(81ap) Challenges In Applying Inherent Safety for Chemical Security

The application of inherent safer technology (IST) as a ?security measure' for chemical security is a very controversial and topic issue in process safety management. The Chemical Facility Anti-terrorism Standards (CFATS) of the US Department of Homeland Security as currently implemented offer inherent safety as an option, but not an explicit requirement, to manage chemical security. While problematic to apply, there are those who see it as an obvious solution to homeland security and are challenging the industry to implement inherent safety at a pace not seen in the past, even to propose it as a future amendment to the rule. What has been the experience of industry in addressing chemical security using IST to date? Has the rule been effective in encouraging asset owners to adopt such practices? If the rule was modified, what changes can the industry expect and how should a company prepare for this change? These are the questions to be addressed in this paper. Thus far the adoption of inherently safer principles has been mixed from direct application, i.e., substituting chemicals or reducing chemical inventories, to no specific action taken. Given it was a choice, this is to be expected. Arguably the high number of facilities that took some action similar to IST to avoid the regulatory obligation shows that the rule motivated them to address the chemicals in use, whether for regulatory or security reasons. The DHS believes this is a successful application of IST and was intentional in the design of CFATS. Critics believe that not enough has voluntarily been done to reduce the most significant risks to the public. The paper will discuss statistics for CFATS on these points and give several examples. Before the rule is modified, it is prudent to understand the challenges facing industry and to see if the ?low hanging fruit' opportunities were taken and whether the remaining situations are far more challenging and how to address the issue. If they are, the expected, outcome should the rule require implementation of IST, is a time-consuming effort, perhaps without clear guidance or rules, of proving that reasonable steps had been taken to consider IST options and to justify actions. Clearly there will be both possibilities (that may or may not be ?feasible'), and infeasible situations (that will have to be proven). This is an entirely different problem than has been addressed up to this point for both industry and the regulators, who will have to judge compliance to the rule. CFATS has, by its nature, an atypical and nontransparent risk assessment and decision-making process now, which complicates the IST decision process. The paper will explain key issues and examples of how the analysis of IST options and justification and risk decision-making process may evolve. This will help enlighten those considering the real impacts of IST regulation for chemical security, and prepare them for the challenges.