Guides to Chemical
Risk Management
May 1999
Chemical Safety
in Your Community:
             New Risk Management Program


    Permission to reproduce this guide is
granted with the accompanying credit line:
"Reproduced from Guides to Environmen-
tal Risk Management, Chemical Safety in
Your Community: EPA's New Risk Manage-
ment Program with permission from the
National  Safety Council's Environmental
Health Center, May 1999."
              May 1999
The Current Status of the Risk Management
Program Rule
  As of the publication date of this backgrounder, key ele-
ments of EPA's Risk Management Program Rule are still not
final. Public access to the offsite consequence analysis data
continues to be debated. EPA has not officially decided on
how it will respond to Freedom of Information Act requests.
The agency  has said that while the offsite consequence
analysis data will not be distributed to the public on the
Internet, it will supply paper copies of the data upon re-
quest. Also, EPA intends to increase the reportable quan-
tity of hydrocarbon fuels (i.e., propane). Concurrently, the
U.S. Court of Appeals granted an interim stay of the Risk
Management Program Rule as it applies to facilities using
propane in a process. For the most current information,

For More Information
  The National Safety Council is maintaining the Chemi-
cal  Emergency Management Web site at
xroads.htm as a resource supplement to this series of pub-
lications. The site is a directory of Risk Management Pro-
gram-related links to organizations, regulations, chemicals,
rules, and regulations involved in emergency management
and the safe handling of chemicals. A selection of articles
and papers written about the Risk Management Program
Rule and local efforts to identify and analyze risk in the
community is also included. The site will be constantly ex-
panding as industry and communities develop new infor-
mation required under the Risk Management Program Rule.

Other Publications in this Series
  Other documents in the Guides  to Environmental Risk
Management Series are listed below:

U New Ways to Prevent Chemical Accidents
U How Safe Am I? Helping Communities Evaluate
  Chemical  Risks
U What Makes a Hazard Hazardous: Working with
  Chemical  Information
U Evaluating Chemical Hazards in  the Community:
  Using an RMP's Offsite Consequences Analysis

  These documents can be downloaded for free from the
Chemical Emergency Management Web site at

About this Document
  The Environmental Health Center produced this guide
under cooperative agreement CX 826604-01-0 with the U.S.
Environmental Protection Agency.  It is part of a series of
publications on the Risk Management Program  Rule and
issues related to chemical emergency management.

Chemical  Safety  in  Your Community:
EPA's New Risk Management Program
  By June 21,1999, an esti-
mated 66,000 facilities—in-
cluding chemical plants, oil
refineries, propane retailers,
fertilizer warehouses, am-
monia users,  and water
treatment  plants—must
comply with the Risk Man-
agement Program Rule (RMP
Rule). These facilities are re-
quired to identify their haz-
ardous chemicals, analyze
the potential risks of these
chemicals to the surround-
ing community, develop
an  emergency response
program, and submit a sum-
mary of their risk manage-
ment program  to the U.S.
Environmental Protection
Agency (EPA). EPA will then
distribute this information,
making public a new genera-
tion of right-to-know infor-
mation about  hazardous
chemicals and  community
  Though the RMP Rule ap-
plies nationwide, the main
effect will be at the local
level. Using this powerful in-
formation, local authorities
and communities will be able
to identify chemical hazards
and risks and improve pub-
lic safety.
  Journalists reporting on
the publicly available risk
management information
will stimulate communities
to learn more about the
chemical hazards in the
community. Related stories
can help communities evalu-
ate the potential for  expo-
sure to risk. And public
dialogue with local industries
can promote facility safety,
encourage accident preven-
tion initiatives, and improve
emergency response plans.

Bhopal: The Trigger
  Human error, equipment
failure, and natural disas-
ters can all cause chemical
accidents. The danger to the
public from an unplanned re-
lease of a toxic chemical is
illustrated by  the  1984
Bhopal,  India,  tragedy.
There, a release of 40 tons
of highly poisonous methyl
isocyanate (MIC) killed more
than 2,000 people and in-
jured 170,000, leaving thou-
sands more to die  later.
Another release involving
the same chemical occurred
months later in Institute,
West Virginia, sending more
than 100 residents to the
  As a result of Bhopal and
similar incidents, Congress
enacted a law to help inform
communities of chemical
hazards and aid their emer-
gency planning. The law,
known as the Emergency
Planning and Community
Right-to-Know Act (EPCRA),
was passed as part of the
1986 amendments to the
Superfund hazardous waste
cleanup program.

