903R93029
       A SURVEY TO MEASURE THE IMPACTS OF
         PUBLIC OUTREACH STRATEGIES ON
 COMPLIANCE WITH ENVIRONMENTAL REGULATIONS
                          By
                  Christine E. ^ustis
            through a National Network for
       Environmental Management Studies fellowship
                         For
                   Janet A.  Viniski
       Chief of the Education and Outreach Branch
            Environmental Protection Agency
       Office of External Affairs for Region III

                      August 1993
                                U.S. EPA Region III
                                Regional Center for Environmental
                                 Information
                                1650 Arch Street (3PM52)
                                Philadelphia, PA 19103
HM
263
.E97
1993

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                               DISCLAIMER
      The information contained in this report  is based  on
interviews,  research and publications  available to the  author.
The  opinions and assertions  contained  in the paper are  the
author's and not to  be construed as official or reflecting the
views of the U.S. EPA.
                                                            Regional Center tor FnvironmenUl Information

                                                                  I'S PPA Region [II

                                                                   1650 Arch St

                                                                 Philadelphia PA 19J05
                                            v l a* Center i'.>r i:nvir::;?T;cr.ta!
                                         ir::;l.;i,:L>hia, PA 10103

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                        Acknowledgements:

The author would like to thank Janet Viniski at the Environmental
Protection Agency for commissioning this study. She would also
like to acknowledge the help of everyone at the Region III office
of the EPA who helped develop the survey: William Toffel, Kurt
Eisner, Lori Kier, Stephen Field, Christopher Day, Carrie
Dietzel, Magdalin Adorno and Virginia Cairns. Plus management
support from Stan Laskowski, Richard Kampf, Mary Sarno, Thomas
Maslany, James Burke and James Hemby. She is also grateful for
the guidance of Dr. Lee Frost-Kumpf at The Pennsylvania State
University who helped conduct the statistical analysis.

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                     TABLE OF CONTENTS

     Acknowledgements   	i
  I. Executive Summary  	I
 II. Introduction  	3
    A. The Central Issue     	3
    B. The Key Questions     	4
III. Literature Review  	4
    A. Background on EPCRA   	4
    B. Previous Studies 	6
 IV. Methodology   	9
  V. Evaluation Design  	10
    A. The Variables	 10
    B. The Schematic Model   	11
    C. Method of Analysis    	12
 VI. Findings and Conclusions     	13
    A. Descriptive Statistics     	13
    B. Multivariate Analysis 	25
VII. Recommendations    	29
     Bibliography  	33
     Appendices:
     Appendix A: Tables and Charts
     Appendix B: Press Releases to Announce  EPCRA Initiative
     Appendix C: List of Publications Where  Releases Were Sent
     Appendix D; Survey Instrument and Data  control Log
     Appendix E; Codebook
     Appendix F; Questions and Answers Used  For  Survey
     Appendix G; Top Trade Publications Companies Named
     Appendix H; List of Abbreviations

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I. Executive Summary
     This study was commissioned by the United States
Environmental Protection Agency  (EPA) to determine if awareness
of environmental regulations influences compliance, and what
public outreach strategies are most effective in increasing
awareness. A telephone survey, which focused on The Emergency
Planning and Community Right-to-Know Act (EPCRA), was conducted
on 100 manufacturing companies in the six Mid-Atlantic states.
     The data show that 75 percent of the companies interviewed
had fewer than 60 employees and represented many types of
manufacturing industries.  In addition, 64 percent of the
respondents hailed from Pennsylvania.
     This survey produced significant statistical data which is
described in detail in the main report. Below are highlights of
some of the findings and conclusions. For an indepth analysis,
refer to Findings and Conclusions on page 13 and Appendix A for
Tables and Charts.
     * Long-term strategies such as continually publicizing
enforcement actions against companies are more effective than
one-time press releases. (See Table 12)

     * The majority of companies agree that press releases do act
as a deterrent but alone are not sufficient to enable companies
to comply with environmental regulations.

     * Companies are looking for more educational material from
the EPA on how to comply with environmental regulations.

     * Companies repeatedly asked for more plain English direct
mailings and easy to understand local seminars from the EPA,

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state and local agencies. (See Table 13)

     * There is a strong correlation between the size of a
company and its familiarity with EPCRA regulations; larger
companies tend to be more familiar with EPCRA than smaller ones.
(See Tables 3 & 4)

     * More than 73 percent of the respondents are somewhat
familiar or fully knowledgeable about EPCRA. (See Pie Chart 1)

     * Over 90 percent of respondents agree that better awareness
of EPA regulations increases compliance. (See Table 5)

     * When companies were asked what information sources they
use to keep them informed about environmental regulations, 77
percent cited a wide range of trade publications. (See Table 10
and Appendix G)

     *  Most companies use more than one information source to
keep informed about environmental news and information.
(See Bar Chart 2)

     * By utilizing five sources, the EPA could reach 86 percent
of these affected industries. When six sources are used the
number increases to 94 percent.  (See Bar Chart 2)

     * 29.2 percent of companies turn to their state
environmental agencies for advice. 16.7 percent turn to other
sources which include trade associations and chambers of
commerce. (See Table 11)
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     * Companies agree that the government should be primarily
responsible for informing them about environmental issues.
(See Table 11)

     * Companies are looking for more direct involvement from
local governmental agencies in informing them about regulations.

     * Companies recognize that they need help from the
government in better educating themselves.
Read on for more detailed information!

II. Introduction
     A. The Central Issue:
     How do manufacturing companies that produce toxic chemicals
learn about the EPA's regulations and what is the relationship
between how these companies learn about the regulations and how
they might comply with these regulations?
      In order to analyze this issue and determine viable
recommendations for improving public outreach strategies, it was
necessary to evaluate the effectiveness of the EPA's current
public outreach program. This was accomplished by conducting a
random telephone survey of 100 manufacturing companies throughout
the EPA's Region III, which includes Pennsylvania, Delaware,
Maryland, Virginia, West Virginia and the District of Columbia.
     This report contains the results of this survey, including
descriptive statistics and a preliminary multivariate analysis of
the variables that affect awareness and compliance with EPA
regulations.  Although the study focuses on EPCRA, these results
can be used to assess general communication strategies that apply
to all environmental laws regulated by the EPA.

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     B. The Key Questions;
     There are six key questions addressed in this study. These
questions represent the interrelated issues that must be analyzed
in order to answer the central issue. The questions are arranged
in the order that they will be discussed in the report.
     * 1) What are the characteristics of the companies
     interviewed?
     * 2) What are the factors that influence manufacturing
     companies' compliance with EPA regulations?
     * 3) To what extent are manufacturing companies in
     these regulated industries familiar with EPA
     regulations, specifically EPCRA?
     * 4) How do manufacturing companies that produce or use
     toxic chemicals regulated by the EPA learn about EPA
     regulations such as EPCRA?
     * 5) Which outreach strategies followed by the EPA are
     more likely to increase awareness and possibly
     compliance with EPA regulations such as EPCRA?
     * 6) How can the EPA improve the process by which
     manufacturing companies learn about EPA regulations?
     This research attempts to answer these questions and develop
an initial outreach strategy for increasing the regulated
community's awareness of environmental regulations.

III. Literature Review
     A. Background on EPCRA;
     EPCRA is under the Superfund Amendments and Reauthorization
Act of 1986 (SARA). It is also referred to as SARA Title III.
This Act requires all levels of government to monitor the
releases of toxic and hazardous chemicals by industry, develop

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emergency planning strategies and compile data on toxic emissions
which is then made available to the public.
     EPCRA "...has four major sections: emergency planning
(Section 301-303), emergency release notification (Section 304),
community right-to-know reporting requirements (Section 311, 312)
and toxic chemical release inventory (Section 313)."  (US EPA,
Feb. 1990 p. 1). This study focuses on Section 313 which requires
the EPA to establish an inventory of the quantities of 300 toxic
chemicals released each year into the environment by
manufacturing companies.
     In order to be subject to compliance under Section 313,
facilities must meet certain criteria. This includes the
following; having more than ten employees, having Standard
Industrial Classification (SIC) Codes between 20 and 39 (these
encompass all manufacturing industries), and processing, handling
or otherwise using one or more of the 300 toxic chemicals subject
to reporting. Facilities that meet all of these requirements must
submit Toxic Chemical Release Inventory Forms (Form Rs) to the
EPA and designated state facilities annually. This Toxic Release
Inventory (TRI) data is available each year to the public through
a computer database and a published report.
     Because of the time constraints and limited scope of this
study, it was not feasible to survey companies on every
environmental law subject to EPA regulations. There are two major
reasons why the EPA chose to study Section 313 of EPCRA. The
first reason is EPCRA's relative obscurity. Unlike Superfund,
which is a widely publicized and generally well-known
environmental law, EPCRA is thought to be less well-known to both
the general public and the manufacturing companies subject to
compliance.

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     The second reason involves the timing of the 1993 EPCRA
National Initiative and the release of the 1992 TRI data. A
National Initiative occurs when EPA Headquarters arranges for
participating regional offices to simultaneously issue
enforcement actions against violators of a particular piece of
legislation. Just before this study began (in late June of 1993)
the EPA had released a National Initiative for Section 313 of
EPCRA. In addition, the previous week EPA Administrator, Carol
Browner, had announced the release of the 1992 TRI data. This
enabled the researcher to not only measure the effects of general
EPA public outreach strategies, but also determine how effective
press releases are in publicizing enforcement actions and
announcing recent EPA events.

     B. Previous Studies:
     According to the TRI data report from 1988, entitled Toxics
in the Community: National and Local Perspectives, there are over
150,000 manufacturing facilities nationwide which have 10 or more
employees and the SIC codes subject to TRI reporting. However,
only 13 percent (or around 20,000) of the facilities actually
reported in 1988. The EPA asked the question, "Does this 13
percent reflect the total number of facilities that have the
threshold limits which require reporting?" In order to answer
this question, the EPA conducted a survey of facilities that are
potentially subject to reporting under EPCRA. (Toxics in the
Community, p. 72) .
     The report does not provide a full explanation of the
survey. It does not explain how many companies were surveyed, the
confidence level for the survey, or the response rate for the
interviews. It does mention that the surveys were conducted over

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the telephone. The survey yielded the following results.
     The overall compliance rate for 1987 was 66 percent. The EPA
estimates that an additional 10,000 companies should have
reported in 1987. The compliance rate differed depending upon the
type of industry. The chemical industry had a compliance rate of
88 percent. Instrument manufacturers, electrical equipment
manufacturers and the petroleum industry had compliance rates
close to 80 percent. The apparel industry had a low compliance
rate of 13 percent and the printing and publishing industry had a
rate of 31 percent.
     According to this report, medium-sized companies (between
20-49 employees) had the lowest compliance rates, whereas large
companies had the best compliance rates. Small companies also had
relatively high compliance rates. One hypothesis for this is that
fewer small companies need to comply and large companies are more
aware of the reporting requirements than medium-sized companies.
     The study concludes "...that many facilities, either
deliberately or through a lack of awareness of their
responsibilities, failed to fulfill their reporting obligations
under TRI for 1987." (Toxics in the Community, p.73).
     The 1988 TRI report further explains some of the efforts the
EPA is making to better inform facilities of their obligations to
comply with EPA regulations. The report states that the EPA
conducts training sessions around the country, provides
literature to explain TRI, issues press releases, publishes
articles and works with trade associations to keep their members
informed.
     According to this report, however, the EPA's most effective
compliance technique is its "aggressive enforcement program." The
EPA conducts more than 800 inspections each year at companies

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suspected of noncompliance. As of July 1990, the EPA had
collected more than three quarters of a million dollars in
penalties and conducted out-of-court settlements which initiated
voluntary emission reductions in lieu of payment.
     Bolstridge  (1991) discusses a number of similar studies the
EPA and GAO conducted from 1988 to 1991 which analyze the
compliance rates of companies reporting under EPCRA.  The first
discussion focuses on a confidential survey the EPA commissioned
in 1989. Similar to the report described in Toxics in the
Community, this study also reported 1987 compliance levels at 66
percent. The survey estimated that 148,000 facilities had SIC
codes between 20 and 39, with ten or more employees, and 29,800
companies met the threshold requirements and should have
reported. However, only 19,600 facilities filed the appropriate
forms for 1987.
     Bolstridge also mentions a United States General Accounting
Office (GAO) survey conducted in 1991. This survey interviewed
all state environmental agencies to estimate the number of
facilities that failed to report under Section 313. 39 states
responded to the survey. The GAO estimated that approximately
10,000 facilities had not reported. They concluded that the
majority did not report because they were unaware of the
regulations.
     Finally, Bolstridge reviews a telephone survey the EPA
conducted in 1988. The agency surveyed 406 facilities based on
608 submitted Form Rs to see how closely actual levels were to
reported levels. The study found that 126 of the reports had been
submitted unnecessarily, either because the company did not fall
within the threshold limits or SIC codes, had fewer than the
required ten employees, or reported for an unlisted chemical.
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     The main purpose of each of these studies was to effectively
measure manufacturing companies' compliance rates for EPCRA.
However, although these studies do raise some relevant questions
which were not answered, this investigator was not able to locate
any surveys that focused on the impacts of EPA communication
strategies on regulated industries.

IV. Methodology
     This survey constituted a simple random sampling of
manufacturing companies drawn from the five states and District
of Columbia ercompassing the Region III office of the EPA. The
eight-page survey instrument was given over the telephone to 100
manufacturing companies possessing two of the three criteria used
to determine compliance with EPCRA; more than ten employees and
SIC codes between 20 and 39. (Note: since data on threshold
requirements is unavailable for all companies subject to
reporting under EPCRA, this criteria was excluded from
determining the study population.)
     A simple random sample of 1,000 manufacturing companies was
generated by Dun & Bradstreet Information Systems (D&B). D&B
entered the criteria listed above plus the appropriate
geographical limitations into their Facility Index System
(FINDS). This produced a study population of 14,305 manufacturing
companies. From this population, they randomly generated a
sampling frame of 1,000 manufacturing facilities which included
company name, address, SIC code and telephone number.
     The researcher determined that 100 would represent a
feasible sample size. This size depicts a confidence level of 95
percent with a population variability of 0.50 and +10 percent
accuracy. In this study, accuracy is sacrificed in order to keep

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the sample size at a manageable number since only one researcher
would be conducting all of the interviews. 600 completed surveys
would have been needed to lower the accuracy to below ±5 percent.
However, the three-month limit in which this study had to be
completed did not allow for 600 completed surveys.
     202 companies were randomly selected from the sampling frame
to generate 100 completed surveys; a response rate of 50.5
percent. The interviewer destroyed all the information about each
company except the telephone number. In this way, the interviewer
was not able to identify the name of the company as the calls
were conducted. In turn, the completed surveys were coded with a
random ID number; the telephone number was not matched with the
respondents' completed answer sheets. This ensured the complete
confidentiality of each respondent's answers.

