Guides to Chemical
Risk Management
EPA550-B-99-012
May 1 999
New Ways to Prevent
Chemical Incidents
•r
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Permission to reproduce this guide is
granted with the accompanying credit line:
"Reproduced from Guides to Chemical Risk
Management, New Ways to Prevent Chemi-
cal Incidents with permission from the Na-
tional 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,
see http://www.epa.gov/ceppo.
For More Information
The National Safety Council is maintaining the Chemi-
cal Emergency Management Web site at www.nsc.org/
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 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
U Chemical Safety in Your Community: EPA's New
Risk Management Program
These documents can be downloaded for free from the
Chemical Emergency Management Web site at www.nsc.org/
xroads.htm.
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.
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New Ways to Prevent
Chemical Incidents
Dr. Paul L. Hill, chairman
and chief executive officer of
the Chemical Safety and
Hazard Investigation Board
(GSB), told Congress on Feb-
ruary 24, 1999, "In 1996,
chemical incidents claimed
the lives of the equivalent of
two fully loaded 737 passen-
ger jets—256 people per-
ished. And an average of 256
people died the year before.
And the year before that."
From 1987 to 1996, the
most recent year for which
full data are available, about
605,000 potentially danger-
ous commercial chemical
incidents were reported, ac-
cording to the CSB's 600K
Report: Commercial Chemi-
cal Incidents in the United
States 1987-1996. And ac-
cording to the CSB, many in-
cidents still go unreported.
The 600K Report details
some staggering statistics:
U An average of 60,000 in-
cidents occur per year, to-
taling 605,000 over the
10-year period.
U These more than 600,000
incidents resulted in
2,565 deaths and 22,949
injuries during that time
period. Of these, 333
deaths and 9,962 injuries
occurred at fixed-site fa-
cilities.
Q Forty-two percent of inci-
dents reported between
1987 and 1996 occurred
at fixed-site facilities; 43
percent of these incidents
occurred in transit.
U General equipment fail-
ures and human error
were key causes of inci-
dents at facilities.
To help prevent accidents
in the future, an estimated
66,000 facilities—chemi-
cal plants, oil refineries,
propane retailers, fertilizer
warehouses, ammonia users,
and water treatment plants
—must comply with the Risk
Management Plan Rule (RMP
Rule) by June 21, 1999. Fa-
cilities must file risk manage-
ment plans (RMPs) if any
process at the site contains
more than specified amounts
of 140 hazardous substances
such as propane, ammonia
or chlorine. RMPs detail in-
formation about hazards
that can be caused by chemi-
cal releases and activities to
prevent chemical accidents
and prepare for emergencies.
Much of this information will
be available to the public.
The RMP Rule focuses
on preventing accidental
chemical releases, reducing
risk to the community from
exposure to hazardous
chemicals, and minimizing
the consequences of releases
on the environment. The
rule requires facilities to
identify the hazardous
chemicals they store and
use, analyze the risks of
these chemicals to the sur-
rounding community, and
develop emergency response
plans. This information is
summarized in the RMP. The
RMPs must include the fol-
lowing:
Q An offsite consequence
analysis (OCA), which ex-
amines potential risk to
the community
Q A five-year accident his-
tory of releases and inci-
dents
Q Reports on incident inves-
tigations
Q A summary of efforts to
prevent accidents from
occurring
Q Plans for responding
to potential spills and
releases
Facilities will submit the
RMP to the U.S. Environmen-
tal Protection Agency (EPA).
EPA will distribute this new
generation of right-to-know
information about chemicals
and potential community
hazards to state and local
emergency planning agencies
and the public.
A New Era
The Clean Air Act (CAA)
Amendments of 1990 ushered
The Impact of Right-to-Know
Just like EPCRA, the intent of the RMP is to reduce risks without
command-and-control government regulations. The theory is that
public knowledge will create public pressure, which will motivate
companies to operate their plants more safely. Does this work? Toxics
Release Inventory data, along with other regulatory and industry
initiatives, suggest that right-to-know has been a key factor in reducing
chemical emissions released by nearly 46 percent from 1 988 through
1996 (Mason 1999).
The accident prevention information in RMPs will help local com-
munities judge the risk from accidental chemical releases. The extent of
accident prevention activity can provide an indication of how serious
the facility management is about controlling hazards. The news media
and other community members can explore whether facilities are doing
what their RMPs indicate.
