Risk, Hazards & Crisis in Public Policy, Vol. 4, No.

3, 2013

Chemical Sector Security: Risks, Vulnerabilities, and

Chemical Industry Representatives Perspectives on
CFATS
Abdul-Akeem Sadiq
The chemical industry plays an important role in the U.S. economy by producing goods and services
and employing myriads of people. Unfortunately, the U.S. chemical facilities are vulnerable to
terrorist attacks and are located near highly populated U.S. cities. Perhaps, as a result of these two
factors, chemical facilities are attractive targets for terrorists. In recognition of the risks chemical
facilities pose, Congress passed the interim final rule known as Chemical Facility Anti-Terrorism
Standards (CFATS), to better secure U.S. chemical infrastructure against potential terrorist attacks.
The purpose of this article is to understand the perspectives of chemical industry representatives on
CFATS. To accomplish this goal, the author uses information collected from interviews of seven key
individuals from the chemical industry supplemented with secondary information from academic
articles, government reports, and Congressional testimonies. Some of the results suggest that
chemical industry representatives think that the design of CFATS is good, but CFATS
implementation is very slow. The article concludes with recommendations offered by chemical
industry representatives to improve CFATS and a discussion of a broad research agenda for
addressing the risks faced by the U.S. chemical industry.
KEY WORDS:

risk policy and management, disaster planning and preparedness, emergency

management and response

Introduction
The chemical industry, which is considered a critical infrastructure by the
Department of Homeland Security (DHS) (National Research Council
(NRC), 2006) is indubitably one of the most important sectors to the U.S.
economy. The chemical sector constitutes about 1.9 percent of U.S. Gross
Domestic Product (GDP) and employs about a million people (Spellman &
Bieber, 2009). In addition, shipments from the chemical industry are valued at
about $555 billion per year (Environmental Protection Agency (EPA), 2011). There
are approximately 15,000 facilities that store, produce, or use a large amount of
chemicals (e.g., chemical manufacturers and fertilizer facilities) across the U.S.
Unfortunately, the proximity of some of these chemical facilities to high

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Sadiq: Perspectives on CFATS

165

population centers put a myriad of communities at risk of potential terrorist

attacks. According to Paul Orum of the Center for American Progress (2008, p. 7),
more than 80 million Americans in 30 states live within range of a catastrophic
chemical release from at least one of the nations 101 highest-hazard chemical
facilities. If any of these chemical facilities is attacked by terrorists, the ensuing
consequences could pose significant threats to public health, national security,
and the economy (Stephenson, 2005).
There is no gainsaying the fact that the U.S. chemical industry is vulnerable
to terrorist attacks (Sadiq & McCreight, 2013) and that terrorists are interested in
attacking chemical facilities in the United States (Schierow, 2006;
Stephenson, 2005). To reduce the risk of chemical terrorism, some chemical
facility owners have implemented a multitude of chemical security measures
voluntarily (Allmond, 2012) and the federal government likewise has put in place
regulations to protect chemical facilities against potential terrorist attacks
(Stephenson, 2005). One of such regulations is the Chemical Facility AntiTerrorism Standards (CFATS). In 2007, Congress gave DHS a mandate to regulate
chemical facilities. As a result of this mandate, DHS issued the interim final rule
(CFATS) and categorized chemical facilities with threshold quantities of 322
chemicals of interest (COI) into one of four tiers (chemical facilities with the
highest risk level are assigned to tier 1) using a Risk Based Performance Standard
(RBPS) methodology (Beers, 2012; Shea, 2012).1 RBPS measures risk by taking into
account the vulnerability of the facility to an attack, the threat posed to the
facility, and what consequences could ensue as a result of an attack (DHS, 2013).
DHS gave the onus of CFATS supervision to the Infrastructure Security
Compliance Division (ISCD) (Beers, 2012; Shea, 2012).
Researchers have found that the participation of stakeholders in the decisionmaking process leads to higher-quality decisions (Beierle, 2002). Similarly, the
successful design and implementation of CFATS hinge on the participation and
inputs from all CFATS stakeholders (e.g., Congress, industry associations, DHS,
the public, workers, and advocacy groups). CFATS stakeholders can offer
valuable practical insights, lessons learned, and recommendations for improving
CFATS. Such a perspective, no doubt, can reveal valuable information that could
be used by both DHS and ISCD to improve the design and speed up the
implementation of CFATS.
While there are some empirical studies on chemical security (e.g., Kosal, 2006;
Santella & Steinberg, 2011) and chemical regulation (e.g., Lindell, 2007), very few
empirical studies exist on CFATS. The author is aware of only one survey on
CFATS conducted by AcuTech on behalf of American Chemistry Council (ACC)
to assess the progress of CFATS (AcuTech, 2011). Although, this pioneering
survey is a commendable step, more empirical research is needed on CFATS.
Recognizing the need to fill this void, Sadiq and McCreight (2013) have called for
more research on CFATS.
The purpose of this article is to answer the question what are the perceptions
of chemical industry representatives on CFATS? This article focuses on the
perspectives of the chemical industry because the chemical industry is regulated

