PRESS*
PUBLIC
A JOURNALIST'S GUIDE TO REPORTING
ON CHEMICALS IN THE COMMUNITY
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"Obviously, a man's judgment cannot be
better than the information on which he has
based it. Give him the truth and he may
still go wrong when he has the chance to be
right, but give him no news or present him
only with distorted and incomplete data, with
ignorant, sloppy, or biased reporting, with
propaganda and deliberate falsehoods, and
you destroy his whole reasoning process, and
make him something less than a man.11
Arthur Hays Sulzberger
Address to the New York State
Publishers Association, August 30, 1948
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Chemicals, The Press,
and The Public
A Journalist's Guide to Reporting
on Chemicals in the Community
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Table of Contents
Preface
Acknowledgements
Introduction
Chapter 1: Reporters'
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Table of Contents (continued)
Chapter 5: Reporting on a Chemical Emergency
Reporter Beware! Your OWN Health May be at Risk!
Question to Ask Before Heading Out
Questions to Ask at the Site
Is Your Community Prepared?
Reporting A Hazardous Materials Incident:
A Reporter's Checklist
Chapter 6: Computers in Emergency Management
On the Scene With CAMEO
65
65
66
66
69
72
'7
78
Chapter 7: Accessing and Using the Electronic Database [
on Toxic Release Inventory Chemicals 83
Where to Start? 84
Searching the Database 85
What to Expect in the Database 86
Searching With Mnemonics 88
Searching Without Mnemonics 89
Using the 'Neighbor Command' 89
Go Ahead ... Give It a Try 90
Chapter 8: Understanding and Working With
the Chemical Information
Opportunities and Pitfalls Abound
Toxicology for Journalists: How Toxic IS Toxic?
Some Tips from Victor Conn's 'News & Numbers'
Chapter 9: Information Sources
Appendix (Independent Press Advisory Committee)
91
91
95
98
103
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Preface
Environmental reporters share with other environmental
professionals the challenge of keeping abreast of increasingly
complex environmental problems and programs.
For journalists, the challenge is compounded by the nature of
their job: They not only have to understand the issues, they have
to interpret and communicate them effectively to a general
audience. Deadline considerations, demands from editors, and the
need for sharp, concise writing heighten the challenges.
One thing is evident: Newspaper, TV, and radio audiences
cannot be expected to understand an issue any better than the
reporters do. Indeed, the public depends on effective media
coverage for its information on environmental issues. And an
informed public -- a citizenry actively involved in environmental
management policies is what makes environmental programs
work in the first place.
This guidebook for journalists addresses one of the most
important environmental issues now facing the American public
-- toxic and hazardous chemicals in the community. It gives print
and electronic journalists insights into reporting on chemical
information disclosed by the Emergency Planning and Community
Right-to-Know Act of 1986. This law was passed by Congress in
the aftermath of the December 1984 Bhopal, India, chemical
tragedy, in which more than 2,000 people died as a result of a leak
of methyl isocyanate. The law could well revolutionize not only
environmental policy, but also environmental journalism.
The media guidebook was prepared by the Environmental
Health Center, a division of the not-for-profit, nongovernmental
National Safety Council, a 75-year-old public service organization.
Funding for the project was.provided through support from the
U.S. Environmental Protection Agency; through a grant from the
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National Safety Council's Foundation for Safety & Health; and
through National Safety Council general operating funds.
The project benefited greatly from the assistance of a special
Independent Press Advisory Committee consisting of former and
current environmental and science journalists.
Bud Ward,
Executive Director,
Environmental Health Center
vi
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Acknowledgements
The Environmental Health Center appreciates the cooperation
and support it received from numerous organizations and
individuals in preparing this media guide on reporting on
chemicals in the community under the Emergency Planning and
Community Right-to-Know Act.
In particular, EHC appreciates the contributions and editorial
reviews of its Independent Press Advisory Committee*:
Joel Shurkin (Chairman), science writer, Stanford University
News Service, Stanford, California;
Mitchel Benson, environment writer, San Jose Mercury News,
San Jose, California;
Sandra Blakeslee, science correspondent, The New York Times,
Los Angeles, California; and
Jim Detjen, science writer, The Philadelphia Inquirer,
Philadelphia, Pa.
In addition, the Environmental Health Center expresses its
appreciation to James Risser, a two-time Pulitzer Prize winner for
his reporting with The Des Moines Register and currently Chairman
of the John S. Knight Fellowship Program at Stanford University.
Risser's assistance in hosting a May 1989 two-day seminar for
journalists was critical in providing EHC insights from reporters
on their needs in covering chemicals in their communities.
*Professional background information on each of the four members of the
Independent Press Advisory Committee is published in the Appendix.
VII
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The project benefited enormously from the journalistic savvy
and sophistication of Charles Osolin of the U.S. Environmental
Protection Agency's Office of Toxic Substances. A former
Washington, D.C., reporter for newspapers in North Carolina and
Florida, and a former editor with the Atlanta Journal and
Washington Star, Osolin was principal EPA contact for the
development of the media guide. His commitment to ensuring the
journalistic integrity and independence of the project has proven
indispensable to the success of the media guide.
Finally, EHC expresses sincere appreciation to additional EPA
program offices and staffc -- the offices of solid waste and
emergency response, policy, and external affairs - without whose
assistance the media guide could not have been completed in a
timely way. In particular, EHC appreciates the assistance of
Dorothy McManus of EPA's Office of Chemical Emergency
Preparedness and Prevention, for her ongoing involvement in the
project.
Production and management responsibilities were amply
handled by Jan O'Brien, without whose extraordinary efforts the
reporters' guide could not have been written.
V1U
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Introduction:
Why This Guidebook?
Environmental journalism has never been easy, either from
the standpoint of communicating complex issues to a broad public
or from the standpoint of dealing internally with editors whose
interests often can conflict with those of environmental reporters.
Nothing on the horizon appears likely to make it any easier.
But a recently enacted federal law -- the Emergency Planning
and Community Right-to-Know Act of 1986 -- has the potential
for making it a lot more interesting and worthwhile, both for
reporters and for their audiences. Widely seen as a legislative
response to a December 1984 chemical tragedy in which more than
2,000 citizens of Bhopal, India, died, the law for the furst time
provides the public and the media unprecedented access to
valuable chemical information concerning their local communities.
Part of an evolving "right to know" ethic in the environmental
health and safety fields, the law mandates advance contingency
planning for chemical emergencies and incidents; emergency
notification of accidental spills and releases of hazardous
chemicals; and annual reporting of manufacturing companies' uses,
inventories, and emissions of hazardous chemicals. A provision
unique in federal law mandates public access by computer and
electronic bulletin board to an extensive "toxic release inventory"
chemical database.
Reporters, if they choose, can have in their hands an
unprecedented amount of plant, industry, city, county, state,
regional, or federal information on about 325 toxic chemicals
released by manufacturing facilities to the air, water or land.
Through newly established local committees, they can get
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information on inventories of various chemicals stored in their
communities, and they can get information on amounts, locations,
and potential effects of hazardous chemicals used or stored locally.
But there is a "missing link" in the newly available chemical
release information - and a Vital one. There Is no question that
the numbers of pounds of pollution emitted annually into the U.S.
environment are large, even staggering. The real question for
reporters is: Precisely what health effects do those emissions have
at various concentrations and various times. Information is
available at the local level, under the law, to help match those
reported emissions to inventories of chemicais and to reported
accidents. All the same, answers to that part of the riddle will not
leap readily from the information now available.
i
Sandra Blakeslee, a well-known science writer in Los Angeles
who writes regularly for The New York Times and other
publications, is among those reporters who recognize the new
Emergency Planning and Community Right-to-Know Act as "a
reporter's gold mine." Blakeslee, a member of a four-person
Independent Press Advisory Committee which was active in review
of this media guide, says, "Reporters are really going to have to
dig, they're going to have to work hard to use this information.
But it will be well worth it to their papers and their audiences."
This media guide is intended to help print and electronic
reporters develop the full potential of the chemical information
now available under the new law. It seeks also to help reporters
understand the substantial limitations of that information -
limitations ranging from scope of facilities and chemicals affected,
to scientific uncertainties, to data quality control issues, to
challenges in interpreting chemical data reported under the law.
The guide was developed by the Environmental Health
Center, a division of the not-for-profit, nongovernmental National
Safety Council, a 75-year-old public service organization. Financial
assistance in preparing the media guide was provided by the U.S.
Environmental Protection Agency, by a grant from the National
Safety Council's Foundation for Safety & Health, and by the
National Safety Council's own operating budget. The guide
benefited also from the participation of 18 journalists from around
the country in a two-day seminar for reporters held at Stanford
University on May 19 and 20, 1989.
Chemicals, The Press & The Public
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Reporting on environmental chemical risk issues has never
been easy. The information now available under this innovative
and potentially revolutionary law certainly will not make it any
easier. Used effectively, however, it should make environmental
reporting a whole lot more interesting for reporters ... and a whole
lot more valuable for their audiences.
October 1989
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Chapter 1
Reporters' *War Stories'
Reporters love telling and hearing journalism war stories. In
its brief history, the Emergency Planning and Community Righf-
to-KnowAct (EPCRA, often referred lo as "Title IIP) has already
spawned its share. Given the nature of the unique "right to know"
law, it promises to give rise to many more. *
Two of the best chemicals-in-the-community war stories were
told by reporters participating in a May 19-20, 1989, journalism
seminar sponsored by the Environmental Health Center at Stan-
ford University in Palo Alto, California. The seminar a vital
element in preparing this media guide - opened with a panel of
four reporters telling their own early experiences in reporting on
chemicals under the new program.
At the request of the Environmental Health Center, two of
the environmental reporters - Mitchel Benson of the San Jose
Mercury News and Scott Thurm of The Courier-Journal, in
Louisville, Ky., subsequently put into their own words their
experiences in developing stories under the law. Each of their
stories deals specifically with the "toxic release inventory" created
by Section 313 of the law, just one provision of the law likely to
generate entertaining and informative reporters' war stories over
time. Their first-hand accounts follow, along with reprints of their
published stories.
Used Properly ... A Great Resource for Reporters
by Scott Thurm, The Courier-Journal
The SARA Title III [a colloquial term often used to refer to
"EPCRA"] toxic release reports are a great resource for reporters.
Every environment writer should become familiar with the reports
for his or her area. They provide important information about the
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, , , 1
chemicals being used and discharged, and how wastes are handled.
To use them properly, however, reporters also must
understand the limitations of the reports. The reporting
requirement covers only manufacturers, and only those that use or
discharge more than a designated amount of one or more of about
325 listed substances. More importantly, the reports say nothing
about the health risks posed by the releases. They include only
annual totals for the amount of each chemical that a plant
discharges to the air, to streams, to landfills and to treatment
facilities. The reports say nothing about the rate at which these
chemicals are released or the concentrations to which people are
exposed, if at all.
The Courier-Journal set out last fall [the fall of 1988, prior to
public availability of the electronic Toxic Release Inventory
database] to compile the toxic release reports for the state of
Kentucky. Upon reflection, Kentucky appears to me to be about
a perfectly sized state for such a project. The 1,254 individual
chemical reports submitted by 254 facilities are a large enough
group to make meaningful conclusions and comparisons, but not
so large as to be overwhelming. When I asked state officials to
see the reports, they were being stored, largely unread, in
cardboard boxes on the floor of an office in Frankfort. I suspect
other states handled the reports similarly; there was, after all, no
federal money provided for processing or using the reports, and
the U.S. Environmental Protection Agency was required to
compile the reports in an electronic database available in 1989.
To make sense of the reports, we chose to transfer selected
information from the written copies to a computer form we
developed. Our form included the name and county of the facility,
how much of the chemical was released to various media, how
company officials had arrived at these figures, whether the waste
streams had been treated before they were released, and whether
the company had taken steps to minimize waste of that, chemical.
In addition to chemical names, we kept track of chemical abstract
numbers, so we could recognize chemical synonyms. All of the
information was typed into an IBM-compatible portable personal
computer that I carried each day to the State Department of
Environmental Protection. '.
:: ' . , 1. ' ' j
I chose to input all of the data myself, which took about six
days, spread over about three weeks. Obviously, it would have
Chemicals, The Press & The Public
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been easier to have a clerk do the typing. But the toxic release
forms are so complicated, I didn't feel comfortable entrusting this
task to anyone else. An omitted or extra "0" can greatly change
the significance of a given release. Moreover, my general
familiarity with environmental issues in Kentucky allowed me to
see things that likely would have gone unnoticed otherwise. For
example, an aluminum refiner reported that it was sending 14
million pounds of aluminum dross to a former quarry that EPA
proposed to declare a Superfund site, because of the
environmental hazards posed by aluminum dross discarded there
earlier. Watching the reaction of a top state environmental
official when I asked why this was being permitted made all of the
work seem worthwhile.
I was by no means an expert in computer databases, but
eventually I could produce just about all of the reports I wanted,
totaling releases by county, facility, chemical, etc.
Our stories, however, did not make much use of these gross
totals. Instead, we took the information we had compiled to
officials, plant managers, environmentalists, and others. The
reason was simple: Few, if any, of our readers would know what
to make of the fact that 225 million pounds of toxic chemicals had
been "released" in Kentucky in 1987. Rather than rely on these
ft:
See Chapter 7
on page 83:
Accessing and Using
the Electronic Database
on Toxic Release
Inventory Chemicals
Chapter 1: War Stories
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figures, we chose to emphasize the reaction to the reports: that
they showed a larger quantity and wider variety of releases than
Officials previously believed, and that many were unregulated. Our
main story emphasized the air. releases, because these are the ones
that officials and public health experts said were the most likely to
affect health. A second story explored some of the ways the
reports can be used: to check compliance 'with permits or other
anomalies, such as the aluminum waste going to the Superfund
site.
The project was greatly rewarding, and generated as much
response as any other environmental story I've written. First,
about a week after I started putting the information into a
cpmp'uter, state officials - who had ignored the reports for three
months -- did likewise. I suspect they didn't want me to know
anything they didn't know. Whatever the reason, it allowed them
to start probing discrepancies with permits and other records.
Second, officials genuinely were surprised by the totals. As a
result, they have begun revising Kentucky's regulations for air
releases of toxic chemicals, and have commissioned a
comprehensive environmental study of the area around a chemical
complex in western Kentucky that the reports showed to have the
most concentrated releases.
: ' : . ! ' -:' ; -..'!"' ' [>
Looking toward the future, the reports will remain a valuable
resource. I now have, literally at my fingertips, a summary of
which plants in the state report releasing what chemicals, and
roughly in what amounts. I have used this information when
writing about a specific plant, or in tracing the source of an
unknown chemical discharge. Moreover, I suspect that the releases
reported last year for 1987 will become practical ceilings on future
releases by industry, since corporate officials are not going to want
to explain why their emissions of a given chemical increased.
But reporters are going to have to be careful in comparing
the reports from different years, because companies may change
their method of estimating emissions to make it appear that they
are reducing waste, and because EPA will be adding and
subtracting chemicals from its list, so that totals will not be easily
comparable.
NOTE: Thurm's two Courier-Journal articles are reprinted in full, with
credit to the newspaper, on the following pages. The text of this chapter
continues on page 15.
Chemicals, The Press & The Public
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, Air^pf Peril:
* More Hazardous Chemicals
* Are Going
1' - ^ . > "
* Into Kentucky Skies
, Than Anyone Knew
' ^November 27,1988)
* * "* '
Kentucky's major industries
-~- emit a wider variety of potentially
hazardous air pollutants than
. "-' previously believed, including
_- * several suspected carcinogens that
'I .'are unregulated, according to new
reports filed by the companies.
The findings are likely to spur
& suffer state and local regulations
^on toxic emissions, officials said,
'& particular, environmental
,.'officials are concerned about the
' concentra-tion of emissions around
" Louisville and Calvert City. The
t ^requirement that firms report these
'* emissions already has spawned
^voluntary efforts by industries to
^"reduce5 their toxic wastes.
"'', t The reports are the product
5 ' * of a 1986 federal law designed to
r* "* increase public knowledge of
* i hazardous chemicals and to
'encourage community planning for
chemical emergencies.
-" ' ^The law^ requires manufac-
turing companies to submit annual
reports about releases of 328
> " hazardous chemicals into ~ the
i, " environment - air, water, landfills,
sewage-treatment plants or inciner-
? ators. v
The first reports, from larger
plants, were due July 1. By
October 1, 254 Kentucky plants
had filed 1,254 reports detailing the
releases of 228 million pounds of
"chemicals last year.
The reports do not provide
any 'assessment of whether the
releases are harmful. They include
only how much of each chemical'
was released and where it went,
without indicating the rate or
concentration at which chemicals
were released.
The Courier-Journal compiled
the reports, conducted a computer-
assisted analysis of them and
shared its findings with a variety of
government officials, industry
managers and citizen "activists.
Among the findings:
* Plants in 67 counties filed
reports, including 63 in which air
emissions were listed, fifty-two
plants in Jefferson County reported
releasing more than 48 million
pounds of the listed chemicals, the
most of any county. Others with
large totals included Ballard,
Hancock, Boyd and Marshall coun-
ties (Calvert City is in MarshallJ.
* Chemicals released in the
largest quantities were among the
least hazardous on the list. For
example, 23 companies reported
sending nearly 75 million pounds
ofs sodium sulfate - a form of salt
~ to rivers and streams. While
sodium sulfate can be harmful to
fish in large concentrations, most
of the releases were to large rivers,
such as the Ohio or Mississippi,
where the chemical is diluted.
Officials and activists said they
were far more concerned about
smaller quantities of more
dangerous chemicals. "Firms
reported releasing more than 9
million pounds of compounds that
show some evidence of causing
cancer and more than 3 million
pounds of compounds that may
cause genetic changes.
* Most of the numbers
reported are estimates. Only a
small percentage were based on
actual testing of how much of a
chemical was in the water or air
Chapter 1: War Stories
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*,
leaving a plant. Many figures were
based on how much of a chemical
could not be accounted for in the
final product or other wastes.
Those interviewed generally
agreed that the volume and variety
of toxic emissions into the air were
the most significant aspect of the
reports. The reports listed 50
million pounds of air' emissions,
/ including more than 6 million
, pounds of chemicals known to
cause" cancer or suspected of
causing it.
^ (> .While air emissions accounted
for only about 22 percent of the
total chemical releases, they
accounted for about 69 percent of
the releases of likely or proven
,, carcinogens.
, The figures "certainly indicate
a need for'.the state to strengthen
its toxics programs, particularly in
- the area of air toxics," said Leslie
. dole, executive director of the state
.^-Environmental Quality
'.'^''^V..'^^!!^!^^..1 a seyeri-mertiber
".','. citizen panel that monitors state
.".''.'V.'agencies.'.':.'.:'.':; : ' ''.'''''";.; ''.'"
''j':'. .:.:... Kentucky regulates emis-sions
':' of 92 toxic compounds, but the
reports show 75 additional
.compounds - including several
likely carcinogens - being released
into.the state's air.
, :: Even in Jefferson County,
which has tougher air pollution
. regulations than the rest of the
state, "a whole lot of that stuff is
not currently addressed," said
Richard Everhart, an engineer for
.: the county Air Pollution Control
; District. .'[
Citizen environmental activists
said gaps in the state rules show
tha' a national strategy of leaving
the states to control airborne toxic
substances has not worked. Aside
.frpm its standard measures of air
10
quality - such as ozone and sulfur
dioxide - the federal government
restricts emissions of only seven
toxic compounds.
"There's no question that air
is probably the area where we
know the least about toxins being
emitted and have done less to
control them," said Tom Fitz-
Gerald, director of the Kentucky
Resources Council, a private
group.
State and local officials said
that they will use the reports to
review regulations and Jhe rules
may need to include more cheni-1
icals and set stricter emission limits.
Russell Barnett, deputy'com-
missioner of the Department for
Environmental Protection, which is
analyzing the reports separately,
said the volume of air emissions
was surprising.
"When it came to air emis-
sions, we had a lot of toxics going
out into the atmosphere ''L. The
gross numbers do give us concern.11
Barnett said he was colicerned
by the concentration of hazardous
air emissions in certain counties,
particularly Jefferson and Marshall.
Industries in each of those
counties reported more than 10
million pounds of air emissions. In
Marshall, the total included 1.6
million pounds of likely or known
carcinogens; Jefferson County
plants reported releasing more than
950,000 pounds of these
compounds. '
Officials at several plants with
large emissions said they had
conducted computer simulations
that showed that their releases did
not result in dangerous concen-
trations for nearby residents.
"The effect on the community
would be negligible,1' said Frank
Kennedy, environmental
Chemicals, The Press & The Public
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-f
*:, coordinator at American Synthetic
.« Rubber* Corp.'s plant in the
"" Rubbertown area just southwest of
f JLouisville.
"Would I want to live next
door to 'it?" asked Dave Scott,
! director of engineering at the
neighboring Borden chemical plant.
» "Sure. I wouldn't feel
-^uncomfortable living there with my
* ^wtfe and my little girl."
\t_ iVFitzGeratd, however, argued
^ tEaf* "there is no safe level of
*^ exposure" to carcinogenic or
? mutagenic compounds. He said
« the industry simulations are invalid,
because they don't consider the
* coniBmed effects of emissions from
t several plants
""i" .Talk of expanded regulations
worries" industry. Tony Sholar, a
director of government affairs for
the state Chamber of Commerce,
urged officials to wait for
additional information, including
reports from the other states.
"We always are concerned
about the scenario where the state
gets out in front of the EPA," he
said, warning that additional
regulations could hurt the state's
effort to attract and retain industry.
' Regardless of whether stiffer ,
f regulations are adopted, the fact
that companies must calculate and
report emissions ^each year will
encourage firms to: reduce waste,
according to most of the corporate
officials interviewed.
The reports contain an
optional section . asking for
information about steps industries
have taken to reduce emissions of
that chemical in -the last year.
Only 35 of the: 1,254 forms.
reviewed by The Courier-Journal -
-about 3 percent -- included such
information >. .
