Addressing Chemical Terrorism

The right questions, but the wrong focus

This newsletter is not intended to be a constant source of complaints against all of the work that the U.S. government does to address unconventional weapons. That would get boring after a while. There is a lot of good work being done out there on a day-to-day basis, mostly at the lower action officer level — people who seriously want to make a difference but don’t get noticed. There has been the occasional success story. There’s also a consistent lack of concern by senior leaders in addressing unconventional weapons issues that frustrates me to no end. And then there’s the those who have a personal agenda, talking about WMD threats but not actually advancing any progress toward developing appropriate strategies or capabilities toward them. It’s in my nature to critically examine and comment on defense reports addressing this topic, with a particular focus on the policy execution of such efforts.

In that light, I’m taking an eye to the National Academy’s recent report titled “Chemical Terrorism: Assessment of U.S. Strategies in the Era of Great Power Competition.” This is the final part of the National Academy’s review of WMD terrorism strategies, the first being on bioterrorism in 2023 and the second being on radiological/nuclear terrorism in 2024. I gave my views on the latter in this Substack post. The bioterrorism report is kind of thin — it is a brief proceedings of a workshop — and I’ve talked enough about biological threats. This report on chemical terrorism is not bad. I personally know the vice chair, Dr. Margaret Kosal, and one of the committee members, Philipp Bleek. They are good people, and I respect their views. I also respect the people who reviewed their report and provided constructive comments and suggestions. That said, while the report has some points that should be considered, it lacks focus on specifics needed to improve national security policies.

I’ve talked in the recent past about the challenges in having scientists address national security policy issues that have technical aspects. Here’s the challenge with talking about WMD terrorism. On the one side, you have respected scientists who examine the threat of chemical warfare agents, biological threats, and radiological and nuclear weapons. They largely believe in controlling access to the materials and improving response capabilities to WMD terrorist incidents. These are important aspects but neglect prevention and protection measures. On the other side, you have the law enforcement and military operators who do not perceive WMD terrorism to be any different than “traditional” terrorism. It’s all about preventing an identified group from acting out its plan, not responding to its execution. All the “WMD” tag means is those adversaries get a slightly higher priority than traditional terrorism and that special handling measures are needed for the devices that might be used. These two groups aren’t talking to each other. Because the chance of WMD terrorism is so small as to be nearly insignificant, there’s not a whole lot of visible action in this area.

Anyway, let’s look at this report. The committee notes that, over history, chemical terrorism has caused more harm to people than biological or radiological terrorism, and that’s true largely due to the significant absence of rad/nuke terrorism or bioterrorism incidents. The committee’s focus is on violent extremist organizations (VEOs) — do people still use this term? — and not state use of chemical warfare agents in assassination plots (e.g., the Skripals in the UK).¹ They use the term “chemical threats” because not every terrorist organization will go for chemical warfare agents, that there are lots of toxic industrial chemicals that could be used. And that’s all true. I think this also goes, however, to the point that not all chemical terrorist incidents will be mass casualty events and will fall far short of the “WMD” categorization. This is a problem in as much as it’s hard to retain senior government or politician attention on the topic if the casualty count isn’t significant.

The committee used the DOE/NNSA framework of “prevent, counter, and respond” as they did in the nuclear terrorism report. Again, I’ll say that this was a mistake in that they should have used the national preparedness framework of “prevent, protect, respond, recover” instead. If they are truly interested in the interagency roles and coordination, that’s the appropriate model to use. It would have offered the opportunity for a more thorough examination and maybe they could have worked in the “strategies” and responsibilities of the state and local agencies, which is largely absent in this report.

The committee has done its due diligence in data collection, in as far as looking at terrorist groups and motivations, what federal agencies have on the books for strategies, and how their prevention and response activities are developed. The problem with the committee’s approach is that they take too much interest in the idea of a smoothly coordinated interagency approach to countering terrorism without considering the context of terrorist incidents, whether they are domestic or foreign, and whether they are using commercial chemicals or developing warfare agents. The interagency often doesn’t work in practice. There is a difference between domestic terrorist incidents and foreign terrorist efforts. There’s even a difference between foreign terrorists working against the United States and foreign terrorists who just want to attack their own governments. These nuances are not in this report, and as a result, I think some of the recommendations are lacking in merit. Here they are.

RECOMMENDATION 2-3: The intelligence community (IC) should continue to monitor interest in emerging technologies and delivery systems, such as drug delivery systems, and trends by terrorist groups to innovate and improvise using chemical agents. This may look significantly different than the applications of advanced materials chemistry by great power states.

