemicals of interest (COI) have been identified. Facilities working with any of these COI were asked to submit information to the Department of Homeland Security (DHS) describing their use and storage. DHS identified more than 6,000 facilities and ranked these facilities on a scale of one through four. Those in the first tier were considered to represent the greatest potential risk.
This summer, DHS began notifying facilities of their final rankings and gave them 120 days to submit a Site-Security Plan (SSP) to cover a variety of areas including perimeter security, securing set assets, screening, and monitoring.
Q. What is the best way to go about that process?
A. My recommendation is to form an internal SSP team to address the numerous areas that the Site Security Plan covers. As for the physical security area of the SSP, my advice is to partner with a security integrator that has expertise in plant wide perimeter based security. Providing this type of security program is complex and requires a specific knowledge base that differs from the general electronic security market. I also recommend choosing a partner that is extremely knowledgeable on CFATS and the Risk-Based Performance Standards (RBPS). It is also important that your integrator is focused on the latest technologies available and reducing the overall cost of your project without jeopardizing the integrity of the security system. There are many details that need to be integrated into the overall security plan for these types of facilities which are different than traditional security programs that were designed solely to deter theft and promote safety.
Q. How does a security or environmental health and safety professional select a security integrator?
A. One of the biggest considerations in selecting a security integrator is to look for one that will examine a facility’s security goals and challenges and come back with cost-effective solutions based on the integrator’s knowledge and background in security — specifically petrochemical facility security. A design-build approach gives the integrator the freedom to put together the best and most efficient system available, which usually saves the end-user money and time.
Also make sure the integrator is more than just talk. Ask for references. Meet the project manager that you will be working with on a daily basis. Check for certifications that indicate a staff that continues to educate itself on advancements in the security industry. Also ask about anti-terrorism related certifications. For example, CVI (Chemical-Terrorism Vulnerability Information) certification that covers how CFATS related information is handled. SAFETY Act certification for Electronic Security Services is also important because petrochemical plants and other facilities would receive torte liability protections against claims that the technology failed to prevent a certified "Act of Terrorism." It’s a little bit of work, but it will be worth the peace of mind that comes with knowing you are in good hands when it comes to such a critical undertaking.
Ryan Loughin is Director of Petrochemical & Energy Solutions for the Advanced Integration division of ADT. He provides security education to CFATS and MTSA affected companies and is a member of the National Petrochemical and Refiners Association (NPRA), Society of Chemical Manufacturers and Associates (SOCMA), Energy Security Council (ESC) and American Society for Industrial Security (ASIS). Loughin has also completed multiple levels of CVI Authorized User training (Chemical-Terrorism Vulnerability Information), which was authored by the U.S. Department of Homeland Security. Ryan can be reached at petrochem@adt.com
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