“I do in fact understand that the horse is already out of the barn in regard to chemical plant security regulation. HR 2868 is supplementary. I also understand that some "up-armoring" of chemical plants is reasonable. “However, the inevitable effect of "federalizing" plant security will be to suppress the use of extremely useful chemical substances because some security specialist could imagine a possible negative consequence of a release. I am lamenting the yet another layer of regulation on the chemical industry that is promulgated by the know-nothing classes.”I must admit that it has been some time since I have seen such a patronizing attitude publicly expressed. It is, unfortunately, not an uncommon enough attitude in the sciences. Some people (not any where near a majority, or even a large minority in my experience) feel that their scientific education makes them better suited for determining how things should be done, even outside of the area of their narrow education.
While no one is going to confuse me with being ‘progressive’, I am a firm believer that all of the people that may be affected by the consequences of an accident or a terrorist attack should have some say in how they should be protected from those consequences. While I certainly don’t think that we should involve people off the street in the facility decision making process, we do have a representative form of government in this country where people are duly elected to ‘represent’ those people on the street.
It would be too cumbersome to even involve those representatives directly in individual site security plan development; instead they develop a set of standards that all chemical facilities must adhere to. Then the facility owners and managers figure out how to best operate within those constraints. Granted, very few of these elected representatives would know a reactive chemical if they found it in a jar on the shelf in Wal-Mart®, or even if they found it under their kitchen sink (and those of us in the business know that there are plenty of ‘dangerous’ chemicals found in both places). But that is entirely beside the point.
Our representatives do not need to have a degree in chemistry or engineering to set operational standards for security, or safety, or environmental protection. Once those laws are written, they will then hire the people with the appropriate knowledge-set to write and enforce the rules that implement those operational standards. That is how the government works. Now my progressive readers will be quick to point out that the chemical industry is not without a voice in the development of these rules. In fact, many would bemoan the ‘unequal representation’ that industry typically has had in these discussions.
But, industry does have a legitimate role in the development of the laws and regulations which constrain their actions. They have a responsibility to point out when those rules go too far in restricting their ability to make enough money to stay in business. They have the responsibility to point out when the objectives of the people’s representatives cannot be met with current technology. They do not, however, have the right to dictate what can and cannot be done in regulating their business. And most in the chemical industry understand and accept those limits.
The rules and regulations of our country are set by the representatives of all of the people. Anyone that can not accept that fact of life can leave and find some place with a ‘better’ set of rules; good luck and God speed. The rest of us are more than happy to live here and work within the rules as they exist; arguing back and forth trying to make this a better place to live. I guess that that makes us part of the ‘know nothing class’; so be it.