Chemicals of Security Concern: Security Overview and Expected Policy
Developments
Dr Angelo Valois – Director, Chemical Security Risk Assessment Unit, Attorney-General’s Department
Introduction
The production and use of chemicals within Australia is ubiquitous and, in the vast majority of instances, legitimate and socially beneficial. However, common chemicals may be misused by terrorists with catastrophic consequences to Australians and Australian interests. Indicatively, there are over 40,000 chemicals approved for use in Australia; however, based on their properties and ease of use only a small number have been assessed as posing a potential terrorist threat.
The relatively minor risk of chemicals being used in terrorist attacks is counterweighted by the devastating consequences which flow from these incidences. Successful policy responses to this risk are faced with a difficult challenge – how do you protect legitimate and necessary use of common chemicals while reducing the terrorist threat from these same chemicals? The Australian Government, in partnership with States, Territories and industry, is taking steps to manage the risk posed by violent extremists accessing and misusing ‘chemicals of security concern’.
Interaction with broader counter terrorism strategies
It should further be noted that the work in preventing terrorist access to chemicals of security concern is a small part of Australia’s efforts to prevent, detect, prepare for and respond to terrorism. The Chemicals of Security Concern Program (Program) complements law enforcement and intelligence efforts to combat the misuse of chemicals by terrorists.
The threat environment and government response
The 2002 Bali Bombings represent the largest loss of life by Australian citizens in a terrorist incident. In the attack on 12 October 2002 terrorists detonated three improvised explosive devices killing 202 people, 88 of whom were Australian citizens. In December 2002, the Council of Australian Governments (COAG) agreed to a national review of the regulation, reporting and security surrounding the storage, sale and handling of hazardous materials. This work was divided into four parts:
ammonium nitrate
radiological sources
harmful biological materials, and
hazardous chemicals (chemicals of security concern).
The review of chemicals of security concern was the latest of these four reviews. The Report on the Control of Chemicals of Security Concern (Chemicals Report) identified 96 chemicals of security concern
(Attachment A). The Report recommended that COAG agree to a Chemical Security Management Framework (Framework) that included:
a process for the ongoing identification of security risks associated with specific chemicals, groups of chemicals or components of the supply chain of potential security concern. The process was also to identify appropriate controls to assist with managing these risks
the development of capability building measures for the community, industry and governments that seek to prevent the use of chemicals for terrorist purposes, and
appropriate management and governance arrangements.
COAG agreed to this recommendation and in October 2008 finalised its Agreement on Australia’s National Arrangements for the Management of Security Risks Associated with Chemicals (Intergovernmental Agreement). The Intergovernmental Agreement outlines a risk based approach to responding to the risks posed by chemicals of security concern.
Risk assessment
Half the battle is understanding the problem. Failure to do this properly is one of the most common causes of policy failure and poor regulation.
Gary Banks AO, Chairman, Productivity Commission Effective treatment of the security risk posed by chemicals of security concern requires a rigorous and realistic assessment of the risk environment at all stages of the supply chain. The ubiquitous use of chemicals creates significant and complex challenges in effectively understanding the flow of risk throughout the supply chain. The Chemicals Report recommended that a principled approach to assessing the security risk of chemicals of security concern based on the Australian and New Zealand Standard AS/NZ 4360:2004 – Risk Management (and its successor standards).
The Chemical Security Risk Assessment Unit (CSRAU) within the Attorney-General’s Department has
developed, in conjunction with consultancy firm Booz and Co Australia, a Chemical Security Risk Assessment Methodology (CSRAM) tool to assist in assessing the security risk posed by the diversion of security sensitive chemicals from the legitimate supply chain for use by terrorists. The CSRAM examines specific chemicals and/or Derived Hazardous Chemicals1(DHCs) from a number of perspectives including:
impact
employability
level of security concern, and
supply chain vulnerability
1In addition to assessing a specified chemical, a critical foundation of the CSRAM is the concept of the Derived Hazardous Chemical (DHC); that is, a chemical of potential security concern may not be particularly dangerous, but it may be used to create more hazardous compounds.
The diagram below outlines the relationships between each element:
Impact
This element of the CSRAM assesses the potential of the chemical and/or the DHC to cause harm. This measure is predominantly based on human lethality. Impact is calculated for both explosive and/or toxic impacts.
Explosive impact – the explosive impact is calculated by considering both the explosive power, the velocity of detonation of the chemical and/or DHC and the deployment scenario contemplated in the risk assessment.
Toxic impact – a toxic lethality score is calculated by considering the exposure mode, the exposure route, the acute toxicity hazard of the chemical and the deployment scenario contemplated in the risk assessment.
Impact also considers modifying factors which allow for broader considerations of public anxiety or disruption, or significant non-lethal effects.
Employability
Employability measures the usefulness of the chemical and/or DHC under realistic conditions and is assessed against toxic2and/or explosive exposure modes. Data incorporated into the assessment considers the real world employability of the DHC, the ease of conversion of the precursor to a DHC and the deployment scenario contemplated in the assessment.
