By L. Vance Taylor, Guest Contributor
You’ve got to give it up for the masters of wordplay, you know, the guys who take offensive or politically charged phrases and weave them into neutral or even positive terms. Like the guy who took ‘global warming’ and gave us ‘climate change.’ To you good sir, I say “Bravo! You are a true word wizard.”
Or what about the person responsible for making the garbage man into a ‘sanitary engineer?’ Kudos to you, whoever you are!
While I’m typically a fan of such creativity, I’m finding myself a little miffed with whoever coined the term ‘Inherently Safer Technology’ (IST). Sure it sounds good -who doesn’t want to replace hazardous substances with something that works just as well AND is ‘inherently’ safer? But, is IST all it’s cracked up to be or is it just another example of a Washington snow job?
Whatever you do, don’t ask Congress for the answer because apparently majority members on both the House Homeland Security and the House Energy and Commerce Committees have decided to decide before hearing all the facts…
Section 550 of the 2007 Department of Homeland Security Appropriations Act authorized DHS to issue a rule known as the Chemical Facility Anti-Terrorism Standards (CFATS). Under the rule, DHS is making chemical facilities conduct vulnerability assessments and implement Site Security Plans. The basic idea behind CFATS is for DHS to work with chemical facilities to ensure they are incorporating the appropriate security measures needed to safeguard their onsite chemicals of interest. As it exists today, CFATS focuses on reducing risk by enhancing physical security. CFATS does NOT provide DHS with authority to force facilities to adopt IST. In other words, the Department isn’t as interested in the chemicals you use as they are in the steps you’re taking to physically protect them.
Last Thursday (June 12, 2008), DHS and EPA officials testified before Congress that CFATS, which sunsets in October 2009, should be made permanent and expanded to incorporate water utilities. While I can easily argue that the water sector should maintain its exemption to the rule, I’ll spare you (for now). According to the June 12th testimony of the EPA’s Assistant Administrator for Water Benjamin Grumbles, the chemical of greatest concern to the Agency is chlorine. Suffice to say that the water sector, (which is actually required by EPA to use chlorine) has already been proactive in protecting itself, its customers and the communities in which they reside and completed vulnerability assessments and voluntarily spent millions of dollars incorporating security measures to protect onsite chemicals. Nonetheless, for liberal groups like the Center for American Progress (CAP), that isn’t enough. According to CAP and its Senior Fellow P.J. Crowley, Congress needs to provide DHS with authority to mandate that water facilities adopt so-called ISTs.
What really drives me nuts is that for guys like Crowley (whom I personally like and respect), ‘progress’ is never enough, and there’s no such thing as compromise. Forget that due to local environmental circumstances the adoption of ISTs could lead to serious health problems for certain communities; forget that utilities like the Metropolitan Water District of Southern California literally employ their own police force, use biometrics, and have their facilities so locked down that Jack Bauer himself couldn’t rob it. Apparently, that’s not enough progress. For CAP, the company line seems to be that it’s IST or the high way.
Well P.J., allow me to drop some knowledge on you: Choosing disinfection processes isn’t exactly a Coke vs. Pepsi type of decision. Some utilities couldn’t adopt IST even if they wanted to because of things such as physical space limitations, economic implications, footprint issues, or preexisting local regulatory requirements precluding them from doing so. Believe it or not, the best people to judge risk reduction options at local water utilities (which you should know differ greatly from one city to another) aren’t Washington bureaucrats or Members of Congress, it’s the experts who reside within those communities. Do we really want Congress playing ‘chemistry mix and match’ when they can’t pass a budget or anything else in a timely manner?
It’s ironic that in response to the incorporation of gaseous chlorine in terrorist attacks in Iraq, officials decided to ‘reduce the risk’ by holding up chlorine at the border only to discover that doing so led to major cholera outbreaks. All told, only two deaths have been directly attributed to the use of chlorine gas in Iraq while the death toll caused by the cholera outbreaks continues to rise.
Don’t get me wrong, I’m not saying IST is bad and gaseous chlorine is good. All I’m saying is that switching one out for the other isn’t always possible, advisable, or ‘inherently’ safer. Local utilities need to evaluate their disinfection options, weigh the risks of adopting alternatives, and choose accordingly. If the feds want to ensure utilities are properly securing their chemicals by bringing them into the CFATS regime, fine – the water sector has never shied away from security or shirked its responsibility to protect public health. In fact, this industry has led the way multiple times. But stripping local choice in favor of letting big government tinker with how my water supply gets treated – that just sounds inherently stupid.
L. Vance Taylor is a principal with Olive, Edwards, & Cooper who has worked to advance the mission of homeland security on Capitol Hill and in the private sector. One of only approximately 250 people in the nation with a Master’s degree in Homeland Security, Mr. Taylor combines specialized educational training with real-world experience to leverage successful outcomes for clients and stakeholders. Read his full biography here.