(June 23, 2003) — I am writing on behalf of the members of the American Chemistry Council to inform you about the leadership role our members have taken in securing our nation's critical infrastructure against terrorist attacks. Safety and security always have been primary concerns of ACC members, and they have only intensified their efforts since Sept. 11, 2001, working closely with government agencies to improve security and defend against any threat to the nation's critical infrastructure.
We have undertaken numerous activities — within individual companies and with our downstream partners — without waiting for the government to act. The purpose of this letter is to provide you with information about our Responsible Care Security Code, key issues in the legislative debate, security enhancements our members have taken at their facilities and our support for federal legislation. In doing this, we hope it will help you to better serve and inform your readers.
ACC's mandatory Responsible Care Security Code, adopted in June 2002, requires member companies to prioritize their sites by degree of risk, assess vulnerabilities, implement security enhancements and verify these mea-s— ures through third parties. It is important to note that ACC had been working on site security and transportation security guidelines prior to Sept. 11, and within weeks after Sept. 11 had these guidelines in place and was helping members to enhance their own security. The members also agreed to take additional steps culminating in the board's approval of the new security code in June 2002.
ACC's security program has been widely recognized by security and government officials as a model for other industries to follow. To be specific, Tom Ridge, secretary of Homeland Security, refers to our security code as a model industrial security program. The FBI has complimented ACC on its security initiatives and has expressed its appreciation for our working in close partnership with it. The General Accounting Office in its March report on homeland security acknowledged and commended ACC's efforts. Finally, Sen. Jon Corzine, D-N.J., a principal proponent of legislation to enhance chemical security, cites ACC's “laudable” security program in his fact sheet on his position.
We have been committed to working with law enforcement and first responders to ensure the security of our employees and our communities. Therefore, I must point out that media reporting of “worst-case scenario” information has been extremely misleading. According to the Environmental Protection Agency, the “worst-case scenarios” were intended to be used as planning tools to ensure community preparedness and emergency planning, not to be predictive. (“Who's Afraid of the Big, Bad RMP?” Craig Matthiessen, U.S. EPA, Chemical Emergency Preparedness and Prevention Office). So, rather than identifying potential nightmare scenarios, the “worst-case scenario” should be regarded as an insurance policy for ensuring a community's safety and preparedness.
As you reported in your May 12, Page 6 Viewpoint, certain parties are advocating that chemical security legislation should contain requirements that would make companies substitute alternative chemicals in their manufacturing processes, frequently known as “inherently safer technologies.” We believe reducing risk at our facilities is a complex process of balancing risks and benefits to ensure that total risks are reduced, and that the needs of customers, suppliers and the community are met. Judgments about how best to manage risk and secure facilities are anything but simple and are not well-suited to government decision-making processes.
We are committed to working with government partners to safeguard chemical facilities from the threat of terrorism. For example, ACC has signed an agreement with the FBI to create the Chemical Sector Information Sharing and Analysis Center to share security information daily among national law enforcement and security agencies and the companies that make and use chemical products. Further, member companies of ACC are working closely with local law enforcement, and their business partners, to protect their communities and individual plants. While specific actions vary from facility to facility, the following are some examples of what is being done to enhance city security:
* Adding security personnel and law enforcement officers.
* Increasing inspection of fencing and gates.
* Making improvements where needed and installing computerized access controls.
* Fortifying computer process control systems.
* Conducting bioterrorism response training for emergency responders.
We agree wholeheartedly with statements made in your editorial that legislation needs to be put in place to reassure all Americans about the security of all facilities handling large amounts of hazardous chemicals. The ACC and its member companies strongly encourage Congress and the administration to guarantee the federal government has oversight of security at chemical plants and enacts strong mandatory safety standards for every plant in the nation. Upward of 30 percent of chemical plants are already covered by such legislation with the recently passed Maritime Transportation Security Act. We believe that legislation addressing the remaining chemical facilities should be based on a security model — such as that established through the MTSA. Such a program would require asset identification, vulnerability assessment, countermeasure implementation, security plans, and enforcement to compel such action.
As I said at the outset, ACC has taken a leadership role to further ensure that our facilities are secured against the terrorist threat. The events of 9-11 have only strengthened our commitment to providing the countless products that make our lives better, healthier and safer, while securing our facilities, our employees and our communities against outside attack. I hope this helps clarify ACC's position on this important national issue and our commitment to ensuring the security of our nation's critical infrastructure.
Lebedev is president and chief executive officer of Arlington, Va.-based ACC.