Thursday, March 19, 2009

Reader Comment 03-19-09 – CSB vs Bayer

Poppy left a comment on my blog from Monday about the CSB vs Bayer controversy. The comment provides links to a couple of articles/editorials on C&E News, a publication of the American Chemical Society about the secrecy-disclosure issue. I would add to that a link to the blog from the editor of the West Virginia Gazette. I was concerned that none of these mentioned the CSB press release from last Friday that announced that the public meeting was going forward. I just went back and confirmed that that press release was still on the CSB web site, so presumably the public meeting is still on. I still have not heard or seen anything that would indicate that there will be any restrictions on what the CSB will discuss about the results of their inspection. While I can understand the Bayer would not want any security details about their facility discussed in a public forum, I do not think that that is their real issue in this case. If it were they could have quietly contacted the Captain of the Port who could have had a quiet talk with the CSB. CSB could have gone forward with their original public meeting while practicing a little discretion about the discussion of security issues. But, looking at the CSB reports from previous incidents I see no indication that they would have had anything to say about security issues. Wait, let me modify that; unless they thought the security issue contributed to the accident. This has not been an issue to date, but it could conceivably be in this or some future case. But there is another way that the CSB could compromise security. Process Safety is Part of Security Process safety and facility security are curiously intertwined. A process that is not adequately protected from a safety stand point cannot be adequately defended from a terrorist attack. If the process controls (physical, electronic and human factors) are not designed to protect against all known and suspected catastrophic process upsets, the process becomes that much more susceptible to a successful terrorist attack. If, for example, there are not multiple redundant systems to protect against a known runaway reaction condition, a terrorist would only have to interrupt only a single control system feed to cause a catastrophic chemical reaction. Now if this is the type security issue that Bayer is trying to avoid having discussed, too bad. It is not something that has been addressed by either MTSA or CFATS. Neither Congress nor DHS is chemically savvy enough to have realized that process safety is part and parcel an integral component of facility security; which is a shame in many ways. I think the people from DHS would be much more aggressive at enforcing process safety rules than either EPA or OSHA has been to date. CSB will Investigate and Report CSB will continue to do what they do best. Investigate chemical related accidents and get to the root cause of the incident. And from their search they will distill the lessons that the chemical community needs to learn to move forward to a safer and more secure future. Bayer needs to do what so many other companies have done before them in this situation; suck it up, say the ‘mea culpa’, and fix the identified problems. If they can’t or won’t do that, security is the least of their problems.

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