Analysis // Ben FrankelHow to pay for greater chemical plant safety

Published 29 November 2007

Critics point to the price tag of the chemical plant safety measure as a reason why it should not be imposed on the chemical industry; they are wrong: Meaningful safety standards should be imposed on chemical plants, but since it is a public good, the taxpayers — not the industry alone — should shoulder the cost

After several years of debate, Congress finally approved measures which would impose safety standards on the thousands of chemical plants in the United States. Readers of the Daily Wire would know that we have consistently inveighed against an entirely inappropriate arrangement which was in place until the passage of that legislation: On the one hand, there was a consensus that short of direct nuclear attack on a U.S. city, no other event could precipitate a mass-casualty catastrophe as a terrorist attack on or a major accident in a chemical plant situated near residential areas would; on the other hand, heavy campaign donations by the chemical industry, mostly directed to Republican legislators, and pressures from the Bush White House, successfully prevented the fashioning of legislation which would create meaningful safety standards for these plants, allowing the industry instead to get away with what was euphemistically called “voluntary, industry-developed” standards. We quoted a chemical industry insider involved in setting up the industry-developed system who described it as “window dressing.”

There is no escaping the fact, though, that establishing and implementing safety measures cost more money than having no safety measures. Chemical plant safety legislation is now in place, and GSN’s Jacob Goodwin wants to know what would be the price tag of these new rules and regulations. “It’s not a pretty picture,” he writes. DHS has devised a risk-assessment methodology which it calls its Chemical Security Assessment Tool, aiming to help chemical plant owners and the federal government to determine which plants are most vulnerable to a crippling attack by terrorists. A DHS Web site will collect information about the types and quantities of chemicals which are stored at each plant — but also on farms, which use bomb-suitable chemicals as fertilizer. “All information collected supports the Department’s efforts to reduce the risk of a successful terrorist attack against chemical facilities,” explained the DHS national protection and programs directorate in a Federal Register notice last Friday.

What would the risk-assessment phase — the collection of information of on-site chemicals —take? Goodwin suggests we add up the numbers here. “If we’re to believe the estimates developed by DHS officials,” he writes, “16,667 owners or operators of chemical facilities will spend about one hour each registering as users of the new Web site, and another half hour being trained to use the Web site. Collectively, those steps will cost nearly $2.2 million nationwide.” These 16,667 owners or operators will then be asked to complete an online form, called the “Top Screen,” which will allow DHS officials to asses each plant’s vulnerabilities. DHS reckons each owner or operator will need about 30 hours filling out one Top Screen, which will consume nearly half a million hours of effort nationwide and cost another $44.3 million.

Note that about 2,500 chemical plant owners and operators will be required by DHS to complete an additional Security Vulnerability Assessment, or an alternative security program, which should consume another 153 hours per plant, or nearly four weeks of one individual’s time. This will add another 382,000 hours of effort nation-wide, which will cost an additional $34.7 million. About 2,100 owners or operators will instead be asked to complete a Site Security Plan, or an alternative security program, which should take about half as long as a Security Vulnerability Assessment. DHS estimates that a Site Security Plan should require about 80 hours of effort per plant, consuming 183,000 hours of work — plus $14.5 million