ROBERT KLEIN AND ELAN GANDSMAN OFFICE OF ENVIRONMENTAL HEALTH AND SAFETY YALE UNIVERSITY

1. HOW TO REDUCE THE LIKELIHOOD OF COLLEGES AND UNIVERSITIES FROM BEING TARGETS OF TERROR: THE YALE EXPERIENCE ROBERT KLEIN AND ELAN GANDSMAN OFFICE OF ENVIRONMENTAL HEALTH AND SAFETY YALE UNIVERSITY

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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)

8. 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 elsewhere B. Likely to cause death or serious injury only in immediate area C. Likely to cause less serious injury/illness or require prolonged exposure to cause any injury/illness D. Consequences limited to regulatory compliance issues

9. 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

11. 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

12. 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

13. 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

15. 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

16. 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

17. 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

18. 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