RBC Shield, LLC

"The Complete WMD Protection Solution"


"The problem you have in an open society is that it's physically impossible to make any large industrial site terrorist-proof. If there are enough terrorists who are dedicated enough and equipped well enough, they're going to overwhelm everything that you put up short of some sort of Fort Knox - which doesn't make much sense, given the cost and the relatively remote possibility that any specific site is going to be targeted."1

DHS has identified 3,400 facilities that it believes pose the greatest hazard to human life and health in the event of a terrorist attack. These sites are primarily those that pose inhalation hazards and very high-order flammables and explosives.2

This number is more than 30 times the number of nuclear power plants in the country; and these 3,400 plants are potentially more lethal than the nuclear power plants because of the inability of most chemical facilities to contain a toxic release. One has only to recall what happened at the Union Carbide plant in Bhopal, India where the release of 46 tons of methyl isocyanate into the air, killed an estimated 15,000 (some say many thousands more) and injured more than 150,000.3 Union Carbide claims the release was the result of sabotage.4

Counter-terrorism experts shudder to think about the number of deaths an intentional release of a toxic chemical could cause. The EPA has warned that a terrorist attack on any one of 111 U.S. chemical facilities located in densely populated areas could expose 1 million people to toxic chemicals. An attack on any one of 700 other U.S. facilities could threaten at least 100,000 people each. And an attack at any one of 3,000 other chemical sites in this country could affect 10,000 people each.5

Until June of 2007, there were no government security standards for the chemical manufacturing industry.6 All security measures were voluntary. Even now, under the new law that took effect in June, there will be no minimum standards. There will only be mandatory areas of vulnerability that the facility must address in its Site Security Plan. How the facility addresses the vulnerabilities will be determined by the facility.


In 1999, the Agency for Toxic Substance and Disease Registry (ATDSR) which is part of the Department of Health and Human Services developed a 10-step procedure to analyze, mitigate, and prevent public health hazards resulting from terrorism involving industrial chemicals. This study was conducted in only two cities in the U.S., but the study located a multitude of "soft targets" in these two cities where toxic substances could be removed and potentially used in a terrorist attack.

"Soft target" sources of chemicals that were located in the two communities mentioned above included:

  • Chemical manufacturing plants (chlorine, peroxides, other industrial gases, plastics, and pesticides)
  • Food processing and storage facilities with large ammonia tanks
  • Chemical transportation assets (rail tank cars, tank trucks, pipelines, and river barges)
  • Gasoline and jet fuel storage tanks at distribution centers, airports, and barge terminals
  • Compressed gases in tanks, pipelines, and pumping stations
  • Gold mines where cyanide and mercury compounds are used
  • Pesticide manufacturing and supply distributors
  • Educational, medical and research laboratories7

The report made the following comment concerning the security at the chemical plants in these two communities:

"Security at chemical plants ranged from fair to very poor. Most security gaps were the result of complacency and lack of awareness of the threat. Chemical plant security managers were very pessimistic about their ability to deter sabotage by employees, yet none of them had implemented simple background checks for key employees such as chemical process operators."8

At present, there is little to indicate that much has changed. The voluntary "Responsible Care" Security Code issued by the American Chemistry Council is very general and addresses high-level management practices. As such, it does not deal with any specific security measures that should be implemented at any facility.


  1. Kriz, Margaret. "Bush Not Doing Enough to Protect Chemical Plants, Critics Contend," National Journal, August 7, 2003. Article re-printed at: http://www.govexec.com/dailyfed/0803/080703nj3.htm. Quote attributed to Joe Barton, chairman of the House Energy and Commerce Sub-committee on Energy and Air Quality.
  2. "Homeland Security: DHS Is Taking Steps to Enhance Security at Chemical Facilities, But Additional Authority is Needed," GAO-06-150, January 27, 2006, pg. 20-21.
  3. "Rallies held over Bhopal disaster," 12/04/04: BBC NEWS: http://news.bbc.co.uk/2/hi/south_asia/4064527.stm
  4. Hindustan Times, July 21, 2016
  5. "Study: 100 chem plants could be terrorist targets," July 6, 2005, Associated Presss via MSNBC.
  6. On October 4, 2006, the DHS Appropriations Act of 2007 was signed into law. The law (Section 550) gave DHS the authority to issue regulations establishing risk-based performance standards for security of chemical facilities that present high levels of security risk. The "interim final rule" was published on April 2, 2007 and became effective on June 8, 2007 (6 CFR 27).
  7. Mark M. Bashor, and Hugart, CDR Joseph L., "Industrial Chemicals And Terrorism: Human Health Threat Analysis, Mitigation And Prevention," Agency for Toxic Substances and Disease Registry, U.S. Public Health Service, 1999
  8. Ibid.