Bayer IST Study Moving Forward
According to a recent article on the Chemical & Engineering News web site the study is moving forward with the first public meeting on February 9th in Washington, D.C. The study report is expected to be published in September.
The article quotes Dorothy Zolandz, director of the NRC panel that is conducting the study, as explaining that:
“Here we have an actual on-the-ground plant that we can use to enlighten us about how these assessments are carried out, what their capabilities and limitations are, and so forth. We have a real case study”Since the recent CSB report on the 2008 fatal accident at the facility indicates that the owners took a number of safety measures to physically protect the MIC storage systems to prevent potential releases, it seems obvious that Bayer and its predecessors had a firm understanding of the safety issues they were dealing with. If that understanding was informed by a documented look at the potential alternatives to using MIC, then this NRC study may provide a valuable look at the IST process in a real world application.
An interesting look at the potential outcome of the study comes from Daniel Horowitz, CSB’s managing director of congressional, public, and board affairs; who is quoted as saying:
“Our interest has always been how inherently safer designs can benefit industry as they strive to make processes safer. We are hoping for advice from [NRC] on how we as an agency should look at these inherently safer technological issues in our accident investigations”IST as a Political Issue
While the noise around the political debate about the use of IST procedures as part of the CFATS process has diminished because of the recent political changes in the House and Senate, anyone that really expects this issue to disappear underestimates the concerns of many people in organizations like Greenpeace and many union organizations. While their political influence is on the wane (and that is always a potentially temporary situation in this country, as closely divided as we continue to be), they will continue to make their voices heard.
I have always tried to maintain a middle ground on the IST issue. I think that the basic concept of taking a serious look at the potential alternative chemical processes to reduce safety and security risks is something that anyone should be able to agree is a worthwhile exercise. The problem of requiring such an exercise as part of a security process is defining how is should be done. And that is something that neither side in the debate has been willing to discuss.
This study by the NRC may give us a good look at how an actual IST process has been conducted by industry. With the issue of the continued use of MIC at Bayer CropScience now a settled, we can hope that the study will spend more time looking at how the IST study process was conducted at the Institute, WV facility over the years. An NRC recommendation of how to conduct such a study would be a valuable contribution to the IST debate.
There is another contribution to this debate that ought to be studied. Many opponents of an IST mandate in CFATS have argued that the chemical industry already looks at IST as part of their business model. They point to the number of facilities that have changed their processes as a result of the CFATS regulations as how the current business model achieves IST results.
It would be interesting for someone to take a detailed look at how many of the facilities that have dropped out of the CFATS process (there were over 6,000 covered facilities in the original Top Screen evaluation and fewer than 5,000 facilities currently in the process) did so because of IST type process changes and how many were due to the current economic situation. This is a study that the Rep. King and his Republican fellows on the House Homeland Security Committee should have no problems supporting. It would be relatively cheap to conduct and would provide valuable information for the debate. And it could be inserted in the final FY 2011 budget.