V. Evaluation Design
     A. The Variables;
     The survey instrument consists of 28 questions. They
represent the dependent and independent variables included in
this study. The dependent variable of compliance with EPCRA was
measured using questions which asked companies' familiarity with
EPCRA and Section 313, as well as opinion questions asking
respondents to agree or disagree about the relationship between
awareness and compliance.
     The independent variable of awareness of EPA regulations
encompasses questions about the number and types of information
sources where respondents receive information about environmental
regulations, the effectiveness of EPA information dissemination
strategies such as press releases on enforcement actions and
demographic information about the companies interviewed.
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     These variables are used in the formulation of the schematic
model. According to O'Sullivan and Rassel  (1989), schematic
models can use pictures, lines and points to explain the
relationship between the variables (p. 9) . A schematic model is
developed in the initial stages of the evaluation design, then
revised after the results have been analyzed. The schematic model
on the following page represents the complete analysis of the
relationships between the elements in the study.

     B. The Schematic Model:
     Each of the five sections in the model represents the most
important elements addressed in the first five key questions
presented earlier. The size of the company is the most pertinent
demographic characteristic affecting awareness of EPA
regulations.  This is placed at the beginning of the model. The
most important ways companies learn about regulations seems to be
through the number and types of sources respondents selected for
general EPA information, as well as specific information on
EPCRA. These two elements are represented in section two of the
model.
     Section three contains the four most relevant information
dissemination strategies measured in the survey. These include
how effectively publicizing enforcement actions increases
compliance, as well as respondents' awareness of the EPCRA
Hotline, the 1992 TRI data and the 1993 EPCRA National
Initiative. In section four, companies' familiarity with EPCRA
regulations is represented including the extent to which
companies believe they have received adequate information from
the EPA.
     The final section deals with the central issue in the study;
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whether awareness of EPA regulations affects compliance with
those regulations. The arrows in the model illustrate how the
elements interact with each other to influence this
awareness/compliance relationship.

     C. Method of Analysis;
     After all of the data was collected, it was entered into a
Lotus spreadsheet before being uploaded to SAS1  as  a  dataset.  SAS
is a computer software system which enables the user to write
custom data analysis programs to meet individual needs (SAS, p.
6). SAS has a built-in set of procedures which perform specific
data analysis functions. They are referred to as PROC procedures.
     In analyzing the EPCRA dataset, the researcher wrote a PROC
FREQUENCY program to provide initial descriptive statistics on
each of the questions in the survey. Also referred to as PROC
FREQ, this program provides a frequency table of the number of
responses under a given answer choice, the percentage of
responses, the cumulative frequency of responses and the
cumulative percentage.
     Other PROC programs used in this data analysis include PROC
UNIVARIATE which creates bivariate tables comparing the
relationship between two variables, as well as statistics
including chi-square and gamma, and PROC TTEST which conducts a
T-test on specified variables and outputs a T-test procedure, a
normal probability plot, a stem and leaf, a box plot and a
frequency table.
     1  This  referenced Trademark is used to identify products or
services of SAS Institute Inc.
                                12

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     The descriptive statistics created by the PROC FREQ and PROC
UNIVARIATE procedures are used in the initial data analysis to
address the hypotheses created from the first five key questions
raised at the outset of this study. The multivariate analysis of
the PROC TTEST is used to conduct a preliminary evaluation of the
relationships between a few of the elements illustrated in the
schematic model. Further study needs to be done to complete a
detailed analysis of the remaining elements in the model.

VI. Findings and Conclusions
     A. Descriptive Statistics;
     The first question the statistics are asked to answer
concerns the characteristics of the companies interviewed.
Table I2 shows the  types  of manufacturing  companies  interviewed
based on SIC codes and the categories of company types defined by
EPCRA. Printing and publishing companies represent the largest
industry surveyed with 16 completed responses. Food and Machinery
rank second and third respectively. Every industry type is
represented by at least one company in the responses except the
Tobacco and Leather industries. There are also five missing
responses representing those respondents who refused to answer
this question.
     This information provides a description of the types of
companies represented by the data.  However, it does not provide
a viable indicator for describing the entire study population.
     Companies which were contacted represent every state in
Region III, including the District of Columbia. The break down is
as follows: 64 percent were from Pennsylvania, 18 percent from
     2 All tables and charts appear in Appendix A.
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Maryland, ten percent from Virginia, three percent from Delaware,
two percent from West Virginia and one percent from the District
of Columbia.
     The most important characteristic reviewed in this study is
the sizes of the companies interviewed. According to the data
presented in Table 2, 26.3 percent of the companies had between
one and 12 employees, 24.2 percent between 13 and 25, and 25.3
percent between 26 and 60. This means that more than 75 percent
of the companies interviewed had fewer than 60 employees and can
be classified as small to medium-sized companies. This is further
confirmed by the fact that only five percent of the companies
interviewed had more than 600 employees.
     This data provides a major contingency factor for
identifying the EPA's primary customer. With these overwhelming
statistics, it is possible to conclude that the majority of
manufacturing companies subject to EPCRA compliance are small to
medium-sized.
     Does company size affect familiarity with EPCRA regulations?
To answer this question, bivariate tables were created that
compare the size of a company with familiarity of EPCRA (Table 3)
and the size of a company with familiarity of Section 313
(Table 4). In order to determine the measure of association
between these variables, the gamma statistic is reviewed. Gamma
"...measures the proportional reduction in error gained by
predicting one variable while taking the other into account."
(Healey, p.350).
     Table 3 displays a gamma level of 0.288. This statistic
indicates that a weak association exists between the two
variables. You would only make 28.8 percent fewer errors in
predicting the size of the company while knowing the familiarity
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with EPCRA. However, this statistic does not prove accurate when
the actual bivariate numbers are reviewed. According to the
table, 100 percent of the companies with over 300 employees are
familiar with EPCRA. Likewise, 72.23 percent of the companies
with between 50 and 300 employees are also familiar with EPCRA.
     This indicates that larger companies are more aware of the
regulation than smaller ones. The gamma statistic is not a good
indicator due to the disproportionate number of companies with
fewer than 50 employees and the significantly small number of
companies with more than 110 employees (15 percent).
     Table 4 displays a strong gamma value of 0.872. This implies
a strong measure of association between company size and
familiarity with Section 313. One reason for this strong
correlation could be that 100 percent of companies above 50
(including both the second and third categories) were familiar
with Section 313. Since respondents must be familiar with EPCRA
before they can respond to being familiar with Section 313, this
indicates that of those larger companies familiar with EPCRA, all
of them were also familiar with Section 313. These tables
conclude that company size does impact familiarity with EPCRA
regulations; larger companies are, in fact, more familiar with
EPCRA than smaller companies.
     The second question asks about the factors that increase
manufacturing companies' compliance with EPA regulations in
general. The researcher hypothesizes that increased awareness of
EPA regulations will lead to increased compliance by affected
industries. This hypothesis is illustrated in the last phase of
the schematic model.
     To test this hypothesis, the surveyor asked respondents to
agree or disagree with two statements. The first statement reads
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"In my opinion, the majority of companies who don't comply with
EPA regulations aren't aware of the regulations.11, and the second
statement reads "In my opinion, better awareness of EPA
regulations will lead to increased compliance by affected
industries." If respondents agree with these statements this
would indicated a direct correlation between awareness and
compliance.
     The results support this hypothesis. Table 5 provides the
number of respondents who agree and disagree with each of these
statements. According to the data, 74.7 percent of respondents
agree that companies who don't comply with EPA regulations aren't
aware of the regulations. Likewise, 91.5 percent of respondents
also agree that better awareness of EPA regulations leads to
increased compliance by industries.
     To further test the measure of association between these two
questions, a bivariate table was created to determine the
relationship between these two questions. A strong correlation
between these two questions, would indicate that respondents who
agree with one question consistently agree with the other.
     Table 6 illustrates the frequency and percent of respondents
who agree and disagree with each statement. Reading the table
across the columns reveals that of the respondents who agree that
companies which don't comply with EPA regulations aren't aware of
the regulations, 81.48 percent also agree with the second
statement that increased awareness leads to increased compliance.
Only 18.52 percent of respondents who disagree with the first
statement agree with the second. Likewise, of the respondents who
agree with the second statement, 95.65 percent also agree with
the first statement and only 4.35 percent disagree.
     This strong, direct covariation relationship between these
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two variables supports the hypothesis that increased awareness
leads to increased compliance. The gamma statistic calculated in
Table 7 further shows a strong correlation between these two
questions. It indicates that you would make 63.0 percent fewer
errors in predicting the answer to the second question by knowing
the answer to the first question. Testing the correlation between
two similar questions also tests the validity of the survey
instrument. Since the majority of respondents answered similar
questions with the same answers, the survey appears valid for
this issue.
     The previous questions could be biased since respondents
were asked to agree or disagree with prewritten questions. To
eliminate this bias, respondents were asked the open-ended
question of what they felt the primary reason is that companies
do not comply with EPA regulations. 53.5 percent felt it was due
to a lack of awareness of the regulations (Table 8). The second
closest response represents a mere 27.3 percent of the
respondents and names expense as the primary reason companies do
not comply with EPA regulations.
     These results are significant because they reveal companies'
attitudes toward compliance. Since this was an open-ended
question, respondents were not given a list of options, but were
allowed to answer any way they felt. By reviewing some of the
other responses, this indicates that respondents seemed to feel
comfortable answering this question openly. Four percent of the
companies felt they would not get caught if they did not comply
with EPA regulations. Four percent felt companies do not care
about environmental regulations. A few respondents even felt that
most companies try to comply or should already be well-informed
about the regulations.
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     Not only do respondents agree with the earlier statements,
but when they are able to give any answer to an open-ended
question asking why companies don't comply with the regulations,
the majority feel it is due to a lack of awareness. These results
are extremely important because they provide insight into why
companies may not be complying with EPA regulations. By knowing
why companies are not complying, the EPA can target these
problems and, in turn, increase compliance of the regulations.
     If the data reveal why companies are not complying with EPA
regulations, they also look at how the EPA can increase
awareness. The question of how familiar companies are with EPA
regulations indicates what efforts may be working and may not be
working to increase awareness. This is addressed in question
three which asks to what extent manufacturing companies are
familiar with EPA regulations, specifically EPCRA.
     The researcher hypothesized that the majority of companies
are not aware of EPCRA since this seems to be a fairly obscure
regulation and previous studies revealed that over 30 percent of
companies are not complying with the regulation.
     To test this hypothesis, the survey asked respondents if
they are familiar with the regulations under EPCRA. According to
the results, 54 percent of respondents are familiar with EPCRA
and 19 percent answered that they are somewhat familiar
(Pie Chart 1). This rejects the hypothesis because the majority
of companies, namely 73 percent, are somewhat familiar or
familiar with EPCRA.3
     The survey further tests how familiar respondents are with
     3 27  percent of companies were unfamiliar with EPCRA.  One
respondent even commented, "Oh no, not another regulation I
should know about!"
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specific details under EPCRA. Of those respondents who affirmed
that they are familiar with EPCRA, 81.7 percent are also familiar
with Section 313, which deals with release reporting requirements
for certain toxic chemicals (Table 9). This indicates that
companies are not only superficially familiar with the
regulation, but also seem familiar with the specific requirements
under the regulation.
     However, 40 percent of the respondents were unable or
refused to answer this question. This 40 percent includes the 27
percent who were not familiar with EPCRA. (This was a contingency
question and assumed that if a company was unfamiliar with EPCRA
it would also be unfamiliar with Section 313.) Since such a large
number of companies were unable to answer the Section 313
question and other contingency questions including knowledge
about threshold requirements and reporting deadlines, these
results have been thrown out as nonviable dependent variables;
only general EPCRA information remains in the schematic model as
an indicator of companies' familiarity with EPA regulations.
     This question provides the dependent variable for testing
companies' compliance with EPA regulations. The researcher
assumes that if companies are not familiar with a regulation,
they are not complying with that regulation. However, being
familiar with the regulation does not. guarantee that companies
are complying; the data just indicate that it improves the chance
that companies are complying.
     The schematic model illustrates that companies' familiarity
with EPCRA is not the only measure of awareness in the survey.
The researcher also asked respondents the extent to which they
believe they are receiving adequate information from the EPA. 62
percent of companies disagree with the statement that "I have
                                19

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received adequate  information from the EPA." This reveals that
although companies seem familiar with EPCRA regulations, they
also feel that the EPA is not doing a sufficient job to educate
them about general EPA regulations. In turn, when respondents are
asked whether they feel the EPA is publicizing too much, the
right amount or not enough on environmental regulations, 56
percent said the EPA was not publicizing enough.
     This leads into the next question which asks how
manufacturing companies that produce or use toxic chemicals learn
about EPA regulations such as EPCRA. The corresponding hypothesis
states that the majority of manufacturing companies learn about
EPA regulations through trade publications which relate to their
particular industry.
     To test this  hypothesis, the survey asked companies to
identify the number and types of sources they refer to for
general EPA information and for information about EPCRA. 77
percent of respondents identified trade publications as a source
they consult for information about environmental regulations
(Table 10). Since  this represents the most frequently sighted
source the hypothesis is supported.
     Other sources that companies consult for general EPA
information include newspapers (63 percent), television (50
percent), direct mailings (50 percent) and other companies (32
percent). However, when companies were asked to identify where
they receive information about EPCRA, 69 percent of the companies
were not able to identify any sources. The most frequently
identified source  for specific information about EPCRA came from
direct mailings (15 percent).
     This information provides an indication of the most commonly
used sources that  companies consult for information on
                                20

-------
environmental laws and regulations. It also provides information
about the number of sources companies consult. Bar chart 2
illustrates the cumulative percentages of the number of sources
companies consult for general EPA information. Three percent of
companies do not consult any sources, 14 percent (a cumulative
total of 17) consult one source, 35 percent consult two sources
and 86 percent of companies consult five sources for general EPA
information.
     This indicates that if the EPA were to provide information
about EPA regulations through five sources, they would presumably
reach 86 percent of their target audience (89 percent minus the 3
percent who do not consult any sources.) By utilizing six
sources, they would reach 94 percent of their audience. These are
not always the same six sources, but by referring again to
Table 10, this will indicate what the six most effective sources
are for targeting manufacturing companies: trade publications,
newspapers, television, direct mailings, other companies and
radio. By utilizing these sources, the EPA would reach a large
proportion of industries regulated under EPCRA.
     Since companies tend to utilize trade publications, the
survey asked respondents to identify the trade publications they
use most often. Appendix G provides a list of trade publications
respondents named. As the list indicates, there is little overlap
between responses. Even companies within the same industry seem
to utilize a wide variety of trade publications. The most
frequently sighted publication is Printing Impressions with four
responses. However, most of the publications were sighted by only
one respondent. This reveals the difficulty in targeting trade
publications. The question arises of how the EPA can effectively
target all types of manufacturing companies through such a
                                21

