Community and Worker Right-To-Know News, January 1999
Experts Say Chemical Industry Must Tackle Y2K Problem on Several Fronts; R-T-K, Risk Management and Utility Readiness Among Issues
While many larger chemical companies have already begun to audit their computer equipment to make sure that the systems can properly interpret the year 2000, there are several other aspects of the "Y2K" problem that still need to be addressed, according to a panel of chemical safety experts gathered at a recent Chemical Safety Hazard Investigation Board (CSB) meeting. Many emergency response agencies and smaller utilities are not aware of the severity of the problem or simply lack the resources to ensure that, for example, communications systems will work or there will be sufficient water to handle a big fire on Jan. 1, 2000, the experts said.
John Koskinen, chairman of the President's Council on Year 2000 Conversion, told the panel that while he expects the electric power distribution grids, telecommunications systems and banking networks to function adequately, there are real risks in other areas. "A lot of small to medium-size businesses and smaller municipalities have come late to the game, if they have come at all," he said.
There is more likely to be a series of smaller crises rather than one major one, Koskinen said. The bigger risks come from the public overreacting, he said. "Industry needs to provide the public with a candid reassessment of where we are; without an alternative, people will rely on rumors," he said. "People panic when they perceive no one is managing the problem."
The need to act is very real, said Gerry Poje, a CSB member; the deadlines are certain and immutable. "The sources of Y2K problems are pervasive, involving computer hardware and software . . . and date-related problems can affect computer clock mechanisms, operating systems, software packages, libraries, tools and application software," he said.
The CSB meeting, held in Washington Dec. 18, was convened in response to a request from the Senate Special Committee on the Year 2000 Technology Problem. In a Nov. 2 letter to CSB Chairman Paul Hill, Sens. Robert Bennet, R-Utah, and Christopher Dodd, D-Conn., asked the agency to undertake a comprehensive review of: the extent of Y2K problems in automated supervisory control and embedded control systems; the awareness of small, medium and large companies about Y2K issues; how companies will address potential Y2K problems in their risk management program (RMP) plans, as required under Clean Air Act Section 112(r); and the appropriate role for other federal agencies to play.
Critical Need for Outreach
Many small to medium-sized firms will wait to fix whatever breaks, according to the experts, who said that larger, better-prepared companies have a critical role to play in sharing technical information about how to solve Y2K problems. Congress recognized the potential for defamation and liability issues to arise when companies closely collaborate and passed a law to specifically address this issue, Koskinen said. The Year 2000 Information and Readiness Disclosure Act, which was signed by the President in October, was developed to encourage the disclosure and exchange of information about computer processing problems, solutions, test practices and test results. Specifically, it relieves anyone making a statement about Y2K computer compliance information from liability in an action for defamation or trade disparagement to the extent such action is based on an allegedly false, inaccurate or misleading statement.
In a roundtable discussion, the panelists outlined the top five Y2K issues that deserve further attention:
Responsive Communication with Stakeholders — Given that there is no central government agency responsible for coordinating Y2K issues, the experts said, trade associations, professional engineering groups and labor unions have an important role to play in informing their members about the scope of the problem as well as possible solutions.
Chemical manufacturers also must reach out to their workforce as well as their neighbors beyond their fence line, Koskinen said. "It's important to establish a level of trust, to reassure people that the normal emergency response mechanisms have been reviewed and updated" for Y2K compliance, he said. "People have a tremendous amount of confidence in the body of local government - build on that."
Risk Management Program - Y2K compliance is another issue that companies must contend with in developing their RMP plans. According to Craig Matthiessen of the U.S. Environmental Protection Agency (EPA), Y2K problems should be addressed in the hazard assessment conducted as part of developing a worst-case scenario. The agency will shortly issue a press release regarding Y2K/RMP compliance. (For coverage of EPA's new Y2K enforcement policy, see the story on page 8.)
Utility Readiness - Companies need to build contingency plans that acknowledge the possibility that one or more utilities could fail and leave them without adequate power, telephone or water service. According to Ray Skinner, director of the U.S. Occupational Safety and Health Admin-istration's South Houston office, if companies need to shut down a plant, they should make sure that it is feasible to do so manually; that there is sufficient firewater in case sprinkler systems are inoperable; and that enough staff are available and appropriately trained.
Outreach to Small and Medium-sized Firms - Such firms tend to lack the necessary resources - including capital, engineering and information technology competency, and organizational support to address potential Y2K problems. Those firms handling highly hazardous chemicals are at even greater risk, the experts said. There are three basic questions that every firm needs to answer, said CSB's Phil Cogan: can it happen? can it happen to me? and are the consequences severe enough to care?
Equipment Testing Companies need to conduct realistic testing based on appropriate weather conditions, staffing and processes, the experts said. Chemical safety concerns include complete failure of safety-related systems, malfunctions of embedded microprocessors in equipment and potential failure to respond correctly to program instructions, Poje said. Computer technology failures could include outright crashes; the generation of large, observable errors; or small, accumulating errors in computer-derived data, he said.
CSB Chairman Hill is expected to issue a report based on the panel's recommendations later this month, and the Senate Committee plans to hold a hearing sometime in the spring.
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