Chemical & Product Stewardship

Background

America’s wood and paper manufacturing industry is committed to operating safe facilities and is actively working with the Department of Homeland Security to achieve this goal. Our commitment to minimize the use of hazardous chemicals and carefully safeguard chemicals that we must use pre-dates the concept of chemical security. We have a remarkable track record of safe operation, and we are implementing facility security measures required by law since 2008. Congress should not change course by mandating hard-to-define concepts like “Inherently Safer Technologies” (IST).

Policy

Infrastructure security laws already passed by Congress -- such as the Chemical Facility Anti-Terrorism Standards, the Maritime Transportation Security Act, and Bioterrorism Act -- require the use of vulnerability assessments and security plans for private facilities but do not create a new requirement for IST. No other security law requires IST for good reasons.

  •  Increased Security Risks: Creating an “Inherently Safer Technology” requirement for American businesses in the name of national security may actually increase risks.  For example, reducing the volume of a hazardous chemical stored at a facility may increase truck, rail, or barge traffic, thereby potentially increasing overall risk.
  • Existing Mandates Have Yet To Be Fully Implemented: Companies that are required to develop vulnerability assessments and security plans have already invested substantial funds to comply with these existing mandates, and they have yet to be reviewed or approved by the Department of Homeland Security. The effectiveness of these investments should be considered before mandating an entirely new approach to chemical security. 
  • Expenses Imposed by New Mandates Will Cost Jobs and Harm the Economy: Mandating the substitution of processes or substances could impose new–and unsustainable–costs on the American paper industry. Converting a single facility to a new bleaching process could cost up to $200 million and increase energy demand by 32,000 MWh/yr with no guarantee of safety or security improvement. Mandating these new – and unnecessary – costs in the midst of a global economic slowdown will kill jobs and will not produce substantial security gains. 
  • These Facilities Are Already Covered By Extensive Safety Regulations: Existing federal requirements -- including the Occupational Safety and Health Administration’s Process Safety Management Program and the Environmental Protection Agency’s Risk Management Program -- already mandate safe practices for the use and storage of chemicals. 
  • IST Mandates Ignore Private Efforts  and Stifle Innovation: Our companies  already consider – and implement – the safest, most innovative, and cost-effective technologies. A government mandate for IST would allow bureaucrats and courts to determine the best technologies for businesses. Micromanagement by government would limit innovation and ignore years of industry practice which has resulted in a remarkable safety record. 
  • Security Legislation Should Focus On Security, Not Mandate Changes in Manufacturing Practices: Groups that have long sought the elimination of vital chemicals, such as chlorine, previously promoted IST as an environmental protection concept. These same groups have seized on anti-terrorism and homeland security as a new vehicle for the same unnecessary concept. Counter-terrorism legislation should focus on protecting facilities from terrorism, not promoting questionable environmental agendas.

Congress should reject IST proposals and continue its focus on steps that will produce real security in the war against terrorism.