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by CFATS. As a result, the perspectives of this stakeholder group would be

instrumental in improving the design and speeding up CFATS. Furthermore,
the chemical industry perspectives might help to increase compliance and
enhance the security of the U.S. chemical industry. To answer this research
question, the author interviewed seven key individuals from the chemical
industry. In addition to this primary source of information, the author also
employed secondary information from academic articles, government reports,
and Congressional testimonies to provide background information on chemical
security and CFATS and to provide context for this study.
This article begins by discussing the risk of terrorism with respect to chemical
facilities, the vulnerabilities of chemical facilities, proximity of chemical facilities
to high population centers, and government legislation to protect the chemical
industry against potential terrorist attacks. Then, the article outlines the
methodology and data collection and presents the results of the interviews.
Finally, the article enumerates some recommendations offered by the interviewees
to make CFATS a better program and concludes with a discussion of a broad
research agenda for homeland security and emergency management with regards
to CFATS and chemical security.
Terrorism Risk, Vulnerability of Chemical Facilities, Proximity of Chemical
Facilities to High Population Centers, and Chemical Security Regulations
In this section, the author discusses terrorism risk, vulnerabilities of chemical
facilities, proximity of chemical facilities to population centers, and government
legislation to protect the chemical industry against potential terrorist attacks.
Terrorists Are Interested in Attacking U.S. Chemical Facilities
Some believe that the threat of chemical terrorism is real and that terrorists
are interested in attacking U.S. chemical facilities. For example, the Department of
Justice (DOJ) (2000, p. 2) noted that the risk of terrorists attempting in the
foreseeable future to cause an industrial chemical release is both real and
credible. And more recently, Rep. Edward J. Markey, D-Massachusetts also
corroborated this point by saying that chemical facilities are at the top of the
terrorists target list (Associated Press (AP), 2005).
Terrorists are particularly interested in chemicals that are highly toxic,
flammable, explosive, or have a combination of these features (NRC, 2006).
Terrorists can either attack chemical facilities with the goal of releasing dangerous
chemicals (e.g., ammonia and chlorine) to nearby communities or with the goal of
obtaining chemicals (e.g., hydrogen and butane) that could be used to carry out
attacks at other locations (Schierow, 2006; Stephenson, 2005). With regard to the
former, there has not been a successful direct attack on a chemical facility in the
United States, although in the late 1990s there were two failed attempts on two
chemical facilities (DOJ, 2000) (cited in Schierow, 2006). However, there are
examples of the latter in the United States. On February 1993, Ramzi Yousef and

