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Hon. Thomas
J. Ridge Dear Gov. Ridge: The ARCC, a coalition of U.S. unions and companies concerned with jobs and investments in the U.S. chlorine chemistry industries, is writing to express its support for actions being undertaken and considered to strengthen the safety and security of the U.S. industrial infrastructure against terrorist attack. We understand that new government-industry and inter-industry measures are being considered to better share sensitive information to help harden our industrial and energy facilities against further attacks. As heightened security measures are considered, we believe that protections must be applied to the creation and communication of information critical to the success of those measures. Without such protections, American plant workers, emergency responders and communities will be placed at further risk. In simple terms: Our enemies must be denied access to sensitive information that could directly assist them in selecting targets and carrying out attacks against our people and industries. In some cases, sensitive information about plant sites should be communicated only on a "need-to-know" basis. We understand that the Department of Justice recently reported that "the risk of terrorists attempting in the foreseeable future to cause an industrial chemical release is real and credible" (and) "an unintended consequence of release of ["worst case" estimated chemical accident data in Risk Management Plans] may be to undermine the counter-terrorism measures being funded by Congress and being implemented at great cost and effort by federal agencies." In this regard, we are concerned that the "worst case scenario" projections for industrial accidents, made publicly available in Risk Management Plans (RMPs) under amendments to the Clean Air Act over the last three years, are too readily accessible to terrorists. We are concerned that these projections constitute a terrorist roadmap for attacks against U.S. infrastructure. We must protect our right to security. Obviously, the provision of such information is indispensable to plant workers, emergency responders and other selected individuals in plant communities. However, we believe that "worst case" RMP information should be withdrawn from public reading rooms where it is very easily accessible. Citing security concerns, President Clinton signed into law in 1999 a measure to keep this "worst case" RMP information off of the Internet. Unfortunately, that measure alone may not be sufficient to keep the information out of the wrong hands. We understand that balancing "right to know" with right to security will not be easy in every case. There are legitimate concerns in promoting and defending "right to know." In particular, unions have been deeply involved in expanding U.S. right to know law to guarantee access to information important to worker and plant community safety. However, under the current circumstances, a distinction must be understood between the risk of a catastrophic chemical plant accident in the United States and the "real and credible risk" of a terrorist attack on a facility. That distinction should be defined and applied to our current security situation. Our position on these matters is endorsed by the International Union of Police Associations. Sincerely,
CC: Hon. Christine
Todd Whitman, Administrator, Environmental Protection Agency
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