Institute of Makers of Explosives Responds to NAS Precursors Report



Contact: Debra Satkowiak                                                                            November 29, 2017
IME President                                                                                      
(202) 809-4765
Institute of Makers of Explosives Responds to NAS Precursors Report
The Institute of Makers of Explosives (IME), the safety and security organization of the commercial explosives industry, would like to thank the members and staff of the National Academy of Sciences Committee on Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Chemical Explosive Precursors for their diligent work and clarity of findings included in the Consensus Report.

IME would like to specifically note the industry’s appreciation for the Committee’s willingness to learn about the industry’s security standards, best practices, and how security is maintained through the supply- chain. The international movement of explosives, blasting agents, and oxidizers while maintaining security is a duty the industry remains committed to achieving on a daily basis.
IME has long maintained that focusing security on a single precursor is a misguided policy; bad actors would simply look to other more easily accessible chemicals to achieve their nefarious goals. The industry was pleased to see the Committee agreed and included the following in the report:

[a precursor security approach] that focuses on merely one chemical, such as ammonium nitrate (AN) as proposed by the ANSP, cannot adequately reduce the threat of IED attacks due to the availability of alternatives and the historically demonstrated capacity of terrorists to modify their tactics in response to single-chemical controls.” (Page 101).
The commercial explosives industry works in bulk transactions and does not sell to the general public. In most instances, control of the product is retained within the industry from start to finish, and any necessary transactions are conducted between explosives licensees and/or permittees in accordance with the industry’s security best practices. This control, combined with legal requirements, makes acquiring precursors at this level sufficiently difficult that those with criminal or terrorist intent would turn to other, more easily accessible chemicals and sources where anonymity can be maintained. In contrast;
The committee found a pronounced lack of visibility and oversight in retail-level transactions, especially those involving e-commerce, suggesting ample opportunity for malicious actors to acquire precursor chemicals for making HMEs. (Page 102).
Deb Satkowiak, President of IME, affirmed the Committees’ conclusions;

Considering that the commercial explosives industry consumes millions of metric tons of high explosives, blasting agents, and oxidizers annually, the fact that the study indirectly confirms that the security practices and procedures used in the commercial explosives sector make it undesirable for lone wolf actors to even bother trying to acquire precursors, is extremely significant and demonstrates the seriousness with which our members take security.”

IME shares the Committee’s concerns about binary exploding target kits (ETs), their ready availability and the ease with which they can be used to construct HMEs. IME member companies do not, as a matter of security policy, sell raw products to ET manufacturers and the Institute has, for several years, advocated for their sensible regulation. Because many ET retailers also are licensed firearms dealers, they are familiar with ATF regulations and would be well equipped to implement similar security requirements if applied to ETs. ATF should be granted the requisite authority to regulate commerce in ETs, cutting off this “easy route of precursor chemical acquisition in the U.S.” (Page 57).

IME recognizes the difficult job facing Congress and federal regulatory agencies as they attempt to address the serious issues outlined by the report. IME will continue to support the ongoing effort to find solutions advancing safety and security for all citizens.

Founded in 1913, IME represents U.S. manufacturers of high explosives and other companies that distribute explosives or provide related services. Commercial explosives are used in every state in the union and are distributed worldwide. The ability to manufacture and distribute these products safely and securely is critical to this industry and to the mining, construction, and demolition industries that use our products. IME’s Safety Library Publications cover all aspects related to the safe and secure manufacture, transport, storage, use and disposal of commercial explosives and are available for free via the website.

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