"This really contradicts what
l ^
we've heard from people in
industry that industry want$> to do
this and is trying," said Jean True,
chairwoman of the toxic-compound
committee of Kentuckians For The
Commonwealth, a statewide
citizens' group. "That reaJly is a
dismal number."
But the annual reporting
requirements "will continue lo drive
industry to reduce those numbers,"
said Ronald Martin, manager of
health, safety and environmental
programs at BF Goodrich Co/s
Louisville plant.
Monsanto, the giant chemical
company based in St. Louis,
already has pledged to reduce its
air emissions which totaled 20
million pounds at 41 plants last
year - by 90 percent over the next
five years.
Glynn Young, the company's
manager for environmental and
community relations, said the new
law forced top officials to look at
their total emissions. "It was a
surprise to see it all at one time,"
he said.
Kennedy, of American Syn-
thetic Rubber in Louisville, said
preparing and submitting the
report "rekindled"" a proposal to
study possible reductions in ;.his
'firm's use of toluene.The: plant
reported releasing more than;3:9
million pounds of toluene last year,
nearly all to the air.
. : American Synthetic already
has made one change,: switching
from chlorine gas to more
expensive H-quid chlorine to
.disinfect water on the,advice of
county Disaster and Emergency
Services officials. Those officials
were working on a related part bf,
the new "Community Right-to-
Know" law,"., requiring each
community' to plan for chemical
Chapter 1: War Stories
-------
I
a
accidents.
Kennedy said company
officials had thought an accident
with a chlorine gas tank merely
"would stink up the plant a bit.
DBS showed me that (the toxic
> cloud) had the possibility of going
five miles out in the community."
To citizen groups that long
have prodded industry to reduce
waste, this could prove to be the
' > most valuable feature of the new
law.
- -'To the extent people start
asking hard questions and
demanding accountability, we may
see industry putting more emphasis
on waste reduction and waste
control than they can ge't By with
under existing regulations,"
FitzGerald said.
E *"
.Copyright 1988, Courier-Journal
and Louisville Times Co. Reprinted
] H*//# permission.
Governments' Response
" Shows Usefulness
of Chemical Release Report
,, ^ i
(November 27, 1988)'
> ,-
, ' r^' i i
' In the Louisville-Jefferson
County Metropolitan Sewer
District, officials have discovered
"places where large amounts of
barium, chromium and zinc may
be entering the sewers.
In the Jefferson County Air
Pollution Control District,
newfound emissions'-of toluene, and
other compounds have sparked
concern.
And at the state Department
for Environmental Protection,
deputy Commissioner Russell
Barnett is trying to find out why
an aluminum company continues
to dump wastes at a quarry already
designated for cleanup under the
federal Superfund program for old
hazardous waste dumps.
Officials at all three agencies
began inquiries after The Couner-
Joumal made available information
it had compiled from 1,254
chemical release reports filed by
Kentucky industries under a new
federal Jaw.
Their searches highlight some
of the ways that the reports can be
used by government. The reports
will be helpful for industry, too,
and citizen groups say they're also
interested in the information.
"It's a great tool," said Leslie
Cole, executive director of the state
Environmental Quality Control
Commission, a seven-member citi-
zen panel. State officials "really
need to start looking at the reports
and focusing on the hot spots and
priority areas."
Tom FitzGeratd, director" of
the Kentucky Resources Council,
a private group, said environmental
officials traditionally have shifted
their attention "from crisis to crisis. f
We've got to manage for environ- *
mental risk, and these reports are^
one vehicle for helping to target"
those areas."
Government officials are
beginning to do that - albeit
tentatively - with the chemical
release reports that larger
manufacturing firms were required
to file for the first time July 1. -
For three months, the reports
sat unscrutinized on the floor of a
state office in Frankfort. State
officials began putting the
information into a computer
database in mid-October, about a
12
Chemicals, The Press & The Public
-------
~!v?eek after The Courier-Journal
began the same task.
* Once they looked, they - and
officials at other agencies with
whom the newspaper shared its
findings - said they discovered
* "significant discrepancies" between
\ "the new reports and information
industries had supplied earlier.
V _*" Tney were reluctant to
^djscuss specific cases until they
'" informed the firms involved.
\~' But Barnett said he was
^extremely "concerned that Barmet
Aluminum 'Corp. in McLean
~ County reported sending 14 million
i pounds of aluminum and alum-
' inum oxide to the Fort Hartford
' Stone Quarry near Olaton in Ohio
'County last year.
"Last June, federal officials
said the quarry was so seriously
' contaminated that it belonged on
the Superfund 'list. The reason?
More than 700,000 tons of alum-
inum-refining wastes that Barmet
dumped' there earlier have
contaminated surface and ground
water, created noxious ammonia
fumes and may be responsible for
killing trees, according to state
" records.
Barnett said the state has
been r battling with the "company
over the issue since 1980. Barmet
claims that the material is not
hazardous and that it is only
storing it at the quarry, not
disposing of it there.
In other cases, Barnett said
some companies reported releasing
dangerous compounds but had not
applied for required state water or
air pollution permits. Another 70
companies that hold permits to
emit toxic air pollutants did not file
the release reports, Barnett said.
The state soon will send inspectors
to these plants, he said.
: Chapter 1: War Stories
i In "Jefferson County, air pol-
lution officials said several firms
reported emitting more of some
hazardous chemicals than they had
earlier reported to the agency; in
one case, the new report showed
33 times greater, emissions of the .
moderately toxic solvent toluene
than earlier submissions.
MSB officials said they found
that some companies reported dis-
charging much larger quantities of
toxic metals - including barium,
chromium, nickel and zinc - than
the agency had previously
estimated. ]
MSD Executive Director
Gordon Garner said he also was
concerned about the reported
discharges of other hazardous
chemicals for which the sewer dis-
trict does not test. Garner's list
includes 130,000 pounds of acrylo-
nitrile, considered a probable
carcinogen.
"We're going to have to
reassess our monitoring and
permitting programs in response to
this," Garner said. "We're getting
discharges of some materials we've
never checked for and (that) aren't
regulated. But they're there in
such large quantities that we need
to know if they're OK"
At three other cities' sewage
treatment plants contacted by the
newspaper, officials said they
already were aware of the chem-
icals being sent to them because of
increasingly stringent pretreatment
and monitoring requirements.
At the Ashland treatment
plant, however, Superintendent
Gary Sheffield said city officials
"haven't done a whole lot in this
area yet." He said the city's
pretreatment program was just
being set up.
Reports indicate more than
13
-------
267,000 pounds of listed chemicals
were discharged to Ashland's treat-
ment plant last year, including
i. large amounts of benzene, cyanide
corn-pounds, naphthalene and
phenol.
' * Once state officials have
completed their analysis, they will
tell sewer districts and landfills of
the chemicals the companies re-
ported sending to them, Barnett
said. In addition, he said, the state
will tram treatment plant and land-
fill operators in how to use the
reports.
Copyright 1988, Conner-Journal
and Louisville Times Co. Reprinted
*\ * i * ^
with permission.
* a >
Ij » .
* s - t
I *\ j
1 '
i it'
!
*,-, I
*i tJH t
a- '--
i f
-------
Trust No One as Being Accurate:
Check Everything Twice ... Three Times
by Mitchel Benson, San Jose Mercury News
Since when does the U.S. Environmental Protection Agency
pick sides?
Not too often, when it's caught between environmentalists and
powerful corporations. But that's what happened in 1988 in a
situation regarding news coverage of SARA Title III in Santa
Clara County, California (Silicon Valley for you Newsweek and
Time magazine readers).
And in this case, the EPA sided with the environmentalists.
What I learned as the environment writer for the San Jose
Mercury News is to trust no one or nothing as being accurate --
not even the Title III reporting documents that are signed under
penalty of law by company engineers.
Check everything twice - including those supposedly error-
free reporting forms - and check it once again if you've got the
time.
The tumult began on a beautiful summer day on a lawn
across the street from an FMC plant in San Jose. The local
Silicon Valley Toxics Coalition held a news conference to present
its spin on the first list of Title III data supplied to the EPA
The toxics coalition charged that 25 major corporations in
Santa Clara County had legally dumped more than 12 million
pounds of toxic and cancer-causing pollutants into the air, land
and water.
The coalition's statistics showed that Advanced Micro Devices
in Sunnyvale, a manufacturer of semiconductors, was the county's
top polluter. That report was based on information found in
documents that AMD itself prepared and filed with the EPA
I should have called AMD right then and there but, frankly,
I didn't. Why? Because I had copies of AMD's actual reports.
Chapter 1: War Stories 15
-------
And I could see in black and white where the toxics coalition was
getting its numbers.
The next morning, after the story appeared, AMD's press
officer called me.
In fact, he called me several things. I hung up. Probably
shouldn't have. But then again, I probably should have been a
dentist so I could make lots of money snooping around in peopled
mouths. We all have regrets.
In any event, the press guy called my boss, and we eventually
had this big "summit session" of sorts with me, my editor, my
editor's editor, the press guy from AMD, an AMD engineer and
AMD's corporate counsel.
.I., ,i, ' j
,
After lots of yelling and screaming, AMD admitted that they
filled out the forms wrong. Period.
Where AMD officials should have noted that extremely potent
acids were being neutralized into rather benign salts before being
dumped in San Francisco Bay, they instead filled out the forms to
show that those acids were being dumped directly into the Bay.
Woops.
, i
AMD officials in fact several highly paid, well educated
AMD officials insisted then, and in a later interview, that they
filled out the forms incorrectly because THE INSTRUCTIONS
WERE DIFFICULT TO UNDERSTAND. AMD officials have
acknowledged that they filled out certain forms to show how much
acids and caustics are used at the company's Sunnyvale, California,
locations. The forms ask, however, how much chemical was
released into the environment or sent to treatment plants.
And even though they thought the completed forms would
send a misleading, if not outright wrong message to state and
federal regulators, AMD's manager of corporate environmental
affairs said he signed the forms anyway.
As for the toxics coalition, AMD officials charged that the
environmentalists probably knew the forms were filled out
incorrectly but interpreted them how they saw fit to their own
advantage.
16
Chemicals, The Press & The Public
-------
This was sort of a silly argument. But it only got sillier in
the coming days when AMD bought a full-page advertisement in
the Mercury News charging the toxics coalition with "Truth
Pollution!"1 They really did. You could look it up.
The same day the advertisement appeared, AMD scheduled
a news conference to accuse the toxics coalition "of deliberate
efforts to distort the facts and misinform the public."
AMD took no responsibility for its mistakes and, to my
surprise, didn't bother to smack me or my newspaper for
contributing to the distortions.
Now for the surprise.
The EPA, which had pretty much stayed out of the mess until
now, decided to bow in.
The newspaper ad prompted Jeffrey Zelikson of the EPA
regional office in San Francisco to write AMD a letter criticizing
the company for filling out the documents incorrectly.
"If the AMD numbers ... represented chemical usage rather
than chemical releases, it was because AMD reported the wrong
information," wrote Zelikson, regional director of the toxics and
waste management division.
When I got a copy of the letter, I promptly called Zelikson
to verify that he had in fact written it. He was not available, but
other EPA staffers -- whom I consider reliable -- confirmed that
it was his letter.
When I called AMD for an official comment, the company's
press officer declined to comment until he could contact Zelikson
himself to confirm that he had written and signed the letter. You
see, the press officer said, there's some question as to whether
Zelikson actually wrote the letter.
I guess even corporate press officers have learned to check
everything twice -- maybe three times. It's not a bad lesson.
NOTE: Benson's two Mercury News articles are reprinted in full, with
credit to the newspaper, on the following pages.
Chapter 1: War Stories 17
-------
*<
1 I
Toxic Dumping Curbs
Sought 12 Million Pounds
. Legally Released Each
Year, Group Says
(August 3, 1988)
Twenty-five major corpora-
tions" with plants in Santa Clara
Couiify legally "dump more than .12
'million pounds of toxic and cancer-
causing pbilutants into the air, land
. and water;^ch year, according to
a study rejease
-------
poltoante into the local
environment.
/'' Smith acknowledged that the
* ' 'amount, ^of chemicals the
companies release is within federal
' ^ requirements. But he argued that
, there are federal standards for only
^ a handful of toxic air contaminants
and that those are too lax.
" - According to the study, the
five most heavily dumped sub-
stances are sodium sulfate, 3
»million pounds a year; Freon, 1.8
million pounds; sodium hydroxide,
1.8 million; sulfuric acid, 1.2
' million; and 1,1,1-trichloroethane,
956,000 pounds.
The study said the Inter-
*~ national Business Machines Corp.
plant in South San Jose is
responsible for almost 1.5 million
* pounds of the 1.8 million pounds
of Freon released annually.
IBM announced last month
that it was developing a safe
* alternative to Freon to clean parts
,', so sensitive that they can be ruined
'' by a speck of dust. IBM officials
, .have said the new method could
( reduce the plant's use of Freon 30
percent within 18 months.
" ,er ' (
s (Mercury News Staff Writer Jack
-' Fischer^ contributed to this report.)
* v »i
J Copyright 1988, San Jose Mercury
News. Reprinted with permission.
EPA Official
Says AMD Goofed
on Pollution Report
(September 1,1988)
A ranking federal official has
taken the unusual step of siding
with a local environmental group in
its battle^with a semiconductor
manufacturer over how much
hazardous waste the company
releases into the environment.
The Silicon Valley Toxics
Coalition kicked things off earlier
this month when it release a re-
port showing that Advanced Micro
Devices in Sunnyvale was the
South Bay's top polluter. That
report was based on information
found in documents that AMD
itself prepared and filed with the
U.S. Environmental Protection
Agency.
AMD shot back witli a full-
page ad in the Mercury News -
and its own news conference
accusing the toxics coalition "of
deliberate efforts to distort the
facts and misinform the public."
AMD said most of what it releases
has been neutralized.
That ad prompted Jeffrey
Zelikson of the EPA regional'
office in San: Francisco to write
AMD a letter criticizing the
company for filling out the
documents incorrectly.
AMD officials have acknow-
ledged that they filled out certain
forms to show how much adds and
caustics are used at the company's
Sunnyvale locations. Th& forms
ask, however, how much chemical
was released into the environment
or sent to treatment plants.
"If the AMD numbers ...
represented chemical usage rather
than chemical releases, it was
because AMD reported the wrong
information," wrote Zelikson,
director of the toxics and waste
management division.
Mike Gingrass, AMD's
manager of corporate environ-
mental affairs, said AMD filled out
the forms incorrectly because the
Chapter 1: War Stories
19
-------
instructions were difficult to
understand.
But he insisted that the toxics
coalition made "the bigger mistake"
because it lumped together chem-
icals released directly into the air
with^others that were treated and
then dumped into San Francisco
Bay as a salt.
. As a result, Gingrass said, the
report'made AME) and most other
companies look much worse than
they really are.
Ted Smith, executive director
, of the toxics^ coalition, agreed that
releasing toxic wastes directly into
the environment is different from
sending them to a treatment plant.
" , "But,1* Smith added, "it does
nothing to the ecology of the bay
to get millions of gallons of these
salts flushed through ... They
(AMD officials) need to acknowl-
edge there are environmentally
better ways to getting rid of the
waste produced than what they're
doing ...,"
Gingrass acknowledged that
AMD in Sunnyvale does not have
a system to re-process adds. But
he said the company has drastically
reduced the amount of hazardous
waste generated during the past
five years by substituting less toxic
materials.
Copyright 1988, San Jose Mercury
News, Reprinted with permission.
'"' ' - ,
See Chapter 9
on page 103:
Information Sources
Business organizations; environmental
organizations; government agencies; and
state emergency response commissions (SERCs)
20
Chemicals, The Press & The Public
-------
Chapter 2
The Evolution of 'Right to Know'
December 4,1984, witnessed one of those seminal events that
changed forever the way business gets done in America.
Americans rose early on the morning of December 5 to learn
of a terrible chemical accident in a faraway and little-known place
named Bhopal, India. An equally unfamiliar chemical methyl
isocyanate, or "MIC", as it was to become known in subsequent
days ~ had escaped from a Union Carbide pesticide manufacturing
facility. The number of fatalities was uncertain, but mounting.
The environmental policy world was transformed by the
Bhopal tragedy, which is now seen as the world's worst industrial
accident, with a death toll exceeding 2,000. Just two years after
Bhopal, the U.S. Congress responded with passage of the
"Emergency Planning and Community Right-to-Know Act," which
was passed as Title III of the Superfund Amendments and
Reauthorization Act of 1986. This law -- which promises to
transform environmental reporting just as it has environmental
policy ~ is a direct result of Bhopal.
Senator Frank Lautenberg (D-N.J.) reflected much of
Congress' thinking when he said:
Hundreds of victims in Bhopal could have been spared their
lives or injuries if they had known of the hazard around them
and known how to respond. Many more lives could have been
saved if a communications system had been in place to alert
residents .... That is true of chemical releases in our country as
well.
The then-Chairman of the Senate Environment and Public
Works Committee, Vermont Republican Robert T. Stafford, took
21
-------
the argument a step further in telling the Senate:
These provisions were developed in large part as a result of the
terrible disaster in Bhopal.... The Bhopal disaster focused public
attention on the fact that extremely dangerous chemicals are
present at chemical manufacturing plants and other facilities in
communities all across America.
Embodying an information-based and largely nonregulatory
approach to pollution control, the law reflects a major evolution
in the history of federal pollution control programs. Those
programs have grown increasingly aggressive since they got their
start with the 1970 "Earth Day" celebration. Since the early 1970s,
environmental
protection has
moved from
"end of pipe"
treatment
aimed at clean-
ing up pollution
as it enters the
air or water
to "right to
know," with its
thrust on citizen
participation
and preventing
the pollution in
the first place
rather than
cleaning it up
afterward. In that sense, the Emergency Planning and Community
Right-to-Know Act serves as a vital link between the traditional
regulatory approach to environmental management and the
information-based approach critical to effective citizen participation
in environmental decision-making.
The time span since enactment of the nation's first pollution
control regulatory programs with real teeth is short.
Environmental programs enacted in the 1970s are among perhaps
the nation's most ingrained and most resilient domestic programs,
enjoying widespread popular support and an extensive body of
statutory law, court decisions and regulations. Yet they are, in
reality, barely pubescent in the scheme of more established federal
22
Chemicals, The Press & The Public
-------
domestic programs involving housing, social security, education,
and hunger. Environmental laws may be just cutting their teeth
... but there's no question that they do have real teeth.
Historical Context
To understand the context of what journalistic shorthand
refers to as "right to know," it helps to review the nation's early
experiences with federal environmental legislative programs,
beginning in the early 1970s. It's in those predecessors, in. those
successes and shortcomings, that "right to know" finds its roots.
As America in the late 1960s and early '70s was re-evaluating
and cutting back its role in Vietnam, bipartisan domestic interest
in environmental protection issues was increasing. An America
frustrated with foreign policy disappointments searched for
successes -- for a popular cause closer to home. With a
presidential election approaching in two years and with a growing
public awareness of environmental issues, politicians from both
major parties courted a favorable environmental image.
Congress seized the initiative with passage in late 1969 of
the National Environmental Policy Act (NEPA), requiring
preparation of detailed environmental impact statements on major
federal actions significantly affecting the environment. President
Richard M. Nixon upped the ante, signing NEPA into law and
proclaiming the 1970s as "The Environmental Decade."
A series of landmark pollution control laws followed in quick
succession. Collectively, those laws have made environmental
protection the nation's most extensive and complex social
regulatory program. At the same time, the Environmental
Protection Agency established by executive order to oversee
implementation of those laws has become the nation's largest
regulatory agency. Its proposed and final rules command a major
share of the Federal Re&ster in any given year. Its rules directly
affect more people ~ those who breathe air or drink water! --
than any other agency's.
Just months after Earth Day, the landmark Clean Air Act of
1970 passed. The law in many respects is the magnum opus of the
nation's pollution control regulatory laws. In its early days, the
Act focused primarily on the grossest and most visible forms of air
Chapter 2: Evolution of Right to Know 23
-------
pollution - the black smoke from industrial stacks and the noxious
emissions from tail pipes. Because of this early focus on the
largest and most visible pollutants, they became colloquially known
as "golf balls" or "clunkers." It was said at the time that if the
environmental regulatory programs and pollution control
equipment didn't succeed in pulling them from the atmosphere,
gravity would. In reality, anyone who has followed environmental
programs knows things proved far more difficult.
1
The Clean Air Act was barely two years old, and its
implementation had just begun, when Congress in 1972 passed the
Federal Water Pollution Control Act Amendments, known now as
the Clean Water Act. Congress and the American public were
reacting to unswimmable rivers and lakes. The words "Lake Erie^
seldom appeared in print without the descriptive adjective "dead."
A Time magazine cover -- illustrating Cleveland's Cuyahoga River
afire -- brought home graphically the extent of the problem.
Along with an $18 billion fund for construction of publicly owned
sewage treatment works, the 1972 Act required industry to get
permits before discharging pollutants to surface waters.
Throughout the early 1970s, Congress passed and presidents
signed into law the Federal Environmental Pesticide Control Act,
and later the Federal Insecticide, Fungicide and Rodenticide Act,
amending it; the Noise Control Act; and the Marine Protection,
Research and Sanctuaries Act, known as the "Ocean Dumping
Act." The Resource Conservation and Recovery Act (RCRA) was
passed in 1976 to foster "cradle to grave" management of industrial
wastes, tracking them from the time they are generated until the
time they are finally disposed of. That same year, Congress passed
the Toxic Substances Control Act, requiring, among other things,
that chemical manufacturers provide premanufacture notification
on new chemicals. Then came passage of the Safe Drinking Water
Act, prompted in part by the discovery of cancer-causing chemicals
in New Orleans' drinking water.
A New Concept: Joint and Several Liability
In 1980, a lame-duck Congress passed, and outgoing President
Jimmy Carter signed into law, the Comprehensive Environmental
Response, Compensation and Liability Act, or "Superfund". The
law was aimed at cleaning up the country's worst hazardous waste
sites which were to be identified on an EPA National Priorities
24 Chemicals, The Press & The Public
-------
List. It established "retroactive joint and several liability" for
parties whose wastes had contributed to degradation of those sites.