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his conspirators attacked the World Trade Center (WTC) killing six people and
injuring over a thousand more (Parachini, 2000). One of Ramzis conspirators was
Nidal Ayyad, a naturalized U.S. citizen that worked for Allied Signal as a
chemical engineer (Parachini, 2000). Ayyad used Allied Signal as a cover to order
different types of chemical ingredients used in making the 1,500 pound bomb
that was detonated in the underground parking garage of the WTC
(Parachini, 2000). More recently in 2009, Najibullah Zazi and several others
plotted to bomb the New York City subway using Triaceton Triperoxide (TATP)
bombs. His plot was foiled after he purchased large quantities of chemicals to
make the bombs (Carafano, Bucci, & Zuckerman, 2012). Likewise, in 2012, Khalid
Ali-M Aldawsari tried to purchase a large quantity of chemicals from a Texas
chemical company to make bombs. On his list of possible targets were nuclear
power plants, the homes of three soldiers stationed at the Abu Ghraib prison, and
the former home of President George W. Bush (Blaney, 2012).
Chemical Facility Vulnerabilities
A general consensus is that some U.S. chemical facilities are vulnerable to
terrorist attacks (e.g., Lippin et al., 2006). Against this backdrop, DHS requested
NRC to undertake a vulnerability study of the chemical industry (NRC, 2006), with
the knowledge that a successful terrorist attack on a large chemical facility would
result in loss of lives, injuries, infrastructural damage, contamination of the
environment, disruption of services, economic loss, and threats to national security.
Vulnerability is a broad term that has been the subject of discourses among
experts interested in emergency management and homeland security (e.g.,
Kosal, 2006; NRC, 2006; McEntire, 2009). The author briefly examines four
definitions of vulnerability from four different sourcesan article, a book, and
two government entitiesto illustrate the broadness of this concept. Kosal (2006,
p. 721) defines vulnerability as a measure of the safeguards in place to prevent
an attack from occurring, the ability to respond during an attack and the ability to
mitigate the effects of an attack. According to McEntire (2009, p. 15), vulnerability means a high degree of disaster proneness and/or limited disaster management capabilities. The Federal Emergency Management Agency (FEMA) defines
vulnerability as any weakness that can be exploited by an aggressor or, in a nonterrorist threat environment, make an asset susceptible to hazard damage
(FEMA, 2004, p. SM IV3). Lastly, DHS defines vulnerability as the likelihood
that an attack on a facility will be successful (DHS, 2013). McEntire (2009) argues
that the concept of vulnerability is multi-faceted and these definitions corroborate
McEntires argument. Furthermore, this multi-faceted argument is well captured
by Congressional Research Service (CRS) (2006, pp. 1415) vulnerabilities arise
not only from characteristics of the chemical infrastructure itself, but also from
characteristics of the system within which that infrastructure operatesfor
example, the local environment (e.g., communities, population size, natural
resources) surrounding a plant, pipeline, or transportation channel; the organization and structure of local, state, and national regulatory and response

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capabilities. Applying this multi-faceted argument to chemical facilities means one

aspect of vulnerability exists when a chemical facility has chemical processes, which
are not properly designed and as a result, could be exploited by terrorists to wreak
havoc on both the facility and nearby communities (Spellman & Bieber, 2009).
Another aspect of vulnerability exists when a facility or its surrounding communities do not have the capability to prevent, protect, prepare, respond, or recover
from terrorist attacks (McEntire, 2009). A vulnerability assessment (VA) can help
chemical facilities identify inherent weaknesses that adversaries can exploit (Bajpai
& Gupta, 2005) and the resources needed to respond and recover from potential
terrorist attacks. Due to the likelihood of negative consequences on nearby
communities if terrorists are successful in attacking chemical facilities, it is
imperative that chemical facilities not only put risk-reducing measures in place
within their facilities, but also collaborate with communities (e.g., through Local
Emergency Planning Committees (LEPCs)) to develop appropriate plans to
mitigate, prepare for, respond to, and recover from potential terrorist attacks.
Proximity of Chemical Facilities to High Population Centers
CRS released a report in 2005 on the proximity of chemical facilities to high
population centers based on a 2003 EPA data. According to this report, 111 chemical
facilities are located close to cities with 1 million or more people (AP, 2005). In a
worst case scenario, people within what is considered the vulnerable zone2
could be exposed to toxic gases (Stephenson, 2005, p. 9). Another study conducted
by the Center for American Progress also found that more than 80 million
Americans live within range of a catastrophic chemical release (Orum, 2008, p. 3).
The implication is that a successful terrorist attack on a large chemical facility located
close to an urban center would no doubt result in mass casualties and injuries, in
addition to considerable damage to infrastructure. As a result of the potential
consequence of such an attack, the federal government, the chemical industry,
communities, and other stakeholders should be aware of the risks faced by our
chemical industry and take appropriate steps to safeguard this important industry.
Government Legislation to Protect the Chemical Industry Against Terrorist Attacks
Congress has enacted numerous pieces of legislation in order to protect the
public from both natural and man-made hazards. Examples of these include, but
are not limited to; The Public Health Security and Bioterrorism Preparedness and
Response Act of 2002 (P.L. 107-188), the Maritime Transportation Security Act
(MTSA, P.L. 107-295) (Schierow, 2006), and the interim final rule called CFATS,
which is the focus of this article.
In 2007, Congress mandated DHS to regulate the security of chemical facilities
against potential terrorist attacks. As a result of this mandate, DHS issued an
interim final rule known as CFATS, identified 322 COI, and categorized chemical
facilities into one of four tiers (chemical facilities with the highest risk level are
assigned to tier 1) based on the screening threshold of each of the COI they

