mmunication
^About Chemicals
"*1n Your ICommunrty
sA Manual For.
Social Officials
The Agency (or Toxic Substances
and Disease Registry
U.S.Departjnerjitof
Transportation
•'Printed on Recycled Paper
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EPA-230-09-89-066
Risk Communication
about Chemicals
in Your Community
A Manual for Local Officials
December, 1989
. . Prepared by Susan G. Madden and Barry V. Bales , .
Lyndon B. Johnson School of Public Affairs
. . The University of Texas at Austin ',.,''
under a cooperative research agreement with '
United States Environmental Protection Agency
in cooperation with the
Agency for Toxic Substances and Disease Registry,
Public Health Service, U.S. Department, of Health and Human Services .
Federal Emergency Management Agency, Office of Training ,
Research and Special Programs Administration, ,
U.S. Department of Transportation
1989
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or moments
Page Topic
Introduction/Purpose
3 i How to Use This Manual
11
17
33
40
Introduction to Title III i
' ' \ ' ' ' • '• •
What is Risk? ! . '.
Commonly-Used Risk Descriptions
' Characteristics of Risk I .
__ . . . |«,., . ;. • ^ i ,
First Scenario: An Unplanned Release of a Chemical '
Procedures with Hazardous Chertiicals
Steps in the Emergency Plan i
Where to Get Information ....''
Sample news release - I :
Characteristics of a Good ResDon'se
1 • ' • • i '' ' •' • .
Second Scenario: Learning about Routine Releases
Emissions, Concentration, and Exposure
Determining Delayed Health Effects
Communicating Long-Term Risks';
Enforcement and Citizen Involvement under Title Ifl
Third Scenario: Storing Large Quantities
Planning for Hazardous ChemicaLEmergencies
Citizen Involvement in Community' Risk Assessment
-"'•'• • '-, • ' -I-. -.' .'.-• .. • '
Conclusion/Summary .. ' .|; . -
Seven Cardinaf Rules of Risk Communication
Opportunity for Citizen Involyemerit'
Personal Action Plan . ! •. - .
Appendices j
1. Glossary of Commonly Used Terms
2. References and Sources ! , ," ' ' ,
3. Brief Description of Title III by Section
4. State Emergency Response Commission Title III Contacts
5. List of Extremely Hazardous Substances
6. Section 313 ToxicChemical List i
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1 State Emergency Response Commission:
Chairperson ' ; : Phone
2, Local Emergency Planning Committee:
Chairperson • Phone
Other Members ___^ . Phone
'. • ; Phone
• " _Phone_
3 Emergency Plan:
Coordinator or Director of Emergency Management for our town/county:
'. ! • Phone
Designated contact for non-emergency personnel who have questions:
' ' " . Phone
4 Who Is authorized to direct citizens to evacuate or take other actions?
5 What are the elements of our response plan?
6 What are other resources (local, state, federal, university) on which I can call
in an emergency?
Which state agency/official receives reports under section 313?
Which state agency/official receives reports under section 312?
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Introduction
&
Purpose
Purpose
"STATE RATES HIGH IN CANCER RISK
FROM FACILITY ^MISSIONS"
"PLANT CHEMICAL [SPILL FORCES
HUNDREDS TO EVACUATE"
Have you seen headlines like theses recently? Do they raise
questions in your mind? If someone asked you about them,
could you answer the questions? ~ .
People are becoming more concerned about hazardous
materials in their communities and how these materials affect
their health and well being. Their ccjncernsbecome most
pressing when there is an accident or a leaking waste site is
discovered, but they are also concerned about hazardous
chemicals they are exposed to every day. In response to these
concerns, local officials are increasingly called upon to respond
to questions about hazardous materials, including the risks they
pose and how to reduce those risks!. For many local officials this
is a new role, one for which they may not be fully prepared.
This workshop manual will help you learn how to respond to
public questions about chemical risks. It also will help you find
additional assistance and information about hazardous
materials. . ! ' ••.'''"-.".•
'Recent tederat legislation is likely tcj increase public awareness
.and concern especially because of the Emergency Planning and
Community Right-to-Know Act, whicih is Title III of the 1986
amendments to the "Superfurid" Act. . '
Title 111 is not a typical regulatory program; it is part of an
innovative approach to managing environmental risk. It makes
a great deal of information available; that has never been
provided before. The information is available to everyone—to
the public and to governments at all levels—about the presence
of hazardous chemicals in the community, about accidental and
routine releases of these chemicals] and about their storage.
The more citizens know about chemical hazards in their
communities, the better equipped they and their local .
governments will be to make decisions and to take actions that
will protect their families and neighbors from unacceptable risks.
,1
-------
Preview
The. new information available .under Title III is Often complex,
and its application and interpretation requires work from all
those involved. It will cause citizens' existing concerns about
hazardous chemicals to become more focused, and public
officials will need to respond to these concerns. Title 111
establishes an ongoing forum at the local level for community
discussion ana'action about hazardous chemicals. This forum
is the Local Emergency Planning Committee, or LEPC.
LEPC members may be called upon to respond to public
questions about the risks they are examining or to participate in
public meetings about those risks—meetings where people will
,ask what the information means or about its significance for a
particular person or segment of the community. If you are a
member of the LEPC or participate in its work, you will be inter-
acting with the community as you work to analyze and mitigate
potential chemical, hazards. Since LEPC membership by law
includes a variety of categories—emergency responders such
as firefighters and police, health professionals, the media,
industry representatives, transportation representatives, and
public interest groups—many different kinds of people with
many different backgrounds will find themselves answering
public questions. This manual is intended to help everyone who
may have to answer questions develop some useful strategies.
/
The manual begins with a brief overview of the law and local
responsibilities. To illustrate situations, and suggest ways to
respond, we will look at three kinds 6f incidents that cause
citizens to seek out local officials.- • We will begin with an •
accident, then'expa'nd our discussion to include more routine
events. These are not the only circumstances under which
citizens "may seek out local officials and become involved in
considerations of risk in the community, but they illustrate ways
in which public officials might interact with the public.
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How to Use
This Manual
Objectives
How the ManuaT
is Organized
Resource
Guide
The manual can be used in three Ways: first, as part of a work-
shop on answering citizen questions about hazardous
chemicals; second, as a stand-alone guide for local officials
unable to attend a workshop; and 'third, as a reference.
Reading or using the manual will help you:
•Know what kinds of questions citizens are likely to ask
—after an accident ] '
—after learning about routine releases
—after learning that large quantities of substances are
-stored nearby. ! / -.
.•<••' .• • '• ... . .•]•••• -'-' '' . - •
• Know the characteristics of a good answer to these
questions. . ' j •
• .' •,' ' " , i". • ' •.••'•
• Understand the kinds of information needed to answer the
questions and where that information may be found.
! • " .
•Respond to the questions and identify some people in the
community who can help answ€ir them.
• Identify opportunities for all sectors of the community to
participate in decisionmaking about potential risks from
hazardous chemicals. j :
The manual is-written so that later jtopics build on material
presented earlier. Those using the manual for self-study will '
rieed to identify the local and stajte!"resources described in this
imanual. - ' "',•"'•••"••..,. . '
This manual should be retained as| a resource guide. The
materials are arranged so that specific information can be found
easily when needed. Specific times to review this manual would
be when an accident or a spill happens, when companies
submit their required Title III reports on hazardous chemicals, or
when the public or the media has concerns or questions to be
answered. !
Remember, there are many other Resources available to help
you respond to risk assessment questions and accidents, and
the early identification of these resources will help you fulfill your
official obligations in a safe and responsible manner. .
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Introduction to
Title III
The Emergency Planning and Community Right to Know Act
was included as the third part or title of the Superfund Amend-
ments and Reauthorization Act of 1986. For this reason, it is
often called Title III." The law has four purposes (readers
should not use the following brief descriptions as the basis for
legal decisions about Title III):
(1) Emergency planning. Facilities that store or use any of
the 366 Extremely Hazardous Substances in excess o^ the
threshold planning quantity (TPQ) report this fact to the State
Emergency Response Commission (SERC) and LEPC. The
LEPC develops an emergency plan based on this and other
information.
(2) Emergency release reporting. Facilities must report to
the SERC and LEPC accidental releases in amounts over a
reportable quantity of the Extremely Hazardous Substances -,
and Comprehensive Environmental Response, :
Compensation and Liability Act (CERCLA) hazardous
substances (which must also be reported to the National
Response Center). . "
(3) Hazardous chemical reporting. Facilities where any
hazardous chemicals are present in amounts over certain
reporting thresholds (often 10,000 pounds) must submit
Material Safety Data Sheets (MSDSs) or a list of chemicals
for which MSDSs are required as well as an annual chemical
inventory form to the local fire department, LEPC, and SERC.
(4) Creation of an emissions inventory. Manufacturing
facilities that use any of-a different list of about 300 chemicals
in excess, of reporting thresholds must report emissions to
EPA and designated state agencies. • ; •
* ' - '' " •" "> '.*'.. '•
As indicated,, different sections of the law apply to different
facilities and different chemicals. Specific sections are listed in
Appendix 3.
In order for the law to work, industry, interested citizens,
environmental and other public-interest organizations, and
governments at all levels must work together to plan for
chemical accidents and to reduce the risk to the public from
releases of toxic chemicals into the environment. The law
represents a path-breaking approach to environmental
protection, because it assumes that the more citizens know
about chemical hazards in their communities, the better
equipped they and their communities will be to make decisions
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Special
Provisions
for Local
Government
Officials
and take actions to protect their families and neighbors from
risks they feel are unacceptable. :
Provisions of special concern to local officials include:
—The law required states to set up State Emergency Response
Commissions, or SERCs. ;
—SERCs were then required to establish local emergency
planning districts and Local Emergency Planning Committees
or LEPCs. : \ • • '
- . - , I • "
—LEPCs must include among their members local elected
officials and staff with competence; in health and emergency
response, industry representatives!, media representatives, and
members of citizens groups. j
—Facilities having more than certsjin quantities of any of the 366
Extremely Hazardous Substances jmust make themselves
known to SERCs and participate iri the LEPC.
—As noted, facilities where hazardous chemicals are present in
certain quantities must submit MSEpSs and inventories of the
chemicals to SERCs, LEPCs and local fire departments. An
MSDS describes the physical and chemical properties of the
substance as weir as its health effects, appropriate safety
equipment, and emergency response measures. . • • .' .
—LEPCs must make the chemical inventories and the MSDSs
available to citizens who want tc> see them. '
—LEPCs must develop a plan for responding to and avoiding
emergencies involving hazardous chemicals, drawing upon
the chemical inventories and other information provided by
facilities. , ;
—Manufacturers must report their'annual.emissions of certain
toxic chemicals into the air, watejr, or land. The reports are
sent to the federal Environmentetl Protection Agency -(EPA)
and to the designated state agencies. Citizens also have
access to these reports. i
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Defining Terms
The information now available to citizens under Title III is one of
the driving forces for citizen questions about hazardous
materials in the community. Sections below describe three
scenarios in which citizens have obtained Title,III information.
Title III makes use of three terms that often seem similar. They
are:
Toxic - substances that are poisonous or can cause
adverse health effects. These are the substances
emissions of -which are reported under Section 313 of
Title III. . .;,."••..-...'•.• 7
Hazardous - substances that are toxic, corrosive,
flammable, or explosive. This is a general term, not .
specific to Title III.
Extremely hazardous - a set of chemicals defined by
Title III as subject to reporting under Section 302,
because they could cause death or irreversible damage.
after relatively short exposure to small amounts,
generally in air. .
As you talk with citizens, it is important to remember that they
may not know the differences among these terms as wellas you
do. Listen to understand what they mean instead of
concentrating on the particular terms they might use.
We know that citizens are often very concerned about toxic and
hazardous chemicals in all these categories. Title III offers an
important new step forward in allowing.and encouraging
citizens, working with government and industry, to participate in
managing these chemicals in their own communities.
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What is Risk?
Common Risk
Characterizations
"Risk" is a word that is used dft;en when people talk about
. ' hazardous chemicals in theicommunity. "
'-'.'•' ':, " .",'.. , . '[V - ' • •'•.__'
What is risk? A convenient definition's:
The likelihood of injury, disease, or death.
Environmental risk then refers to T '
The likelihood of injury, disease, or death resulting from
human exposure to a potential environmental hazard.
(In addition to human health, the environment itself may-also be
at risk. We will not mention these risks below, but the
considerations are the same.). : ,
Experts often use the definitions abpve. When experts are
asked to describe or characterize a) risk, they use statements
like these: '-•"'";
• There is a lifetime risk of i in 65 of dying in a motor vehicle
accident. . -. [ ' .
• The range of risks in humans is Between 100 and 1000
, cancers per 1,000,000 people exposed. ; . " .
• the chance of getting this disease is 1 x iO'7:(1.10-miHibnth
orl in lOmillion.); .r; '
• The risk to children is high relative to that for adults., •
• 25,000 people die each year frorri at-home injuries.
• The risk of death from leukemiaiis 1 in 12,500 people per
year. : ; -
• The risk of cancer from indoor air is 600 times the risk from
tap water. ;
- -" - '. JL, - . - '
• An airplane crash involving 100 cir more deaths is likely to
occur once in two years. ! ;
7
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• I ne risK to this neighborhood from chemical, releases at
Fapihty A is, likely to be higher than the risk to a different
neighborhood from releases at Facility A.
• The risk of neighbors getting sick is higher with this waste
disposal site here than it would be if the waste were not
disposed here. ;
Experts tend to focus on the likelihood of a particular risk but
non-experts tend to think of other characteristics of trie risk.>
For example, an industry representative at a public meeting
about a proposed new incinerator reported that a person who
spent her whole life downwind of the incinerator would incur a
risk that was smaller than the risk from dying her hair A
member of the audience stood up to say, "Yes, but I choose to
dye my hair, while I don't choose to live downwind of the incin-
erator, and furthermore, I get some benefit from dying my hair
while I get none at all from the incinerator." This woman was'
reacting to the involuntary nature of the risk and the perceived
balance between risks and benefits. "
Table 1 on the next page illustrates some of the other-features
of nsk that make it seem "riskier to most people and gives brief
examples. i
8
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Table 1: Characteristics of Risk
(Factors on Right Increase! Perception of Riskiness)
Vpluntary
Driving a car
Natural
Radon in basement
Familiar
Household
cleansers
Chronic
Routine srnall
releases of chemicals
from a facility
Visible
Benefits
Dying hair
Controlled by
Individuals
Driving
Fair
Involuntary
Breathing air polluted
by a neighboring
factory
Man Made
Industrial
chemicals
Exotic
Genetically
engineered organism
Catastrophic
Large accidental
release of chlorine
gas from a plant
-' - * i ' .
No Visible
Benefits
Incinerator effluents '
Controlled by
Others
Industrial; pollution^
Unfair
The notion of "fairness" sums'up many of the-other aspects of
risk that make people feel special concern or "outrage." If a
pers~on or community feels that it is bearing a lot of risk while
someone else is getting most of the benefits, then the risk will
seem especially unacceptable. Risk communicators.must
understand these feelings, ortheyjwill not succeed in working
with the community to make good decisions about risk
reduction. I
• .•'••]• > • - •
We also know that most people seek information about
hazardous chemicals only when something happens to make
them interested or cause them to. (relieve that they are directly
affected. I
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Questions citizens
ask about
hazardous
materials
We will use as examples three kinds of circumstances that may
cause citizens to become concerned enough about hazardous
chemicals in their communities to ask questions: during/after an
incident, when they learn about routine releases, and when they
learn about the many kinds of substances stored nearby. Most
questions will concern human health, but many citizens also will
ask questions about environmental and other possible effects of
chemical exposure or release. In addition to these substantive
questions about health or the environment, citizens also ask
many "procedural" questions about where they can obtain.
additional information, why it was so difficult to get answers to
their questions, or how they can get involved in making sure
risks are managed properly.
Few public officials will be able to answer all these questions.
