IT'S
A Guide for Ixical Einergeiicy
    Implementing the             PI
          Community
                  (SARA      LI!)

                                             Prtoterf oo ft&cyd&d Paper

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 The purpose of this booklet Is
 to offer suggestions to Local
 Emergency Planning
 Committees (LEPCs) to help
 them implement Title HI; it is
 not a comprehensive guide to
 running an LEPC. This
 booklet draws on the
 experience of those LEPCs
 that have developed
 comprehensive plans as well
 as on the experience of the
 U.S. Environmental Protection
Agency (EPA), the Federal
Emergency Management
Agency (FEMA), the states,
 the Chemical Manufacturers
Association (CMA), other
industry and trade
associations, and public
interest groups. It is
intended to help LEPCs
establish and maintain their
momentum in meeting the
Tide UI mandate and to
address some possible
implementation problems.
                                                About This Booklet
 The following organizations developed this booklet:

 American Red Cross
 Chemical Manufacturers Association
 Environmental Policy Institute
 Federal Emergency Management Agency
 International City Management Association
 International Association of Fire Chiefs
 National Association of Counties
 National Coordinating Council on Emergency Management
 National League of Cities
 National Safety Council
 National Wildlife Federation
 U.S. Chamber of Commerce
 U.S. Environmental Protection Agency

 The following organizations supported this booklet:

 Adhesive and Sealant Council, Inc.
 Agency for Toxic Substances and Disease Registry,
  U.S. Public Health Service
 American Coke and Coal Chemicals Institute
 American Institute of Chemical Engineers
 American Library Association
 Association of New Jersey Environmental Commissions
 The Chlorine Institute, Inc.
 Citizen Action
 Citizens Commission on Bhopal
 Cleveland Council on Hazardous Materials
 The Cosmetic, Toiletry, and Fragrance Association, Inc.
 Dry Color Manufacturers' Association
 Environmental Action Foundation
 Environmental Defense Fund
 The Formaldehyde Institute, Inc.
 Michigan  State Fire Fighters' Union
 National Association of Chemical Distributors
 National Association of Printing Ink Manufacturers
 National Association of Solvent Recyclers
 National Association of State Title ffl Program Officials
 National Association of Towns and Townships
 National Emergency Management Association
 National Solid Waste Management Association
 Occupational Safety and Health Administration
 Ohio Public Interest Campaign
 OMB Watch
 Research and Special Programs Administration,
 U.S. Department of Transportation
 The Rubber Manufacturers Association
 Society of American Wood Preservers, Inc.
 Synthetic  Organic Chemical Manufacturers Association
 U.S. Public Interest Research Group
Workplace Health Fund

The review and comments from individuals associated with
LEPCs and SERCs are appreciated.

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                                                                             PAGE1
                  About Title HI
 In 1986 Congress passed the Emergency Planning and
 Community Right to Know Act as Title HI of the
 Superfund Amendments and Reauthorization Act
 (SARA). Congress enacted this law to help local com-
 munities protect public health and safety and the envi-
 ronment from chemical hazards.

 To implement Title HI, Congress required each state to
 appoint a State Emergency Response Commission
 (SERC). The SERCs, in turn, were required to divide
 their states into emergency planning districts and name
 a Local Emergency Planning Committee (LEPC) for each
 district. The expertise (e.g., fire fighting, health, local
 officials, community groups, media, facility representa-
 tives, emergency management) of the required LEPC
 members ensures that all the necessary elements of the
 planning process are represented.

 The LEPC is the focal point for Title III activities in the
 community. The performance of the LEPC is critical to
 ensuring that the public benefits from the opportunities
 and information provided for under the law.

The responsibilities of the LEPCs are stated in the law:
 each LEPC must develop an emergency plan, collect and
 store information provided by facilities, and make that
information available to the public.  Other LEPC activi-
ties can be anticipated and are important to carrying
out the spirit of the law. For example, LEPCs will pro-
vide a continuing forum in which the local community
and facilities can discuss issues related to hazardous
substances.
Two of the main goals of Tide
HI are to:

  Provide a basis for each
  community to develop a
  chemical emergency
  preparedness andplanning
  program that suits its
  individual needs, and.

  Provide the public with the
  identity, quantity, location,
  and properties of hazardous
  substances in the
  community as well as data
  on annual releases of
  certain chemicals into the
  environment

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PAGE 2
"It's not over in October."
Title m sets October 17,
1988, as the deadline for
each LEPC to complete a
comprehensive emergency
plan. However, October 17
is not the end of the planning
process; it is thejfrst step.
Each plan must be revised
and updated annually. The
SERCs must review and
make recommendations for
any revisions. Other LEPC
activities such as managing
the information coUectedfrom.
facilities and making it
available to the public,
coordinating response
activities with other planning
districts, conducting
exercises based on the plan,
training,  and maintaining the
dialogue with the community
and industry to improve the
safety of facilities and
preparedness for accidents
are ongoing. In short, as far
as LEPCs and the law are
concerned, it's not over in
October.
 Getting Off to the Right Start:  Outreach Makes
                      It Work

Title HI introduced a new relationship among govern-
ments at all levels, the private sector, public organiza-
tions, and the general public. Each group has a differ-
ent, but equally important role in making emergency
planning and community right-to-know work. The goal
is national chemical safety and the value to a commu-
nity can be very real.

The need for outreach ~ establishing and maintaining
two-way communication -- is a responsibility everyone
shares. The need for outreach in this program is un-
precedented because the audience is so diverse. For
example, states and localities need support to imple-
ment the law; industry needs to understand how and
when to comply; the public needs to be aware of the
kinds of information available and what it might mean
to them. Everyone has a role and the LEPC is critical to
the success of the  program.
                A Role for Everyone

     The federal role is to provide national leadership,
     guidance, technical assistance, access to data
     about chemical releases, and training through
     the states.

     The states, through the SERCs, provide leader-
     ship to ensure that an emergency planning and
     implementation structure is developed and to
     provide-training and technical assistance to
     communities.

     The local role is to work with LEPCs in actually
     carrying out emergency planning, community
     right-to-know, and response functions.

     Industry complies with Title III reporting require-
     ments and participates actively with LEPCs and
     SERCs to ensure that Title IE works.

     The public can get involved by increasing their
     awareness and understanding of chemical risks
     and  supporting actions to increase public safety
     and  protection of the environment.