-------
diverse list of trade publications? This question requires
further study in order to be answered.
     The survey also asked companies what agency they use most
often for information and advice on environmental issues. As the
results in Table 11 illustrate, 29.2 percent of companies turn to
their state environmental agency for advice.4 16.7 percent turn
to other sources which mostly include trade associations and
chambers of commerce. Only 12.5 percent utilize the EPA for
advice on environmental issues. When the interviewer asked
companies why they did not use the EPA, many respondents felt
that the EPA -, as too large and impersonal to contact. Companies
who tried to telephone the EPA had a difficult time getting
through to an actual person.
     Respondents were also asked what agency they should be using
for information and advice on environmental issues.  State
agencies retain the lead with 26.5 percent of respondents.
However, local government agencies increase from 8.3 percent to
22.5 percent of respondents. Companies seem to think that local
environmental agencies should be utilized to provide advice. The
EPA increased almost six percentage points. Only one percent of
respondents felt that their trade association or chamber of
commerce should be keeping them informed. Overall, companies feel
that it is the government's responsibility; whether it is at the
local, state or federal level.
     The fifth question this survey addresses asks which outreach
strategies followed by the EPA are more likely to increase
compliance with EPA regulations such as EPCRA. Do press releases
     4 Despite this statistic,  many companies expressed a
dissatisfaction with their state agencies.
                                22

-------
to these various trade publications that publicize enforcement
actions effectively reach these companies and deter them from
violating? Are companies aware of the EPCRA National Hotline? Did
the recent press release regarding the release of the 1992 TRI
data reach these companies? And are companies aware of the 1993
EPCRA National Initiative? These are the four strategies the
survey measured for their effectiveness.
     The results, displayed in Table 12, indicate the answers to
these questions. More than 72 percent of respondents agree that
publicizing enforcement actions against companies deters other
companies from violating the regulations. This seems to be an
effective strategy for increasing compliance.
     However, only 43 percent of these companies are aware of the
EPCRA National Hotline. This indicates that although companies
seem aware of EPCRA, they do not know who to turn to for
additional advice about EPCRA. It also reveals that the EPA has
not done a sufficient job in informing companies about this
valuable service which has been established to assist regulated
industries.
     These two strategies, which have been categorized as long-
term strategies because they provide an ongoing way to
disseminate information, are more effective than the one-time
strategies measured by the 1992 TRI data and EPCRA National
Initiative. Both of these strategies were one-time efforts by EPA
Headquarters and the regional offices to publicize specific EPA
events. In both cases, the EPA's Office of External Affairs
issued press releases to selected newspapers and trade
publications detailing a recent occurrence at the EPA.
     The first strategy was an announcement by EPA Administrator
Carol Browner of the release of the 1992 Toxic Release Inventory
                                23

-------
data which provides annual statistics outlining the top emissions
to the air, land and water by manufacturing companies. 75.8
percent of the companies surveyed were not aware of the release
of these data.
     Likewise, 83.8 percent of companies surveyed were not aware
of the second strategy; the EPCRA National Initiative. This was a
series of enforcement actions sent out across the country to
manufacturing companies who had been issued complaints for
violating EPCRA. The Initiative was publicized on a national
level through EPA Headquarters and regionally. The Region III
office had sent out press releases to 91 trade publications and
newspapers targeting the types and locations of the industries
affected by the enforcement actions.
     Both of these one-time strategies were less effective than
the long-term strategies in increasing awareness. There are many
reasons why these single efforts proved less successful
strategies for increasing awareness. The most plausible reason
deals with the timing of the press releases. Many trade
publications are printed monthly or bimonthly. This means that
many of the publications which received the press releases may
not have had the time to print the information before the survey
was conducted.
     Also, it is unclear what percentage of the press releases
sent to publications are actually utilized. The Region III Office
of External Affairs has proposed a survey to interview trade
publications, newspapers and television and radio stations to
determine how many use the press releases sent by the EPA.
     When the companies were asked what they suggest the EPA do
to better inform companies about environmental regulations the
responses were more varied. As Table 13 depicts, 31 percent of
                                24

-------
the companies surveyed asked for more direct mailings in simple
language. 12 percent asked for more regional seminars in plain
English. Eight percent asked for annual or quarterly newsletters,
six percent want to see the EPA work more closely with local
governments and chambers of commerce, and five percent feel the
EPA should publicize more in trade publications. Some respondents
had even more creative and diverse answers including creating an
environmental phonebook or a TV station devoted to EPA
legislation.
     However, the majority of companies consistently asked for
simplified explanations of the complicated issues that encompass
environmental laws. Since the majority of the companies
interviewed are under 60 employees, they do not have the time,
personnel or financial resources needed to effectively educate
themselves about all of the nuances under the environmental
regulations affecting them. They need the EPA to better educate
them through more targeted information dissemination strategies.
Press releases about particular enforcement actions alone are not
sufficient to inform these companies. These strategies are
somewhat effective, but need to be combined with other strategies
such as direct mailings, seminars or newsletters.

     B. Multivariate Analysis;
     It is necessary to refer again to the schematic model
presented earlier in this report in order to analyze the
relationships between the important factors affecting awareness
and compliance with EPA regulations. A preliminary multivariate
analysis was conducted to examine the relationships between the
three variables contained in sections four and five of the model.
The evaluation focuses on the relationship between awareness and
                                25

-------
compliance of EPA regulations and how they are affected by
companies' familiarity with EPCRA plus the extent to which
companies believe they have received adequate information from
the EPA.
     To assist in a diagnosis of these relationships, it was
first necessary to combine the awareness/compliance relationship
into one index. This was done by setting values for responses to
the two questions used to measure awareness and compliance. A
value of five means respondents strongly agree that awareness
influences compliance. A value of one means they strongly
disagree.
     The results presented in Table 14 indicate that the median
value is four, the mean is 3.9 and the mode equals four. This
demonstrates that the average response for this index signifies a
general agreement with the awareness/compliance relationship. The
0% minimum value of two shows that none of the companies strongly
disagreed with the awareness/compliance relationship. The stem
and leaf and normal probability plot in Table 15 illustrate the
normality of the data; 37 respondents answered four (agree). In
general, companies agree that there is a strong correlation
between awareness of EPA regulations and compliance.
     After this index was created, PROC TTEST was run to compare
this index with the extent to which companies believe they
receive adequate information from the EPA. Table 16 displays the
results of this procedure. The null hypothesis (Ho) states that
there is no difference between those who disagree with the
question of receiving adequate information from the EPA and those
who agree with the awareness/compliance relationship. The
alternate or research hypothesis (Ha) states that there is a
significant difference.
                                26

-------
     According to the results, there is no significant difference
between the averages and standard errors for the disagree and
agree groups. Therefore, the equal variance statistic must be
used. If Prob>/T/ (T statistic) is smaller than 0.05, it is
necessary to reject the null hypothesis (Ho) of no difference
between the two groups. If the T statistic is greater than 0.05,
the null hypothesis must be accepted. These results reveal that
under the equal variance, the T statistic is 0.0013 or less than
0.05. Therefore, we must reject the null hypothesis in favor of a
significant difference between the companies who disagree with
the first question of receiving adequate information from the EPA
but agree with the awareness/compliance relationship.
     This means that there is a significant inverse relationship
between the first question and the awareness/compliance index.
Those who have not received adequate information from the EPA
feel that they would be more likely to comply with EPA
regulations if they were made more aware of the regulations.
However, those who have received adequate information from the
EPA do not believe as strongly that companies would be more
likely to comply if they are made more aware. Once companies are
made aware, they do not seem to value the information as much, or
feel as strongly that this awareness will affect compliance.
     There are many reasons why this relationship appears to be
true. The most important concerns the quality and content of the
information provided to affected industries and the method this
information is dispersed. The small manufacturing companies
affected by the regulations studied are looking for more detailed
and simplified information on how to comply with these
regulations. They want to understand the specifics of the laws
and how their industries can comply; not just be aware of the
                                27

-------
enforcement actions taken against similar companies.
     It is also necessary to target these companies through a
range of information sources; not just one particular source.
Press releases sent to trade publications alone will not
significantly increase awareness of regulations and increase
compliance. Publicizing  in multiple sources greatly increases
companies' chances of learning about the regulations. However,
surface awareness does not greatly affect compliance. The extent
of the awareness, the specific facts and procedures these
companies are familiar with greatly influences their ability to
comply. The majority of  the companies interviewed expressed a
genuine interest in complying with the regulations, they just do
not understand how to comply.
     The PROC TTEST was  also conducted on the relationship
between companies' familiarity with EPCRA and the
awareness/compliance index. The null hypothesis (Ho) states that
there is no difference between the group of companies who
disagree that they are familiar with EPCRA and those companies
who agree with the awareness/compliance index. The alternate
hypothesis (Ha) states that there is a significant difference
between the two groups.
     The results presented in Table 17 show that there is no
significant difference between the averages and standard errors
for the disagree and agree groups. Just like the previous test,
the equal variance is used. However, unlike the previous test,
the T statistic under the equal variance is greater than 0.05 at
0.9663. This means that  we can not reject the null hypothesis of
no difference. Consequently, there is no difference (no
correlation) between companies' familiarity with EPCRA and
whether they agree or disagree with the awareness/compliance
                                28

-------
relationship.
     To complete the analysis of the right side of the schematic
model, it is necessary to compare the relationship between the
extent to which companies believe they received adequate
information from the EPA and companies' familiarity with EPCRA.
This can be accomplished by developing a bivariate table shown as
Table 18. With a gamma statistic of 0.438 there is a moderate
relationship between these two variables. This means that you
would make 43.8 percent fewer errors in predicting whether
companies feel they receive adequate information from the EPA if
you know whether the companies are familiar with EPCRA.
     Of the companies who are not familiar with EPCRA, 77.78
disagree that they receive adequate information from the EPA and
22.22 agree. However, of those that are familiar with EPCRA, the
answers are divided between those who agree and disagree about
whether they receive adequate information from the EPA. 57.75% of
those who are familiar with EPCRA feel they do not receive
adequate information from the EPA and 42.25 felt they did receive
adequate information. This reinforces the theory stated earlier
that once firms are made aware of the regulations, they do not
seem to value the information as much as those who are not
familiar with the regulations.

VII. Recommendations
     This multivariate analysis addresses one half of the
schematic model in detail. It also provides some answers to the
sixth and final question posed at the outset of this study; how
can the EPA improve the process by which manufacturing companies
learn about EPA regulations?
     This final section of the report attempts to outline some
                                29

-------
recommendations that have been generated based on the results of
the survey. It also suggests further study that could be
investigated to measure additional factors not included in this
research.
     The companies, themselves, have suggested ways the EPA can
better inform them about environmental regulations. The most
popular form is through more direct mail in simple language.
Companies recommend such mailers as quarterly newsletters,
brochures sent with annual tax return forms, and publications
targeted to specific industries as a means of better informing
them.
     The EPA already works with local trade associations to
provide some outreach and education on environmental regulations.
However, many companies feel more efforts are needed to provide
regional seminars in plain English to local businesses. Many
suggested working with the chambers of commerce to provide
workshops, buy mailing lists and maybe even offer tax incentives
to companies willing to make the effort to become more aware of
the regulations.
     These companies are asking the government for more help in
educating them effectively about environmental regulations. This
researcher found that the majority of small businesses
interviewed did not have an environmental consultant on sight. In
fact, none of the respondents sighted an environmental consultant
as the primary source of information on the regulations and only
3.1 percent named an attorney (Table 11). Even more telling is
the fact that the majority of small companies interviewed did not
have any type of environmental employee on staff. The owner or
manager generally handles whatever environmental questions or
problems may arise. On the other hand, all of the companies with
                                30

-------
over 600 employees had an environmental division to concentrate
on complying with environmental regulations.
     This evidence further emphasizes that small companies are
the ones that need the government's aid in educating them about
environmental issues. If they are better informed they agree that
they will more likely comply.
     Educating the thousands of small companies subject to
compliance of the many environmental regulations is a growing
challenge for the EPA. With limited resources and growing public
demand, a major effort must be focused on education and public
outreach.
     Besides providing publications and direct mailings, the EPA
should also concentrate on better utilizing the mass media in
informing companies about issues. Television, newspapers and
radio may not be the most effective mediums for educating
specific companies about the requirements under a particular
regulation, but they are effective sources for creating general
awareness among industries and the public.
     As the data reveal, individual strategies, such as publicity
on specific enforcement actions, will not greatly increase
awareness of the regulations. Utilizing the mass media, however,
will continue to generate public support for environmental
regulations. This, in turn, will increase public pressure on
companies to comply. And this pressure may force companies to
make a proactive effort to educate themselves.
     The government alone can not educate every company. It must
also be industries' responsibility to educate themselves. Once
industries realize their environmental responsibilities, they can
work with government to comply with all environmental
regulations. If government and industries can work together to
                                31

-------
become better informed about the regulations, it will increase
compliance of these regulations. The EPA must provide incentives
to these companies, easy access to the information and public
pressure to force companies to want to comply. These efforts
should constitute the central foci of the EPA's future public
outreach strategies.
     If the EPA chooses to assess the effectiveness of these
recommendations, a possible follow-up study could focus on a
variety of publicity strategies. The EPA could initiate different
outreach campaigns from mass media only to direct mail combine
with local seminars and workshops. These strategies could be
assessed for their value of information to the regulated
community and general public. Their effectiveness could be
measured by interviewing focus groups before and after the
strategies are released to measure their impact on awareness and
compliance.
     The study could also look at the relationships between the
forms of media used, the content, the display, the timing and the
reinforcement of the information. By measuring the effectiveness
of specific strategies, the EPA can determine which strategies
are most effective in educating the regulated community and
increasing compliance of environmental regulations.
                                32

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                        BIBLIOGRAPHY
Bolstridge, June C., 1992. EPCRA Data on Chemical Releases,
     Inventories, and Emergency Planning: A Guide to the
     Information on Industrial Facilities and Chemicals
     Available Under the Emergency Planning and Community
     Right-to-Know Act. Van Nostrand Reinhold, New York.