That concept was revolutionary in environmental law: It means
that a company which long ago had disposed of wastes could now
be held accountable for all of the site clean-up costs unless other
responsible parties could be identified and made to pay their fair
shares.
From the standpoint of practical implementation, one issue
stands out in considering the nation's 1970s approach to pollution
control. The nation tended to treat each medium of pollution
air, water, or land -- unto itself. Far from taking the "Spaceship
Earth" approach (which became more accepted as distant views of
the planet from orbiting space shuttles were published), society
and politicians tended to treat pollutants as though they never
strayed from one medium, air, to another, water or land. In many
ways, policy makers treated pollutants as though they respected
arbitrary political boundaries, such as county or state borders.
They do not, of course.
Toward Integrated Environmental Management
Our institutional approach reflected this misconception of
pollution. We established an air office, a water office, a pesticides
office, a waste office, a drinking water office, a groundwater office,
and so forth. Although often under the same roof, they developed
communications difficulties common to bureaucratic structures.
"Multi-media" and "integrated environmental management" were
concepts missing from their lexicons.
This kind of tunnel vision in our legislative and regulatory
approach encouraged society to "fix" one pollution problem by
shifting it to another medium. What had been a water pollution
problem became an air pollution problem, and vice versa. The
image became tangible with word of hazardous wastes' being
cleaned up at one site, only to be transported to another where
they would pose troubles anew. It was as though merely
incinerating a waste could remove a hazardous waste problem with
no implication whatsoever for air pollution. What might be an air
pollution problem in one area could be "remedied" by erecting tall
stacks and shipping the pollutant elsewhere, someplace downwind
of its source.
Chapter 2: Evolution of Right to Know 25
-------
The New Focus on Health Effects ... and Cancer
Just as environmental policy makers began to appreciate the
need for an "integrated" multi-media approach, they began also to
adopt a more public health-oriented outlook. Their primary
concern: cancer.
1 i
This shift to public health from "birds and bunnies," as it was
pejoratively known, occurred gradually. But it came to a head in
the late '70s under the Carter Administration when EPA actively
sought to promote its image as a public health agency. Cancer
became the target of the pollution control initiatives. Scientists
began to call into question the legitimacy of "thresholds" ~ those
levels of pollution below which there would be no detectable
adverse health effects and, therefore, presumably, no adverse effects
at all. "Zero threshold" became a widely accepted tenet,
particularly as it applies to carcinogens.
,. ^ |
With the maturing of environmental programs and with an
increased recognition that numerous and deserving pollution
control programs were competing for limited resources, risk
assessment and risk management came into vogue. Evaluating
"relative" risks became the religion. The notion of a "risk-free"
society was increasingly criticized.
In the early 1980s,
environmental programs,
competing for scarce federal
resources, were subjected to
stringent cost-benefit analysis.
The Reagan Administration
demanded that benefits -
though often hard to quantify
justify federal and private
sector expenditures for
pollution control. Critics and
skeptics of environmental expenditures employed the rule-of-thumb
argument that 90 percent of the pollution could be controlled for
10 percent of the total cost, but that controlling the final 10
percent of the pollution often would entail 90 percent of the costs.
The implicit question: Is it worthwhile to control the final
increments of pollution? Critics of cost-benefit analysis - in
26
Chemicals, The Press & The Public
-------
particular environmental activists countered that only costs, and
not benefits, can be easily calculated.
Turning to "good science" for an answer wasn't enough.
Scientists never will be able to resolve to the complete satisfaction
of policy makers some of these difficult "How clean is clean?"
riddles.
Societal Distrust of Institutional Authority
Then, in the mid-1980s, two important factors combined to
galvanize the "right to know" movement which since has gathered
such momentum in the environmental field.
On the one hand, there was an increasing sense of futility in
addressing environmental problems only after they had been
created. Why not avoid those problems in the first place? The
economics of "Pay me now, or pay me later" lent support to so-
called source/use reduction and waste minimization efforts. (In the
highly charged jargon of environmental policy, reporters should
appreciate that the term "waste minimization" in particular is
suspect in some quarters as suggesting merely that pollution can
be diluted, rather than necessarily implying an avoidance approach
to pollution control.) A sense of dwindling waste treatment
capacity and the "Not in My Back Yard" (NIMBY) attitude against
siting and operation of controversial facilities also fanned these
fires.
As these trends were occurring, an equally important shift in
attitude was taking place generally: Society was growing less
trustful of its authority figures. Not limited to environmental
protection, the change clearly has had an impact on the
management of environmental resources.
Some sociologists trace the loss of confidence in our diverse
institutions to America's experiences in Vietnam. Others point to
the Watergate controversy and subsequent scandals involving public
figures. Whatever the sources, however, many researchers agree
that increasing segments of the population have lost confidence in
a wide range of institutions at all levels - local, state, federal, in
both the public and private sectors.
In 1986, California citizens overwhelmingly passed a
Chapter 2: Evolution of Right to Know 27
-------
referendum specifically stating their lack of confidence in the
ability of regulators, the courts, Congress, and industry to
adequately control pollution. In "Proposition 65," they largely gave
that responsibility to themselves, greatly restricting Executive
Branch discretion. Under this approach, chemicals and potential
risks clearly were to be judged "guilty until proven innocent," and
not vice versa. To a somewhat lesser degree, the same thing had
happened at the federal level in 1984 when the Congress -
reacting against what it perceived to be the excesses of early
Reagan Administration appointees -- passed nondiscretionary
"hammer provisions" as part of the Hazardous and Solid Waste
Amendments to the Resource Conservation and Recovery Act. In
effect, in the absence of Executive Branch action by a deadline, the
hammer would fall, triggering a regulation into action.
Along with these manifestations of a growing public
participation and "right to know" ethic in the environmental field,
a similar trend was occurring in the occupational health field. The
Occupational Safety and Health Administration had adopted right-
to-know provisions as part of its hazard communication standards
regulatory program. Procedures were established for assuring that
manufacturing workers knew what hazardous chemicals they were
working with and what they should do to minimize their exposures
to those chemicals. After losing in court, the government in 1987
was forced to expand the hazard communication standards program
beyond just the manufacturing sector.
i i
That brings us back to Bhopal. When the chairman of the
House of Representatives Subcommittee on Health and the
Environment, Henry Waxman (D-Ca.), surveyed chemical
companies on their inventories and emissions of hazardous
chemicals, he found high volumes that surprised even the chemical
companies. When Congress was preparing to amend the 1980
Superfund hazardous waste site clean-up law, legislators found
fertile ground for action.
It is in that broad context that Congress considered and
eventually passed the Emergency Planning and Community Right-
to-Know Act as Title III of the 1986 Superfund Amendments and
Reauthorization Act. It's a law that many believe will
revolutionize the business of pollution control in the U.S. in the
years ahead.
28 Chemicals, The Press & The Public
-------
Chapter 3
Key Provisions of the Law
The Emergency Planning and Community Right-to-Know Act,
in EPA's own words, "makes citizens full partners in preparing for
emergencies and managing chemical risks."
This partnership taps the journalist in several ways: as an
individual citizen, as a possible member of a local emergency
planning committee*, and as a news reporter with a responsibility
to inform readers about toxic health hazards and emergencies in
the local community. To meet these challenges, journalists must
understand the law, its key provisions, and its enormous potential
for providing information needed for good chemical reporting.
At the same time, they should appreciate the significant limitations
in the information being made available under the law.
The provisions of the law offer a gold mine for good
reporting. But like other good stories, they involve lots of work.
The Emergency Planning and Community Right-to-Kriow Act
has two purposes: to encourage and support emergency planning
for responding to chemical accidents, and to provide local
*Section 301(c) of the law calls for local committees to include, "at a
minimum," representatives of various community interests, including
"broadcast and print media." The media representatives are seen as lending
expertise in communicating with the public. They are seen as participating
in the planning process rather than as reporting on it, a distinction clearly
difficult for working press to accommodate. Many reporters understandably
consider such participation inappropriate for journalists, while other
reporters have agreed to participate in the committees. The exact number
of committees with reporters as members is unknown. In some cases, the
committees include media representatives not from the news room, but
from the business office.
29
-------
governments and the public with timely and comprehensive
information about possible chemical hazards in communities. The
law operates through provisions detailed in four major sections.
Emergency Planning (Sections 301-303) requires state and
local efforts to develop emergency response and preparedness
capabilities based on chemical information provided by industry.
Emergency Release Notification (Section 304) requires immediate
emergency notification to state and local authorities when any one
of approximately 366 chemicals designated "extremely hazardous"
is released to the environment or when chemicals specified under
Superfund are released accidentally.
Hazardous Chemical Reporting (Sections 311-312) requires all
businesses to submit information on chemicals broadly defined as
"hazardous" to local and state emergency planners and local fire
departments. The Toxic Chemical Release Reporting and
Inventory provision (Section 313) requires certain manufacturers
to file an annual inventory of chemical releases with EPA and the
states.
Emergency Planning (Sections 301-303)
i
These sections are designed to help communities prepare for
and respond to emergencies involving hazardous substances. Every
community in the United States must be part of a comprehensive
emergency response plan.
The governor of each state by April 17, 1987, had to appoint
a State Emergency Response Commission (SERC), which can be
one or more existing state agencies, or may consist solely of
individual citizens. (Some SERCs have no state agency
representative and are "staffed" entirely by private citizens.) These
commissions have been named in all 50 states, and the U.S.
territories and possessions.
! j
Each SERC in turn has divided the state into local emergency
planning districts, and has appointed a Local Emergency Planning
Committee (LEPC) for each district. The number of "local
committees" varies widely from state to state. In some states, such
as Georgia and Oregon, one committee covers the entire state; in
New Jersey, on the other hand, the state is divided into 588 local
committees. As a rule of thumb, the opportunity for meaningful
30 Chemicals, The Press & The Public
-------
Lists of Chemicals
- 3 j r - *~ ~ ,. !"&<-
There are four groups of chemicals subject to reporting
under the Emergency Planning and Community Right-to-Khow*
Act. Some chemicals appear in several groups. I '
* ° ~'
< "Extremely Hazardous Substances (Sections 301-304)' t
" list currently contains approximately 366 chemicals. JBecause of (
* their acutely toxic properties, these cbemiqats were chosen^ to
provide an initial focus for chemfcal emergency planning. ""If
,, these chemicals are released m certain amounts, they may be" of
>, >\ i, * "?>-' J J « r-
^unmediate concern to_,the community." Releases must be
reported immediately. ^ _ * 1 "" ', * fu;
' " '*< * ^ r- - ;3 " 1
Hazardous Su&stances (Section 3Q4): These ^re hazardous
Substances listed under4previous Superfund hazardous waste
' cleanup regulations. 'This list contains about 720*substances.
Releases of these chemicals tatibve certain amounte must^ be
reported immediately because they may represent an immediate
^hazard to the community. The reports are made to the state5
commission and to the local committee.
< ' V, ^
*n ~ '
Hazardous Chemicals (Sections 311-312); These chemicals
are not on a list at all, but are defined by Occupational Safety
and Health Administration regulations as chemicals which
represent a physical or health hazard. Under this definition,
thousands of chemicals can be subject to reporting requirements^
Inventories of these chemicals and material safety data sheets for
each of them must be submitted if they are present at the
facility in certain amounts.
Toxic Chemicals (Section 313): There are now about 325
chemicals or chemical categories on this list which were selected
by Congress primarily because of their chronic or long-term
toxicity. Estimates of releases of these chemicals into air, water,
or land must be reported annually and entered into the toxic
release inventory.
31
-------
local citizen participation in an LEPC decreases as the number of
committees decreases, particularly in the larger states.
The State Emergency Response Commissions must supervise
the activities of LEPCs, and together they must establish
procedures for receiving and processing requests from the public,
media, and others for information collected under other sections
of the new law. SERCs also must annually review local emergency
plans to make sure of such things as uniform coordination
throughout the state.
The Local Emergency Planning Committees are the grassroots
groups where the real work of carrying out the new law is being
done. To truly represent their communities, LEPCs by law are to
include:
i
representatives of elected state and local officials;
law enforcement officials, civil defense workers and
firefighters;
first aid, health, hospital, environmental, and
transportation workers;
representatives of community groups and the news
media; and
owners and operators of industrial plants and other users
of chemicals, such as hospitals, farms and small
businesses.
The LEPCs must analyze hazards and develop a plan to
prepare for and respond to chemical emergencies in its district.
The plan should be based on the chemical information reported to
the LEPC by local industries and other facilities dealing with
chemicals.
'. 'i
i
All local emergency plans must:
use the information provided by industry to identify the
facilities and transportation routes where hazardous
substances are present;
establish emergency response procedures, including
32 Chemicals, The Press & The Public
-------
evacuation plans, for dealing with accidental chemical
releases;
set up notification procedures for emergency response
personnel;
establish methods for determining the occurrence and
severity of a release and the areas and populations likely
to be affected;
establish ways to notify the public of a release;
identify the emergency equipment available in the
community, including equipment at facilities dealing with
chemicals;
contain a program and schedules for training local
emergency response and medical workers to respond to
chemical emergencies;
establish methods and schedules for conducting
"exercises" (simulations) to test elements of the
emergency response plan; and
designate a community coordinator and facility
coordinators to carry out the plan.
The list of 366 "extremely hazardous substances" identified by
EPA as having immediate toxic health effects and hazardous
properties serves as a focus for emergency planning. However, the
plans are to address all hazardous materials in the community that
present risks to public health and safety - including, for example,
widely used fertilizers, preservatives, photographic chemicals, and
insecticides.
The list of extremely hazardous substances includes a
"threshold planning quantity" for each substance. If at any time
this amount or more of the chemical is present at any manufac-
turing plant, warehouse, hospital, farm, small business, municipal
installation, or any other facility, the owner or operator must
notify the SERC and the LEPC. [Reporters will note the
omission from this listing of federal facilities, which the law
exempts from coverage. The Executive Branch nonetheless is
seeking voluntary compliance throughout federal facilities, with
Chapter 3: Key Provisions 33
-------
varying levels of success. Critics say that legislative exemption
leaves a large quantity of hazardous substances uncovered.] The
facility's owners or operators must also name an employee as
"facility coordinator". He or she participates in the district's
planning process.
Violators of these reporting provisions are subject to civil
penalties of up to $25,000 a day for each day a violation continues.
j i
LEPCs must make all their information available to the
public. They must let their communities know about their
emergency response plans by publishing notices and scheduling
public meetings open to comment. Their plans must be reviewed
annually, and updated as needed. LEPCs, particularly as they get
over inevitable learning curves and come up to speed, accordingly
should be excellent sources of local information for reporters. By
law designed to represent diverse segments of the community, they
can serve as a focus for community action.
Emergency Release Notification (Section 304)
If a specified "extremely" hazardous substance is released -- in
an accident at a facility or on a transportation route -- in an
amount that exceeds the reportable quantity for the substance,
facilities must immediately notify the LEPCs and the SERCs likely
to be affected.
Chemicals covered by this section of the law include not only
the 366 "extremely hazardous substances," but also about 720 other
hazardous substances now subject to the emergency notification
requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act, CERCLA or the so-called Super-
fund law. Some chemicals are on both lists. Superfund requires
immediate notification of substance releases to the National
Response Center, which alerts federal emergency response teamsJ
Part of the significance of Section 304 is that it requires
immediate notification not just of federal agencies, but also of
local and state officials.
Initial notification of a substance release can be made by
telephone, radio or in person. If the release resulted from a
transportation accident, the transporter can dial 911 or the local
34 Chemicals, The Press & The Public
-------
Local Emergency Planning Committees
is a Local Emergency Planning Committee (LEPC)?
""
A local group appointed by the'State Emergency Response
'Commission to develop an emergency plan to gather
information on chemicals in the community and prepare
'for and respond to chemical emergencies.
r - ,
" A focal point for the relationship between the Title lH^dat
, and^communfty action. <. ?
*
t nart LEPC? c , <*
T /Representatives of: elected* state and local'officials; law
»^ ^!enforcement, civil defense, firefighting, first'aid, health,
" local environmental and transportation agencies- hospitals;
- ^brocidcast and pnnl media; community groups; and facilities
', * -^subject to Title'lII requirements. " N *
*' f ^ ''' * -, -* f r " ,
** Volunteers and professionals.
" ' ' , \ * Jf ' _ '
'LEPC do? ,4
" Receives from facilities 'matenal safety "data sheetst
"(MSDSs)., annual mventones about hazardous chemicals,
and 'notification of accidental releases of hazardous
chemicals. ; ""
:- -,
i
Based on chemical information in the community, develops
a local emergency response plan tailored to the needs of
its district - then publicizes it through public meetings or
newspaper announcements, gets public comments, and tests
the plan periodically with emergency drills.
j
Updates the plan at least annually.
: Makes its information available to the public.
Takes civil actions against facilities if they fail to provide
the information required under Title III.
Serve as a focus for community awareness and action
concerning the presence of chemicals in the community.
Chapter 3: Key Provisions 35
-------
State Emergency Response Commissions
What is a State Emergency Response Commission (SERC)?
A commission appointed by the governor of each state to
serve as the main source of Title HI authority and as a
source of information for anyone interested in the
emergency planning process.
A new commission, or one or more existing state agencies,
such as the environmental, emergency, health,
transportation, commerce, and other relevant agencies. In
some states, SERCs consist solely of citizens, with no state
representation.
Who serves on a SERC?
Members of trade associations, public interest organizations,
and others with experience in emergency planning,
including representatives of environmental, emergency
management, and health agencies.
What does a SERC do?
Divides its state into local emergency planning districts.
Appoints a Local Emergency Planning Committee (LEPC)
for each district, and helps them and citizens .create
effective plans.
' Supervises and coordinates the activities of LEPCs,and
with LEPCs, establishes procedures for receiving and
processing public requests for information collected under
other sections of the new law.
Reviews local emergency plans annually to make sure of
such things as coordination across the state.
Receives from facilities material safety data sheets
(MSDSs), annual inventories about hazardous chemicals,
and notification of accidental releases of hazardous
chemicals.
36 Chemicals, The Press & The Public
-------
telephone operator to report it. All emergency notifications must
include:
the chemical name;
the location of the release;
whether the chemical is on the "extremely hazardous"
list;
how much of the substance has been released;
the time and duration of the incident;
whether the chemical was released into the air, water or
soil, or some combination of the three;
known or anticipated health risks and necessary medical
attention;
proper precautions, such as evacuation; and
a contact person at the facility where the release
occurred.
Notification will activate emergency plans. As soon as
practical after the release, the facility coordinator must submit a
written report to both the LEPC and the SERC. That report
must update the original notification and provide additional
information about response actions taken; known or anticipated
health risks; and, if appropriate, advice regarding any medical care
needed by exposure victims. By law, this information is to be
available to the public.
Anyone who fails to notify the authorities of a substance
release is subject to civil penalties of up to $25,000 a day for each
day of non-compliance. Repeat offenders can be fined up !to
$75,000 a day.
In addition, criminal penalties may be imposed on any person
who knowingly and willfully fails to provide notice. Criminal
violators face fines of up to $25,000 or prison sentences of up to
two years. Repeat criminal offenders can be fined up to $50,000
and imprisoned for as long as five years.
Hazardous Chemical Reporting (Sections 311-312)
Accidental chemical releases are only part of what the public
has a right to know about under the Emergency Planning and
Community Right-to-Know Act.
Chapter 3: Key Provisions 37
-------
Under Sections 311 and 312, facilities also must report the
amounts, locations, and potential effects of hazardous chemicals
present in designated quantities on their property.
All companies, of any size, manufacturing or non-
manufacturing, are potentially subject to this requirement. They
must report this information to the relevant LEPCs, SERCs, and
local fire departments. Facilities must report on the hazardous
chemicals in two different ways:
1. Material safety data sheets (MSDSs): These contain
information on a chemical's physical properties and health effects,
and whether it presents hazards in any of these categories:
immediate (acute) hazard, delayed (chronic) health hazard, fire
hazard, sudden release of pressure hazard, or reactive hazard.
Under federal laws administered by the Occupational Safety
and Health Administration (OSHA), companies are required to
keep MSDSs on file for all hazardous chemicals in the workplace.
They also must make this information available to employees, so
workers will know about the chemical hazards they are exposed to
and can take necessary precautions in handling the substances.
The relevant chemicals are those defined as "hazardous
chemicals" under OSHA's requirements -- essentially, any chemical
that poses physical or health hazards. As many as 500,000
products can be defined in this way. If they are present, they must
be reported under the hazardous chemical reporting provisions.
An MSDS or list must be provided when new hazardous
chemicals become present at a facility in quantities above the
established threshold levels. A revised MSDS must be provided if
significant new information is discovered about a chemical.
Once submitted to the LEPC, SERC and local fire
department, the MSDS information is available to the public upon
request.
When the Emergency Planning and Community Right-to-
Know Act was passed in 1986, OSHA's regulations applied only to
manufacturers - about 350,000 facilities. In the wake of court
decisions applying OSHA's hazard communication standard beyond
the manufacturing sector, these regulations now apply also to most
38 Chemicals, The Press & The Public
-------
facilities where workers are exposed to hazardous chemicals
about 4.5 million facilities nationwide.
2. Annual inventories: Companies must report on hazardous
chemicals by submitting annual inventories to their LEPCs, SERCs
and local fire departments, under a two-tier system. Under Tier
I, a facility must report the amounts and general location of
chemicals in certain hazard categories. (Example: A facility stores
10,000 pounds of a substance that causes chronic health effects.)
A Tier II report requires a brief description of how each
chemical is stored and the specific storage location for each
hazardous chemical. (Example: A facility stores 500 pounds of
benzene in the northwest corner storage room of the warehouse.)
Congress gave companies the choice of filing a Tier I or Tier
II form, unless the SERC, LEPC, or fire department requests Tier
II. The Tier I/II forms must be submitted annually beginning
March 1, 1988. Tier I forms must estimate (in ranges) the
maximum amount of chemicals present at a facility at any time
during the preceding calendar year; provide a range of estimates
of the average daily amount of the chemicals present in each
chemical category; and provide the general location of hazardous
chemicals within the facility.