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                                                                              PAGES
               The LEPC  Is the Key

Although EPA, FEMA, other federal agencies, state gov-
ernments, and industry are cooperating with local com-
munities to make Title in work, the ultimate responsi-
bility for the success of the program rests with you at
the local level. Because you are most familiar with your
community, you are in the best position to develop
plans to prevent emergency situations, to ensure appro-
priate responses if they occur, and to become the forum
in your community for discussions and decisions on
hazardous substances.
The SERCs appoint LEPCs and have the responsibility
for coordinating and supervising LEPC activities, but it
is up to you at the local level to make the LEPC work.
The mission of your LEPC is:

    To develop a comprehensive emergency plan for
     your community by October 17, 1988, and keep
     the plan up-to-date.  To be effective, planning
     must be an ongoing activity.

    To receive information about accidental chemical
     releases.

    To collect, manage, and provide public access to
     information on hazardous chemicals in your
     area.

    To educate the public about risks from accidental
     and routine releases of chemicals and work with
     facilities to minimize the risks.

The first three responsibilities are mandated by Title III;
the last is not included in the letter of the law, but
rather in its spirit. The right-to-know provisions of the
law will be of limited value to the community unless the
public is given the means to understand the information
and its implications. The ability of your LEPC to im-
prove the safety of your community will be far greater if
you have an informed and active citizenry to support
your activities.
 "Because you are most
familiar with your
 community, you are in
 the best position to
 develop plans to prevent
 emergency situations."
 SERCs designated
 emergency planning districts
for which LEPCs have been
 named. Thirty-Jive states
 used existing local
 government subdivisions
 (counties, municipalities, or a
 combination of the two). Ten
 states and one territory
 named existing regional
 response or planning
 districts. Five states
 designated the entire state
 as the planning district
 Overall an estimated 4,000
 districts have been
 designated across the
 country. Some states have
 allowed localjurisdictions to
 consolidate into multt-
jurisdictional districts to form
 their LEPC.

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PAOE4
         HUM
          mil
 "The SERC should serve
 as your link to state
 agencies."
 All states as well as the
 District of Columbia, Puerto
 Rico, and American territories
 have established SBRCs.
 Some states, such as
 Nebraska and Mississippi,
 have named a single state
 agency to act as the SERC.
 Others, such as Montana,
 have drawn members from a
 number of state agencies.
 Many states have included
 local officials, industry
 representatives, and the
 public as well as state
 officials; for example, the
 OhtoSERChas 14
 representatives of state
 agencies and 17 members
 drawn from industry, public
 interest groups, and local
 officials.
              Work with Tour SERC

You should look upon your SERC as a resource that
can provide support and might save you time and
money. The law requires SERCs to provide coordination
and oversight of LEPCs; the SERC should serve as your
link to state environmental and health agencies as well
as to state law enforcement and emergency manage-
ment offices. These agencies may be able to provide
technical assistance and guidance.  The SERC is also
your link to the Regional Response Team (RRT), which
is available to review plans from state priority areas and
provide information on federal assistance during an
emergency.

Your SERC may be able to provide you with some of the
following kinds of assistance:

    Planning assistance,  plan testing, and training;

    Information on sources of funding;

   A storage/retrieval location for computerized infor-
     mation, as well as other information management
     assistance;

    Contact with statewide and possibly national
     industry groups that can help you with information
     and expertise;

    Workshops that focus on Title in issues;

    Data on chemicals being transported on interstate
     and state highways that pass through your plan-
     ning district; and

    Literature that can be used to inform the public
     about Title in.

Because the SERCs will be reviewing all LEPC plans,
they will have information and ideas they can pass on to
you. Working with your SERC at an early stage will
be to your benefit.

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                                                                               PAGES
                 Knowing the Law

Title III is a complex law that places a number of re-
quirements on you, your SERC, facilities, and EPA. To
carry out your role, it is important that you understand
the law.

One part of Title HI that has confused some LEPCs in-
volves the various information reporting requirements.
You will receive different kinds of information from fa-
cilities about chemicals on several lists. This informa-
tion must be made available to the public through the
LEPCs and SERCs. Facilities may also give you infor-
mation that they are required to submit only to the
SERCs and EPA.  The following is a summary of the
Title HI reporting requirements.

   Emergency Planning fsection 3031. Facilities that
     have one or more of 366 extremely hazardous
     substances in quantities above limits set by EPA
     (threshold planning quantities) must notify you
     that these substances are present. Substances are
     included on the list of extremely hazardous sub-
     stances because  they are acutely toxic, that is,
     they can cause death or injury with a brief expo-
     sure.  In addition to facilities that handle these
     chemicals, Title in requires you to identify any
     other facility that could pose a risk or be at risk
     (e.g., hospitals or facilities that handle explosives
     or flammable substances). A comprehensive plan
    will include all facilities and transportation routes
    that you judge to pose a threat even if they do
    not handle extremely hazardous substances.

  Emergency Notification (section 304). You and the
    SERC will receive emergency information (e.g.,
    identity of the substance released, the quantity re-
    leased, health effects) about accidental releases of
    chemicals on the extremely hazardous substances
    list, as well as substances covered by Superfund,
    the hazardous substance cleanup program.  As
    soon as possible  after an accident, the facility must
    submit a written follow-up notice with additional
    information.
A complete copy of the law is
available in the United States
Code (42 USC 11001 etseq.)
and can be obtatnedfrom the
federal and state govern-
ments, most attorney's
offices, many public libraries.
and all law libraries.

EPA, the states, industry,
and public interest groups
have published a number of
fact sheets and guides to
Title HI requirements.
Videotapes and slide shows
are also available. See
"Information Resources" at
the end of this booklet for a
list of some of the available
brochures and information on
how to obtain them.
If you need ideas on how to
organize your LEPC, what to
include in your plan, and
how to arrange your plan,
consult the Hazardous
Materials Emergency
Planning Guide (NRT-1),
published by the National
Response Team tnMarch
1987. NRT-1 contains a
sample plan outline as well
as we key elements that
should be included in your
plan.  (See "Information
Resources" at the end of this
booklet for Information on
obtaining NRT-1.)