Some questions have no sure answers, and others can be
answered only in light of the particular conditions prevailing in
the community. However, this manual is intended to help users
understand the kinds of answers that are appropriate and find
sources for the factual information that is available. Keep these
questions in-mind as you think about the scenarios from the
perspectives of government, industry, or citizen representatives
10
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Scenario 1
Procedures with
Hazardous
Chemicals
Unplanned Release of a Chemical
About 2:30 on a weekday afternoon you receive a telephone call from the
Director of Emergency Managementtpllingyouthatachlorine tank inthe
basement of the local school has sprung a leak and that the gas, which
is very dangerous/has entered the indoor swimming pool area and gym
and is being sucked into the school's aircirculatton system. The tank has
been removed from the basement to the open air and the 'leak is being
repaired; emergency personnel are moving rapidly through the school
to locate and rescue students and teachers; local hospitals have been
notified; and vehicles are on their way| to the school to transport anyone
suffering impaired breathing. f ' ,
Within fifteen minutes, your telephone; starts ringing with questions from
frantic parents and the media. What ishould you say to them? ..As an
LEPC member, you would refer calls to the appropriate emergency
response public contact. But what if you are that person? Or what if you
have to answer "spillover questions because you are on the LEPC or in
another position in which people'are liikely to call you?
To answer people's questions, you must first know about the
plans and procedures for emergencies involving hazardous
chemicals. ; -
i • ' .
1. SARA Title. Ill requires any facility that stores any of 366
Extremely Hazardous Substances in amo.unts greater than
specified Threshold Planning Quantities to notify the Local
Emergency Planning Committee (LEPC) and the SERC. (Many
of these substances are also covered by the annual toxic
chemical reporting requirements c|f Title III described,abbve on
page 4.) A list of the Extremely Hazardous Substances •
appears in Appendix 5. ._.''!
i .'''',''•. • " '
2. The LEPC uses this information'to plan for accident
prevention and for emergency response in case of an accident.
Individual facilities also should have their own emergency
response plans. i •*.-..-.'••'
!• *
'i . • ' ' t
For some chemicals, including chlorine, there are professional
standards-for the kinds of emergency warning systems and
emergency equipment that should;be on hand.
3. The local emergency plan developed by the LEPC should:
'-.11- " i •' . • ;
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i: unplanned He/ease of a Chemical
Some Steps in the
Emergency Plan
Citizens' Questions
• Designate a coordinator for emergencies—usually the
Director of Emergency Management or someone in the Fire
Department. (Note that many states have rules about first
responders that should have been considered as the plan
was developed.)
• Provide a means for notifying appropriate authorities.
• Provide a means for emergency responders to obtain
information about appropriate responses particular to
specific chemicals involved in the incident (including needs
for special equipment and clothing).
• Identify sources of necessary equipment and trained
personnel and describe procedures for bringing them to the
site.
• Specify the division of duties between the public and private
sector response personnel. (Many companies insist on
deploying their own specially^trained staff for accidents that
do not cross the plant boundary, in part to .firnit possible
.liability for damages to non-employee emergency •
responders).
(Although cities or other jurisdictions smaller than the area
covered by the LEPC could have their own plans, in this manual
we focus on the LEPC plari. The planning principles would be
the same for the smaller jurisdictions.) . . .
In the chlorine spill, the plan has worked quite well. Authorities,
including you, have been notified, equipment mobilized; and the
problem treated. Your callers ask: /
a. What's going on?
b. Am I at risk?
c. Should I evacuate?
d. What are you doing to mitigate the consequences?
Although citizens will call the elected official, he is not
necessarily the best person to provide answers. The person
designated as emergency coordinator should in turn have
designated a particular person or position in his office to be
the contact for non-emergency personnel who have
12
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scenario 7; unplanned Release of'& Chemical
Where to get
information to
answer these
questions.
Questions after
the event
questions. This person's name land especially phone number'
snould.be emphasized to the media before any accidents occur
(Many facilities are designating a'particularcontact person and '
inviting the media to meet with that parson on an informal basis
independent of any particular events. Public agencies could
adopt this approach, ensuring that the media are aware of
procedures and plans.) The elected official should refer almost
all calls to the appropriate contact]person, since during an
emergency, it is often impossible to ensure that every office is
kept up to date on rapidly changing events.
Local officials should know about 1;he system in place in their
own communities for emergency planning and response and be
prepared to talk about it with the public. You should know the
answers to these questions:
a. Who is the central contact person or where information
will be available? ;
b. Which departments,.programs, or offices are responsible
for emergency response? :
c. Who has authority to direct citizens to evacuate or take
other action? '• . \ '. > .
d. What is their relationship tojthe Local Emergency
Planning Committee (LEPC)? yVho is chairman of the LEPC
and what is the role of the LEPJC during an emergency?
e. What are other sources of information to answer citizens'
questions? . i ••;••'•'
a - - ! " '"..','
In short, officials need to be familial1 enough with.local
procedures to be able to tell caHersjwhere to find the information
they need right away. It is important to identify the LEPC and
local emergency coordinators in advance. (The State
Emergency.Response Commission! is a resource that should be
used during the planning peripd and not during an emergency -
see Appendix 4.) '
Another series of questions will arista after the event. Among the
most likely to be asked are:
a. How did this happen? I
b. How long will the "short-term" health effects (those that show
up within a few weeks of the incident) continue to be felt?
c. Will we have other health effects that do not show up for a
longtime? I •••'•.-•,••
. What are you doing to prevent it from jappening again?
13
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Sample
News Release
Of course, the answers differ for each incident. [Appendix 2
lists some sources for information about specific chemicals.] In
answering what is being done to prevent a similar accident from
occurring, officials may need to refer to state and local laws that
give them power to prevent accidents, such as inspections for
enforcing the building code.
For this incident/an official might issue a statement something
like this: :
News Release
For release, Tuesday 9:00 AM. Office of the Mayor.
"-'•'•* ' • ' v
About 100 pounds of chlorine gas were accidentally released in the
basement of North High yesterday when a storage tank began to leak during
routine transfer of chlorine to the pool-cleaning system. The gas was
sucked into the air circulation system of the school, which was turned off five
minutes after the leak was detected.' All 1100 people in the building were
outside within fifteen minutes. Although some people experienced difficulty
in breathing for several hours, and twenty people were treated at the
hospital, no one was admitted and no one is experiencing aftereffects now.
Chlorine can affect human health in two ways. In high concentrations that
may be present during accidents, it causes difficulty in breathing, choking,
coughing, chest pain, and sometimes nausea and vomiting. It also reacts.
with moisture, including body moisture, to form acids that are very irritating
to skin, eyes, and mucous membranes.- In yesterday's incident, no one
suffered any skin irritation because concentrations except in the basement
were not high enough. Once the symptoms of chest tightness or difficulty
in breathing have disappeared, there are.no further health problems that we
are aware of associated with an exposure to chlorine. .
Our city has a plan in place for responding to emergencies involving
hazardous chemicals. This plan worked well, with efficient and effective
response by the Fire, Emergency Management, and Volunteer Rescue
teams, although the first person calling to report the accident had some
trouble finding the right telephone number and right place to report, the city
has had a plan since 1973, but it has been revised and updated recently by
the Local Emergency Planning Committee. This committee was established
under a federal law that calls for emergency planning and public access to
data about hazardous chemicals. •
In order to limit the likelihood that any further such incidents will occur, the
14
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Dr.
Characteristics
of a good answer
School Board has agreed that tranter of chlorine will no longer be done
during school hours. Chtorne is also stored in large quantities at city
swimming pools and water and wastewater treatment plants, vye have
reviewed our systems for detecting! leaks and made sure they'are,all
working properly: We have also issued instructions that transfers of
chlorine at city pools will only occur when the pools are closed for the day.
and will be made only by trained personnel. Finally, we have tried to
publicize the telephone number to which initial accident reports should be
',made: it is 333-3333. !
To prepare a good answer:
L
—describe the incident, the response, and other events
—describe the chemical itself, including short- and long-term
health effects of brief exposure at relatively high levels
- ' \ ..,-''.-
- •' "1 • . . -'
—describe the health effects sulWed in the incident and any
longer-term concerns ,
—summarize the good and bad points of the response
! . '
—describe actions being taken to reduce^the likelihood of a
similar incident
There are a variety of sources of information about chemicals,
including theirphysical properties land possible health effects. •
Som^ of these sources are listed in Appendix 2. Many public
libraries and local emergency response departments have
reference books that provide some1 of this information. The
Material Safety Data Sheets (MSRSs) that facilities must supply
to the LEPC on request also contain this information. EPA and
several private companies maintain computerized databases
with chemical information. CAMEQ1*, a computer program
developed with assistance from EF'A, contains information
about more than 2700 chemicals. The National Library of
Medicine has toxicological information in computer databases
called TOXNET. These sources sejdom contain any information
about long-term health effects of exposures that may occur
during an accident, because it is often the case that little is
known about them. ' " '
15
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Summary
Citizens' co.ncerns about an accidental release of a chemical
focus first on response to the emergency. Later, citizens want
to know what is being done to prevent a similar emergency from
arising again, and they want to know more details about the
health effects of exposure to the chemicals involved in the
accident. Prior to any incidents, local officials should ensure
that ',-..' ' ;
> i •
—a plan has been developed
—a central source of information for the public has been
designated,
—they are aware of the,procedures to be followed during an
emergency. (Filling out the Risk Communication Resource
Sheet at the beginning of the manual will help meet this
guideline.)
After incidents, local officials should be'prepared to
—provide an evaluation of the effectiveness of the plan
—provide available information about health effects of the
chemical
—provide information about how citizens can become involved
.in emergency planning and risk reduction through the
LEPC.
16
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Scenario 2: Routine Releases
Scenario 2
Learning about Routine Releases
As a result of the incident in scenario 1, the local media
become very interested in the hazardous chemicals in the
community. They obtain emissions reports from the state
agency assigned the responsibility of keeping them or from
EPA, which maintains the Toxic Release Inventory (TRI)
database. The TRI can be accessed through the National
Library of Medicine's TOXNET system. The following
newspaper article is an example o'jf. the kinds, of information
being publicized. !
Ourcity Daily News
325,000 Pounds of Four Toxic Chemicals Emitted Locally
Benzene, Chlorine, Pyridine, Ammonia Most Prominent
••- Industry Says, "Risk is Low" '
Last year, fifteen local manufacturing facilities emitted more than 10,000
tons of toxic chemicals into the air, water, and land of Ourcity. The top
chemicals emitted (in pounds) wenb benzene (200,000), chlorine
'(100,000), pyridine (10,000) and amrnonia (15,000).
Benzene is a known carcinogen. Chloi;ine is a highly toxic chemical that"
may cause severe respiratory problems. Chlorine was involved in the
recent accident at the North High School, causing evacuation of 1100
., students and teachers. Pyridine is ja reproductive toxin, causing
'possible damage to reproductive organs, as well as having serious
; effects on the central nervous system, Ammonia, a common-household'
cleaner, is irritating to eyes and the respiratory system.
','[_.• • '. . .
Newspaper staff examined reportii submitted by fifteen local
manufacturing facilities under the requirements of a federal law, the
Emergency Planning and Community ftight to Know Act. The federal
Environmental Protection Agency requires facilities to disclose the
amount of toxic chemicals they release into the environment each year.'
In addition to benzene, chlorine, pyridine, and ammonia, local facilities
emit more than 500,000 pounds per year of ethylene, creosols,^
formaldehyde, and twelve other chemicals. '
.'•-i1'
•') • . • . .-'.-.
Tom Jones, senior safety engineer for Newtown Chemical Company,
noted that the emissions reported do not give cause for any alarm.
Benzene emissions by all fifteen companies, he said, are only one-tenth
of the benzene given off by automobile!? in Ourcity. Jones also pointed
to a recent study by the State Environmental Department which showed
that total concentrations of benzene and seven other chemicals in
17
7
-------
scenario 2: Routine Releases
Citizens' Questions
Emissions
vs.
Exposure
Ourcity are well below..state standards. In Ourcity, they have been
measured at about 20 parts per billion at the intersection of Broad and
Main Streets.
Rodney Smith of the State Environmental Department stated that the
department will be looking more closely at the emissions to see whether
they violate any state standards. "For now," he said, "we are just happy
to see the companies providing the.reports, complying with the law.
Later we will use the data to examine whether we need regulatory
changes."
After reading such a news article, the questions that people are
likely to ask local officials include: '
(1) What risk is posed by these exposures?
(2) Are these emissions the cause of. (various health
symptoms)?
(3) Why are the plants allowed to emit these substances?
(4) Was the facility in'compliance with state and federal laws?
(5) Are there other facilities in the area that have not reported
that also are emitting these substances? Should they be
reporting too? -
(6) What other sources might lead-to my being exposed to
these chemicals? ,
To answer the first two questions, we need to know about
• • emissionsr concentration, exposure, and dose
•.toxicity'- • •;'.
• acute', high-level vs. Icing-term, low-level exposures
• immediate vs. delayed risks.
To answer questions 3 and 4, officials should know a little about
the present system for regulating emissions, the procedures for
getting information under Title III, and how citizens can begin to
work with industry to reduce emissions if that is what they want
to do.
An emission or release is the amount of a substance released
from a facility. Releases are usually classified either as
routine—small regularly released amounts that are planned to
be released as part of a manufacturing process—or as
accidental.
18
-------
Scenario 2: Routine Releases
j
Characteristics
of the chemical
Just because a facility emits some amount of a substance does
not mean that it affects anyone. Substances are diluted as they
are released into the airand watejr. The concentration is the
amount of the substance in a representative unit of the air,
water, or land. For example, due io automobile exhaust,
.benzene may be found in the air of many cities in a
concentration of about 8 parts pe(biltion. The concentration is,;
of course, higher if emissions within a fixed time are higher and
other conditions remain the same! Concentrations also will tend
to be higher closer to the emissioip source.
.~ - - • -••••. \ ~
Exposure happens when an individual comes in contact with a *
substance Exposure can occur through breathing, drinking,
eating, and by direct skin contact.JThe amount of exposure is
determined by many factors, including the concentration of the
substance in the environment, how long the contact lasts, and
how often the exposure occurs^ \ .'.*-..
Figure 1 shows the paths by whiclh emissions might lead to
exposure. At each point, there ah? difficulties in determining
how much a person is exposed. This makes.it hard to estimate
the,risk. . ! . ' \
Dose is the amount of the substance that actually enters the
body, The dose is related to exposure, but differs according to
individual susceptibilities and habits. The dose received from a
hazardous chemical in the environment is influenced by the
concentration, route of entry, length of exposure, presence of
other chemicals, and the ability of ith'e body to break down the
substance. I • .
• '' 1 h - • •
Toxicity [s a measure of how harmful a substance is to human
health or to plants or animals. Higjhly toxic substances have
adverse health effects at smaller closes.
i' 'i. • ' • • , - -' '.
An acute exposure is one that occurs over a short period of
time. It could be a large exposure] such as might occur during
an accidental spill. ' i .
Long-term exposure can occur when a substance is present in
the environment over an extended period.
19
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Figure 1
Exposure Pathways for Humans
Deposits on crops • D jts on nd
Inhalation of gases
Crop ingestion
Dermal / Uptake *
absorption
from
water' /
aquatic foods
'/
Aquatic food ingestion
Volatilization from
water to air '
''\'A
Milk ingestion
Dermaf,
absorbtion
from soil
Water irigestion
From "Assessing Risk'at Superfund sites," .
prepared by CH2M HILL
20
-------
Determining delayed
health effects
•-*•*•-'•£>:
Acute or short-term exposures rh^have
effects, and may have fong-term (effects. The immediate effect
of the chlorine was to cause people to gasp and choke. We do
not know about any delayed effects of acute exposures to
chlorine, ,. '.
' . - ' ' I ; - '
Long-term, low level exposures iaiso may cause health effects
Usually these are delayed health effects that may not show up
for many years. Cancer and birth defects are often delayed
health effects. , :
The ways in which we learn about delayed health effects make
it difficult to discuss them with any certainty.
