In June 2007, the Chemical Facility Anti-Terrorism Standards Interim Final Rule published by the Department of Homeland Security (DHS) went into effect, imposing new federal regulations for US chemical facilities considered the highest risk to public safety. Under the new rule, such facilities are required to submit an online security assessment used by DHS to determine those sites considered a high risk. These facilities then have a 60 day time period to complete a vulnerability assessment and a site security plan, which are evaluated to determine the level of regulations required at the site. Moreover, those considered of high risk are also subject to a larger number of inspections and audits to ensure that the required standards are adequately implemented and maintained. Facilities that fail to meet these requirements face daily fines or are shut down until security levels are deemed appropriate by DHS (Previous Report).
The Final Rule affects chemical plants, as well as other facilities that contain a defined quantity of particular chemicals. The proposed Appendix A to the Final Rule lists these various chemicals and quantities that would require a site to submit the online survey.
Propane Gas Labeled as “Chemical of Interest”
Among those chemicals listed in Appendix A is propane gas, and facilities with 7,500 pounds (1,785 gallons) or more of the fuel will be required to comply with the new federal regulations. This listing of propane has sparked debate around the country, as the inclusion of the fuel would affect at least 20,000 chicken farms/facilities throughout the US. Propane gas is the most popular method used by poultry farmers for heating chicken houses. Each chicken house is typically attached to a 1,000-1,500 gallon tank.
Some US officials have denounced the inclusion of propane, and the facilities requirement as a waste of government money, stating that chicken houses are not considered a prime target by terrorists. Critics have also maintained that completing the screening process could create economic hardship for smaller, family-owned farms.
Conversely, DHS has indicated that the regulations are necessary to protect the homeland against extremists. Officials in support of the measures have citied the June 2007 foiled plot in London, where officials uncovered two cars containing improvised explosive devices composed of nails, propane, and gasoline. Additionally, homemade bombs with propane tanks have been used in attacks in Iraq.
US Agriculture System Vulnerable to Attack
The proposed regulations have drawn attention to the US agriculture system, of which poultry farms comprise a significant proportion. The raising of poultry is a major industry in many states and an important component of the US economy. Yet despite this central role, such farms and facilities are often not adequately protected and lack appropriate security measures. Such vulnerabilities present opportunities for extremists to exploit these weaknesses and potentially carry out an attack on the US food supply. There are several ways in which an extremist could attack the agricultural system, to include the physical destruction of crops and/or livestock- possibly through the use of chemicals located at the farms.
Moreover, documents uncovered during US raids carried out in Afghanistan after the September 11, 2001, attacks indicate al-Qaeda’s interest in potentially carrying out an attack on the US agricultural system. Among those located were numerous US agricultural documents that were translated into Arabic. Additionally, it is believed that the group is in possession of training manuals that provide detailed information on how to attack crops and livestock with biological weapons.
Moving Forward
While the proposed listing of propane as a chemical of interest would impose strict regulations on numerous farms across the country, such requirements could ultimately be an important step in preventing an extremist attack on the US agricultural system. Additionally, such regulations could also assist in thwarting a strike using chemicals located on these farms against various other targets in the US.
Any attack on the country’s agricultural system would result in significant damage to the US economy, which remains a high priority target for terrorist groups, specifically al-Qaeda. Thereby it is important for heightened security measures to be put in place, primarily at smaller farms that often lack uniform plans and procedures. If the farming industry remains unregulated and lacks adequate security planning, it will leave a large security hole that could potentially be exploited by extremists.