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PAGES
Tennessee is making data
submitted under Title 2ZT
easier for its LEPCs to use.
The Tennessee Emergency
Management Agency CIEMA)
has developed its own format
for the MSDS information
submitted under Sections
311 and 312. The
reorganized data is divided
into 3 general areas:

  UBaseline  data (facility
   and contact, localjfre
   department. TEMA
   region);

  M Compliance data; and

  U Chemical lists.

The reorganized data is
provided to the LEPCs.
TEMA has also developed a
tracking system for data
submitted under Sections
302, 304, and 313. To help
the LEPCs understand the
data, how it can be obtained.
and how it can be used for
planning, TEMA has held
workshops for LEPCs.
  Hazardous Chemical Reporting (sections 311-121.
    Each LEPC, SERC, and local fire department
    will receive information on hazardous chemicals for
    which the Occupational Safety and Health Admini-
    stration (OSHA) requires industry to have Material
    Safety Data Sheets (MSDSs). MSDSs include the
    basic characteristics of the chemical involved; this
    information can be used for emergency planning,
    response, and other public purposes. Under sec-
    tion 311 faculties must submit either the MSDS
    for each chemical or a list of MSDS chemicals.
    Under section 312 each facility must submit an in-
    ventory form that includes general information on
    the quantity and location of OSHA-regulated haz-
    ardous chemicals it handles and stores.

  Toxic Release Inventory (section 3131.  EPA head-
    quarters and the states will receive information
    about total annual releases to air, land, and water
    of over 300 toxic chemicals and 20 chemical
    categories listed under section 313 of Title in. EPA
    is required to make this information available to
    the public through a data base. In general,  the
    chemicals on the section 313 list are those that are
    toxic, are suspected carcinogens, or are capable of
    having a significant adverse effect on the environ-
    ment. Although industry is not required to submit
    the release information to your LEPC, some  com-
    panies may provide it to you directly. You should
    request it from the state or facilities or access the
    EPA data base. This information will assist you in
    developing a full picture of chemical hazards for
    your community and for individual facilities. The
    public may request it and you can anticipate ques-
    tions on this information.

In summary,  your plan must include facilities that have
extremely hazardous substances. You will receive infor-
mation about other chemicals.  Together these four
reporting requirements provide a broad picture of haz-
ardous chemicals present in your community. The infor-
mation you receive will help your planning and make it
easier for you to make decisions about the potential
hazards posed by these chemicals in your community.

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                                                                            PAGE?
              Get Everyone Involved

Congress required that LEPC meetings and decisions
involve public participation and that you provide the
public with access to the information you receive.  The
right-to-know provisions of Title III are meant to give the
LEPC and the public information about chemical haz-
ards and to involve the entire community in a process of
protecting public safety and health and the environ-
ment.

LEPCs are to be broad-based and include, at a mini-
mum, representatives of elected officials, law enforce-
ment, emergency management, fire service, emergency
medical services, health, local environmental and trans-
portation groups, hospitals, the media, community
groups, and owners and operators of the facilities cov-
ered under Title III.  The average LEPC has about 15
members.

Regardless of the number of members, you must be
sure that the LEPC membership represents the entire
community, particularly those people who will have to
make the plan work in an emergency. Your plan is
more likely to be carried out successfully if the people
who have to use it have a voice in creating it. In addi-
tion, wide-ranging community involvement will increase
the credibility of the plan and improve community co-
operation in an emergency.
               Leadership Is Critical

The LEPC chairperson can be any LEPC member. Some
LEPCs have chosen political leaders; others have ap-
pointed representatives from public safely departments,
emergency management agencies, environmental agen-
cies or groups, industry, or civic organizations.  Impor-
tant factors to consider are the leader's availability,
credibility, management and communications skills,
commitment to the process, and the degree of respect
the person has from other members and the commu-
nity.

Because LEPC members have diverse backgrounds and
perspectives, conflicts could arise. Members should see
their role as providing their particular expertise, rather
than representing a specific organization.  For example,
the media representative does not represent a newspa-
per or broadcast station looking for a story, but rather
is there to ensure that communications issues are ad-
dressed adequately.
"The LEPC membership
represents the entire
community."
The Baytown, Texas, LEPC
createdjotnt indusiry/nan-
industry co-chairs far the
LEPC as a whole and for
individual subcommittees.
The LEPC wOl include
representatives from Ihe
following:

Petrochemical industry
Baytown Health Department
Houston Emergency
  Management
Fire Department
Police Department
American Red Cross
City Safety Coordinator
City Public Works /
  Engineering
Office of the state senator
Baytown Emergency
  Management
Baytown City Manager
Baytown newspaper
Local radio station
Medical community
School district
Women's Club
Chamber of Commerce
Baytown Emergency Services
Environmental groups
Private citizens

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PAGES
"Subcommittees allow
members to specialize
and help move the
process forward."
The Racine, Wisconsin, LEPC
has established 7 standing
subcommittees:

 Medical and Community
   Health
 Fire Service
 PubUc Information and Media
   Relations
 JMW Enforcement
 Fac&ittes
 Liaison (with SERC, EPA)
 Border (for cross-county
   planning)
             Appoint Subcommittees

Large LEPCs have found that dividing the work among
subcommittees can facilitate planning and data man-
agement. Subcommittees allow members to specialize
and help the process move forward more quickly be-
cause you can work on several areas at one time. You
might appoint subcommittees for the following tasks:

   Gathering and reviewing existing community and
    facility plans;

   Making a list of existing response equipment avail-
    able in the community;

   Identifying financial resources;

   Coordinating with neighboring LEPCs and the
    SERC;

   Conducting a hazards analysis;

   Managing information (e.g., MSDSs); and

   Replying to citizens' requests for information.

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                                                                            PAGE 9
              Encourage Compliance

Businesses that manufacture, process, or handle any
hazardous or toxic chemicals in quantities above EPA's
limits must comply with Title HI.  However, small compa-
nies that use hazardous substances and perhaps even
larger businesses that do not usually think of themselves
as involved with chemicals may need your help. Be-
cause some small businesses may not be aware of Title
IE, let alone that they are subject to its provisions, one of
your first jobs will be outreach  getting the message
to small businesses, as well as large companies, to
encourage their compliance.