Sure, I guess. I would hope that the National Counterterrorism Center and the IC are looking at trends by terrorist groups seeking to develop improvised chemical devices. The problem is, there’s a lack of data to provide said trends. I am sure that terrorist groups will have financial and technical limitations that prevent them from making high-quality chemical warfare agents in large quantities, limitations that do not exist for nations with advanced industrial capabilities. This is a no-brainer. At the same time, this reinforces the point that terrorists with improvised chemical devices do not have a WMD capability, and that lowers the policy makers’ sense of urgency.

RECOMMENDATION 4-3 (Abbreviated): Existing IC programs should actively seek and incorporate new approaches to identify existing chemical threats (traditional and improvised) and potential emerging threats by terrorist groups. In developing new approaches, program managers should develop strategies that look beyond the traditional terrorism suspects and that augment and leverage skill sets of the U.S. Government (USG) agencies. The threat assessments should be updated reflecting the current times and demographics.

RECOMMENDATION 4-4: The National Counter Terrorism Center (NCTC), Department of Defense (DoD), and Department of Homeland Security (DHS) should review current identification approaches to determine whether shifts in emphasis are required as a result of expanded and augmented VEOs and terrorist capability resulting from the potential migration of chemical agents, other materials, technology, and expertise from state actors to VEOs.

RECOMMENDATION 4-5: The USG should ensure that the identification of chemical terrorism threats is explicitly included in ongoing and future strategies. Chemical terrorism threats should be considered distinct from nuclear nonproliferation, identification of state-based offensive chemical programs, and traditional (non-nuclear-biological-chemical) terrorism.

Threat assessments are funny things. First of all, usually these assessments are classified and so we can’t really examine the methodology or data that federal agencies use to develop them. Second, because there are a lot of terrorist groups out there and only a few who actually have ambitions and capabilities to use improvised chemical devices or chemical warfare agents, it’s very hard to identify required “shifts in emphasis” in how federal agencies approach this topic.

Two quick points, DHS is supposed to do threat assessments for domestic WMD incidents, because Congress told them to, but there’s a heavy weight on how many casualties a specific chemical will cause if used, as opposed to specific groups, their capabilities to make a quantity of chemicals to cause a mass casualty event, and where the incident occurs. Second, DOD used to have a priority list for biological warfare agents, and OSD leaders told them to scrap the list because they didn’t feel it moved the programmatics. Add to this the ridiculous current direction of the CB Defense Program and its “threat-agnostic” approach to developing new capabilities, ignoring the need to prioritize threats while simultaneously embracing all chem-bio threats. What’s the point of these threat assessments if the data doesn’t impact policy decisions or programmatic direction?

I’m not saying that these three recommendations are bad, just that they are overly ambitious, and no one really uses threat assessments as risk management tools to guide strategy development as they should.

RECOMMENDATION 5-1: The National Security Council should give careful consideration to incorporating direct deterrence of chemical terrorism into existing Chemical WMDT strategies.

Okay, I will say strongly here that the committee got its deterrence discussion wrong. First, there is no national chemical WMDT strategy, because everyone tends to focus on biological and nuclear threats (both terrorist and nation-state). Chemicals just make a mess that requires a HAZMAT team to clean up. I think the committee understands that and wants it to be corrected, but the NSC won’t take it seriously. We can argue as to whether terrorists can be deterred by the threat of reprisal — and I think they can, they are political actors just like nation-state leaders — and the committee appropriately notes that there has to be explicit communications of direct deterrence to those terrorists thinking about this. The committee notes that there is no such explicit statement of direct deterrence.

There’s a larger problem that the committee is missing (or ignoring), in that most civilian policy makers believe that strategic ambiguity is required when it comes to deterring WMD use. The US leadership won’t say what the punishment will be, because then they might actually have to go through with their threat of retaliation with a specific measure that might or might not result in the adversarial group backing down (see Houthis, continued attacks on shipping and Israel). I don’t like strategic ambiguity, but others defend it. Also, for some reason, US policy makers seem really bad at understanding deterrence and the ridiculous “integrated deterrence” concept in the 2022 NDS is a prime example of this.