Most of our information about deljayed health effects comes
from laboratory studies conducted on test animals. Usually
more than one species is used. Animals are exposed to the
substance in different ways, including eating, drinking
breathing, or on the skin, and different groups are exposed to
different quantities. After some time, animals are examined to
see whether there are abnormal cells or other evidence of harm
The number of these abnormalities in the test animals is
compared to that in unexposed control animals. Statistical tests
are used to determine whether the difference between the test
animals and the controls is "significant," or suggests that the
substance may have a health effeict.
1 i ' " - • . ' - ',
Many people disregard laboratory' studies because animals are
exposed to quantities of the substance that are so much higher' •
than humans ever would receive. I Laboratory siudies-are done
this way in order to reduce the number of test animals used and
the time needed for the study; otherwise, studies would be
prohibitively expensive. Results from the high doses are used to
predict what would happen at mpr^ realistic doses. These
results may tell us approximately how many people will get sick
or die from particular exposure levels, but they can never tell us
which people will be affected. j -r. • . :
. - ! •'.-'•'''
Some laboratory studies are conducted on tiny organisms in test
tubes. Scientists have learned that substances that affect the
growth of these organisms often hiave adverse human health
effects. Usually these "in vitro" ("ini glass") studies are used to
screen chemicals; those that seem suspicious are further tested
on animals ("in vivo"). J ..
21
-------
Scenario 2: Routine Releases
Answering health
effects questions
Epidemiological studies use data about humans who have been
exposed to a substance and data about their health to try to
determine whether a substance causes health problems. Such
, studies are often difficult to interpret because people are
exposed to so many substances throughout their lives and
because the health effects of interest may not occur for many
years. Combined with laboratory evidence, however, it is often
possible to show that certain exposures cause unwanted health
effects, in humans. .
Because the evidence about long-term effects, when it is
available at all, is based on laboratory and/or epidemiological
studies it is often open to different interpretations. There is
never full proof about the cause of such effects. This may
create political controversy between people who believe the
chemical creates a riskfor those exposed and those who
believe that the evidence is not good enough to suggest that
there is a risk. Citizens who want to discuss-these questions
should be referred to appropriate experts. Officials should try
not to get caught in such arguments. Instead, they should try to
present whatever facts are available and provide ways for
opponents to work together to achieve acceptable policy .
solutions. -
Now we can turn back to some of the questions citizens ask:
1) What risk is posed by these exposures?-
2) Are these emissions the cause of (various health
symptoms)? '
1) What risk is posed by these exposures? . ,
The' word "rfsk" often carries different meanings for different
people. In communicating with the public, it is usually not
helpful to say, "the risk is high" or "the risk is low."
The factors contributing to the risk include:
Factor
Quantities
Concentrations
'Exposures
Probabilities
Example •
How much effluent was released
Parts per million
How much is likely to be
absorbed, inhaled, drunk
How jikely is it to happen
22
-------
Risk levels
Toxicity
Expected number of deaths or disease per
year j • .
How strong is the effect of exposure on
„ human health
(Adapted from Hance, Chess, and Sandman,
Communities" p! 64.) 1 ,
"Improving Dialogue With
In answering questions, people often confuse these factors
when attempting to put risks into context. In addition to these
risk factors, other characteristics live have noted on page 8
affect people's perceptions of risk, including how fair the risk
seems to be, who benefits and who bears the risk, and whether
the risk is voluntary or easy to understand.
i ~ "••,''
One way to talk about risks of exposures is to provide:
1 ) A description of known health effects. : • : -
- -'•,'. • •('•'. ' , '•
2) Any information about concentrations or levels of exposure.
• . i ' '
3) Any comparisons of these concentrations with existing
government standards or other directly comparable
information. (Caution: Be ^rafyi ^hen providing
Comparisons with risks frp'rp flth4r: chemicals or artiyiffp.; For
example, avoid making comparisons between risks such as
drinking water containing hazardous chemicals and the risk of
driving an automobile. Comparing dissimilar,risks often makes
citizens angry, especially when the comparison is-betweeri an',
involuntary risk such as drinking water containing hazardous
chemicals emitted by a facility and a voluntary-risk such-as
driving. However, people might find it useful to hear a
comparison of similar risks of two chemicals, both of which are
found in drinking water. The Covellp, Sandman, and Slovic
book mentioned in Appendix 2 giyes other good examples.)
4) In addition, people- like to knoW why the chemical is present
in the community— that is, what it! is being used for,
Remember, familiar risks are likefy to be perceived as less
risky than unfamiliar or exotic ones. The multi-syllabic name
of a chemical, in contrast, might increase concern.
-------
Scenario 2: Routine Releases
Other Sources
for Referral
._
A public official confronted with questions about benzene
emissions might state the following: ,
"Benzene is a chemical found in many common products such as gasoline
and often used in making plastics, textiles, rubber, and solvents. It is
known, to cause leukemia if people are exposed to it at levels of hundreds
of parts per million over many years. In our town, concentrations in the air
are about 20 parts per billion. EJecause this is about 400 times lower than
exposures known to cause leukemia, scientists do not know what kinds of
health effects might result from exposures at this level. In other cities that
do not have factories emitting benzene, concentrations in the air average
about 9 parts per billion, because both automobile exhaust and other
everyday activities such as pumping gasoline result in benzene emissions
too." ; -
For a substance with less well-documented effects, a statement
might include the following: , " . <
"We have recently found trichloroethylene (TCE) is a chemical that is
emitted by local facilities into the water. TCE is used by these facilities as
a solvent and a compound in cleaning fluid and typewriter correction fluid
In some laboratory tests on mice. TCE has been shown to have
'reproductive effects at levels hundreds of times higher than the levels
found in our drinking water. We just do not know what effects exposure at
tower levels may have." •
2) Are these emissions the cause qf my unwanted health
effects?
Causation is the most difficult question officials are called upon
to consider. Except in well-conducted laboratory experiments,
causation1 is almost impossible to prove. Workers who develop
certain rare diseases after being exposed to relatively high
concentrations of. workplace substances known to be associated
with those diseases can reasonably say that workplace
exposure caused.their problem. Otherwise, it is almost
impossible, since people are exposed to so many different
substances in so many different ways. Again, laboratory studies
suggest the rale, at which people will experience the unwanted
health effects, but can never tell which individ^ig «/iii get Sjck.
Local officials should know how to get more information,
including specialists to whom they can refer these more specific
questions'.
24
-------
Additional
Responses
How Safe Ami?
•^Several books are available in most^ublic libraries. Am0n7
them is the'£oj]£isa£hamicaiJ2ictiflaaa.. Appendix 2 lists
some others. •'-...;-.-- •••..••
•Local health department officials may not have the necessary
expertise but will know appropriate health officials at the state
level. ;
•Local universities have professors who are familiar with the
issues surrounding identification of long-term health risks.
Technical experts often anger pepple by emphasizing the
difficulties.!!! establishing causation or the extent of scientific
uncertainty. Nevertheless, policy! or legal decisions must often
be made even when these uncertainties exist. Sometimes it is
useful to respond to.questions about individual symptoms and
emissions or exposures with fourikinds of statements:
• Our scientific knowledge is not good enough for us to say
whether these exposures cause; your symptoms.
• You can try to reduce the exposures by... (give specific
relevant directions such as drinking bottled water, keeping
windows closed, etc.) "•. • (
• (If appropriate) Emissions constitute only a small portion of
most people's exposures.
• You have an opportunity to work with industry to reduce
these emissipns through the LT=PC.
Perhaps the most common question asked is some form of:
How safe am I?
As noted, individual exposures differ and individual
susceptibilities also differ. More important, individuals'
willingness to assume risks differ v/idely. In other words, safety
is a relative term. This is especially true when we consider the
non-quantitative aspects of ,risk, such as perceived fairness or
controllability. Local officials can ppvide information about risk
measurement, but each person mujst decide, for himself or
25
-------
Scenario 2: Routine Releases
Other questions
about Scenario 2
herself whether a risk is acceptable
something seems "safe." :
-that is, whether
Without supplementary information, the emissions data
available under section 313 of Title III cannot answer-questions
about safety. The data can help people choose the facilities,
media (air, water, land), or chemicals about which they would
like to know more, however. Among the other information that
would help determine whether the present level of safety is
adequate (or the present level of risk is low enough) are the
following things that affect the dose received : stack height, wind
velocity, temperature, known health effects, concentrations at
the fenceline, and the nature of the dose-response curve.
Perhaps the most important thing to remember is that because
• safety is a relative term, community members must be involved
in decisions about the levels of safety they would like. One
important.feature of Title III is that it provides people with initial
information to allow them to participate in such decisions,
especially through the LEPO. . v •
. '":''• , • f
One other way a local official can help people make a " '
determination about safety or acceptable risk is by "answering"
as a citizen rather than as an official, describing how he or she
would act or is acting: .
"I drink the water", or "I let my children play outside."
An answer such as this is more effective when it includes a
recognition of people's feelings: .
"I can see that you are very concerned about this. What are
your concerns and questions?" . , r
In addition.to questions about risk and safety, the newspaper
article about emissions data is likely to elicit questions about
existing government programs and enforcement:
. • % . " >.
3) Why are the plants allowed to emit these substances?
4) Is this facility in compliance with state or federal laws.
5) Are there other facilities in the area that have not
reported that are also emitting these substances?
26
-------
. To answer question 3, we need] to know abcut the present
system for regulating emissions'. Answering questfonJ 4 LH
requ,res obtaining and analyzing new inform^on
Present System
for Regulating
Emissions
The Present System for Regulating Emissions "
ions' few are subject directly to
em.ssipn permits or standards. Most EPA
l with ambient lev, Is of chemicals On otheV
words, they specify acceptable concentrations in the
commijnity's air or drinking water U not the amounts of the
chem,cals *at can be released trim a parflcula?SSS
VVhere EPA does have regulation! based on emissions^ they-
generally apply to classes of chemicals (volatile organic '
compounds and particulate matter in , the case of air total
^nded^lids and certain type^ of waste streams for water).
And in the handful of cases where EPA has established
f0f ^pecific chemica's- they apply
^
mdustnes Therefore, to determine: whether a particular
company ,s complying with the -benzene standard you would
fStf 1'
ar
are
°nl Wl"!iqh of its Proces^s are
fro What PercentaOe «f the reported releases
from those processes, i -
Crtizens may ask whether all the err issions have been reported
The answer ,s no. Some facilities afe not covered by the
requirements of Title III; others may |not know that they^ed to
report: and «tm ^^ _.. nave ^^ -^ need to
-------
Scenario 2: Routine Releases
Enforcement and
Citizen Involvement
Under Title III
Additionally, not all substances are covered - only those on the
Section 313 list (see Appendix 5.) In short, the data provided by
Title III, although better than anything we have had before, are
still very limited. However, this question offers a good reason to
discuss the opportunities for citizens to become involved in Title
III activities.
Title III provides penalties for not submitting reports of routine
releases. Facilities that do not submit may be sued by citizens
and fined by EPA. In the many states that have passed their
own right to know and chemical reporting laws, state agencies
may also be able to obtain penalties for non-reporting. It may
be difficult for states to determine that a facility has not reported,
however. Local residents often have access to information that'
regulatory agencies do not have, so citizens may be able to help
enforcement officials identify facilities that have failed to report.
Citizens who suspect that a facility is not reporting all or any of
its emissions might begin by obtaining the chemical inventory
Hsts available under Title III sections 311 and 312,. and
comparing those lists with the lists of chemicals reported as
emissions on the section 313 report. Just because a chemical
appears on the inventory does not mean it is emitted, so citizens
will have to work with industry, local officials, and experts to
determine whether it is likely that a substance is being emitted.
It is also important to recognize that the first emissions reports
were due on July 1,1988.' 'Not every facility that should have
.reported even knew of its responsibility. Local officials and
citizens can help identify facilities that are covered by the law
and encourage them to report and notify state and EPA'officials.
One answer to question 3—"Why are the plants allowed to
emit these substances?" is
"Not all emissions of toxic substances are harmful. Usually environmental
or human health problems arise when the substance is present at more ,
than a particular concentration. Government regulations are formulated to
keep the concentrations at levels that evidence suggests are consistent
with environmental and human well-being. If regulations made all
emissions illegal, little manufacturing could,take place. If new information
becomes available that suggests that the existing standard is wrong or that
some substance for which there is no standard should have one, regulatory
agencies try to write new standards. Under Title III, citizens and regulatory
28
-------
ao.lv, i
"•"•*"•""»"«
SH=~^""•—
££±?±™X£!;*sposf «| **h medium:
^ community, these data
-------
the routes by which people might be exposed to particular
chemicals. The newspaper article in which,the emissions are
reported for this scenario does not consider the medium to
which the chemicals are emitted, but this information is readily •
available from the forms submitted to EPA and state agencies.
Because the answer to this question rests on considering data
for all local facilities a,t the same time, officials may feel that -they
are unable to answer it—they lack the time to do the necessary
calculations. In anticipation of such questions and needs,
Congress required EPA to computerize the emissions data. The
Toxic Release Inventory (TRI) database is available ,to the
public at modest cost. It contains all the emissions reports and
allows users to examine the data in a variety of ways, including
adding up all emissions of a particular chemical to a particular
medium in a city or county. Appendix 2 provides information ori
how to get access to the TRI database. SERCs also have
access to a similar database maintained at EPA, arid may be
able to provide some data to questioners.
30
-------
Summary of
Scenario 2:
Routine Emissions
.,-••••••<- M<5r»o|jci(jer aniCI'
BU,rS ^^^^o;S^9-an,so,
1. Rtsks or risk levels should be bompared at two different
«"!• •» Provide listeners with
comPariso"s. People Should have an
in
-------
Scenario 2: Routine Releases
4. Where possible, indicate ways people can control risks
They may be able to take some personal preventive action such
as drinking bottled water and using pesticides more carefully
around the home, or they may be able to join the LEPG or other
community groups to act collectively against a risk.
5. Help people understand why the substance is present in the
community in the first place. Familiar risks seem less Worrisome
than unfamiliar ones. Long chemical names are usually
unfamiliar. Explaining what familiar items the chemical is used
to manufacture may help people balance the risks and benefits
32
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Scenarios
Storing Large Quantities 1 ,
- •'- ' ' : I "' : ' ' \ , '
" I ' • •
About six weeks after publication of the article on emissions
data, the following article appears in the local newspaper.
Ourcity Daily News
100 of 366 Extremely Hazardous Substances
Present in Ourcfty
Possibility of Sericjus Accidents Great
Emergency planning:based on reports, but
only 70 reports filed: hlow many are missing?
More than 100 of the 366 chemicals the federal government calls
extremely hazardous" are found in; our community in amounts greater
than 10.000 pounds. Some of the chemicals are so hazardous that just
a few pounds released into the air could kill hundreds of people under
the. worst conditions.
' " • 1 • ' ; • ' ' '
Seventy different facilities in New Obunty have reported that they store
these chemicals. Thirty of the chemicals are stored or used in quantities
greaterthan 100,000 pounds. Forty facilities reportedusing chlorine the
• cr.em.cal that spilled three months! ago in the North High basement
caus.ng the evacuation of 1100 students and teachers. The New County
Local Emergency Planning Committee, established under a new federal
law.designed to prevent chemical iaceidents, is developing a- list of
facilities that need to increase safety measures .based on the list. • '
Extremely hazardous substances are chemicals determined by the
federal Environmental Protection Agency to have the potential for
caus.ng serious human harm. Facilities must report these and many
other hazardous chemicals under thei federal Emergency Planning and
Community Right-to-Know Act. The ,-eports are available at the Ourcity
Emergency Department, 110 Main Street. /
!' ' " •
Reporters from this newspaper examined the inventories submitted by
local facilities as part of a continuing investigation'into hazardous
chemicals present in Ourcity. We teamed that:
.'•!•-. . • •• '•'.'•'
• Seventy facilities have submitted inventories. The federal law covers all
commercial facilities that store hazardous chemicals in amounts greater
than 10,000 pounds. There are 400 members of the Ourcity Chamber of
Commerce. Charles Smith, president of Ourcity Citizens Against Toxics
stated that it seems likely that not alii the facilities have reported that
should have. ;
-------
Citizens' Questions
• Forty facilities store substances in quantities greaterthan 100 thousand
pounds, and some as much as 1 million pounds. If storage container
leakjargequarrtrtiesofchemicalscouldleachirrtotheairorgroundwar
Accidents involving many people are possible, mostly from Wor
explosion. . ' ,
• Among the substances stored in large quantities are chlorine, which
produces a highly irritating toxic gas.