Many business owners belong to organizations such as
the Chamber of Commerce, Rotary, and local manufac-
turers' associations. Speaking to meetings of these
groups and using their newsletters can help get the
message out inexpensively. If you, your SERC, local in-
dustries, or trade associations have printed brochures
about Title in, you may be able to include the brochures
in a newsletter mailing. Some LEPCs have sent notices
to industry in utility bills.  You may also want to have
your SERC contact statewide trade associations and use
their newsletters, meetings, and trade shows  to reach
particular groups of small businesses that might not be
aware of Title m.

Local governments may also be covered under Title HI.
For example, municipal water and sewage treatment
plants may use chemicals that are listed as extremely
hazardous substances. Transit authorities may also'
handle extremely hazardous substances in sufficient
quantity to be covered by Title III. You may be able to
use the appropriate representatives on your LEPC to
ensure that such local agencies are aware of the require-
ments.
"Small companies that
use hazardous sub-
tances may need your
help."
Reaching the back shop
electroplating plant with, its
5,000-gaUon dip tank of
sul/urtc acid was the concern
of Bob Straw, chairman of
the York County,
Pennsylvania, LEPC. Straw
included a member of the
county manufacturers
association on the LEPC to
serve as a link to these small
businesses. He also
appointed the county
agricultural agent to help the
committee contact farmers.
Through these people. Straw
was able to put notices about
Title HI requirements in
newsletters from the
manufacturers' association
and the local Chamber of
Commerce.
                                                             | York County j^X

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 PAGE 1O
Title in (section 303) requires
that apian include at least the
following:

IJFadllHes that have extremely
  hazardous substances
  (EHSs), routes used to
  transport EHSs, and other
  facilities contributing to or
  subject to risks;
 2.Methods and procedures to
  be followed by facilities and
  responders during an
  incident:
 S.DeslgnaUon of community
  and facility emergency
  coordinators;
 4.Proceduresfor effectively
  notifying the community of a
  release;
 SMethodsfor determining the
  occurrence of a release and
  identifying areas likely to be
  affected;
 6.Bmergency  equipment and
  facilities in the community
  and at coveredfacUitles;
 7.Evacuation plans;
 S.Training programs; and
 9.Methods and schedules for
  testing the emergency plan.

In addition, plans should
clearly identify a chain of
command during response
actions and provide for
ejfective communications
among those who respond.
See NRT-1 for a detailed
discussion of elements to be
included in an emergency
plan.
              Draw on Existing Plans

Existing plans developed specifically for your area may
include information about issues, such as transporta-
tion routes, that you will need to consider. You can
reduce your planning load by "piggybacking" on these
plans; that is, you can use the information and ideas in
existing plans as a basis for developing elements of your
plan. Before using Information from other plans, how-
ever, be sure it is up-to-date and relevant to your plan.

   If your area has an "all-hazard emergency opera-
     tions plan" funded by FEMA, or other state or local
     plans, you may be  able to integrate your Title in
     plan Into the overall plan as an appendix  (see
     NRT-1).

   If your area is near a nuclear power plant, check
     existing plans for traffic control, evacuation, or
     sheltering provisions; many such provisions may
     be applicable to planning for chemical emergen-
     cies.

   If hospitals In the area already have mass casualty
     plans, you can probably incorporate portions of
     these.

   If your fire departments have mutual aid agree-
     ments with other jurisdictions, you will probably
     want to integrate these into your Title in plan.

   If local facilities have plans developed under the
     Chemical Manufacturers Association's Community
     Awareness and Emergency Response program
     (CAER), you may be able to incorporate these.
Developing an emergency plan is time-consuming.
Some possible short-cuts, such as using a "model
plan," are not only contrary to the intent of Title in
planning but more importantly will reduce effective
local preparedness in the long run.  "Model plans" have
generalized language appropriate for any planning
district, with blank spaces in which a LEPC can insert
specific local information. Using a model plan does not
encourage the active participation of all LEPC members
in the planning process and does not recognize unique
local issues.

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                                                                              PAGE 11
                    Set Priorities

Title III sets October 17, 1988, as the deadline for each
LEPC to complete a plan. While you must have a first
plan by this date, you may not have a comprehensive
plan completed by the deadline.  As you work toward
the October 17 deadline, you will need to set priorities.

To determine which facilities you should plan for first,
do a hazards analysis in order to identify those that
pose the greatest risk. These  can be facilities that
handle large quantities of extremely hazardous sub-
stances, facilities that have had serious releases in the
past, or facilities that are close to highly populated
areas. Then focus your planning efforts on the high
priority hazards.

Technical Guidance for Hazards Analysis - Emergency
Planning for Extremely Hazardous Substances (pre-
pared by EPA, FEMA, and the U.S. Department of
Transportation (DOT)) provides technical assistance to
LEPCs to assess the hazards related to potential air-
borne releases. (See "Information Resources" at the end
of this booklet for information on how to obtain this and
other documents mentioned.)

You can follow the guidance to decide which hazards
pose the greatest risk and develop plans for high prior-
ity hazards before the October deadline.  You should
then expand the plan, where needed, to cover the lower
priority hazards in your area.  The exercises or simula-
tions you run to test your community's ability to re-
spond to an emergency and your  annual plan reviews
will provide the basis for revising the plan and for devel-
oping standard operating procedures for responders.
                                                           "Develop plans for high
                                                           priority hazards before
                                                           the October deadline."
A hazards analysis is
essential to developing a
plan. As used in NRT-1 and
In the Technical Guidance the
term "hazards analysts"
includes three steps:

Hazards Identification:
determining the identity,
location, and quantity of
hazardous chemicals, and
the hazards they pose.

Vulnerability Analysis:
determining the areas,
populations, and facilities
that may be vulnerable to
harm if a release occurs.

Risk Analysis:  determining
the likelihood of a release
and the severity of the
consequences.

A community hazards
analysis should not be
confused with facility risk
assessments or hazard
evaluations, both of which
involve formal techniques
requiring technical experts.