RECOMMENDATION 5-3: Substitution of safer alternative chemicals for hazardous chemicals in industrial and academic settings should be included as part of the overall strategy to impede acquisition of raw materials for chemical terrorism. The planning and development of these strategies should be spearheaded by DHS’s Chemical Information Sharing and Analysis Center under a reauthorized CFATS program and should continue to be conducted in conjunction with regulatory agencies, specifically, the EPA, OSHA, and representatives from industry and academic research environments.

RECOMMENDATION 7-6: Congress should immediately reauthorize the CFATS program and consider long-term reauthorization.

The sad thing about the DHS CFATS program is that it wasn’t cancelled because someone evaluated it and found it to be lacking. It was because Congress just didn’t get around to reauthorizing it and let it expire. Because, hey, that’s our Congress inaction. I do not believe that the chemical industry will go out and look for “safer alternative chemicals” in its production because the lines are already set up and they’re not interested in substitutes that don’t work as well or that are more expensive. I also think that it’s in the chemical industry’s best interests to self-regulate itself and keep up facility security measures. We’ll see what happens.

RECOMMENDATION 5-4: Counter-insider threat activities should be incorporated explicitly into broader counter WMD strategy. The DHS should develop a strategy to ameliorate insider threats explicitly for the chemical domain.

Okay, no one is going to do counter-insider threat activities within industry facilities. Sorry. These aren’t nuclear power reactors or biological laboratories. There are limits to what industry is going to do in this regard. The juice isn’t worth the squeeze.

RECOMMENDATION 5-5: Agencies should work to reconcile operational practice with policy by supplementing extant strategies to include current omitted effective activities and programs for countering chemical terrorism. This would ensure that effective practices are maintained, properly resourced, and reflected in comprehensive strategies.

As to “current omitted activities,” the committee is referring to “military capabilities to provide early warning of chemical terrorism plots; law enforcement capabilities to counter chemical threats tactically; integration with broader counterterrorism and counter-smuggling efforts; and involvement with other multilateral activities beyond the Organization for the Prohibition of Chemical Weapons” that is not mentioned in USG strategy documents addressing WMD terrorism. I don’t see this happening. Agencies write strategies that address their resources and their agendas. This is nit-picking. While chemical terrorism is the most likely form of WMD terrorism that might happen, nobody cares that much to make it a grand interagency strategy.

RECOMMENDATION 6-6: Considering the complexity of the chemical threat space and USG coordination required for an effective response to a chemical event, the committee recommends continuing a robust program of interagency exercises and trainings that practice communication and resource sharing.

Yes, the US government should practice coordinating a federal response to a terrorist chemical incident through its national exercise program. It exists. This report has not said enough about the state, local, tribal, and territorial government responsibilities to deal with chemical terrorism. But this vehicle exists and they should use it.

RECOMMENDATION 7-1: The shift in the global threat landscape has led to a corresponding shift in countering WMD to a focus on GPC, but care should be taken to ensure that existing capabilities focused on countering terrorism are maintained. Recommendations based on revised risk assessments that are aligned with new national-level priorities should be developed.

Okay, sure, the DOD has shifted to a focus on great power competition, but NO ONE in the USG is looking at countering WMD in scenarios involving Russia or China. Okay, outside of the State Department and its arms control/nonproliferation role, no one is looking at these scenarios. I don’t think the U.S. military has any concept as to GPC use of WMD other than twentieth century Cold War concepts of NBC weapons use. That said, again, combating WMD terrorism is just the same as combating terrorism and SOCOM won’t let that mission go away. And that’s a good thing.

RECOMMENDATION 7-2 (Abbreviated): DHS should develop strategies, including an updated chemical defense strategy that consider the implications of the strategic shift to great power competition, including potential resourcing shifts, on reducing the risk of chemical threats and chemical terrorism.

Nope. Nope. Not DHS’s role. The “strategic shift” of looking at countering terrorism between 2001 and 2018 to taking on great power competition has no effect on DHS roles or capabilities. I don’t see this as an issue at all, unless you’re making the argument that Russia and China are going to use proxy forces to attack the United States with improvised chemical devices. I would love to see DHS promote a plan on its role in preparing for and responding to chemical terrorism, but the foreign relations trend doesn’t affect their mission.

RECOMMENDATION 7-3: DoD should monitor risks associated with the shift in strategic focus and adapt if evidence of terrorist activities ramps back up.

RECOMMENDATION 7-5: DoD should conduct risk and threat assessments to understand how best to direct resources to address risks of chemical terrorism events in an era of GPC-focused strategies.