• There are at least 50 substances being stored in underground storage
tanks. Accordingtoa recent survey conducted bythe State Environment
Department, more than half the underground storage tanks in the state
are improperly built and in imminent danger of Jeaking.
Industry spokesmen emphasized the care they use in storing and
workmg with the hazardous chemicals. "We're closer to them than
anyone else, so we have a strong incentive to be .careful." said Tom
Thomas of Generic Chemical. City and county emergency officials
stated that the annual inspections of facilities storing hazardous chemicals
convinced them that chemicals are properly stored. They are working
wrth facilities to reduce the possibility.of accidents further. They stated
that the emergency response plan updated underthe same federal law
that requires submission of chemical inventories also ensures citizens'
safety.
Neighborsofplantsare not so sure. "About once a month I hearthe sirens
overtherei-saysSnaronShivers,wholivesin the Northridge neighborhood
near the Generic plant. "I think their storage is faulty but they donl want
lift tn lrn/Mj/ » • .
. US to know."
After reading this article, citizens might ask the following
questions: • , y
• 1) Are the hazardous materials used by nearby facilities stored
properly? What is the chance of leaks developing?
2) How likely are stored materials to be involved in an
accident?
3) If.they are released, what kinds of health or other hazards
do they present?
4) Can we reduce the amounts of these materials that are
stored in order to reduce risk?
34
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Planning for Hazardous
Chemical Emergencies
5) What about the danger from chemicals stored by facilities
that didn't have to report because they had less than 10 000
pounds? ' .,;.:•• -
Answers to these questions requirb some understanding of the
process by which we plan for hazardous materials accidents
and how we assess potential risks! posed by facilities that store
and use hazardous materials. Some of the questions raise
issues we have already considerect-providing information
about health effects and opportunities for citizens to participate
in planning and risk reduction .activities. '
, ' • '' • ' ' • . -
; . - , •' '/'".. .'• ,.!.'• ' ' • "
Section 303 of Title III requires the local Emergency Planning
Committees (LEPCs) to formulate a plan for emergency
response. In order to make a realistic plan, LEPCs must first
learn where and what chemicals are stored. The chemical
inventories submitted under sections 311 and 312 and the lists
of extremely hazardous substances submitted under section
302 provide this information. • ^
- ' i •'-•'•'
To plan for emergencies, LEPCs follow these steps:
•• ' , -. ''(•**.
1. Identify Hazards: using information provided by "facilities, •
determine the ways in which they 'store and use hazardous
chemicals.; •].
' " '. , . . . "'•! : -"' •. • '. • -
2, Conduct a vulnerability analysis: .using credible worst case
assumptions, determine a vulnerability zone and identify
special facilities' within that zone such as nursing homes or'
schools or special problems such as a drinking water source.
3. Work with high-priority facilities to refine and re-evaluate the
hazards identification and vulnerability analysis.
4. Complete a risk analysis: make a rough estimate of risks
based on hazard identification and; vulnerability analysis and
likelihood of releases. Then, integrate..this information into a
community.wide emergency plan. j(The components of a
community-wide plan are described on page 12.)
Figure 2 shows a sample hazards
hazardous chemical at one site. If..
for alt hazardous chemicals found in
ar alysis for an extremely
such an analysis is conducted
the community, it will
35
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Figure 2
SAMPLE HAZARDS ANALYSIS FOR ONE
EXTREMELY HAZARDOUS SUBSTANCE
AT A HYPOTHETICAL SITE
(REPEAT THIS ANALYSIS FOR EACH EHS AND SITE IN THE COMMUNITY)
INITIAL SCREENING
1. HAZARDS IDENTIFICATION
(Major Hazards)
a. Chemical
b. Location
c. Quantity
d. Properties
2. VULNERABlLfTY ANALYSIS
a. Vulnerable zone
b. "Population within vulnerable zone
• •. ' * '
c. Essential services, withinzone
3. RISK ANALYSIS ' .'
(Initial Evaluation of Reporting
Facilities—Relative Hazards)
Chlorine
Water treatment plant
800 tos. .
Poisonous; may be fatal if inhaled. Respiratory
conditions aggravated by exposure. Contact
may cause bums to skin and eyes. Corrosive
Effects may be delayed.
A spjll of 800 fos. of chlorine f rorrf a storage tank
could result in an area of radius-greaterihanio
miles where chlorine gas may exceed the level
of concern (LOG). This would be a credible
worst case scenario.
Approximately 600,residents of a nursing home-
workers at a small factory; 29 workers at the wa-
ter treatment plant; urban area^OO persons/sq -
mile; total population in vulnerable zone is more
than 125,000. •
2 fire stations and 1 hospital
Relative to potential hazards of other
reporting facilites--h{gh
-------
REEVALUATION(PLANNING)
i. HAZARDS ID€NTIFCATION
a. Chemical '
b. Location
c. Maximum quantity that
• could be released
* ' ' •
d. Properties
2. VULNERABtLfTY ANALYSIS , , .
,, a. Vulnerable Zone, .
b. Population within vulnerable zone
c. Essential services '
'3 RISK,ANALYSIS
a. Likelihood of hazard occurrence
. •• -b- Consequences if people are exposed
c. Consequences for property
d c°nsequences of environmental
• exposure , '.
e Summary: likelihood/severityof
on site '. ' .
Chlorine
No change
500 Ibs,' (deer-ease)
1 i
No change
Zone decreases (new radius -1.0 miles) due to
smaHer quantify released and use of urban dis-
persion model.
Decreases; total population in vulnerable
1250
None
zone is
Low-because chlorine is stored in an area with
SL ^fon '^uiPment jn a» hour service with
alarms. Protective equipment is kept outside
storage room, i • - , ,
High levels of chlorine gas in the nursing home
and factory could cause death and respiratory
distress. Bedridden nursing home patients are
especially susceptible. -High severity of ;
consequences. [ However, gas is.unlikely to
reach a nursinghome under reevaluated release
conditions. • '•• • -
» . ' "?*',-,
Possible superfipial damage to facility
equipment and structures from corrosive fumes '
(repairable). ' , , ; .
Possible destrucltion of surrounding fauna and
' ' ' •
Low/High. i
-------
Scenario 3: Storing Large Quantities
provide answers for many of the questions on page 34. For
example, the answer to the question "How likely are stored
materials to be involved in an accident" may be found under
Part 3 (Risk Analysis) of the Reevaluation section,»which
assesses risk after a change in the amount of the chemical-
stored. There, the risk for accidents from chlorine is evaluated
as being low because chlorine is stored in an area with leak
detection equipment and alarms.
Information that the LEPC collects, even extra information such
as a worst-case vulnerability analysis or transportation routes is
available to the public. If the LEPC has completed a plan using
the steps outlined above, it should be able to assist in
answering the question about proper storage.
.It is-difficult to estimate the chance of leaks or accidents This
question is answered-by-describing the planning process, which,
both encourages facilities to store their hazardous chemicals in
the best way and sets up a plan for minimizing damage that
might result if an accident does occur.
Again, in answering questions about accidents, it is important to
remember the risk characteristics listed on page 8.^ People feel
more confident when it seems that all likely, causes of accidents
have been considered and planned for, because the risks seem
more controllable, better understood, and less likely to be
catastrophic.. , .
Facility owners-and managers have the final say over reducing
the amounts of stored hazardous chemicals. - The LEPC can
provide a forum in which citizens can voice concerns to industry
representatives and work with them to get these amounts
reduced. Many facilities are willing to do this after they see the
results of a vulnerability analysis. They may find out that their
inventory costs decrease as well by having less of each
hazardous chemical on hand.
Information about the health effects of individual chemicals will
also be available through the LEPC, health professionals in
state and local health and environment departments, poison
control centers, and academic institutions, or through the
references listed in Appendices 2 and 4.
38
-------
Summary
' ~—~ *—• — ——_____
The kinds of questions that storage raises are hare' to answer.
Because each facility and each community is different the
answers can only be obtained by working carefully through the
specific data provided by local facilities. This is very tfm£
consuming^work_ After the data are obtained, citizens will still
have to work w.th experts to cetermine whether storage
methods and quantities are appropriate and whether health
effects are worrisome.
Rather than providing sample
scenarios, we can offer only
answers, as we did in the other
general suggestions:
Officials can best answer mos1
—referring to the plan and
creating it, and
—referring to the sources
can work with government
within government where citizens
and industry.
39
of these questions by
the procedures that went into
-------
Summary &
Conclusion
The "Seven Cardinal Rules of Risk Communication," written by
Vincent Covello and Frederick Allen and available in an EPA
pamphlet are reprinted here. They both summarize-and add to
the information presented in this manual.
" ' h \
1. Accept and Involve the Public as a Legitimate Partner
* Involve the community early.
* Involve all parties that have an interest or stake in the
issue. ,
* Remember, you work for the public.
The goal of risk communication should be to produce an
. informed public that is involved, interested, reasonable,
, thoughtful, solution-oriented, and collaborative. • ,
2. Plan Carefully and Evaluate Your Efforts
* Begin with clear, explicit objectives.
* Evaluate the information you have about risks and know its
strengths and weaknesses.
* Identify and address the particular interests of different,
groups. ,
* Train your staff — including technical staff — in
communication skills.
* Practice and test your messages. , . "'
* Evaluate your efforts and learn from,your mistakes.
3. Listen to the Public's Specific Concerns
If you do not listen to people, you cannot expect them to
listen to you. Communication is a two-way activity.
• \ ' .'.•.'•
* Do not make assumptions about what people know,
think, or want done. Take the time to find out what
people are thinking. ,
* Let all parties with an interest in the issue be heard.
* Identify with your audience. Put yourself in their place
, and recognize their emotions.
People are often more concerned about trust, credibility,
competence, control, voluntary fairness, caring and
compassion than mortality statistics or quantitative risk'
assessment.
40
-------
J ' •
4. Be Honest, Frank and Open
' O4***4 A • .._ . . . ( .. -I
aut do not ask or expect to be
"Get back l kn°W^ answer or are uncertain, say so.
* Disclose risk information as soon as possible.
* PO not minimise or exaggerate the level of risk
Lean toward sharing more information, not less - or
people may think you are-hiding something.
Trust and credibility are difficult to obtain. Once lost they are
almost impossible to regain completely. X
• and Collafciorate with Other Credible
Take time to coordinate with other organizations or
groups.
Devote effort and resources to the slow, hard work of
^ building bridges with other organizations.
sources1* C0mmunications J°int|y w»h other credible
Few tWngs make risk communication more difficult than '•'-•
contnctsor pubhc disagreements with other credible^urces.
6, Meet the Needs of the Media
open with and accessible to reporters; respect their
* Provide risk information tailored to the needs of each
type of media. '
•*. %s?-£r* and^ravide baqk9round materiai°n;
* Try to establish long-term relationships of trust with
specific editors and repbrters.
' ' ' • ' •' i • •
The media are frequently mo^ interested in politics than in
nsk; more interested in simplicity than in complexity more
interested in danger than in safety. ompiexitv• more
• " ' . ' 'i ' '
7. Speak Clearly and with Compassion
Technical information and jargon are barriers to successful
-------
communication with the public.
Be sensitive to local norms, such as speech and dress.
* Use vivid, concrete images that communicate on a
. personal level. Use example and anecdotes that make
technical risk data come alive. '
* Use simple, non-technical language.
Use risk comparisons to help put risks in perspective; but
avoid comparisons that ignore distinctions that people
consider important. ,
* Acknowledge and respond (both in words and with
actions) to emotions that people express — anxiety,
fear, outrage, helplessness.
* Always try to include a discussion of actions that are
under way or that can be taken. Tell people what you
cannot do. Promise only what you can do, and be sure
to do what you promise:
* If people are sufficiently motivated, they are quite capable
of understanding complex risk information, even if they
may not agree with you.
Regardless of how well you communicate risk information,
some people will not be satisfied. "
these rules seem to be only common sense. Yet it is surprising
how often they are violated when communicating about risk.
Following them does not guarantee effective risk
communication. On the other hand, it is unlikely that you will
communicate effectively without them. There is also an
'informal eighth rule, which underlies all the others:
Know what you are talking about.
Since no one person can be expected to know everything, we
have tried to provide sources for additional information as well
as sample answers to questions in which you refer citizens to
these sources.
Talking to people about risk is difficult. Certain buzzwords or
ideas such as "cancer" often set off reactions that may be too
strong. Many familiar chemicals that people use every day may
have more serious effects than some of the unfamiliar
chemicals they will hear about under Title III. Public officials
must try to help citizens keep these risks in perspective.
42
-------
Opportunity for
Citizen Involvement
Plan of Action
One of the most important
is of risk is wheth
... -—,., when the questions cannot be answered with
indu^ H CS mClUde rePr^entatives from government
industry, and citizen groups, they offer a good settlna tor
encouragmg the different interests to work together
before some particular incident {(such as a
no^i ire Qnff to IL* \*/f4K M A a . .i
i i_\j iQi(\ wiin. not to Cfti?^nQ
? .. inan rGpay tns uuois wnen wnat WOL
oe a divisive community issue is settled throuah
compromise and negotiation. «uieainrougn
•"',.'- • j __ "X''
°r "master P'an" *« wiil
m t0 6V6ry question ^u may ever face in
commun.cations. The following steps are suggested
^f0'0"8 y°U Can tak€l "^ toda ^ITSelp
you for your responsibilities in this area:
by Which you wi" h£fve filled^ in all of the
"RJSk Communical:ion Resource Sheet" in the
^ you already have;
-------
other information might take,some "digging." This resource
sheet will provide a quick reference to many of the contact
people who are knowledgeable about emissions, releases,
stored substances, etc. Update this resource sheet annually.
2. Obtain copies of this manual for persons involved in your
emergency plan.
3. Initiate contact, if you have not already done so, with
members of your Local Emergency Planning Committee, and
learn more about their activities. / ,
4. Keep this manualin an accessible place for periodic review
and/or in case of emergencies. ,,
Please let us know your successes in communicating about risk,
and what works most effectively. Contact:
Ann Fisher
Office of Policy Planning & Evaluation, PM-221
Environmental Protection Agency ,
• Washington D.C. 20460
(202)382-5500
Susan <3. Madden ,
LBJ School of Public Affairs
The University of Texas at Austin
Austin, Texas 78713
(512)471-4962
Steve Finefrock
National Emergency Training Center
Building N
Room 242
Emmitsburg, Maryland 21727
(301)447-1282
44
-------
APPENDIX 1
Glossary of Commonly Uibecl Terms
'••'-. ' ' L '•'.'' '••.•-
Absorbed dose-The amount of a chemical that enters the body of an organism.
"" de"el0pme"' - «*« - after a single expose ,o a
A«ive effect-Combined effect o, ,» or more chemicals e<,ua, „ ,he surn 0, thelr individua,
Ambient-Environmental or surrounding conditions. I '
o,
Se.ioa,
Carclnogen-A chemical that causes or induces cancer.
"Umb6r"A numher assi»^ ^'neChemica, Abstracts Service to
e .
delayed effect.) ime even if caused by a single acute exposure. (See also
Chronic exposure-long-term, low-level exposure to ate \ Lmical. • :
Ooncentration-the amount o, «,, SUDSIanoe ,in a represen,W ^ „, ^ ^^
ef,ec,.-an e,,ec, o, exposure that does no, occur for some ,,me. Sometimes called
e amount o, , he sbustance that actually enters the body. : ' ,
qUam"aliVe ^"""^.p.beN.een the dose of a Jhemical and an effeci caused by the
-e9reeo, ensure to a
manufacturing process-and JccidentaL are P anned lo W released as Part »'
f- « P='-«al danger to human
penmen, assessment ^meisT^rs^^^^^ or
-------
Environmental fate--The destiny of a chemical after release to the environment; involves
consideration's such as transport through air, soil, and water; bioconcentration; degradation.
