SOCMA Comments on DHS's Proposal for Chemical Site Security

February 8, 2007
Patricia Van Arnum
ePT--the Electronic Newsletter of Pharmaceutical Technology

Washington, DC (Feb. 7)-The Synthetic Organic Chemical Manufacturers Association (SOCMA) submitted comments to the US Department of Homeland Security in response to proposed DHS regulations on chemical site security, asking DHS to take into consideration the unique nature of the specialty batch manufacturing sector.

Washington, DC (Feb. 7)-The Synthetic Organic Chemical Manufacturers Association (SOCMA, www.socma.com) submitted comments to the US Department of Homeland Security (DHS, Washington, DC, www.dhs.gov)in response to proposed DHS regulations on chemical site security, asking DHS to take into consideration the unique nature of the specialty batch manufacturing sector.

SOCMA is the US-based trade association representing custom and batch manufacturers. The association includes contract manufacturing organizations supplying active pharmaceutical ingredients and intermediates to the pharmaceutical industry as well as contract manufacturers supplying specialty chemical sectors.

In late December, the DHS proposed regulations on site security for high-risk chemical facilities (see “DHS Proposes Regulations for Chemical Facilities,” in the Jan. 11, 2006 ePT).

The proposed regulations require that chemical facilities fitting certain profiles (based largely on data from the US Department of Environmental Protection risk management chemical safety program) complete a secure online risk assessment to determine overall risk. High-risk facilities will then be required to conduct vulnerability assessments and submit site-security plans that meet the department’s performance standards. 

 “The Department of Homeland Security did a good job in proposing a set of rules for chemical site security,” said SOCMA President, Joe Acker, in a statement. “With that said, we still have concerns regarding the way risk screening and vulnerability assessments will be carried out. Any risk-based approach must be based on the factors that take into account the attractiveness of a facility as a terrorist target.”

 

Some key points highlighted by SOCMA in its comments are:

  • DHS must consider variable risk when evaluating specialty and batch chemical facilities. The varying risks caused by the ever-changing chemicals and processes at specialty and batch sites must be more adequately addressed in the regulations.

  • The Top Screen program, an initial screening tool to identify chemical facilities at risk, should be refined by using a focused chemicals list to allow DHS to focus on high priority sites. Otherwise, there is concern that the Top Screen could screen in too many lower-risk facilities and overwhelm DHS.

  • The relative “attractiveness” of a target to terrorists is a key component that should be integrated into the vulnerability assessment method for chemical facilities. Features that make up the attractiveness of a chemical facility as a potential terrorist target can be more objectively analyzed with greater certainty than threats and attack scenarios.  

  • DHS should consider the asset-based approach as a viable alternative to the scenario-based approach to vulnerability assessment.

SOCMA’s comments may be found at: http://www.socma.org/PDFfiles/gr_pdf_files/Socma_Comments_on_Chemical_Facility_Anti-Terrorism_Standards_2-6-07.pdf