Setting The Stage: The
Emergency Planning
and Community Right-
to-Know Act
  EPCRA created  State
Emergency Response Com-
missions (SERCs) and Local
Emergency Planning Com-
mittees (LEPCs) to imple-
ment the  act. SERCs are
appointed by the governor
and consist of state  emer-
gency, environmental, and
health agencies; public inter-
est associations; and  others
with emergency manage-
ment experience. LEPCs,
whose makeup is specified by
the law, typically consist of—

U Representatives of elected
  state and local officials
Q Law enforcement offi-
  cials, civil defense work-
  ers, and firefighters
^.1 First aid, health, hospital,
  environmental, and trans-
  portation workers
_l Representatives of com-
  munity groups and  the
  news media
U Owners and operators of
  industrial  plants  and
  other users of chemicals,
  such as hospitals, farms,
  and small businesses

  Participation of the news
media is specified by law. In
practice, however, very  few
journalists actually sit on an
LEPC, believing that such
participation represents a
conflict of  interest. This
same infrastructure will be
leveraged to implement the
Risk Management Program.
(See Key  Events Related to
the Risk Management Pro-
gram Rule.)
  About  868,000 facilities
that have  more than 400 ex-
tremely  hazardous sub-
stances listed by EPCRA
report  information about
their chemical inventories to
LEPCs, SERCs, and local fire
departments. Under EPCRA,
facilities are required to file
reports if the quantities of
the hazardous chemicals ex-
ceed specified thresholds. In
1987, EPCRA launched an-
other important right-to-
know program,  called  the
Toxics  Release Inventory,
that reports emissions of
hazardous substances into
the environment.
  EPCRA's reporting  re-
quirements and emergency
planning and notification
provisions  established a
coordinated effort  among
EPA, state governors, SERCs
and LEPCs, owners and op-
erators of regulated facilities,
and local fire departments.
LEPCs receive chemical
inventory  information,
analyze the hazards, and

  Key Events Related to the Risk Management
                      Program Rule




       The OSHA Hazard Communication Standard (29 CFR
       191 0.1 200) provides employees a right-to-know about the
       hazards of chemicals to which they are exposed.
       In Bhopal, India, a release of 40 tons of highly toxic methyl
       isocyanate kills more than 2,000 people; thousands more
       die later
       In Institute, West Virginia, a release involving methyl
       isocyanate sends more than 1 00 people to the hospital.
       EPA creates its Chemical Emergency Preparedness Program
       and urges a voluntary program to develop plans that address
       potential hazardous chemical emergencies at facilities.
       Congress  enacts EPCRA to provide the public with information
       about the amounts of hazardous chemicals present and
       discharged from fixed-site facilities. The law establishes the
       infrastructure of SERCs and LEPCs to develop emergency
       response plans for each community and fosters chemical
       emergency management dialogue between industry and local
       Congress enacts the Clean Air Act Amendments. Section 1 12(r)
       includes requirements for establishing the Risk Management
       Program Rule to (1) prevent and prepare for accidental
       releases of chemicals  that could cause immediate,  serious
       harm to human health and the environment and
       (2) communicate hazard information to the public.
1992  The OSHA Process Safety Management Standard is released.
       This standard is designed to prevent or minimize the
       consequences of a catastrophic release of toxic,  reactive,
       flammable, or highly  explosive hazardous chemicals from a
       process.  It serves as a model for Risk Management Program
       Rule requirements.
1994  EPA publishes  its List of Regulated Substances and
       Thresholds for Accidental Release Prevention, identifying
       the Risk Management Programs regulated substances and
       threshold quantities. Amendments were published in 1 996,
       1997,  and 1998.
1996  EPA releases the Risk Management Program  Rule
       requirements under section 1  12(r) of the Clean Air Act.
       Facilities are given three years to comply. This rule also
       establishes the obligation to create an independent
       Chemical Safety and Hazard Investigation Board to
       investigate the causes of major chemical  accidents and
       provide industry with information about conditions that
       compromise safety.
1999  Under Clean Air Act section 1  12(r), RMPs must be
       submitted to EPA before June 21,1 999.
            develop local emergency re-
            sponse plans.  They are re-
            sponsible for disseminating
            this information to the pub-
            lic and serving as a focus for
                                       community awareness and
                                         EPCRA extended right-to-
                                       know beyond the workplace
                                       and into the community.
This information has stimu-
lated communication be-
tween industries and com-
munities and encouraged
industries to store smaller
inventories of hazardous sub-
stances, discharge less, and
substitute  less-hazardous
chemicals.  In addition, the
availability  of public infor-
mation about hazardous
chemicals has encouraged
investigative reporting and
community activism, often
combining chemical hazard
issues with related issues,
such as environmental jus-
tice and children's health.