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possess (Beers, 2012; Berrick, 2012; Shea, 2012). According to DHS, the selection of
the 322 COI is based on three contexts; the release of chemicals from a facility
that could potentially harm the health or life of individuals, the theft or diversion
of chemicals that could be misused or easily converted into weapons, and the use
of chemicals for sabotage and contamination (Shea, 2012). A facility containing
any of the COI at the threshold quantities is required to submit a Top Screen (a
consequence based screening tool) to DHS, and then DHS will give a preliminary
tier designation to the facility (Spaulding, 2012, p. 3). After assigning a risk tier, a
facility has to submit a Security Vulnerability Assessment (SVA) within 90 days.
After submitting an SVA, DHS reviews the SVA and assigns a final risk tier.
Within 120 days of this assignment, a facility is required to submit a Site Security
Plan (SSP), which details how a facility would go about reducing its vulnerabilities. Once the SSP is submitted, DHS reviews the SSP and carries out an
inspection of the facility. Upon inspection, DHS will either accept or reject the
SSP. If the SSP is accepted, then the facility can implement the security measures
in the SSP (Beers, 2012; Sadiq & McCreight, 2013; Shea, 2012). However, if the SSP
is rejected, the facility would have to make suggested changes and resubmit the
SSP. See Shea (2012) for more information about CFATS and Sadiq and McCreight
(2013) on the achievements and challenges facing CFATS.
Data and Methods
The author used purposive sampling technique (Ireland, Berg, &
Mutchnick, 2010) to identify key chemical industry stakeholders who are
knowledgeable about CFATS, such as individuals in charge of security at
chemical facilities and individuals who represent their trade associations on the
Chemical Sector Coordinating Council. The author attended a meeting organized
by a chemical industry trade association and requested volunteers for an
interview from heads of security at chemical facilities in attendance. Initial
contacts from this group were interviewed and asked to name others in the
chemical industries that are knowledgeable about CFATS and willing to be
interviewed. Using this snowball approach (Yin, 2009), the author interviewed
seven individuals by phone. The interviews, which took 3050 min, were
conducted between August and November 2012. The interview questions
consisted of information about respondents (e.g., their position within their
organization and whether they have chemical security experience), information
about their organizations (e.g. size and function) and information regarding
CFATS and chemical security (examples of these are discussed later in detail).
After completing the interviews, the author typed up the responses and sent
them back to the interviewees to ensure that the information provided was
accurately recorded. It is important to note that it was quite difficult to find
volunteers for the interview despite all the measures that were put in place and
approved by the Institutional Review Board to ensure confidentiality and
anonymity. This difficulty was probably engendered by the sensitivity of the
information requested from the interviewees.

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Results
In this section, the author presents detailed results of the interviews (see
Table 1 for a quick snap shot of industry perspectives on CFATS). Due to the
small number of interviewees, the author did not quote any response directly, but
rather summarized the responses.
1. Do you think the way CFATS is currently designed can help to reduce future
terrorist attacks against chemical facilities? Please explain.
All the respondents except two said that the way CFATS is currently designed
can help to reduce future terrorist attacks against chemical facilities. Two
supporters of CFATS design said that CFATS is making the chemical industry
think more about security and that CFATS is providing more security
enhancements at chemical facilities. The two respondents that had contrary
views said the SSP is a complicated and slow process, among other reasons.
2. Would an extension of CFATS beyond the current year-after-year extension through
appropriations benefit the chemical industry? Please, explain.
All the respondents were of the opinion that an extension of CFATS would
benefit the chemical industry. Although, one respondent would like flaws in
CFATS to be fixed before an extension is granted. Some respondents noted
that an extension would allow long-term planning by chemical facilities and
enable Congress to reaffirm its commitment to CFATS.
Table 1. Summary of Industry Representatives Perspectives of CFATS
Industry Perspective
CFATS can help to reduce future
terrorist attacks against chemical
facilities
An extension of CFATS beyond the
current year-after-year extension
would benefit the chemical industry
DHS implementation of CFATS is poor
or slow
The RBPS are practical and attainablea
DHS Help Desk for CFATS is helpful
Inherently Safer Technologies (IST)
should be added to CFAT
CFATS should be extended to sewage/
wastewater treatment facilitiesb
CFATS compliance entails facility
investments
CFATS is a consideration in closing a
facility
CFATS is a consideration in transferring
operations overseas
a

Agree

Disagree

Not
Applicable

Did Not
Answer

5
5
1

0
0
5

0
0
1

0
2
0

Two respondents had mixed opinions about this question.