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in a new era in preventing or
reducing accidental releases
of hazardous chemicals. Sec-
tion 112(r) of the GAA makes
three federal agencies chiefly
responsible for preventing
chemical catastrophes: EPA,
CSB, and the Occupational
Safety and Health Adminis-
tration (OSHA).
Section 112(r) requires
OSHA to establish regula-
tions that protect workers
from chemical spills and re-
leases. These regulations
were issued as the Process
Safety Management of Highly
Hazardous Chemicals Rule,
also known as the PSM Stan-
dard (29 GFR 1910.119).
Under Section 112(r),
EPA was required to estab-
lish regulations to protect
the public from uninten-
tional chemical release.
These regulations are
contained in the Acciden-
tal Release Prevention
Requirements: Risk Man-
agement Program Rule, also
known as the RMP Rule (40
GFR Part 68). Flammable
and toxic chemicals ca-
pable of causing severe,
acute health effects are cov-
ered under the rule; pyro-
technic and explosive
chemicals are not.
Section 112(r) also cre-
ated a new independent fed-
eral agency, the GSB. The
agency does not have regu-
latory authority. Its chief re-
sponsibility is to investigate
chemical incidents. GSB in-
vestigative reports are made
public, which could help to
deter or prevent future inci-
dents and releases.
PSM Versus RMP
Although the accident
prevention provisions of the
RMP Rule closely parallel
OSHA's PSM, there are sev-
eral significant differences.
For example, the PSM Stan-
dard affects about 30,000
industrial facilities. The RMP
Rule affects nearly 66,000
facilities, including retail and
government entities. Under
the PSM Standard, employ-
ers must only provide
chemical accident preven-
tion information to employ-
ees, not to the public. The
RMP, with the exception of
confidential business infor-
mation, is public informa-
tion. Therefore the RMP
serves as a community right-
to-know vehicle for the PSM
Standard since it includes a
summary of the facility's ac-
cident prevention program.
Three Levels of Safety
Not all facilities are
treated alike. The processes
regulated by the RMP Rule
are divided into three lev-
els—Program 1, 2, and 3—
based on the scope of
hazards from the processes
and the facility's accident
history. Each level has differ-
ent compliance require-
ments.
Program 1 processes rep-
resent the least public threat
from an offsite chemical re-
lease. To qualify as Program
1, a facility—
U Must not have experi-
enced an accidental re-
lease with an offsite
consequence in the prior
five years
U Must have a worst-case
scenario release that could
not affect the public
Because these programs
pose less hazard to the com-
munity, they are subjected to
limited hazard assessment,
prevention, and emergency
response requirements. Pro-
gram 1 processes must coor-
dinate emergency response
plans with local responders.
Program 2 processes are
not eligible for Program 1,
yet are not as hazardous as
Program 3 processes. Pro-
gram 2 has been referred to
as "PSM Lite." These pro-
cesses must—
U Perform a hazard review
of the process and regu-
lated substances.
U Identify potential equip-
ment malfunctions or hu-
man error.
U Take steps to monitor or
detect releases.
Program 3 processes, the
most hazardous, must per-
form a rigorous, step-by-step
hazard analysis of processes,
equipment, and procedures
to identify each point at
which an accidental release
could occur.
See the table on page 5 for
a comparison of the accident
prevention requirements of
the three programs and the
PSM Standard.
Diagnosing Hazards
Accident prevention be-
gins with analyzing opera-
tions to identify equipment
and procedure failures that
could lead to unplanned
spills and releases. The RMP
Rule requires Program 3 pro-
cesses to conduct what is
formally known as a process
hazard analysis (PHA). Pro-
gram 2 processes, which are
generally less complex than
Program 3, also must iden-
tify potential failures, but a
formal PHA is not required.
PHAs identify areas where
improvements can be made
in system design, operating
procedures, training, and
other accident prevention
strategies. PHAs must be
carefully scrutinized since
many other aspects of risk
management programs are
based on the findings and
recommendations of these
analyses. Information from
PHAs will likely be used as
the basis for the alternate
release scenarios developed
as part of OGA. The OGA will
then be used to develop fa-
cility and community emer-
gency response plans.