Picking Up Where
EPCRA Left Off: The
Risk Management
  In 1990, Congress  took
additional  measures  to
protect communities  from
hazardous chemicals by in-
cluding accident prevention
and emergency prepared-
ness measures in the Clean
Air Act Amendments of 1990
(CAA). Section 112(r) of the
CAA authorizes EPA to cre-
ate regulations that prevent
and prepare for accidental
releases. On June 20, 1996,
EPA issued the RMP Rule (40
CFR 68). Its primary goal is
to protect communities from
releases  of toxic or flam-
mable  chemicals that are
prone to cause immediate,
serious harm to public and
environmental health.
  Like  EPCRA, the  RMP
Rule contains important
right-to-know provisions.
The RMP Rule requires facili-
ties to provide  EPA with a
summary of their risk man-
agement programs if more
than a specified threshold
amount can be released by
an incident involving one
process. A process is defined
as manufacturing,  sorting,
distributing, handling, or us-
ing  a regulated substance.
Chemicals in transit, includ-
ing pipelines, are excluded.

   Summary of Key RMP Requirements
  U Develop and implement a risk management program,
     consisting of the following:
     • Hazard assessment program
       * identity of listed substances and quantities
        stored  on site
        five-year history of accidental releases
       * worst-case release scenario analysis with effect
        on the community
        alternative release scenario analysis (only by
        some facilities)
     • Accidental release prevention program
     • Emergency response program
  U Submit written RMP to EPA before June 21,1999
  U Revise RMP at least every 5 years
  EPA  will  distribute a
summary of each  facility's
risk management program,
known as a risk management
plan,  or RMP, to state and
local agencies involved with
emergency planning and re-
sponse. These programs will
include an accident preven-
tion program,  a hazard as-
sessment (which includes an
offsite consequence  analy-
ses), and an emergency re-
sponse program. The RMPs
will provide  state and local
agencies with additional in-
formation about chemicals
and facilities regulated by
EPGRA. Since the RMP Rule
regulates some chemicals
not regulated  by  EPGRA,
state and local agencies will
have access  to  information
about additional chemicals
  The general public will be
given ready access to some—
but not all—RMP  informa-
tion  through the  Internet
and other means, including
SERGs and LEPGs.  Informa-
tion made available to com-
munities  enables  them to
learn more about  local
chemical  hazards  and the
extent to  which risk of ex-
posure to these hazards is re-
duced through a facility's risk
management program.
Reducing Risk:
Accident Prevention
as the Key
  The accident prevention
requirements of the RMP Rule
are based on the requirements
of the  Occupational Safety
and Health Administration's
(OSHA's) standard: Process
Safety Management of Highly
Hazardous Chemicals (29 GFR
1910.119). This regulation, often
referred to as the PSM Standard,
was published in 1992. Although
both regulations are designed to
minimize the potential for and
extent of accidental releases,
there are differences  in the
chemicals and facilities they
regulate. The RMP Rule will ex-
pand the number of facilities re-
quired to have  an accident
prevention program and will
make information about those
programs readily available to the
community for the first time.
  The accident prevention pro-
gram of many RMPs contains in-
formation on  the types  of
hazards that may be created,
process controls that prevent or
minimize releases, mitigation
systems used to lessen the ef-
fect of releases, and monitoring
         Types of Facilities Regulated by the
            Risk Management Program Rule
                     Distributors 2%
       Electric/Gas Utilities
  Refineries and Allied
    Industry 5%
    Ammonia Refrigeration
           Agriculture Retaili
                                                   Other 11%
                              Drinking Water and
                            Municipal Waste Treatment
                                Facilities 14%
Facilities that have more than specified threshold quantities of any of 77 acutely
toxic substances or 63 flammable substances must submit an RMP All of the
listed substances can form gas or vapor clouds that may travel offsite and have
dangerous consequences if more than the threshold quantity is released. Not
all of the covered substances are regulated by EPCRA. Initially, 44 percent of
the 66,000 facilities affected by the Risk Management Program Rule were
propane distributors and users. This number could change dramatically if pro-
posed legislation to exempt propane from the RMP or an EPA proposal to raise
the reporting threshold for hydrocarbon fuels become effective.