Tier II information must be submitted upon request from a
local committee, the state commission or a local fire department.
Tier II information is to include more specific information about
each substance subject to the request: chemical name or common
name as indicated on the material safety data sheet; an estimate of
the maximum amount of the chemical present at any time during
the preceding calendar year; a brief description of how the
chemical is stored; and the location of the chemical in the facility.
Tier II reports also must indicate if the reporting facility has
withheld location information from disclosure to the public for
security reasons, such as protecting against vandalism or arson.
However, the information reported under Sections 311 and 312
generally is to be available to the public through local and state
governments during normal working hours. Aware of this, many
companies may provide the information to reporters upon request,
rather than putting them through the additional steps of going
through the state commission or local committee.
Chapter 3: Key Provisions 39
-------
EPA, in its own words, "believes that Tier II reports provide
emergency planners and communities with more useful
information, and is encouraging facilities to submit Tier II forms."
!
The public and reporters can gain access to MSDS and annual
inventory reports by contacting the LEPC or SERC. The state
commissions may be the best bet, because some have incorporated
additional requirements, and some may have included the federal
requirements in their own forms. Under law, the state or local
commissions must respond within 45 days to written requests for
Tier II information involving specific facilities.
The civil penalty
for failing to submit
MSDSs or lists of
MSDS chemicals is up
to $10,000 a day for
each violation. For
non-compliance with
the annual inventory
requirements, the
penalty is $25,000 per
violation.
Toxic Chemical
Release Reporting
and Inventory
(Section 313)
The fourth key
element of the Emer-
gency Planning and
Community Right-to-
Know Act requires cer-
tain manufacturing
plants to report an-
nually, beginning July 1,
1988, on the amounts
of about 325 toxic
chemicals they release
into the air, water or
soil. This provision
applies to an estimated
40
Chemicals, The Press & The Public
-------
25,000 - 30,000 facilities with 10 or* more employees. A small
business exemption frees companies with nine or fewer employees
from coverage.
Toxic chemical release reports are required by facilities that
use more than 10,000 pounds of a listed chemical in a calendar
year. Under a phase-in schedule, the 1988 and 1989 reports were
required for facilities that manufactured or processed any of these
chemicals in excess of 75,000 pounds in 1987 and in excess of
50,000 pounds in 1988. Thereafter, the annual reports must-be
submitted by facilities that manufacture or process more than
25,000 pounds in a year.
Many companies long have been required to report data on
chemical emissions to EPA and the states under other
environmental laws such as the Clean Air Act, the Clean Water
Act and the Resource Conservation and Recovery Act. What
makes the annual toxic chemical release reporting requirement
different, and particularly useful, is that estimated releases of a
specific chemical to air, water and land will appear on one form,
and that the public and press will have direct access to the data.
Companies that fail to file annual toxic chemical release
reports are subject to civil penalties up to $25,000 a day for each
chemical they should be reporting.
Facilities must annually file a Toxic Chemical Release
Inventory Form (Form R) to estimate the total amount of each
chemical that they release into the environment, either by accident
or as a result of routine plant operations, or that they transport
as waste to another location. A complete Form R must be
submitted for each chemical. A sample Form R is reproduced
beginning on the following page.
Releases covered include emissions to the air from stacks,
liquid waste discharged into water, wastes disposed of in landfills,
and waste transported off-site to a public or private waste
treatment or waste disposal facility.
Many of the chemicals covered by this section of tltie law,
though not all, pose long-term (chronic) health and environmental
hazards, such as cancer, nervous system disorders, and reproductive
disorders stemming from routine exposure. Among the most
commonly used substances included on the list of the approxi-
Chapter 3: Key Provisions 41
-------
D
Form Approved OMB No.
Approval ExplnM
r nrinf w' linraalma btlart comflelini form.)
A PDA U.S. Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY REPORTING ' £0*
Section 313 of the Emergency Planning and Community FUght-to-Know Act of 1SB6.
EPA FORM
R
1.
PART 1.
FACILITY
IDENTIFICATION
INFORMATION
,L£25S"7!°
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(Important: Type or print; read instructions before completing form.) pa<|B 2 Of 5
R(Thts spaca for your optional use '
** CfA PART 11. OFF-SITE LOCATIONS TO WHICH TOXIC
CHEMICALS ARE TRANSFERRED IN WASTES
1. PUSUCLY OWNED TREATMENT WORKS (POTWm)
y
County
Zip
1.2 POTWnamo
City County
Zip
2. OTHER OFF-SITE LOCATIONS (DO NOT REPORT LOCATIONS TO WHICH WASTES AHg SENT OM.Y FOR HECVCUNQ OR REUSE).
2.1 Ol [-!( location n«n«
City
""""
County
Zip
it location undw control of reporting f»eimy or p*r»nt company?
MY- [ ]N.
2.3 OH-«il« location nam*
A ten r*»mow (R O. No.)
a tract MJrua
Cliy
8I«1»
It Ideation undw control ol r«portlno f*elllty
County
zip
w pirwit eompiny?
[ ]v.. [ ]N.
2.6 Olf-ilt* looallon nam«
EPA kfWimiMtkxt Numt»r (RCRA O, No.)
StrMl Addr«n
City
8l*t*
County
Zip
U locmtloa und*r control ol r»portlno facility or p«r*nt comp»ny7
[ ]v» [ 3»
] Ch*Ck If tdcftllonal P*OM of P*rt a «r*
Il*ch«d. How minyT
2.2 Oll-xlta location name
sttMi Addr»M
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Sl»l« Zip
It location undtr control of nDoritna Uelllty or ptrmt oompmny?
[ ]v., [ ]»
2.4 OIf-slt« location nam«
EPA Wanllllcatlon Number (RCRA ID. No.)
GlrMt AdoVMi
City County
StBla Zip
Is location unOvr central of ttportlng facility or par«ni company?
[ ]v.. [ ]»
EPA ktenilfteatJon NumMr (RCRA ID. No.)
5ir**i Addrvn
City County
Slat* Zip
location undw contiol at (pofting taclllly or ptrvnt company?
[ ]v.. [ 1»
BHBBHHHHH
EPA Form 9350-1(1 -39 1 Rovlaod Do not ute pravlous versions.
Chapter 3: Key Provisions
43
-------
D
(Important; Type or print; read instructions before completing form.)
D
Paoa 3 of S
(This apace for your optional uso.)
EPA FORM R
PART III. CHEMICAL-SPECIFIC INFORMATION
HEMICAL IDENTITYlOo not complete this section II you compete Secti
CAS Number (Enw th« numbw «mctly « It «PP««'i «> th« 313 Hit, Eni« NA 1
Chemical or Chamlcal Cateaory Name (6ntw it» n«m» «uothr « » «PP««« ««tt>« aia II
HE CHEMICAL AT THE FACILITY 1C
e or Import:
For on-slta
use/processing
e.[ ] A« a byproduct
Manufacture the
chemical:
a. I ] Produce
b. [ ] Import
distrtoutlon
f.[ JAo an Impurity
a.[ } As arsactant
d. [ ] Repackaging onj
o,[ ] Ancillary or other USB
CALENDAR
5. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITB
You may report ratoaseg ol less than
1.000 Us. by checking ranges under A. 1.
(Do net use both A. t and A.2)
[ ] (Owe* II «
-------
n
(Important: Type or print; read inslrucllons before completing form.)
n
Page A of 5
SERA
PART III.
This space for your optional use.
EPA FOR1V.R
CHEMICAL-SPECIFIC INFORMATION
(continued)
6. TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
You may report transfers
of lass than 1,000 Ibs. by checking
ranges under A.1 . (Do not use
both A.1 and A.2J
Dlicliiro* to POTW
6.1.1 Jrom"pl5tBI,ll5«e«ori'
'..mo
Othw o1(-»!t» location . . . .
OlrW otf-f It* tocillon
6.2.2 terpisTaaESs
.iDDO
6.2.3 S^VS??., BO
A. Total Transfers
(tbs/yr)
A.I
Reporting Ranges
O t-4M 50O-HB
[][][]
[][][]
[ I
] [ ]
LI f 1 f ]
A.2
Enter
Estimate
B.
Basis of Estimate
(enter code)
..,.,» D
6.2. 1b I I
6.2. 2b I I
6.2.3B I I
C.Type of Treatment'
Disposal
MB
«.,... wn
6.2.2C |M| 1 1
6.2.30 |M| j 1
[ ] (Check If additional Information Is provided on Part IV-Supptememal Information.)
7. WASTE TR ATMENT METHODS AND EFFICIENCY
A. General
Wastoatream
(enter coda)
7.1. n
7.2. n
7.3. n
7.«» n
7.5. O
7.6. O
7.7. O
7.8. 1^1
7.9a O
7.10a r~j
B
7.111
7.2b
7.3S
7.4b
7.5D
7.66
7.7b
7.8b
7.9b
7.tOb
Treatment
Method
enter code]
cm
cm
am
cm
cm
cm
cm
cm
can
cm
C. Range of
Influent
Concent rat on
(enter code!
7,= D
7.2c Q
7.3c £"__!
7.4c | I
7.5e Q
7.6c Q]
7.7c | )
7.8= n
7.9= O
7.100 O
0. Sequential
Treatment?
(check if
appllcablo)
7.1d [ ]
7.2d [ ]
7.3d [ ]
7.« [ ]
7.« [ ]
7.6d [ ]
7.7d [ J
7.8d [ ]
7.9d [ ]
7.10d [ ]
E. Treatment
Efficiency
Estimate
7.1. %
7.2e %
7.30 %
7.4s %
7.5e -a
7.6e %
7.7e «
?.ce K
7.9e %
7. Ida V.
F. Based on
Operating
Data!
Yes No
'" [ ] [ I
7.2f [ ] [ ]
7-3' 1113
7.4f [IF]
"' [ ] I ]
7-6' [ ] [ I
"' [ ] [ ]
7-8' [ ] I ]
7-8' Mil
7.IOf [ ] [ ]
[ ] {Check It additional Information Is provided on Part IV-Supplemental Information. )
4. OPTIONAL INFORMATION ON WASTE MINIMIZATION
(Indicate actions taken to reduce the amount of the chemical being released from the facility. See the instructions far coded
Items and an explanation of what information to Include.!
A. Type of
Modification
(enter code)
3D
8. Quantity of the Chemical In Wastes
Prior to Treatment or Disposal
Currant Prtor
reporting year
year (Ibs/yr) (Ibs/yr]
Or percent
change
C. Index 0. Reason for Action
(enter code)
D.D Lan
EPA Form 9350-1 (1-89) Revised - Do not usa previous versions.
Chapter 3: Key Provisions
45
-------
n
(Important; Type or print; read Instructions before completing form.)
n
p>go 5 of 5
EPA FORM R
PART IV. SUPPLEMENTAL INFORMATION
A CPiA
«' tKA
Use this section If you need additional space lor answers to questions i In Part HI.
Kumbar the Unas usud sequentially from Unas In prior sections {o.g.. 5.3.4, 6.1.2. 7.11)
(This space for your optional uso.)
ADDITIONAL INFORMATION ON RELEASES OF THE CHEMICAL TO THE ENVIRONMEI
(Part 111. Section 5.3) .
You may report releases of less than
1,000 IDS. by checking ranges under A. 1.
;Do not use both A.1 and A.2}
5.3 Dischargee to ii
receiving streams or , I
water bodies s-3 ''
""n
EPA Form 8350-1 |1-S9> Rvllod-Do not ura previous versions.
46
Chemicals, The Press & The Public
-------
mately 325 chemicals are ammonia, chlorine, copper, lead,
methanol, nickel, saccharin, silver, and zinc.
Information that must be estimated and reported by
manufacturers for these reports includes:
Which toxic chemicals were released into the
environment during the preceding year?
How much of each chemical went into the air, water and
land?
How much of the chemicals were transported away from
the site of the facility for disposal?
How were chemical wastes treated on-site?
How efficient is that treatment?
These reports must be filed by July 1 of each year covering
releases in the previous calendar year. That means the reports
filed by July 1, 1989, for instance, covered calendar year 1988.
They are submitted to EPA headquarters in Washington, and to
the state environmental, health or emergency response agency
which coordinates with the SERC.
Under an unusual provision of federal law seen by some as
a precedent for providing the public increased access to federal
information, EPA is required to compile the Section 313 reports
into a national computerized database called the Toxic Release
Inventory, or TRI. That national database must be accessible to
the public through computer telecommunications or other means.
The agency on June 19, 1989, made the database available through
the Toxicology Data Network (TOXNET), operated by the
National Library of Medicine (NLM). That Library is part of the
National Institutes of Health, in the U.S. Public Health Service,
U.S. Department of Health and Human Services. The TOXNET
system is accessed through the "Telenet" or "irymnet"
telecommunication networks, and reporters should contact the
"TRI Representative" at NLM in Bethesda, Maryland, for details
on accessing the TRI file. The telephone number there is (301)
496-6531. In addition, see Chapter 6 of this media guide.
Chapter 3: Key Provisions 47
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Limitations of the Section 313 Information
In many cases, the information reported under Section 313 is
based on estimates, not on actual measurement of releases.
Because most facilities do not normally monitor their releases,
EPA provides guidance to ensure that estimates are as accurate as
possible. The agency also is conducting some audits and
inspections to help facilities improve the accuracy of the data they
report.
Another limitation is that not all toxic chemicals or sources
of toxic chemical releases are covered. Only manufacturing
facilities with 10 or more employees are required to report the
release information. As mentioned earlier, federal facilities, such
as large military bases and other facilities which store large
volumes of hazardous substances, are exempt from the law.
i
i
The reports also show only total annual emissions, and then
only those emissions that cover the previous calendar year. The
reports therefore do not indicate whether a chemical was released
in large amounts over a short period of time, or in small amounts
every day throughout the year. If all the air toxics, for instance,
happened to be released during an atmospheric inversion in the
dead of summer, the public and press will never know it by
reviewing the required TRI reports. Information on the rate and
duration of chemical releases can be important in determining the
effects of the release on human health and the environment, but
the TRI does not provide that information at this time. (However,
many of the chemicals that must be reported on. the TRI are also
on the Extremely Hazardous Substances list. Section 304
accidental release information also can be helpful here in putting
together the puzzle. This example illustrates the need for
reporters to use all of the various components of the new law
collectively to be sure they see the big picture.)
Finally, the reports cover releases of chemicals, but do not
show the extent of public exposure to the chemicals after they
enter the air, water or soil. Few will argue that the millions of
pounds of hazardous substances emitted into the air are "good" for
public health; but the argument over just how "bad" the releases
are remains a contentious and complex one. Many things can
happen to a chemical once it is released into the environment. In
addition, the ways in which a pollutant can enter the human body
4g Chemicals, The Press & The Public
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are numerous and diverse... through ingestion, through absorption
or inhalation. These variables make it difficult to determine the
extent to which people are actually being exposed to chemicals
after they are released.
Getting the Information Through the TRI
The toxic release inventory database has been accessible on-
line through a computer and telephone modem since June 1989.
By paying a $25 hourly standard access fee, reporters can obtain
information on what releases have occurred in a particular
community by searching through the reports electronically and
pulling out information of interest from more than one report at
a time. For journalists with the computer power and know-how,
outright purchase of tapes of the entire database or parts of it
will obviate the need to pay a $25 per hour access fee.
The public and journalists can, for example, look at all
reports filed by facilities in a certain zip code, or discharges to a
particular body of water, or reports on releases of one specific
chemical. The National Library of Medicine, in a February 1989
announcement of the TRI database, gave examples of questions
that can be asked of the database:
How much benzene was reported released to
waterways in 1987 by Virginia industrial plants?
What waste minimization methods are reported by
Marin County manufacturers of toluene?
How much chlorine gas have entire plants of
Company XYZ released into the air last year
throughout the country? [Reporters might note
that "estimated they released" would make this
question more accurate, given that the releases in ;
many cases are estimates.]
What are the names and addresses of Baltimore i
steel plants importing vanadium?
What quantity of sulfuric acid at Boston's ABC
Waste Treatment Facility is transferred there from
outside the state of Massachusetts?
Chapter 3: Key Provisions 49
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If that weren't enough to whet journalists' curiosity and
appetite for information, the database also will provide reporters
information on the estimated annual emissions of a chemical in a
specific geographic area. The public and journalists will also be
able, for example, to compare and contrast the emissions reported
by similar facilities in different parts of the country. In addition,
they can match TRI information with inventory and accidental
release information available through the state commissions and
local planning committees for the same facilities.
Journalists and citizens not having ready access to a computer
and modem will be able to obtain the release information on
microfiche from the state where the forms are filed, federal
depository libraries, LEPCs, and regional EPA offices. They may
be able to get copies of the reports also from companies
submitting the reports. Although those facilities are not
specifically required to release their reports directly to citizens and
journalists, many may choose to do so given that the information
is to be publicly available in any event and they may want to avoid
an appearance of "stonewalling."
Other Sources of Information
f
Notwithstanding the "glamour" some may see in using the on-
line database, reporters should not neglect the tried-and-true
approach of also looking close to home for TRI data. That
information, remember, is reported to the state commissions, and
many SERCs may have done their own analyses of the informa-
tion. Those state commissions, and in some cases local
committees, also are excellent sources of information on TRI
reports. They'll be valuable resources to reporters along with the
TRI database itself, and reporters lacking familiarity with or access
50
Chemicals, The Press & The Public
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to computers and databases may find them more convenient and
more productive. (See Chapter 9 for SERC and state Section 313
contacts.)
Trade Secrets: The One Exception
... But a Limited One
Under Section 322 of the law, companies reporting under the
Emergency Planning and Community Right-to-Know Act, under
very limited conditions, can request that the specific identity of
chemicals in their reports not be disclosed to the public. Congress
in this section takes a very cautious approach to allowing claims
of trade secrecy, requiring that companies state and justify their
claims up-front, rather than allowing the claims and then making
them subject to challenge after-the-fact.
In addition, Congress specifies in the law that a company
claiming a trade secret must be able to prove that the withheld
information is not subject to disclosure under any other fisderal or
state law, and that it is a legitimate trade secret - that disclosure
could substantially damage the company's competitive position.
The chemical's identity must be included in the company's reports.
Furthermore, the organization claiming trade secret protection
must demonstrate that it has taken "reasonable measures" to
protect the confidentiality of that information and that it intends
to continue taking such measures. Once such a trade secret claim
is withheld, information beyond the specific chemical identity still
will be available to the public. Information, for instance, about
the general category of the chemical, which will disclose its
environmental and health effects, is to be included in the public
version of the reports, even after a trade secret claim has been
approved.
Citizen? may challenge a trade secret claim by filing a petition
with EPA requesting disclosure of the chemical.
Owners and operators who submit "frivolous" claims of trade
secrets can be penalized up to $25,000 for each such claim. For
that reason and because the trade secret provision is so narrow,
only about 40 trade secret claims are reflected in the first-year
toxic release inventory database, and indications are that trade
secret claims will be made only infrequently in coming years.
Chapter 3: Key Provisions 51
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Enforcement Provisions
Nongovernmental parties failing to comply with the law's key
provisions -- for emergency planning, emergency notification, and
reporting requirements - face civil, administrative, and\or criminal
penalties under the Section 325 enforcement provisions of the
Emergency Planning and Community Right-to-Know Act.
Violations of the law's emergency planning and emergency
response requirements, under Sections 302(c) and 303(d), are
subject to potential civil penalties of as much as $25,000 daily. A
civil penalty of up to $25,000 can be assessed for a violation of
the Section 304 emergency notification requirements, once the
accused is given notice and an opportunity for a hearing on the
alleged violation. Second and subsequent violations can draw fines
of up to $75,000 for each day the violation continues.
Those found guilty of "knowingly and willfully" failing to
provide Section 304 emergency notification reports on extremely
hazardous substances or CERCLA hazardous substances released
from their facility face penalties, once convicted, of up to $25,000
or imprisonment for up to two years. Those penalties are doubled
for second or subsequent criminal convictions.
In addition to the emergency planning and notification
penalties, Section 325 authorizes civil penalties of up to $25,000
per violation for failure to meet Section 312 or Section 313
provisions dealing with emergency and hazardous chemical
inventory forms and toxic chemical release forms. A finding by
the EPA Administrator that a trade secret claim is insufficient and
"frivolous" can bring an administrative or judicial penalty of
$25,000 for each such claim. Also, a person who "knowingly and
willfully divulges or discloses" information entitled to trade secret
52 Chemicals, The Press & The Public
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protection under the law can be fined up to $20,000 or imprisoned
for as much as one year.
As is true under the environmental statutes generally,
individual citizens have authority to bring civil suits. They can
bring suit against a facility for alleged failure to submit emergency
notices; for failure to submit a material safety data sheet or list of
chemicals under Section 311(a); for failure to complete and submit
a Section 312(a) inventory form; or for failure to complete and
submit a Section 313(a) toxic chemical release form.
The government and the public clearly have the authority to
bring stringent enforcement actions under the law. The question
is whether they have the will and resources to back up the written
authority.
In issuing complaints totaling $1.5 million in penalties against
25 companies in December 1988 for alleged reporting violations,
an EPA official said the companies "have a responsibility, by law,
not only to EPA and the states, but to the citizens who live near
their manufacturing facilities." EPA's then-Acting Assistant
Administrator for Pesticides and Toxic Substances said the reports
"are an essential element of our community right-to-know program.
Without these reports, we cannot develop our nationwide database
that will provide the public with information on what is being
emitted into its air, land, and water." In a December 19, 1988,
press release, the agency called the enforcement effort "part of an
ongoing, nationwide enforcement initiative coordinated through
EPA headquarters and regional offices to bring facilities into
compliance with the law." The largest penalty sought in the action
was $721,000 against a midwest steel maker.
EPA enforcement of the new law was back in the news six
months later, on June 27, 1989, when the agency sought fines of
another $1.65 million against 42 facilities alleged to have violated
reporting requirements. In this case, the largest fine involved a
claim of $262,000 against a California electronics manufacturer.