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Summary of Key Accident Prevention Compliance Requirements
Requirement
Compile written process safety information
Establish employee participation in and access
to process safety analysis and management
Analyze process hazards
Prepare written operating procedures
Conduct worker training
Conduct contractor training
Conduct safety review before startup
Ensure ongoing integrity of equipment
Manage process changes
Conduct incident investigations
Conduct compliance audit
Coordinate emergency response plan with community
PSM
Standard
/
/
S
/
/
S
/
S
S
/
S
/
RMP
Program 3
/
/
S
/
/
/
/
S
S
/
S
/
RMP
Program 2
/
/
S
/
/
S
/
S
/
RMP
Program 1
/
Known Safety
Measures
Human and mechanical
errors are the major causes
of spills and releases (see
chart below). Accident pre-
vention programs should
seek to identify problem ar-
eas and resolve them. Some
examples of known safety
measures follow.
Worker Training Prevents
Accidents. Most incidents
occur because of a combina-
tion of unsafe conditions and
unsafe acts. Proper training
of workers can minimize the
number of accidents. The
RMP Rule requires workers
and contractors who are in-
volved with the regulated
processes to receive appro-
priate training. Worker re-
fresher training must be
given at least every three
years. Facilities must docu-
ment specifically who was
trained and when and how
they verified that the employ-
ees understood the training.
Maintaining Mechanical
Integrity of Process Equip-
ment Reduces Risk. Higher
hazard facilities must pre-
pare written preventative
maintenance procedures
to ensure the mechanical
integrity of the process
equipment and controls.
The RMP Rule requires
documentation of tests and
inspections of equipment
and controls. The frequency
must be consistent with
manufacturers' recommen-
dations and good engineer-
ing practices.
Incident Investigations
Prevent Future Accidents.
Despite effective accident
prevention efforts, acci-
dents and "near-misses" will
occur. Facilities with Pro-
gram 2 and 3 processes are
required to investigate and
Number of Chemical Incidents
by Initiating Event
1987-1996
250,000
200,000
100.000
50.000
Mechanical Human Error Natural
Error Phenomenon
Other
Mechanical Error Causes
Construction
Error
Z%
Human Error Causes
Source: Chemical Safety and Hazard Investigation Board 1999
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6
Verifying Compliance
Scarce resources may limit the ability of OSHA, EPA, and the states
to audit RMPs. Although many facilities are operated safely, community
scrutiny often will be key to ensuring that facilities complete reliable
audits and respond to identified weaknesses. Some suggestions to help
verify compliance follow:
U Assess the scope and frequency of training and how trainees are
evaluated to determine whether they have learned what they need
to know.
U Verify whether equipment used in regulated processes is inspected
and maintained as indicated in an RMP
U Determine whether all incidents are investigated and reported as
required by the RMP Rule.
U Examine a facility's five-year accident history of regulated processes
that must be submitted as part of the RMP The frequency of reported
incidents and accidents may reveal potential weaknesses in a facility's
accident prevention program.
U Evaluate whether facilities have the necessary federal and state
permits for their releases of hazardous substances.
report incidents that
resulted in, or could
have resulted in, a cata-
strophic release of a
regulated chemical. In-
vestigations are aimed at
determining the cause or
causes of incidents and
recommending changes
that can prevent recur-
rence. Facilities must
document resolutions
and corrective actions.
Implementation of these
corrective actions can
play an important role in
reducing future risk.
Auditing Keeps Pro-
grams Up-to-Date. Higher
hazard facilities must
evaluate their compli-
ance with the RMP Rule's
accident prevention re-
quirements at least every
three years. The facilities
must report the findings
of the audit to EPA and
correct any deficiencies.
The purpose of the audit
is to verify that the pro-
cedures and practices
developed under the stan-
dard are adequate and are
being followed. The peri-
odic audits also provide
an opportunity to ensure that
operating procedures, poli-
cies, and training programs
have been modified to reflect
changes in processes. An on-
going facility audit program
is a positive sign of an active
safety culture.
Reducing Hazards Im-
proves Safety. Substituting
less hazardous chemicals
and reducing onsite inven-
tories are effective ways to
lower hazards. According to
environmental activist Fred
Millar, a member of the
Washington, D.G., Local
Emergency Planning Com-
mittee (LEPG), the city's
Blue Plains wastewater
treatment facility main-
tained a large enough quan-
tity of chlorine to threaten
Capitol Hill, nearby Boiling
Air Force Base, and other
Department of Defense
buildings. The LEPC con-
vinced Blue Plains to explore
replacing chlorine with
much less hazardous sodium
hypochlorite (bleach).
