Tuesday, September 30, 2008

More Reader Comments 9-29-08

Fred Millar, a long time reader and commenter, had responses to two of yesterday’s blogs about TIH rail shipments. As old readers are sure to remember, Fred has been working on the issue of re-routing hazmat rail shipments, TIH shipments in particular. That means that I was expecting some input from Fred when I wrote the two blogs.

TIH Tracking System

The first blog was about the Savi SmartChain TSS® tracking system used by Dow Chemical (see: “TIH Shipment Tracking”). Fred responded to my remarks about using the system to get rid of the requirement to placard and mark TIH rail cars. Fred noted that:


  • “Rail workers, fire chiefs, citizen watchdog groups and other also need placards to see what they are dealing with.”

This is a point that I clearly overlooked. Actually, the system that I suggested would include fire chiefs, but that does leave the two other groups. The comments that I made in my second blog on this issue (see: “Reader Comment 9-29-08”) addressing the cell phone dead zones could be used to address this issue. Train crews and yard workers could receive the low-power radio transmissions identifying TIH railcars and their status. The transmissions could be encrypted for security purposes.


Citizen Watchdog Groups


That leaves the issue of Fred’s ‘citizen watchdog groups’. If Fred is limiting this to semi-official groups like Local Emergency Response Committees (LERCs; formed under EPA regulations), then providing them with the secured receivers would certainly raise eyebrows of only the most fanatical security gurus. Unfortunately, I don’t think that Fred would be willing to limit his definition that much.


There are a number of small, vocal groups around the country that have a much more adversarial relationship with their local chemical manufacturer. While a small number are just plain radical, anti-chemical activists, the majority are responses to public relations blunders or, even outright lies and deceptions, surrounding chemical incidents. These organizations keep an eye on chemical facilities because they do not trust the companies to keep them informed of on-site incidents that have off-site impacts.


Any effort to ‘hide’ TIH shipments from groups like this by removing placards and other markings will not be met with fatalistic acceptance. The only thing that will stop this issue from further aggravating the relationships between these groups and the chemical companies is to co-opt them into the process. This is something that should probably be broached and guided by security consultants for the facility. Remember, these groups have a strong interest in preventing terrorist attacks on these local facilities.


Rerouting TIH Shipments


In his closing comment on the first blog, Fred notes that Dow has done the ultimate in re-routing a large part of their TIH rail shipments. They moved the production of their chlorine and shortened their rail shipments from 1200 miles to 400 miles. This reduction in shipping mileage along with avoiding shipping through Chicago should reduce the potential threat of terrorist attack.


In his reply to the second blog Fred takes the opportunity to excoriate the railroads for their failure to re-route TIH shipments around 60 major urban areas in the United States. Actually, Fred is very aware of the complexity involved in the re-routing issue. Because of the varying ownership of rail lines,contractual relationships, and Federal regulations it is very difficult to route these shipments around urban areas. Fred has provided a link to a Friend’s of the Earth (FOE) White Paper examining the complexities of just one such re-routing issue.

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