Wednesday, August 27, 2008

Chemical Facility Inspection Team Philosphy

In yesterday’s blog I looked at the factors that have delayed the fielding of the inspection teams that will visit every high-risk chemical facility in the United States. That blog was brought about by some questions asked by a reader, Brandon Williams. In addition to asking cogent questions, Brandon brought up some ideas that need to be considered when establishing teams like these.


Training and Background


The first thing that needs to be determined is the necessary qualifications for being an inspection team member. First off, there are very few people that have expertise in both security and chemistry. The situation is even worse when you consider that both fields have developed an impressive degree of specialization. This effectively means that there is no one that is really an expert in security or chemistry; they are experts in a limited subset of one of those fields.


I remember reading some where that DHS had decided that their initial hires (back in 2007) would be personnel from the security field. The idea was that they would have the primary skill set that would be lacking at chemical facilities. Chemical facilities would supply the chemical and engineering expertise, allowing for a well rounded team.


There is a problem with that rationale. There is a fundamental disconnect in vision and even language in people with a security background and those with a commercial or manufacturing outlook. Without experience in and around chemical facilities security personnel are going to have a difficult time communicating with personnel operating in that environment.


There is a group of people that have a requisite background in security and a basic familiarity with chemical manufacturing and distribution facilities. These are the people that have worked for the federal government in the Chemical Warfare Convention inspection process. These are the people that helped chemical facilities get ready for, and escort the international CWC inspection teams over the last ten years or so.


Enforcement or Assistance


The amount of communication required between inspectors and facilities will depend in large measure on the purpose of these teams. If their purpose is to enforce the CFATS regulations, then the level of communication required is relatively low. If their purpose is to help facilities achieve an acceptable level of security against terrorist attacks a great deal of two-way communication is required.


My high-school English teacher would have complained that the phrase ‘two-way communication’ was unnecessarily repetitive; communication requires a two-way exchange of information or ideas. Anyone that has sat through an EPA, OSHA, or DOT compliance inspection understands why the repetition is necessary. I can still recall a plant manager telling us: “Don’t say anything more than necessary. Answer all questions truthfully, but don’t provide more information than asked for”.


There are those that insist that federal inspectors are there to ensure that regulations are followed, that an adversarial environment is inevitable. In my opinion that is a fundamentally flawed outlook. It underlines the basic failure of both OSHA and EPA to make workers or neighbors safer. It ensures that inspections are limited to paperwork drills with inspectors seeing just what they ask to see, no more.


Checklist Inspections


With a small number of inspectors and a large number of complex facilities to inspect and re-inspect there will be a natural tendency for an inspector to arrive with a checklist of things to see. Those items will be looked at; a few pointed questions will be asked and succinctly answered; then the inspector will move on to the next facility. This will ensure that facility reports are easy to write and a year-end report can be prepared for congress showing that the agency met its requirement to check all 7,000 high-risk facilities.


As time goes on, budget cuts will result in fewer inspectors. They will conduct shorter and more infrequent inspections. There will be minimal communication between inspectors and facilities. The result will be an agency that is no more effective than OSHA or EPA at proactively detecting and preventing problems. The problem is that a failure of the DHS CFATS program will result in one or more successful terrorist attacks on vulnerable chemical facilities.

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