One respondent did not have an opinion on this question.

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3. What is your assessment of the implementation of CFATS by DHS?

All the respondents had only negative things to say about CFATS implementation by DHS. Majority of the respondents said the implementation was slow
and behind schedule. Others noted that the implementation of CFATS was
poor.
4. Do you think the RBPS are practical and attainable?
Five of the respondents said that the RBPS are practical and four said they
were attainable. One respondent said the RBPS are not attainable and two
respondents have mixed opinions on whether the RBPS are both practical and
attainable. One of the two respondents who had mixed opinions said the
RBPS could be both practical and attainable if DHS allows each chemical
facility to apply the RBPS to fit their circumstances. In addition, one of the
respondents who said the RBPS are practical and attainable also noted that
DHS needs to resolve RBPS #12 (personnel surety).
5. Have you contacted DHS Help Desk regarding CFATS? If yes, please describe your
experience.
Five of the respondents said they had a positive experience with DHS Help
Desk. According to them, DHS Help Desk was very helpful, receptive, and
positive. However, one respondent who answered also noted that the Help
Desk was only able to answer procedural questions about CFATS and unable
to answer questions on policy issues with regard to CFATS. Two respondents
did not answer this question.
6. What is your opinion about adding the requirements of Inherently Safer Technologies
(IST)3 to CFATS?
Five respondents opposed the idea of adding IST to CFATS. Some of their
arguments are that IST is complicated and technical, DHS has no knowledge
of chemical and manufacturing processes, and that adding IST to CFATS will
overburden CFATS. One respondent said it was a good idea and one
respondent said the question was not applicable.
7. Should CFATS be applied to sewage/wastewater treatment facilities?
Three of the respondents said CFATS should be applied to sewage/
wastewater treatment facilities, while two respondents disagreed. Some of
those that disagreed said that adding sewage/wastewater facilities will over
burden CFATS and that CFATS was already facing many challenges. One
respondent did not have an opinion on this question and one respondent did
not answer this question.

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8. Have you made any investments in your chemical facility in order to comply with
CFATS regulations? Please, explain.
Six respondents said their facilities have made investments in order to comply
with CFATS. For example, one respondent said their chemical facility hired a
24-7 security guard. One respondent did not answer this question.
9. Have you ever considered closing your facility as a result of the compliance cost of
CFATS regulations? Please, explain.
Two respondents said they were considering closing due to the compliance
costs of CFATS, while two respondents said they were not considering closing
their facilities. Two respondents did not respond and one respondent said the
question was not applicable.
10. Have you ever considered transferring your operations overseas as a result of the
compliance cost of CFATS regulations? Please, explain.
Three respondents said they have not considered transferring their operations
overseas as a result of the compliance cost of CFATS regulations. Two
respondents said the question was not relevant to them and two respondents
did not answer this question.

Industry Recommendations for Improving CFATS

This section presents several recommendations put forward by the chemical
industry representatives that were interviewed. Again, due to the small number
of interviewees, the author did not quote any recommendations directly.
First, DHS should increase the level of collaboration with the chemical
industry during the design and implementation of CFATS. The respondents cited
two areas where DHS could benefit from chemical industry input. (i) Risk Based
Performance Standard (RBPS) #12 (Personnel Surety), which requires covered
chemical facilities to verify and validate identity, check criminal history, verify
and validate legal authorization to work, and identify individuals with terrorist
ties (House of Representatives, 2013, p. 103). Respondents consistently mentioned that DHS can resolve the Personnel Surety issue by simply allowing
chemical facilities to meet this requirement through the use of Transportation
Worker Identification Credential (TWIC) cards. TWIC allows personnel to have
unescorted access to secured areas through the use of a tamper-resistant
credential (Transportation Security Administration (TSA), 2013). Although,
Personnel Surety is no doubt a good idea, collaboration with and inputs from the
chemical industry on this issue would help DHS come up with an agreeable and
effective solution. (ii) Site Security Plans (SSPs). Respondents recommended that
DHS should redesign the SSPs with inputs from the chemical industry. The
current SSP is not viewed as an actionable plan, rather it is seen by the chemical