             Areas at Risk Identified in Hypothetical
               Worst-Case and Alternative Scenarios
and  detection  systems.
Worker training, process
maintenance, compliance
audits, and incident investi-
gation information  is re-
ported also.
  In addition, RMPs include
a summary of the accident
history for the past five years
of process operation. Past
behavior is a useful indica-
tor of the facility's safety cul-
ture and commitment to
accident prevention.

Identifying Hazards:
The Offsite
Consequence Analyses
  The RMP must include an
offsite consequence analysis
(OCA) of potential chemical
accidents. Two scenarios are
required of most facilities: a
worst-case and an alterna-
tive case scenario.  The main
purpose of the analysis is to
identify vulnerable popula-
tions in residences, schools,
businesses, and other facili-
ties (public receptors) and
vulnerable parks, wildlife
preserves, and other natural
areas (environmental recep-
tors). Identifying  the scope
and needs of the vulnerable
areas is key to planning com-
munity response to an inci-
dent (see map  above).
  The OCA simulates a re-
lease and estimates how far
away  from  the  release
people or property could be
harmed—a "distance to
endpoint." The area that is
vulnerable to damage from a
release will often be repre-
sented by a circle with its
center at the point of release
and its radius equal to the
distance to endpoint. Dis-
tances to  endpoint estima-
tions can be either cal-
culated from acceptable air
dispersion models or ob-
tained from a lookup  table
prepared by EPA.
  All facilities must prepare
worst-case scenarios. Worst-
case scenarios assume that
the total quantity of the sub-
stance is quickly released,
that atmospheric conditions
will maximize the effect of
the  event,  and that  no
mitigation or response ac-
tions  are taken. Worst-case
scenarios can predict  spec-
tacularly  long distances—
more than 25 miles in  some
cases. However, worst-case
scenarios represent a highly
unlikely chain of events. Al-
though catastrophic releases
have occurred, they are very
rare.  Combining these fail-
ures with worst-case weather
conditions makes the  over-
all scenario even less likely.
But such events can and may
indeed happen.
  Many facilities must also
prepare alternative release
scenarios, which are based
on more credible,  realistic
factors. For example, the
scenario can assume that
mitigation measures  (e.g.,
dikes,  shut-off  valves, fire
sprinklers) operate as de-
signed and environmental
conditions are typical, rather
than the worst possible. The
scenario may even be based
on the facility's accident his-
tory. Alternative release sce-
narios represent more likely
events, providing more prac-
tical information to emer-
gency  planners  and the

Preparing for
Accidents: Emergency
Response Programs
  Despite prevention  mea-
sures, accidents do happen.
Therefore, the RMP Rule re-
quires  facilities to  have an
emergency response pro-
gram if their worst-case re-
lease scenario can  have an
offsite consequence.
  The  emergency response
program must include a plan
for informing the public and
local emergency response
agencies about accidental
releases. The plan must be co-
ordinated with the  commu-
nity emergency response
plan. In addition, the emer-
gency response program must
also  include procedures for
the use, inspection, testing,
and  maintenance of emer-
gency response equipment, as
well as training for employees
in relevant procedures.
  Facilities whose  employ-
ees will not respond to acci-
dental releases do not need
to develop an emergency re-
sponse program if they take
certain measures: Facilities
must notify emergency re-
sponders  when there is a
need for response. Facilities
with regulated flammable
substances must coordinate
response actions with the

local fire department. Facili-
ties with regulated toxic sub-
stances must be included in
the community emergency
response plan.
   The emergency response
provisions of the  RMP Rule
build on EPGRA's emergency
planning provisions, encour-
aging facilities to coordinate
their plans with community
emergency planners and re-

