Core Practices: Homeland Security: What is Your Role?

We cannot go back to before 9/11. We can, however, move forward and eventually reach a more secure post 9/11 world. We will achieve this through a combination of measures, such as being better prepared to prevent, or react to, a terrorist attack. More importantly, we can continue to do our part in developing a sustainable world, and establishing a better quality of life and environment needed for a more secure world.

Environmental health and safety (EHS) professionals have essential skills needed for homeland security efforts. The industrial hygiene profession, for instance, is based on the anticipation, recognition, evaluation and control of factors arising from the work environment that affect the health and well being of workers and the community. This same framework is uniquely suited to position the profession on the frontline of anti-terrorism efforts related to emergency preparedness and response activities. Our experience with intentional defeat of environmental and safety measures put in place on the job will be helpful, but we will be learning new skills via working with law enforcement, military and security professionals to address new levels of intent to harm. This is not a new issue for the profession, but an expansion of skills used in the past. What is new for EHS is the strategic and planning focus to look at purposeful rather than accidental occurrences, and what the impacts and protective measures to prevent occurrences could be.

For industrial hygienists, the issue of anti-terror activities emerged when the American Industrial Hygiene Association's Environmental special interest group (EnviroSig) convened its first meeting in 1996. While anti-terror professional skills were not a priority amid all the issues the new EnviroSig addressed, members recognized that industrial hygiene had a role to play in this area.

After the attacks on U.S. Department of State facilities in Africa in 1998, industrial hygienists were part of the initial response team. This activity was notably reported by Andrew Rahaman (AIHA Synergist, October 1999), who was active in initial clean-up and follow-up activities. He outlined a risk management approach to anti-terror activity applicable to EHS professionals. Many of the lessons learned are still applicable today and have been incorporated into new instruments for assessing vulnerabilities to terrorist attack. His proactive approach consisted of three major areas:

Establish a multi-disciplinary proactive risk management team (support services, personnel, community and communications)
Analyze capabilities and hazards
Develop a risk reduction plan.

In 2001, Joselito Ignacio led a panel at the American Industrial Hygiene Conference and Exposition (AIHCE) that examined issues and skills required to react to chemical-biological terrorism. The session, held four months before 9/11, was standing room only. His work and those of other colleagues has evolved into a new course on this subject that was offered at AIHCE 2003.

Immediately after the 9/11 attacks, OSHA Assistant Secretary John Henshaw sent a call for assistance, and the AIHA and many suppliers of EHS equipment responded admirably. EHS professionals of all stripes served well and the lessons learned have propelled us forward to meet new threats. After 9/11, EHS professionals (based primarily in the Washington area) from OSHA, NIOSH, Department of Defense, Centers for Disease Control, Veterans Administration and the private sector, assisted in exposure assessment, worker protection measures, safe decontamination and clearance assurance for re-entry activities after the anthrax letters were delivered to the Hart Senate Office Building and the Brentwood postal facilities.

Where Are We Now?

AIHA recently identified emergency preparedness and response related to homeland security as its number one issue. It is likely other EHS professional groups also will make this issue a very high priority.

The actual roles of EHS professionals will be determined from the resources allocated by federal, state and local governments and from the private sector to homeland security. We will volunteer as good citizens where we can, but in the big picture, what gets paid for gets done. It will be up to EHS professionals to expand their role where needed and make their services available to new markets and clients in homeland security areas. Table 1 lists some areas where EHS professionals may have roles in homeland security.

At the federal level, the new Department of Homeland Security will receive funding of nearly $37 billion in fiscal 2004, an increase of 60 percent from 2002. The department expects to add 61,000 staff, bringing it up to 179,241 employees. In areas of interest to EHS professionals, $500 million will be allocated to assess the nation's critical infrastructure and assess vulnerabilities. Some $350 million has been allocated for research, development and testing of capabilities in such areas as nuclear and biological terrorism detection. Congress appropriated $3.5 billion for the Office of Domestic Preparedness for first responder education and equipment; $500 million of this will be direct aid to firefighters and $500 million will support state and local law enforcement anti-terror activities.

EHS professionals are employed within many of the 13 critical infrastructure areas, such as public health, energy and water, identified as priorities by the Homeland Security department. One, the $450 billion chemical industry, employs many EHS professionals and offers opportunities if voluntary and perhaps new regulatory Homeland Security measures increase in the future.

In March 2003, the General Accounting Office (GAO) issued a report on the preparedness of the chemical industry in the event of a terrorist attack. It concluded the chemical industry has undertaken initiatives to address security concerns at chemical facilities, but challenges remain.

For example, the American Chemistry Council, which covers approximately 1,000 (or about 7 percent) of the 15,000 facilities subject to EPA Clean Air Act's risk management plan (RMP) provisions, now requires its members to conduct security vulnerability assessments and implement security improvements. ACC's security code generally requires that third parties, such as insurance representatives, local emergency responders or local law enforcement officials, verify that improvements have been implemented. The code does not require third parties to verify that vulnerability assessments are conducted appropriately or that the actions taken by the facility adequately address security risks. The highest-risk ACC member facilities must complete the process by December 2003.

