Implementation Guide for Responsible Care Security Code Of

Implementation Guide for Responsible Care® Security Code of Management Practices Site Security & Verification American Chemistry Council July 2002 This guide necessarily addresses problems of a general nature. Local, state, and federal laws and regulations should be reviewed with respect to particular circumstances. In publishing this work, the American Chemistry Council is not undertaking to meet the duties of employers, manufacturers, or suppliers to warn and properly train and equip their employees, and others exposed, concerning health and safety risks and precautions, in compliance with local, state, or federal laws. Information concerning security, safety, and health risks and proper precautions with respect to particular materials and conditions should be obtained from the employer, the manufacturer or supplier of that material, or the material safety data sheet. This Guide provides sample strategies and resources to assist companies in the implementation of the Responsible Care® Security Code of Management Practices. The sample strategies and implementation resources are intended solely to stimulate thinking and offer helpful ideas on code implementation. They are in no way intended to establish a standard, legal obligation, or preferred option for any practice. Other approaches not described here may be just as effective or even more effective for a particular company. If a company so chooses, it may adopt any of these sample strategies or may modify them to fit the company’s unique situation. Nothing contained in this publication is to be construed as granting any right, by implication or otherwise, for the manufacture, sale, or use of any method, apparatus, or product covered by letters patent. Neither should anything contained in the publication be construed as insuring any- one against liability for infringement of letters patent. The American Chemistry Council and its employees, subcontractors, consultants, and other as- signs make no warranty or representation, either express or implied, with respect to the accuracy, completeness, or utility of the information contained herein, or assume any liability or responsibility for any use, or the results of such use, of any information or process disclosed in this publication, or represent that its use would not infringe upon privately owned rights. Copyright © 2002 American Chemistry Council This guide was produced with the assistance of Ohlhausen Research, Inc. Peter E. Ohlhausen, President. (703) 978-7549. [email protected]. www.ohlhausen.com. Implementation Guide for Responsible Care® Security Code of Management Practices Contents I. Introduction ..................................................................... 1 II. ACC Security Code of Management Practices ............ 4 III. Implementing the Code in Your Company .................. 7 IV. Management Practices ............................................... 10 1. Leadership Commitment...........................................................11 2. Analysis of Threats, Vulnerabilities, and Consequences ....13 3. Implementation of Security Measures.....................................18 4. Information and Cyber Security ...............................................21 5. Documentation............................................................................23 6. Training, Drills, and Guidance ..................................................26 7. Communications, Dialogue, and Information Exchange ......29 8. Response to Security Threats ..................................................33 9. Response to Security Incidents ...............................................36 10. Audits .........................................................................................39 11. Third-Party Verification ...........................................................42 12. Management of Change ..........................................................46 13. Continuous Improvem ent........................................................50 V. References .................................................................. 52 VI. Implementation Resources ........................................ 54 1. Leadership Commitment...........................................................55 2. Analysis of Threats, Vulnerabilities, and Consequences ....59 3. Implementation of Security Measures...................................134 4. Information and Cyber Security .............................................172 5. Documentation..........................................................................177 6. Training, Drills, and Guidance ................................................191 Implementation Guide for Responsible Care® Security Code of Management Practices 7. Communications, Dialogue, and Information Exchange ....203 8. Response to Security Threats ................................................221 9. Response to Security Incidents .............................................242 10. Audits .......................................................................................256 11. Third-Party Verification .........................................................286 12. Management of Change ........................................................287 13. Continuous Improvement......................................................298 Implementation Guide for Responsible Care® Security Code of Management Practices I. Introduction The terrorist attacks of September 11, 2001, forever changed the way Americans live and work. The chemical industry—like every other American industry—is reassessing and enhancing its security measures in the wake of these attacks. We realize that these unprecedented circumstances call for nothing less than the best from our industry—to increase our level of prepared- ness and solidify our partnerships with law enforcement and security agencies. In the wake of terrorist attacks against our way of life, chemistry has played an essential role in our nation’s first line of defense against terrorism. From the disinfectants and antibiotics used to protect against potential biological warfare agents, to the bulletproof and flame-resistant fibers used to make the helmets and flak jackets that protect our troops in the field and our firefighters at home, to the microprocessors that give the technological intelligence edge to our security forces here and abroad, chemistry is a vital part of our military and public safety operations. As a backbone industry, the business of chemistry has a rich history of providing products that are essential to America’s economy, our way of life, and our national security needs. In the wake of the new security challenges, the industry is committed to doing its part to help protect these values. Our objective is to help ensure the protection of chemical facilities so we can con- tinue—safely—to provide essential, life-saving products, to play a key role in revitalizing the nation’s economy, and to secure the protection of our employees and neighbors. Attention to security is a natural corollary to the chemical industry’s safety culture. By reducing the risk of a wide range of threats and mitigating the effects of such incidents as terrorism, van- dalism, sabotage, and workplace violence, security measures can serve the goals of process safety management, risk management, and Responsible Care®. Security efforts, like safety efforts, protect the community and company employees while keeping a chemical plant operational and profitable. The purpose of the Security Code of Management Practices is to help protect people, property, products, processes, information, and information systems by enhancing security throughout the chemical industry value chain. The Code is designed to help companies achieve continuous improvement in security performance using a risk-based approach to identify, assess, and address vulnerabilities, prevent or mitigate incidents, enhance training and response capabilities, and maintain and improve relationships with key stakeholders. The Code must be implemented with the understanding that security is a shared responsibility requiring actions by others such as customers, suppliers, service providers, and government agencies. Everyone in the chemical industry value chain has security responsibilities and must act accordingly to protect the public inter- est. Implementation of the Security Code helps achieve several of the Responsible Care® Guiding Principles: · To seek and incorporate public input regarding our products and operations. · To make health, safety, the environment, and resource conservation critical considerations for all new and existing products and processes. Implementation Guide for Responsible Care® Security Code of Management Practices 1 · To work with customers, carriers, suppliers, distributors, and contractors to foster the safe use, transport, and disposal of chemicals. · To operate our facilities in a manner that protects the environment and the health and safety of our employees and the public. · To lead in the development of responsible laws, regulations, and standards that safeguard the community, workplace, and environment. · To practice Responsible Care® by encouraging and assisting others to adhere to these principles and practices. The Security Code complements, and should be implemented in conjunction with, other management practices that demonstrate the industry’s commitment to protecting its employees and society. Existing management practices that enhance community awareness and emergency pre-

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