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PAGE 12
"Some of your best
sources of help are the
organizations in your
community that deal
with emergencies."
InPampa, Texas, thejfre
department is expanding an
existing program in which
every business in the city is
inspected annually forJfre
hazards. During the
inspections, a hazardous
materials response team
member surveys thefacilUy
to determine reportable
chemicals, informs the owner
or operator about Title HI,
and assists with reporting
procedures. This not only
helps planning, but also
enhances the departments
relations with the public.
The Butler, Kansas, LEPC
found help in an unlikely
place: the state prison honor
camp. A welL-educated
inmate was working as ajlle
clerk in the Health
Department The LEPC got
him interested in Tide flT and
he directed the county's
hazardous materials survey.
                       \
           I Butler)
    Make the Best Use of Available Resources

Because LEPC members are likely to have full-time
jobs, you will need to be creative in your use of commu-
nity resources to help cany out the LEPC's functions.
Many LEPC members will be able to call upon their or-
ganizations' staff for some support functions.  Commu-
nity groups, volunteer organizations, environmental and
public interest groups, and industry may be able to
provide administrative and secretarial support. Techni-
cal support may be available from science and engineer-
ing faculties at local colleges or high schools, from
industry, or from retired scientists and engineers.

Some of your best sources of help for planning and
outreach are the organizations in your community that
deal with emergencies. For example, fire departments
can help analyze hazards and assess potential risks;
police departments may have information about pos-
sible evacuation routes; the! local emergency manage-
ment agency can provide information on existing emer-
gency procedures.

LEPC members represent a wide range of community
agencies and organizations. Maximize your capabili-
ties by using the LEPC members as contact points to
identify people within the community who can provide
you with specific help.

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                                                                             PAGE 13
       Talk with Neighboring Communities

Consult with your neighboring LEPCs, especially if
you have common risks and concerns.  In an emer-
gency, you may have to call on them for help or they
may call you. In many cases, plans must include sev-
eral communities to be effective. Consider the need to:

   Identify whom to call in other planning districts if
    you need help in an emergency;

   Ask them how they are funding their activities:

   Identify available response equipment and person-
    nel;

   Negotiate procedures for mutual assistance for
    emergencies that cross boundary lines;

   Coordinate your hazards analyses:

   Coordinate your review of transportation routes:
    and

   Investigate sharing computers or other resources.

Each LEPC should consider its neighboring LEPCs as
partners and resources. They share your problems;
working with them may help you find common solu-
tions.
"Consider your
neighboring LEPCs as
partners and resources."
When the hazards analysts
subcommittee of the Prince
William County, Virginia,
LEPC needed information on
transportation routes, one
subcommittee member
suggested that neighboring
LEPCs might have
information because the
types and quantities of
hazardous materials
transported on the interstate
highway through Prince
WOliam County would be
roughly the same on other
segments of the highway.
After he began asking other
planners in the area for  ,
information on the
availability of transportation
data bases for the highway,
it was discovered that the
State of Virginia, had such a
data base.

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PAGE 14
The Chemical Transportation
Emergency Center
(CHEMTREC), operated by
CMA, provides information
and assistance to first
responders at the scene of a
chemical release.
CHEMTREC contacts the
shipper or producer of the
materialfor more detailed
information, including on-
scene assistance when
feasible. CHEMTREC
provides a digital
transmission of the chemical
report, which includes data
on the hazards, protective
actions needed, mitigation
techniques, and first aid. For
emergencies involving
chlorine, a call to CHEMTREC
will activate the mutual aid
program operated by the
Chlorine Institute, the
Chlorine Emergency Plan.

The initial process of data.
collection creates a dialogue
between the LEPC and
chemicalfadlities that may
lead to prompt safety
results. The Washington,
DC, LEPC has met with an
official of each industry that
uses extremely hazardous
substances within the city.
Discussions led to
immediate commitment by
one industry to reduce the
amount of ammonia on site.
The city's sewage treatment
plant will reduce its storage
of chlorine by 60 percent
                  Industry's Role
Title HI requires each facility owner or operator with
extremely hazardous substances to promptly provide
you with any information you need to develop and im-
plement the emergency plan.  Title III also requires
these facilities to designate a facility emergency coordi-
nator. Experience has shown that many facility emer-
gency coordinators will be eager to cooperate with you.
They can provide:

   Technical experts;

   Community awareness programs;

   Training and safe handling instructions;

   Access to non-emergency chemical information
    through the Chemical Referral Center (see
    "Information Resources");

   Computer assistance; and

   Information about transportation routes.

Facility hazard information, safety audits, and emer-
gency plans are a good starting point for information-
gathering and planning.

The Chemical Manufacturers' Association (CMA), a
trade association for chemical companies, developed the
Community Awareness and Emergency Response
(CAER) program to encourage chemical plant managers
to take the initiative in opening a dialogue and cooper-
ating with local communities to develop integrated
hazardous materials response plans. Even if you have
no CAER facilities in your distrct, CAER resources (e.g.,
"CAER Program Handbook") can be useful to LEPCs.
See "Information Resources" at the end of this booklet
for information on obtaining CMA publications.

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                                                                            PAGE 15
              Managing Information

Title in requires local facilities to give you information
on a variety of substances. You are probably already
facing the problem of how to cope with all this material.
As you develop strategies to deal with the material, keep
in mind that:

    You must have procedures for making the material
     available to the public:

    You are required to designate an information coor-
     dinator; and

    You must be able to access the information quickly
     in an emergency.

LEPCs are using a number of approaches to organize
the Title in materials. Some LEPCs are able to manage
the data manually using the LEPC members or staff.
Other LEPCs manage the data using their own comput-
ers or those of other agencies with systems and infor-
mation management techniques already in place.

If your LEPC wants to use a computer to handle the
information but does not have the funds to buy one, you
may be able to enlist the help of your local fire depart-
ments, local governments, state agencies, or local busi-
nesses. They may have computers, software, and staff
who can help organize the data.  In the case of fire
departments, or other government agencies, they may
already have data bases that can be expanded to in-
clude your information.

One method of controlling the amount of data you have
to handle is to encourage facilities fulfilling MSDS re-
quirements to supply a list of the chemicals for which
MSDSs are required, rather than to supply the MSDSs
themselves. You can then request MSDSs on those
chemicals that are of particular concern. If you need
more information on certain chemicals, you can draw
on a number of data bases maintained by federal agen-
cies (see "Information Resources") and on CMA's Chemi-
cal Referral Center (1-800-262-8200), which provides
access to chemical information in non-emergency situ-
ations.
For some LEPCs, developing
a system for accessing
information during an
emergency witt be challeng-
ing. Areas having one or two
facilities may be able to store
files on emergency response
vehicles for now. However,
communities receiving large
volumes of Information will
need other approaches. A
number of communities are
exploring computer systems
or asking facilities to set up
lock boxes on site that
contain the information about
thefacility.
Kansas is planning to set up
an integrated computerized
data base to handle all Title
HI information submitted in
the state. LEPCs will be able
to use the system to gain
access to chemical data and
to feed it to responders.  The
state also hopes to make the
information available on
computer disks for libraries
so the public wUl be able to
check on localfacUittes if
they wish.