Determining Reliability
One way to help determine
the reliability of a particular
facility's RMP information
is to compare it with other
reports the facility has
completed. Regulated pro-
cess operators will often
have a variety of reporting
obligations in addition to
the RMP. For example,
Section 313 of the Emer-
gency Planning and Com-
munity Right-to-Know Act
(EPCRA) requires report-
ing on the identities and
quantities (but not the uses
or process) of specific ex-
tremely hazardous sub-
stances. Sections 311-312
of EPCRA require many of
the same facilities to sub-
mit chemical inventory
and facility identification
information to State Emer-
gency Response Commis-
sions (SERCs) and LEPCs.
In addition, the Compre-
hensive Environmental Re-
sponse, Compensation, and
Liability Act (CERCLA),
commonly referred to as
Superfund, requires that fa-
cilities notify the National
Response Center, local EPA
regional office, SERC, and
LEPC of chemical releases.
Determining whether all
required information has
been submitted to the ap-
propriate entity, and the
extent to which reported
values agree, can provide
an indication of the reli-
ability of particular RMP in-
formation.
Terrorism and Facility
Security
The chief of the FBI's Do-
mestic Terrorism Section,
Robert Burnham, testified
before Congress on February
10, 1999, that the FBI be-
lieves chemical facilities are
a terrorist target because
they contain hazardous sub-
stances that can cause mass
casualties and, consequently,
are a security risk to the
community. The Chemical
Manufacturers Association
agrees with this position.
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Writing a Story: Questions to Think About
The following questions may help elicit more information about accident prevention programs at
facilities regulated by the RMP Rule.
Questions for the plant manager or facility spokesperson:
U What are the top three or four actions being taken in the next 12 to 18 months to protect the local
community from accidental chemical releases?
U What steps are taken to promptly notify the local community of chemical releases from the facility?
U What steps or processes are in place for informing the local citizens of progress in preventing
accidental chemical releases at the facility?
U What steps should local citizens follow to obtain more information about the dangers of the chemi-
cals at the site, and what actions are taken to protect the local community?
Questions for contractors who currently or recently worked in the facility:
U What safety and accident prevention information and instructions were received before you began
work at the site?
U What do you think of the effectiveness of the chemical safety and accident prevention programs at
this facility?
U What concerns do you have about conditions that might lead to a chemical release that could harm
workers and citizens?
U How does this facility's accident prevention and safety effort compare to those of other similar
facilities where you have worked in the past?
Questions for local officials such as the fire chief, fire marshal, or LEPC chairman or executive director:
U What visits to the plant or facility have you made and what impressed you most about what you
saw?
Q What information has been exchanged between the facility manager and the local community?
Does this information fully satisfy all of the facility's obligations to the local community?
Q What steps can local citizens take to obtain information about the facility's chemical hazards and
chemical release prevention efforts?
Q What major community hazards are created by the facility and how are they being addressed or
controlled?
To reduce the risk of a ter-
rorism, the online RMP*Info
database of worst-case and
alternate scenario data from
RMPs will not be posted on
the Internet. Nevertheless,
the facility's physical plant
remains a security risk, and
reporters should ask about
this vulnerability.
Gardner Bates of the
Chlorine Institute noted that
physical security has always
been a significant concern
and priority within the in-
dustry. Since security details
are sensitive, he suggests
that reporters arrange a fa-
cility tour to obtain more in-
formation. The LEPG might
be helpful in gaining access.
Key questions to deter-
mine risk are—
Q How effectively does the
facility secure its perim-
eter? What are its access
policies and controls?
U Can personnel be located
and tracked within the fa-
cility?
U Does the facility and/or its
parent company have a
program in place to safe-
guard its databases and
communications?
Q Are there protective
buffer zones between
chemical operations and
neighbors?
U Are hazardous operations
fortified against bomb at-
tacks?
Y2K Issues
Most people think of the
Year 2000 problem, or Y2K,
as affecting only computers
and the data they contain
plus the potential impact on
financial institutions, per-
sonnel data, and Social Se-
curity checks.
But increasing attention is
now being paid to the
widespread Y2K problem on
electronic devices with em-
bedded chips used to regu-
late processes and safety
equipment in chemical
facilities. Embedded chips or
embedded systems abound
in the chemical industry.
These include microproces-
sors and computer chips
embedded in many chemical
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Key Y2K Questions to
Ask Facilities
U Have facilities examined and tested
their systems?
Q Do facilities have contingency plans
in place?
U Have facilities accounted for
potential power and communica-
tions failures?
U Are LEPGs and SERGs involved in
Y2K planning issues?