I just don’t think that DOD leadership has any time, desire, or additional resources to put to “adapting” if there is evidence of terrorist activities “ramping up.” They’re all focused on developing massive conventional arsenals that can perform kinetic strikes in support of the national security strategy. DOD has just one point of view in dealing with regional adversaries and terrorist groups:

RECOMMENDATION 7-4 (Abbreviated): The IC and its offices throughout the departments with significant chemical terrorism roles and responsibilities (DoD, DHS, Department of Justice (DOJ)) should take steps to ensure that counter chemical weapons programs, whether state-based or by nonstate actors, are not technologically deterministic.

Okay, there those brainiacs go, using big terms again. All they are saying is that, over time, the USG should make sure to transfer its knowledge to new personnel as others transition. Sure. Whatever. They’ll put together a briefing book. It’ll be good enough.

RECOMMENDATION 7-7: Federal agencies should prioritize broadly applicable approaches beyond the specific mission sets represented by the U.S. Army Combat Capabilities Development Command Chemical Biological Center (DEVCOM CBC), BARDA, and CISA, to all areas of the CWMDT enterprise to maximize the United States’ government capacity for appropriate response on time scales of relevance.

No, it’s not DOD’s job to develop “threat-agnostic” medical countermeasures to chemical or biological warfare agents, as much as OSD wants them to and as much as Edgewood wants that sweet, sweet outside funding. It’s SO FAR REMOTE FROM REALITY that this small niche R&D agency within DOD should try to fill the gaps for what BARDA is funded to do, to develop medical countermeasures required to support the response to a WMD incident.² Then there’s the committee’s reference to the CBDP’s Transformational Medical Technologies Initiative (“one drug, many bugs”) as a Good Thing. It was not, it was a waste of $2 billion, diverted from warfighter requirements. This is a bad recommendation and should be shunned.

RECOMMENDATION 7-8: WMD budgets should be aligned with evolving strategic priorities.

RECOMMENDATION 7-9: Chemical WMDT budgets should incentivize activities that transition promising research to operations.

Oh hell no. Again here’s an example where scientists don’t understand policy or how defense budgets are made. While we need science-informed policy, scientists don’t get to look at budget materials and comment on them. They don’t understand how the game is played. No one is going to separate chemical terrorism risks from biological or rad/nuke terrorism risks. This is a policy issue, and there are always other priorities. NO ONE IS GOING TO MAKE A WMD BUDGET because it isn’t a strategic priority. They have a nuclear deterrence posture and a counter-terrorism effort that are priorities in the budget. Countering WMD is a subset of major combat operations, not to be emphasized as “requiring more resources.” Not going to happen.

This commentary should not reflect against the earnest effort here to examine how the USG approaches chemical terrorism. There’s a lot of good information in this report, but it’s not effectively focused on good solutions. I think the committee should have addressed the protection aspects, notably, critical infrastructure protection and installation CBRNE protection. Its committee members also missed a lot of details that policy makers need to make better decisions. Like many NAP reports, it’s professionally done but a little too optimistic on its recommendations. I don’t think anything is going to change within the US government as a result of this report. People will nod and say, “thanks for your service to national security” and move on to what they are already doing.

I have, on more than one time, asked counterterrorism officials and USSOCOM operators if there is a special approach to WMD terrorism, and could they explain it in unclassified terms. In both cases, they said “no.” I asked the deputy director of the National Counterterrorism Center, if terrorists are so determined to get WMD and then they will immediately use it because of the fear of being pursued by government forces, then why haven’t we seen a WMD terrorist incident? He had no answer. It’s been a long time since I’ve seen someone take on this subject for policy making in a serious and objective fashion.³ It won’t happen again until a chemical terrorist incident actually happens, and then we can all do the postmortem then.

1. The committee notes that they want to focus on non-state supported terrorism and VEOs, and yet they also seem to believe that Russian, North Korean, and Syrian use of chemical weapons might “encourage” terrorists to look at using chemical threats.

2. As a note, the Army R&D center at Edgewood used to have a big role in the Domestic Preparedness Program in the late 1990s. The DOJ took it from them, before it was transferred to DHS. This is just to say, sure, the Army labs can be helpful here but IT’S NOT THEIR MISSION when they really could be focused more on the mission of protecting warfighters from CB warfare agents.

3. See for instance, Brad Roberts, “Terrorism with Chemical and Biological Weapons,” CBAC, 1997, and Jonathan Tucker, “Toxic Terror: Assessing Terrorist Use of Chemical and Biological Weapons,” MIT Press, 2000.