Iowa Senators Upset About Propane Security Rules

An Associated Press article tells about how thetarget, therefore not a high risk facility. A propane tank
Senators from Iowa realized that the new chemicalin the middle of town may be a terrorist target, thus a
facility security regulations were going to affect manyhigh risk facility. The only way that DHS can make the
farmers from their state. The provision that caughtdetermination is for the Top Screen information to be
their attention is the Screening Threshold Quantitycompleted.
(STQ) of 7,500 lbs for Propane in the proposedThe completion of the Top Screen will be a minor
Appendix A to 6 CFR part 27. It seems that lots ofadministrative burden. It should not be beyond the
farmers use Propane for drying grain and have tankscompetency of any one capable of managing a
that hold more than 7,500 lbs.decent sized farm. There is, however, a way to
Of course, the Propane Industry initiated a significantconsolidate that administrative burden. The propane
letter writing campaign during the comment period thatsupply company could complete the Top Screen for
ended May 9th to call attention to this potentialtheir customers. All that it takes is for the customer to
problem. While DHS has yet to release the finalappoint the supplier as the Preparer for CSAT
version of Appendix A, the procedures they publishedsubmissions during the registration process, and even
for completing the Top Screen portion of the onlinethat can be done by the supplier, only requiring a
Chemical Security Assessment Tool (CSAT)signature by the customer.
continues to list the same STQ, so it seems likely thatThings get a little more complicated if DHS determines
when the final version of Appendix A is published thethat the propane tank makes the farmer (or whatever
STQ will still be 7,500 lbs.propane customer) a high risk facility, since a Security
What the regulations call for is that any facility withVulnerability Assessment and a Site Security Plan will
more than the STQ amount of any of the 300+then be required. Even then, the supplier (who has a
chemicals listed in the Appendix must complete thevested interest in the customer's continued use of
Top Screen portion of the CSAT. That information willpropane) can assist with the remainder of the process,
then be used by DHS to determine if the facility is amost of which will be cookie cutter security in any
high risk chemical facility. High risk chemical facilities willcase.
then be required to complete the other requirementsA tank containing 7,500 pounds of propane is a
of the new security regulations. Those not deemed topotential bomb, easily detonated by even a poorly
be a high risk can then essentially continue to ignoretrained terrorist. If that tank is in a high-profile location, it
security concerns.would certainly be a good terrorist target. Potential
DHS has not published the details of how they willterrorist targets must be secured, that was the central
determine which facilities are high risk facilities. Theymessage that we took away from the 9/11 attacks.
decided that that information would give too muchRather than trying to exempt targets because of the
guidance to potential terrorists. DHS has said that theypolitical pull of their owners, we need to try to find
will look at more than just the amount of chemicalsreasonable methods of protecting these potential
on-site; they will also look at the potentialtargets. Airline passengers put up with many indignities
consequences of a successful attack. Thus a farmerand inconveniences every time they get on an airplane;
with a tank out in the middle of an Iowa corn field isIowa farmers can certainly learn to deal with these
likely only to be a risk to his family, not a terroristregulations.