Reader Comments - Hydrogen Facility Security

An interesting coincidence, I have received two comments on different blog posts about potential issues with hydrogen as a transportation fuel. One was a comment by a long time reader with a chemical safety background posted to a Short Takes post that included a link to an article about hydrogen fueling stations. Rosearray noted: “Widespread storage & use of hydrogen for transportation scares the sh!!!!t out of me as a safety hazard, not to mention potential for sabotage.”

I partially addressed those security concerns last month in a blog post about hydrogen fuel stations and the Chemical Facility Anti-Terrorism Standards (CFATS) program. In that post I talked about some uncertainties companies might face in planning for security measures that would comply with CFATS regulations. Those comments drew an email yesterday from my CFATS contact at CISA reminding me that the Office of Chemical Security already has programs in place to allow facilities to share preliminary information with CISA to help determine if a proposed facility might be covered under the CFATS program and what types of security measures might be required for regulatory compliance. This was not designed exclusively for hydrogen related facilities, but for the broader chemical facility audience that might be considering new facilities or expanding existing facilities. This is a good way to avoid unplanned expenses and regulatory headaches.

The general process is outlined in the CISA publication “Top-Screen Submission Considerations”.

As I discussed in my CFSN Detailed Analysis post (no longer behind paywall), if the hydrogen economy is to expand at the rate being considered by some congressional leaders, I think it would be more efficient for CISA to automate this process as part of their Chemical Security Assessment Tool (CSAT), but this early in the process, the tools currently in place would certainly work.