Sunday, February 21, 2010

Reader Comment 02-19-10 IST Misstated

Anonymous posted a comment about an earlier blog about the introduction to Sen. Collins’ S 2998. Anonymous’ full posting can be seen at the end of that blog, but it does included this important quote from a statement made by Sen. Collins:
“Forcing chemical facilities to implement IST could wreak economic havoc on some facilities and affect the availability of products that all Americans take for granted. For instance, according to October 2009 testimony by the Society of Chemical Manufacturers and Affiliates before the House Committee on Energy and Commerce, mandatory IST would negatively restrict the production of pharmaceuticals and microelectronics, unnecessarily crippling those industries.”
In today’s political climate we have come to expect and excuse politicians exaggerating their opponent’s position into something that can not be easily equated with the perceived reality. This is one of the reasons that the public is so disgusted with the political process. It was, however, professionally disheartening to me to see an organization that I have had a great deal of personal respect for stoop to the same level of disinformation in their Congressional testimony, especially when it is subsequently used by professional politicians to justify their own misinformed stand on an issue. There are a number of serious shortcomings with the IST language in HR 2868. First conducting an IST concurrently with the SSP submission is counterproductive since it does not allow for full accounting for the security costs of not applying the IST in determining the financial feasibility of the program. The language seriously underestimates the complexity of conducting an IST assessment in a chemical manufacturing environment and doesn’t provide a way out of the implementation when new and more detailed information shows that a marginal IST process it is no longer technically or financially feasible. It provides no inducement for industry to conduct the necessary research to develop useable IST programs. Ignoring these real difficulties (that could be overcome if industry, activists and Congress would work together) while slandering an entire piece of necessary legislation with made-up problems demeans the political process and provides legitimate adversaries with further justification for their mistrust of the chemical industry. The pharmaceutical industry is almost certainly the least likely industry in the United States to be affected by the current IST language in HR 2868. Their formulations and manufacturing procedures are strictly controlled by the Food and Drug Administration and can only be changed after extensive research, testing and evaluation. The time for completing those process change procedures would certainly be justification, under this legislation, for declaring that there is no current IST option available for assessment. Likewise, the electronic industry’s well known need for pure, uncontaminated raw materials mean that there will have been little process work done on diluted acids (for example) to replace the anhydrous materials currently in use. The lack of detailed process work that must precede the assessment of alternative materials would preclude the affirmative assessment that there are technically feasible alternatives to the chemicals currently in use. In fact, throughout the chemical manufacturing industry there will be very few alternative chemicals that will have had the laboratory and process research, or the customer re-evaluation of the manufactured product necessary to determine if there is a technically viable alternative process. In fact, it is not uncommon for manufacturers belonging to SOCMA to require months or years of work to qualify the same raw materials from alternative suppliers. Introduction of new materials typically requires years of research, testing, and evaluation. There are legitimate problems with the current legislation. Rather than throwing up straw obstacles to non-existent problems the chemical industry needs to work pro-actively with Congress to develop real, workable chemical security legislation. Doing anything less will just provide further ammunition to the more radical activist organizations proving that the chemical industry does not care about the safety and security of their workers and neighbors.

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