"These companies have a legal responsibility to provide the data,"
President Bush's EPA Administrator, William K. Reilly, said. "We
will not allow non-reporting companies to thwart the right of
citizens to find out which toxic chemicals are being released into
their communities." The enforcement actions prompted The Wall
Street Journal to report that Reilly "is prosecuting the 'citizen's
right to know' law on toxic chemicals with the zeal of a crusader."
Chapter 3: Key Provisions 53
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The newspaper suggested that perhaps EPA "could forego its
appropriation and live off corporate fines."
Perhaps, but the environmental community, not surprisingly,
is hoping for far more - and far more aggressive -- enforcement.
Agency critics insist EPA needs to go after more violators, and
seek larger fines, if the public is to have confidence in the
reporting system and if the reporting system itself is to have the
level of thoroughness and integrity essential for making policy
decisions. With the law's key provisions now up and running and
the initial planning stages behind, continued, enforcement will be
a key in assuring that Reilly's words are backed up by action.
See Chapter 5
on page 65:
Reporting on
a Chemical Emergency
Questions to ask before heading out
Questions to ask at the site
Checklists to assist you ...
Is Your Community Prepared?
Reporting A Hazardous Materials
Incident (At the scene; Back at
the Office)
54
Chemicals, The Press & The Public
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Chapter 4
Unlimited Possibilities for Journalists
Though still in its infancy, the Emergency Planning and
Community Right-to-Know Act promises to make available enough
data and information to provide unlimited story possibilities for
journalists interested in reporting in depth on:
the presence and release of toxic chemicals, locally and
nationally;
the environmental and health risks of hazardous chemicals;
the extent of local and national community participation in
community-based chemical risk management; and
the extent of local and national industry participation and
commitment to the goals of the law.
Though critics of the law brand it a product of the "too much
data syndrome,11 the law will provide information critical to
communities and emergency responders and citizens if they are to
better understand the possible risks they face. The public
continues to be dependent on the mass media to better understand
chemical risks in their communities. That reliance in turn will put
an increased burden on patient and enterprising journalists who
will sift through massive quantities of information in search of the
right story.
Each July's filing date for reporting chemical release
information is just one important opportunity afforded by the law
to enterprising journalists. Using reports filed under various
provisions of the law and available through local committees
and/or state commissions, reporters will more easily be able to
draw a community's chemical profile: What chemicals are stored
there? What is released? Are effective steps being taken to
reduce unnecessary storage and/or release? How is the community
dealing with its own "chemical profile"? A community's state of
55
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preparedness, or lack of preparedness, for dealing with a chemical
accident, and the kinds of accidents that might occur, are other
ongoing story possibilities.
Getting the most out of the law will require using its various
component parts collectively. For example, a facility reporting
large quantities of fugitive emissions under Section 313, large
inventories under Section 312, and repeated accidents under
Section 304 might warrant increased community attention. IS it
getting it? Is the problem poor management, inadequate
maintenance, inattention to safety?
What to Look For in
'Right to Know' Information
A number of organizations -- each with its own axe to grind,
to be sure - have drawn up suggested questions they would like
to see asked based on the Section 313 Toxic Release Inventory
reports.
_
Here are some questions, for instance, suggested by the air
quality and "right to know" activist Deborah Sheiman of the
Natural Resources Defense Council, a national environmental
membership organization:
i
What are the environmental and health effects of
the chemicals released? [Reporters should question here
whether the effects are chronic or acute.]
1 ,
What effects has the particular chemical been tested
for, and what effects have not been tested?
" '
What is the basis of the emissions estimate? Actual
measurements provide the most accurate information:
when and for what chemicals were they done?
Has the industry measured or merely estimated
human exposure to the chemicals? Do the estimates
represent a release over a year, on a daily basis, or in
one accident?
Are air or water monitors (if any) located downwind
or downstream of the disposal locations? How far are
56 Chemicals, The Press & The Public
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they from the point of release? How often do the
monitors collect samples?
What concentrations of the chemical have been
detected? Is the chemical harmful in that volume?
Some substances disperse or degrade; others do not, and
their total discharge volume is harmful.
Has the facility provided a quantitative assessment
of cancer risks and then compared those figures with the
risks associated with natural events or everyday activities?
Is the reported risk for the most exposed persons or
a person with average exposure?
Do the total releases reported include "accidental"
spills? If so, what percentage of the total do they
represent?
Has the facility reported its accidental releases to
the National Response Center and the LEPC?
Do the major sources of the toxic releases within
the facility have pollution controls? Are any additional
control measures available? If so, why haven't they been
installed?
Are there less toxic substitutes which could be
used?
Has the company reduced or increased releases from
last year? Has it ever analyzed what can be done to
reduce releases?
Are there federal, state, or local standards regarding
releases of these chemicals? What federal, state, or local
Chapter 4: Unlimited Possibilities 57
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permits apply to the facility? Is it in violation of any of
those permits?
Reporters might also consider some questions about what
isn't available under provisions of the law:
Are there other facilities in your community that
are not covered but which may be releasing the same
chemicals? Military installations, for instance, often use
and store the same chemicals as private sector facilities.
What chemicals are released but not covered under
Section 313? Are they covered under Section 304
emergency release notification provision?
Are there any local facilities which might not have
filed their required reports?
Has the company kept the identity of any chemical
releases secret? If so, why?
Activist environmental organizations, of course, are not alone
in putting forward questions they think should be asked concerning
community chemical information. The American Chemical Society
poses the following questions for local public health officials (and
therefore reporters?) to ask. They are questions which in many
cases cannot be answered based on the information available under
the Emergency Planning and Community Right-to-Know Act. But
they are questions which might be sparked by availability of that
information:
Is anyone in the community at risk? [LEPCs, using
302, 304, and 311/312 data, may be good sources of
perspective on this question.]
How much of the chemical could have been
breathed or ingested by an individual?
Are the concentrations safe?
What is chemical risk?
What is chemical toxicity?
58 Chemicals, The Press & The Public
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What is "exposure"?
What were the quantities emitted per day?
Were releases continuous, intermittent, or planned?
What is the danger of chemicals detected at low
concentrations?
What is the source of that information?
What else is the chemical combined with or in the
presence of?
How often, when, and how are the releases
occurring?
At what height are emissions released?
At what temperature?
Where on the property?
What is the predominant daily wind direction? Are
releases restricted during certain wind or weather
conditions?
What are the potential exposure routes (e.g.,
drinking water, air, or surface water) for the community?
Are the air and water safe?
How do the chemical risks compare with other risks
in the community?
What are the symptoms of adverse chemical
exposure?
Are people who work outdoors at greater risk?
Is it risky to sleep in rooms with open windows?
Is eating fish from or swimming in local streams
risky?
Chapter 4: Unlimited Possibilities 59
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Are older people, pregnant women, and children at
greater risk than others?
Are chemical risks affected by diet, smoking, and
other personal choices?
Are government standards the best guide to
determine "safety" or "purity" of drinking water or
contaminant levels?
Are "toxic" and "hazardous" the same thing (in
regulatory language)?
What are "extremely hazardous substances"?
Why can't these emissions be stopped entirely?
What will the govern-
ment do about this? [A
good additional question
here: What is the Local
Emergency Planning Com-
mittee doing with the
information it has? How is
the LEPC using that
information?]
Why didn't you tell me
this before?
From the standpoint of the Chemical Manufacturers
Association, key questions and points that should be raised
concerning the chemical information are:
Is the information being reported going to be
perennially out of date, because it applies to the
previous calendar year and not to what is going on
today? Are emissions in many cases lower today than
they were a year ago?
Are the numbers merely estimates, based on
industries' "assumptions" about their emissions? Is it
correct that the numbers do not represent "actual
emissions"? [CMA says "our guess" is that actual
60
Chemicals, The Press & The Public
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emissions "are a lot lower" than reported emissions based
on estimates. Others, however, are skeptical that
industry would intentionally estimate emissions on the
high side.] :
Is it misleading to suggest that "a direct link" can be
made between the raw numbers and health effects?
Is the information and data subject to misuse,
unintentionally and intentionally, by people wanting "to
promote laws or causes they favor"?
Will misuse of the data needlessly frighten people?
"If the data are misused, we won't be able to focus on
problems that might really exist -- and solve them."
Without specific information on exposure,
concentration, and duration of exposure, the emissions
numbers do not really identify risks or health effects.
Even with concentration and duration information, one
still could not determine "health effects."
Estimating emissions of a substance at a valve or a
flange does not provide guidance on concentrations in
the community, because the chemicals are dispersed and
become highly diluted in the atmosphere. Furthermore,
many substances break down chemically in the
atmosphere.
A Gold Mine and a Mine Field
~ of Good Stories
The Emergency Planning and Community Right-to-Know Act
is a gold mine - and a mine field - for news stories. A reporter
need not await a chemical "incident" to find good story ideas.
Long before any chemical emergency might occur, reporters
might develop an overall "community chemical risk profile" by
assembling the information compiled under various provisions of
the law. How has your community organized itself to anticipate,
prevent, or, in the worst case, effectively respond to a possible
chemical emergency? Consider these possible angles in pursuing
such a story idea:
Chapter 4: Unlimited Possibilities 61
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Is your Local Emergency Planning Committee
appropriately representative of the community overall?
Are key government, business, health, and citizen
interests adequately represented? Has the Committee
met? How often? How is it organized? Into
subcommittees?
Is the Committee effectively organized and managed to
meet its responsibilities to provide the public access to
needed information?
Has the Committee designed an adequate emergency
response plan defining responsibilities of key community
representatives? How have particular risk activities, such
as a waste disposal operation or a nuclear power plant,
been accounted for? Is the role of off-site emergency
personnel spelled-out? Has the plan been reviewed by
the State Emergency Response Commission?
i
Has the Committee conducted a "community hazard
analysis" as outlined by federal guidance documents?
Do neighboring communities' emergency response plans
function cooperatively? Are there conflicts which could
increase rather than reduce risks during an emergency?
; I
Has the Committee surveyed local facilities through a
questionnaire? If so, what did it find? Has it conducted
on-site inspections of any facilities?
How openly has the Committee conducted its business?
Are its meetings open to the public and well publicized
in advance? Did it hold public meetings on its draft
plans? Has it sought to develop adequate financial
support to meet its own needs?
Has the Committee tested its own emergency response
plan through full-scale drills? Does it plan to do so
regularly? What did it learn from those test-runs?
i
Do local emergency response teams have adequate
equipment, adequately maintained, to respond to a
potential emergency?
62 Chemicals, The Press & The Public
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One effective tool for reporters will involve looking at
Section 313 Toxic Release Inventory information, for instance, in
the context of other reports filed under the Emergency Planning
and Community Right-to-Know Act, rather than in isolation. For
example, has a company which submitted TRI data submitted
additional information on the same chemical under the Section
304 emergency notification provision, or under the Section 311/312
hazardous chemical reporting provisions? Does that additional
information shed new light on the facility's TRI reports, and vice
versa? Does the Section 304 reporting show for a particular
facility a pattern of accidental releases over a period of time?
What future emerges for a facility with such a pattern, and what
are the safety implications? What future emerges for a community
overall given the collective reports of its facilities?
Turning Information Into
Knowledge ... and Using that
Knowledge Effectively
The Emergency Planning \ and
Community Right-to-Know Act
represents a bold and potentially
revolutionary approach to
environmental protection. In EPA's
words, the law "assumes that the
more citizens know about chemical hazards in their communities,
the better equipped they and their local governments will be to
make decisions and take actions that will better protect their
families and their neighbors from unacceptable risks."
Despite its promise, one is reminded of the adage that a little
knowledge can be a dangerous thing. The law will increase the
amount of information generally available about chemicals in the
community. But information alone is not knowledge, and the
"right to know" is not per se a "right to understand." Whether that
increased information translates into increased knowledge and
understanding depends on how it's used. Converting volumes of
complex chemical information into practical and useful knowledge
will require hard work on the part of the companies reporting the
information, the agencies receiving it, the public, and the news
media.
Chapter 4: Unlimited Possibilities
63
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The journalist's role in this evolving new process can be as
extensive as individual reporters and news outlets choose to make
it. Reporters have a new and potentially potent weapon in their
journalistic arsenal. As a result, the opportunity has never been
greater for more in-depth coverage of chemicals in the community.
64 Chemicals, The Press & The Public
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Chapter 5
Reporting on a Chemical Emergency
Just as environmental problems do not respect state borders
or political jurisdictions, neither do they respect a reporter's
convenience or deadlines. It's just a matter of time before a
newspaper or radio or TV station must respond to a chemical
emergency while its most-seasoned environmental reporter is on
vacation, or on assignment.
For those occasions - and even for the environmental
specialist responding to a sudden chemical emergency - here are
a few things reporters should consider as they rush to cover a
breaking chemical story:
Reporter Beware!
Your OWN Health
May be at Risk!
A critical point to keep in mind is that the very aspect of
the event that makes it newsworthy -- such as the sudden and
uncontrolled release of hazardous chemicals -- may make it. a risk
for reporters covering the story. You do yourself and your readers
no favor if you become involved in the story and suffer health
effects which either diminish your ability to cover the story, or
delay the clean-up efforts under way.
When it comes to covering an ongoing transportation
emergency, plant explosion or leak, what's good for the health of
your audience is good also for you: Stay beyond official "hot zones"
designated by emergency response personnel. Transgressing those
borders can be dangerous not only to the reporter, but also to
official response personnel whose full attention during such an
emergency must be focussed on the cleanup.
65
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Questions to Ask Before Heading Out
Is there an LEPC in the community? Is there an emergency
plan? Before reaching the site of the incident, confirm that a
Local Emergency Planning Committee (LEPC) has been formed
and has developed emergency response plans. (Ideally, the
reporter will have asked these kinds of questions well in advance
of an accident.) Try to review the emergency response plan and,
if possible, bring it along to the site of the incident.
Had risks at the facility been identified? If a particular facility
is involved in the incident, had the LEPC identified that plant as
a potential hazard? Had the plant notified the LEPC of its use
and/or storage of hazardous substances? Has a vulnerability zone
around the facility been identified? Was the LEPC aware of the
presence of the affected chemicals at the facility? If not, why not?
Who are the experts to contact? By reviewing the emergency
response plan and/or the Section 313 Toxic Release Inventory
Form Rs or database before arriving at the incident, you can
identify specific individuals responsible for dealing with the
chemical emergency. That information also will give you phone
numbers of the experts to contact.
Questions to Ask at the Site
At the site, initial questions to consider fall into several
categories:
The Particular Chemical Involved
What is the chemical involved in the incident?
Is it a gas? A liquid? A solid? What are the public health
implications?
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Chemicals, The Press & The Public
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What quantity was released? Was the release "accidental" or
"routine"?
By what routes are humans exposed to the chemical? Do
they breathe it in? Do they eat it? Is it absorbed through the
skin? How do those routes of exposure affect potential health
effects?
What are the potential health effects? Are those effects
"acute" or "chronic"? That is, are they manifested in the short
term, or only after long latency periods? Are particular
population groups especially susceptible?
Meteorological Factors
What are the current temperature, humidity, arid wind
conditions? Are those considered favorable or unfavorable as they
affect spread of the chemical?
What is the short-term forecast for changes in the weather,
and how will that affect the chemical?
Physical Surroundings
What is the nature of the area in which the chemical incident
occurred? Is the terrain flat, or hilly? How might that affect the
seriousness of the incident?
Are there nearby population centers that might be at
particular risk, such as schools, hospitals, or shopping centers?
Are nearby residents to be evacuated, or is a "protection-in-
place" strategy preferred? What are the criteria for deciding?
Health Risks
In addition to the questions raised above, you should question
whether health risks are correlated to duration of exposure?
Route of exposure? Concentrations? In addition, just how are
humans "exposed" in the first place?
Does the chemical in question interact synergistically with
other chemicals or factors in the environment? For instance, are
the effects of a particular chemical incident worsened or lessened
Chapter 5: Chemical Emergencies 67
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by the presence of other chemicals in the environment? The point
here is that the accidental release of Chemical X may be relatively
harmless, unless that release coincided with a spill of Chemical Y,
with which it was being blended. In that case, the combined effect
-- or "synergism" - may be especially dangerous.
When the Siren Sounds
On the following pages is a checklist for reporters with
guidelines to follow, questions to ask, and sources to contact when
you are suddenly assigned to cover a chemical emergency. Take
a few minutes to "personalize" the handbook with the names and
phone numbers of key officials. Then when the editor calls, you
will have a quick reference on hand to help you put your story
together on deadline.
68 Chemicals, The Press & The Public
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Is Your Community Prepared?
(Questions to Ask BEFORE an Emergency Occurs)
1. Has an LEPC been formed in your area?
2. Are there extremely hazardous materials in your community?
What facilities report them?
3. Have there been chemical releases or hazardous materials
incidents in your area?
4. Has an emergency response plan been developed by your LEPC?
Has the LEPC coordinated its efforts with facilities in developing
the plan?
5. Have risks posed by the chemicals and facilities been analyzed?
What are the vulnerable zones surrounding each facility?
6. What facilities have reported to the LEPC and fire department
under Title III Section 302, 304, 311, and/or 312?
7. What facilities have reported to the state and EPA under Section
313?
8. Has the LEPC tried out its emergency response plan?
9. Did the emergency response plan identify particular resource
and training needs in the community?
10. Is the emergency response plan sufficiently detailed to anticipate
an adequate response to an incident?
11. Have any patterns developed concerning risk at a particular
facility?
12. Who are the key information sources in your communitiy?
Chapter 5: Chemical Emergencies 69
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LEPC Chair
Name:_
Phone:
LEPC Member
Name:
Phone:
LEPC Member
Name:
Phone:
LEPC Member
Name:
Phone:
LEPC Member
Name:
Phone:
LEPC Member
Name:
Phone:
LEPC Member
Name:
Phone:
LEPC Member
Name:
Phone:
Chief, HAZMAT Team
Name:
Phone:
Chief, Fire Department
Name:
Phone:
Director, Emergency Management Office
Name:
Phone:
Facility Representative
Name:
Company:_
Phone:
70 Chemicals, The Press & The Public
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Name:
Company:
Phone:
Name:
Company:
Phone:
Name:
Company:
Phone:
Chemical Specialist
Name:
Phone:
Local University Chemists and Toxicologists
Name:
Phone:
Name:_
Phone:
Name:_
Phone:
Chemical Manufacturers Association's Chemical Referral Center
Name:
Phone: 202/887-1100
Chair, State Emergency Response Commission (See Chapter 9)
Name:
Phone:
Chapter 5: Chemical Emergencies 71
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! .
Reporting A Hazardous Materials Incident:
A Reporter's Checklist
i . |
At the Scene:
1. DO NOT GO INTO THE "HOT ZONES". They present
health risks to reporters no less than to other people. You don't
have to endanger your health to cover the story.
2. Upon reaching the scene, find the people - the designated
emergency response officials - responsible for dealing with the
incident and with news media while emergency response actions
are underway. Be aware that electronic equipment, such as
cameras and recorders, can be damaged by hazardous materials
and can cause sparks that could worsen the situation. Avoid
impeding response or clean-up actions.
i
3. Find out what chemical is involved, and what potential hazards
it poses. Does the chemical react synergistically with other
chemicals (if so, which ones?) in ways that would increase or
decrease potential health risks?
How much was released? Does the quantity pose
particular concerns?
When did the release occur?
What was the physical state of the chemical? What
are the implications for public health?
What were the meteorological conditions? How do
they affect potential risks to human health?
What is the current weather forecast, and are forecast
conditions likely to reduce or increase potential health
implications?
What are the chemical's effects on human health and
the environment?
Are they short-term or long-term effects?
Are they cumulative or transitory?
Is the chemical reactive (unstable)?
72 Chemicals, The Press & The Public
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_4. What special populations might be affected by the incident?
(Schools, hospitals, retirement homes, prisons)
_5. What special facilities might be affected by the incident?
(Water supply, sewer, power, police stations, other chemical
facilities)
_6. How did the incident happen? (Result of negligence, poor
safety procedures, poor storage conditions, inadequate
maintenance, etc.)
_7. What is the safety record of the facility involved? What about
the record of its parent company, if any?
_8. Is an evacuation necessary? If so, why? Does the evacuation
extend beyond the plant and its own employees to involve the
community? What is the basis for determining which areas
should be evacuated and which should not be?
General:
Back at the Office:
Follow-up Questions
1. How many people were injured? What is the nature of the
injuries?
2. How many people were evacuated?
3. How was the incident cleaned up?
4. How was the surrounding environment affected?
5. Have similar incidents occurred in the area?
Facility Information:
1. What kinds of safeguards were in place on-site?
2. Was the facility covered under the local emergency response
plan?
Chapter 5: Chemical Emergencies 73
-------
I
3. Did the facility have to report under any sections of Title III?
Did it report?
Section 302 (presence of extremely hazardous substances)
Section 304 (accidental releases and emergency notificaiton)
Section 311 (material safety data sheets on hazardous chemicals)
Section 312 (emergency and hazardous chemical inventory form)
Section 313 (toxic chemical release form)
]
What overall picture of the facility emerges from this cumulative
information?
4, What prevention approaches resulted from past events?
5. Does the facility have a history of accidents? Check the morgue
for details of the previous accidents.
6. Does the facility provide training to its employees?
i
7. what routes are used by the facility to ship and transfer its
hazardous materials?
, |
8. What were the storage conditions for the chemical in question?
What about other chemicals at the facility?
i l
9. Was the facility aware of the risk it posed?
i !
'
_10. What type of facility is it?
11. Did the facility have its own hazardous materials response plan?
12. Did the facility have equipment on-site to detect a release?
I
13. Did the facility have equipment on-site to deal with the incident?
14. Does the facility know of possible substitutes for the chemical
~ released? What are the environmental and health issues posed
by those substitutes? What are the economic issues involved in
using substitutes?
