If the evolving regulations and documentation developed under the Chemical Facility Anti-Terrorism Standards (CFATS) Program seem onerous now, think again. New proposed rules will require much greater recordkeeping and for good reason. Although ammonium nitrate has long been the Improvised Explosive Device (IED) component of choice in Afghanistan and Pakistan, other products, such as calcium ammonium nitrate and even urea, may be added to this list, given concerns over 'manipulation' that can increase their explosive nature.

U.S. Department of Defense (DOD) and Department of Homeland Security (DHS) officials have suggested to The Fertilizer Institute (TFI) that domestic use of IEDs for terrorist acts is expected. "We have been meeting with Lt. Gen. Michael Barbero, director, Joint Improvised Explosive Device Defeat Organization (JIEDDO), on a regular basis," said Pam Guffain, vice president member services, TFI. "He noted that IEDs are already being used in Columbia and Somalia, and he is concerned that it's only a short time before they will be a problem in the U.S. The U.S. has had events using homemade explosive materials, and they feel IEDs could become a big issue due to availability of ammonium nitrate."

In fact, the fertilizer industry has been in the lead in demanding regulations in relation to ammonium nitrate, due to potential for misuse as a bomb feedstock. TFI went to Congress in 2005 requesting tighter controls on ammonium nitrate. While it took time for Congress to react, The Secure Handling of Ammonium Nitrate Act of 2007 was finally sent to President Bush to be signed in 2007. The law, which regulates fertilizer mixes containing 30 percent or more ammonium nitrate, took nearly four more years for rules to be proposed, and a year later the final rule is still being discussed. Proposed rules require sellers and purchasers to register with the DHS, be cleared through a terror-screening database and fulfill recordkeeping and other rules.

"Congress called for fairly straightforward registration of buyers and sellers and recordkeeping of transactions, what we were already doing on a voluntary basis," said Kathy Mathers, vice president of public affairs, TFI. "Our members are doing a good job making sure product stays in the right hands, but uniform national rules were needed. Now we are working to streamline the rules for our members."


Guffain describes some of the rules that TFI has been working to "streamline." They include required registration and verification of registration of each individual purchase, though the same customer might make repeat purchases in a single day. TFI is working toward recognition of repeat sales that don't require repetitive registration and verification of individuals or their employees.

Although reducing the recordkeeping burden is important, neither Mathers nor Guffain downplay the importance of the overall effort or its evolving nature. "We used to worry about detonability or the explosive potential of a product, but almost any product with nitrogen can be manipulated if someone has the time, money and ingenuity," said Guffain.

Guffain cited calcium ammonium nitrate, once thought to be a lesser detonable product. Although it’s produced in Pakistan for use as a fertilizer with careful controls and the best of intentions, once out the door, it is untrackable and easily smuggled into Afghanistan. There, manipulation is as easy as running it through a coffee grinder or putting it in solution to remove the calcium. Urea has a similar potential, though nitric acid is needed to manipulate it into a detonable product. Unlike the U.S., nitric acid isn't widely available in Afghanistan.

That a domestic terrorist attack hasn't already happened is largely the result of successful security measures, terrorist ineptitude as seen with the Times Square car bomb attempt and a lot of luck. It is not for want of trying. The Institute for Homeland Security Solutions (IHSS) reported 20 al Qaeda-inspired plots, 20 initiated by white supremacists and 16 by anti-government militants between 1999 and 2009. The Southern Poverty Law Center documented 97 plots from July 1995 through November 2011, discovered at various stages and prosecuted by law enforcement. Many included assembled bombs or components, several of which were ammonium nitrate and fuel oil based and one urea based.


JIEDDO wants the industry to do more. It is working with TFI and others on a broad range of security related issues that include:

• Creating new fertilizer formulations with reduced explosive potential and ways of making current formulations more difficult to reprocess or manipulate;

• Introducing additives to simplify the detection of nitrogen fertilizers associated with precursors and HME manufacturing sites that would enable rapid identification, detection and traceability;

• Developing industry-wide standards, regulations and safeguards related to production and distribution of nitrogen fertilizers and identifying methods to increase the accountability of fertilizer purchase and distribution;

• Encouraging a global education and awareness campaign to make manufacturers and consumers aware of the threat posed by misuse and highlight ways to mitigate the risk through security plans, communicating with customers, recording sales, identifying suspicious activities and notifying law enforcement if problems arise.

Honeywell isn't waiting. The company recently introduced a new nitrogen formulation and an agreement with J.R. Simplot Company to produce it. The two are building a facility to produce Honeywell's Sulf-N 26, which Simplot will operate and for which it will have exclusive distribution rights in the western U.S.

Sulf-N 26 is a dry, granular, ammonium sulfate nitrate fertilizer that has been granted SAFETY Act (Support Anti-terrorism by Fostering Effective Technologies) designation by the DHS. With this designation comes liability protection and other incentives. The process chemically fuses ammonium sulfate and ammonium nitrate to produce a new, highly stable molecule 26-0-0 14S. Agronomic tests have found it to be safe and effective for agricultural use, compatible with other fertilizers in blends and safe to transport, handle and store. Honeywell reported that testing under DHS guidance along with the Bureau of Alcohol, Tobacco, Firearms and Explosives, "demonstrated significantly less or, in some cases, no explosive power, when compared to traditional nitrate-based fertilizers.

"We believe that in order to take the next steps toward reducing the risks of ammonium nitrate, one must move beyond simple content thresholds and investigate safer, alternative technologies, such as Sulf-N 26," said Deborah Patterson, business director, Sulf-N 26, Honeywell Performance Materials and Technologies. "Sulf-N 26 is a new molecule, not simply a blending of ingredients, and therefore cannot be physically separated. As with other molecules, attempting to chemically modify Sulf-N 26 requires advanced skills and knowledge, including a well-equipped lab and advanced chemicals."

Although the proposed DHS rule on the manufacture and sale of ammonium nitrate would regulate the manufacture and sale of any fertilizer containing more than 30 percent ammonium nitrate, Patterson reported that the company doesn't expect Sulf-N 26 to be regulated under the proposed rule. The final product has less than 5 percent free ammonium nitrate.


New products or old, regulated or unregulated, the key to security and reducing the risk of misuse of nitrate fertilizer products today, rests in large part with the distribution system. It is a responsibility that Mathers and Guffain indicate the fertilizer industry takes seriously and can help carry out by following common sense, even as official rules are still being developed.

"Know your customers, keep records of sales, don't sell to people wanting small amounts and wanting to pick it up in a pickup truck," said Guffain. "We introduced the Be Aware program after the Oklahoma City bombing, and America’s Security Begins With You started after 9/11. These programs have served America well. We may well need to renew our emphasis on them and keep reminding ourselves that we still have a problem and need to remember our security protocols."

This article is brought to you in cooperation with the National Agronomic Environmental Health and Safety School (NAEHSS).