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Testimony on Chem Site Security

Posted: February 26, 2008

David Pulham, director of compliance for Siegfried USA (Pennsville, NJ), is testifying before the House Committee on Homeland Security today regarding new proposed chemical site security regulations. Siegfried USA is a member of the Synthetic Organic Chemical Manufacturers Association. Pulham's full remarks are below:

Good morning Chairman Thompson, Ranking Member King, and Distinguished Members of the Committee. My name is Dr. David C. Pulham, Director of Compliance at Siegfried (USA), Inc., in Pennsville, New Jersey. I spent 27 years with the Food and Drug Administration as a National Expert Investigator. Part of this responsibility required inspecting pharmaceutical facilities around the world and qualifying foreign regulatory agencies. As Director of Compliance at Siegfried, my responsibilities include FDA, DEA, EPA, OSHA, and DHS compliance.

Thank you for this opportunity to share with you my company’s perspective on the Chemical Facility Anti-Terrorism Act of 2008, specifically with regard to inherently safer technology. My remarks will speak generally to the issue of inherently safer technology, reference our experience with the State of New Jersey’s security provisions, and conclude with our recommendation on the bill going forward.

Siegfried USA’s Pennsville, New Jersey, facility manufactures bulk pharmaceuticals and employs 150 personnel. Most of Siegfried’s products are controlled substances. Therefore, we are highly regulated by the Drug Enforcement Administration. Siegfried takes pride in its compliance record with all Federal and state government agencies.

Siegfried (USA) is a member of the Synthetic Organic Chemical Manufacturers Association (SOCMA), which is the leading chemical industry association representing the batch, custom, and specialty chemical industry since 1921. As a member of SOCMA, Siegfried adheres to the principles of the ChemStewards® program, an environmental, health, safety, and security management system. This self-imposed program requires companies to develop systematic approaches to environmental and chemical risk management with independent, third-party verification. ChemStewards incorporates SOCMA’s security vulnerability assessment methodology, which is recognized by the Center for Chemical Process Safety and is accepted by the Department of Homeland Security (DHS) for Tier Four facilities under the Department’s Chemical Facility Anti-Terrorism Standards. SOCMA makes this methodology publicly available in its effort to serve as a leading industry resource for assessing security vulnerabilities at chemical facilities.