Dillman, Don A., 1978. Mail and Telephone Surveys: The Total
     Design Method. John Wiley & Sons, New York.


Groves, Robert M. and Kahn, Robert L., 1979. Surveys by
     Telephone: A National Comparison with Personal
     Interviews. Academic Press, Inc., New York.


Healey, Joseph F., 1993. Statistics: A Tool For Social Research.
     Wadsworth Publishing Company., California.


Lynn, Frances M., Kartez Jack D., and Connelly, Cheryl., January,
     1992. The Toxics Release Inventory. Environmental
     Democracy in Action. United States Environmental
     Protection Agency, Office of Pollution Prevention and
     Toxics. Washington, DC.


Management Information Services. October 1984, Citizen Surveys.
     16:10. International City Management Association.


McNeil, Caroline, Arkin, Elaine Bratic and McCallum, David,
     Ph.D., September, 1989. Toxic and Hazardous Substances,
     Title III and Communities: An Outreach Manual for
     Community Groups. Institute for Health Policy Analysis,
     Georgetown University Medical Center, Washington, DC.


0'Sullivan, Elizabethann and Rassel, Gary R., 1989. .Research
     Methods for Public Administrators.  Longman, New York.
SAS Institute Inc., 1989. SAS Language and Procedures: Usage.
     Version 6, First Edition. SAS Institute Inc.
                                33

-------
                    BIBLIOGRAPHY continued
United States Environmental Protection Agency,  Office of
     Pesticides and Toxic Substances,  January,  1992.  The
     Emergency Planning and Community Right-to-Know Act:
     Section 313 Release Reporting Requirements.
     Washington, DC.


United States Environmental Protection Agency,  Office of Toxic
     Substances, January, 1991. Toxic Chemical  Release
     Inventory Magnetic Media Submission Instructions.
     Washington, DC.


United States Environmental Protection Agency,  February, 1990
     (Revised). SARA Title III Fact Sheet: Emergency
     Planning and Community Right-to-Know.


United States Environmental Protection Agency,  Solid Waste and
     Emergency Response, July 1990. When All Else Fails!
     Enforcement of the Emergency Planning and Community
     Right-To-Knoir Act. A Self Help Manual For Local
     Emergency Planning Committees. Washington, DC.


United States Environmental Protection Agency,  Pesticides and
     Toxic Substances, June, 1988. Toxics in the Community:
     National and Local Perspectives.  Washington, DC.
                                34

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   APPENDIX A:
TABLES AND CHARTS

-------
                          TABLE
    TYPES OF MANUFACTURING COMPANIES INTERVIEWED
                                   Number
SIC Code     Type of Company    Interviewed  Percent

   27    PRINTING & PUBLISHING       16       16.8
   20    FOOD                        10       10.5
   35    MACHINERY                   10       10.5
   24    LUMBER & WOOD               7         7.4
   34    FABRICATED METAL            7         7.4
   32    STONE, CLAY & GLASS         6         6.3
   38    INSTRUMENTS                 6         6.3
   28    CHEMICALS                   5         5.3
   36    ELECTRICAL, ELECTRONIC      5         5.3
   39    MISC. MANUFACTURING         5         5.3
   22    TEXTILES                    3         3.2
   23    APPAREL                     3         3.2
   25    FURNITURE                   3         3.2
   33    PRIMARY METALS              3         3.2
   30    RUBBER & PLASTICS           2         2.1
   37    TRANSPORTATION EQUIPT.      2         2.1
   26    PAPER                       1         1.1
   29    PETROLEUM & COAL            1         1.1
   21    TOBACCO                     0         0.0
   31    LEATHER                     0         0.0

                     Missing = 5

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                               TABLE
         STATISTICS FOR SIZE OF MANUFACTURING COMPANIES SURVEYED
                # of Companies  Cumulative £  % of Companies  Cumulativ*
Range of Employe Within Range   Within Range   Within Range   of Compan:

      1-12

     13-25

     26-60

     61-110

    111-220

    221-600

   601-20,000

                                    Missing = l
26
24
25
10
5
4
5
26
50
75
85
90
94
99
26.3
24.2
25.3
10.1
5.0
4.0
4.0
26.3
50.5
75.8
85.9
90.9
94.9
100.0

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                     TABLE 3
BIVARIATE FREQUENCY TABLE FOR EPCRA SURVEY DATA
  Familiar with EPCRA by Number of Employees
Familiar with EPCRA
         No. of Employees
Frequency
Expected
Percent
Row %
Column % UNDER 50
         EMPLOYEES
NO
    21
19.376
 21.43
50-300
EMPLOYEES

          5
     4.7755
       5.10
OVER 300
EMPLOYEES

          0
     1.8571
       0.00
                               TOTAL
   26
                                                26.53
YES/
SOMEWHAT
TOTAL
 80.77
 28.77

    52
53.632
 53.07
 72.22
 71.23

    73
 74.49
      19.23
      27.78

         13
     13.224
      13.26
      18.06
      72.23

         18
      18.37
       0.00
       0.00

          7
     5.1428
       7.14
       9.72
        100

          7
       7.14
         Gamma =
            Missing = 2

       Value       ASE
       0.288       0.188
   72

73.47
   98
  100

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                     TABLE  \
BIVARIATE FREQUENCY TABLE FOR EPCRA SURVEY DATA
Familiar with Section 313 by Number of Employees
Familiar with Section 313
         No. of Employees

Frequency
Expected
Percent
Row %
Column % UNDER 50
NO
YES/
SOMEWHAT
TOTAL
. 50
YEES
11
7.8833
18.33
100
28.77
32
35.12
53.33
65.31
74.42
43
71.67
50-300
EMPLOYEES
0
2.0167
0.00
0.00
0.00
11
8.98
18.34
22.45
100
11
18.33
OVER 300
EMPLOYEES
0
1.1
0.00
0.00
0.00
6
4.9
10.00
12.24
100
6
10
         Gamma =
     Missing = 40

Value       ASE
0.872       0.123
                                             TOTAL
                              11

                           18.33




                              49

                           81.67
                              60
                             100

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                             TABLE ~>
       AWARENESS OF EPA REGULATIONS INFLUENCES  COMPLIANCE
Question
Agree
Percent
Agree
Disagree
Percent
Disagree
# Missing
Q14A:
COMPANIES WHO
DON'T COMPLY
AREN'T AWARE
Q14C:
BETTER
AWARENESS
LEADS TO
INCREASED
COMPLIANCE
 74
 86
  74.7
   19
   19.2
 91.5
              6.4

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               TABLE
QUESTION 14A CROSSED WITH QUESTION 14C
Q14AR3 (LA(
Frequency
Expected
Percent
Row Pet
Col Pet
DISAGREE
AGREE
:K OF AWARENESS)
Q14CR3 (BETTER AWARENESS)
DISAGREE; AGREE j Total
3 j 15
1.2414 | 16.759
3.45 j 17.24
16.67 j 83.33
50.00 I 18.52
3
4.7586
3.45
4.35
50.00
66
64.241
75.86
95.65
81.48
Total 6 81
6.90 93.10
1
I
|
i
i
i
|

18
20.69
69
79.31
87
100.00
  Frequency Missing = 13

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                    TABLE T"
STATISTICS FOR TABLE OF QUESTION 14A BY QUESTION 14C
Statistic
DF
Value
 Prob
Chi-Square
Likelihood Ratio Chi-Square
Continuity Adj. Chi-Square
Mantel-Haenszel Chi-Square
Fisher's Exact Test  (Left)
                     (Right)
                     (2-Tail)
Phi Coefficient
Contingency Coefficient
Cramer's V
 1
 1
 1
 1
3.374
2.765
1.728
3.335
       0.197
       0.193
       0.197
0.066
0.096
0.189
0.068
0.985
0.100
0.100
Statistic
       Value
             ASE
Gamma
Kendall's Tau-b
Stuart's Tau-c
Somers' D CJR
Somers' D R|C
Pearson Correlation
Spearman Correlation
Lambda Asymmetric CJR
Lambda Asymmetric R|C
Lambda Symmetric
Uncertainty Coefficient CJR
Uncertainty Coefficient RjC
Uncertainty Coefficient Symmetric
0.630
0.197
0.081
0.123
0.315
0.197
0.197
0.000
0.000
0.000
0.063
0.031
0.042
0.261
0.134
0.061
0.091
0.209
0.134
0.134
0.000
0.000
0.000
0.079
0.040
0.053
      Estimates of the Relative Risk (Rowl/Row2)


Type of Study           Value
             95%
     Confidence Bounds
Case-Control
Cohort
Cohort
(Coll
(Col2
Risk)
Risk)
4.
3.
0.
400
833
871
0
0
0
.807
.844
.704
23
17
1
.981
.420
.078
Effective Sample Size = 87
Frequency Missing = 13

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                            TABLE 5
       REASONS COMPANIES DON'T COMPLY WITH EPA REGULATIONS
Reason
No. of Companies
% of Companies
AREN'T AWARE
OF REGULATIONS
EXPENSE
DON'T CARE
TOO MANY REGS/
TOO DIFFICULT
WON'T GET CAUGHT
FINES AREN'T STIFF
ENOUGH
DON'T BELIEVE
THREAT EXISTS
LACK OF PERSONNEL
AFRAID OF PENALTIES
WASTE OF MONEY
MOST TRY TO COMPLY
SHOULD BE INFORMED
     53
     27
     53.5
     27.3
                               4.0
                               4.0
                               4.0
                               1.0
                               1.0
                               1.0
                               1.0
                               1.0
                               1.0
                               1.0
                           Missing = 1

-------
 tt
 u
ffi
E-
      ^
      o
      ft
      U
Q

fe
O
PL,

CQ
                                                     a?
                                                     o

-------
                                    9
                              TABLE
HOW FAMILIAR MANUFACTURING COMPANIES ARE WITH EPCRA & SECTION 313
Question
             Yes/Smwhat
%Yes
No
% No
# Missing
Familiar
with EPCRA?
               73
73.0
27
27.0
Familiar
with
Section 313?   49
                           81.7
          11
        18.3
            40

-------
                      TABLE iO
PERCENTAGE OF COMPANIES CONSULTING INFORMATION SOURCES
Sources
TRADE PUBLICATIONS
NEWSPAPERS
TELEVISION
DIRECT MAILINGS
OTHER COMPANIES
RADIO
FEDERAL REGISTER
ATTORNEYS
OUTREACH WORKSHOPS
EPA
General Information (%)
77
63
50
50
32
17
15
10
9
EPCRA
Information (%)
5
3
0
15
2
0
7
0
2
Missing = 3 Missing = 69

-------
ft
        (72
        03
        o
        CO
        o
        H
             i
             2
             o
             o
        3

                         o
                         o
                                                                                      fVJ
                                                                                           n
                                                                                           u
                                                                                           «H

                                                                                           0
                                                                                           3
                                                                                           z
                     o    o
                     -I    O
o
Cl
o
CO
o
CO
                                       B»!ir0dTii03 jo % 3-A.rvBiTi.Txm3

-------
            TABLE  / "J
AGENCIES USED FOR ENVIRONMENTAL ADVICE
Organization
STATE ENVIRNMTL AGENCY
ANOTHER
FEDERAL EPA
ALL THREE GOV. AGENCY
LOCAL ENVIRNMTL AGENCY
INTERNAL SOURCE
NONE
NONPROFIT ORGANIZATION
ATTORNEYS
Agency Used
For Advice (%)
29.2
16.7
12.5
12.5
8.3
8.3
6.3
3.1
3.1
N (Used)
28
16
12
12
8
8
6
3
3
Agency Should Be
Used For Advice (%)
26.5
1.0
19.4
23.5
22.5
5.1
0.0
2.0
0.0
N (SHOULD USE)
26
1
19
23
22
5
0
2
0
Missing = 4 Missing = 2

-------
     EPA EFFORTS TO INCREASE AWARENESS OF EPCRA
Long-term Strategies
  Yes
PUBLICIZING ENFORCEMENT
ACTIONS DETER VIOLATIONS? 72.9

AWARE OF EPCRA HOTLINE?  43.0
% No    # Missing
             27.1

             57.0
             4

             0
One-time Strategies
% Yes
AWARE OF 1992 TRI DATA?   24.2

AWARE OF EPCRA NATIONAL
INITIATIVE?                16.2
%No
             75.8
             83.8
# Missing

-------
                            TABLE JL3
     RECOMMENDED WAYS THE EPA CAN BETTER INFORM COMPANIES  OF
                    ENVIRONMENTAL REGULATIONS
Recommendation
No.  of Companies
% of Companies
DIRECT MAILERS WITH
SIMPLE LANGUAGE
REGIONAL SEMINARS IN
PLAIN ENGLISH
NEWSLETTERS/QUARTERLY
OR ANNUAL
WORK WITH LOCAL GOV'TS
AND CHAMBERS OF COMMERCE
PUBLICIZE IN TRADE
PUBLICATIONS
EPA DOING GOOD JOB
SEND A REPRESENTATIVE
NO MORE MATERIALS
MAKE INFORMATION EASIER
TO READ
CREATE AN ENVIRONMENTAL
PHONEBOOK
TELEVISION ADS
CREATE A TV STATION FOR
ENVIRONMENTAL LEGISLTION
TARGET SMALLER COMPANIES
         31
         12
          8
    31.0
    12.0
     8.0
                              6.0
                              5.0
                              4.0
                              3.0
                              3.0
                              2.0
                              2.0
                              2.0
                              1.0
                              1.0

-------
           Univariate Statistics for Size of Firm & Awareness Index
Variable=Q14ACRl
                              Univariate Procedure
AWARENESS INDEX
                                    Moments
N
Mean
Std Dev
Skewness
USS
CV
T:Mean=0
Num *= 0
M(Sign)
Sgn Rank
W: Normal

100% Max
75% Q3
50% Med
25% Ql
0% Min

Range
Q3-Q1
Mode
93
3.908602
0.671413
-0.81413
1462.25
17.17782
56.14014
93
46.5
2185.5
0.881939
Quantiles
5
4.5
4
3.5
2

3
1
4
Sum Wgts
Sum
Variance
Kurtosis
CSS
Std Mean
Pr> j T J
Num > 0
Pr>= ,' M |
Pr>= J S j
Pr
-------
                              Table
           Univariate Statistics for Size of Firm &  Awareness  Index
Variable=Q14ACRl
               Univariate Procedure

        AWARENESS INDEX
       Stem Leaf
         50 000000
         48
         46
         44 00000000000000000000000
         42
         40 0000000000000000000000000000000000000
         38
         36
         34 000000000
         32
         30 00000000000000
         28
         26
         24 0
         22
         20 000
            	+	+	+	+	+	+	+—
        Multiply Stem.Leaf by 10**-1
                                       #
                                       6
                                      23

                                      37


                                       9

                                      14


                                       1

                                       3
                                   Boxplot
                                                     I
                                                     *.
                                         i
                                         i
                                         •it
5.1+
               4.5+
3 . 9+
3.3+
2.7+
                                 Normal Probability Plot
                                                            *+** *
                                       ***********
                                           +++
                                    ***+
                                  +++
                            ********
                         +++
       +++ *

2.1+*   * *
    + ---- +
        -2
-1
                                      +1
                                                               +2
                                Frequency Table
                 Value Count
                     2     3
                   2.5     1
                     3    14
                   3.5     9
                Percents
               Cell   Cum
                3.2   3.2
                1.1   4.3
               15.1  19.4
                9.7  29.0
              Value Count
                  4    37
                4.5    23
                  5     6
                                              Percents
                                             Cell   Cum
                                             39.8  68.8
                                             24.7  93.5
                                              6.5 100.0

-------
                                   Ifc
                        TABLE
      AVERAGE DIFFERENCES ON AWARENESS INDEX BY
ADEQUACY OF INFORMATION RECEIVED BY FIRMS FROM THE EPA
RECEIVED ADEQUATE INFORMATION FROM THE EPA?

