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Welcome
to the January 2007 Issue!
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This
is the First 2007 (January) Community Safety/Security
Newsletter for people who are interested in making their homes,
families, workplaces, neighborhoods, and communities safer.
Happy
New Year!
BIG NEWS! (Continued)
As we let you know last
month, the Department of Homeland
Security came out with a preliminary rulemaking requiring chemical
facilities to perform Security Vulnerability Assessments. It took
us longer than a week to come up with comments, but they are up on the
website now. You are welcome to use our letter as a template for
your own letter to DHS, or you can pick and choose parts that you would
like to incorporate into your letter. I don't know how many
changes DHS will make at this late date, but the more of us that
comment, the better chance that eventually, we will have the
regulations we need. Remember, there will be only one round of comments for these
regulations, so if you want to get comments in, make sure you get them
in by February
7, 2007. The text of the regulations can be
found at: http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/06-9903.htm
MORE NEWS!
We've had some great people
signing on to help us make the world safer. Over the next few
months, we'll be telling you about some of the folks who have decided
to help us out.
One more thing for everyone: we have changed the tag line for SRM
Associates and we will also be changing the look and feel of this
newsletter to fit your needs better . Our old tag line was:
"Safer Communities through Education and Training." Our new tag
line is: "We make the world safer." It was more apropos
than the old one. To email us and let us know what you think of
the new tag line, click here: info@oursafetowns.com.
Past newsletters are all on the
website at: Newsletters.
As
always, thanks for helping us make the world just a little safer!
-Stephen
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Comments
on DHS' Proposed Chemical Vulnerability Assessment Regulations
by Stephen R. Melvin, PE CSP
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Mr.
Deziel:
We
have reviewed the proposed Chemical Facility Vulnerability Assessment
regulations, and based upon our experience of implementing Risk
Management Program/Process Safety Management Program Regulations for
numerous facilities, regulating over 100 facilities required to
comply with the California Accidental Release Prevention Program (the
State version of the RMP regulations), assisting Sandia National Labs
in developing their Chemical Facility Security Vulnerability
methodology prior to their 2001 deadline, and performing
Vulnerability Assessments on nearly 30 water facilities throughout
the state of California, we have the following comments. Thank you
for taking the time to review them, and if you have any questions,
please do not hesitate to contact me. We have provided these
comments in one of three categories: Regulatory, Business, or
Methodology.
Very
respectfully,
Stephen
R. Melvin
Regulatory
Comments:
- The
Department has requested comments on appropriate sources to determine
risk of a facility, how the “Top Screen” Process should work, and
whether a Hazard Class approach would be the best solution. We
suggest building a generic methodology that when a facility applies
it, will tell them whether they are required to comply, but which
most open source information would not reveal to an outsider. Similar
to public key encryption, DHS promulgates the “public key”
of what is required to comply, but the facility needs to have their
“private key” of their information in order to determine if they
are required to comply. Criteria might include: population possibly
impacted by a release, potential impact to the country (in terms of a
standard variable such as dollars) if the facility is damaged or
destroyed, proximity to nearby targets of interest (stadia,
universities, etc.), damage to a municipality's economy if the
facility is damaged or destroyed, etc. While these are only a few,
they need to be categorized in terms of variables that are applicable
across the board (i.e. rather than measuring dollars of damage to a
municipality's economy, one might measure percentage, or might
measure both.) Each criteria would be “binned” to rank the
facility within that criteria (e.g. if 100% of the locality's economy
comes from a refinery, then that category might be ranked “5”,
whereas, if it is less than 5% of the economy, then it might be
ranked “1”.) If a facility is over a certain value in any
category, or has an aggregate value over a certain amount, then they
would have to comply.
Continued...
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Recent
and Upcoming Events
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RECENT EVENTS
US Embassy bombing in
Greece. Looks like we've still got a job to do.