15. Was emergency medical care available on-site?
16. Are technical experts present at the facility?
Questions for the LEPC:
_1. Had the LEPC identified the facility as a possible hazard because
. it stored extremely hazardous chemicals, or for other reasons?
i
74 Chemicals, The Press & The Public
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2. Had the LEPC determined the potential vulnerable zone around
the facility due to the chemicals stored on-site?
3. Did the LEPC identify conditions that could lead to an
emergency release?
4. Did the LEPC have a completed emergency response plan?
5. Did the plan work during the emergency?
6. Were the LEPC and emergency response personnel aware of
the existence of hazardous materials at the facility? If not, why?
Questions for Emergency Response Officials:
1. How did response personnel respond to the incident?
2. Were they trained in HAZMAT (hazardous materials) response
procedures? If not, why?
3. What emergency response teams responded to the incident and
why?
4. Were teams from more than one department called in?
Chapter 5: Chemical Emergencies 75
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-------
Chapter 6
Computers in Emergency Management
Reporters shouldn't be surprised to find that their trusty
laptops are not the only computers on-site at a chemical
emergency. Increasingly, they are likely to find fire departments
and hazardous materials teams using a Macintosh-based "CAMEO
IF* software system in their work.
The CAMEO II program (nationally distributed by the
National Safety Council, the not-for-profit, nongovernmental
parent organization of the publisher of this media guide) was
developed by the U.S. Department of Commerce's National
Oceanic and Atmospheric Administration, with support from the
U.S. Environmental Protection Agency. It is designed to help in:
quickly accessing data on chemical compounds;
identifying specific areas that might be affected by toxic
releases;
plotting the course of toxic release plumes, based on a
number of variables, such as quantity of spill and
weather; and
projecting possible accident events and optimum
responses to those events.
*CAMEO, a trademark name of the U.S. Government, is the acronym for
Computer-Aided Management of Emergency Operations.
77
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Once an area's maps are entered into the computer, the
program can correlate them with chemical storage locations and
population information. Detailed area maps can be displayed on-
screen or printed out. Susceptible population areas - schools,
hospitals -- can be highlighted, and phone numbers and contact
names displayed. Want to zoom in on a particular three-square-
block area of town and overlay a projected toxic plume to see
which areas could be affected by a release?* CAMEO II will do
it. (See example on the following page.) That information allows
fire departments and companies making or using chemicals not
only to work with Local Emergency Planning Committees to plan
their responses to chemical accidents, but also to handle
emergencies when they do occur.
The following section appeared in the May/June issue of EPA
Journal. Written by Jean Snider and Tony Jover, the case study
describes how CAMEO II can be used.**
; i
On the Scene With CAMEO
How does this emergency information system work? Just
suppose you are fictional fire lieutenant Joe Sadder when the
firehouse bells sound at 2:35 A.M.... Sackler jumps from his bunk
and wipes the sleep from his eyes. It was only a short catnap, but
it sure has helped; in the last 10 hours, he and his crew have been
through several fire runs and one hazardous material incident.
Now the bells and the public address system are signifying another
HAZMAT problem: a strange sulfur-like smell being reported by
people living near the Freeland Chemical Company.
i
*The U.S. Bureau of the Census and the U.S. Geological Survey provide
digital maps of most U.S. cities on CD-ROM (compact disk - read only
memory). Those maps can be simply loaded into the CAMEO program to
enable users to bring specific cities and areas on-screen.
**Snider is with the Hazardous Materials Response Branch of the National
Oceanic and Atmospheric Administration. Jover is Director of the
Information Management and Program Support Staff in EPA's Chemical
Emergency Preparedness and Prevention Office.
78 Chemicals, The Press & The Public
-------
The above section of a street map (a sample from the CAMEO software)
is a hexane plot for a large "puddle" spill that is several thousand square
feet in the Seattle area. The contoured dashes next to the three-loop
imaginary plume (or plume "footprint") represent the likely shift of the
plume under existing atmospheric conditions. The drum symbolizes a
chemical facility, which could be in the path of the plume if wind shifts to
the north.
Chapter 6: Computers in Emergency Management
79
-------
As the fire officer pulls his boots on, he thinks about the way
HAZMAT runs used to be - and how they have changed over the
past two years. Formerly, firemen responding to a hazardous
materials incident or a fire involving chemicals had no idea what
they might encounter when they arrived on-site. This was
especially true when the incident was at one of the smaller,
marginally profitable companies. On "pre-fire" visits to such
facilities to determine what chemicals might be stored on the site
and the location of fire hydrants, fire department inspectors were
often rebuffed by owners who said, in effect, "Trust us, we are safe
operators and will take care of any spills on our property. The
people who live around here won't be affected."
! I
Although most plant operators are responsible and
cooperative, one bad incident involving a "fly-by-night" operator
was enough to convince the lieutenant that his department must
have all available information in its possession and readily
accessible when the alarm sounds. In the past, it was simply too
uncertain and nerve-wracking to depend, on others to provide it
after the firefighters reached the scene - assuming, of course, that
someone was there on-site with the necessary information.
But now things are different. Lieutenant Sackler has his Mac
(nickname for the Macintosh computer)! He jumps into the back
of the HAZMAT van as the driver pulls out of the firehouse.
While the driver switches on the siren and flashing lights, Sackler
turns on his computer and calls up his CAMEO system. The
sooner he knows what problems they face, the better off they'll be.
As the van races down the street and the sirens wail outside,
Sackler hears the familiar sound of the computer warming up and
sees the smiling face on the Macintosh before CAMEO's opening
screen comes up. This is the "Navigator," which allows him to
select the data he needs by a simple click of the mouse, pointing
to the picture representing the database he wants. First, he reads
what chemicals Freeland Chemical has stored on its premises.
Next, he learns the name of the company contact person and how
to reach him if he is not already at the site, in order to verify the
chemical identification.
Fortunately, his captain previously insisted on stepping up
efforts to survey the chemical plants in the community, especially
since new federal laws provide additional leverage to collect critical
information from chemical facilities on v/hat hazardous chemicals
80 Chemicals, The Press & The Public
-------
were stared in the community, and to plan for possible accidents.
As a result, the information is in his CAMEO program, organized
in a logical retrieval form, including recommendations for response
actions. The new law - popularly known as SARA Title III ~ and
the computer program have certainly associated with past
HAZMAT runs.
From the CAMEO screen, Sackler learns that Freeland has
a number of nasty substances that could produce a sulfur smell.
He checks out methyl disulfide and sulfur tetrafluoride to see
which would be the more likely culprit and what types of problems
these particular chemicals might cause firemen trying to control
the situation.
The van sways as the driver races over potholes and around
corners. The lieutenant wishes his boots were bolted down, like
the computer. CAMEO has more to tell him: only sulfur
tetrafluoride is a gas and likely to give off a sulfur smell. And,
says CAMEO, to control a spill the firemen are going to have to
suit up in full gear with protective breathing apparatus AND NOT
USE WATER!
Next question: where is the stuff stored (and what would be
a good staging area)? Click, and the screen shows the facility site
plan. More questions: Who would be affected by the fumes?
The worst-case scenario run several months earlier had shown
several schools in the area, although they would not be in session
at this hour, and the hospitals are out of range of the airborne
plume, given the amount of the chemical stored by Freeland. But
a rest home is close by. What kind of ventilation does it have?
Can it be shut off for a few hours? Click: the answer.
Now, as the van nears the scene, Sackler and his crew are
ready for what they have to do. What a difference from the old
days, when they spent precious time on arrival to get the same
information they are ready with as the van rocks to a stop.
Chapter 6: Computers in Emergency Management 81
-------
CAMEO Software and Hardware
Needs and Availability
CAMEO H operates on Apple Macintosh Plus, SE, or Mac
II computers having at least one megabyte of memory, a hard
disk with 12 megabytes of storage, and Apple Computer
Company's HyperCard software. In designing the software
initially, CAMEO's designers found it to be cost-effective to
develop and produce the program for that particular hardware
configuration. They believe also that Macintosh systems are (
popular systems in fire departments because they do not require
extensive computer training to operate and run.
While reporters may not have immediate access to the
necessary hardware and software, they may find it useful to work
with the CAMEO II software through local fire departments,.
and/or Local Emergency Planning Committees. In some cases,
LEPCs have been provided the hardware and software by local
companies to help them in their emergency management >
activities. Some 2,000 copies of CAMEO software have Iseen
distributed, with users representing state, county, and municipal
governments; federal agencies; Coast Guard offices; universities;
and individual corporations and consultants.
. j, i ' v £
The 15-SOOK-diskette program arad user's manual is
available for $115 from the non-profit National Safety Council.
The software, user's manual, and three and one-half hours of
technical^ training cost $329. A complete entry-level hardware
and software system for operating NOAA ranges from $6,000 to
$10,000, a cost comparable to many other pieces of emergency
response equipment. Additional information on CAMEO II is
available from the NOAA CAMEO database manager in Seattle
at (206) 526-6317; or from the National Safety Council in
Chicago at (312)527-4800.
' v
82
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Chapter 7
Accessing and Using
the Electronic Database
on Toxic Release Inventory Chemicals
"Because that's where they keep the money."
Jesse James' response when asked why he robs banks may be
apocryphal. But the point it makes is worthwhile. Eliot Jaspin
- a former Providence Journal reporter whose extensive use of
computers in investigative journalism has earned him wide
recognition -- uses the Jesse James anecdote to respond to
reporters who ask "Why use databases in reporting?"
"Because that's where they keep the information," Jaspin says.
He says information critical to journalists ~ and essential for
informed and effective citizen involvement in policy-making --
increasingly will be maintained in electronic databases. If reporters
want all the information relied on by the government and needed
by the public, they will have to get it from electronic databases.
Plain and simple.
Not all reporters are computer hacks, of course, though more
are likely to be in the future. But the conventional "Front Page"
reporter making do with hunt-and-peck
typewriting is an anachronism. With
modern word processing becoming
routine in many news rooms, frequent
on-line data searches may not be far
behind.
In reporting on chemicals in the community under the
Emergency Planning and Community Right-to-Know Act, one to6l
available to reporters since June 1989 is the Toxic Release
83
-------
Inventory electronic database of manufacturing companies' Section
313 reports. Reporters experienced in on-line database searches
should find familiar ground in exploring the 313 database. Those
inexperienced with databases likely will find plenty of frustration
along their learning curve to discovering the valuable information
the TRI database contains.
No one said it was going to be easy. But first-time users may
take comfort in a National Library of Medicine suggestion that
they "not be alarmed by the seeming complexity" of the system at
first. "It's easier than it sounds."
Where to Start?
Based on data collected by the Environmental Protection
Agency under Section 313 of the Emergency Planning and
Community Right-to-Know Act, the Toxic Release Inventory is
publicly accessible through the National Library of Medicine's
Toxicology Data Network (TOXNET) system.
To access the TRI database, users must have a computer, a
modem connecting it to the telephone system, and communications
software. They must register with the National Library of
Medicine as on-line service user. Call (800) 638-8480 or (301)
496-6531, the TRI Representative in the National Library of
Medicine's (NLM) Specialized Information Services, in Bethesda,
Md.
; , . j
There is no fee for becoming a subscriber to NLM's on-line
services, but reporters should expect about a two- to three-week
turnaround time before they receive a password necessary to access
the electronic database. At the time they receive their application
forms, they also will receive training information for using the on-
line services. (In addition, users can leave on-line "comment"
messages for NLM staff while on the database, and they will get
their questions answered on-line or by telephone or mail.)
I , . ! '
! . ' .
Once assigned a password, NLM on-line service users can
access TRI on the TOXNET system either by dialing-in directly or
by going through networks such as Telenet, Tymnet, CompuServe,
or InfoNET. [In addition, users registered to access the TRI
database automatically.have access to other TOXNET databases
such as the Hazardous Substances Data Bank (HSDB), the
Registry of Toxic Effects of Chemical SJubstances (RTECS), the
84 Chemicals, The Press & The Public
-------
Chemicaf Carcmogenesis Research Information System (CCRIS),
the Environmental Teratology Information Center Backfile
(ETICBACK), the Environmental Mutagen Information (Center
(EMICBACK), and the Director of Biotechnology Information
Resources (DBIR).]
Logged-on to the system, users will be able to review a variety
of EXPLAIN TEXT and HELP messages. Each user will receive
a TOXNET Quick Reference Guide and a separate TRI User's
Guide, which includes information specifically on the TRI
database. Articles written by NLM staff will describe TRI search
strategies and share the experiences of other TRI users. In
addition, reporters can call NLM's Specialized Information Services
at the numbers above and request a copy of a September 1989, 86-
page "TRI Reference Guide," providing information on using the
database. Along with refinements made in response to users'
actual experiences, those tools should help users learn the system.
In the end, however, the best approach to learning to use the TRI
database is likely to be to just do it; No amount of reading-up
will substitute for learning it through first-hand use.
Searching the Database
The database is designed to be used by individuals with
various levels of familiarity in using databases. Searches can be
performed directly, using special commands, or by selecting special
menus. Data can be retrieved and displayed on-screen and printed
on-line by your printer. In addition, NLM offers off-line prints by
mail for 25 cents per page.
With the direct search, users will see the following cue:
[TRI] SS 1/cf
USER:
That cue tells them the system is ready to be searched. They will
enter search statement (SS) -- either single terms or combined
terms joined by "or," "and," or "and not" ~ and press carriage
return. TRI then will try to match the terms specified with terms
in the chemical records in the file, retrieving records or postings
such as: SS (1) PSTG (67). That means there are 67 records, or
postings, identified for search 1.
Chapter 7: Accessing & Using the TRI Database 85
-------
What to Expect in the Database
, . i , ,i
TRI users will find the data arranged in five broad subject
categories:
- Facility Identification
Substance Identification
- Environmental Release of Chemical
~ Waste Treatment
-- Off-Site Waste Transfer
Reflecting manufacturing industries' reports to EPA on
estimated releases of more than 300 toxic chemicals into air, water,
and land, the TRI data include:
1
names, addresses, and public contacts for plants
manufacturing, processing, or using the. reported
chemicals;
the maximum amount stored on-site for each of the
covered chemicals;
,1 ' '
the estimated quantity emitted into the air, both from
stacks and through "fugitive" emissions;
i i
the estimated quantity discharged into surface water
bodies or injected underground;
j
I
the estimated quantity released to land;
! ' I "
information on waste treatment methods and the
efficiency of those methods; and
data on chemicals transferred off-site to publicly owned
treatment works or other facilities for treatment and/or
disposal.
For those experienced in using the National Library of
Medicine's TOXNET system, the TRI database will look pretty
familiar. The data is structured in a four-level hierarchy, from the
most specific to the most general: Subfield, Data Field, Header,
and Category.
86 Chemicals, The Press & The Public
-------
In this scheme of things, the broadest and most general term
would be "CATEGORY," and within each of six categories there
would be "HEADERS" grouping conceptually related information.
That grouped information would be listed under individual "DATA
FIELDS," under which would be listed the basic data-containing
unit... the "SUBFIELD."
Seen as an outline, it would look something like this:
CATEGORY (e.g., Environmental Release of Chemical, "EREL")
HEADER (e.g., Air Emissions, "AIR")
DATA FIELD (e.g., Point Air Emission Estimates,
"AIRPE")
SUBFIELD (e.g., Basis of Estimate, "AIRPB")
The approach is intended to make it easier to group related
information and to simplify information searches and printing.
The use of mnemonics also facilitates a search.
Consider the following example:
How much acrvlonitrile was released to the air or water in
1987 by XYZ Manufacturing Company in Dubuque. Iowa?
[TRI] SS 1/cf?
USER:
(name) acrylonitrile
SEARCH IN PROGRESS
SS (1) PSTG (34)
[TRI] SS 2/cf?
USER:
(fnm) XYZ
SEARCH IN PROGRESS
SS (2) PSTG (9)
[TRI] SS 3/cf?
USER:
(fcty) Dubuque and Iowa (fet) [search for city/state]
SEARCH IN PROGRESS
SS (3) PSTG (1)
[search for chemical name]
[search for facility name]
[TRI] SS 4/cf?
1 and 2 and 3
SEARCH IN PROGRESS
SS (4) PSTG (1)
[combine search parameters]
[one record retrieved]
Chapter 7: Accessing & Using the TRI Database
87
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The "CATEGORY" groups together related headers and data
fields, but itself contains no data per se. The six categories,
identified in the TRI unit record by a double asterisk (**), are
Administrative Information, Facility Identification (FACID),
Substance IDentification (ID), Environmental Release of Chemical
(EREL), Waste Treatment (WASTE), and Off-Site Waste Transfer
(OFFS).
The second most general hierarchy, "HEADER," also does
not contain data, but rather groups-related fields of data. Headers
are identified with a single asterisk (*). For instance, using the
header "Air Emissions," one would find Individual data fields for
"non-point air emissions estimates" and for "point air emissions
estimates," along with a third data field totaling those two
estimates.
For each data field, header, and category, a two- to five-letter
mnemonic can be used for qualifying search and print commands.
Type in the word "EXPLAIN" before the mnemonic, to display the
full name and general description of the subject contents. For
instance, typing "EXPLAIN AIRPE" will yield the following:
AIRPE Point Air Emissions Estimates
Contains two data subfields that provide the estimate of the
total annual releases of the chemical to air from point sources
and the basis for the estimates. Point sources are stacks,
vents, ducts, pipes, storage tanks, or other confined air
streams
Searching With Mnemonics
i1
i
Using terms qualified with Category, Header, or Field
mnemonics, users can search for information in a specific part of
the TRI file records. Enclose the mnemonic in parentheses so the
system will search for occurrence of the term within any field in
that category.
'i ' i . ' *' 1
For instance, Category searching for XYZ (fetid) would yield
all occurrences of the term "XYZ" in the Facility Identification
Category (FACID). Header searching for XYZ (offs) would
search for all occurrences of "XYZ" in the Off-Site Waste Transfer
(OFFS) Category.
88 Chemicals, The Press & The Public
-------
If
11
Searching Without Mnemonics
While searching with mnemonics is more efficient, TRI will
still display information, for example, if the term "ABC" were
entered without mnemonics for the Category, Header, or Data
Field. Clearly, however, you'll get more information, less well-
focused, than you may be looking for.
Using the 'Neighbor Command'
Abbreviated NBR, the Neighbor command can be used to
find terms closely related to the particular search term and to see
categories or fields where the search term appears. For Instance,
use "NBR XXX" to specify a search term containing a combination
of letters, numbers, spaces, and special characters. As an example
of neighboring with a qualifying mnemonic, consider this example:
nbr JACKSON (fac)
#
1
2
3
4
5
POSTINGS
82
4
5
2
1
Finds Jackson in Facility Heading
field.
TERM
Jackson
Jackson/Smith Corp.
Jackson Jones Operation
Jackson Electronics Div.
Jackson Flight Mechanics Div.
Chapter 7: Accessing & Using the TRI Database
89
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Go Ahead ...
Give It a Tiy
The world wasn't built in a day, and neither was the TRI
database. Users shouldn't expect it to necessarily be "perfect" or
"user friendly" on their first try. If so, they'll likely be
disappointed.
i i
Given substantial early interest in the public in using the
database, however, and given an expressed willingness on the part
of the U.S. Environmental Protection Agency and the National
Library of Medicine to constantly improve the database in
response to user's experiences, reporters should take full advantage
of the resources now available to them in reporting on chemicals
in the community. They should do so with a full understanding of
both the enormous potential and the significant limitations of the
information reported, as detailed elsewhere in this guide.
i ' I
Test drive the TRI, and see what it contributes to your
reporting on'-- and your audience's understanding of -- chemicals
in your circulation or broadcast area.
See Chapter 4
on page 55:
Unlimited Possibilities
for Journalists
What to look for in 'right to know' information
A gold mine and a minefield -- of good stories
Turning information into knowledge ... and
using that knowledge effectively
90
Chemicals, The Press & The Public
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Chapter 8
Understanding and Working With
the Chemical Information
In a perfect world, all the chemical and health effects
information now available under the Emergency Planning and
Community Right-to-Know Act would be accurate. And
understandable. Potential health effects would be readily
discernible. Quantities and concentrations, timing and duration
of emissions would be reported with precision. How chemicals
interact with each other in the environment would be understood.
Humans would be foolproof in entering that information into
readily accessible and digestible formats. Ice cream wouldn't melt,
and salad dressings wouldn't spot neckties.
The real world of chemicals in the community is, alas, far
from perfect. Far indeed.
The Environmental Protection Agency is candid in
acknowledging, for instance, particularly in the early years of
implementation of the Section 313 Toxic Release Inventory
database, that the information reported is "expected to be of
limited quality and type for assessing risk because of the lack of
information on rates of release and uncertainties associated with
release estimates." The agency says it hopes that 313 data quality
will improve over time as industries become more familiar with the
reporting form and the requirements. (EPA Risk Screening Guide,
Vol. I -- The Process, July 1989, p.6.)
Opportunities and Pitfalls Abound
Even assuming that the 313 information submitted by industry
is outstanding in overall quality, however, there are other caveats
reporters need to appreciate if they are to take advantage of the
91
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full potential of the Emergency Planning and Community Right-
to-Know Act for enhancing environmental journalism and, through
that, improving public understanding of chemicals in the
community.
Estimates, Not Monitored Releases. First, reporters should
keep in mind that annual release data submitted to state
commissions and to EPA in the Form R reports by law represent
not monitored releases, but rather industry estimates of those
releases.
i . < , j
Chuck Elkins, director of EPA's Office of Toxic Substances,
notes that, "Except in a handful of states that already have
community right-to-know laws [such as West Virginia, New Jersey,
and California], businesses have little or no experience in reporting
this kind of data. Consequently, some reports - especially the
reports of annual 'routine' emissions of toxic chemicals required by
Section 313 of Title III -- are likely to be very rough estimates of
actual releases. The value of the emissions data in the first years
of the program probably will be limited to helping EPA and other
authorities identify potential 'hot spots9 « areas with apparently
high levels of toxic emissions for careful monitoring and
evaluation to determine if an environmental hazard may be present
that requires immediate attention."