                              Average        Standard error

DISAGREE                      4.09           0.08

AGREE                         3.62           0.12


Variances	T	DF	Prob>/T7

Unequal        3.2799         63.9      0.0017
Equal          3.3262         89.0      0.0013

T-TEST
Ho: Average for disagree group = average for agree group
Ha: Average for disagree group not equal average for agree group

No significant difference between Averages and  Standard errors of
Disagree and Agree groups. Therefore use Equal  Variances.

If Prob>/T/ is smaller than 0.05, then reject the  null (Ho)
hypothesis of no difference between two groups. If Prob>/T/ is
larger than 0.05, accept the null (Ho) of no difference.

T = 0.0013 < 0.05
Therefore, there is a significant difference between two groups.

Meaning;
Those who have not received adequate info from  the EPA feel
they'd be more likely to comply if they were made  more aware.

However, those who have received adequate info  do  not believe as
strongly that companies would comply if they were  made more
aware. Once companies are made aware, they don't seem to value
the information.

-------
                              TABLE -L I
            AVERAGE DIFFERENCES ON AWARENESS INDEX BY
                COMPANIES' FAMILIARITY WITH EPCRA
ARE YOU FAMILIAR WITH EPCRA?

DISAGREE
AGREE
Variances T
Unequal -0.0383
Equal -0.0423
T-TEST
Average
3.90
3.91
DF
37.9
91.0

Sta
0.1
0.0
Prob>/T/
0.9697
0.9663

                                             Standard error
Ho: Average for disagree group = average for agree group
Ha: Average for disagree group not equal average for agree group

No significant difference between Averages and Standard errors of
Disagree and Agree groups. Therefore use Equal Variances.

If Prok»/T/ is smaller than 0.05, then reject the null (Ho)
hypothesis of no difference between two groups. If Prob>/T/ is
larger than 0.05, accept the null (Ho) of no difference.

T= 0.9663 > 0.05
Therefore, there is no significant difference between two groups.

Meaning;
There is no difference in how companies view the relationship
between awareness and compliance and whether or not they're
familiar with EPCRA.

-------
                     TABLE
BIVARIATE FREQUENCY TABLE FOR EPCRA SURVEY DATA
Familiar with EPCRA by Received Adequate Informatio
Familiar with EPCRA
         Received Adequate Information

Frequency
Expected
Percent
Row %
Column %
         DISAGREE
       AGREE
NO
YES
TOTAL
            TOTAL
    21
17.082
 21.43
 77.78
 33.87

    41
44.918
 41.84
 57.75
 66.13

    62
 63.27
6
9.9184
6.12
22.22
16.67
27

27.55


30
26.082
30.61
42.25
83.33
71

72.45


         Gamma =
         36       98
      36.73      100

     Missing = 2

Value       ASE
0.438       0.211

-------
               APPENDIX B:
PRESS RELEASES TO ANNOUNCE EPCRA INITIATIVE

-------
EmfaanronW PM^Uui                    841 Chain* Baking
Agency                         PMMlel|j|
-------
     The initiative is focused on making companies aware of their obligations for
complying with EPCRA.  It is also intended as a reminder of the July 1st deadline for
filing toxic chemical release forms with EPA headquarters and designated state
agencies.

    EPA Administrator Carol M. Browner said, "Today's actions reflect EPA's
determination to vigorously enforce the data reporting requirements of our environmental
laws and to ensure the integrity of the data submitted. Pollution prevention is the
cornerstone of environmental protection, and accurate data and information are essential
to planning and tracking pollution prevention."

    Companies must file one toxic chemical release form for each chemical listed in
EPCRA Section 313 that exceeds the specified threshold level. Subject facilities which
do not report may face fines of up to $25,000 per day per chemical.

    John Evan's Sons is located in Montgomery County and employs 80 people. The
company manufactures metal coil springs from metal wire (Standard Industrial
Classification code 3495). An inspection by  the EPA revealed that the company
otherwise used trichloroethylene in excess of the 10,000  pound threshold
reporting level for 1988, 1989 and 1990.  However, the company failed to file toxic
chemical release forms for each of these years.

    Companies are required to submit toxic chemical release forms if they conduct
manufacturing operations (primary Standard Industrial Classification codes 2000-3999),
employ 10 or more people,  and manufacture, process or use any of the more than  300
toxic chemicals listed under Section 313 above designated threshold levels.

    The reported information is compiled to form the Toxic Release Inventory (TRI),  a
database that is directly available to the public. This information is published in an
annual printed report and is available through the National Library of Medicine
Toxnet and at most public and university libraries. A copy of the database can also be
purchased on compact disc or magnetic media.

    Facilities must annually submit a completed toxic chemical release form, for each
toxic chemical subject to reporting, by July 1 for releases covering the preceding
calendar year. The next forms are due by July 1, 1993 for calendar year 1992.  To
receive the most current version of the toxic chemical release form with instructions,
companies can call the EPCRA Hotline at 1-800-535-0202.

    This initiative directly follows a press conference Browner held on Tuesday,  May 25,
1993 to announce the release of the 1991 TRI data.  Browner also announced that  by
November 1, 1993, the  EPA expects to expand the list of 300 chemicals by
approximately 200 and  require federal facilities to report.
                                 #  #  #  #  #

-------
UnMSMH
ni»lri«»nii
-------
EPA headquarters in Washington, DC.  The Region III office of the EPA, which issued the
complaint, has joined with nine other regional offices in filing complaints seeking a total
of $2.8 million against 37 manufacturing companies nationwide.

      The initiative is focused on making companies aware of their obligations for
complying with EPCRA.  It is also intended as a reminder of the July 1st deadline for
filing toxic chemical release  forms with  EPA headquarters and  designated state
agencies.

      EPA Administrator Carol M. Browner said, "Today's actions reflect EPA's
determination to vigorously enforce the data reporting requirements of our environmental
laws and to ensure the integrity of the data submitted.  Pollution prevention is the
cornerstone of environmental protection, and accurate  data and information are essential
to planning and tracking pollution prevention."

    Companies must file one toxic chemical release form for each chemical listed in
EPCRA Section 313 that exceeds the specified threshold level.  Subject facilities which
do not report may face fines of up to $25,000 per day per chemical.

      Lynchburg Steel is located in Amherst County and employs 34 people.  The
company produces fabricated structural metal (Standard Industrial Classification code
3441). An inspection by the EPA revealed that the company used xylene in excess of
the 10,000 pound threshold reporting level for 1989 and 1990.   However, the company
failed to file toxic chemical release forms for xylene for these years.

      Companies are required to submit toxic chemical release forms if they conduct
manufacturing operations (primary Standard Industrial Classification codes 2000-3999),
employ 10 or more people,  and manufacture, process  or use any of the more than 300
toxic chemicals listed under Section 313 above designated threshold levels.

    The reported information is compiled to form the Toxic Release Inventory (TRI), a
database that is directly  available to the public.  This information is published in an
annual printed report and is also available through the National Library of Medicine
Toxnet national computer database and at most public and university libraries.  A copy
of the database can also be purchased on compact disc or magnetic media.

      Facilities must annually submit a completed toxic chemical release form, for each
toxic chemical subject to reporting, by  July 1 for releases covering the  preceding
calendar year. The next reports are due by July 1, 1993 for calendar year 1992. To
receive the most current version of the toxic chemical release form with instructions,
companies can call the EPCRA Hotline at 1-800-535-0202.

    This initiative directly follows a press conference Browner held on Tuesday, May 25,
1993 to announce the release of the 1991  TRI data. Browner also announced that by
November 1,  1993, the EPA expects to expand the list of 300 chemicals by
approximately 300 and require federal facilities to report.
                                  # #  #  # #

-------
Untod State.                          ItogianM
EmiranmnM Protection                   841 Chntnut BuMmg
                                                             PI 5)597-8825
Official Burinm
PunaJtyfaf Private Un>
$300
          EPA  Environmental  News
                               Contact: Carrie Deitzel
                               (215) 597-6728
                               93-067; June 3, 1993
FOUR REGION III COMPANIES INCLUDED IN EPA EPCRA NATIONAL INITIATIVE

   PHILADELPHIA- The U.S. Environmental Protection Agency (EPA) today filed civil

administrative complaints against four companies in West Virginia, Pennsylvania and

Virginia for total penalties of $81,000 for failing to report the use and release of

toxic substances such as zinc compounds, nitroglycerin and trichloroethylene. The

complaints represent violations of Section 313 of the Emergency Planning and

Community Right-to-Know Act (EPCRA), the federal law requiring the reporting of toxic

chemical uses, releases and off-site transfers. EPCRA is intended to provide the general

public and communities surrounding regulated facilities with crucial information on toxic

chemical emissions.

-------
   The complaints are included in an EPCRA National Initiative announced today by
EPA headquarters in Washington, DC.  The Region III office of the EPA, which issued the
four complaints, has joined with 9 other regional offices in filing complaints
seeking a total of $2.8 million against 37 manufacturing companies nationwide.

   The initiative is focused on making  companies aware of their obligations for
complying with EPCRA.  It is also intended as a reminder of the July 1st deadline for
filing toxic chemical release forms with  EPA headquarters and designated state
agencies.

   EPA Administrator Carol M Browner said, "Today's actions reflect EPA's
determination to vigorously enforce the data reporting requirements of our environmental
laws and to ensure the integrity of the data submitted. Pollution prevention is the
cornerstone of environmental protection, and accurate data and information are  essential
to planning and tracking pollution prevention."

   Companies must file one toxic chemical release form for each chemical listed  under
EPCRA Section 313 that exceeds the specified threshold level.  Subject facilities which
do not report may face fines of up to $25,000 per day per chemical.

   The four companies from Region III against which complaints have  been filed are
ACTIV Industries, Inc., Kearneyville, WV; American National Rubber Co., Ceredo, WV;
John  Evan's Sons,  Lansdale, PA; and Lynchburg Steel and Specialty Co., Monroe, VA.

   Companies are required to submit toxic chemical release forms if they conduct
manufacturing operations (primary Standard Industrial Classification codes 2000-3999),
employ 10 or more people, and manufacture, process or use any of the more than 300
toxic chemicals listed under Section  313 above designated threshold levels.

   The reported information is compiled to form the Toxic Release Inventory (TRI), a
database that is directly available to  the public.  This information is published  in an
annual printed report and is also available through the National Library of
Medicine Toxnet national computer database and at most public and university libraries.
A copy of the database can also be  purchased on compact disc or magnetic  media.

   Facilities must annually submit a completed toxic chemical release  form (for each
toxic chemical subject to reporting) by  July 1 for releases covering the  preceding
calendar  year. The next reports are due by July 1, 1993 for calendar year 1992. To
receive the most current version of the toxic chemical release form with instructions,
companies can call the EPCRA Hotline at 1-800-535-0202.

   This initiative directly follows a press conference Browner held on Tuesday,  May 25,
1993 to announce the release of the 1991 TRI data.  Browner also announced that by
November 1, 1993, the EPA expects to expand the list of 300 chemicals by
approximately 200 and require federal facilities to report.
                                   #  #   #  #

-------
                             •41 Owkm* Bk***j
Agmy                        PH*i*pH*,t>*mmfi~rim 1M07                     ptS)SS7
$300
          EPA Environmental  News
                              Contact: Carrie Deitzel
                              (215) 597-6728
                              93-067; June 3, 1993
FOUR REGION III COMPANIES INCLUDED IN EPA EPCRA NATIONAL INITIATIVE


   PHILADELPHIA- The U.S. Environmental Protection Agency (EPA) today filed civil

administrative complaints against four companies in West Virginia, Pennsylvania and

Virginia for total penalties of $81,000 for failing to report the use and release of

toxic substances  such as zinc compounds, nitroglycerin and trichloroethylene. The

complaints represent violations  of Section 313 of the Emergency Planning and

Community Right-to-Know Act (EPCRA), the federal law requiring the reporting  of toxic

chemical uses, releases and off-site transfers. EPCRA is intended to provide the general

public and communities surrounding regulated facilities with  crucial information on toxic

chemical emissions.

-------
   The complaints are included in an EPCRA National Initiative announced today by
EPA headquarters in Washington, DC.  The Region III office of the EPA, which issued the
four complaints, has joined with 9 other regional offices in filing complaints
seeking a total of $2.8 million against 37 manufacturing companies nationwide.

   The initiative is focused on making  companies aware of their obligations for
complying with EPCRA.  It is also intended as a reminder of the July 1st deadline for
filing toxic chemical release forms with  EPA headquarters and designated state
agencies.

   EPA Administrator Carol M Browner said, "Today's actions reflect EPA's
determination to vigorously enforce the data reporting requirements of our environmental
laws and to ensure the integrity of the data submitted. Pollution prevention is the
cornerstone of environmental protection, and accurate data and information are essential
to planning and tracking pollution prevention."

   Companies must file one toxic chemical release form for each chemical listed under
EPCRA Section 313 that exceeds the specified threshold level.  Subject facilities which
do not report may face fines of up to $25,000 per day per chemical.

