Monday, September 8, 2008

Reader Comment 09-06-08

On Saturday there was an interesting reader comment posted to my blog  about DHS staffing (see: “DHS Inspections: Alternative Staffing Ideas”). Doc Fungus makes a number of interesting points.

It’s the Chemicals

He points out that: “CFATS is about security; but lets not forget why this is so important - it's about the chemicals involved”. He is, of course correct. While ‘security’ is important at all industrial facilities for a variety of reasons, high-risk chemical facilities are high-risk because of the special hazards associated with their on-site chemicals as targets for a terrorist attack.


Build on Existing Successes


He suggests that we ought to “to build upon the existing successes within the EPCRA, SARA Title III, RCRA, CERCLA programs”.  Unfortunately there are all too many examples where these environmental laws are poorly enforced and unevenly (I’m being kind) supported by industry. One only needs to at the recent public outcry from the Bayer CropScience incident in West Virginia to see how poorly these serve as a successful model for preventing a terrorist attack. While a large number of facilities work hard to comply with existing laws, a significant number work even harder to get around the current safety and environmental rules.


Doc Fungus himself points out that in “many parts of our country we still only have a fledgling capability to respond to a chemical spill, let alone launch a defensive posture involving a terrorist imployed (sic) event against a chemical facility.” True, there are many facilities and localities where there is a good working relationship between chemical facilities and local responders; places where real response drills are planned, executed and critiqued. But there are too many places where that is not the case.


First Responders will Respond


Finally, Doc Fungus asks: “Are we really not going to respond to an emergent event because of a lack of funding?” The simple answer is of course not. The brave men and women of the emergency response community will do their job with courage and dedication. Unfortunately, because of a lack of funding many of them will be injured or killed in their response.


This is one of the reasons that I am a firm and vocal supporter of a strengthened and permanent CFATS law. A law that requires detailed and coordinated emergency response plans. A law that requires those high-risk chemical facilities, the federal government and local responders work together to prevent attacks on high-risk chemical facilities and yet provides for a strong response framework if such an attack does occur.

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