Monday, June 30, 2008

Reader Comment – 6-29-08

Fred Millar has provided some comments on one of my recent blogs (see: "SVA – Facility Security Information").

Lack of Seriousness

He notes that the short comings that are pointed out in my blog indicate "lack of seriousness of these DHS programs".

I have to vehemently disagree here. What I would like my readers (including my readers at DHS) to understand is that what I intend is a critique not a criticism. Too many people in today’s culture do not understand the difference. A critique is an observation that is intended to be of assistance, to help a person or agency improve. A criticism is an observation made more in the way of an attack.

DHS has spent a great deal of time and energy working on the many documents required to support and illuminate these programs in the Chemical Facility Anti-Terrorism Standards. As a writer, a technical writer who has written many instructions in technical areas over the years, I greatly appreciate how hard it is to craft a set of instructions that is clear and concise. On the whole, the DHS writers have done a very credible job.

The other thing that must be remembered, my comments and suggestions are not word from on high. I have no access to "Truth". I only have observations and my personal opinions. I would like to think that they have some worth based on my background and their internal consistency, but they are only my opinion.

Chlorine the Only Weapon?

Fred questions why a terrorist would want to go to the effort of stealing or diverting chemicals "when we already daily pre-position for him or her the most dangerous industrial poison gas (TIH) chemicals in the middle of our 60 target cities?"

All I can say is that Fred has a severe case of chemical myopia. Yes, chlorine gas is a dangerous chemical, but it is certainly not the "most dangerous industrial poison gas"; for my money Hydrogen Fluoride is much more dangerous. There are other chemicals out there that are also dangerous, and many that are much more flexible in their utilization.

The 9/11 attackers did not seek to kill the largest number of people they could. They never would have flown into the Pentagon if that were their aim. They attacked specific targets for social, political and economic reasons, not just to kill people. Could some of those chlorine rail cars be used for political ends? It is very likely to be the case.

Are there other targets where other chemicals would be better suited as a weapon? The answer is an unqualified yes. Theft/diversion chemicals were selected for inclusion in Appendix A for just this reason.

Fred Millar is campaigning against chlorine. I think that that campaign may be short sighted and is certainly too narrowly focused. Do I agree that Chlorine is dangerous? Of course I do. Do I agree that it must be eliminated? I certainly do not, as I have said time and again.

DHS Must Have a Broader Focus

Fortunately, DHS does not have the luxury of being able to campaign against a single chemical, they are charged with developing a program for ensuring a minimal level of security for the gamut of highly hazardous chemicals. Have they thought of everything? Certainly not. Have they thought of things that I have missed? You bet.

My hope is that they will be given the chance to continue with their efforts and will continue to improve the program that they have started.

1 comment:

Anonymous said...


1.   Who told you I was "campaigning against chlorine"?  You are being mis-led.  I work on what one former top Bush Admin homeland security official testified in Congress is "the most serious [homeland security] vulnerability in the nation":  chemical plants and transportation.  The Bush Admin has consistently opposed any vigorous government role in both these areas, with the totally sham new FRA "routing" rule the most grotesque example of pretending to have a government while letting the corporations continue putting us at enormous risk.

2.   When I wrote "...the most dangerous (TIH) cargoes", that is plural, plainly.  Not just chlorine.

And the re-routing law I authored, as a consultant with the DC Council (which passed on a 10-1 vote and was upheld in Federal District Court), and after getting advice from my federal DOT career regulator friends, covered:
         a. both truck and rail shipments of through cargoes
         b. the four most dangerous classes of hazmat cargoes:  the top class of explosives, the top class of flammables, and the top two classes of toxics (solids and liquids, and [the whole class of] TIH poison gases -- the latter being the MAIN focus of all serious folks, with chlorine and ammonia within TIH cargoes as the main practical focus of the security efforts of federal regulators)  

Want to know why chlorine rises to the top of the agenda for many serious folks as something to reduce the risk of ?  Check p. 26 of the Chlorine Institute's venerable Pamphlet 74, "Estimating the Area Affected by a Chlorine Release" --  the lethal cloud from just one tank car stretches 15 miles downwind by 4 miles wide.  Think Americans at risk are being told that,  by their Local Emergency Planning Committees or by any Bush Administration agency?  Think again.  Some democracy, huh?


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