Level of security concern
The level of security concern (LSC) assesses the threat and relative interest to acquire and deploy a given chemical and/or DHC. The LSC is expressed according to three levels:
Most Security Concern
2Inhalation, ingestion and physical contact
Moderate Security Concern, and
Least Security Concern.
Vulnerability
Vulnerability is the ease by which a useable quantity of the chemical can be diverted from a given point in the legitimate supply chain. Vulnerability is determined for each point in the supply chain and considers any existing controls and/or industry practices aimed at preventing unauthorised access to, or misappropriation of, a chemical.
The legitimate supply chain is as follows:
Supply Chain Node Description
Introducer The first point in the supply chain. Introducers either import the chemical or manufacture the chemical at a facility in Australia.
Transport / Logistics Multiple points in the supply chain, includes transport and storage of chemicals.
Processor Processors reformulate or repackage the chemical. The chemical and/or reformulated product will then be on-sold to wholesalers, retailers and/or end users.
Wholesaler Sell primarily to businesses and institutions and do not repackage or reformulate the chemical.
Retailer Sell primarily to individuals and do not repackage or reformulate the chemical.
End User (business) Consume the chemical in their business/industrial/institutional processes. Do not on-sell the chemical or any products that contain the chemical. Does not apply to domestic/home use.
Industry engagement
Finalised draft risk assessments are then reviewed by a Technical Working Group (TWG), comprised of State and Commonwealth government and industry representatives. Following review, the results are presented to the NGAG for endorsement. Following NGAG endorsement, the results are also presented to the National Industry Reference Group (NIRG) for their information.
Approach to risk management
Flowing from the completed risk assessments of hydrogen peroxide, nitric acid, potassium chlorate and sodium chlorate, work is currently being conducted to develop targeted risk management strategies.
Approach to risk management
Australia’s approach to securing chemicals of security concern is outlined at a strategic level by the Framework.3 Risk management strategies must be in furtherance of one or more ‘targeted security outcomes’, namely:
community – an informed and vigilant community that is able to assist jurisdictional police and security agencies in deterring, and/or detecting the use of chemicals for terrorist purposes
3Note: the Chemical Security Management Framework is a schedule to the Intergovernmental Agreement.
industry – an informed and vigilant industry that understands the security risks associated with the use of chemicals for terrorist purposes and has appropriate measures in place to prevent, detect and deter such use
government agencies – informed agencies that act, in partnership with industry and community, in a coordinated manner to manage the security risks from the use of chemicals for terrorist purposes, and
chemicals – appropriate security around priority chemicals of security concern.
In addition, measures developed to achieve the targeted security outcomes must take account of the following guiding principles:
control measures should be proportionate to the assessed risk of the use of chemicals for terrorist purposes
the development of strategies for control measures should be nationally coordinated and nationally consistent
control measures should, where possible, be built on existing industry and/or government arrangements
proposed measures should be cost effective and subject to a cost benefit analysis
control measures should be developed in partnership between government and industry so that appropriate knowledge and needs can be effectively and efficiently integrated, and
Australia should take account of arrangements applied in other countries that do not restrict industry competitiveness or the trade of chemicals.
Risk Management Working Group
The Risk Management Working Group (RMWG) was formed in May 2010. The RMWG is comprised of representatives from the Australian Government, State and Territory governments, industry associations and industry. The aim of the RMWG is to, under direction of the National Government Advisory Group, provide advice and assistance to the NGAG on the range of risk management measures available on identified chemicals of security concern. The inaugural meeting of the RMWG was held on 23 June 2010 in Sydney.
Risk management in the chemicals of security concern context involves consideration of two related but distinct concepts:
the actual risk management measures to be implemented, and
the implementation framework (for example, codes of conduct, standards, legislation).
Discussions concerning potential risk management strategies are ongoing.
Retail Sector Risks
The CSRAM has identified a VERY HIGH vulnerability for hydrogen peroxide at the retail node of the supply chain. On 3 August 2010, AGD facilitated a meeting with key retail organisations to generate ideas to reduce the security risk posed by hydrogen peroxide at the retail node of the supply chain. The key outcome from this meeting is that AGD, in partnership with the Australian National Retailers Association and the Pharmacy Guild of Australia will work to identify, develop and implement risk management strategies utilising existing processes where practicable.
Public Awareness
Public Awareness – Phase One
The Chemicals of Security Concern Awareness Campaign (the Campaign) aims to inform and build vigilance across the target audience to assist jurisdictional police and security agencies in deterring, and/or detecting the use of chemicals. It is intended to be low-key (non alarmist) but informative with a focus on educating and fostering relationships with industry to assist them in strengthening their security arrangements, and communicating broadly with the community.
Phase One of the Campaign was launched by the Attorney-General on 3 December 2009. It serves to raise awareness among industry and the general public that everyday chemicals can be misused by terrorists. It also encourages both industry and the public to report suspicious activity to the National Security Hotline.