GAO noted that according to industry officials, chemical companies are challenged to achieve cost-effective security solutions because they must weigh the cost of implementing countermeasures against the perceived reduction in risk. Industry groups whom GAO interviewed indicated their members face the challenge of effectively allocating limited security resources. Each facility must determine what constitutes a reasonable level of security against known or suspected threats.

GAO concluded despite voluntary industry initiatives, the extent of security preparedness across the chemical industry is unknown. The Secretary of Homeland Security and the EPA Administrator have stated voluntary efforts alone are not sufficient to assure the public of industry's preparedness. They support bipartisan legislation requiring the 15,000 chemical facilities nationwide containing large quantities of hazardous chemicals to comprehensively assess their vulnerabilities and reduce them. GAO recommended:

"...that the Secretary of Homeland Security and the Administrator of EPA jointly develop, in consultation with the Office of Homeland Security, a comprehensive national chemical security strategy that should:

Identify high-risk facilities based on factors including the level of threat and collect information on industry security preparedness;
Specify the roles and responsibilities of each federal agency partnering with the chemical industry;
Develop appropriate information sharing mechanisms; and
Develop a legislative proposal, in consultation with industry and other appropriate groups, to require these chemical facilities to expeditiously assess their vulnerability to terrorist attacks and, where necessary, require these facilities to take corrective action."¹

The last bullet is significant. How these new requirements will be paid for is key to their success. Will resources come directly from the federal government, similar to traditional defense appropriations to private sector contractors and industry, or will new regulations instead be paid for by transfer of costs to chemical customers? In the current tight economy, it is safe to say unfunded mandates will be ineffective.

On a city level, Baltimore passed an ordinance addressing the threat of terrorism that requires chemical manufacturers to follow safety and security regulations devised by its fire and police commissioners. Companies that fail to comply may face the withholding or suspension of facility operating permits.

Volunteer education and community awareness at a local level will be a growing need where IH and EHS professions play a significant role. At my home county level, I helped set up and moderate a panel of experts at a recent Prince William County meeting on what the average citizen can do to protect themselves against terrorism and an update on our county preparedness activities. Our panel consisted of members of the local chapter of the American Red Cross, our county emergency response coordinator, our new bioterrorism coordinator, a public information specialist and a public health physician/anti-terror expert from George Washington University.

Recently, all members of the AIHA Washington (Potomac) section were invited to voluntarily participate in a CDC-sponsored project to develop new, smarter databases on agents likely to be encountered in a terrorist event by first responders. My expectation is that many industrial hygienists and EHS professional have been, or will be, asked to perform similar functions in the near future in their communities.

Looking Ahead

In the future, we face three major roles for EHS professionals. They are direct prevention activities, direct reactive activities and indirect preventive activities. Many EHS professionals will be operating to some extent in all three. The first two, direct preventive and reactive activities, are more traditional, immediate and build upon skills we currently use.

Indirect preventive activities are far more important, yet have not received much attention within the EHS literature.

Advocates recently have focused attention on the need for the United States and the developed world to play a bigger role in environmental security and the eradication of human ills that lead to unstable societies, international tensions and the fostering of terrorism. New York Times columnist Thomas L. Friedman recently said at a lecture titled "American Foreign Policy After 9/11:"2 "the first thing we (U.S.) need to do, we need to be the best global citizen we can be...but when it comes to a war for a greener planet, a war against global warming, (we say) sorry, taking a powder, not with you, driving my humvee. We are either tending to the world in all its aspects or we are not tending to the world."

The entire U.S. commitment of aid for environmental problems at the 2002 United Nations Johannesburg Environmental Summit, including assistance for problems such as AIDS in Africa, electrical energy and water in sub-Saharan Africa and global biodiversity, amounted to a little over $3 billion. This total outlay roughly equals the appropriation under the new Department of Homeland Security for firefighters and police for equipment and training.

Professions and people that build a sustainable world environmentally, economically and equitably are needed now more than ever. Environmental security, including healthy and safe workplaces, and fair global trade are key factors in attaining a secure world. The results from traditional and new EHS activity reduce the drivers of anger at the West and developed nations. All of us are part of a fundamental transformation in environmental sustainability that will make the world more secure. As awareness grows of the value of international EHS practice as a means to build nations that make us more secure by assisting others to attain adequate environmental infrastructure, perhaps more resources will be directed to this end.

John F. Meagher, CIH, is deputy director of the International Center for Environmental Technology (INTERCET Ltd.) in McLean, Va. He can be reached by e-mail at [email protected], by telephone at (703) 734-1454 or by fax at (703) 734-3241.

¹ "Homeland Security: Voluntary Initiatives Are Under Way at Chemical Facilities, but Extent of Security Preparedness Is Unknown." GAO-03-439, March 14. www.gao.gov/cgi-bin/getrpt?GAO-03-439