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PAGE 16
"Educating the public
about risks and
involving them in
decisions are important
challenges for LEPCs."
TheSERC and local
industries may be able to
help you. with risk
communication. EPA has
published a short pamphlet,
Explaining Environmental
Risk, which can help you
deal with both the public and
the press, and Technical
Assistance Bulletin #4. which
summarizes the results of a
conference on risk
communications. CMAand
the New Jersey Department
of Environmental Protection
have also published material
on this subject
         Responding to Public Requests

Title in gives the public the right to obtain copies of
information the facilities submit to you. You should
keep this in mind when you develop methods of organiz-
ing information. For instance, you may want to file the
data by facility for emergency purposes, but the public
may be more interested in obtaining information on all
the facilities in the area using a particular chemical.
Reserve some of your LEPC resources for responding to ,
public requests for information.

Simply providing the information may not be enough;
you may also have to help the public understand the
risks posed by certain substances and certain situ-
ations. Although it has often been left to technical
experts, educating the public about risks and involving
them in decisions about what is an "acceptable" level of
risk are important challenges for LEPCs. The LEPC, as
the focal point for public discussion, can help reach a
common understanding of the risks in the community
and can help communicate this information to the
general public.

Sometimes, anger about what the public perceives as
risky situations arises not so much from the actual risk,
as from people's feeling that they have no control over
what is happening to them.  You can mitigate this by in-
cluding the public in the decision-making process from
the beginning.

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                                                                            PAGE 17
                      Liability

Check with your SERC about your state law and ask
about liability considerations and protection. Some
LEPCs and individual LEPC members have expressed
concern that they might be held legally liable if they
approve an emergency response plan that proves to be
inadequate during an accident.  SERCs are generally
considered state agencies and are, therefore, covered by
the state's immunity provisions. Some states have
extended this immunity to LEPCs through laws or
through legal decisions. Others have provided liability
coverage for LEPCs.
             Funding Tour Activities

When Title HI was passed, Congress did not provide
funding for most of the required activities.  Some states
and communities have appropriated general revenue
funds for LEPC activities; others are relying on imple-
mentation fees and existing state agency budgets.  Be-
cause states have limited resources, each LEPC must
find the means for achieving its goals. Some LEPCs will
do their work with little additional money.  Your LEPC
members may already be donating their time.
              LEPCs and Computers

You may have decided that the right computer could
help you with your LEPC tasks. Available software can
provide you with a way to store information submitted
by facilities, conduct hazards analyses, map hazards in
your community as part of your planning process, and
store information on the properties and health risks
posed by chemicals in your area. Appendix K of the
Technical Guidance for Hazards Analysis includes
information on computer applications for emergency
response planning.

Virginia has obtained a
commitment from the State
Division of Risk Management
to provide insurance
coverage for LEPC members
for any claims made against
them as LEPC members.
Some LEPCs are tapping
local businesses and
agencies for cost-saving
services and donations.
Local colleges and
universities may be a source
of volunteer data collectors,
planners, and programmers.
EPA has made chemical data
bases available to states, the
public, and private sector
computer firms. EPA has
also collaborated with the
National Oceanic and
Atmospheric Administration
(NOAA) to develop the
Computer-Aided
Management of Emergency
Operations (CAMEO) program
to help emergency planners.

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PAGE 18
"Maximize the impact of
training programs and
other information
programs."
In FY" 1987 Kansas received
$51,000 and California.
$334,000 under Title Iff. All
states received some of the
federal training grantjunds.
Kansas added $10,000 in
state funds to begin separate
training seminars forLEPC
members andjfrst
responders. These funds are
being admisistered by FEMA.
Check with your SERC to
learn how to apply for
federalfunds and to see
what state training programs
may be available to you.
 "LEPCs have the
 authority to initiate
 legal actions."
                     Training

Title HI mandated federal emergency training courses to
emphasize hazardous chemicals. Congress authorized
$5 million a year for  1987 through 1990 for Title in
training funds to help state and local governments im-
prove emergency planning, preparedness, mitigation,
and response. Over the past two years, several hundred
planners from around the country have attended week-
long emergency planning training sessions at FEMA's
Emergency Management Institute in Emmitsburg, Mary-
land. These courses,  sponsored by FEMA, EPA, and
DOT, are designed to train planners so they will be able
to return to states and communities to instruct others.
Consult your EPA and FEMA Regional Office for feder-
ally sponsored training courses.

One way to maximize the impact of training programs
and other information programs is to coordinate them
with other LEPCs and with industry.  For example, if
your LEPC arranges a meeting with experts on transpor-
tation planning or hazards analysis, invite your neigh-
boring LEPCs to join you. If you hear that another LEPC
is setting up a seminar that interests you, ask to partici-
pate. By doing this, you will create a network of contacts
and mutual aid that will benefit everyone.
                   Enforcement

Section 325 of Title El addresses the penalties for failure
to comply with the requirements of this law. Civil and
administrative penalties ranging from up to $ 10,000-
$75,000 per violation or per day per violation can be as-
sessed to facilities that fail to meet the emergency plan-
ning, emergency notification, community right-to-know,
toxic chemical release,  and trade secret reporting re-
quirements.

Also, criminal penalties of up to $50,000 or five years in
prison may be given to any person who knowingly and
willfully fails to provide emergency release notification.
Penalties of not more than $20,000 and/or up to one
year in prison may be given to any person who know-
ingly and willfully discloses any information entitled to
protection as a trade secret. In addition, section 326
allows citizens to initiate civil actions against EPA,
SERCs, and the owner or operator of a facility for failure
to meet certain requirements of Title HI. LEPCs have the
authority to initiate actions under the provisions for
state and local suits or under the citizen suit provisions
of section 326.

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                                                                           PAGE 19
                                 CHECKLIST*


  Q Make sure your LEPC membership is broad-based and representative of your com-
    munity.                             ',

  Q Develop a plan for financing your LEPC.

  Q Organize your LEPC to use available resources such as trade and volunteer organi-
    zations.                             '

  Q Develop a public education and information program to:

        Involve the public in the planning process;
        Respond to requests for inforrnatioii; and
    -   Help the public understand the risks.

