Tuesday, November 3, 2009
Chemplant Database Updated
For my ‘liberal environmentalist’ readers, this will be old news, but last week the organization OMB Watch updated their on-line ‘Chemical Security Database’. This title is only slightly misleading as it is a copy of the RMP database that the Environmental Protection Agency that the EPA used to keep on-line. After the 9-11 attacks this data base was moved off-line, but is still publicly available in EPA Reading Rooms across the country. I said, ‘slightly misleading’, because DHS did not only use only the RMP status in setting up the list of Chemicals of Interest (Appendix A to 6 CFR 27), and did not include all of the RMP chemicals on that list. For example, the generic ‘flammable liquids’ did not make the COI list while many CW precursors on the COI list do not make the RMP list. Having said that, this database is the most readily available listing of facilities that have many of the COI on site. One minor problem with this list is that it is static; it only reflects RMP status as of a single date last summer. This is because OMB Watch does not have ‘real time’ access to the EPA database. They have to send people to the Reading Rooms to compile this data. RTK vs Security The re-publication of this database will again bring up the discussion of weighing the public’s right-to-know (RTK) versus keeping potential targeting information out of the hands of terrorists. First off, Federal law requires this information to be made public, because the public does have a legal right to know what dangerous chemicals are being used and stored in their communities. This is why OMB Watch was able to compile this information without fear of legal retaliation. The public has a right to know what risks it faces from potential terrorist attacks on local facilities or even just accidental releases at those facilities. While many chemical companies are open and honest in their communications with the local communities, too many have a history of secrecy and denial. Publication of this database allows community activists and, hopefully, local elected officials to press companies for public engagement. Having said that, it is also clear that this on-line database is searchable from all over the world. It will make it easier for enemies of this country to find and target potential high-risk chemical facilities. This causes some level of concern in the chemical security community. Does this increase the risk of a terrorist attack? By some small amount it probably does. It does provide international terrorists with a searchable list that could be used to identify which chemical facilities, if successfully attacked, would provide the largest possible potential impact. The terrorists would still have a lot of work to go from that list to executing a potential attack. Eliminating this type of list would not eliminate that risk. There are enough news stories and environmentalist ‘rantings’ about dangerous facilities that an only slightly longer internet literature search would certainly identify these facilities. Local, homegrown terrorists, on the other hand have almost no need for this list. Local community activists have a good idea of what hazardous chemicals are located in their community and readily try to share this information with their communities. Lacking that source, all someone has to do is to conduct a cursory surveillance of a chemical facility to get a decent understanding of the hazards associated with chemicals moving into or out of the facility by watching placards on tank trucks and rail cars. Some local terrorists will even have inside information from working at or having worked at the facilities. Negligible Security Risk No, while there is a slight increase in risk associated with a publicly searchable data base such as this, it is negligible. The benefit provided by this list to informed public discourse on safety and security far out weighs the risk.