Monday, November 24, 2008

Reader Comments 11-21-08

Last Friday the ever present Anonymous left a comment about my blog (see: "New IST Report from Center for American Progress") concerning the recently released report from the Center for American Progress. Among other things, he took exception to one of the ‘goals’ of the CAP report, the one about utilizing the ‘experience and knowledge of facility employees’ in conducting SVAs and formulating SSPs. Employee Involvement His comment was that: “Many of the employees of these facilities have limited knowledge and experience with regards to REAL security.” I’ll go one better and state that, in my experience, almost no employees, hourly or salaried, had any significant knowledge or experience with security. The rare exception came to the job with security experience from the military. Does that mean that they should be excluded from the assessment and planning process? Absolutely not! At the facilities where I worked, we always had one of the hourly workers sit in on all of the safety reviews. It wasn’t because of their superior knowledge of process safety; it was because of their superior knowledge of plant processes. The chemists and engineers certainly knew more about the safe limits of the process, but the workers knew more about how the operators actually did things and reacted to things. This knowledge was important to designing the process and writing the instructions that the operators would be required to execute. This is why safety reviews and process hazard analyses are always conducted by a team. The problem will be worse, of course, for security assessments and security planning. Since essentially no one from the facility will have an adequate security background, the facility will have to rely on security professionals, either consultants or hired to staff. Those security professionals will not have anywhere near an adequate understanding of the process safety concerns that will play into the security plan. Worse, they will not talk the same language as the facility operational personnel. As facility employees receive the necessary training and get hands on experience with security processes this problem will ease. Facilities that use consultants for their security professionals will continue to have a language translation problem unless they establish a long-term relationship with their consultant to provide for an adequate learning curve. Facilities that hire staff security professionals will have a shorter learning curve and a better working relationship. Robust Security Forces Anonymous made another comment, almost in passing, which I think is very important and practically ignored in the recently released Draft Risk Based Performance Standard guidance document. He said that: “While the various companies might hire Wackenhut or similar security guard companies for onsite ‘security,’ what is needed for some of these Tier 1 facilities are real response and security forces similar to Nuclear Power Plant facilities.” For Tier 1 facilities, those that pose the highest risk of terrorist attack, are going to require more than a gate guard and security system monitors. There will have to be someone on site that is capable of intercepting and detaining armed intruders. This is going to require an armed security force, with all of the problems attendant to that situation. See my discussion at “Security Forces at Chemical Facilities – Sourcing Security”. Someone is going to have to take a hard look at what types of weapons can safely be used in an environment packed with flammable, toxic and/or explosive chemical compounds Anonymous One personal note, I really like to hear from my readers. I want to see their comments and I enjoy hearing their points of view and ideas. Hopefully, so do my other readers. Having said that, I have to say that I really do not like names like ‘Anonymous’. I do understand that there are people that, for a variety of political or legal reasons, cannot make public comments about security matters. I would prefer that they contact me by email ( rather than using a nom-de-guere (I hope my French spelling is correct), but I realize that even that may not provide adequate deniability. Be forewarned, though, that I will be much more likely to delete an anonymous comment that is even borderline discourteous or malicious.

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