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Executive Summary
As the new home of Illinois PIRG's environmental work,
Environment Illinois can be contacted with any questions regarding this report.
The events of September
11, 2001 have triggered a national reexamination of the security of airlines,
drinking water supplies, nuclear plants, and other areas. Policymakers and industry
have to date inadequately addressed one threat to our communities: the use and
storage of highly hazardous chemicals.
Across America, thousands
of industrial facilities use and store hazardous chemicals in quantities that
put large numbers of Americans at risk of serious injury or death in the event
of a chemical release. One hundred twenty-five (125) facilities each put at
least 1 million people at risk; 700 facilities each put at least 100,000 people
at risk; and 3,000 facilities each put at least 10,000 people at risk. The threat
of terrorism has brought new scrutiny to the potential for terrorists to deliberately
trigger accidents that until recently the chemical industry characterized as
unlikely worst-case scenarios. Such an act could have even more severe consequences
than the thousands of accidental releases that occur each year as a result of
ongoing use of hazardous chemicals.
Frederick L. Webber, president
of the American Chemistry Council, has said “No one needed to convince us that
we could be – and indeed would be – a target at some future date….If they're
looking for the big bang, obviously you don't have to go far in your imagination
to think about what the possibilities are.” The Agency for Toxic Substances
and Disease Registry said in 1999 that industrial chemicals provide terrorists
with “…effective and readily accessible materials to develop improvised explosives,
incendiaries and poisons.”
Fortunately, there are well-established
measures for reducing hazards at facilities – and making communities safer.
An industrial facility could take a range of actions in response to the threat
of terrorism, from switching to inherently safer systems (using safer chemicals
or using chemical in safer quantities or processes) to adding on secondary safety
systems (emergency valves, containment dikes) to adding physical security at
the site.
But the threat of terrorism
requires eliminating or reducing hazards through the use of inherently safer
technologies wherever feasible. Reducing the amount of hazardous chemicals on
site or switching to a safer chemical or process can reduce or eliminate the
possibility of a chemical release. If terrorists continue to use airplanes or
truck bombs, add-on security measures such as safety guards and physical barriers
cannot prevent a chemical release. Similarly, secondary prevention or mitigation
measures, such as safety valves, would be decidedly inadequate in the event
of an attack like those seen on September 11.
Inherent safety is an opportunity
for policymakers to remove a terrorist threat in many cases. This is an option
that is not available for all terrorist risks. Airline passengers have to rely
on increased security to make flying safer. For American industry, however,
many chemicals have readily available safer alternatives, and many facilities
could redesign processes to be inherently safer. The use of chlorine to treat
drinking water is one of the best examples. Chlorine gas is one of the chemicals
most prone to a catastrophic release; the contents of a 90-ton rail tank car
could drift for miles if released, threatening injuries and death. However,
safer options are available, and policymakers can encourage and require industries
to use them. A state program in New Jersey has enabled hundreds of drinking
water facilities to stop using chlorine. In the months following September 11
th , the Blue Plains water treatment facility in Washington, DC, switched from
the use of dangerous chlorine gas to safer sodium hypochlorite. As a result,
no longer can a terrorist trigger a chemical release that could send a deadly
chlorine gas cloud across the nation’s capital.
This paper documents, for
policymakers, advocates, and the general public, the terrorist threat posed
by chemical use in communities and opportunities to make communities inherently
safer. Policymakers should encourage and require companies to reduce chemical
hazards by implementing the following:
1. Require all companies
manufacturing, storing, or using hazardous chemicals in quantities of concern
to conduct an assessment of technology options to evaluate hazards and opportunities
to reduce or eliminate each of them. Companies should be required to explain
regulators why they chose not to implement safer options; regulators should
narrowly limit the acceptable reasons for allowing a risk to remain.
2. Mandate specific inherently
safer technologies where they provide clear alternatives to existing hazards.
A good example is the use of chlorine in treating water, which should be phased
out on the most rapid timeline possible. Policymakers should mandate inherently
safer technologies for the highest-hazard facilities first, such as for the
125 facilities that each put at least 1 million people at risk.
3. Reevaluate current regulatory
programs for chemical risks to take into account the potential for terrorism.
Because even facilities with small quantities of chemicals may be a terrorist
target, policymakers should reconsider the threshold quantities of chemicals
that currently trigger regulation at a specific facility and lower them where
appropriate. Policymakers also should consider whether any industries or chemicals
not currently covered by regulatory programs should be added.
4. Require strict accident
prevention, accident mitigation, and site security measures to minimize the
chance of a successful terrorist attack wherever chemical hazards cannot be
eliminated. It is important that industries using high-hazard chemicals pay
for these programs to internalize the cost of the hazard.
5. Maintain and improve
public access to information about chemical hazards in communities and potential
impacts of chemical releases.
Policymakers at the state
and federal levels can and should enact these policy solutions. In addition,
the Office of Homeland Security and state security agencies should adopt an
inherent safety mandate in all their work with facilities that manufacture,
use, store, or otherwise handle hazardous chemicals.
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