  Q Take steps to reach small businesses in your community.

  Q Organize your LEPC into functional subcommittees to make the tasks more manage-
    able.

  Q Include all appropriate agencies, departments, or organizations in the process of
    developing or reviewing the emergency !plan.
                                        i
  Q Complete a hazards analysis that:     '
                                        i

    -   Identifies the types and locations of hazards;
    -   Identifies the vulnerable zones and human populations at risk; and
    -   Assesses the likelihood of an accident and the severity of consequences to
        humans.

  Q Identify available emergency equipment, personnel, and facilities:

        In the community;
    -   At facilities; and
    -   In the region.

  Q Identify (by title or position) the one individual responsible for each participating
    organization during a response, as well as the one individual responsible for each
    major response function and service.  :

  Q Develop a program to:

    -   Train emergency personnel to carryi out your plan; and
    -   Test the plan and revise it.

  Q Obtain the Toxic Release submissions for your area in order to develop a full
    picture of chemical hazards for your community and for individual facilities.

  Q Review all chemical information you receive for your area and work to reduce
    risks.                               i

Tor an extended list of criteria, see NRT-1.

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        PAGE 20
                               INFORMATION RESOURCES
       EPA has a number of brochures that you may find helpful. For technical and regulatory
         assistance on Title HI call: (800) 535-0202 (or 202-479-2449 in Washington DC and
         Alaska). EPA requests that you do not call to obtain documents; write:

                   Emergency Planning and Community Right-to-Know Information
                              U.S. Environmental Protection Agency
                                           OS 120
                                         401 M St., SW
                                    Washington, DC 20460.
       FEMA can provide information on training. FEMA and the US Department of Transpor-
         tation (DOT) sponsor the National Hazardous Materials Information Exchange (HMEX).
         For HMIX, call 1-800-752-6367 (in Illinois call 1-800-367-9592). For computer access,
         call FTS 972-3275 or 312-972-3275. A bulletin board with information from and for
         LEPCs will soon be available from HMIX. For information on training, write:

                             Federal Emergency Management Agency
                                      Federal Center Plaza
                                         500 C St., SW
                                     Washington, DC 20472
                                        (202) 646-2969.
        CMA. The Chemical Manufacturers Association, a trade association for chemical
        companies, publishes a number of booklets which you may buy. For a list of
        materials available from CMA and the costs, write:

                                             CMA
                                        2501MSt., NW
                                     Washington. DC 20037
                                        (202) 887-1255.
       The Working Group on Community Right-to-Know is a coalition of public interest
         and environmental groups, which provides packets of material related to Title III. The
         coalition requests donations to cover the cost of copying and mailing.  For information,
         write:

                           Working Group on Community Right-to-Know
                                         218 D St., SE
                                     Washington, DC 20003
                                        (202) 544-2600.
_

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                                                                            PAGE 21
                       INFORMATION RESOURCES
The Center for Emergency Response Planning (CERP) is a consortium of industrial
  union departments, AFL-CIO, and the Workplace Health Fund.  CERP is involved in
  planning, information dissemination, and research. CERP can provide:  educational
  resources for workers, labor officials, and community leaders; planning assistance to
  worker representatives on LEPCs; and general chemical information through unions.
  For further information, call:

                      Center for Emergency Response Planning
                              Workplace Health Fund
                                815 16th St., NW
                              Washington, DC 20006
                                  (202) 842-7834
The National Response Center provides a single, continuously staffed location that re-
  ceives and refers for action or investigation, all reports of environmental incidents
  throughout the United States. To report an incident, call:

                                 1-800-424-8802
The Agency for Toxic Substances and Disease Registry, a part of the Public Health Ser-
 vice, can provide health information and assistance in simulation design, training for
 health professionals, and emergency response. For further information, call:

                          Emergency Response, DHAC
                                 ATSDR (E-32)
                               1600 Clifton Road
                             Atlanta, Georgia 30333
                                (404) 639-0615

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PAGE 22
                         INFORMATION RESOURCES

             (See page 20 for Information on how to contact EPA, FEMA, CMA and
                     the Working Group on Community Right-to-Know.)
                 RESOURCE
                                        HOW DO YOU GET IT?
    a
     o
    p
        The law itself

        Title in Fact Sheet

        Using Community
        Right-to-Know:
        A Guide to a New Federal Law
EPA Title IH Section 313
Release Reporting Requirements

Chemicals in Your Community

Community Rlght-to-Know and
Small Business

Title HI Community Awareness
Workbook

Community Guide to Title HI

What Is the Emergency Planning
and Community Rlght-to-Know
Act?

Reducing the Risk of Chemical
Disaster: A Citizen's Guide to
the Federal Emergency Planning
and Community Right-to-Know
Act

Understanding Title III
(video)
         The Toxics Release Inventory
         (video)
SERCs, law libraries, many public libraries, EPA

EPA

OMB Watch
2001 O St., NW
Washington, DC 20036
202-659-1711

EPA


EPA

EPA


CMA


CMA

Working Group on Community Rlght-to-Know
                                       National Wildlife Federation
                                       Environmental Quality Division
                                       1400 16th St., NW
                                       Washington, DC 20036
                                       202-797-6800

                                       CMA
                               Color Film Corp.
                               Video Division
                               770 Connecticut Ave.
                               Norwalk, CT 06854
                               800-882-1120

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                                                                            PAGE 23
                       INFORMATION RESOURCES

           (See page 20 for Information on how to contact EPA, FEMA, CMA and
                   the Working Group on Community Right-to-Know.)
               RESOURCE
                                         HOW DO YOU GET IT?
1
E co
si
Title ffl List of Lists
EPA
     Hazardous Materials Emergency
     Planning Guide (NKT-1)

     Guide for Development of
     State and Local Emergency
     Operations Plans (CPG 1-8)

     Community Awareness and
     Emergency Response Program
     Handbook

     Computer-Aided Management of
     Emergency Operations (CAMEO)
      (software)
                              EPA, FEMA, SERCs
                              FEMA
                              CMA
                              CAMEO Data Base Manager
                              NOAA/Hazardous Materials Response Branch
                              7600 Sand Point Way NE
                              Seattle, WA 98115
                              (206) 526-6317
 a
 CO
     Emergency Management
     Handbook
Technical Guidance for
Hazards Analysis (EPA, FEMA,
DOT)

