ChemLock Exercises - Chemical Sector Active Shooter
NOTE: This is part of a series of blog posts looking at various CISA Tabletop Exercises Packages (CTEP) offered to chemical facility managers by the new CISA ChemLock program, a voluntary chemical security program run by the Office of Chemical Security (the CFATS folks). It is a follow-up to my earlier Overview post. CTEP administrative documents can be found here. The scenario manuals can be found here. Earlier posts in the series include:
The Situation Manual for this exercise bills it as a review of “emergency preparedness plans and response procedures to an active shooter incident at a chemical sector facility.” It follows the same format as the IED exercise I previously discussed. Using the same format will make it easier for facilities to run subsequent exercises as they will already be familiar with the exercise processes.
Incident and Response Module
This Module is slightly more complex than that seen in the IED exercise. It provides two separate starting points for the exercise, a stolen vehicle and a disgruntled employee. Both starting points lead to an unidentified shooter arriving at the loading dock who is quickly killed by responding officers before the shooter can progress into the facility.
The Module then goes on to present the same 13 discussion questions seen in the IED exercise. Since these questions are about security processes and responses, these generic questions still serve the same purpose and will likely lead to different discussions.
Remaining Two Modules
With the exception of the opening sentence of the scenario in the Sustained Response Module, this is the same scenario seen in the IED exercise as are the discussion questions and the same will be seen in the Short-Term Recovery Module. While this use of common questions could have led to different conclusions in the initial incident review, from here on out, there is little likelihood that there will be substantially different conclusions reached.
Commentary
Active shooter situations are becoming much more common in the United States. With that in mind, facilities certainly need to consider running exercises such as this. This scenario, as presented, could be run at any manufacturing facility. Unfortunately, it is billed as a “Chemical Sector Active Shooter” exercise, but it does not take into account any of the unique problems that chemical facilities could face in an active shooter situation. This exercise assumes that the shooter, his bullets and the bullets of the responders that take him down never enter an area of the facility that contain chemicals. While such a limited event could occur, that is not what a “Chemical Sector Active Shooter” exercise should address.
With that in mind, I would like to suggest that the following questions be added to the discussion in module 1:
What areas of the facility would provide potential chemical release hazards in the event that firearms were discharged in or into those areas? What are the hazards?
How do responding police officers identity those areas?
What actions can be safely taken against an active shooter in those areas of the facility?
What chemical processes would need to be shutdown in the event of an active shooter being on the property? Who makes the decision to begin shutdown?
What chemical response activities have to wait until after an active shooter incident is concluded?
Immediately after an active shooter incident is ended (shooter leaves facility, is apprehended or killed) the facility is going to have to determine if there was any incidental damage to the facility from random bullets. The following questions should be added to Module 2 to address that damage assessment issue:
What portions of the facility will require detailed inspection after an active shooter incident?
What inspection techniques will be used to identify bullet damage to chemical process equipment?