I received an interesting email from a reader about the CFATS delay blog that I wrote earlier this week. He noted that Congress would not get upset about Beer’s less than complete testimony about SSP delays because “CFATS is a success”. In many ways I have to agree. As I have said on numerous occasions, DHS has done a great job in getting this program up and running. A major reason for their success to date is that they have really worked with industry to put into place a workable and effective regulatory program that actually increases security at high-risk chemical facilities.
What I am afraid of is that all of that could get ruined if DHS has to start cutting corners in this program because it does not have the necessary resources to complete the SSP review/approval process. In an era of increasing budgetary constraints it would become very easy for this process to turn into a rubber stamp of submitted site security plans. If that happens, then CFATS will go the way of EPA and OSHA chemical safety programs; responsive only after the fact. Unfortunately an after-the-fact inspection in the DHS sense could mean the deaths of thousands of people as the result of a terrorist attack.
My friends at SOCMA and ACC are quick to point out that they have been working hard at security long before CFATS and that is true. I worked at a facility that worked hard at getting their Responsible Care certification, but did not have a real effective security program because they just did not understand security. It wasn’t that they tried to take shortcuts to try to skate by, but they did take shortcuts because no one had ever told them the proper way to do things.
If this could happen at a Responsible Care facility, just think about the security measures that are routinely found at smaller facilities. One just has to look at the number of anhydrous ammonia releases at farm supply stores across this country because of theft by amateur methamphetamine manufacturers to see how lax security is at many potentially high-risk facilities.
Until we get an effective CFATS process down to the Tier 3 and 4 facilities across this country, the vast number of the covered facilities, we can’t really call the CFAT program a success. And it won’t continue to be a success if it starts to take the easy way out on SSPs; high-risk facilities must be held to standards that favor security.