EPCRA-The Emergency Response and Community Right-to-Knqw Act of 1986; same as SARA Title III.
Epidemiological studies-Investigation of factors contributing to disease or adverse health e'ffects in
human populations.
Exposure-The contact with alchemical or physical agent. This contact can occur through breathing,
drinking, eating, and by direct skin contact.
Extrapolation-Estimation of unknown values by extending or projecting from known values.
Extremely hazardous substances-Chemicals that have the potential for causing death 'or, irreversible
toxicity after relatively short exposure to small amounts. (They are acutely toxic.) On the basis
•of toxicity, generally in air, EPA has identified the list of the chemicals in Appendix 5. '
Latency-Time from the first exposure to a chemical until the appearance of an adverse health effect.
.LC50--the concentration of a chemicalin air or water that is expected to cause death in 50 percent of'
test animals living in that air or water. ,
LD50-The dose of a chemical by a specific exposure pathway (eating, breathing, injection, or absorbed
by the skin) that is expected to cause death in 50 (percent of the test animals so treated.
LEPC--Local Emergency Planning Committee/Local body established under Title III. " ,
LOAEL-Lowest-Observed-Adverse-Effect Level; the lowest dose in an experiment .that produced an ,
observable adverse effect. • . : ,
Laboratory studies-Studies of the effects of chemicals on animals or cells.
:-Jn vitro studies-Studies of chemical effects conducted in tissues, cells or subcellular extracts .
'.!'- . from an organism (i.e., not in the living organism). ,
--In vivo studies-Studies of chemical effects conducted in intact living organisms.,
Long-term. exposure-This occurs when a substance is present in the environment around a person
over a long period of time.
MSDS-Material Safety Data Sheet. A description of the chemical, physical, and health effects of a
chemical along with methods for protection and emergency response written for workplace settings.
Materials balance--An accounting of the, mass-flow of a substance from sources of production, through
distribution and use, to disposal or distribution, and including any releases to the environment.
Mutagen~An agent that causes a permanent genetic change, in a cell other than that which occurs during
'normal genetic recombination.
NOAEL-No-Observed-Adverse-Effect Level; the highest dose in an experiment that did not produce an
observable adverse effect.
NRC--National Response Center, 1-800-424-8802.
Pathogen-Any disease-causing agent, usually applied to living agents.
-------
Permissible dose-The:dose of a chemical that may be
of a significantly harmful result. - .
ty an individual without the expectation
RC subs'ta^s06 Conservation and Recovery Act. Another federal
Release-see "Emission."
Reversible effect'-An effect that is not permanent; an especially
exposure to a toxic chemical ceases. H«w<«iy
adverse effect that diminishes when
Risk-Trie likelihood of injury, disease, or death.
A qualitative or quantitative evaluation of the
exposure to a chemical or physical agent (
results with toxicity assessment results to estimate risk
environmental and/or health risk
(pollulant); combines exposure assessment
Risk estimate.-A description of the probability that .organisms
w,ll develop an adverse response (e.g., cancer).
exposed to a specified dose of chemical
Risk factor-Characteristic (e.g., race, sex, age, obesity) or v
exposure level) assbciated with increased probability of an
posure"the avenue ^ which a chemical comes into
, mgestion, dermal contact, injection). '..:..
variable (such as. smoking, occupational
adverse health effect. /
cor tact with an organism (e.g.,
SARA-Superfund Amendments and Reauthorization Act of 1986,
SERC-State Emergency Response Commission. Established under
rv,~7f '.• '—"'*' °* a physical or chemical agent to
malformations (birth defects) in offspring.
«*7h V -T clllp|yBflcy Banning and Comm
or tne Superfund Amendments .and Reauthorizal
Toxicity--The quality or degree of being poisonous or harmful to
TRI--Tox.es (or Toxic Chemical) Release Inventory. The database
Th« Toi'SPS -iSI!, .ltte? by certain manufacturing facilities, s
me TRI .s available to the public in county libraries, through a
National Library of Medicine, and through
statute concerning hazardous
Title III.
cause hereditary congenital -
measLrable effect is observed and below
and Comm jnity Right to Know Act of 1986,
ion Act.
plant, animal, or human life.
containing annual toxic chemical '
specified in Section 313 of ERCRA.
national computerized database
regional EPA offices. See Appendix 2
-------
3. About Specific Chemicals
Chemical Manufacturers Association. Chemical Referral Center. 1-800-262-8200.
CAMEO (Computer-Aided Management for Emergency Operations). (Software-contains descriptions,
health effects information, and emergency response information for more than 2400 chemicals.)
Department of Transportation. Emergency Response Guidebook. Lists about 1,000 substances by
name and DOT identification number, giving hazards and isolation distances. Available from Office of
Hazardous Materials Transportation, DMH-50, RSPA, DOT, 400 7th Street, S.W., Washington, D.C.
20590. : '
Environmental Protection Agency. Common Synonyms for Chemicals Listed under Section 313 of the
Emergency Planning and Community Right-to-Know Act of 1986. December 1988!
Illinois EPA. Chemical Information Sheets. Springfield, III, 1986,1987.
Massachusetts Department of Environmental Quality Engineering. Layperson's Guide to Reading
MSDSs: Boston, Mass.
'Michigan Department of Natural Resources. Chemical Summaries. East Lansing, Michigan.
New Hampshire Department of Health and Human Services. Health Information Summaries. Concord,
N.H. '
•New Jersey Department of Health. Hazardous Substance Fact Sheets. Trenton, N.J. (Distributed by
EPAtoSERCs.] • .',--.. ,
North Carolina Department of Natural Resources and Community Development: Chemical Profiles of
Toxic Air Pollutants. Raleigh, N.C., 1986. .
• Virginia Department of Health. Virginia Fact Sheets. Richmond, Va. N
U.S. Coast Guard, Chemical Hazards Response Information System 202-267-1577.
Washington Department of Social and Health Services. Toxic Substances Fact Sheets. Olympia, WA.
4. General Information about Health Effects
Agency for Toxic Substances and Disease Registry. Case Studies in Environmental Medicine.
Agency for Toxic Substances and Disease Registry. Toxicological Profiles. Profiles have been
developed for the hazardous substances that pose a significant potential threat to human health and are
common at Superfund sites. Each profile contains lexicological and health effects information for the
substance. (Write for information on how to obtain the Profiles: ATSDR, E-28, Division of Toxicology,
1600 Clifton Road, N.E., Atlanta, Georgia 30333.) ; -.'•....
Bell, Carolyn. The Environment in Small Dos.es: A Layperson's Guide to Understanding Toxic
Substances. Memphis, Tenn.: Autumn Expressions, 1987.
Environmental Protection Agency. Chemical Exposures: Effects on Health. ,1987. Available from the
TSCA Assistance Office, TS-799 at EPA.
-------
1. Title III
APPENDIX 2 '
References and Sources
m^woi^l< y
Chemcal Manufacturer Association. Ccmmnity Guiteu ne ill. ;
er: Coto.:
^
2. About Risk Communication
ȣ^
Pele,
-------
Keeney
Uro«. Richard A, 7^ ,,eAI, Washington.
1984 A
torn exposure lo chemicals and me°tas public p«ceSons« Sf1"™"**.'!" ".I* «» iding
, MO: Na,tona,
Sasnan^amK., r=«SP,TO, Wash^cn.DC;Ua3ue0, women Voters o,,heurt,ed
Eva,ua,lon Methods, or: US6 m .SpecH.c CommunUie, V '
^ssn!^^
CAMEO (C.mpu,er.AidedManaaamemfor Emergency Operations,'. (so«ware, '' '
(NRT1.A)
3vt,e* r\ i • w"" la*<*'i I, I
-Sl Passionals who are
-------
Rail David P., Medicine for the Layman: Environment and Disease. Bethesda.MD: National Institutes for
H63iin, 1982. L
Sherry, Susan. High Tech and'Toxics:A Guide for Local Communities! Washington DC- Golden Emoire
Health Planning Center, 1985. . " H
Working Group on Community Right to Know. Hazard Assessments and Plume Mapping Documents for
• " - " " " •
6. State and Local Level Contacts and Resources (also see Appendix 4.)
i ' • . - • • i ..'.".••
Public Health Foundation, Environmental. Hearth Program. Directory of ptate and Territorial Environmental
°n PHF' 198?' Updat6d annua"y anb ln P°ssession
7. Waste Reduction
The
Waste Reduction: Six Steps States Can
r^""^^rvtd J'' Warren Muir' Catherine G. Miller, and Sebastian R. Sperber, Cutting Chemical Wastes-
What 29 Organic Chemical Plants are Doing to Reduce Hazardous Washes: NewYork: INFORM.TSs
8. Databases.
(NLM)l 860° Rockville Pike' Bethesda, MD. 20894. 1 -800-638-8480 or
' PerS°na' comPuter and ™>dem connection, or
on cn,
fn ?a "rnedicaNibrary
' TOXLINE. A collection of online bibliographic information convering the
pharmacological, bioctiemical, physiological, and lexicological effects of drugs and
hazardous chemicals. For information; MEDLARS Management Section at the NLM
address given above. | .. .
Toxicology Data Network System (TOXNET). A computerized system of files oriented to
ucCnm9Lan£ related areas" Th-e files include the Hazardous Substances Data Bank
(HSDB), the Registry oi Toxic Effects of Chemical Substances (RTIECS) and the
Environmental Protection Agency's Toxic Chemical Release Inventory (TRI) For
information, contact the NLM at the address given above
CCINFOdisc. Canadian Centre for Occupational Health and Safety.
CCJNFOdisc is a compact disk with several toxic substances <
New Jersey Fact Sheets.
databc ses, including the
-------
APPENDIX 3
Brief Description of Title III by Section
301 - establishes LEPCs and SERC
-------
Appendix 4
Contacts
rgency
Community Right-To
Act of 1986
State Emergency
Cpmmission/Ti
Contacts
itle
November 1, 1989
Response
III
r™ ^ Prepared by
The Emergency Planning and Community
Kignt-To-Know Information Hotline
For more information call
(or (202) 479-2449 inl0e"wa5shin^o2n, DC metro -,
-------
State Emergency Response Commission and
State-Designated Agencies for the
Emergency Planning and Community Right to-Know Act
November 1, 1989
T
-------
ALABAMA .
State Commission:
— J. Danny Cooper, Co-Chair
Afabama Emergency Response Commission
Director, Alabama Emergency Management
Agency
520 South Court Street
Montgomery, AL 36130
(205)834-1375
Contact: Dave White
Section 311/312 Submissions:
Leigh Pegues, Co-Chair
Alabama Emergency Response, Commission
Director, Alabama Department of Environmental
Management
1751 Congressman W.L. Dickinson Drive
Montgomery, AL 36109
(205)271-7700 •
' Contact: L.G. Linn (205) 271-7700
E.John Williford (205)271-7931
Section 313 Submissions: ;
E. John Williford, Chief of Operations
. Alabama Emergency Response Commission
Alabama Department of Environmental '
Management .
1751 Congressman W.L Dickinson Drive
Montgomery, AL 36109
(205)271-7700
Contact: L.G. Linn (205)271-7700
E. John Williford (205)271-7931
ALASKA -....'.
Dennis Kelso, Chair ,
''Alaska State Emergency Response
Commission .
P.D. BoxO
Juneau, AK 99811
.(907)465-2600
Mailing Address: ' . ,
Linda VanHouten
Alaska State Emergency Response
Commission
9000, Old Glacier Highway
P.O. Box 32420
Juneau, AK 99803
State Commission:
Maiava O. Hunkin . . '"
Program Coordinator for the Territorial
Emergency Management Coordination
Office '.
American Samoan Government
P.O. Box 1086 ; ; , ':
Pago Pago, American Samoa 96799
niernational Number (684) 633-2331
& 313 Submissions: '
Pati Faiai, Director - ,
American Samoa EPA
••• Office of the Governor
Pago Pago, American Samoa 96799
International Number (684) 633-2304
ARIZONA
Carl F. Funk, Eixecutive Director
Arizona Emergency Response Commission
Division of Emergency Services
5636 East McDowell Road
Phoenix, AZ 85008
(602) 231-63213
ARKANSAS
State Commission:
Randall Mathis,-Director . --
Arkansas Department of Pollution Control and
Ecology ;-
P.O. Box 95831 -
8001 National Drive .
Little Rock, AR 72219 ' '
. . (501)562-7444'
Contact: John! Ward
(501)562-7444
JA 313 Submissions:
Section 311/312
. Becky Bryant
Depository of Documents
Arkansas Department of Labor
10421 West Markhanv
Little Rock, AR 72205
- . . [ ; . • . t
Contact: Beck]!' Bryant (501) 682-4534
Mailing Address: | ' ' . ...-.-
Arkansas Department of Pollution Control and
Ecology '
P.O. Box 9583 '
8001 .National Drive | ••'••-.
Little Rock, AR 72219
Attn: John Ward , -
CALIFORNIA
State Commission:
William Medigovich. Chair
California Emergency Planning and Response
- Commission j
Director, Office of Emergency Services
, 2800 Meadowview Road
Sacramento, CA 95832
(916)427-4287 ! ••".:..'.. ..'
Section 302, 304,1 311/312 Submissions:
California Emergency Planning and Response
Commission {'. •
Office of Emergency Services ' - '
Hazardous Materials Division
2800 Meadowview Road
-------
Sacramento, CA 95832
(916)427-4287
Contacts: Gary Burton
Michelle LaBella
Dave Zocchetti
Section, 313 Submissions:
Chuck Shutock ,
Office of Environmental Affairs
P.O. Box 2815
Sacramento, CA 95812
Attn: Section 313 Reports
(916)324-8124
(916) 322-7236 Completed Form R Information
COLORADO
State Commission:
David C. Shelton, Chair
Colorado Emergency Planning Commission
Colorado Department of Health
4210 East 11th Avenue
Denver. CO 80220
(303)331-4880 - ,
Emergency Release Notification:
(303)331-4858
After Hours & Weekends (Emergencies Only)1
(303)377-6326
Section 302, 304, 311/312 & 313
Submissions:
Colorado Emergency Planning Commission
4210 East 11th Avenue
Denver, CO 80220
Delaware City, DE 1 9706
(302) 834-4531
Section 304 Submissions:.
Phillip Retallick, Director .
Division"of Air and Waste Management "'
Department of Natural Resources and '
Environmental Control
Richardson and Robbins Building
. 89 Kings Highway
P.O.Box 1401 '
.Dover, DE 19903
•(302) 736-4764
Section 311/312 Submissions: '
Dr. Lawrence Krone, Chief ' '
Bureau of Environmental Health
Jesse Cooper Building ,
Federal Street ' - '
P.O. Box 637
Dover, DE 19903 ' ^
(302)736-4731 ' ,
Section 313 Submissions:
Robert French, Chief Program Administrator
Air Resource Section
Department of Natural Resources and '
Environmental Control .
P.O. Box 1401
Dover, DE 19903 ''.••'
(302) 736-4791
DISTRICT OF
Contact: Judy Waddill
CONNECTICUT
,(303)331-4858
Sue Vaughn, Title III Coordinator
State Emergency Response Commission
Department of Environmental Protection
State Office Building, Room" 161
165 Capitol Avenue
Hartford. CT06106
(203) 566-4856
DELAWARE
State Commission:
Patrick W. Murray, Chair
Delaware Commission on Hazardpus Materials
Department of Public Safety
P.O. Box 818
Dover, DE 19903
Contact: George Frick (302) 736-3169
Section 302'Submissions:
Dominick Petrilli, Acting Director
Division of Emergency Planning and
Operations , '
P.O. Box 527
Joseph P. Yeldell, Chair '
State Emergency Response Commission for
, Title III
in the District of Columbia
Office of. Emergency Preparedness
2000 14th Street, NW
Frank Reeves Center for Municipal Affairs
, Washington, DC 20009 '' • >
(202)727-6161 ' -
Contact: Pamela Thurber, Environmental
Planning Specialist
FLORIDA
Mr. Thomas G. Pelham, Chair
Florida Emergency Response Commission
, Secretary, Florida Department of Community
Affairs
2740 Centerview Drive
Tallahassee, FL 32399-2149
• (904) 488-1472
. In FL: 800-635-7179 i .