   The four companies from Region III against which complaints have  been filed are
ACTIV Industries, Inc., Kearneyville, WV; American National Rubber Co., Ceredo/WV;
John Evan's Sons, Lansdale, PA; and Lynchburg Steel and Specialty Co., Monroe, VA.

   Companies are required to submit toxic chemical release forms if they conduct
manufacturing operations (primary Standard Industrial Classification codes 2000-3999),
employ 10 or more people, and manufacture, process or use any of the more than 300
toxic chemicals listed under Section  313 above designated threshold levels.

   The reported information is compiled to form the Toxic  Release Inventory (TRI), a
database that is directly available to  the public.  This information is published in an
annual printed report and is also available through the National Library of
Medicine Toxnet national computer database and at most public and university libraries.
A copy of the database can also be  purchased on compact disc or magnetic media.

   Facilities must annually submit a completed toxic chemical release  form (for each
toxic chemical subject to reporting) by  July 1 for releases covering the  preceding
calendar year. The next reports are due by July 1, 1993 for calendar year 1992. To
receive the most current version of the toxic chemical release form with instructions,
companies can call the EPCRA Hotline at  1-800-535-0202.

   This initiative directly follows a press conference Browner held on Tuesday, May 25,
1993 to announce the release of the 1991  TRI data.  Browner also announced that by
November 1,  1993, the EPA expects to expand the list of 300 chemicals by
approximately 200 and require federal facilities to report.
                                   #  #  #

-------
 Agancy           	          n+mtaW*,***-!!**** 191O7                      P1S)SB7-
  Pmfty for Private Un
  $300
(m)    EPA Environmental  News
 % ~««<.
-------
   The initiative is focused on making companies aware of their obligations for
complying with EPCRA.  It is also intended as a reminder of the July 1st deadline for
filing toxic chemical release forms with EPA headquarters and designated state
agencies.

   EPA Administrator Carol M. Browner said, "Today's actions reflect EPA's
determination to vigorously enforce the data reporting requirements of our environmental
laws and to ensure the integrity of the data submitted. Pollution prevention is the
cornerstone of environmental protection, and accurate data and information are essential
to planning and tracking pollution prevention."

   Companies must file one toxic chemical release form for each chemical listed in
EPCRA Section 313 that exceeds the specified threshold level. Subject facilities which
do not report may face fines of up  to $25,000 per day per chemical.

   American National Rubber Company is located in Wayne County and employs 175
people. The company manufactures gaskets, packing and  sealing devices (Standard
Industrial Classification code 3053). An inspection by the EPA revealed that the
company used zinc compounds in excess of the 25,000 pound threshold reporting levels
for 1988, 1989 and 1990. However, the company failed to file toxic chemical release
forms for zinc compounds for these years.

   ACTIV Industries is located in Jefferson County and employs 25 people.  The
company manufactures shotgun shells and  small arms ammunition (Standard Industrial
Classification code 3483). An  inspection by the EPA revealed that the company
processed nitroglycerin in excess of the 25,000 pound threshold reporting level for 1990.
However, the company failed to file a 1990 toxic chemical release form for nitroglycerin.

      Companies are required to submit toxic chemical release forms if they conduct
manufacturing operations (primary Standard Industrial Classification codes 2000-3999),
employ 10 or more people, and manufacture, process or use any of the more than 300
toxic chemicals listed under Section 313 above designated  threshold levels.

   The reported information is compiled to form the Toxic Release Inventory (TRI), a
database that is directly  available to the  public.  This information is published in an
annual printed report and is available through the National Library of Medicine
Toxnet national computer database and  at most public and university libraries.  A copy
of the database can also be purchased on compact disc or magnetic media.

      Facilities must annually submit a completed toxic chemical  release form  (for each
toxic chemical subject to reporting) by July 1 for releases covering the preceding
calendar year. The next forms are due by July 1, 1993 for calendar year 1992. To
receive the most current version of the toxic chemical release form with instructions,
companies can call the EPCRA Hotline at 1-800-535-0202.

   This initiative directly follows a  press conference Browner held on Tuesday, May  25,
                                     -More-

-------
1993 to announce the release of the 1991 TRI data.  Browner also announced that by
November 1, 1993, the EPA expects to expand the list of 300 chemicals by
approximately 200 and require federal facilities to report.

                                #  #  #  #  #

-------
       APPENDIX C:
   LIST OF PUBLICATIONS
WHERE RELEASES WERE SENT

-------
           PUBLICATIONS WHERE PRESS RELEASES WERE SENT
              TO ANNOUNCE EPCRA NATIONAL INITIATIVE
To Receive Regional Press Release:
1) Advanced Materials and Processes
9639 Kinsman Road
Materials Park, OH 44073-0002
(216) 338-5151
fax  (216) 338-4634

2) Agricultural Chemical News
PO Box 9335
Fresno, CA 93791-9335
(209) 435-2163
fax  (209) 435-8319

3) American Druggist
60 E. 42nd Street
New York, NY 10165-0012
(212) 297-9680
fax  (212) 286-9886

4) American Drycleaner
500 N. Dearborn Street
Chicago, IL 60610-4901
(312) 337-7700
fax  (312) 337-8654

5) American Machinist
826 Broadway, 4th Floor
New York, NY 10003
(212) 477-6420
fax  (212) 477-6457

6) American Pharmacy
2215 Constitution Avenue, NW
Washington, DC 20037-2976
(202) 628-4410
fax  (202) 783-2351

7) APICS. The Performance Advantage
2555 Cumberland Parkway, #299
Atlanta, GA 30339
(404) 435-2849
fax  (404) 432-6969

8) ASHRAE Journal
1791 Tullie Circle, NE
Atlanta, GA 30329-2305
(404) 636-8400
fax  (404) 321-5478

-------
9) Associated Press
222 St. Paul Place, Suite 400
Baltimore, MD 21202
(410)  539-3524
fax (410) 727-1550
10) Associated Press
2021 K Street, NW, Suite 606
Washington, DC 20006
(202) 828-6400
fax  (202) 828-6422

11) Automotive Engineering
400 Commonwealth Drive
Warrendale, PA 15096-0001
(412) 776- 4841
fax  (412) 776-9765

12) Automotive Industries
1 Chilton Way
Radnor, PA 19089
(215) 964-4254
fax  (215) 964-4981

13) Automotive News
841 National Press Building
Washington, DC 20045
(202) 662-7200
fax  (202) 638-3155

14) Baltimore Sun, The
50 N. Calvert
Baltimore, MD 21278
(410) 332-6000
fax  (410) 752-6049

15) Builder
655 15th Street, NW, #475
Washington, DC 20005-5701
(202) 737-0717
fax  (202) 737-2439

16) Building Design & Construction
1350 E. Touhy Avenue
Des Plaines, IL 60018-3303
(708) 635-8800
fax  (708) 299-8622

17) Building Products
655 15th Street, NW, #475
Washington, DC 20005-5701
(202) 737-0717
fax  (202) 737-2439

-------
18) Cars & Parts
P.O. Box 482
Sidney, OH 45365-0482
(513) 498-0803
fax  (513) 498-0808

19) Chemical & Engineering News
1155 16th Street, NW
Washington, DC 20036-4800
(202) 872-4600
fax  (202) 872-6381

20) Chemical Engineering
108 Hamilton Avenue
Silver Springs, MD 20901-3415
(301) 565-2798
fax  (301) 565-2798 (home#)

21) Chemical Equipment
301 Gibraltar Drive
Morris Plains, NJ 07950-3406
(201) 292-5100
fax  (201) 539-3476

22) Chemical Processing
301 E. Erie Street
Chicago, IL 60611-3037
(312) 644-2020
fax  (312) 644-1131

23) Chemical Week
810 Seventh Avenue
New York, NY 10019-5849
(212) 586-3430
fax  (212) 621-4950

24) Coal
101 Pine Villa Drive
Beckley, WV 25801-9358
(304) 252-6801
fax  (312) 726-2574

25) Contracting Business
1100 Superior Avenue
Cleveland, OH 44114-2518
(216) 696-7000
(216) 696-7932

26) Farm Industry News
7900 International Drive, #300
Minneapolis, MN 55425-1510
(612) 851-9329
fax (612) 851-4601

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27) Gannett News Service
PO Box 7858
Washington, DC 20044
fax (202) 243-0190

28) International Operating Engineer
1125 17th Street, NW
Washington, DC 20036-4707
(202)  429-9100
fax (202) 429-0316

29) Journal of Petroleum Technology
P.O. BOX 833836
Richardson, TX 75083-3836
(214)  669-3377
fax (214) 952-9435

30) Maintenance Technology
1300 S. Grove Avenue, #205
Harrington, IL 60010-5262
(708)  382-8100
fax (708) 304-8603

31) Managing Automation
5 Penn Plaza
New York, NY 10001-1810
(212)  695-0500
fax (212) 629-1584

32) Maryland PHCC News & Views
10176 Baltimore National Pike, #205
Ellicot City, MD 21043-3652
(410)  461-5977
fax (410) 750-2507

33) Material Handling Engineering
1100 Superior Avenue
Cleveland, OH 44114-2518
(216)  696-7000
fax (216) 696-7658

34) Materials Engineering
1100 Superior Avenue
Cleveland, OH 44114-2518
(216)  696-7000
fax (216) 696-0177

35) Metal Forming
27027 Chardon Road
Richmond Heights, OH 44143-1193
(216)  585-8800
fax (216) 585-3126

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36) Metals Week
1221 Avenue of the Americas
New York, NY 10020-1001
(212) 512-2823
fax  (212) 512-2949

37) Metalworking Digest
P.O. Box 650
Morris Plains, NJ 07950-0650
(201) 292-5100
fax  (201) 898-9281

38) Metlflax Magazine
29100 Aurora Road, #200
Cleveland, OH 44139-1855
(216) 248-1125
fax  (216) 248-0187

39) Modern Materials Handling
275 Washington Street
Newtown, MA 02158-1611
(617) 964-3030
fax  (617) 558-4402

40) Modern Plastics
1221 Avenue of the Americas
New York, NY 10020-1001
(212) 512-6241
fax  (212) 512-6111

41) National Clothesline, The
717 E. Chelten Avenue
Philadelphia, PA 19144-1298
(215) 843-9795
fax  (215) 843-8511

42) New Equipment Digest
1100 Superior Avenue
Cleveland, OH 44114-2518
(216) 696-7000
fax  (216) 696-7932

43) Packaging
1350 E. Touhy Avenue
Des Plaines, IL 60018-3303
(708) 635-8800
fax  (708) 635-6856

44) Packaging Digest
400 N. Michigan Avenue
Chicago, IL 60611-4187
(312) 222-2000
fax  (312) 222-2026

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45) Painters and Allied Trades Journal, The
1750 New York Avenue, NW
Washington, DC 20006-5301
(202) 637-0700
fax  (202) 637-0771

46) Pennsylvania Contractor
4015 Jonestown Road
Harrisburg, PA 17109-2212
(717) 541-9109
fax  (717) 541-9823

47) Pharmacy Times
PO Box 911
Port Washington, NY 11050-0241
(516) 883-6350
fax  (516) 883-6609

48) Plant Engineering
1350 E. Touhy Avenue
Des Plaines, IL 60018-3303
(708) 635-8800
fax  (708) 390-2636

49) Plant Services
301 E. Erie Street
Chicago, IL 60611-3037
(312) 644-2020
fax  (312) 644-1131

50) Plastics News
1725 Merriman Road
Akron, OH 44313-5283
(216) 836-9180
fax  (216) 836-2322

51) Plastics World
275 Washington Street
Newton, MA 02158-1611
(617) 558-4232
fax  (617) 558-4417

52) Plastics World  (NY)
249 w. 17th Street
New York, NY 10011-5300
(212) 645-0067
fax  (212) 463-6404

53) Processing
301 E. Erie Street
Chicago, IL 60611-3037
(312) 644-2020
fax  (312) 644-1131

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54) Production
6600 Clough Pike
Cincinnati, OH 45244-4028
(513) 231-8020
fax  (513) 231-2818

55) Quality
191 Gary Avenue South
Carol Stream, IL 60188-2095
(708) 665-1000
fax  (708) 462-2225

56) Quality Progress
310 W. Wisconsin Avenue
Milwaukee, WI 53203-2205
(414) 272-8575
fax  (414) 272-1734

57) Reuters Limited
1700 Broadway
New York, NY 10019
(212) 603-3300
fax  (212) 603-3446

58) Reuters Limited
1333 H Street, NW, Suite 410
Washington, DC 20005
(202) 898-8300
fax  (202) 898-8383

59) Surplus Record
20 N. Wacker Drive
Chicago, IL 60606-3181
(312) 372-9077
fax  (312) 372-6537

60) Tire Business
814 National Press Building
Washington, DC 20045
(202) 662-7200
fax  (202) 638-3155

61) Today's Chemist
500 Post Road East
Westport, CT 06880-4431
(203) 226-7131
fax  (203) 454-9939

62) U.A. Journal
P.O. Box 37800
Washington, DC 20013-7800
(202) 628-5823
fax  (202) 628-5024

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63) United Press
1400 Eye Street, NW, Suite 800
Washington, DC 20005
(202) 898-8000
fax  (202) 789-2362

64) U.S. Pharmacist
352 Park Avenue South
New York, NY 10010-1709
(212) 685-4848
fax  (212) 696-5318

65) U.S. Oil Week
1101 King Street, #444
Alexandria, VA 22314-2944
(703) 683-4100
fax  (703) 739-6517

66) Washington Post, The
1150 15 St., NW
Washington, DC 20071
(202) 334-6000
fax nat'l (202) 334-5547
fax local (202) 334-5661

67) Washington Times
3600 New York Avenue, NE
Washington, DC 20002
(202) 636-3000
fax  (202) 269-3419

To Receive West Virginia Press Release:
68) Associated Press
1001 Virginia St. E., Suite 206
Charleston, WV 25301
(304) 346-0897
fax  (304) 345-5282

69) Huntington Herald Dispatch
P.O. Box 2017, 946 Fifth Avenue
Huntington, WV 25720
(304) 526-4000

70) Martinsburg Journal
P.O. Box 807
207 W. King Street
Martinsburg, WV 25401
(304) 263-8931
fax  (304) 263-8058

71) Spirit of Jefferson
P.O. Box 966
Charles Town, WV 25414
(304) 725-2046

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72) Wheeling Intelligencer/News Register
1500 Main Street
Wheeling, WV 26003
(304) 233-0100
fax  (304) 233-0100 x287
To Receive Virginia Press Release:
73) Associated Press
700 E. Main, Suite 1300
Richmond, VA 23219
(804) 643-6646
fax  (804) 643-6223