Balancing Right-to-
Know and Security:
Risk Management
Planning in the
Information Age
   The Glean Air  Act man-
dated that EPA make RMP in-
formation readily available
to the public. Through pub-
lic disclosure, Congress  in-
tended to save lives, reduce
accidents, limit pollution,
and protect property.
   Initially, EPA planned to
post all of the data on the
Internet—freely available to
all. However, on November 5,
1998,  EPA announced it
would not include the OCA
portion of the RMP data in the
online database because this
particular information could
be used by terrorists to iden-
tify mass casualty  targets.
   The Chemical  Manufac-
turers Association (CMA)
took the lead role to prevent
the distribution of OCA data
on the Internet.  CMA as-
serted that a database of
chemical inventories and
OCAs universally available
on the Internet could make
chemical facilities ready tar-
gets for terrorists. James
Solyst, CMA Team Leader for
Information Management/
Right-to-Know, remarked
that while the CMA supports
the RMP Rule,  "... making
the worst-case scenario data
available via the Internet is
a bad idea, given  the times
in which we live." Solyst
continued that putting this
data on the Internet "... will
     Writing a Story: Questions to Think About

     How effectively has the LEPC or other emergency management
     organizations developed and tested emergency plans required under
  U How will local chemical emergency planning and response organiza-
     tions use RMP information to improve safety (e.g., through emer-
     gency response, hazard reduction, or zoning restrictions)?
  U Who would be affected by a release? How would these vulnerable
     populations know that an emergency is occurring and how to
  U How will local officials and the public perceive the risk of accidental
     releases? What factors will they consider to determine risk from the
     chemical hazards reported on the RMP?
  U Has  the publics perception of the facility's safety and environmental
     record led them to trust the facility?
  U Are local facilities with chemical inventories prepared for a major
     release? Have they developed emergency response plans? Are the
     plans current and  have exercises  been conducted to test them? Has
     the facility communicated with neighbors and developed working
     relationships with  community response organizations?
  U How many affected facilities  are there in the community?  What is
     their accident release history?
  U Has  the facility changed its operations to improve prevention and
     response as a result of the need to complete the  RMP? Are they
     undertaking any hazard reduction actions to lower the quantity and
     number of chemicals? Has the facility improved accident prevention
     design and procedures? How does a facility's program compare with
     others in its industrial classification?
increase the risk of terrorist
attacks." The Federal Bureau
of Investigation supported
CMA's position and helped
persuade EPA to reverse its
earlier policy of free Internet
   In contrast, public interest
groups argued that full disclo-
sure remains the best option
to safeguard the public. Paul
Drum, Coordinator of the
Working Group on Commu-
nity Right-to-Know, asserted
"... the need to reduce real
hazards (chemicals) in the
community cannot be ac-
complished by withholding
data from the public. Broad
distribution  and  public
awareness of worst-case haz-
ards through the Internet is
the only effective way to mo-
tivate companies."
   Obtaining OCA data will
be a challenge. Public inter-
est organizations that main-
tain right-to-know Web sites
such as the Environmental
Defense Fund (Chemical
Scorecard) and the Unison
Institute (RTKNET) have not
indicated whether they will
distribute  the data them-
   Having RMP data not only
on the public record, but also
easily accessible and search-
able online, would have
provided reporters an oppor-
tunity to develop local  sto-
ries. Nevertheless, there are
alternative sources for locat-
ing this essential hazard in-
formation. As of May 1999,
all RMP data is still subject
to the Freedom of Informa-
tion Act (FOIA)—although
congressional initiatives
maybe underway to block
this avenue. (For more infor-
mation  on the debate, see