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industry as complex. In fairness to DHS, it is important to note that there have

been some collaborative partnerships between DHS and the chemical industry
(e.g., the Alternative Security Program developed by ACC and approved by DHS
for use by chemical facilities). Nevertheless, more needs to be done to make
industry input part and parcel of the CFATS process and to increase collaboration
between the two parties. After all, collaboration, which is one of the principles of
emergency management, has tremendous benefits to all parties involved (e.g.,
better coordination of resources and increased trust).
Second, DHS should be transparent in the approach used to classify chemical
facilities into tiers. The tiering methodology remains a black box to the industry
(Sadiq & McCreight, 2013), and as a result, some chemical facilities are frustrated.
There are immense benefits of divulging this tiering methodology to chemical
facilities. If chemical facilities are aware of the tiering methodology, they might be
able to alter their chemical processes in such a way that their chemical facility
would be re-assigned into a lower risk tier or no longer be considered at risk. In
addition, chemical facilities might be able to suggest other ways to improve the
methodology. Assuming chemical facilities suggest improvements and DHS
accepts and implements the suggestions, the chemical industry is likely to view
the tiering process as inclusive. Additionally, having the opportunity to contribute to the tiering process will give legitimacy and buy-in from the chemical
industry and ultimately improve the design and implementation of CFATS, and
increase compliance. It is important to clarify that industry representatives are
not clamoring for the tiering methodology to be made public, but that the
chemical industry should be allowed to contribute to the development of the
tiering methodology.
Third, DHS should give the responsibility of determining whether or not a
chemical facility meets the requirements of the RBPSs to a third party.
Respondents said it was not a good idea for DHS to both establish the RBPSs
without industry input and determine the adequacy of the measures put forward
by chemical facilities to meet each of the RBPSs. Respondents suggest that DHS
should learn from EPAs Spill Prevention, Control, and Countermeasures (SPCC),
where professional engineers determine the adequacy of SPCC. In the same vein,
DHS should employ private entities, with expertise in chemical processes and
security to assess the adequacy of chemical facilities measures to address each
RBPS.
Fourth, DHS should develop a professional and knowledgeable cadre of
CFATS inspectors. This particular recommendation is against the back drop of
responses that suggested that CFATS inspectors are not knowledgeable about
chemical processes. One way to address this potential gap in knowledge might be
to provide training to CFATS inspectors on topics related to chemical processes.
Respondents also suggest that DHS should allow its inspectors to visit with
chemical facility owners in a non-enforcement manner. This may allow both
parties to learn from each other.
Fifth, DHS should speed up the CFATS process. The slow pace of CFATS
implementation is something that several respondents identified. Congress and

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industry trade associations both concur with this finding that CFATS implementation is slow. For instance, since 2007, ISCD has assigned 3,468 facilities to their
final tier designations and of these, only 40 have had their plans approved (Beers
& Wulf, 2013). DHS anticipates it will take about seven more years to approve
and complete the inspections for all covered facilities (Shea, 2012). In the face of
the slow implementation, communities should endeavor to work with their
LEPCs to ensure that they are adequately prepared for potential terrorist attacks
against chemical facilities located in their communities. Part of the planning
should include the request of the inventory of chemicals within those chemical
facilities and collaboration with those chemical facilities on mitigating, preparing
for, responding to, and recovering from potential chemical terrorism.
Sixth, respondents recommended that Congress should grant a permanent
authorization to CFATS and DHS should stop making changes to ISCD
management. A permanent authorization and stable ISCD management will reaffirm the commitment of Congress to the success of CFATS. Such a reaffirmation might lead to more investments in chemical security, more compliance with CFATS, and ultimately improve the security of the U.S. chemical
sector.
Conclusion
The chemical industry plays an important role in the U.S. economy by
producing goods and services and employment to many. Unfortunately, according to experts, U.S. chemical facilities are vulnerable to potential terrorist attacks.
To make matters worse, some of these chemical facilities are located close to
highly populated areas. Perhaps, as a consequence of these two factors, chemical
facilities in the United States are attractive targets for terrorists. In an attempt to
reduce this risk and better secure U.S. chemical infrastructure, Congress passed
several pieces of legislation, including CFATS.
The purpose of this article is to answer the question what are the perceptions
of chemical industry representatives on CFATS? To answer this question, which
would serve as a very important ingredient for improving CFATS, the author
interviewed seven representatives of the chemical industry and asked them
several questions about CFATS, as well as recommendations that could help
improve the design and implementation of CFATS. Some of the results suggest
that chemical industry representatives think that the design of CFATS is good,
but that CFATS design can be improved with inputs from the chemical industry.
In addition, all seven representatives said that CFATS implementation is very
slow.
This study has three key limitations. The first limitation is the small number
of interviewees. As noted earlier, it was very difficult to find volunteers for the
interview. This difficulty is understandable due to the sensitivity of the
information requested from the interviewees. The second limitation is the narrow
focusthe perspectives of the chemical industry. There are other important
CFATS stakeholdersCongress, industry associations, DHS/ISCD, the public,

