The recent terrorist attacks in Mumbai should serve as a reminder that we are all under threat; a threat made more real, perhaps, by the recent report of a blue-ribbon commission to Congress that a devastating terror attack using biological or nuclear weapons is likely somewhere in the world within the next five years. While we in industry can’t do much to prevent someone from setting off an anthrax bomb in the New York subway system, such warnings can act as a reminder to get our own acts together.
Not that industry and government have been sitting on their hands. Last year the Department of Homeland Security released its Chemical Facility Anti-Terrorism Standards Interim Final Rule, effective June 8, 2007, which, in DHS’s own words, “establishes risk-based performance standards for the security of our nation’s chemical facilities. It requires covered chemical facilities to prepare Security Vulnerability Assessments, which identify facility security vulnerabilities, and to develop and implement Site Security Plans, which include measures that satisfy the identified risk-based performance standards.” Appendix A was last modified in August of 2008, and Version 2.7.a of the CSAT Top-Screen Questions came out in November.
The American Chemistry Council provided much of the input for the regulations, and quotes ACC Senior Director for Security Ted Cromwell on Washington’s new view of the chemical industry: “The most refreshing aspect of our new relationship with the government is that our products, facilities and role in society are seen as assets to be protected, not just liabilities to be regulated.”
The Chemical Facility Anti-Terrorism Act of 2008 [H.R.5577.IH] was introduced in the House in March 11 of 2008 and three days later reported by the Committee on Homeland Security. H. Rept. 110-550, Part I. In October the House Committee on Energy and Commerce granted an extension for further consideration ending not later than Jan. 3, 2009. How much in the bill may change after the new members of Congress are seated and after the new administration takes office are unknown, including any possible shifts in the balance between carrot and stick, and in the amount of paperwork required.
We are undeniably more secure than we were on 9/11, yet I still don’t feel all that safe, That may be because there’s a rail line that runs within sight of my home, and a fair number of the trains that go past each day include tank cars. Many of those cars are defaced with graffiti, and I wonder: if a kid with a can of spray paint can so easily get to them, what’s to stop someone with more evil intent?