The National Safety Council
Environmental Health Cen-
ter's April 1999 issue of En-
vironment  Writer at the
NSC EHC Web site) LEPCs
or  SERCs  are   another
source. So are the regulated
facilities; many, in fact, have
already been communicat-
ing their RMPs in a variety
of public forums. CMA is rec-
ommending that its mem-
bers share RMP data with the
   Informing  the  public
about risks they face  is
something many reporters
consider a key part of their
job. They are often the trans-
lators through which techni-
cal information is compiled,
interpreted,  and relayed  to
a broader public. RMP data
should provide local journal-
ists with the  raw material for
many stories. Open informa-
tion was a key to the strat-
egy  Congress  and  EPA
envisioned  for improving
public safety.

Funding: The
Perennial  Problem
   Although EPCRA estab-
lished the infrastructure and
mandate to conduct local
emergency  planning, the
availability  of  resources  to
support these efforts some-
times limits  a community's
ability to prepare for emer-
gency responses.  Similarly,
the RMP Rule gives emer-
gency management groups
information  that better en-
ables them  to protect the
public. However, the lack  of
direct federal funding to sup-
port these  activities may
hamper their ability to use
the information.
   Many state and local gov-
ernments see  EPCRA and
the RMP Rule as positive ad-
ditions to their public safety
efforts and  are incorporat-
ing them into their pro-
grams. Others just do not
have the resources to imple-
ment another  requirement
in an already over-burdened
agency. Some implementing
agencies  address  the fund-
ing issue by charging facili-
ties   fees   for   EPCRA
activities to offset the opera-
tional costs. Others rely on
industry  contributions.

Implementing the
Rule:  Variations from
State  to State
  EPCRA gives states flex-
ibility in the structure and
operation of the SERCs and
LEPCs. For example, Califor-
nia has 5 LEPCs, while New
Jersey has 587. Just as struc-
ture and resources vary, so
does effectiveness. Although
some  SERCs and LEPCs
have established  excellent
working relationships with
the facilities that report to
them and the community
they serve, others have had
less success.
  Many RMP Rule programs
will actually be administered
and enforced by  state and
local agencies. These agen-
cies  must request and be
delegated from EPA the right
to implement the Risk Man-
agement Program within
their jurisdictions. Other-
wise, EPA remains  respon-
sible for  implementing the
rule.  As  of April 1999,
Florida,  Georgia,  Puerto
Rico, and the Virgin Islands
had been delegated respon-
sibility for managing the
Risk Management Program.
Twelve other states and two
counties are also seeking del-
egation to manage their own
programs. Check EPA's Web
site or the  Right-to-Know
Hotline for the most current
  Both EPCRA and the RMP
are "minimum rules." Imple-
menting  agencies have the
option of adding  reporting
requirements, chemicals,
and threshold quantities.
California's Office of Emer-
gency Services, for example,
has already indicated that it
intends to modify the RMP
Rule to be consistent with its
own requirements.

Evaluating Risk: Its
Up to Local
    The RMP offers commu-
nities information on chemi-
cal hazards;  the frequency
and severity of previous
chemical releases; and  the
measures taken to either pre-
vent, minimize,  or respond
to an accidental release. It
does not provide information
on the risks these chemicals
present to the community;
that is, the probability of an
accident occurring, its poten-
tial effect, and what the event
would mean to the commu-
    EPA believes that identi-
fying risk is best left to stake-
holders in the community:

    Preventing accidental re-
    leases  of hazardous
    chemicals is the shared
    responsibility of industry,
    government, and the
    public. The first steps to-
    ward accident preven-
    tion are identifying the
    hazards  and assessing
    the risks. Once informa-
    tion about chemicals is
    openly shared, industry,
    government, and the
    community can work to-
    gether toward reducing
    the risk to public health
    and the environment.
EPA, Risk Management
Planning: Accidental Release
Prevention—Final Rule:
Clean Air Act Section 112(r),
Office of Solid Waste and
Emergency Response, 550-F-
96-002, May 1996

