A requirement to consider IST is much more problematic. One company spent nearly as much time focusing on inherent safety as it did on its entire security vulnerability assessment. Any national legislation involving IST will almost certainly impose inordinate time demands.
Putting security into focus
New legislative requirement or not — sites that manufacture, use or store hazardous chemicals will be under continued pressure to take measures to increase security. “Critical” facilities will be expected to conduct vulnerability assessments, implement security measures to address the vulnerabilities, and develop security management plans. In the absence of new regulatory authority, DHS will work through chemical sector partners to implement such measure on a voluntary basis. A new chemical security law will give DHS authority to compel such actions.
Security assessment and planning will be demanding, particularly for companies and facilities that have not already taken such steps. Any requirement for IST evaluations and implementation may be especially challenging.
Efforts focused on inherent safety may identify some good risk-reduction opportunities, particularly at sites that have not previously embraced the concept. However, in practice, the approach can’t substantially reduce overall security risk because cost and other factors limit the opportunities for making step changes in the type and quantity of hazardous materials in existing facilities. This is especially true where facilities manufacture a hazardous material or use such materials as feedstocks or catalysts and there are few or no alternatives. Major improvements will generally require substantial investments to modify processes using alternative chemistries or to cut inventories, for example, by constructing a unit onsite to generate only enough of the hazardous materials needed for immediate consumption. In some cases this may be feasible but in most cases it will not. As with process safety, it should be left to the judgment and expertise of knowledgeable company personnel to determine whether IST implementation makes sense for their facility.
The prospect of chemical security regulations is very significant and yet, the outlook still isn’t perfectly clear on the final shape and timing of any requirements. They could potentially create a federal mandate on security of the chemical industry, incorporate the need to evaluate inherent safety more widely than any other regulation in the U.S., and force industry to prove compliance to security “standards.” The challenge for DHS and all those who participate in the regulatory development process will be to make such rules rational, measured, cost-effective and fully justified.
David A. Moore, P.E., C.S.P., is president and C.E.O. of the AcuTech Consulting Group, Alexandria, Va. E-mail him at firstname.lastname@example.org. Dorothy Kellogg, M.P.A., is a senior consultant with the AcuTech Consulting Group in Alexandria, Va. E-mail her at email@example.com.