However, Rep. Dan Lungren (R-CA), chairman of the subcommittee, expressed concern over CFATS's emphasis on inherently safer technologies (IST), a concept where the types of chemicals or processes used are altered to reduce the security risk. “IST isn’t something you can buy off the shelf or simply plug in," he said. "It is a concept, a not very well understood concept at that.”
Witnesses disagreed on the issue.
Beers advocated that all high risk chemical facilities should assess IST methods and report those assessments in the site security plans. Beers also noted that facilities posing the highest degree of risk should be required to implement IST if such methods “demonstrably enhance overall security, are determined to be feasible, and, in the case of water sector facilities, consider public health and environmental requirements.”
Scott noted that mandating the use of any particular security method, including IST, would undermine the very feature that makes CFATS a success. “The program is predicated on the idea that performance standards are the regulatory tool of choice for ensuring security, as they can be met by the facility selecting from a variety of layered security measures that best suit that specific facility.”
M. Sam Mannan, regents professor and director of chemical engineering at Texas A&M University, argued that mandating IST could backfire, making facilities less secure. He notes that designing IST into a facility is a complex task and, in many cases, could result in unintended consequences that result in more risk or simply transfer the risk elsewhere.
Mannan noted, for example, that replacing chlorine with a less combustible sodium hypochlorite could be considered a IST success. However, sodium hypochlorite is manufactured from chlorine, thus the risk has merely been transferred to another facility. Furthermore, unlike chlorine, sodium hypochlorite decomposes into perchlorates, which are toxic to humans.
Mannan also noted that IST is most successful when factored into the planning stages making it impractical for most facilities. “Because inherent safety is an intrinsic feature of the design, it is best implemented early in the design of a process plant…the U.S. has a huge base of installed process plants and little new construction,” said Mannan.
♦ Photo by Accretion Disc/Flickr