Keep the focus on security
“Inherently Safer Technology,” or IST, is merely a conceptual approach to engineering involving chemical processing, equipment, protection and, when feasible, the use of less hazardous substances in these processes. It is not a technique, but merely a philosophical approach to reviewing a facility’s operations, and may or may not involve the substitution of certain chemicals for available alternatives. IST proponents who lobby for its inclusion in new security legislation, primarily environmental activists, believe that chemical substitution will result in more secure facilities that are less vulnerable to a terrorist attack. In the aftermath of 9/11, who would argue with the need to revisit and strengthen security protocols? Claims of easy IST implementation, however, fail several key tests.
IST is governed by the laws of physics and engineering, not the laws of politics and emotion. A reduction in hazard will result in a reduction in risk if, and only if, that hazard is not displaced or replaced by another hazard. Even if it were possible to simply switch from one chemical to another, switching often results in the mere transfer of risk from the chemical plant to some other entity, perhaps the surrounding community, with no actual risk-reduction registered. For example, a government mandate that forces a company to reduce the amount of a particular chemical at a facility could very well result in an increase in transportation and safety risk. The company still has to maintain the same level of production capacity and the only way to maintain current capacity is to increase the number of shipments—through the community—going into the chemical plant.
Chemical plants are not off-the-shelf kits purchased at the local hardware store. These facilities are custom-designed and engineered for very specific processes. Typically, switching from one substance to another requires significant plant and process modifications, which come at an enormous cost—potentially more than a hundred million dollars just for one site. These are significant costs that will surely place domestic productive capacity and jobs at risk.
Arguably the most important test for a government mandate is how to measure its effectiveness; in this case, an enhancement of security. This is where the concept of mandatory IST fails to meet these criteria. As a concept, not an actual technique, there is no valid method for measuring “inherent safety.” According to the world’s leading authorities’ past testimony on IST, there is no objective way to measure whether one process is inherently safer than another process. In other words, the government would have no way of verifying whether or not the mandate resulted in anything meaningful.
To be perfectly clear, chemical manufacturers do not oppose IST. The entire concept, in fact, was born in the chemical industry and developed by professional chemical engineers. The concept of IST has now been institutionalized throughout the nation’s leading engineering schools. What manufacturers do oppose is implementation of IST as a thinly veiled attempt to appease environmental activists and federally force their political product substitution agenda under false security pretenses. IST may be a great political sound bite, but it is not a panacea for security.
Since the days preceding 9/11, chemical businesses have recognized the need for increased security at their facilities. They have spent billions of dollars securing their plants and equipment, and are subject to some of the strictest environmental, health, safety and security regulations in the world. There is still plenty of real security work to be done, but let’s not allow some politicians to focus on political victory at the expense of sound policy. There is room for all interested parties to voice their concerns and opinions on preventing terrorist actions targeting chemical facilities. Let’s ensure that our focus remains on security rather than not-so-hidden agendas.
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