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  • Assessing Risks and Vulnerabilities in US Chemical Facilities

Assessing Risks and Vulnerabilities in US Chemical Facilities

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By: Warren Silverman, MD FACOEM, Medical Director, Workplace Forensics LLC

Following the attacks of 9/11, there was a realization that the open freedoms of the society in the United States created massive vulnerabilities for those who wish to harm us. With an analysis of these dangers, the Department of Homeland Security (DHS) was tasked to come up with comprehensive regulations and guidelines to reduce the risk of a chemical-related disaster by limiting the vulnerability of industrial sites which use and store these chemicals. In 2007, DHS established this regulatory program, known as the Chemical Facility Anti-Terrorism Standards (CFATS).

Under CFATS, facilities are required to monitor for such chemicals, report possession of chemicals above regulated thresholds, and implement security measures. The areas of concern are theft or diversion of substances capable of being used as a weapon, sabotage or contamination causing explosion or release, or the release as an explosive or a toxic or flammable cloud. DHS has the authority to inspect facilities for compliance with CFATS, impose civil penalties up to $25,000 per day, and shut down facilities that fail to comply with these regulations.

Since the implementation of CFATS, there have been significant advances in technology from a diverse new world of capabilities. In many cases, coordination between safety and security becomes a major strategy, and meetings between these teams may promote best practice deterrents. In the years since the standards were implemented, technologies have advanced. This includes the widespread availability and increased sophistication of drones.

Drones can now be found in a wide variety of shapes, sizes, forms, and capabilities. Identifying the origins of control of these devices and recognizing their presence may be difficult. Drones are not only airborne but can be found in liquid or other environments as well.

The artificial intelligence controlling robots and other invasive machinery is rapidly developing such that we shall soon see robots that can independently achieve a mission without control by a human.

Micro-robots can be dropped into an area where they can move about in a stealth fashion without being noticed.

Hacking into the control systems of facilities is rapidly becoming a major means of inflicting damage and can be accomplished from anywhere on earth and potentially in the future from extraterrestrial control.

Study of the new technologies being researched and developed by the military and foreign governments is helpful for anticipating future developments, and security teams should try to stay aware of information as it becomes available. As issues related to COVID-19 begin to leave the spotlight, now may be a good time to do a reassessment of your areas of vulnerability, as it relates to the chemicals and substances used in your work environments. Looking at some of the new technologies and artificial intelligence should be integrated into your defenses.

Artificial intelligence can be utilized not only on offense but also toward efforts of our safety and security capabilities by taking over much of this responsibility. Even if these capabilities are not yet fully developed, the 5- and 10-year plans of the future should begin to integrate and project areas of development of proper defenses. Let’s tighten things up a bit!

Jacqueline "Jackie" Annis is an industrial hygienist with the Office of Partnerships and Recognition, Directorate of Cooperative and State Programs in OSHA’s National Office.  Jackie’s primary responsibilities include developing and overseeing internal policies and procedures for the VPP, reviewing VPP on-site evaluation reports for process safety management information, serving as the National Office liaison for two of OSHA’s ten Regions, and facilitating the management of OSHA’s National Strategic Partnership Program.  She is an integral part of OSHA’s National Office team. 

She has served with the Agency for 36 years, including five years as a senior industrial hygienist in OSHA’s Office of Health Enforcement, Directorate of Enforcement Programs in the National Office and 17 years as a compliance safety and health officer in the Denver, CO Area Office.  Prior to her tenure at OSHA, Jackie worked as an industrial hygienist for the Department of the Navy in Alameda, California.  Jackie obtained a Bachelor of Science degree from Old Dominion University in Norfolk, VA in 1983.

Wayne Howard earned a B.S. in Chemical Engineering from UC Davis and has spent 12 years with Shell (at Martinez) refinery, 3 years with the consulting firm Process Safety, 15 years with Valero (at Benicia), and the last 10 years in the Corporate Process Safety Department. He is the Valero representative to AFPM's Advancing Process Safety Initiative.

Nathan Obaugh, PE is a senior engineer in the Safety and Operational Excellence Group at NuStar Energy. Nathan has over 10 years of PSM and process design experience in the petrochemical, refining and midstream industries. At NuStar, Nathan oversees all elements of the corporate PSM program and works directly on hazard analysis, process safety studies, PSM/RMP audits and provides process engineering support to the operations and capital projects groups.

Jared Teter, PhD is a senior staff scientist with a background in physics and hazards analysis. He has extensive experience in subscale testing of energetic materials and has served as program manager for several large testing and risk management projects. He has applied engineering and risk management protocols while evaluating the risk associated with propellant and explosives manufacturing, combustible dust, and other hazardous material related processes.

Tim Belitz has a degree in Environmental Health/Industrial Hygiene from Old Dominion University and a Master’s from Duke University. He has over 25 years of Industrial Health Safety and Environmental Experience and is a Certified Safety Professional. He has many years focused on Contractor Management and Process Safety programs.

Rob Walker graduated from Virginia Tech in Microbiology and Chemical Engineering. Rob has almost 35 years of experience working in the chemical plant and refining industry. His passion for Process Safety and Mechanical Integrity began very early in his career. Rob began with his current company, Honeywell, back in 2011.

Prasad Joshi has B.S. and M.S. Degrees in Chemical Engineering from two universities in India. Prasad has over 30 years’ experience in the business. He began with Honeywell in May 2022 as Principal Maintenance Engineer. He has worked internationally in Asia and Europe.