Timing of Releases Need Not Be Reported. Moreover,
companies reporting their emissions need not indicate the timing
of those emissions over the course of the year. If all of a
particular facility's air emissions occurred during a six-hour period
during the peak of an inversion (an unlikely event), you'll never
know it just by reviewing the Form Rs. "There is a considerable
difference, from a public health standpoint, if the emissions were
in several major bursts or a slow but steady stream," Washington
Post health writer Cristine Russell has written. But there's no
requirement that reporting industries provide a seasonal, monthly,
or weekly breakdown of how their emissions occurred ... just the
total over the calendar year.
A Major Gap: Data on Human Exposure. One of the most
critical elements missing from the newly available Toxic Release
Inventor}' information involves the essential issue of human
exposures to those chemicals that are emitted or released into the
environment. Release does not equal exposure. Exposure occurs
only when a chemical is transported from the site of the release to
j ! ' j
92 Chemicals, The Press and The Public
-------
vftiere people are. Estimates of exposures can be made from
estimates of releases if extensive site- and chemical-specific data is
available, for instance height of an air release, wind speed and
direction, distance to populations, and chemical persistence. Those
exposure estimates, obtained through computer models, are only
as good as the data on release, meteorology, and chemical fate.
"Real" or "Paper" Reductions. Reporters also need to pay
attention to how the annual emission and release estimates were
calculated. Calculation methods can vary from year-to-year and
from facility-to-facility. Some facilities will report emission
reductions not as a result of actual reductions, but rather because
they used a different method of calculating emissions. Beware of
this possibility.
Questions reporters should consider asking: "Are your
reported emission reductions the result of actual cutbacks, or a
reflection of your using a different method of calculating
emissions? Are your reports this year based on the same
calculation method you used in past years? If not, how did the
calculation protocol affect the results?"
The Listing/Delisting Issue. In making year-to-year
comparisons, reporters also need to pay attention to chemicals that
are removed from the reporting list. For example, calendar 1987
reports include data on sodium sulfate releases and transfers.
That chemical alone accounted for 54 percent of total releases and
transfers for all TRI chemicals! Interestingly, just one facility in
California reported releasing 5.2 billion pounds of sodium sulfate
- 23 percent of total U.S. Toxic Release Inventory releases and
transfers.
EPA in May 1989 granted a petition to remove sodium
sulfate from the list of chemicals subject to TRI reporting, on
grounds that it is not of significant concern as a toxic. With
sodium sulfate included in the database, California led the list of
states emitting TRI chemicals into the environment in 1987.
Without it, California would drop to ninth position. With sodium
sulfate, surface water was easily the preferred disposal medium
based on 1987 reports; without sodium sulfate, surface water would
be last among preferred disposal options ~ behind air; off-site
treatment and disposal; land; underground injection; and public
sewage treatment systems.
Chapter 8: Working With the Information 93
-------
Also important: Total 1987 Toxic Release Inventory release
and transfer volumes would be cut by more than half with the
delisting of sodium sulfate -- from the 22.5 billion pounds reported
to about 10 billion pounds. Furthermore, sodium sulfate is
unlikely to be the only high-volume chemical to be removed from
reporting requirements, while others will be added. Reporters
should be alert to such changes. A claim of a major drop in
emissions could be riding the coattails of a delisting.
With the government expected to occasionally add to and
delete from (list and delist) chemicals subject to the law's
reporting requirements, reporters will have to be aware of an
"apples and oranges" problem in making year-to-year comparisons.
They'll do well to check with EPA to keep current on new listings
and delistings.
i
A Rose is A Rose ... But is a Chemical a Chemical?
Chemicals have aliases. But they also have fingerprints.
Reporters need to know their chemicals. If they use a
popular name or a trade name, for instance, they may be missing
all the other names under which a chemical is reported. The
problem of double-counting, or of under-counting, can be avoided
if reporters use the one unique handle: the Chemical Abstract
Service, or CAS, number.
i .
Limited Scope of Coverage. Finally, be aware that only a
small fraction of all potentially toxic chemicals are covered by
Section 313 Toxic Release Inventory reporting requirements in the
first place. Moreover, those reporting requirements do not apply
to all the facilities using and storing the chemicals ~ just to those
with 10 or more employees in specified standard industrial
classification codes, specifically including manufacturing facilities.
Only those facilities manufacturing more than 25,000 pounds (as
of 1989 reports) or using more than 10,000 pounds annually of
an affected chemical must submit Form Rs. Accordingly, the Toxic
Release Inventory database may be representative of toxic
emissions nationally, but, in sheer volumes, it clearly will
understate the total amounts of those emissions.
94 Chemicals, The Press and The Public
-------
Toxicology For Journalists:
How Toxic IS Toxic?
Toxicology isn't routinely taught in university journalism
curricula. And it's not something that many reporters casually
pick up along the way.
But for environmental journalists reporting on frequently
controversial public health issues ... a little toxicology can go a
long way toward better reporting.
It's not enough for reporters to simply keep in mind the old
toxicology saw that "the dose makes the poison." Although true,
that point is subject to abuse from those wanting to minimize
environmental risks.
Two concepts ~ potency and exposure are particularly
important. Only with an understanding of both can health risks
be assessed.
Potency applies to the toxicity of a chemical, that is "the
ability of a chemical to do systemic damage to an organism," as
the Foundation for American Communications' (FACS) April 1989
Toxicology Study Guide for Journalists describes it. Potency
information is chemical-specific and independent of whether
humans or living organisms actually come into contact with the
chemical. To understand potency, scientists first must evaluate the
nature of adverse health or ecological effects produced by a
chemical and the concentrations at which those effects occur
(usually referred to as dose-response relationships).
Exposure, on the other hand, deals with whether and how a
human or other organism comes into contact with the chemical
-- usually by eating or drinking it, inhaling it into the lungs, or
having it penetrate through the skin. If there were no exposure,
there would be no risk, and the amount of risk can vary depending
on the nature and duration of the exposure and the concentration
of the toxic chemical in question.
In a sense, it comes down to how much of which toxic
chemical an individual is exposed to, how often, over how long a
duration and by what means of exposure. Clearly, the reporter's
traditional "Five Ws" approach comes in handy here.
Chapter 8: Working With the Information 95
-------
Michigan State University's Center for Environmental
Toxicology writes, for instance, that "a variety of events may occur"
once exposure to a toxic chemical takes place. If the chemical
does not penetrate far into the body, any effect would be local, at
the site of contact, rather than systemic or system-wide. Some
chemicals having those local effects are considered to be corrosive
rather than toxic. On the other hand, if the toxic chemical is
absorbed into the bloodstream, it can travel throughout the body
and produce toxic effects in organs most sensitive to the chemical.
"Everything in our physical world is chemical," writes retired
California State Department of Public Health lexicologist Alice
Ottoboni, Ph.D., in the FACS journalism study guide, which was
adapted from her book The Dose Makes The Poison. "All matter
is composed of chemical elements, 90 of which are stable and
hence commonly found in nature."
"! " ' !
Given that, how is the public to decide the answer to the
riddle: "How toxic is toxic?"
Michigan State University lexicologists Alice Marczewski and
Michael Kamrin, with the Center for Environmental Toxicology,
write thai "the mosi imporlani factor lhat influences is the dose,
or amount of chemical that enters the body. Every chemical is
loxic at a high enough dose. The dose of a chemical plays a major
role in determining toxicily. Generally, there is no effect at low
doses, bul as the dose is increased, a toxic response may occur.
The higher ihe dose, ihe more severe ihe toxic response that
occurs." They provide the following graphic to illustrate the dose-
response curve for alcohol (ethanol):
Death
"Labored breathing
Unconscious
Deep sleep
Sleep
'Giddy
No effect
DOSE-
Sowce: Toxicology for the Citizen, Center for Environmental Toxicology,
Michigan State University, Second Edition, June 1987, p.10.
96
Chemicals, The Press and The Public
-------
In addition to dose, a chemical's individual properties and the
susceptibility of an individual to a chemical exposure also are
critical in addressing the "How toxic is toxic?" question.
A chemical's structure influences its relative toxicity, and that
is why some chemicals are very dangerous in very, very small
amounts. How a chemical affects or does not affect a human body
is a function of its peculiar chemical structure.
As for an individual's sensitivity to a particular chemical,
factors such as age, health, nutrition, and medical history are
critical. Previous exposures to toxic chemicals can worsen the
effects of subsequent exposures to the same or different chemicals.
Chemicals are acutely toxic when they result in harm after
relatively brief one-time exposures. In these cases, the harm is
manifested within minutes or hours of exposure, and in areas other
than just the site where the chemical first entered the organism.
Acute toxicity is often measured as "LD50" in rats or mice.
That means the dose is lethal to 50 percent of the animals tested.
Expressed relative to the test animals' weights to allow for weight
differences between animals and humans, a lower LD50 means a
more acutely toxic chemical.
Chronic toxicity applies to a chemical's propensity for harming
an organism over long periods of time - 20 or 30 years in the
case of cancers -- and as a result of repeated exposures. Less is
known about chronic toxicity than about acute toxicity, as testing
is time consuming, complex, and expensive, and results are
complicated by the need to extrapolate from exceptionally high test
doses to doses representative of human exposures.
Specific toxicity effects also must be considered. Some
chemicals are carcinogenic -- they cause tumors in tissues. Others
may lead to gene and chromosomal mutations or adverse effects
on the central nervous system. Still others may cause reproductive
and developmental effects.
For journalists, applying the traditional "Five Ws" is a sound
practice in helping audiences better answer the "How toxic is
toxic?" question.
Chapter 8: Working With the Information 97
-------
Some Tips From Victor Cohn's
'News & Numbers'
! I
Washington Post Senior Writer and (Columnist Victor Conn in
1989 published News & Numbers: A Guide to Reporting Statistical
Claims and Controversies in Health and Other Fields (Iowa State
University Press, 1989). The i90-page paperback, available from
the Iowa State University Press in Ames, Iowa, is a valuable tool
for reporters covering environmental and other public health
issues.
i
In Chapter 8, "The Statistics of Environment and Risk," Conn,
the Post's former Science Editor, writes that "the media are
typically accused of overstating, needlessly alarming, emphasizing
the worst possible case, reporting half-baked and unsupported
conclusions, or falsely reassuring. We do them all sometimes.
Trying to be objective, perhaps stung by such criticism, we too
often write only 'on the one hand, on the other hand' stories - I
like to call them 'he said, she said' stories - without expending
any great effort to find the most-credible evidence, the most-
reliable statistics, the best-informed, least-prejudiced views, the
greatest probabilities."
i . i |
To Conn (who was a member of the faculty for the May 1989
journalism seminar at Stanford University that was held as part of
the preparation of this media guide), the problem arises because
environmental writers function in an arena in which:
j [
Uncertainty reigns, and data are incomplete,
inadequate, or nonexistent;
1
i
We are told different things by different people, and
distinguished scientists make opposing, even warring,
assertions, such as "The hazard is horrendous" and
"The hazard is minimal or nonexistent."
i
Much of the public doesn't worry greatly about
driving, using seat belts, drinking, or smoking, but
it often vibrates about the often lesser and less
certain dangers of nuclear power and chemicals in
our foods. Someone said, "Americans want to be
protected from nuclear accidents so they can go
hand gliding."
1
98 Chemicals, The Press and The Public
-------
Cohn, citing works of others,* points to "half a dozen basic
facts" reporters should try to understand:
the true complexity of the problem;
the limitations of science;
the limitations of analysis;
the limitations of risk assessment; and
the limitations of scientists.
Muddling one's way through this morass of uncertainty isn't
easy, Cohn told the Stanford seminar. He provided several factors
reporters can consider to help identify the "most believable results"
and claims.
Have the results or claims been successfully repeated? Cohn
writes that reporters should verify that health claims have been
successfully repeated and that different studies of different
populations at different times show "much the same results."
Have the results been successfully tested using more than one
method? Results should be reevaluated using different
mathematical techniques.
Do the claims test high for statistical significance? The
probability that the same result could have occurred by chance
alone should be small.
What is the strength of the statistical claim? "The greater the
odds of an effect, the greater the strength of an association," Cohn
writes in his book. "If the risk is 10 times as likely -- the relative
risk of lung cancer in cigarette smokers compared with non-
smokers -- the odds are pretty good that something is happening."
Are the results specific? A causes B "is a more specific
association than a sweeping statement that substance A may cause
everything from hair loss to cancer to ingrown toenails."
*Cohn cites work done by Michael Greenberg, professor of urban studies
and director, Public Policy and Education, Hazardous and Toxic Substances
Research Center, Rutgers University, and Peter Montague, director,
Hazardous Waste Research Program, Princeton University. He also cites
former Post environment reporter Cass Peterson.
Chapter 8: Working With the Information 99
-------
Can the results be explained by confounding factors or other
relationships?
'"' ' 'i "" "'l
-------
Are you concluding that there is a cause-and-effect
relationship? Or only a possibly suspicious association?
Or a mere statistical association?
Do most people in your field agree that this
relationship is right for this agent?
What is the highest safe level we can tolerate? Or
is the only safe level zero?
Might we be exposed to multiple risks or cumulative
effects? Are there individual sensitivities?
What is the relative importance of this risk
compared with others that we face in daily life?
How many species were tested?
What was the method of exposure?
Have the results been reviewed by outside
scientists?
"What we need to tell people, basically, are the answers to
these questions," Cohn writes:
Is it a risk?
If so, how great or small?
Under what circumstances?
How certain is this?
What are the alternatives?
In addressing those questions, Cohn suggests that reporters
"include the uncertainties." He says uncertainties "virtually always
exist in any analysis or solution. If all the studies are weak, say
so. If no one knows, say so."
Reporters should also "report probabilities ... rather than just
that mainstay of jazzy leads, the worst case. This is also called the
'as many as' lead. (Example: 'As many as a jillion could be
killed.') This is not to say that worst cases should not be included
- or sometimes be the lead of the story -- if there is a good
enough reason, not just a grab for a headline."
Chapter 8: Working With the Information 101
-------
Conn advocates that health and environmental reporters also
"put numbers on risks" when possible and that they "compare risks
when appropriate." He encourages reporters to address "scientific
and technological fact."
In the end, he quotes Cornell University professor Dorothy
Nelkin, author of Selling Science, as saying: "The most serious
problem" in reporting on risk is reporters' reluctance to challenge
their news sources and "those who use the authority of science to
shape the public view." Nelkin: Maintain "the spirit of
independent, critical inquiry that has guided good investigation in
other areas."
102
Chemicals, The Press and The Public
-------
Chapter 9
Information Sources for
the Emergency Planning and
Community Right-to-Know Act
Environmental Organizations
Environmental Policy Institute
218 D St., SE
Washington, D.C. 20003
Contact: Fred Millar, Director, Toxic
Chemicals, Safety, and Health Program
Tel.: 202/544-2600
National Wildlife Federation
1400 16th St., NW
Washington, D.C. 20036
Contact: Jerry Poje,
Environmental Toxicologist
Tel: 202/797-6800
Natural Resources Defense Council
1350 New York Ave., NW
Washington, D.C. 20006
Contact: Deborah Sheiman,
Resource Specialist
Tel.: 202/783-7800
OMB Watch
2001 O St., NW
Washington, D.C. 20036
103
-------
Contact: Gary Bass, Executive Director
Tel.: 202/659-1711
,| , ',! , ' .
Toxics Coordinating Project
942 Market Street, #502
San Francisco, CA 94102
Contact: Ted Smith, Executive Director,
Silicon Valley Toxics Coalition
Tel.: 415/781-2745
U.S. Public Interest Research Group
215 Pennsylvania Ave., SE
Washington, D.C. 20003
Contact: Paul Orem, Coordinator for the
Working Group on Community Right-to-Know
Tel.: 202/546-9707
Business Organizations
Chamber of Commerce of the U.S.
1615 H St., NW
Washington, D.C. 20062
Contact: Tia Armstrong or Mary Bernhard
Tel: 202/463-5533
I
Chemical Manufacturers Association
2501 M St., NW'
Washington, D.C. 20037
Contact: Jeff Van or Tom Gilroy
Tel.: 202/887-1222 or 202/887-1224
National Association of Manufacturers
1331 Pennsylvania Ave., NW
Washington, D.C. 20004
Contact: Theresa Pugh
Tel.: 202/637-3175
104 Chemicals, The Press & The Public
-------
Government Agencies
U.S. Environmental Protection Agency
401 M St., SW
Washington, D.C. 20460
Contact: Right-to-Know Information Hotline
Tel: 1-800-535-0202
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
Boston
New York
Philadelphia
Atlanta
Chicago
Outside Illinois
Dallas
Kansas City, KS
Denver
San Francisco
Seattle
State-by-State Listing
With EPA Region Having Jurisdiction
Alabama - 4
Alaska - 10
Arizona - 9
Arkansas - 6
California - 9
Colorado - 8
Connecticut - 1
Delaware - 3
Florida - 4
Georgia - 4
Hawaii - 9
Idaho - 10
Illinois - 5
Indiana - 5
Iowa - 7
Kansas - 7
Kentucky - 4
Louisiana - 6
Maine - 1
617/565-4502
212/264-2515
215/597-9904
404/347-3931
312/886-6871
800/621-8431
214/655-2270
913/236-2806
303/235-4923
415/974-0577
206/442-1200
Maryland - 3
Massachusetts - 1
Michigan - 5
Minnesota - 5
Mississippi - 4
Missouri - 7
Montana - 8
Nebraska - 7
Nevada - 9
New Hampshire - 1
New Jersey - 2
New Mexico - 6
New York - 2
North Carolina - 4
North Dakota - 8
Ohio - 5
Oklahoma - 6
Oregon - 10
Pennsylvania - 3
Chapter 9: Information Sources
105
-------
Rhode Island - 1
South Carolina - 4
South Dakota - 8
Tennessee - 4
Texas - 5
Utah - 8
Vermont - 1
Virginia - 3
Washington - 10
West Virginia - 3
Wisconsin - 5
Wyoming - 8
American Samoa - 9
District of Columbia - 3
Guam - 9
Puerto Rico -2
Virgin Islands - 2
Federal Emergency Management Agency
Regional Offices
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
Boston
New York
Philadelphia
Atlanta
Chicago
Denton, TX
Kansas City, MO
Denver
San Francisco
Bothell, WA
617/223-9565
212/238-8225
215/931-5528
404/853-4454
312/408-5524
817/898-9137
816/283-7011
303/235-4923
415/923-7187
206/487-4606
State Emergency Response Commissions
(SERCS)
ALABAMA
State Commission:
J. Danny Cooper (Co-Chair)
Alabama Emergency Response
Commission
Director, Alabama Emergency
Management Agency
520 South Court Street
Montgomery, AL 36130
205/834-1375
Contact: Dave White
106
Section 311/312 Submissions:
Leigh Pegues, Co-Chair
Alabama Emergency Response
Commission
Director, Alabama Department of
Environmental Management
1751 Congressman W.G.
Dickinson Drive
Montgomery, AL 36109
205/271-7700
Contact: L.G. Linn
(205/271-7700)
E. John Williford
(205/271-7931)
Chemicals, The Press & The Public
-------
Section 313 Submissions:
E. John Williford,
Chief of Operations
Alabama Emergency Response
Commission
Alabama Department of
Environmental Management
1751 Congressman W.G.
Dickinson Drive
Montgomery, AL 36109
205/271-7700
Contact:
L.G. Linn
(205/271-7700)
E. John Williford
(205/271-7931)
ALASKA
Linda VanHouten, Chair
Alaska State Emergency
Response Commission
P.O. Box O
Juneau, AK 99811
907/465-2630
Mailing Address:
Linda VanHouten
Alaska State Emergency Response
Commission
3220 Hospital Drive
Juneau, AK 99801
AMERICAN SAMOA
State Commission:
Maiava O. Hunkin
Program Coordinator
for the Territorial
Emergency Management
Coordination Office
American Samoan Government
Pago Pago,
American Samoa 96799
Int'l Number: 684/633-2331
Section 311/312 & 313
Submissions:
Pati Faiai, Director
American Samoa EPA
Office of the Governor
Pago Pago,
American Samoa 96799
Int'l Number: 684/633-2304
ARIZONA
Carl F. Funk, Executive Director
Arizona Emergency Response
Commission
Division of Emergency Services
5636 East McDowell Road
Phoenix, AZ 85008
602/231-6326
ARKANSAS
State Commission:
Randall Mathis, Acting Director
Arkansas Hazardous Materials
Emergency Response Cmsn.