8
process controls and sensor
devices. Processes at chemi-
cal facilities are primarily
computer controlled. Conse-
quently, relief valves and
other safety features may
not operate correctly.
Dr. Gerald V. Poje, Board
Member and Y2K project
coordinator of the GSB,
noted that "... chemical
safety concerns include
complete failure of safety-
related systems, both for
control and protection; mal-
functions of embedded
microprocessors and equip-
ment; and potential failure to
respond correctly to pro-
gram instructions." Com-
puter-related process failures
have the potential to pro-
duce small to catastrophic
consequences. In its Year
2000 Issues: Technology
Problems and Industrial
Chemical Safety report is-
sued in March 1999, the CSB
asserts that large chemical
companies have the capabil-
ity and resources to resolve
their Y2K problems, assum-
ing continuity of the
powergrid. However, me-
dium and small companies
present a special concern
because of lack of informa-
tion and suggestions that
much more work still needs
to be done.
Annotated List of Accident Prevention
References and Links
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
http://www.epa.gov/ceppo
This EPA office maintains a comprehensive Web page
that includes chemical accident prevention and risk
management planning information. EPA will maintain an
online database of all RMPs—in RMP*Info. However,
RMP*Info will not contain the OCA data.
EPAs Resource Conservation and Recovery Act, Underground
Storage Tank, Superfund, and EPCRA Hotline
http://www.epa.gov/epaoswer/hotline
This site provides information on how to contact the
EPA-sponsored Hotline that addresses the Risk Manage-
ment Program Rule. Other information resources are also
provided. Many related documents, including those listed
on the EPA site above, can be ordered by calling (800)
424-9346 or (703) 412-9810 in the Washington, D.C.,
area.
EPAs Emergency Response Notification System
http://www.epa.gov/ERNS/
The Emergency Response Notification System (ERNS)
is a database used to store information on notifications of
oil discharges and hazardous substances releases. The
ERNS program is a cooperative data sharing effort among
EPA, the Department of Transportation, and the National
Response Center. ERNS provides the most comprehensive
data compiled on notifications of oil discharges and
hazardous substance releases in the United States.
National Response Center
http://www. nrc. uscg. mil
The National Response Center serves as the sole point
of contact for reporting all oil, chemical, radiological,
biological, and etiological discharges into the environ-
ment anywhere in the United States and its territories.
Summary statistics on chemical accidents are available
on the National Response Center's Web site.
OSHAs Process Safety Management Standard
http://www.osha-slc.gov/SLTC/processsafetymanagement
Information on the Process Safety Management Stan-
dard is available on OSHA's Web site.
Chemical Safety and Hazard Investigation Board (CSB)
http://www.chemsafety.gov
The Chemical Safety and Hazard Investigation Board
Web site has information about incidents investigated by
the board, as well as a library of chemical safety docu-
ments and information on the year 2000 issue.
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Nonprofit Organisations
National Safety Council
http://www. nsc. org/xroads. htm
The Environmental Health Center's Crossroads Chemi-
cal Emergency Management page is designed to expand
and strengthen the network of organizations involved in
emergency planning and response, chemical safety, and
hazardous chemical rules and regulations. This Web page
will continually evolve to feature a comprehensive risk
communication repository focusing on the Risk Manage-
ment Program Rule. Additional useful resources not
included in this document can be found at this Web site.
Center for Chemical Process Safety
http://www.aiche.org/docs/ccps/index.htm
Information on chemical process safety, engineering
design, and related issues is available through the Center
for Chemical Process Safety (CCPS) Web site or by phone
at (212) 591-7319. CCPS is a nonprofit professional
organization affiliated with the American Institute of
Chemical Engineers.
Position Papers
Too Close To Home: A Report on Chemical Accident Risks in
the United States
http://www.pirg.org/enviro/toxics/home98/
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
http://204.146.87.27/cmawebsite.nsf/pages/responsiblecare
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.
Regulations
Section 1 1 2(r) of Title III of the Clean Air Act Amendments of
1990
http://www.epa.gov/oar/caa/caal 1 2.txt
RMP Rule (40 CFR Part 68)
http://www.epa.gov/ceppo/pubs/potw/98part68.pdf
PSM Standard (29 CFR 1910.1 1 9)
http://www.osha-slc.gov/OshStd_data/l 91 0_01 1 9.html
Uln 1996, chemical
incidents claimed the
lives of the equivalent
of two fully loaded 737
passenger jets—256
people perished. And
an average of 256
people died the year
before. And the year
before that.