Contact: Eve Rajney •
-------
State Commission:
Mr. J. Leonard Ledbetter, Chair
Georgia Emergency Response Commission
Commissioner, Georgia Department of Natural
Resources.
205 Butler Street, SE
Floyd Towers East, 11th floor'
Atlanta, GA 30334
' (404) 656-4713
Section 302, 304, 311/312 & 313
Submissions:
Jimmy Kirkland .
Georgia Emergency Response Commission
205 Butler Street, SE
Floyd Tower East .
11th Floor, Suite 1166
1 Atlanta, GA 30334
. (404) 656-6905 ; - "
Emergency Release Number (800) 241-4113
GUA
.P.O. Box 3378 . .
Honolulu, HI 96801-99Q4
(808) 548-6505
|
ICAfcLQ
State Commission:
Idaho Emergency Response Commission
State House j
Boise, ID 83720
(208)334-5888 .
State Commission & Section 311/312
Submissions: .
Dr. George Boughton, Chair .
Guam State Emergency Response
Commission
Civil Defense '
Guam Emergency Services Office
Government of Guam
P.O. Box 2877
Aguana, Guam 96910
(671)472-7230
FTS 550-7230 . "
Section 313 Submissions:
• RolandSolidip
Guam EPA
P.O. Box 2999
Aguana, Guam "96910
. (671)646-8863
HAWAM
State Commission- and Section 311/312
• Submissions:
Bruce S. Anderson, Ph.D., Vice-Chair
Hawaii State' Emergency Response
Commission
Hawaii Department of Health
P.O. Box 3378
Honolulu, HI 96801
i'808) 548-2076
(808)548-5832 '. - - •
3J1/312 & "SIS Submissions-
Idaho Emergent Response Commission
State House i •.
.Boise, ID 83720
Attn: Jenny Records
j -
Contact: Jennyj Records (208) 334-5888
ILLINOIS ! ,
State ^Commission and Section 311/312
Submissions: •'.
Oran Robinson !
Illinois Emergency Response Commission
'
110 East Adams Street
Springfield, IL 62706
(217)782-4694 |
Section 313 Submissions
Joe Goodner j
Emergency Planning Unit
Illinois EPA i
P.O. Box 19276 |
2200 Churchill Rc'ad
Springfield, IL 62794-9276
(217) 782-3637 i
INDIANA.
i ' ' 1
Skip Powers, Director
Contact: . SamirAraman
Mark Ingoglia
(808) 543-8249
(808)543-8276
Section 313 Submissi.ons:
John C. Lewin, M.D., Chair
Hawaii State Emergency Response
Commission
Hawaii State Department of Health
u,,
5500 West Bradbury Avenue
Indianapolis, IN 46241
(317)243-5176 i
IOWA '
State Commission 4 Soction
Submissions:]
Ellen Gordon, Chair
bwa Disaster Services
Hpover Building, Ltivel A
Room 29 '•!,..'
DesMoines, IA50319
(515)281^3231 !
-------
Section 304 Submissions:
Department of Natural Resources
Division of Environmental Protection
Emergency Response Section
Wallace Building, 5th Floor
Des Moines, IA 50319
(515)281-8694
Contact: Ron Kozel
Section 311/312 Submissions:
Iowa Emergency Response Commission
Division of Labor
1000 East Grand Avenue
Des Moines, IA50319
(515)281-6175
Contact: Don Peddy
Section 313 Submissions:
Department of Natural Resources
Records Department
900 East Grand Avenue
Des Moines, IA 50319
(515)281-8852
Contact: Pete Hamlin
KANSAS
State Commission:
Karl Birns, Staff Director . ' -
Kansas Emergency Response Commission
and
Community Right-To-Know Program
Mills Building, 5th Floor
109 S.W. 9th Street
Topeka. KS 66612
(913)296-1690 '
Section 302 & 304' Submissions:
Karl Birns • :
Kansas Department of Health and Environment
Right-to-Know Program
Mills Buildirjg, 5th Floor . .
109 S.W. 9th Street' •
Topeka, KS 66612 . .
(913)296-1690
Emergency Release Number Only (24 hrs):
(913)296-3176 .. ' .
Section 311/312 & 313 Submissions:
Right -to- Know Program
Kansas Department of Health and Environment
Mills Building, 5th Floor
109 S.W. 9th Street
Topeka, KS 66612
(913) 296-1690
Contact:
KENTUCKY
Karl Birns
State Commission & Section 311/312
Submissions:
Colonel James H. "Mike" Molloy, Chair
Kentucky Emergency Response Commission
, Kentucky Disaster and Emergency Services'
Boone National Guard Center
Frankfort. KY 40601-6168
(502)564-8660 ,
(502) 564-8682
Contact: Mike Molloy or Craig Martin
Section 313 Submissions:
Valerie Hudson
Kentucky Department of Environmental
. Protection
18ReillyRoad
Frankfort, KY 40601
(502) 564-2150 ; '
Mailing Address:
Lucille Orlando , '
SARA Trtle III
Kentucky Department of Environmental
Protection '
Kentucky Disaster and Emergency Services
Boone National Guard Center
Frankfort, KY 60601-6161
LOUISIANA
State Commission & Section 311/312
Submissions:
Sergeant Ronnie Mayeaux
Louisiana Emergency Response Commission
Office'of State Police
P.O. Box66614
7901 independence Boulevard
Baton Rouge, LA 70896
(504)925-6113
Section 313 Submissions:,
R. Bruce Hammatt
Emergency Response Coordinator '
Department of Environmental Quality
P.O. Box 44066
333 Laurel -Street
•Baton Rouge, LA 70804-4066
(504)342-8617
MAINE
David D. Brown. Chair
State Emergency Response Commission
' Station Number 72 . •
Augusta, ME 04333
(207) 289-4080 ,
(800)452-8735 in ME
Contact: Tammy Gould '
MARYLAND
State Commission:
June L. Swem
Governor's Emergency Management Agency
c/o Maryland Emergency Management Agency
2 Sudbrook Lane, East • . • -
Pikesville, MD21208
(301)486-4422 .
-------
Section 302, 304, 311/312 & 313
Submissions:
Marsha Ways
State Emergency Response Commission
Maryland Department of the Environment
Toxics Information Center
2500 Broenirig Highway
Baltimore, MD 21224
(301)631-3800
MASSACHUSETTS
Arnold Sapehter
c/o Title Three Emergency Response
Commission •
Department of Environmental Quality
Engineering
One Winter Street, 10th floor
Boston, MA 02108
(617)292-5993
For LEPC Information: Jack Callahan (508) 820-
2060
MICHIGA^ ,
, Title III Coordinator ' .
Michigan Department of Natural Resources
Environmental Response -Division
Title III Notification
P.O. Box 30028 . '
Lansing, Ml 48909
(517)373-8481 ,
MINNESOTA.
Lee Tischler, Director .
'290 Bigelow Building
450 North Syndicate •
St. Paul, MN 5515$ •
(612)643-3000 - '
MISSISSIPPI
J.E. Maher, Chair
Mississippi Emergency Response Commission
Mailing Address:!:
Dean Martin • \
Missouri Emergency Response Commission
™fn°u' DePartm!ent<* Natural Resources
2010 Missouri Boulevard
Jefferson Crty, MO 65109 .
j -
MONTANA
Tom Ellerhoff; Co-Chair
Montana Emergency Response Commission
Environmental Sciences Division
Department otHealth& Environmental
Sciences <
Cogswell Building A-1 07
Helena, MT 59620
(406) 444-6911
Contact: Guy Youngblood
-
Clark Smith, Gisordinator
w!Kfata ^meir9ency Response Commission
P 0.rSxa98e9?2m'Bnt d Environmental 'Cort«l
State House Station
Lincoln, NE 6EI509-8922
(402)471-2188
Emergency Nurnber (After-hours): (402) 471 -
4545 i •;-''•
NEVADA j -
i
State commlsskin and Section 311/312
Submissions:
Joe Quinn '
Fondren Station
Jackson, MS 39296-4501
(601)960-9973
Contact: Bill Austin
Dean Martin, Coordinator
Sur1nm
-------
NEW JERSEY
State Commission:
Tony McMahon, Director
New Jersey Emergency Response
Commission
SARA Title III Project
Department of Environmental Protection
Division of Environmental Quality
CN-405
Attn: 304 Notification
Trenton, NJ 08625
(609) 292-6714
Emergency Number: (609) 292-7172
Section 302, 311/312 Submissions
New Jersey Emergency Response
Commission
SARA Title III Project
Department of Environmental Protection
Division of Environmental Quality - ,
CN-405
Trenton. NJ 08625
(609) 292-6714 •
Section 304 Submlsslpns:
New Jersey Emergency Response
Commission
SARA Title III Project
Department of Environmental Protection
Division of Environmental Quality
CN-027
Trenton, NJ 08625
(609) 292-6714
Section 313 Submissions:
New Jersey Emergency Response
Commission '
SARA Title III Section 313
Department of Environmental Protection
Division of Environmental Quality
Bureau of Hazardous Substances Information
CN-405 ' .- .
Trenton, NJ 08625
(609)292-6714
MEW MEXICO
Samuel Larcombe
New Mexico Emergency Response
Commission
New Mexico Department of Public Safety
P.O. Box 1628
Santa Fe, NM 87504-1628
(505) 827-9222
NEW YORK;
State Commission:
Anthony Germano, Deputy Director
State Emergency Management Office
Building 22
State Campus
Albany, NY 12226
(518)457-9996
313
Section 302, 304, 311/312 4
Submissions:
New York Emergency Response Commission
New York State Department of Environmental
. Conservation
Bureau of Spill Response
50 Wolf Road/Room 326
Albany, NY 12233-3510
(518)457-4107
Contact: William Miner
NORTH C
State Commission:
Joseph-Myers, Chair
North Carolina Emergency Response
Commission >'.••.•'
116 West Jones Street
Raleigh, NC 27603-1 335
- (919) 733-3867 '
Section 302, 304, 311/312 & 313
Submissions:
North Carolina Emergency Response
Commission
North Carolina Division of Emergency
Management
116 West Jones Street . • '
Raleigh, NC 27603-1 335
(919)733-3867
(800) 451-1403 (In NC Genera) Information
Only) . _ _
Contacts: VanceKee'
Emily Kilpatrick
NORTH DAKOTA
(919) 733-3844
(919) 733-3865
State Commission: '
' Ronald Affeldt, Chair
. North Dakota Emergency Response
Commission
Division of Emergency Management
P.O. Box 5511 ,
Bismark, ND 58502-5511
(701)224-2111
Section 302, 311/312 & 313 Submissions:
SARA Title III Coordinator
North Dakota State Department of Health and
, Consolidated
Laboratories
1200 Missouri Avenue
P.O. Box 5520
Bismarck, ND 58502-5520
(701)224-2374
Contact: Charles Rydeli
-------
COMMONWEALTH of
MARIANA
State Commission and Section 311/312
Submissions: '
. Felix A Sasamoto, Civil Defense Coordinator
Office of the Governor
Capitol Hill
Commonwealth of Northern Mariana Islands
Saipan, CNMI 96950 '• •-
International Number (670) 322-9529
Section 313 Submissions-
- Russell Msecham, III
Division of Environmental Quality
P.O. Box 1304
Saipan, CNMI 96950
(670) 234-6984
OHIO
state
Sectlon 311/312
Ken Schultz, Coordinator
, Ohio Emergency Response Commission
Offir. E7'ronmental Protection Agency •
Office of Emergency Response
P.O. Box 1049 .
Columbus, OH 43266-0149
(614)644-2260 ,,
Section 313 Submissions-
Cindy Sferra-DeWulf
Division of Air Pollution Control
1800 Watermark Drive
Columbus, OH 43215
.(614) 644-2266 •. • .
OKLAHOMA \
Response Commission
vil Defense
P.O. Box 53365
Oklahoma City, OK 73152
(405)521-2481
Contact: Aileen Ginther
Ralph M. Rodia
Salem, OR 97310
(503)378-2885
State Commission:
Richard Rodney
SARA Tde III Officer
HarrisbuVg, PA17105
(717)783-8150
Sect'°n
Submissions:
c/o Bureau of Right-to-Know
Hm 1503 r
^ ^f.oor and' Industry Building,
7th & Forrester Streets
Harnsburgi, PA 17120
(717)783,2071 ,
Section 3l3JSubmissio:ns-
James Tinney
Bureau of Right To- Know
Room 1503
Labor and industry Building
7th & Forrester Streets
Harrisburg,!PAi7l20
(717)783-2071 '
Mr. Santos Rohena, Chair
Environmental Quality Board
P.O. Box 11488
Sernades Juncoa Station
Santurce, PR 00910
(809) 722-1 175
(809) 722-2173 :
cn 313 .
SERC Commissioner
Title III-SARA Section 31 3
Santurce, PR 00910
(809) 722-00;7
RHODP
•
State Commission:
Director
emergency Response
•Commission
Sjate House Room 27
Providence, R I 02903
(401)277-303!)
Emergency Releaso Number (401) 274-7745
.Contact: John Aucott
-------
Section 311/312 Submissions: .
Anthony Diccio
Rhode Island Department of Labor'
Division of Occupational Safety
220 Elmwood Avenue
Providence, Rl 02907
(401)457-1847 •
Section 313 Submissions:
Department of Environmental Management
Division of Afr and Hazardous Materials
291 Promenade Street
Providence, Rl 02908 "
Attn: Toxic Release Inventory
(401)277-2808
Contact: Martha Mulcahey
SOUTH CAROLINA
State Commission and Section 302
Submissions:
Stan M. McKihney, Chair,
South Carolina Emergency Response
Commission •
Division of Public Safety Programs
Office of the Governor
1205 Pendleton Street
Columbia, SC 29201
(803) 734-0425
Section 304 & 311/312 Submissions:
South Carolina Emergency Response
Commission
Division of Public Safety Programs
Office of the Governor
1205 Pendleton Street
Columbia, SC 29201
Attn: Purdy McLeod
(803) 734-0425
Section 313 Submissions:
Ron Kinney
Department of Health and Environmental
Control .
2600 Bull Street
00^01^3.5029201
(803) 734-5200
SOUTH DAKOTA
State Commission and Section 311/312
Submissions:
Clark Haberman, Director
South Dakota Emergency Response
Commission
Department of Water and Natural Resources
Joe Foss Building
523 East Capitol .
Pierre. SD 57501-3181
(605)773-3151 ,
Section 313 Submissions:
Lee Ann Smith, Director,
South Dakota Emergency Response
Commission
Department of Water and Natural Resources
Joe Foss Building
523 East Capitol
,Pierre, SD 57501-3181
(605) 773-3153
TENNESSEE
• Mr. Lacy Suiter, Chair
. Tennessee Emergency Response
Commission
Director, Tennessee Emergency Management
Agency
3041 Sidco Drive
Nashville* TN 37204
(615) 252-3300
(800) 258-3300 (out of TN) ; • '
(800) 262-3300 (in TN) , ' • '
. Contact: Lacy Suiter or Tom Durham
TEXAS
State Commission: "
David Haun, Coordinator ;
.Texas Emergency Response Commission
Division of Emergency Management
P.O. Box 4087 .
Austin, TX 78773-0001
-(512)465r2138
Section 302, 311/312 Submissions:
Dr. William Elliot ...
Texas Department of Health
Division of Occupational Safety and Health
1100 .West 49th Street
Austin, TX 78756 . ~ .