74) Bedford Bulletin
P.O. Box 331
Bedford, VA 24523
(703) 586-8612
fax  (703) 586-0834

75) Danville Register & Bee
700 Monument Street
Danville, VA 24541
(804) 793-2311
fax  (804) 797-2299

76) Lynchburg News and Advance
P.O. Box 10129
101 Wyndale Drive
Lynchburg, VA 24506
(804) 385-5941

77) New Era-Progress
P.O. Box 90
Amherst, VA 24521
(804) 946-7195

78) Richmond News Leader
Box C-32333
333 E. Grace Street
Richmond, VA 23293
(804) 649-6000

79) Richmond Times Dispatch
Box C-32333
333 E. Grace Street
Richmond, VA 23293
(804) 649-6000

80) Times-Virginian
P.O.Box 2097
Appomattox, VA 24522
(804) 352-8215
fax  (804) 352-2216

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To Receive Pennsylvania Press Release:
81) Associated Press
One Franklin Plaza, Suite 250
Philadelphia, PA 19102
(215) 561-1133
fax  (215) 561-3544

82) Bucks-Mont Courier
P.O. Box 204
Harleysville, PA 19438
(215) 721-9100

83) Lansdale Reporter, The
P.O. Box 390
307 Derstine Avenue
Lansdale, PA 19446
(215) 855-8440
fax  (215) 368-5367

84) Montgomery Co. Observer
1050 Route 202
Blue Bell, PA 19422
(215) 277-6342

85) Norristown Times - Herald
P.O. Box 591
410 Markley Street
Norristown, PA 19404
(215) 272-2500
fax  (215) 272-4003

86) Philadelphia Inquirer
P.O. Box 8263
400 N. Broad Street
Philadelphia, PA 19101
(215) 854-2000
fax  (215) 854-4794

87) Philadelphia News
P.O. Box 7788
400 N. Broad Street
Philadelphia, PA 19101
(215) 854-5900
fax  (215) 854-5524

88) Phoenixville Phoenix
225 Bridge Street
Phoenixville, PA 19460
(215) 933-8926
fax  (215) 933-1181

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89) Reporter, The
P.O. Box 28
Royersford, PA 19468
(215) 948-4850
fax  (215) 948-5914

90) Schwenksville Item
P.O. Box 38
Schwenksville, PA 19473
(215) 287-8131
fax  (215) 489-4252

91) United Press
1819 JFK Boulevard, Suite 301
Philadelphia, PA 19103
(215) 563-6008
fax  (215) 563-3778

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             APPENDIX D:
SURVEY INSTRUMENT AND DATA CONTROL LOG

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               SURVEY INSTRUMENT FOR EPCRA PROJECT
     Can I speak with someone who handles environmental laws and
regulations at your company?

     Hello, my name is Christine Eustis. I am a graduate student
at Penn State University. This summer I received a fellowship
from the federal Environmental Protection Agency's Region III
Office of External Affairs to study communication techniques at
government environmental agencies. I'm mainly interested in
finding out what you think about the government's current
environmental outreach strategies and how they can be improved to
better inform companies like yours about environmental
policies.

     Your company has been selected at random to be included in
the telephone survey.

     Do you have 10-15 minutes to answer the questions on the
survey? We can do the survey now, if you have time, or set up a
time that I can call back; whichever is most convenient for you.


(If they say YES, we can do it now, read below)

     Before we begin, let me assure you that all your responses
are completely confidential and are not linked in any way to you,
your company or your telephone number. I am only interested in
general statistics, not specific characteristics about your
company.
(If they say NO, emphasize the importance of their responses in
helping the government better assist companies through public
relations campaigns. Also, reiterate that their responses will be
anonymously entered into a database without any link to their
name, company name or phone number. The data from 100 companies
will be entered and analyzed for general statistics only.)
SET UP TIME TO CALL BACK

OR

CONTINUE WITH SURVEY

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First, i am going to ask you general questions about the
government's present communication techniques.

1) How do you feel about the amount of publicity the EPA uses to
announce environmental laws. Do you feel the EPA publicizes too
much, about the right amount, or too little on environmental
regulations?

                    NOT ENOUGH          1
                    ABOUT RIGHT         2
                    TOO MUCH            3
                    DON'T KNOW          8
                    REFUSAL             9
2) From what media or other information source do you receive
news about federal environmental laws and regulations? I'm going
to read the choices once. Please select all choices that apply.
(READ RESPONSES. CHECK ALL THAT APPLY.)

          FEDERAL REGISTER    1              DIRECT MAILERS  7
          TELEVISION          2    	   OTHER COMPANIES  10

          NEWSPAPERS          3	RADIO            11

          TRADE PUBLICATIONS  4	ANOTHER 	      12

          ATTORNEYS           5	DON'T KNOW      8

          OUTREACH WORKSHOPS  6              REFUSAL         9
     2a) Which one source keeps you best informed?


3) What trade publication(s), if any, does your company (or
division) subscribe to? 	

4) What agency or organization do you most rely on for
information and advice on environmental regulations? Again, I'm
going to read all the choices. Please choose the best one. (READ
ALL RESPONSES.)

     LOCAL ENVIRONMENTAL AGENCY                             1
     STATE ENVIRONMENTAL AGENCY                             2
     FEDERAL ENVIRONMENTAL PROTECTION AGENCY                3
     NONPROFIT ORGANIZATION                                 4
     ATTORNEYS (LEGAL COUNSEL)                              5
     INTERNAL SOURCE (PLEASE SPECIFY 	)  6
     ANOTHER	7
     DON'T KNOW                                             8
     REFUSAL                                                9

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     ALL THREE GOVERNMENT AGENCIES                          10
     ENVIRONMENTAL CONSULTANT                               11
     NONE                                                   12

5) In your opinion, what agency or organization should be
primarily responsible for keeping companies like yours informed
about environmental laws and regulations? The choices are the
same: (READ ALL RESPONSES.)

     LOCAL ENVIRONMENTAL AGENCY                             1
     STATE ENVIRONMENTAL AGENCY                             2
     FEDERAL ENVIRONMENTAL PROTECTION AGENCY                3

     NONPROFIT ORGANIZATION                                 4
     ATTORNEYS (LEGAL COUNSEL)                              5
     INTERNAL SOURCE (PLEASE SPECIFY 	)  6
     OTHER	   7
     DON'T KNOW                                             8
     REFUSAL                                                9
     ALL THREE GOVERNMENT AGENCIES                          10
     ENVIRONMENTAL CONSULTANT                               11
     NONE                                                   12

     (ASK IF THEY ANSWERED 1, 2, OR 3 TO ABOVE QUESTION:)
     *6) Since you believe it is the government's
     responsibility, what methods do you feel would be most
     effective in educating companies like yours about
     environmental laws and regulations, given limited
     resources? 	

7) Are you in contact at all with your Local Emergency Planning
Committee and/or State Emergency Response Commission?

          NO                       1
          YES                      2
          DON'T KNOW               8
          REFUSAL                  9

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Now I am going to ask you more specific questions about the
Emergency Planning and Community Right-to-Know Act
(commonly referred to as EPCRA or SARA TITLE III).

8) Are you familiar with the regulations under EPCRA (often
referred to as the Right-to-Know Act)?

          NO                       1 (IF NO, 60 TO QUES. 15)
          SOMEWHAT                 2
          YES                      3
          DON'T KNOW               8
          REFUSAL                  9
     *9) (IF SOMWHAT OR YES) How did you became aware of
     this statute? (READ RESPONSES. CHECK ALL THAT APPLY.)
          FEDERAL REGISTER    1              DIRECT MAILERS   7
          TELEVISION          2	CO. WHO VIOLATED 10

          NEWSPAPERS          3	RADIO            11

          TRADE PUBLICATIONS  4	OTHER 	 12

          ATTORNEYS           5	DON'T KNOW       8

          OUTREACH WORKSHOP   6              REFUSAL          9
     *9a) Which one source keeps you best informed about EPCRA?
     *10) As you might know, there are four major sections
     under EPCRA. I'm interested to know if you're familiar
     with Section 313, which pertains to release reporting
     requirements for certain toxic chemicals?
          NO                       1  (IF NO, GO TO QUES. 15)
          SOMEWHAT                 2
          YES                      3
          DON'T KNOW               8
          REFUSAL                  9

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*11)  (IF SOMEWHAT OR YES) How did you become aware of
Section 313? (READ RESPONSES. CHECK ALL THAT APPLY.)
     FEDERAL REGISTER    1              DIRECT MAILERS   7
     TELEVISION          2    	   CO. WHO VIOLATED 10

     NEWSPAPERS          3    	   RADIO            11

     TRADE PUBLICATIONS  4    	   OTHER 	 12

     ATTORNEYS           5    	   DON'T KNOW       8

     OUTREACH WORKSHOP   6              REFUSAL          9
*lla)  Which one source keeps you best informed?
*12) More specifically, are you familiar with the
threshold requirements for the toxic chemicals subject
to Section 313?

     NO                       1
     SOMEWHAT                 2
     YES                      3
     DON'T KNOW               8
     REFUSAL                  9
*13) Do you know when.the reporting deadline is for
filing toxic chemical'release inventory forms with the
EPA and designated state agencies which is stated under
Section 313?

     NO                       1
     YES                      2
     DON'T KNOW               8
     REFUSAL                  9

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14) Tell me whether you agree or disagree with each of the
following statements: This is an opinion question. Do you
strongly agree, agree, disagree or strongly disagree?

1 STRONGLY DISAGREE  2 DISAGREE  3 NEUTRAL  4 AGREE  5 STRONGLY
                                                       AGREE
8 DON'T KNOW  9 REFUSAL

A) In my opinion, the majority of companies who
don't comply with EPA regulations
aren't aware of the regulations.             1234589

B) In my opinion, I have received adequate
information from the EPA
regarding environmental regulations.         1234589

C) In my opinion, better awareness of
EPA regulations would lead to increased
compliance by affected industries.           1234589

D) In my opinion, the majority of
companies who don't comply with
EPA regulations feel that they
won't be penalized for not complying.        1234589


15) In your opinion, what do you think the primary reason is that
companies don't comply with EPA regulations? 	


16) In late May of this year, did you hear any publicity
regarding the release of the 1991 Toxic Release Inventory data?

          NO                       1 (IF NO, GO TO QDES. 18)
          YES                      2
          DON'T KNOW               8
          REFUSAL                  9

     *17) (IF YES) Where did you hear about it?
     (READ RESPONSES. CHECK ALL THAT APPLY.)

                                             DIRECT MAILERS   7
          TELEVISION          2	CO. WHO VIOLATED 10

          NEWSPAPERS          3	RADIO            11

          TRADE PUBLICATIONS  4	OTHER 	 12

          ATTORNEYS           5	DON'T KNOW       8

          OUTREACH WORKSHOP   6    	    REFUSAL          9

                                6

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*17a) Which one source kept you best informed about the TRI data?

18) Did you hear any publicity about the EPCRA National
Initiative that was announced in early June and names companies
who have recently had actions filed against them for violating
the Act?

          NO                       1 (IF NO, GO TO QUES. 20)
          YES                      2
          DON'T KNOW               8
          REFUSAL                  9
     *19)  (IF YES) Where did you hear about it?
     (READ RESPONSES. CHECK ALL THAT APPLY.)

                                             DIRECT MAILERS   7
          TELEVISION          2    	   CO. WHO VIOLATED 10

          NEWSPAPERS          3    	   RADIO            11

          TRADE PUBLICATIONS  4    	   OTHER 	 12

          ATTORNEYS           5    	   DON'T KNOW       8

          OUTREACH WORKSHOP   6              REFUSAL          9
     *19a) Which one source kept you best informed about the
National Initiative?

20) In your opinion, does publicizing enforcement actions against
companies deter other companies from violating the regulations?

          NO                       1
          YES                      2
          DON'T KNOW               8
          REFUSAL                  9
21) Are you aware that the EPA has an EPCRA NATIONAL HOTLINE
which companies can call for regulatory and technical assistance?

          NO                       1
          YES                      2
          DON'T KNOW               8
          REFUSAL                  9

22) What would you recommend to the EPA and state environmental
agencies to help them better publicize EPCRA and other
environmental regulations?	

-------
Thank you for your time, the survey is almost completed. I just
want to ask you some general questions about your company so that
I can gather a cross-section of data from different types of
companies.

23)  How many full-time employees are at your company? 	

24)  What were your estimated gross sales for the last fiscal
year? I'm going to read a series of categories. Which one does
your company fall into?

               LESS THAN 2 MILLION DOLLARS        1
               2 TO 5 MILLION DOLLARS             2
               5 TO 10 MILLION DOLLARS            3
               10 TO 50 MILLION DOLLARS           4
               50 TO 100 MILLION DOLLARS          5
               OVER 100 MILLION DOLLARS           6
               DON'T KNOW                         8
               REFUSAL                            9

25)  How much money do you estimate that your company spends
annually to comply with environmental regulations? Again, I'm
going to read categories.

               UNDER 50,000 DOLLARS                    1
               BETWEEN 50,000 AND 100,000 DOLLARS      2
               BETWEEN 100,000 AND 250,000 DOLLARS     3
               BETWEEN 250,000 AND 500,000 DOLLARS     4
               BETWEEN 500,000 AND 1 MILLION DOLLARS   5
               OVER 1 MILLION DOLLARS                  6
               DON'T KNOW                              8
               REFUSAL                                 9

26)  How many other locations does your company have?

27)  What is your primary Standard Industrial Classification code?

