CHEMICAL 

SAFETY

ALERT

United States 

Environmental Protection

Agency

Office of Solid Waste

and Emergency Response

(5104)

EPA-K-550-F00-002

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 dayto-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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C 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.

C 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.

C 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 DAMAGE

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: 

C The chemicals stored at your site; some

chemicals may be particularly attractive targets

because of the potential for greater

consequences if released.

C The location of the site; sites in densely

populated areas may need more security than

those at a distance from populations.

C The accessibility of the site; are the existing

security systems (e.g., fences, security lighting,

security patrols) adequate to limit access to the

site?

C 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.

C 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)(1), 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 ProcessK 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)

C General Duty Clause [Section 112(r)(1) of the

Act] - Facilities have a general duty to prevent

and mitigate accidental releases of extremely

hazardous substances.

C 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

C 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-toKnow Act (EPCRA)

C 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)

C 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)

C Spill Prevention Control and Countermeasures

Plan (SPCC) [40 CFR part 112] - Facilities

storing oil above a certain threshold must
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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/

prepare and implement an SPCC plan. These

plans need to address security elements such as

locks, guards, access, lighting, and vandalism.

OSHA

C General Duty Clause [OSH Act section 654] -

Employers are required to provide a safe

workplace free of recognized hazards.

C 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.

C 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 OSHA 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.