  Determining the likeli-
hood of these scenarios is dif-
ficult because  the data
needed (e.g., rates for equip-
ment failure and human er-
ror) are not usually available.
Even when data are available,
significant   uncertainties
remain in applying the  data
because each facility's situ-

ation is unique. The prob-
ability of an event occurring
is only part of the risk equa-
tion. How right-to-know in-
formation is communicated
will affect the community's
perception of the risk posed
by accidental chemical re-
leases. The perception of
risk  will be  shaped by the
community's ability to un-
derstand the nature of po-
tential hazards; facilities'
ability to control, mitigate,
and  respond to  those haz-
ards; and, the community's
ability to manage emergen-
cies. A community's reac-
tion to perceived risk is
tempered  by other factors,
such as local industry's re-
lationship with the commu-
nity and socioeconomic
factors that are important to
the community.
  In collaboration  with
LEPGs and SERGs, a number
of industries are launching
public risk communication
and  education programs to
help explain RMP data and to
initiate discussions about risk
within the community. (See
reference  section pages
10-11 under Journalism, for
more information on model
programs  conducted  in
Kanawha Valley, West Vir-
ginia, and Augusta, Georgia).
  Journalists are a primary
source of information that
the community will rely on
to determine risk. The story
is not only about worst-case
scenarios, but also about
more probable  outcomes.
The  story includes what fa-
cilities are doing (or failing
to do) to prevent accidents
and the capabilities of facili-
ties and communities to re-
spond to an incident.  The
probability of chemical acci-
dents occurring compared to
the probability of other cata-
strophic events  (such as an
earthquake) also puts the
story into perspective.
Annotated List of RMP Links and Documents
  References and links to documents or Internet sites
should not be construed as an endorsement of the views
contained therein.

Federal Information
EPAs Chemical Emergency Preparedness and Prevention Office
  EPA's web  page for Chemical Accident Prevention and
Risk Management Planning provides very useful, compre-
hensive information. Examples of available information in-
clude fact sheets, questions and answers, newsletters, links
to non-EPA sites, the Glean Air Act section 112(r) legisla-
tion, the List of Regulated Substances and Thresholds for
Accidental Release Prevention, the Risk Management Pro-
gram Rule regulations, technical guidance documents, and
many other resources. EPA will maintain an online data-
base of all RMPs—in RMP*Info. However, RMP*Info will not
contain the OGA data.

EPAs Resource Conservation and Recovery Act, Superfund,
and EPCRA Hotline
  This site provides information on how to contact the EPA-
sponsored Hotline that addresses the Risk Management Pro-
gram Rule.  Other information resources are also provided,
including up-to-date information on several EPA programs,
including the RMP Rule.. Many related documents, includ-
ing  those listed on the EPA site above, can be  ordered by
calling (800) 424-9346 or (703) 412-9810 in the Washing-
ton, D.G., area.

Nonprofit Organisations
National Safety Council
http://www. htm
  The Environmental Health Center's Crossroads Chemi-
cal Emergency Management page is designed to expand and
strengthen the network of organizations involved in emer-
gency planning and response, chemical safety, and hazard-
ous chemical rules and regulations. This Web page will
continually evolve to  feature a comprehensive risk com-
munication repository focusing on the Risk Management
Program Rule. Additional useful resources not included in
this document can be found at this Web site.

RMP Background and Rule Summary Information 998/
Papers/Makris. htm
  A history of the evolution  of the Risk Management Pro-
gram Rule is provided by Jim Makris, Director, EPA's Chemi-
cal Emergency Preparedness and Prevention Office in his
presentation, "EPA Perspective on Advances  in Process
Safety." The presentation was  made at the First Annual Sym-
posium of the Mary Kay O'Connor Process Safety Center,
"Beyond Regulatory  Compliance, Making Safety Second
Nature," on March 30-31,1998. Access other presentations
from the symposium and links provided by the host's home

Position Papers
Too Close To Home: A Report on Chemical Accident Risks in
the United States
   U.S. Public Interest Research Group (U.S. PIRG). 1998.
Too Close To Home: A Report on Chemical Accident Risks
in the  United States. Using non-RMP right-to-know data,
U.S. PIRG presents a national overview and ranking of U.S
areas vulnerable to the effects of chemical disasters and
recommends ways to significantly reduce chemical acci-
dents and toxic pollution.