(512)458-7410,
Section 313 Submissions:
David Barker, Supervisor
Emergency Response Unit
Texas Water Commission ' "
•.' P.O.'Box 13087-Caprtol Station
Austin, TX 78711-3087
(512) 463-8527 '- . : . ' ,
Contact: ' Priscilla Seymour
UTAH
State Commission:
Lorayne Frank, Director
Comprehensive Emergency Management
P.O. Box 58136
1,543 Sunnyside Avenu'e
Salt Lake City, UT 84158-0136
(801)584-8370 • ..' '
-------
Section 311/312 & 313 Submissions:
Neil Taybr
Utah Hazardous Chemical Emergency
Response Commission
• Utah Division of Environmental Health
288 North 1460 West
P.O. Box 16690-
, Salt Lake City, UT 84116-0690
• 80,1):-538-6121. • ; .
VERMONT
State Commission:
Jeanne VanVlandren, Chair •
Vermont Emergency Response Commission
Department of Labor and Industry
• 5 Court Drive .
Montpelier, VT 05602
(802) 828-2286
Contact: Robert McLeod (802) 828-2765
Section 311/312 & 313 Submissions:
Dr. Jan Carney, Commissioner
Department of Health
60 Main Street
P.O. Box 70
' Burlington, VT 05402
(802) 863-7281
Mail Stop""GH-S1 .
9th and Columbia Building
Olympia, WA 98504
.(206) 753-5625. • , '"-,
. \ _ ....
Contact: EJill Bennett (206)459-9191
(JBOOJ, 633-7585 (in WA)
Section 311/312 and 313 Submission:
John Ridgway,' Chair "
-Washington Slate Department of Ecology
Hazardous Substance Information Office
' MS-PV/11 | :
Olympia, WA 98504
(206)438-7252 ,
WEST VIRGINIA
. i .,''...
Carl L. Bradford, Director
West Virginia Emergency Response
Commission
West Virginia Office of Emergency Services
State Capital Eiuilding 1, Rm. EB-80
Charleston, WV 25305
(304)348-5380 .-.-'..
Emergency Rolease Number (304) 348-5380
Contact: EiillJopling
VIRGIN ISLANDS
Allan D. Smith, Commissioner
Department of Planning and Natural Resources
. U.S. Virgin Islands Emergency Response
Commission . - '
Title III '
Suite 231.
Nisky Center ' . •
Charlotte Amalie . . • ."
St.Thomas, VI00802 . - • '
(809) 774-3320 Extension 169 or 170 '
Contact: 'Gregory Rhymer
VIRGINIA
Wayne Halbleib, Director
Virginia Emergency Response Council
Department of Waste Management
James Monroe Building
• 14th'Floor ' .
101 North 14th Street
Richmond, VA 23219
(804) 225-2513
WASHINGTON
State Commlslon:
Chuck Clarke ,
. Washington Emergency Response
Commission
Department of Community Development
WISCONSIN '
State Commission:.
Richard I. Braund, Director
Wisconsin Emergency Response Commission
Division of Emergency Government
4802 Sheboygan Avenue
P.O. Box 786(5
Madison, Wl 53707
. (608)- 266-3232 ' .
Section 313 Submissions: , .
Department of Natural Resources
P.O. Box 7921
Madison, Wl 53707
. Attn: Russ Dumst ' .
(608) 266-9255 • '
WYOMING |
Ed Usui, Executive Secretary
Wyoming Emergency Response Commission
Wyoming Erne rgency Management Agency
Comprehensive Emergency Management
P.O. Box 17051
Cheyenne, WY 82003 ' '
(307) 777-7566'
Contact: Brooke Hefner
Mailing Address: •
Ed Usui- ..).-•
Wyoming Emergency Response Commission
Wyoming Emergency Management Agency
Comprehensive Emergency Management
5500 Bishop Boulevard
Cheyenne, WY 82009
-------
APPENDIX 5
Extremely Hazardous Substances
Chemical Name
•-J23C3
•••693
::=59738
••£35
.• •J-372
:3702
:"3«
; ; • 4
•"•'533
;-i:3
"52:2
i'"7
i • «^tf
;:354
."5417
-"5
:W34S
M555
.::-90
-•J530
:J3
-•5733
ACETONE CYANOHYDRIN
ACETONE THIOSEMICARBAZIDE
ACROLEIN
ACRYLAMIDE
ACRYLONITRILE
ACRYLYL CHLORIDE
ADIPONITRILE
' ALDICARB
ALDRIN
ALLYL ALCOHOL '
ALLYLAMINE
ALUMINUM PHOSPHIDE
AMINOPTERIN
AMITON
AMITON OXALATE
AMMONIA
AMPHETAMINE
ANILINE
ANILINE, 2,4,6-TRIMETHYL-
ANTIMONY PENTAFLUORIDE
ANTIMYCINA
ANTU
ARSENIC PENTOXIDE
ARSENOUS OXIDE
ARSENOUS TRICHLORIDE
ARSINE
AZINPHOS-ETHYL
AZINPHOS-METHYL
BENZAL CHLORIDE
BENZENAMINE. 3-(TRIFLUOROMETHYL)-
BENZENE. 1 -(CHLOROMETHYLH-NITRO-
BENZENEARSONIC ACID
BENZIMIDAZOLE.4.5-DICHLORO-2-
(TRIFLUOROMETHYL)-
BENZOTRICHLORIDE
BENZYL CHLORIDE
BENZYL CYANIDE
BICYGLq22.i]HEPTANE-2*
CARBONITRILE, 5-CHLORO-6-
((((METHYLAMINO)CARBONYL)OXY)IM
BIS(CHLOROMETHYL)KETONE
BITOSCANATE
BORON TRICHLORIDE
BORON TRIFLUORIDE
GASNumhflf
BROMADIOLONE
BROMINE
CADMIUM OXIDE
CADMIUM STEARATE
CALCIUM ARSENATE
CAMPHECHLOR
CANTHARIDIN
CARBACHOL CHLORIDE
CARBAMIC ACID, METHYL-. O-(((2,4-
DIMETHYL-1.3-DITHIOLAN-2-
METHYL)METHYLENE)AMINO)-
CARBOFURAN
CARBON DISULFIDE
CARBOPHENOTHION
CHLORDANE
CHLORFENVINFOS
CHLORINE
24934916
999815
79118
107073
627112
67663
542881
107302
3691358
1982474
21923239
10025737
10210681
62207765
64868
56724
5836293
95487
535897
4170303
123739
506683
506785
2636262
675149
66819
108918
17702419
8065483
919868
10311849
19287457
111444
149746
62737
141662 ,
1464535
814493
,1642542
' 71636
2238075•
20830755
115264
60515
2524030
77781
75183
99989
75785
57147 -
644644
534521 .
88857
1420071
78342
82666, '
152169 ',
298044
514738
541537
— •• — •• [[•»-," i T^| i [^
CHLORMEPHOS . . .
CHLORMEQUAT CHLORIDE
CHLOROACETIC ACID
CHLOROETHANOL
CHLOROMETHYL ETHER
CHLOROMETHYL METHYL ETHER
CHLQROPHACINONE
CHLOROXURON
CHLORTHIOPHOS
CHROMIC CHLORIDE
COBALT CARBONYL
F°BrALT. <(2.2'-(1.2-ETHANEDIYLBIS
(NITRILOMETHYLIDYNE))BIS(6-
FLUOROPHENOLATO))
COLCHICINE
COUMAPHOS
.COUMATETRALYL
CRESOL.O-
CRIMIDINE
CROTONALDEHYDE
CROTONALDEHYDE (E)-
CYANOGEN BROMIDE' •'-"' .
CYANOGEN IODIDE
CYANOPHOS
CYANURIC FLUORIDE
CYCLOHEXIMIDE
CYCLOHEXYLAMINE '. "
DECABORANE(14)
DEMETON
DEMETON-S-METHYL
DIALIFOR
DIBORANE
DICHLOROETHYL ETHER
;St§KosETHYLPHENYLSILANE
DICROTOPHOS
DIEPOXYBUTANE
DIETHYL CHLOROPHOSPHATE
DIETHYLCARBAMAZINE CITRATE
DK3ITOXIN .
DIGLYCIDYL ETHER
DIGOXIN ' .:-...
DIMEFOX
DIMETHOATE •
DIMETHYL
PHOSPHOROCHLORIDOTHIOATE
DIMETHYL SULFATE
DIMETHYL SULFIDE
DIMETHYL-p-PHENYLENEDlAMINE
DIMETHYLDICHLOROSILANE
DIMETHYLHYDRAZINE
DIMETILAN
DINITROCRESOL
DINOSEB . "
DINOTERB '
DKDXATHION
DIPHACINONE
DIPHOSPHORAMIDE, OCTAMETHYl-
DISULFOTON
DITHIAZANINE IODIDE
DITHIOBIURET
-------
CAS Number Chemical Name
316427
115297
2778.043
72208
106898
2104645
50146
379793
1622328
563122
13194484
538078
371620
75218
107153
15,1564
542905
22224926'
122145
115902
4301502
7782414
640197
. ' 144490
359068
51218
944229
50000
107164
23422539
2540821
17702577
21548323
387819T
110009
13450903
77474
4835114
302012
74908
7647010-
7664393 -
7722841
7783075
7783064
123319
13463406
297789
78820
102363
465736
55914
4098719
108236
625558
119380
78977
21609905
541253
58899
7580678
109773
EMETINE, DIHYDROCHLORIDE
ENDOSULFAN
ENDOTHION
' ENDRIN
EPICHLOROHYDRIN
EPN
ERGOCALCIFEROL -
. ERGOTAMINE TARTRATE -'
ETHANESULFONYL CHLORIDE, 2-
CHLORO-10140871 ETHANOL, 1,2-
DICHLORO-, ACETATE \
ETHION
ETHOPROPHOS
ETHYLBIS(2-CHLOROETHYL)AMINE
ETHYLENE FLUOROHYDRIN
ETHYLENE OXIDE
ETHYLENEDIAMINE
ETHYLENEIMINE
ETHYLTHIOCYANATE
FENAMIPHOS
FENITROTHION
FENSULFOTHION
FLUENETIL
FLUORINE
FLUOROACETAMIDE
FLUOROACETICACID
FLUOROACETYL CHLORIDE
FLUOROURACIL -
FONOFOS
FORMALDEHYDE
FORMALDEHYDE CYANOHYDRIN'
FORMETANATE HYDROCHLORIDE
FORMOTHION
FORMPARANATE
FOSTHIETAN
FUBERIDAZOLE
FURAN
GALLIUM TRICHLORIDE
HEXACHLOROCYCLOPENTADIENE
HEXAMETHYLENEDIAMINE, N.N'-DIBUTYL-
HYDROCYANICACD ' •«
HYDROGEN CHLORIDE (Gas Only)
HYDROGEN FLUORIDE
HYDROGEN PEROXIDE (Conc.> 52%)
HYDROGEN SELENIDE .
HYDROGEN SULFIDE
HYDROQUINONE
IRON. PENTACARBONYL-
ISOBENZAN
ISOBUTYRONITRILE
ISOCYANIC ACID. 3.4-DICHLOROPHENYL
ESTER -
ISODRN
ISOFLUORPHATE
ISOPHORONE DIISOCYANATE
SOPROPYL CHLOROFORMATE
ISOPROPYL FORMATE
ISOPROPYLMETHYLPYRAZOLYL
-DIMETHYLCARBAMATE
LACTONITRILE
LEPTOPHOS
LEWISITE
LINDANE
LITHIUM HYDRIDE
MALONONITRILE
CAS Nun-*W
12108133
5.1752 •
950107
1600277
7487947
21908532
10476956
760930
126987
920467
30674807
10265926
558258
950378
2032657
16752775
51382
80637
74839
79221
624920
60344
624839
556616
74931
3735237
676971 .
556649
78944
502396
75796
1129415
7786347
315184
50077 .
6923224
2763964
505602
' 13463393.
54115
65305
7697372
10102439
98953
1122607
10102440
62759
991424
, MANGANESE, TRIGARBONYl
j METHYLCYCLOPENTAD1ENYL
iMECHLORETHAMINE
JMEPHOSFOLAN
jMERCURIC ACETATE
[MERCURIC CHLORIDE
jMERCURIC OXIDE
[METHACROLEIN DIACETATE
;METHACRYLIC ANHYDRIDE
METHACRYLONITRILE
METHACRYLOYL CHLORIDE
630604
23135220
7871.7"
2497076 .
10028156
1910425
2074502
56382
298000
12002038
19624227
2570265
79210
594423
108952
97187
METHANESULFONYL FLUORIDE
iMETHIDATHION
METHIOCARB
METHOMYL
METHOXYETHYLMERCURIC ACETATE
METHYL 2-CHLOROACRYLATE
METHYL BROMIDE
METHYL CHLOROFORMATE
METHYL DISULFIDE
METHYL HYDRAZINE
METHYL ISOCYANATE
METHYL isoTHiocYANATE
METHYL MERCAPTAN
METHYLPHENKAPTON
METHYL PHOSPHONIC DICHLORIDE
METHYL THKDCYANATE
METHYL VINYL KETONE
METHYLMERCURIC DICYANAMIDE
METHYLTRICHLOROSILANE
METOLCARB
MEVINPHOS
MEXACARBATE
MITOMYCINC
MONOCROTOPHOS
MUSCIMOL
WIUSTARD GAS •
NICKEELCARBONYL
NICOTINE
NICOTINE SULFATE
NITRIC; ACID
NIITRIC OXIDE
NITROBENZENE .
NITROCYCLOHEXANE
NITROGEN DIOXIDE
NITROSODIMETHYLAMINE
NORBORMIDE
0 ORGANORHODlUM COMPLEX(PMN-82-
' 147)
OUABAIN
OJ^AMYL .
0)(ETANE, 3,3-BIS(CHLOROMETHYL)-
OXYDISULFOTON
OZONIE
PARAQUAT '.•-'-.
PARAQUAT METHOSULFATE
PARA7HJON
PARATHION-METHYL
PARIS GREEN
PE;NTABORANE
PENTADECYLAMINE
PERACETICACID
PERCHLOROMETHYLMERCAPTAN
PHENOL
PHENOL, 2,21-THIOBIS(4,6-DICHLORO-
-------
CAS N.^Qgr Chemical N
£4'3560
PHENOL, 2,2'-THIOBIS[4-CHLORO-6-
METHYL-
PHENOL, 3-(1-METHYLETHYL)-.
METHYLCARBAMATE
PHENOXARSINE, 10,10'-OXYDI-
PHENYL DICHLOROARSINE
PHENYLHYDRAZINE HYDROCHLORIDE
PHENYLMERCURY ACETATE
PHENYLSILATRANE
PHENYLTHIOUREA
PRORATE
PHOSACETIM
PHOSFOLAN
PHOSGENE
PHOSMET,.
