Introduction
Recent terrorist events in the United States underscore the
importance of fire prevention and workplace emergency planning
efforts. Fires or explosions created by arson or an explosive
device can be the quickest way for a terrorist to affect a
targeted business. Consequently, OSHA developed this
Fire and Explosion Planning Matrix to provide employers
with planning considerations and on-line resources that
may help employers reduce their vulnerability to, or
the consequences of, a terrorist's explosive device or
act of arson. A terrorist's explosive device or
act of arson are not workplace fire hazards or ignition
sources that OSHA expects an employer to reasonably
identify and attempt to control. However, an
effective fire prevention plan that includes these fire
hazards/ignition sources may increase workplace safety and
security, and ensure that employees know how to respond to
threats and incidents safely and effectively.
Since terrorism can impact employers and workers, OSHA is
committed to strengthening workplace planning and preparedness so
that employers and workers may better protect themselves and
reduce the likelihood that they may be harmed in the event of a
terrorist incident. OSHA continues to work with other Federal
response agencies, including the Federal Emergency Management
Agency (FEMA), the Environmental Protection Agency (EPA), the
U.S. Army Soldier and Biological Chemical Command (SBCCOM), the
Centers for Disease Control and Prevention (CDC), and, within
CDC, the National Institute for Occupational Safety and Health
(NIOSH), to provide accurate, current information in this rapidly
developing area of occupational safety and health.
Assessing the Risk of a Terrorist
Incident
Within this document, OSHA draws on the FBI definition of
terrorism and defines terrorist act/incident as a
premeditated, unlawful act dangerous to human life that is intended
to further political or social objectives. The Fire and Explosion
Matrix addresses terrorist acts/incidents that involve arson or an
explosive device to achieve political or social objectives.
In order to use this fire prevention guidance effectively, an
employer must first assess the risk of a terrorist incident in
the workplace. The level of risk is a combination of workplace
vulnerabilities, recognized threat, and anticipated consequences
of the event. This kind of assessment is not a typical safety and
health evaluation. However, guidance on conducting such an
assessment is becoming more widely available. For many employers,
Best Practices in Workplace Security, a homeland security
guide developed by the South Carolina Department of Labor,
Licensing and Regulation (which operates an OSHA-approved State plan)
and an advisory committee of private and public employer
representatives, can offer valuable assistance and is available
on-line at
http://www.llr.state.sc.us/workplace/workplacesecurity.htm.
In its
Worksite Risk Assessment List [507Kb PDF], an employer will
be asked whether the worksite is characterized by any of the
following terrorism risk factors:
- uses, handles, stores or transports hazardous materials;
- provides essential services, e.g., sewer treatment,
electricity, fuels, telephone, etc.;
- has a high volume of pedestrian traffic;
- has limited means of egress, such as a high rise complex or
underground operations;
- has a high volume of incoming materials (e.g., mail,
imports/exports, raw materials);
- is considered a high profile site, such as a water dam,
military installation, or classified site; or
- is part of the transportation system, such as shipyard, bus
line, trucking, airline.
If these risk factors apply to your workplace
and cannot be eliminated, your vulnerability to a terrorist
incident may be greater than that of other workplaces. To further assess the
potential threat and consequences of a terrorist incident at or
near your workplace, consult local law enforcement, the local
office of the FBI, the Bureau of Alcohol, Tobacco, Firearms, and
Explosives (ATF), and/or your Local Emergency Planning Committee
(LEPC) (see EPA's LEPC database online at
http://www.epa.gov/ceppo/lepclist.htm). Information from
these agencies will help you complete your risk assessment and
determine which of the three risk zones noted below best
characterizes your workplace.
Chemical facilities can use the U.S. Department of Justice
Chemical Facility Vulnerability Assessment Methodology, at
http://www.ojp.usdoj.gov/nij/pubs-sum/195171.htm, to assess
workplace vulnerabilities. Although this document also discusses
threat and consequence assessment, you still will need input from
local law enforcement, local FBI and ATF offices, and/or your
local LEPC to complete your evaluation.