Responsible Care® Program
    This Chemical Manufacturers Association web page pro-
vides information about the association's Responsible Care*
Program. Safety Street and other materials on the Kanawha
Valley  Demonstration  Program may also be available by
calling (703) 741-5000.

CMA House Leaders Want Chemical Disaster Scenarios Offline
    Davis, Joseph A. CMA, house leaders want chemical di-
saster scenarios offline, Environment Writer 11, no. 1 (April

The Augusta Chronicle
    (Note: The Augusta Chronicle's web page provides a search
function. Entering "worst-case scenario" provides links to many
article summaries, some of which are listed below.)

Planning for the Worst
http://www.augustachronicle.eom/stories/l 01097/met_risk. html
    Gourley, Meghan. 1997. Planning for the worst, Augusta
Chronicle.  October 10, 1997. Ms.  Gourley wrote several
articles about a model  effort to hold a public presentation
of RMP information. This article includes a description of
some scenarios and provides maps showing worst-case and
alternative scenarios from each.

Richmond Industries to Develop Disaster Scenarios 597/
    Pavey, Robert. 1997. Richmond industries to develop
disaster scenarios, Augusta Chronicle (August 15, 1997).

Who Gets Polluted? The Movement for Environmental Justice
http://www.majbill.vt.edU/geog/31 04/justice.htm
    Rosen, Ruth. 1994. Who gets polluted? The movement
for environmental justice. Dissent ("Spring 1994), 223-230.

The Charleston Gazette
   Ward, Ken, Jr. 1994. Many ounces of prevention noted.
The Charleston Gazette (June 14,1994), 4B. This article  is
a commentary on a trial "Safety Street" meeting in Kanawha
Valley,  West Virginia
   Ward, Ken, Jr. 1994. Disaster possibilities follow set guide-
lines. The Charleston Gazette (June 6,1994), 6A. Mr. Ward

reports on RMPs provided by 12 industries in Kanawha Val-
ley, West Virginia. (Kanawha's hazard assessment project
served as a national model for establishing the Risk Man-
agement Program Rule.) Ward's series, "In Harm's Way?,"
was based on RMPs and interviews with plant managers,
engineers, and other chemical industry experts

Sources of Environmental Data
EPAs Envirofacts Warehouse
  Information from completed RMPs will be made avail-
able to the public through the  Envirofacts Warehouse data-
base, a single point of access to selected EPA data.

Environmental Defense Fund
http://www. scorecard. org/
  The Environmental Defense  Fund's "Chemical Scorecard"
can be used by the public to identify which chemical haz-
ards are located in the community, their known or suspected
effects, and actions the public can take.

Right-to-Know Network (RTK NET)
    RTK NET provides access to numerous databases, text
files, and conferences on the environment, environmental
"toxics," housing, and sustainable development. LEPG
information is also available. RTK NET provides information
about specific LEPGs in its database at
www/data/lepc.html and information about SERGs in its
database at
Be advised: not all servers are recognized by the host.

Organisational Contacts
U.S. Environmental Protection Agency
Contact: Carole Macko, Communications Team Leader,
         Chemical Emergency Preparedness and
         Prevention Office
Address: U.S. Environmental  Protection Agency
         401 M Street, SW 5104
         Washington, DC  20461
Phone:   (202) 260-7938

Chemical Manufacturers Association
Contact: James Solyst, Team  Leader, Information
Address: Chemical Manufacturers Association
         1300 Wilson Boulevard
         Arlington, VA 22209
Phone:   (703) 741-5233

Working Group  on Community Right-to-Know
Position: Paul Orum, Coordinator
Address: Working Group on Community Right-to-Know
         218 D Street, SE
         Washington, DC  20003
Phone:   (202) 544-9586
Web site:
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Safety Council, an 85-year-old nonprofit, nongovernmental organiza-
tion. The National Safety Council is a national leader on accident pre-
vention and home, workplace, auto, and highway safety issues.
  The National Safety Council established EHC in 1 988 to undertake
environmental communications activities aimed at helping society and
citizens better understand and act knowledgeably and responsibly in
the face of potential environmental health risks.  Since that start,  EHC
has built a strong record of effective, nonpartisan communication on
environmental health risks and challenges.
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