There was a link today on the SOCMA Blog site (used to be Joe’s Blog) to an article on the SecurityManagement.com web site about IST. That article by Joseph Straw is a relatively balanced look at the IST issue facing Congress and the chemical security community. Now this article is not an article by SOCMA, nor have I seen a specific endorsement of this article by SOCMA; simply a link to it on the SOCMA page. There is also a link to this blog on that page and I think that I can safely say that SOCMA has not endorsed my comments about them.
So, why am I pointing out this article as a new face of SOCMA opposition to IST (which hasn’t changed as far as I can tell)? Well, my comment is based on an observation made by Mr. Straw in his article; he writes:
“Other chemical industry groups, including SOCMA, which represents smaller specialty chemical manufacturers, oppose both the regulatory authority and the assessment requirement, which critics argue would pose an undue burden on small operations.”Now, this is an argument that I haven’t seen addressed before, and I think it is one that should be expanded upon by SOCMA and must be addressed by IST proponents. Let me see if I can take a stab at the first part of that.
Types of IST Assessments
First we have to remember that there are a wide range of chemical engineering techniques that fall under the IST banner. Chemical substitution (with a less hazardous chemical) is the one that gets most of the news space by both proponents and opponents of the legislative mandate. There are inventory control measures that reduce the releaseable quantities on site. There are process control measures that reduce temperatures and pressures that would also limit the amount of a release in the event of a successful attack. Release mitigation measures that would stop a release from leaving the facility could be included in the broad banner of Inherently Safer Technology.
Known Chemical Replacement
Making an assessment of IST alternatives could cover all of these types of actions. The simplest, of course, is where there is a near drop in chemical replacement that is less hazardous. The premier example of that is the replacement of chlorine gas by sodium hypochlorite in water disinfection processes.
The chemical substitution here is pretty well understood and would require little research. The assessment then would be a fairly straightforward chemical engineering assessment of the cost of designing, buying, installing and operating the necessary new equipment. The cost would then be compared to the continued operating costs of the chlorine gas process plus the cost of security required to protect that system against a terrorist attack.
If the resulting assessment showed a marginal result in favor of the switch and the utility did not desire to switch to hypochlorite, the facility could then look at their supply chain for the hypochlorite to see if their business would increase the security risk at the hypochlorite supplier’s facility so that they became a CFATS covered facility or increased their DHS Tier ranking to a level One or Two. That would allow, under the current version of HR 2868, the facility to decline to implement the changeover to hypochlorite.
Now the engineering studies necessary to complete such an assessment could be costly. The current legislation does not address the cost of conducting the assessment, but does allow for grant monies to be made available to offset the costs of the conversion. Of course if the engineering work made it clear that the implementation were too expensive, even the grant money would not be available.
Another relatively easy technique to apply to reduce the release probability for a high-risk facility is inventory management. The simplest form of this is to simply reduce the maximum intended inventory on site by taking more frequent and perhaps smaller shipments of the hazardous material in question. Drafters of HR 2868 intend to discourage that sort of IST because it transfers the risk to the transportation sector where it is more difficult to prevent a terrorist attack.
Another inventory management technique that has received less attention is similar to what Bayer CropScience recently announced what it would do with MIC at their Institute, WV facility. That facility produces MIC that is later used on site for the manufacture of a number of different products. They recently announced that they would reduce their maximum inventory of MIC by 80%. This can be done by decreasing the products made that consume MIC or by increasing the frequency of production.
The assessment of the costs of these types of inventory control techniques can be costly and time consuming. They may involve a great deal of market research, sales and production modeling. They also involve some significant process safety assessment work to determine if the increased risks associated with starting and stopping production processes off set the risks associated with storage.
The final inventory control technique is one that I haven’t seen discussed elsewhere; I call it dispersed storage. This is a technique that is used extensively in munitions and explosives manufacturing. A number of smaller and isolated storage tanks are used to replace larger more centralized storage facilities. To obtain the same size of release a terrorist would have to overcome security controls at a number of storage tanks, reducing the likelihood of achieving the large scale release possible against a single successful attack on a large storage tank. Again there would be significant engineering costs associated with the design of such a system, something that would be necessary before a comparative cost assessment could be made.
Costs of Assessments
This is just a brief look at two of the types of assessments that could be required by legislation like HR 2868. So we can see that the cost burden on a small chemical manufacturer, just to conduct the assessment, could be substantial. This potential burden needs to be addressed in the political discussions that are proceeding in the Senate on this issue.