P.O. Box 9583
8001 National Drive
Little Rock, AR 72219
501/562-7444
Contact:
Mike Bates
(501/455-6888)
Section 311/312 & 313
Submissions:
Becky Bryant
Depository of Documents
Arkansas Department of Labor
10421 West Markham
Little Rock, AR 72205
Contact:
John Ward
(501/562-7444)
Mailing Address:
Arkansas Department of Pollution
Control and Ecology
P.O. Box 9583
8001 National Drive
Little Rock, AR 72219
Attn: John Ward
Chapter 9: Information Sources
107
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CALIFORNIA
State Commission:
William Medigovich, Chair
California Emergency Planning
and Response Commission
Director, Office of Emergency
Services
2800 Meadowview Road
Sacramento, CA 95832
916/427-4287
Section 302, 304, 311/312
Submissions:
California Emergency Planning
and Response Commission
Office of Emergency Services
Hazardous Materials Division
2800 Meadowview Road
Sacramento, CA 95832
916/427-4287
Contact:
Gary Burton
Michelle LaBella
Dave Zocchetti
Section 313 Submissions:
Chuck Shulock
Office of Environmental Affairs
P.O. Box 2815
Sacramento, CA 95812
Attn: Section 313 Reports
916/324-8124
916/322-7236
Completed Form R Information
COLORADO
State Commission:
David C. Sheltpn, Chair
Colorado Emergency Planning
Commission
Colorado Department of Health
4210 East llth Avenue
Denver, CO 80220
303/273-1624
Emergency Release Notification:
303/377-6326
108
After Hours & Weekends
(Emergencies Only): 303/370-9395
Section 302, 304, 311/312 & 313
Submissions:
Colorado Emergency Planning
Commission
4210 E llth Avenue
Denver, CO 80220
Contact: Richard Bardsley
(303/273-1789)
Judy Waddill
(303/331-4858)
CONNECTICUT
Sue Vaughn, Title III Coordinator
State Emergency Response
Commission
Department of Environmental
Protection
State Office Building, Room 161
165 Capitol Avenue
Hartford, CT 06106
203/566-4856
DELAWARE
State Commission:
Patrick W. Murray, Chair
Delaware Commission on
Hazardous Materials
Department of Public Safety
Administration Center
Dover', DE 19901
Contact:
George Frick
(302/736-3169)
Section 302 Submissions:
Dominick Petrilli, Acting Director
Division of Emergency Planning
and Operations
P.O. Box 527
Delaware City, DE 19706
302/834-4531
Section 304 Submissions:
' ' ! ' I '
Chemicals, The Press & The Public
-------
PMffip Retelliek, Director
Division of Air and
Waste Management
Department of Natural Resources
and Environmental Control
Richardson and Robbins Building
89 Kings Highway
P.O. Box 1401
Dover, DE 19901
302/736-4764
Section 311/312 Submissions:
Dr. Lawrence Krone, Chief
Bureau of Health and
Social Services
802 Silver Lake Boulevard
Dover, DE 19901
302/736-4731
Section 313 Submissions:
Robert French, Chief Program
Administrator
Air Resource Section
Department of Natural Resources
and Environmental Control
P.O. Box 1401
Dover, DE 19901
302/736-4791
DISTRICT OF COLUMBIA
Joseph P. Yeldell, Chair
State Emergency Response
Commission for Title III
in the District of Columbia
Office of Emergency Preparedness
2000 14th Street, NW
Frank Reeves Center for
Municipal Affairs
Washington, DC 20009
202/727-6161
Contact: Pamela Thurber
Environmental Planning
Specialist
FLORIDA
Mr. Thomas G. Pelham, Chair
Florida Emergency Response
Commission
Secretary, Florida Department of
Community Affairs
2740 Centerview Drive
Tallahassee, FL 32399-2149
904/488-1472
In FL: 800/635-7179
Contact: Greg Dawkins
GEORGIA
State Commission:
Mr. J. Leonard Ledbetter, Chair
Georgia Emergency Response
Commission
Commissioner, Georgia Depart-
ment of Natural Resources
205 Butler Street, SE
Floyd Towers East, llth floor
Atlanta, GA 30334
404/656-4713
Section 302, 304, 311/312 & 313
Submissions:
Jimmy Kirkland
Georgia Emergency Response
Commission
205 Butler Street, SE
Floyd Tower East
Atlanta, GA 30334
404/656-6905
Emergency Release Number:
800/241-4113
GUAM
State Commission & Section
311/312 Submissions:
Dr. George Boughton, Chair
Guam State Emergency Response
Commission
Civil Defense
Guam Emergency Services Office
Government of Guam
P.O. Box 2877
Aguana, Guam 96910
671/734-3410
Chapter 9: Information Sources
109
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Section 313 Submissions:
Roland Solidio
Guam EPA
P.O. Box 2999
Aguana, Guam 96910
671/646-8863
HAWAII
i
State Commission and Section
311/312 Submissions:
Bruce S. Anderson, Ph.D.,
Vice-Chair
Hawaii State Emergency Response
Commission
Hawaii Department of Health
P.O. Box 3378
Honolulu, HI 96801
808/548-2076
808/548-5832
Contact: Samir Araman
(808/548-5832)
Mark Ingoglia
(808/548-2076)
Section 313 Submissions:
John C. Levin, M.D. Chair
Hawaii State Emergency Response
Commission
Hawaii State Department of
Health
P.O. Box 3378
Honolulu, HI 96801-9904
808/548-6505
IDAHO
State Commission:
Idaho Emergency Response
Commission
Department of Health
and Welfare
State House
Boise, ID 83720
208/334-5888
Section 311/312 & 313
Submissions:
Idaho Emergency Response
Commission
State House
Boise, ID 83720
Attn: Jenny Records
Contact:
Jenny Records
(208/334-5888)
ILLINOIS
State Commission and Section
311/312 Submissions:
Oran Robinson
Illinois Emergency Response
Commission
Illinois Emergency Services
& Disaster Agency
Attn: Hazmat Section
110 East Adams Street
Springfield, IL 62706
217/782-4694
Section 313 Submissions:
Joe Goodner
Emergency Planning Unit
Illinois EPA
P.O. Box 19276
2200 Churchill Road
Springfield, IL 62794-9276
217/782-3637
INDIANA
Skip Powers, Director
Indiana Emergency Response
Commission
5500 West Bradbury Avenue
Indianapolis, IN 46241
317/243-5176
IOWA
State Commission & Section 302
Submissions:
Ellen Gordon, Co-Chair
Iowa Disaster Services
110
Chemicals, The Press & The Public
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Hoover Building, Level A
Room 29
Des Moines, IA 50319
515/281-3231
Section 304 Submissions:
Air Quality & Solid Waste
Protection Bureau
Department of Natural Resources
Wallace Building, '5th Floor
Des Moines, IA 50319
515/281-8694
Contact: Pete Hamlin
Section 311/312 Subtrdssions:
Iowa Emergency Response
Commission
Iowa Division of Labor
1000 East Grand Avenue
Des Moines, IA 50319
513/281-6175
Contact: Don Peddy
Section 313 Submissions:
Department of Natural Resources
Records Department
900 East Grand Avenue
Des Moines, IA 50319
515/281-6175
Contact: Don Peddy
KANSAS
State Commission:
Karl Birns, Staff Director
Kansas Emergency Response
Commission
Building 740, Forbes Field
Topeka, KS 66620
913/296-1690
Section 302 & 304 Submissions:
Karl Birns
Kansas Department of Health
and Environment
Right-to-Know Program
Building 740, Forbes Field
Topeka, KS 66620
913/296-1690
Emergency Release Number Only
(24hrs): (913/296-3176)
Section 311/312 & 313
Submissions:
Right-to-Know Program
Kansas Department of Health
and Environment
Building 740, Forbes Field
Topeka, KS 66620
913/296-1690
Contact: Karl Birns
KENTUCKY
State Commission & Section
3111312 Submissions:
Colonel James H. "Mike" Molloy,
Chair
Kentucky Emergency Response
Commission
Kentucky Disaster and Emergency
Services
Boone National Guard Center
Frankfort, KY 40601-6168
502/564-8660
502/564-8682
Contact: Mike Molloy
or Craig Martin
Section 313 Submissions:
Valerie Hudson
Kentucky Department of
Environmental Protection
18 Reilly Road
Frankfort, KY 40601
502/564-2150
Mailing Address:
Lucille Orlando
SARA Title HI
Kentucky Department of
Environmental Protection
Kentucky Disaster and Emergency
Chapter 9: Information Sources
111
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Services
Boone National Guard Center
Frankfort, KY 60601-6161
LOUISIANA
State Commission & Section
311/312 Submissions:
Sargeant Ronnie Mayeaux
Louisiana Emergency Response
Commission
Office of State Police
P.O. Box 66614
7901 Independence Boulevard
Baton Rouge, LA 708%
504/925-6113
Section 313 Submissions:
R. Bruce Hammatt
Emergency Response Coordinator
Department of Environmental
Quality
P.O. Box 44066
Baton Rouge, LA 70804-4066
504/342-8932
MAINE
David D. Brown, Chair
State Emergency Response
Commission
Station Number 72
Augusta, ME 04333
207/289-4080
in ME 800/452-8735
.
Contact: Tammy Gould
MARYLAND
State Commission:
June L. Swem
Governor's Emergency
Management Agency
c/o Maryland Emergency
Management Agency
2 Sudbrook Lane, East
Pikesville, MD 21208
301/486-4422
Section 302, 304, 311/312 & 313
Submissions:
Marsha Ways
State Emergency Response
Commission
Maryland Department of
the Environment
Toxics Information Center
2500 Broening Highway
Baltimore, MD 21224
301/631-3800
MASSACHUSETTS
Arnold Sapenter
c/o Title Three Emergency
Response Commission
Department of Environmental
Quality Engineering
One Winter Street, 10th floor
Boston, MA 02108
617/556-1096
For LEPC Information:
Jack Callahan
508/820-2060
MICHIGAN
Title III Coordinator
Michigan Department of Natural
Resources
Environmental Response Division
Title HI Notification
P.O. Box 30028
Lansing, MI 48909
517/373-8481
i ' , .'1
MINNESOTA
Lee Tischler, Director
Minnesota Emergency Response
Commission
Department of Public Safety
Room B-5
State CTapitol
St. Paul, MN 55155
612/296-0488
112
Chemicals, The Press & The Public
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MISSISSIPPI
J.E. Maher, Chair
Mississippi Emergency Response
Commission
Mississippi Emergency
Management Agency
P.O. Box 4501
Fondren Station
Jackson, MS 39296-4501
601/960-9973
Contact: Bill Austin
MISSOURI
Dean Martin, Coordinator
Missouri Emergency Response
Commission
Missouri Department of Natural
Resources
P.O. Box 3133
Jefferson City, MO 65102
314/751-7929
Mailing Address:
Dean Martin
Missouri Emergency Response
Commission
Missouri Department of Natural
Resources
2010 Missouri Boulevard
Jefferson City, MO 65109
MONTANA
Tom Ellerhoff, Co-Chair
Montana Emergency Response
Commission
Environmental Sciences Division
Department of Health &
Environmental Sciences
Cogswell Building A-107
Helena, MT 59620
406/444-3948
NEBRASKA
Clark Smith, Coordinator
Chapter 9: Information Sources
Nebraska Emergency Response
Commission
Nebraska Department of
Environmental Control
P.O. Box 98922
State House Station
Lincoln, NE 68509-8922
402/471-4217
NEVADA
State Commission and Section
3111312 Submissions:
Joe Quinn
Nevada Division of Emergency
Management
2525 South Carson Street
Carson City, NV 89710
702/885-4240
Emergency Release Number
(After Hours & Weekends)::
702/885-5300
Section 313 Submission:
Bob King
Division of Emergency
Management
2525 South Carson Street
Carson City, NV 89710
702/885-4240
NEW HAMPSHIRE
Richard Strome, Director
State Emergency Management
Agency
Title IE Program
State Office Park South
107 Pleasant Street
Concord, NH 03301
603/271-2231
Contact: Leland Kimball
NEW JERSEY
State Commission:
Tony McMahon, Director
113
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New Jersey Emergency Response
Commission
SARA Title III Project
Department of Environmental
Protection
Division of Environmental Quality
CN-405 ;
Trenton, NJ 08625
609/292-6714
Section 302, 304 & 311/312 \
Submissions:
New Jersey Emergency Response
Commission
SARA Title HI Project
Department of Environmental
Protection
Division of Environmental Quality
CN-405
Trenton, NJ 08625
609/292-6714
Section 313 Submissions:
New Jersey Emergency Response
Commission
SARA Title III Section 313
Department of Environmental
Protection
Division of Environmental Quality
Bureau of Hazardous Waste
Information
CN-405
401 East State Street
Trenton, NJ 08625
609/292-6714
I
NEW MEXICO
.
Samuel Larcombe
New Mexico Emergency Response
Commission
New Mexico Department of
Public Safety
P.O. Box 1628
Santa Fe, NM 87504-1628
505/827-9222
NEW YORK
State Commission:
Anthony Germain,
Deputy Director
State Emergency Management
Office
Building 22
State Campus
Albany, NY 12226
518/457-9994
Section 302, 304, 311/312 & 313
Submissions:
New York Emergency Response
Commission
New York State Department of
Environmental Conservation
Bureau of Spill Response
50 Wolf Road/Room 326
Albany, NY 12233-3510
518/457-4107
Contact: William Miner
CAROLINA
State Commission:
Joseph Myers, Chair
North Carolina Emergency
Resrionse Commission
116 West Jones Street
Raleigh, NC 27603-1335
919/733-3867
Section 302, 304, 311/312 & 313
Submissions:
North Carolina Emergency
Response Commission
North Carolina Division of
Emergency Management
116 West Jones Street
Raleigh, NC 27603-1335
919/733-3867
In NC: 800/451-1403
General Information Only.
Contacts:
Vance Kee
(919/733-3844)
114
Chemicals, The Press & The Public
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Emily Kilpatriclc
(919/733-3865)
Darian Maybry
(919/733-3890)
NORTH DAKOTA
State Commission:
Ronald Affeldt, Chair
North Dakota Emergency
Response Commission
Division of Emergency
Management
P.O. Box 5511
Bismarck, ND 58502-5511
701/224-2111
Section 302, 311/312 & 313
Submissions:
SARA Title HI Coordinator
North Dakota State Depart-
ment of Health and
Consolidated Laboratories
1200 Missouri Avenue
P.O. Box 5520
Bismarck, ND 58502-5520
701/224-2374
Contact: Charles Rydell
COMMONWEALTH of
NORTHERN MARIANA
ISLANDS
State Commission and Section
311/312 Submissions:
Felix A Sasamoto,
Civil Defense Coordinator
Office of the Governor
Capitol Hill
Commonwealth of Northern
Mariana Islands
Saipan, CNMI 96950
Int'l Number: 670/322-9529
Section 313 Submissions:
Russell Meecham, III
Division of Environmental Quality
P.O. Box 1304
Chapter 9: Information Sources
Saipan, CNMI 96950
670/234-6984
OHIO
State Commission and Section
311/312 Submissions:
Ken Schultz, Coordinator
Ohio Emergency Response
Commission
Ohio Environmental Protection
Agency
Office of Emergency Response
P.O. Box 1049
Columbus, OH 43266-0149
614/644-2260
Section 313 Submissions:
Cindy Sferra-DeWulf
Division of Air Pollution Control
1800 Watermark Drive
Columbus, OH 43215
614/644-2270
OKLAHOMA
Jack Muse, Coordinator
Emergency Response Commission
Office of Civil Defense
P.O. Box 53365
Oklahoma City, OK 73152
405/521-2481
Contact: Aileen Ginther
OREGON
Ralph M. Rodia
Oregon Emergency Response
Commission
c/o State Fire Marshall
3000 Market Street Plaza
Suite 534
Salem, OR 97310
503/378-2885
115
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PENNSYLVANIA
. M ,
State Commission:
Sanders Cortner
Pennsylvania Emergency Response
Commission
SARA Title IE Officer
PEMA Response and Recovery
P.O. Box 3321
Harrisburg, PA 17105
717/783-8150
717/783-8193
;: ' :; t ] ";
Emergency Release Number -
24 hours: 717/783-8150
Section 311/322 Submissions:
Pennsylvania Emergency Response
Commission
c/o Bureau of Right-to-Know
Room 1503
Labor and Industry Building
7th & Forrester Streets
Harrisburg, PA 17120
717/783-2071
Section 313 Submissions:
James Tinney
Bureau of Right-To-Know
Room 1503
Labor and Industry Building
7th & Forrester Streets
Harrisburg, PA 17120
717/783-8150
PUERTO RICO
State Commission and Section
311/312 Submissions:
Mr. Santos Rohena, Chair
Puerto Rico Emergency Response
Commission
Environmental Quality Board
P.O. Box 11488
Sernades Juncos Station
Santurce, PR 00910
809/722-1175
809/722-2173
Section 313 Submissions:
SERC Commissioner
Title ill-SARA Section 313
Puertq Rico Environmental
Quality Board
P.O. Box 11488
Santurce, PR 00910
809/722-0077
RHODE ISLAND
State Commission,-
Joseph A. DeMarco,
Executive Director
Rhode Island Emergency
Response Commission
Rhode Island Emergency
Management Agency
State Incuse Room 27
Providence, RI 02903
401/277-3039
Emergency Release Number:
401/274-7745
Contact: John Alcott
Section 311/312 Submissions:
Lynn Colby
Rhode Island Department of
Laboir
Division of Occupational Safety
220 Elrnwood Avenue
Providence, RI 02907
401/457-1847
J : ':
Section 313 Submissions:
Department of Environmental
Management
Division of Air and Hazardous
Materials
291 Promenade Street
Providence, RI 02908
Attn: Toxic Release Inventory
401/277-2808
Contact: Martha Mulcany
116
Chemicals, The Press & The Public
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SOUTH CAROLINA
State Commission and Section 302
Submissions:
Stan M. McKinney, Chair
South Carolina Emergency
Response Commission
Division of Public Safety Programs
Office of the Governor
1205 Pendleton Street
Columbia, SC 29201
803/734-0425
Section 304 & 311/312
Submissions:
South Carolina Emergency
Response Commission
Division of Public Safety Programs
Office of the Governor
1205 Pendleton Street
Columbia, SC 29201
Attn: Purdy McLeod
803/734-0425
Section 313 Submissions:
Ron Kinney
Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
803/734-5200
SOUTH DAKOTA
State Commission and Section
311/312 Submissions:
Clark Haberman, Director
South Dakota Emergency
Response Commission
Department of Water and Natural
Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501-3181
605/773-3151
Section 313 Submissions:
Lee Ann Smith
Title III Coordinator
S.D. Department of Water and
Natural Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501-3181
605/773-3153
TENNESSEE
Mr. Lacy Suiter, Chair
Tennessee Emergency Response
Commission
Director, Tennessee Emergency
Management Agency
3041 Sidco Drive
Nashville, TN 37204
615/252-3300
800/258-3300 (out of TN)
800/262-3300 (in TN)
Contact:
TEXAS
Lacy Suiter
or Tom Durham
State Commission:
Mike Scott, Coordinator
Texas Emergency Response
Commission
Division of Emergency
Management
P.O. Box 4087
Austin, TX 78773-0001
512/465-2138
Section 302, 311/312 Submissions:
Dr. William Elliot
Texas Department of Health
Division of Occupational Safety
and Health
1100 West 49th Street
Austin, TX 78756
512/458-7410
Section 313 Submissions:
David Barker, Supervisor
Emergency Response Unit
Texas Water Commission
P.O. Box 13087-Capitol Station
Chapter 9: Information Sources
117
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Environmental Health Center
Community Right-to-Know
Independent Press Advisory Committee
Joel N. Shurkin (Chairman), Stanford University News Service
Joel Shurkin writes science news for Stanford Univer-
sity's News Service in Palo Alto, California. The author of
seven books (he's working on the eighth) on science and the
history of science, Shurkin from 1963 to 1968 was with
United Press International in bureaus throughout the world.
During that time, he headed the UPI bureaus in Baltimore
and Cleveland.
From 1968 to 1971, Shurkin was a national correspon-
dent for Reuters in New York, and he next spent^nine years
as science editor of The Philadelphia Inquirer. While w th
the Inquirer, he was part of a reporting team whose work
won a Pulitzer Prize for its coverage of Three Mile Island.
In 1979 and 1980, Shurkin was a Professional Journal-
ism Fellow at Stanford. He has a B.A. from Emory Univer-
sity in Atlanta, and he studied law at Temple University in
Philadelphia.
Mitchel Benson, San Jose Mercury News
Mitchel Benson since July 1984 has been the environ-
ment writer for the San Jose Mercury News in the heart of
California's high-tech Silicon Valley. His coverage wi 1 the
Mercury News has focused primarily on toxic waste and
Appendix
-------
and
°f the UnivBBi» <* Wisconsin
r^
level journalism at the Nebraska State
. . .
Sandra Blakeslee, Science Correspondent, The Ne* York Times
Sandy Blakeslee since 1982 has been a freelance
in
Appendix
-------
3\m Detjen, Science Writer, The Philadelphia Inquirer
Jim Detjen joined the Inquirer in 1982 as science writer.
As an undergraduate at Rensselaer Polytechnic Institute in
Troy, New York, he was managing editor of the "All
American" student newspaper. He received his M.S. in
journalism from Columbia University and studied also at
Harvard University.
Detjen was a reporter with the Poughkeepsie Journal
from 1973 to 1977, covering PCB and other chemical
pollution of the Hudson River. From 1978 to 1982 he was
environmental writer with The Courier-Journal in Louisville.
He worked there on several investigative projects, including
a 10-part series on toxic wastes that prompted passage of
Kentucky's first comprehensive toxic waste laws.
His reporting with The Inquirer has included coverage of
the space shuttle, AIDS, genetic engineering, depletion of
stratospheric ozone, and the "greenhouse effect". He spent
more than a year investigating and writing about radioactive
contamination resulting from the Three Mile Island nuclear
accident, and in 1986 he won the Scripps-Howard Founda-
tion's Edward Meeman Award for this work.
The National Science Foundation in 1985 selected
Detjen to be one of four U.S. journalists to report on
scientific developments at the South Pole and other
Antarctic research stations.
The winner of more than 35 state and national
journalism awards - including the Polk Award and the
National Headliner Award for investigative reporting - he
five times has won the Edward Meeman Award for conserva-
tion reporting. He twice won the Thomas Stokes Award for
natural resource reporting, and he twice has been a finalist
for a Pulitzer. He wrote the Hudson River PCB chapter for
Ralph Nader's Who's Poisoning America.
Detjen teaches science writing at Drexel University in
Philadelphia. He is a member of the Investigative Reporters
& Editors (IRE) and the National Association of Science
Writers (NASW).
Appendix
-------
fti
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Established in 1988, the Environmental Health Center (EHC),
a division of the National Safety Council, operates as a not-for
profit, nongovernmental public service organization. In this
capacity, the EHC is charged with helping diverse sectors of
society better focus limited resources on the numerous
environmental challenges which pose significant risk to the health
and safety of its people and, therefore, to society overall.
The Environmental Health Center, through its projects and
activities, strives to promote a broader understanding of complex
environmental issues., The Center takes no "sides," except to
support sound and workable environmental policies. Working
with a broad range of public and private sector organizations, the
Center assists in developing and implementing policies aimed at
recognized public health risks.
The National Safety Council's EHC fosters improved com-
munication not only among those professionally engaged in
environmental protection and resource management, but also
-- and most importantly ~ among the public at large.
Environmental Health Center
National Safety Council
1050 17th Street, N.W., Suite 770
Washington, D.C. 20036
202/293-2270 .
National
§1 Safety
Council
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