Dr. Paul L. Hill
February 24, 1999
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10
Local Information Sources
Many facilities will be prepared to
provide information that explains or
supplements the RMP information they
submit. Their information may include
the results of OCAs, which EPA will not
make available to the public over the
Internet.
The RMP Rule requires facilities to
coordinate their emergency response
programs with the local emergency
response community. Other local
sources of information regarding
hazardous chemicals and emergency
preparedness include the LEPC and the
local fire chief or fire marshal. The LEPC,
local fire department, or local emer-
gency management agency also may
be able to provide current copies of
material safety data sheets, which
provide information about chemicals'
physical and chemical characteristics,
fire and explosion hazards, and health
hazards.
Local hospital administrators or
heads of emergency room units also
may be able to provide information
about their ability to appropriately treat
workers or citizens who may be ex-
posed to specific regulated chemicals.
Other Documents
Potential Effects of Electronic Dissemination of Chemical "Worst-
Case Scenarios"
http://www.fbi.gov/congress/senlast.htm
Burnham, Robert M. 1999. Potential effects of electronic
dissemination of chemical "worst-case scenarios," Data
Statement for the Record of Robert M. Burnham Chief, Do-
mestic Terrorism Section before the United States Senate
Subcommittee on Glean Air, Wetlands, Private Property and
Nuclear Safety. March 16, 1999.
Year 2000 Issues: Technology Problems and Industrial
Chemical Safety
http://www.chemsafety.gov/! 999/news/n991 9.htm
Chemical Safety and Hazard Investigation Board. 1999.
Year 2000 Issues: Technology Problems and Industrial
Chemical Safety.
The 600K Report: Commercial Chemical Incidents in the United
States, 1987-1996
http://www.csb.gov/! 999/news/n991 6.htm
Chemical Safety and Hazard Investigation Board. 1999.
The 600K Report: Commercial Chemical Incidents in the
United States, 1987-1996.
EPCRA: Is It Working?
http://www. nsc. org/xroads. htm
Mason, Steve. 1999. EPCRA: Is it working? CAMEO To-
day 9, no. 2 (March/April 1999). This article is a literature
review and summary analysis of the effectiveness of public
disclosure "information-based" environmental protections
programs.
OSHA fact sheet (OSHA 93-45) summarizing the PSM Stan-
dard
http://www. osha-slc.gov/OshDoc/Fact_data/FSNO93-
45.html
Organisational Contacts
Center for Y2K and Society
Contact: Fred Millar
Address: Center for Y2K and Society
1800 K Street, NW #924
Washington, DC 20006
Phone: (202) 775-3157
E-mail: fmillar@erols.com
Chemical Manufacturers Association
Contact: James Solyst, Team Leader, Information
Management/Right-To-Know
Address: Chemical Manufacturers Association
1300 Wilson Boulevard
Arlington, VA 22209
Phone: (703) 741-5233
E-mail: jim_solyst@mail.cmahq.com
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Chemical Safety and Hazard Investigation Board
Contact: Phillip Cogan, Special Assistant to External
Relations
Address: Chemical Safety and Hazard Investigation Board
2175 K Street, NW, Suite 1400
Washington, DC, 20037
Phone: (202) 261-7600
E-mail: phil.cogan@csb.gov
The Chlorine Institute
Contact: Gardner Bates
Address: The Chlorine Institute
2001 L Street, NW, Suite 506
Washington, DC 20036
Phone: (202) 775-2790
Web Site:: http://www.cl2.com/
E-mail: gbates@cl2.com
Occupational Safety and Health Administration
Address: Department of Labor, Public Affairs Office,
200 Constitution Avenue, Room 3647
Washington, DC, 20210
Phone: (202) 693-1999
Web Site: www.osha.gov
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
E-mail: macko.carole@epamail.epa.gov
Working Group on Community Right-to-Know
Contact: Paul Orum, Coordinator
Address: Working Group on Community Right-to-Know
218 D Street, SE
Washington, DC 20003
Phone: (202) 544-9586
Web site: www.rtk.net/wcs
E-mail: orum@rtk.net
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The Environmental Health Center (EHC) is a division of the National
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.
May 1999
ENVIRONMENTAL HEALTH CENTER
A Division of the National Safety Council
1025 Connecticut Avenue, NW • Suite 1200
Washington, DC 20036
www.nsc.org/ehc.htm
(202) 293-2270
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