Anhydrous Ammonia Theft

I haven’t talked about this issue in a while but I ran across an interesting article about one of the larger anhydrous ammonia thefts that I have ever seen. The article notes that a trailer used to apply anhydrous ammonia fertilizer to fields was stolen from a farm outside of Kalamazoo, MI. The empty 1,000-gallon tank was later recovered.

Terrorist Weapon?

As with presumably all such thefts to date this trailer was taken and emptied in support of the illicit manufacture of methamphetamines. If that was the case her, the thieves have a problem on their hand; according to the article “the ammonia was treated with GloTell, a substance that dyes the product bright pink and makes it unsuitable for meth production”.

With that said, could this type theft be a precursor for a terrorist chemical attack? It certainly could as any toxic inhalation chemical could be used in an attack. That is why anhydrous ammonia is a DHS chemical of interest (COI). It is listed in Appendix A as a release – toxic chemical and as such has a screening threshold quantity (STQ) of 10,000 lbs. While agricultural production facilities are exempted submitting Top Screens, if this farmer never had more than the quantity found in this trailer (reportedly 4,000 lbs) on site no Top Screen submission would be required.

Does that mean that this smaller quantity could not be used as a terrorist weapon? Certainly not. In many ways this quantity, in a portable tank, is much more useable as a weapon as it could be delivered to an appropriate target and the TIH material released there. In normal transport or in fixed tanks the material would have to be in the right place at the right time for it to be an effective weapon.

Why Not a Theft Diversion COI?

This begs the question, why isn’t anhydrous ammonia listed in Appendix A as a theft-diversion COI as well as a release COI? Chlorine gas, for example, is dual listed and these two chemicals share many traits; both are readily available TIH industrial chemicals. They both cause serious damage to the respiratory system in less than lethal concentrations. Chlorine is listed as a theft-WME (weapon of mass effect) COI with an STQ of 500 lbs in portable containers.

Technically, chlorine is listed as a theft-WME COI and anhydrous ammonia isn’t because chlorine was used as a war gas in WWI and is listed in the Chemical Weapons Convention list of chemical weapons. Anhydrous ammonia was never used or seriously considered for chemical weapons use and is not included in the Convention’s list of chemical weapons or their precursors.

Anhydrous ammonia was not considered for use as a chemical weapon because of its affinity for water, even water vapor in the air. This could seriously inhibit its functionality as a war gas. This wouldn’t have any practical effect on the effectiveness of its use against terrorist targets especially within buildings like shopping malls, schools, churches or other soft targets.

Agriculture Exemption

I am relatively certain that this CWC technicality was not the main reason that anhydrous ammonia was never considered as a theft-diversion COI when DHS put together Appendix A. One of the industries that use huge quantities of this material is agriculture where it is used as a very effective and cheap nitrogen fertilizer. It is typically hauled to fields in these 1,000-gallon tanks (they look like large propane tanks on wheels) and these tanks are then used to disperse the material into the ground before planting.

If DHS had included anhydrous ammonia as a theft-diversion COI it would have raised the cost of the use of this fertilizer and the agriculture industry would have raised fits. If you don’t think that this had any influence on the listing decision consider the case of propane. Because of the concerns of the agriculture industry and their tame Senators the STQ for propane (widely used on farms and other production facilities for a variety of heating uses) was set at 60,000 lbs instead of the 10,000 pounds set for similar release flammable COI.

Or consider the fact that the farmers, or their employees, hauling these trailers from the local supplier to their fields do not have to have hazardous material endorsements on their commercial driver’s license. PHMSA has given them a blanket agricultural exemption from that requirement.

Appendix A Review

This is another chemical of concern that needs to have its status reviewed during the current discussions about amendments to Appendix A of the CFATS regulations. This is particularly true since State regulations trying to prevent the theft of anhydrous ammonia for use in the manufacture of methamphetamines.