Using OSHA's Fire and
Explosion Planning Matrix
The Matrix is not a compliance tool for conducting a
comprehensive compliance evaluation of a fire prevention plan
developed to comply with the
Fire Prevention Plan Standard (29 CFR 1910.39). Rather, this
document covers the general aspects of fire prevention planning
and includes broad questions to help employers review their plan
content as it would relate to a terrorist act involving arson or
an explosive device. Each broad question is followed by planning
considerations and suggested preparedness measures appropriate
for workplaces in each of the three risk zones. On-line resources are
included that may offer additional assistance. After you
complete the terrorism risk assessment, review the
description of each risk zone to see where your
workplace fits best, then review the questions and the related planning
considerations for that zone.
NOTICE |
OSHA offers this guidance to assist employers
and workers who are interested in implementing plans and
procedures that may reduce the likelihood of a terrorist incident
and reduce the effect of a terrorist's explosive device or act of arson,
should a terrorist incident occur at a workplace. However, the
guidance does not create legal obligations for employers or
create rights for third parties. Legal obligations under the
OSHAct are created by statute, regulations, and standards. |
Fire Prevention Plans (FPP) often work in conjunction with the
procedures identified in existing
Emergency Action Plans (EAP)(29 CFR 1910.38). Therefore, any
modification to the FPP can affect your EAP. If you have decided
to include arson and explosive device incidents in an existing FPP, you also may
want to do so in your EAP.
Note: If you do not have a fire prevention plan and want
to determine whether OSHA requires you to have one, please see Does Your Facility Need a Fire
Prevention Plan? (Attachment A) If you do not have an emergency plan and
want to determine whether OSHA requires you to have one, please
see Does Your Facility Need an
Emergency Plan? (Attachment B)
There are 26 States and Territories which operate their own
occupational safety and health programs under an OSHA-approved
State plan. State Plan
States set and enforce state standards which are identical to
or "at least as effective as" Federal OSHA standards,
including those referenced in this matrix (such as the Fire
Prevention Plan, Emergency Action Plan, and Personal Protective
Equipment Standards). While this matrix can provide useful
guidance to all employers and workers, if you work in a State
plan State, you also should contact your State plan agency to
determine whether they have any additional or different
requirements and to obtain State-specific guidance.
OSHA Terrorist Incident Risk
Categories
OSHA shows the zones in the shape of a pyramid to represent how
the nation's workplaces appear to be distributed within the
zones. Based on information currently available, the vast
majority of American workplaces are at low risk for a terrorist
incident, i.e., are in the Green Zone. The questions,
recommendations, and on-line resources in each risk zone build on
the those in the zone below it. For example, the Yellow Zone
includes both the information in the Green Zone and additional
information for Yellow Zone workplaces.
Green Zone:
Workplaces that are not likely to be a target for a terrorist
incident because they are characterized by limited vulnerability,
limited threat, and limited potential for significant
impact (consequence).
Note: If the workplaces around you seem to be in a higher
zone, you may wish to review and implement the
planning/preparedness considerations in the Yellow Zone.
Yellow Zone:
Workplaces that may be targets because they are characterized by
high vulnerability or high threat or a potentially
significant impact (consequence) but, not more than one of
these.
Note: If the workplaces around you seem to be in a higher
zone, you may wish to review and implement the
planning/preparedness considerations in the Red Zone.
Red Zone:
Workplaces that are most likely to be targets because they are
characterized by two or more of the following: high
vulnerability, high threat, and potentially catastrophic impact
(consequence). Such workplaces may consider assigning some
terrorist incident response roles to their own employees.
Note: The color-coded risk levels in this Matrix do not
equate to the Threat Levels in the Homeland Security Advisory
System developed by the Department of Homeland Security. However,
employers that place themselves in the Yellow or Red risk levels
may consider implementing sequential preparedness measures
consistent with those listed in the
Homeland Security Presidential Directive - 3 (describes
Threat Levels) for federal agencies.
Limitations of Guidance
Because of the vast number and types of workplaces in the United
States, this Matrix provides broad information applicable to most
workplaces. If you want to modify your plan to address specific
considerations, you can get additional information from the
on-line resources identified. For additional information about
workplace fire prevention planning, see
OSHA's Safety and Health Topics: Fire Safety web
page.
As a nation, our understanding of the risk of terrorism and the
devices involved continues to evolve. It is likely that
OSHA's recommendations for preparedness, training, and
equipment also will evolve. OSHA remains committed to helping
employers and workers protect themselves from the risk of
terrorism in the workplace and is working closely with other
Federal and State agencies to provide employers with current
information and guidance.
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