Friday, May 7, 2010
CSB MIC Study Comments
The Chemical Safety Board has published on their site the public comments that they have received so far on their proposed National Academy of Sciences study on the methyl isocyanate situation at the Bayer CropScience plant in Institute, WV. They have posted eleven comments (including mine) though their 15 day comment period doesn’t actually end until Monday. The comments that they have received to date have been interesting and varied. They come mainly from academics and consultants. With the short response time that CSB provided for comments, I am not surprised that there have been so few comments received. What does concern me, however, is that many of the commentors are so unfamiliar with the public record of this particular case. A couple of the commentors suggested transportation safety measures for MIC, apparently unaware that the material is produced on-site. Other commentors suggested just-in-time or in situ manufacturing without realizing that the Institute plant uses a continuous manufacturing process so that it can supply MIC to multiple processes, including at least one not owned/operated by Bayer. Political Considerations Readers of this blog, and the smaller number that may be aware of my personal blog, will know that I am an admirer and ardent supporter of the work that the Chemical Safety Board does. This is one of the reasons that I was very happy to see that they would be responsible for the design of the NAS study of the IST issues at Bayer. Their single minded devotion to process safety and ability to delve into the minutia of safety issues will provide the proper focus for the planned study. I am not sure, however, that they realize that this is not solely, or perhaps even mainly, a process safety issue. In a much larger sense it is a very potent political issue. Both sides of the current debate on the use of IST techniques as security measures are going to be looking to this study to validate their particular view point. The side that does not receive that validation will, in the current political climate, almost certainly vilify the study and perhaps the messenger as well. The only way that the CSB is going to be able to avoid that political fight is to ensure that both sides have an ample opportunity to provide their input into the design process for the study. If CSB can get the support from both sides at the start of the study and the NAS provides a reasonably balanced (both technically and politically) study team, then the study will face much less criticism when it is published. While the Board is well known for its technical competency, they are not exactly political neophytes by any stretch of the imagination. I had hoped that they had the necessary political acumen to pull of a successful response to this techno-political problem. I was concerned when I saw the 15 day comment period and their failure to use the Regulation.gov comment mechanism. Seeing the lack of politically important commentors to date, has increased my level of concern. We still have today and Monday before the current comment period expires. We may yet get the necessary participation. Or, more likely, CSB will announce an extension of the comment period and then lobby the important parties to gain their participation.