Computer-Aided Management of
Emergency Operations (CAMEO)
 (software)
     Hazard Assessments and Plume
     Mapping Documents for LEPCs
IAFC
1329 18th St., NW
Washington, DC 20036

EPA, SERCs
CAMEO Data Base Manager
NOAA/Hazardous Materials Response Branch
7600 Sand Point Way NE
Seattle, WA 98115
(206) 526-6317

Working Group on Community Right-to-Know
 .
EPl

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PAGE 24
                         INFORMATION RESOURCES

             (See page 20 for Information on how to contact EPA, FEMA, CMA and
                     the Working Group on Community Right-to-Know.)
                 RESOURCE
                                          HOW DO YOU GET IT?
  a
  o
  1
  43
  O
  8
  O
American Institute of Chemical
Engineers (AIChE)

Chemical Hazards Response
Information System (CHRIS)

Chemical Referral Center (CRC)

Integrated Risk Information
System (IRIS)
      Chemicals and Communities:
      Chemicals and Agriculture
                                     Call state or local chapter
U.S. Coast Guard
(202) 267-1577

CMA 1-800-262-8200

IRIS User Support
513-569-7254
(Note: IRIS Is designed for people with a basic under-
standing of toxicology and risk assessment.)

Working Group on Community Right-to-Know
  8
  i
Layperson's Guide to Reading
MSDSs
Massachusetts Department of Environmental Quality
One Winter St.
Boston, MA 02108
(617) 292-5993
  1
Section 313 Toxic Release
Inventory Reports
      Toxic Emissions
Title m Reporting Center
P.O. Box 70266
Washington, DC 20024-0266
Attn: TRI Public Inquiry
(202) 488-1501

Working Group on Community Right-To-Know

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                                                                          PAGE 25
                   INFORMATION RESOURCES

       (See page 20 for Information on how to contact EPA, FEMA, CMA and
               the Working Group on Community Right-to-Know.)
           RESOURCE
            HOW DO YOU GET IT?
LEPC Bulletin Board
State Emergency Response
Commissions  '

National Emergency Training
Center

Hazardous Materials Training
Manuals
Lending Library for Emergency
Responders (23 videos)
Call HMIX (FTS 972-3275; (312) 972-3275
in Illinois).

See list of SERCs telephone numbers following
this table.

FEMA
Fire Protection Publications
Oklahoma State University
Stillwater, OK 74078
(405) 744-5723

CMA
Explaining Environmental Risk

Preparedness and Prevention
Technical Assistance Bulletin #4
Improving Dialogue with
Communities
Risk Communication
Risk Communication,
Risk Statistics and
Risk Comparisons

Talk About Risk (video)
EPA

EPA
New Jersey Dept. of Environmental Protection
Division of Science and Research
Risk Communication
401 East State St., 6th Floor
Trenton, NJ 08625

Working Group on Community Right-to-Know
CMA
CMA
Review of Emergency Systems
Report to Congress
Section 305(b) Title III
SARA

Emergency Warning Systems
Guidebook
EPA
CMA

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PAGE 26
                        INFORMATION RESOURCES


            (See page 20 for information on how to contact EPA, FEMA, CMA and
                    the Working Group on Community Right-to-Know.)
                RESOURCE
                                               HOW DO YOU GET IT?
g
33
  &
      Guidelines for Hazard
      Evaluation Procedures
      Hazard Assessment and Plume
      Mapping
                                    AIChE
                                    345 East 47th St.
                                    New York, New York 10017
                                    (212) 705-7657

                                    Working Group on Community Rlght-to-Know
  8
 33
      Review of Emergency Systems
      Report to Congress
      Section 305(b) Title HI
      SARA
                                     EPA
 o
33
<  
So
       Evaluation Guide for Computer
       Applications:
       Appendix K, Technical
       Guidance for Hazards Analysis
       Preparedness and Prevention
       Technical Assistance
       Bulletin #5:
       Software Applicable to Title HI
                                     EPA
                                     EPA

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                                                                        PAGE 27
            STATE EMERGENCY RESPONSE COMMISSION
                         TELEPHONE NUMBERS
Alabama
(205) 834-1375
(205)271-7700

Alaska
(907) 465-2600

American Samoa
(684) 633-2331

Arizona
(602) 231-6326

Arkansas
(501) 562-7444

California
(916) 427-4287

Colorado
(303) 331-4880

Connecticut
(203) 566-4856

Delaware
(302) 736-3169

District of Columbia
(207) 727-6161

Florida
(904) 488-1472

Georgia
(404) 656-4713

Guam
(671) 477-7230

Hawaii
(808) 548-5832
Idaho
(208) 342-5888

Illinois
(217) 782-4694

Indiana
(317) 243-5176

Iowa
(515) 281-3231

Kansas
(913) 296-1690

Kentucky
(502) 564-8660

Louisiana
(504) 925-6113

Maine
1-800-452-8735

Northern Mariana
 Island
(670) 322-9529

Maryland
(301) 486-4422

Massachusetts
(617) 292-5993

Michigan
(517) 373-8481

Minnesota
(612) 643-3000

Mississippi
(601) 960-9973
Missouri
(314) 751-7929

Montana
(406) 444-6911

Nebraska
(402) 471-2186

Nevada
(702) 885-4240

New Hampshire
(603) 271-2231

New Jersey
(609) 292-6714

New Mexico
(505) 827-9222

New York
(518) 457-9996

North Carolina
(919) 733-3867

North Dakota
(701) 224-2111

Ohio
(614) 644-2260

Oklahoma
(405) 521-2481

Oregon
(503) 378-2885

Pennsylvania
(717) 783-8150
Puerto Rico
(809) 722-2173
(809) 722-1175

Rhode Island
(401) 277-3039

South Carolina
(803) 734-0425

South Dakota
(605) 773-3151

Tennessee
(615) 252-3300

Texas
(512) 465-2138

Utah
(801) 584-8370

Vermont
(802) 828-2286

Virgin Islands
(809) 774-3321

Virginia
(804) 225-2513

Washington
(206) 753-5625

West Virginia
(304)  348-5380

Wisconsin
(608)  266-3232

Wyoming
(307)  777-7566
                                                        &U.S. GOVERNMENT PRINTING OFFICE: 1989-626-114

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