We were asked to put out a brief on the Disaster Preparedness
Summit 2007 LA. We had one person attend, and they mentioned that it was a good basic class, but did not provide a ton of new or innovative information.
CONFERENCES
Feb 6-7: Stephen Melvin will be speaking at "Homeland Security: The
Ripple
Effect" next February. His topic is: Impacts
of a Major Disaster on Smaller Local Communities and Some Possible
Solutions. Other
speakers will
include: Hon.
Bennie G. Thompson
(ranking member of the Committee on Homeland Security, U.S. House of
Representatives), Hon.
Gary Hart (former
senator, presidential candidate, and the Wirth Chair in Environmental
and Community Development Policy at the University of Colorado at
Denver & Health Sciences Center), Hon.
James S. Gilmore, III
(chairman of the National Council on Readiness and Preparedness
(NCORP); chairman of the Congressional Advisory Panel to Assess
Domestic Response Capabilities for Terrorism Involving Weapons of
Mass Destruction; and former governor of Virginia), Lieutenant
General Russel L. Honoré
(commanding general of the U.S. First Army in Fort Gillem, GA, and
current commander of the Joint Task Force-Katrina), and James
W. Spears (Homeland
Security Advisor and Secretary of Military Affairs and Public Safety,
State of West Virginia). It looks to be an all-star lineup, so we
hope to see you there. More information can be found at: http://www.apus.edu/disaster.
<>Feb 12-15: The 9th annual CUPA Conference will be held in
Garden Grove, CA
from February 12-15. Mr. Melvin and Mr. Lane will be presenting
on Industrial
Security on February 12 (read: Chemical VAs). He will be
covering the new regulations and the RAMCAP Methdology which is called
out as the "official" methodlogy in the Chemical Facility Rgulations.
There will also be a
joint meeting of
California's Region VI and Region Local Emergency Planning
Committees. This meeting is open to the public. More
information on the conference can be found at: http://www.calcupa.net/conference/2007/index.html.
Feb 13-16: The
Public Agency Risk Manager's Association (PARMA) Conference will be
this February 13-16 in Monterey, CA. More information is available at: http://www.parma.com/index.cfm?pageid=545
Feb 20-21: The Environmental
Professionals of Arizona (EPAZ), Thunderbird Chapter of the
Academy of Certified Hazardous Material Managers (ACHMM) and the Arizona Emergency Response
Commission (AZSERC) will co-host the Third Annual GATEKEEPER
REGULATORY ROUNDUP (GRR) on February 20-21, 2007 at the Chaparral
Suites in Scottsdale, Arizona. Mr. Melvin will be speaking on Chemical Facility Vulnerability
Assessments. For more
information, please click: http://www.dem.state.az.us/azserc/upcoming.htm#February
If
you are planning a conference or other event and would like Stephen
Melvin
to appear, please call us at (951) 764-3626 or email us at: info@oursafetowns.com.
His bio and information are available here.
TRAINING CLASSES
Congressman
Rohrabacher's office (in Orange/LA County) is still sponsoring
regular classes on anti-terrorism topics. If you would like more
information on these classes, please let us know.
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What
lies ahead?
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Keeping
Our Schools Safe is progressing. We aren't going to make the
AAPUS Conference in Feb, but we'll do our best to get it out
soon.
We have begun offering consulting services under the SRM Associates
banner. Emergency Response Planning for businesses, agencies, and
communities. Tabletop exercises, vulnerability assessments,
safety assessments, etc. Many of you have worked with us in the
past, so you know the type of things that we do. It is our
intention to work with businesses and agencies that truly wish to
improve their ability to prevent, respond to, and recover from a
disaster. We find ways to make your community safer, while
working to make your job easier. We help to find grant funding
for emergency preparedness programs and often, can help you accomplish
your project with little to no money out of your budget. If you
are interested in working with us directly to make your community,
business, or agency safer, please contact us at: info@oursafetowns.com.
See
you next month! |
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| ©
2007 SRM Associates |
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