(This last question is optional)
*28) What types of products does your company manufacture?
Thank you so much for your time. That's the end of the survey. Do
you have any questions?
                                8

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                DATA CONTROL LOG FOR EPCRA SURVEY
Code Number:  	                  *17
4
7
14 a        b
                                        *17a
2 	                  18 _



2a 	                               *i9




3 	                  *19a




	                                20
5 	                                21




*6                                      22
8 	                                23




*9 	                  24




*9a	                               25




*10	                               26 _




*11 	                  27 _




*lla	                              *28_




*12 	                              	




*13
   c        d                           Area code:
15 	              Corresponding State:
16

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APPENDIX E:
 CODEBOOK

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CODEBOOK FOR ECPRA SURVEY
CHRISTINE EUSTIS
JULY 1993
NUMBER NAME        TYPE

     1 ID Number   Numeric

     2 Ql          Numeric
            VARIABLE DESCRIPTION

            Case number in chrono. order  #1

            Amount of EPA Publicity       Ql
     3 Q2
Numeric
Sources of EPA info
Q2
     4 Q2a

     5 Q3

       Q3.1
Numeric     Number one source

Character   Trade Publications

Numeric     Number of pubs index
                              Q2a

                              Q3

                              Q3.1
     6 Q4
Numeric
Agency most rely on
Q4
     7 Q5
Numeric
Agency should be respon.
Q5

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VARIABLE VALUES

1-100

l=Not enough
2=About right
3=Too much
8=Don't know
9=Refusal
.^Missing

l=Federal Register
2=TV
3=Newspapers
4=Trade Publications
5=Attorneys
6=0utreach workshops
7=Direct mailers
8=Don't know
9=Refusal
I0=other companies
ll=Radio
12=Another
.=Missing

Same codes as above

25 characters

0=0
1=1
2=more than 1

l=Local env. agency
2=State env. agency
3=Federal EPA
4=Nonprofit org.
5=Attorneys
6=Internal Source
7=Another
8=Don't know
9=Refusal
10=local,state&fed
1l=env.consultant
12=None
VAR. TYPE
Data Mgmt

ind. var.
TYPE DESCRIPTOR

Primary key identifier

Ordinal/discrete
ind. var,
Nominal/discrete
ind. var.

ind. var.

ind. var.



ind. var.
Nominal/discrete

Categorical variable

Nominal/discrete



Nominal/discrete
Same codes as above   ind. var,
              Nominal/discrete

-------
 8 Q6




 9 Q7
Character   Most effective methodtoinform Q6



Numeric     Contact with LEPC or SERC     Q7
10 Q8
Numeric
Familiar with EPCRA
Q8
11 Q9
Numeric
Sources of EPCRA info
Q9
12 Q9a




13 Q10
Numeric     Number one source



Numeric     Section 313 specs
                              Q9a



                              Q10
14 Qll
Numeric
Sources of EPCRA info
Qll
15 Qlla
Numeric
Number of source
Qlla

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25 characters         ind. var.     Categorical variable

l=No                  indep. var.    Ordinal/discrete
2=Yes
8=Don't know
9=Refusal
.=Missing

i=No                  dep. var.     Ordinal/discrete
2=Somewhat
3=Yes
8=Don't know
9=Refusal
.=Missing

l=Federal Register    ind. var.     Nominal/discrete
2=TV
3=Newspapers
4=Trade Publications
5=Attorneys
6=0utreach workshops
7=Direct mailers
8=Don't know
9=Refusal
10-Other companies
ll=Radio
12=Another
.=Missing

Same codes as above   ind. var.     Nominal/discrete

l=No                  dep. var.     Ordinal/discrete
2=Somewhat
3=Yes
s=Don't know
9=Refusal
,=Missing

l=Federal Register    ind. var.     Nominal/discrete
2=TV
3=Newspapers
4=Trade Publications
5=Attorneys
6=0utreach workshops
7=Direct mailers
3=Don't know
9=Refusal
I0=0ther companies
ll=Radio
12=Another
.=Missing

Same codes as above   ind. var.     Nominal/discrete

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16 Q12
Numeric
Threshold requ. Section 313   Q12
17 Q13

18 Q14A
19 Q14B
20 Q14C
21 Q14D
Numeric     Reporting deadline            Q13

Numeric     LACK OF AWARENESS             Q14
Numeric     RECEIVE ADEQUATE INFO
Numeric     BETTER AWARENESS=COMPLIANCE
Numeric     PENALIZING COMPANIES
22 Q15

23 Q16
Character   Why co. don't comply

Numeric     Publicity re: TRI data
                              Q15

                              Q16
24 Q17
Numeric
Sources of EPA info
Q17
25 Q17a

26 Q18
Numeric     Number one source             Q17a

Numeric     Publicity on national init.   Q18
27 Q19
Numeric
Sources of info
Q19

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l=No                  dep. var.     Ordinal/discrete
2=somewhat
3=Yes
8=Don't know
9=Refusal
.=Missing

Same codes as above   dep. var.     Ordinal/discrete

l=strongly Disagree   dep. var.     Ordinal/discrete
2=Disagree            or ind. var.
3=Neutral
4=Agree
5=strongly Agree
8=Don't know
9=Refusal
.^Missing

25 characters         ind. var.     Categorical variable

l=No                  ind. var.     Ordinal/discrete
2=Yes
8=Don't know
9=Refusal
.=Missing

2=TV                  ind. var.     Nominal/discrete
3=Newspapers
4=Trade Publications
5=Attorneys
6=outreach workshops
7=Direct mailers
8=Don't know
9=Refusal
10=Other companies
ll=Radio
12=Another
.=Missing

Same codes as above   ind. var.     Nominal/discrete

l=No                  ind. var.     Ordinal/discrete
2=Yes
8=Don't know
9=Refusal
.=Missing

2=TV                  ind. var.     Nominal/discrete
3=Newspapers
4=Trade Publications
5=Attorneys
6=0utreach workshops
7=Direct mailers
8=Don't know

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28 Q19a
29 Q20
Numeric     Number one source             Q19a
Numeric     Publicizing enforc. actions   Q20
30 Q21
Numeric
EPCRA National Hotline
Q21
31 Q22
32 Q23
Character   Further recommends
Numeric     Number of employees
                              Q22
                              Q23
33 EMP
33 Q24
Numeric     Actual employee count
Numeric     Gross sales for last FY
                              EMP
                              Q24
34 Q25
Numeric
Amount to comply with regs.   Q25
35 Q26
36 Q27
37 Q28
Numeric     Number of other locations     Q26
Numeric     Primary SIC code              Q27
Numeric     Products manufactured         Q28

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9=Refusal
I0=0ther companies
ll=Radio
l2=Another
.^Missing

Same codes as above   ind. var.
l=No
2=Yes
8=Don't know
9=Refusal
.=Missing

l=No
2=Yes
8=Don't know
9=Refusal
.-Missing

25 characters

l = under 50
2 = 51-300
3 = 301 and over
8=Don't know
9=Refusal
.=Missing

Numeric
dep. var.
Nominal/discrete

Ordinal/discrete
ind. var.
Ordinal/discrete
ind. var,

ind. var,
Categorical variable

Ordinal/discrete
ind. var.
l=less than 2 million ind. var.
2=2-5 million
3=5-10 million
4=10-50 million
5=50-100 million
6=over 100 million
3=Don't know
9=Refusal
Interval/discrete

Ordinal/discrete
l=Under $50K
2=$50=$100K
3=$100-$250K
4=$250-500K
5=$500K-1 million
3=Over 1 million
3=Don't know
3=Refusal
ind. var.
Ordinal/discrete
3 characters

5 characters
?0=Food
ind. var.

ind. var.

ind. var.
Categorical variable

Ordinal/discrete

Ordinal/discrete

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38 Area code   Numeric     Area code of # called



39 State       Character   Cooresponding state

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2l=Tobacco
22=Textiles
23=Apparel
2 4=Lumber,wood
25=Furniture
26=Paper
27=Printing,publishing
28=Chemicals
29=Petroleum and coal
3 0=Rubber,plastics
3l=Leather
32=Stone,clay,glass
33=Primary metals
34=Fabricated metals
35=Machinery(not electrical)
36=Electrical,electronic
37=Transportation Equip
3 8=Instruments
39=Misc. manufacturing

3 characters          ind. var.     Categorical variable

2 characters          ind. var.     Categorical variable

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             APPENDIX F:
QUESTIONS AND ANSWERS USED FOR SURVEY

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            QUESTION AND ANSWER SHEET FOR EPCRA SURVEY

I will be interviewing 100 companies.

WHO IS SPONSORING  (PAYING FOR) THE SURVEY?

The survey is sponsored by the United States Environmental
Protection Agency's Region III Office of External Affairs.
The funding for this survey is provided by a National Network for
Environmental Management Studies fellowship program which gives
funding to undergraduate and graduate students to conduct
research on environmental issues.


WHAT IS THE PURPOSE OF THIS SURVEY?

There are three main goals of this survey:
1) To determine how manufacturing companies in Region III are
learning about, environmental regulations.
2) To assess if increased awareness of environmental regulations
increases compliance by regulated industries.
3) To discover how the EPA can better educate these companies
about environmental regulations.
4) To determine if publicizing enforcement actions against
companies deters other companies from violating the regulations.

WHO IS THE PERSON RESPONSIBLE FOR THIS SURVEY?

I am responsible for this survey. I am a graduate student at Penn
State University and am solely responsible for collecting the
data, analyzing the results and writing the final report. This
report will summarize my findings and provide the Office of
External Affairs at the U.S. EPA in Region III with my
recommendations for how they can better communicate environmental
regulations to affected companies.


HOW DID YOU GET MY COMPANY NAME/ MY NAME AND TELEPHONE NUMBER?

Your company's telephone number has been randomly selected from a
computer database compiled by Dun & Bradstreet Information
Systems. The database is called FINDS or Facility Index Systems
which collects data on more than 10 million companies. In order
to generate a sampling frame, I had D&B select all companies who
are covered under Section 313 of the Emergency Planning and
Community Right-to-Know Act. As it is stated in the Act, the
companies who must comply have primary Standard Industrial
Classification codes between 2000 and 3999 and more than 10
employees. I further narrowed the list to include only those
companies in Region III, which includes Pennsylvania, Delaware,
Maryland, Virginia, West Virginia and Washington, DC. This
process generated a list of 14,305 companies. D&B than randomly
selected 1,000 companies who all had an equal chance of being
included in the final sampling frame. I am going down this list

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and calling these companies.

IS THIS SURVEY CONFIDENTIAL?

I can assure you that this survey is completely confidential! I
have your company name and phone number on an index card. After
you agree to respond to the survey, I will code your responses on
a separate code sheet and assign it a code number that is
separate and distinct from your company name or phone number.
There is no way for anyone, including myself, to link your
responses to your phone number or company name.

CAN I GET A COPY OF THE RESULTS?

Yes. The results will be available after August 31, 1993. I can
take your name and current address over the phone, or if you
prefer, you can call, Janet Viniski, Head of the Education and
outreach Branch of the U.S. Environmental Protection Agency
Region III at  (215) 597-6554.

WHO CAN I TALK TO ABOUT TECHNICAL QUESTIONS REGARDING EPCRA?

If you have any technical questions regarding the Emergency
Planning and Community Right-to-Know Act, you can contact Kurt
Eisner, Acting Chief, TSCA Enforcement and TRI Section, Region
III at (215) 597-9937.


HOW CAN I RECEIVE ADDITIONAL INFORMATION ABOUT EPCRA?

The EPA has established an EPCRA Information Hotline which you
can call between 8:30 am and 7:30 pm Eastern Time to get
information or copies of the toxic chemical release inventory
forms. The number is  (800) 535-0202 or (703) 412-9877. Or you can
write to: Emergency Planning and Community Right-to-Know
Information Hotline  401 M St. SW  (OS-120) Washington, DC 20460.
Or the Emergency Planning and Community Right-to-Know Document
Distribution Center, P.O. Box 12505, Cincinnati, OH 45212.

WHAT IS THE PURPOSE OF THE EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT?

EPCRA is intended to increase public's knowledge and access to
information on the presence of hazardous chemicals in their
communities and releases of these chemicals into their
environment. It is also intended to help communities better meet
their responsibilities in regard to potential chemical
emergencies. This is a broad summary. The EPA has many brochures
and handouts that will better explain EPCRA. You can receive them
by calling or writing to the EPCRA Information Hotline.

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             APPENDIX G:
TOP TRADE PUBLICATIONS COMPANIES NAMED

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        TOP TRADE PUBLICATIONS COMPANIES NAMED
PRINTING & PUBLISHING
Printing Impressions (4)
Graphic Arts Monthly (2)
American Lithographer
Print Graphics
Printers Inc.
Graphic Reproductions
Quick Printing
Instant Printing
Paintware
Graphic Arts Association Publication
Business Forms and Labels

FOOD
National Association for Food Packagers and Producers
Packer
Produce News
Food Business
Beverage World
Brewers News
Bakery Products
Bakery Industry News
Snack Food Association Publication
Soft Drink World

MACHINERY
Modern Machine Shop (2)
American Machinist
Welding
Manufacturer Engineering
Metalworking and Machining
Wire Journal
Machine Tools

LUMBER & WOOD
Modern Woodworking (2)
Custom Woodworking
Cabinets
Woodworkers
Kitchen Business News
Remodeling

FABRICATED & PRIMARY METALS
Metal Facts (2)
Metal Digging

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STONE. CLAY & GLASS
Stained Glass Magazine
Cement Industry News
Rock Production
Concrete Construction

INSTRUMENTS
Computer World
Macweek
Kodak
Appliance Magazine
Industry Week
Vending Machine Times
Printed Circuit Design
Sensors
Tubing and Piping Utilities
Optical News

CHEMICALS
ChemWeek (2)
Chemical Engineering
Chemical Manufacturing
American Chemical Association Publication
Chemical Engineering News
American Cancer Society Publications

ELECTRICAL. ELECTRONIC
Air Conditioning and Refrigeration News
Microwave Journal
Refrigeration and Microwaves

MISC. MANUFACTURING
Hazmat World
Industrial Equipment News
Signage Publications
Snips
Filtration News
Pollution Equipment News
Pollution Engineering
Waterworks
Giftware News

APPAREL
Apparel Industry
Footwear News

RUBBER & PLASTICS
Modern Plastics
Plastic Design
Plastics Industry

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TRANSPORTATION EQUIPMENT
Maryland Motor Truck
NTEA (National Truck Equipment Association)

ENVIRONMENTAL PUBLICATIONS
Environmental Reporter (2)
Occupational Health and Safety Report (2)
Community Right-to-Know Magazine
EPA Journal
Environment & Ocean Compliance
Industrial Hygiene
Environmental Protection
Inside the EPA
DER pamphlets
Clean Air News
Clean Monthly Newsletter
Safety

OTHER PUBLICATIONS
The Wall Street Journal (2)
Keller's News Report (2)
Human Resource and Personnel
Thompson Reports
Business Legal Report
Licensing
Business Inc.

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     APPENDIX H:
LIST OF ABBREVIATIONS

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                          ABBREVIATIONS
Abbreviation
Full name
D&B
Dun and Bradstreet Information Systems
EPA
EPCRA
FINDS
The United States Environmental Protection
Agency

The Emergency Planning and Community Right-
to-Know Act

Facility Index System
Form R
Toxic Chemical Release Inventory Form
GAO
United States General Accounting Office
Ha
Alternate or research hypothesis of a
significant difference between the two groups
Ho
Null Hypothesis of no difference between the
two groups
SARA



SIC



TRI
Superfund Ammendments and Reauthorization Act
of 1986

Standard Industrial Classification Code
Toxic Release Inventory Data

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