The Campaign comprises of tailored brochures and posters for industry and consumers; and a dedicated website<www.australia.gov.au/chemicalsecurity> (for poster examples see Attachment B). Advertising was undertaken in May/June 2010 and consisted of national metropolitan press and online search advertising.
The success of Phase One is currently being reviewed.
Public Awareness – Phase Two
Phase Two of the Campaign is in the initial stages of development. As more specific information concerning supply chain vulnerabilities is available from risk assessment data, AGD expect to develop a more targeted campaign.
Further resources
www.australia.gov.au/chemicalsecurity www.coag.gov.au
Acknowledgement
I would like to acknowledge the invaluable assistance that the Fertilizer Industry Federation of Australia has given throughout the risk assessment process and current development of risk management strategies. In particular, the continued engagement by Mr Nick Drew has been particularly valuable in the work of Chemical Security.
ATTACHMENT A – Chemicals of Security Concern
A Aldicarb
Ammonia (anhydrous) Ammonium nitrate*
Ammonium perchlorate Arsenic pentoxide Arsenic trioxide Arsine
Azinphos methyl B
Bendiocarb Beryllium sulphate Bromine
C
Cadusafos Carbofuran Carbon disulphide
Carbon monoxide
Chloropicrin
Chlorfenvinphos Chlorine gas Cyanide calcium Cyanide mercury Cyanide potassium Cyanide sodium Cyanide zinc Cyanogen bromideCyanogen chloride
DDiazinon Dichlorvos
CAS # 116-06-3 7664-41-7 6484-52-2 7790-98-9 1303-28-2 1327-53-3 7784-42-1 86-50-0
22781-23-3 13510-49-1 7726-95-6
95465-99-9 1563-66-2 75-15-0 630-08-0 76-06-2 470-90-6 7782-50-5 592-01-8 592-04-1 151-50-8 143-33-9 557-21-1 506-68-3 506-77-4
333-41-5 62-73-7
E
Endosulfan Ethion
Ethyl mercury chloride Ethyldiethanolamine F
Fenamiphos Fluorine gas Fluoroacetic acid Fluoroethyl alcohol Fluoroethyl fluoroacetate H
Hydrochloric acid Hydrogen chloride
Hydrogen cyanide
Hydrogen peroxide Hydrogen sulfide MMercuric chloride Mercuric nitrate Mercuric oxide Mercurous nitrate Methamidophos Methidathion Methiocarb Methomyl
Methyl fluoroacetate Methyldiethanolamine Mevinphos
CAS # 115-29-7 563-12-2 107-27-7 139-87-7
22224-92-6 7782-41-4 144-49-0 000371-62-0 459-99-4
7647-01-0 7647-01-0 74-90-8 8007-30-5 7783-06-4
7487-94-7 8046-70-6 8028-34-0 7782-86-7 115182-35-9 950-37-8 716-16-5 16752-77-5 453-18-9 105-59-9 7786-34-7
O
Omethoate Osmium tetroxide Oxamyl
P
Paraquat
Parathion methyl Perchloric acid Phorate Phosgene Phosphide Al Phosphide Mg Phosphide Zn Phosphine Phosphorus
Phosphorus oxychloride
Phosphorus pentachloride
Phosphorus trichloride
Potassium chlorate Potassium nitrate Potassium perchlorate PropoxurS
Sodium azide Sodium chlorate Sodium fluoroacetate Sodium perchlorate Sodium nitrate Strychnine
Sulfur dichloride
Sulfur monochloride
Sulphuric acidCAS # 1113-02-6 7446-13-1 23135-22-0
2074-50-2 63653-66-7 7601-90-3 298-02-2 75-44-5 8005-48-9 12057-74-8 12037-79-5 7803-51-2 7723-14-0 39380-77-3 10026-13-8 37231-52-0 7790-93-4 96193-83-8 7778-74-7 114-26-1
26628-22-8 7775-09-9 62-74-8 7601-89-0 7631-99-4 6899-11-2 39461-36-4 12771-08-3 7664-93-9
Diethyl phosphite
Dimethyl phosphite Dimethyl mercury Dimethyl sulphate Disulfoton762-04-9 868-85-9 593-74-8 77-78-1 298-04-4
N
Nitric acid Nitric oxide Nitromethane
78989-43-2 90880-94-7 75-52-5
T
Terbufos Thallium sulfate Thionyl chloride
Thiophosphoryl chloride
Triethanolamine
Triethyl phosphite
Trimethyl phosphite13071-79-9 87993-82-6 7719-09-7 3982-91-0 7376-31-0 122-52-1 121-45-9
* security-sensitive ammonium nitrate (SSAN) [ammonium nitrate, ammonium nitrate emulsions and ammonium nitrate mixtures containing greater than 45 per cent ammonium nitrate, excluding solutions]
Note: CAS means the Chemical Abstracts Service, a division of the American Chemical Society