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175

and advocacy groupswhose perspectives could also help to make CFATS a

better program, but whose views were not included in this study. Nonetheless,
the author believes that focusing on the group of stakeholders that are regulated
by CFATS is a good starting point for the discussion and examination of CFATS
stakeholder perspectives on CFAT. Finally, because this study is based on
perceptions, there might be some factors influencing the opinions expressed by
the chemical industry representatives. For example, it is likely that the recommendation of using TWIC cards is a way for the chemical industry to reduce cost. As
a result of these limitations, any attempt to generalize the findings from this
study should be done with caution.
Despite these limitations, the contribution that this article makes in helping to
understand chemical industry perspectives of CFATS is an important first step.
Nevertheless, more needs to be done by the research community to have a better
understanding of not only the chemical industry perspectives but other CFATS
stakeholders perspectives as well. As said earlier, there is very little empirical
research on CFATS, a regulation that has far reaching implications for emergency
management and homeland security. The author hopes that this article will serve
as a foundational study that would spur discourses and research among
emergency management and homeland security researchers on chemical security
in general and CFATS in particular.
There are many unanswered questions in this line of research that may be of
interest to researchers in emergency management, homeland security, and other
related disciplines. First, how can we increase the level of collaboration between
DHS and the chemical industry and between chemical facility owners and local
governments, including first responders? This question is important and relevant
to emergency management and homeland security because collaboration is not
only one of the principles of emergency management; it is also a good practice in
emergency management and homeland security. Second, how prepared are
highly populated areas to potential terrorist attacks on nearby chemical facilities?
Studies that could help shed light on the levels of preparedness in these highly
populated places would be quite beneficial to those communities. Third, what
are the perceptions of other CFATS stakeholdersCongress, industry associations, DHS/ISCD, the public, workers, and advocacy groupson CFATS? These
stakeholders could provide diverse and useful perspectives on CFATS. Fourth,
what specific risk-reducing security measures are chemical facilities adopting as
a result of CFATS? According to some respondents, chemical facilities have
invested in security as a result of CFATS. Perhaps, some researchers might find it
worthwhile to investigate what risk-reducing security measures chemical facilities
are spending their money on. Knowing this may allow us to ascertain whether
those investments are meaningfullead to lower risk or not. Finally, How can
DHS speed up the implementation of CFATS? This question is not only
important, but urgent because of the inherent vulnerabilities of U.S. chemical
facilities and the potential for terrorists to exploit those vulnerabilities. These
aforementioned questions are not an exhaustive list; rather, they are starter
questions for setting the agenda for increased research on CFATS and chemical

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security for researchers interested in risk issues either from the emergency
management and homeland security community or from other disciplines. This
study and others to come will hopefully help to make this very important
regulationCFATSa better program that can reduce the inherent vulnerabilities
of the U.S. chemical industry and safeguard the U.S. populace from potential
terrorist attacks.
Dr. Sadiq is an Assistant Professor in the School of Public and Environmental
Affairs at Indiana University Purdue University Indianapolis. He teaches
undergraduate and graduate courses in emergency management, public safety
management, and terrorism.

Notes
1. For more information on COI see http://www.dhs.gov/xlibrary/assets/chemsec_appendixafinalrule.pdf.
2. Vulnerable zones are determined by drawing a circle around a facility with the radius of the
circle equal to the distance a toxic gas cloud would travel before dissipating to relatively harmless
levels (Stephenson, 2005, p. 9).
3. The idea of IST is to build safety into processes and technologies to reduce or eliminate hazards, as
opposed to adding on safety measures to simply control hazards (American Chemical Society,
2012).

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