ROBERT KLEIN AND ELAN GANDSMAN

OFFICE OF ENVIRONMENTAL HEALTH AND SAFETYYALE UNIVERSITY

HOW TO REDUCE THE LIKELIHOOD OF COLLEGES AND UNIVERSITIES FROM BEING TARGETS OFTERROR: THE YALE EXPERIENCE

INTRODUCTION

The terrorist acts of September 11 forever changed our country and the university community

Newly enacted regulations designed to enhance security with potential agents of biological, radioactive and chemical terror

Research universities have a special responsibility to protect hazardous materials in their possession

The recent events have raised questions concerning security of these materials

MAGNITUDE OF HAZARDOUS MATERIALS/OPERATIONS

Universities are characterized by small quantities of hazardous materials

Biological, chemical and radioactive agents, and waste streams are stored and used in laboratories, maintenance shops, warehouses, and support areas

Larger institutions also have their own power generating plants

HAZARDOUS MATERIALS OF CONCERN

Based upon risk ranking, only a small fraction of the these locations contain “high or unusual hazard” materials or operations

Only about a dozen are sufficiently hazardous to pose both on and off site potential for adverse consequences in the event of a serious accident

BIOLOGICAL MATERIALS

Most of the biological research occurs at a Bl-2 level or lower, a very small subset of researchers work at a Bl-3

August 2002 redefinition of select agents by CDC

and USDA has expanded the list to include toxins of biological origin, infectious agents, and agents

with high consequences to livestock and plants

RADIOACTIVE MATERIALS

Yale neither conducts research with or has in its possession weapons grade or highly enriched radioactive materials

Most common radioactive materials found in the laboratories are H-3, P-32, C-14 and I-125 and the totals for each are less than one curie at any one time. Similar amounts can be found in waste storage

Yale does not operate a nuclear reactor although the physics department does operate an accelerator

CHEMICALS

Chemicals used in laboratories are not present in quantities or types likely to attract the interest of terrorists. Dangers arise from accidents or vandalism

Chemicals in potentially dangerous quantities or forms are present in facilities such as ice skating rink (anhydrous ammonia), athletics and ground maintenance (pesticides and fertilizers), and the central power plant (aqueous ammonia, water treatment chemicals)

HAZARD RANKING FOR HIGH AND UNSUAL HAZARDS

Assessment of the potential consequences from a large scale release, fire, vandalism, or other significant impact

Risk criteria:

A. Likely to cause death or serious injury/illness to persons in immediate area and potential for harmful consequences elsewhereB. Likely to cause death or serious injury only in immediate areaC. Likely to cause less serious injury/illness or require prolonged exposure to cause any injury/illnessD. Consequences limited to regulatory compliance issues

BROAD VULNERABILITIES

Despite the small number high hazardous locations, there are vulnerabilities which could make them a potential target as well as a potential source of dangerous materials: Campus interspersed within larger community, making access

control very difficult Academic environment making access restrictions between

teaching areas and research areas difficult to enforce International student, faculty and employee population Extensive domestic and international travel by staff and

students Very high volume of mail and packages delivery

BRAOD VULNERABILITIES

The unfortunate reality is that even with the stricter control, an unscrupulous person who has access to hazardous materials can easily defeat the system. Over the past 20 years the most serious incidents and laboratory-associated terror have been by authorized users in actions of vendetta, jealousy and possibly self-inflicted

Serious infrastructure damage have also been inflicted to research facilities by animal right activists

RECOMMENDED ENHANCEMENTS

Many opportunities exist to further enhance the security of hazardous materials, these range from simple and easily implemented actions (costing hundreds of $) to complex and difficult measures (costing many thousands of $)

Develop a site specific security plan for all areas involved in the receipt, storage, use, disposal or transport of hazardous materials

Require all laboratory doors to be locked when no one is present. Design new laboratories with safety reinforced glass view panels and alternative door hardware to reduce the need for researchers to prop doors open

RECOMMNEDED ENHANCEMENTS

Expand the use of building perimeter controls to all research buildings to reduce unauthorized entry. If this is not feasible during scheduled class hours, then expand the off-hours periods of access control. Controls might include ID card readers/ security guards. A long term step might be segregation of teaching from research labs so access to research space is restricted and separated from “public” spaces

Expand the “lock box” approach currently required by the NRC for radioactive materials, by the DEA for controlled substances, and by the CDC/USDA for select agents, to all other hazardous materials. A physical lock on a freezer, refrigerator, or cabinet can greatly increase the security of higher risk materials

RECOMMENDED ENHANCEMENTS

Centralizing procurement, purchasing and distribution functions to eliminate the independent use of the credit card system for research supplies and equipment

Establish purchasing procedures with vendors to restrict access to certain hazardous materials

Get serious about new employee orientation and safety training, and require it for all hires. Make this training mandatory and cover basic safety in one compact session

Future options could include the bar coding of all incoming chemicals, biological and other reagents and samples to create a single university- wide materials inventory

RECOMMNEDED ENHANCEMENTS

Design HVAC systems for new buildings in such manner that access is limited to mechanical components, controls, and specially the actual air intake location. This will help prevent the introduction of toxic materials into the air intake

Develop and implement a standard uniform faculty registration system that covers all hazardous materials. The process must be linked with other university departments so failure to participate in the registration results in the denial of services, funds, access, or even paychecks

LESSONS FROM YALE LAW SCHOOL EXPLOSION

A bomb exploded on may 21, 2003 on the first floor of the Yale law school building causing significant structural damage to two law school rooms

Fortunately nobody was injured Yale OEHS emergency response was immediate and a

personnel of 6 and the fully equipped emergency van was dispatched to the site

OEHS reported to new haven police on hazardous materials (asbestos) and provided respirators and radiation detectors for the search and rescue operation

LAW SCHOOL EXPLOSION

Physical plant was also on stand by with supervisors, electricians, carpenters and plumbers. They also provided the blue prints to the building

Many agencies were involved in the incident: FBI, New Haven Fire Department, New Haven Police Department, CT State Police, Yale Police, ATF, and DEP

Incident allowed to evaluate first responders and the coordination of all these agencies

The entire block around the law school was cordoned off Initial incident commander was the New Haven Fire Dept.

and then the FBI took over