PHOSPHAMiDON
PHOSPHINE
PHOSPHONOTHIOIC ACID, METHYL- O-
ETHYLO-(4-
(METHYLTHIO)PHENYL) ESTER
PHOSPHONOTHIOIC ACID. METHYL- S-(2-
(BIS(1-METHYLETHYL)AMINO)ETHYL)0-
ETHYL ESTER
PHOSPHONOTHIOIC ACID, METHYL- O-f4-
NITROPHENYL) O-PHENYL ESTER (
3254635 PHOSPHORIC ACID. DIMETHYL 4-
(METHYLTHIO) PHENYL ESTER
PHOSPHOROTHIOIC ACID.O.O-DIMETHYL-
5-(2-(METHYLTHIO)ETHYL)ESTER
PHOSPHORUS
PHOSPHORUS OXYCHLORIDE
PHOSPHORUS PENTACHLORIDE
PHOSPHORUS PENTOXIDE
PHOSPHORUS TRICHLORIDE
PHYSOSTIGMfNE
PHYSOSTIGMINE, SALICYLATE (1:1)
PICROTOXIN * '
PIPERIDINE
PIPROTAL '
-. PIR1MIFOS-ETHYL
POTASSIUM ARSENITE ' '
POTASSIUM CYANIDE
POTASSIUM SILVER CYANIDE
PROMECARB
PROPARGYL BROMIDE
PROPIOLACTONE. beta-
PROPIONITRILE
PROPIONITRILE, 3-CHLORO-
PROPIOPHENONE.4-AMINO
PROPYL CHLOROFORMATE
PROPYLENE OXIDE
PROPYLENEIMINE ,
PROTHOATE
PYRENE
PYRIDINE. 2-METHYL-5-VINYL-
PYRIDINE. 4-AMINO-
CASNurrfr* • Chemical f^?
s-sccs
53366
696286
59881
62384
2097190
103855
298022
4104147
947024
75445
732116
13171216
7803512
2703131
50782699
2565307
2587908
7723140
•0025873
1C026138
•314563
"19122
£7476
57647
•24878
"0994
.-:231130
: 35054 11
'.:: 24502
•£-.508
5! 35
1 -=245
•-"•:330
•H33251
••-•>
SALCOMINE
SARIN
SELENIOUS ACID
SELENIUM OXYCHLORIDE
SEMICARBAZIDE HYDROCHLORIDE
SILANE, (4-
AMINOBUTYL)DIETHOXYMETHYL-
SODIUM ARSENATE
SODIUM ARSENITE
- 26628228
124652
143339
62748
131522 '
13410010
- 10102188
10102202
900958
57249
60413
3689245
3569571
7446095
• 7783600
7446119
7664939
77816
13494809
7783804
107493
13071799
78002
597648
75741
509148
10031591
6533739
7791120
2757188
7446186
2231574
39196184
297972 '
108985
79196
5344821
614788
7550450
584849
91087
110576
1031476
24017478
1558254 :
'27137855
76028
115219
327980
98135
998301
75774
824113 ••
1066451
639587
555771 .
2001958
1314621
108054
81812
129066
28347139
1314847
58270089
SODIUM AZIDE (Na(N3))
SODIUM CACODYLATE
SODIUM CYANIDE (Na(CN))
SODIUM FLUOROACETATE
SODIUM SELENITE
SODIUM TELLURITE
STRYCHNINE, SULFATE
SULFOTEP
SULFOXIDE, 3-CHLOROPROPYL OCTYL
SULFUR DIOXIDE ^^ITL
SULFUR TETRAFLUORIDE
SULFUR TRIOXIDE
SULFURICACID
TABUN
TELLURIUM
TELLURIUM HEXAFLUORIDE "
TEPP
TERBUFOS
TETRAETHYL'LEAD
TETRAETHYLTIN '
TETRAMETHYL LEAD
TETRANITROMETHANE
THALLIUM SULFATE
THALL6US CARBONATE
THALLOUS CHLORIDE
THALLOUS MALONATE
THALLOUS SULFATE
THIOCARBAZIDE
THIOFANOX
THKDNAZIN
THIOPHENOL
THIOSEMICARBAZIDE
THIOUREA, (2-CHLOROPHENYL)-
THIOUREA. (2-METHYLPHENYL)-
TITANIUM TETRACHLORIDE
TOLUENE 2.4-DIISOCYANATE
TOLUENE 2,6-DIISOCYANATE
TRANS-1 ,4-DICHLOROBUTENE
TRIAMIPHOS
TRIA2OFOS
TRICHLORO(CHLOROMETHYL)SILANE
TRICHLORO.(DICHLOROPHENYL)SILANE
• TRICHLOROACETYL- CHLORIDE -
TRICHLOROETHYLSILANE
TRICHLORONATE
TRICHLOROPHENYLSILANE ,
TRIETHOXYSILANE '
TRIMETHYLCHLOROSILANE
TRIMETHYLOLPROPANE PHOSPHITE
TRIMETHYLTIN CHLORIDE
TRIPHENYLTIN CHLORIDE
TRIS(2-CHLOROETHYL)AMINE
VALINOMYCIN
VANADIUM PENTOXIDE
VINYL ACETATE MONOMER
WARFARIN
WARFARIN SODIUM
XYLYLENE DICHLORIDE .
ZINC PHOSPHIDE •
ZINC, DICHLORO(4,4-DIMETHYL- •
5((((METHYUMINO)
CARBONYi)OXY)IMINO)PENTANENITRILE)
-------
APPENDIX 6 1 ;
SECTION 313 TOXIC CHEMICAL LIST FOR REPORTING YEAR 1988
Toxics Release Inventory Chemical
; (including Chemical Categories) !
Alphabetical Chemical List
CAS Number Chemical Name
De Minimus Concentration
(percent), j ;
75-07-0 . Acetaldehyde
60-35-5 Acetamide t
67-64-1 Acetone
75-05-8 Acetonitrile
53-96-3 2-Acetylaminofluorene
107-02-8 Acrolein
79-06-1 Acrylamide
79-10-7 Acrylic acid
107-13-1 Acrylonitrile
309-00-2 Aldrin
0.1
•'-- 0.1
10
1 * W f - .
10
1 .W t - .
0.1
10
1 • W ~.
0.1 '
1 0 i
- 1 • V .
0.1 !
1.0 !
l^4;,5>8"DimetnanonaPhtnalene' ^ 2-3,4,10,1 O^hexachloro-1 4 4a
, 5,8,8a-hexahydro-(1.alpha.r4.i
107-05-1 . Allyl chloride
7429-90-5 Aluminum (fume or dust)
1344-28-1 Aluminum oxide
1 1 7-79-3 2-Amirioanthraquinone
60-09-3 4-Arriinoazobenzene
slpha 4a beta 5 aloha 8 aloha &a t
. , r1 , o.aijjiia,,oa.i
1:0 ! /
10
I »W - i , >
0.1
01 ^ "
92-67-1 4-Aminobiphenyl o!i
82-28-0 1-Amino-2-methylanthraquinone 0.1 >
7664-41-7 Ammonia 1 n !
6484-52-2 Ammonium nitrate (solution)
7783-20-2 Ammonium sulfate (solution)
62-53-3 Aniline
.90-04-0 o-Anisidine
104-94-9 p-Anisidine
•134-29-2 o-Anisidine hydrochloride
.120-12-7. . Anthracene
7440-36-0 Antimony
7440-38-2 Arsenic
1332-21-4 Asbestos (friable)
7440-39-3 Barium •
98-87-3 Benzal chloride
55-21-0 Benzamide ,
71-43-2 Benzene
92-87-5 Benzidine
98-07-7 Benzole trichloride
(Benzotrichloride)
98-88-4 Benzoyl chloride
94-36-0 Benzoyl peroxide
100-44-r? Benzyl chloride
7440-41-7 Beryllium
92-52-4 Biphenyl
i!o
1.0 ' !
10
1 ,\J t • - .
01 l
W.I '
o!i V
10 " '•
0'1 . " • I--"- .. , :"
01 - !
W.I
10-"--'
.'•w. • i" .,-
1.0 ;
1 0- ; •
1 • W I • -
01 '
»•!.-, ]. ,
01 . ! ,
.W.I. ' -j. ; -
0.1 ;
** • > - i
1.0
1.0
01
10 i
111-44-4 Bis(2-chloroethyl) ether ' i 6
542-88-1 Bis(chloromethyl), ether ,01 ! . '
lSf«2"1 : Bis(2-chloro-1-methylethyl) ethen.O j
103-23-1 Bis(2-ethylhexyl) adipate 0.1
75-25-2 • Bromoform -J.Q ,
-------
74-83-9
106-99-0
141-32-2
71-36-3
78-92-2
75-65-0
85-68-7
106-88-7
123-72-8
4680-78-8
569-64-2
989-38-8
1937-37-7
2602-46-2
16071-86-6
2832-40-8
3761-53-3
81-88-9
3118-97-6
97-56-3
842-07-9
492-80-8
128-66-5
7440-43-9
156-62-7
133-06-2
63-25-2
75-15-0
56-23-5
463-58-1
120-80-9
133-90-4
1 57-74-9
7782-50-5
10049-04-4
79-11-8
532-27-4
108-90-7
510-15-6
75-00-3
67-66-3
74-87-3
107-30-2
126-99-8
1897-45-6
7440-47-3
{Tribromomethane}
Bromomethane
{Methyl bromide}
1,3-Butadiene
Butyl acrylate
n-Butyl alcohol
sec-Butyl alcohol
tert-Butyl alcohol ,
Butyl benzyl phthalate
1,2-Butylene oxide
Butyraldehyde
C.I. Acid Green 3*
C.I. Baste Green 4*
C.I. Basic Red 1*
C.I. Direct Black 38*
C.I. Direct Blue 6*
C.I. Direct Brown 95*
C.I. Disperse Yellow 3*
C.I. Food Red 5*
C.I. Food Red 15*
C.I. Solvent Orange 7*
C.I. Solvent Yellow 3*
C.I. Solvent Yellow 14*
C.I. Solvent Yellow 34*
Auramine)
C.I. Vat Yellow 4*
Cadmium
Calcium cyanamide .
Captan
1.0
0.1
0.1
0.1
1.0
0.1
0.1
1.0
0.1
1.0
0.1
1.0
.0
{1 H-lsoindole-1,3(2H)-dione, 3a,4,7,7a-tetrahydro-2r[(trichloromethyl)thio]-}
Carbaryl , 1-0
{1-Naphthalene!, methylcarbamate} • • , , ,
Carbon disulfide 1.0
Carbon tetrachloride 0.1
Carbonyl sulfide 1.0
Catechol 1-0 - •
Chloramben 1-0
{Benzoic acid, 3-amino-2,5-dichloro-} .
Chlordane 1.0 ..... »• '
{4,7-Methanoindan, 1,2,4,5,6,7, 8,8-octachloro-2,3,3a,4,7;7a-hexahydro-}
Chlorine 1-0 "
Chlorine dioxide . 1,0 .
Chloroacetto acid 1.0
2-Chloroacetophenone • -. 1.0
Chlorobenzene 1.0
• Chlorobenzilate 1.0 .
•{Benzeneaceticacid,4-chloro-,alpha.-(4-chlorophenyl)-alpha.-hydroxy-,ethyl
ester}
Chloroethane - - 1.0
{Ethyl chloride} . :
Chloroform . 0.1 - ;
Chtoromethane 1..0 -
{Methyl chloride} "
Chtoromethyl methyl ether 0.1 . .
Chloroprenfi ' 1.0
Chlorothalonil 1.0 '
{1,3-Benzenedicarbonitrile; 2,4,5,6-tetrachloro-}
Chromium • 0.1
-------
7440-48-4
7440-50-8
120-71-8
1319-77-3
,108-39-4 .
95-48-7
106-44-5
98-82-8
80-15-9
•135-20-6
110-82-7
94-75-7
1163-19-5
2303-16-4
615-05-4
39156-4
101-80-4
25376-45-8
95-80-7
334-88-3
132-64-9 -•'•
96-12-8
106-93-4
84-74-<2
25321-22-6
95-50-1
541-73-1
106-46-7
91-94-1
75-27-4
107-06-2 "
540-59-0
75-09-2
120-83-2
78-87-5
542-75-6
62-73-7
115-32-2
1464-53-5
111-42-2
•117-81-7,
84-66-2
64-67-5
119-90-4
60-11-7
119-93-7
79-44-7
dichloro-2-propenyl) ester)
Cobalt 1.0
Copper 1.0
p-Cresidine O.T
Cresol (mixed isomers) 1.0
m-Cresol 1.0
o-Cresol 1.0
p-Cresol, 1.0
Cumene ' 1.0
Cumene hydroperoxide 1.0
Cupferron .0.1
{Benzeneamine, N-hydroxy-N-nitroso, ammonium salt}
Cyclohexane 1.0
2,4-D 1.0
{Acetic acid, (2,4-dichlorophenoxy)-}
Decabromodipnenyl oxide i.p
Diallate ' 1.6 .
{Carbamothioic acid, bis(l-methylethyl)-, S-(2,3-
2,4-biaminoanisole -. 0.1
'1-7 2,4-Diaminoanisole sulfate 0.1
4,4'-Diaminodiphenyl ether 0.1
Diaminotoluene (mixed isomers) 0.1
2,4-Diaminotoluene 0.1
Diazomethane 1.0
Dibenzofuran 1.0
1,2-Dibromo-3-chloropropane. 0.1
• {DBCP}
1,2-Dibromoethaine. 0.1
{Ethylene dibromide)
Dibutyl.phthalate 1.0
Dichlorobenzene (mixed isomers)0.1
1,2-Dichlorobenzene 1.0
1,3-Dichlorobenzene „ 1.0
1,4-Dichlorobenzene 0.1
S.S'-Dichlorobenzidine 0.1
pichlorobromomethane 1.0
1,2-Dichloroethane , 0.1
{Ethylene dichloride} ' •
1,2-Dichloroethylene 1.0
Dichloromethane 0.1
{Methylene chloride}"
2,4-DichlorophenoI 1.0
1,2-Dichloropropane 1.0
1,3-Dichloropropylene 0.1
Dichlorvos .1.0
{Phosphoric acid, 2,2-dichloroethenyl dimethyl ester}
Dicofol .1.0
{Benzenemethanol, 4-chloro-alpha.-(4-ch!orophenyl)-alpha.-(trichloromethyl)-}
Diepoxybutane 0.1
Diethanolamine 1.0
Di-(2-ethylhexyl) phthalate 0.1
{DEHP}
Diethyl phthalate 1.0
Diethyl sulfate 0.1
3,3^Dimethoxybehzidine 0.1
4-Dimethylaminoazobenzene 0.1
3,3'-Dimethylbenzidine 0.1
{o-Tolidine}
Dimethylcarbamyl chloride 0.1
-------
57-14-7
105-67-9
131-11-3
77-78-1
534-52.-1
51-28-5
121-14-2
606-20-2
117-84-0
123-91-1
122-66-7
106-89-8
110-80-5
140-88-5
100-41-4
541-41-3
74-85-1
107-21-1
151-56-4
75-21-8
96-45-7
2164-17-2
50-00-0
76-13-1
76-44-8
118-74-1
87-68-3
77-47-4
67-72-1
1335-87-1
680-31-9
302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
78-84-2
67-63-0
80-05-7
7439-92-1
58-89-9
108-31-6
12427-38-2
7439-96-5
7439-97-6
67-56-1
72-43-5
1,1-Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-creso!
2,4-Dinitrophenol
2,4-Dipitrotoluene
2,6-Dinitrotoluene
ri-Dioctyl phthalate
1,4-Dioxane
1,2-Diphenylhydrazine
{Hydrazobenzene}
Epichlorohydrin
2-Ethoxyethanol
Ethyl acrylate
Ethylbenzene
Ethyl chloroformate
Ethylene
Ethylene glycol
Ethyleneimine
{Aziridine}
Ethylene oxide
Ethylene thiou'rea
Fluometuron
0.1
1.0
1.0
0.1
0.1
1.0
0.1
.0
.0
.0
.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
{Urea, N,N-dimethyl-N'-[3-(trifluoromethyl)phenyl]-}
Formaldehyde 0.1 '
Freon 113 -1.0
{Ethane, 1,1,2-trichloro-1,2,2-trifluoro-}
Heptachlor- • . .1.0
{l.^ey.S.S-Heptachloro-Sa^JJa-tetrahydro^J-methano-IH-indene}
Hexachlorobenzene ft *
. Hexachloro-1,3-butadiene
Hexachlorocyclopentadiehe
Hexachloroethane
Hexachloronaphthalene
Hexamethylphosphoramide
Hydrazine-
Hydrazine sulfate
Hydrochloric acid
Hydrogen cyanide'
Hydrogen .fluoride
Hydroquinone
Isobutyraldehyde °
Isopropyl alcohol . ... .
(manufacturing-sti'dng acid process, no supplier notification)
4,4'-lsopropylidenediphenol 1.0 -
Lead 0.1
Lindane . - 0.1
{Cyclohexane, 1,2,3,4,5,6-hexachlpro-,(1 .alpha.;2.alpr)a, Slbeta 4 alpha
o.alpha., e.beta.)-}
Maleic anhydride 1.0
Maneb , ' . 1.0
{Carbamodithioic acid, 1,2-ethanediylbis-, manganese complex}
Manganese- - 1.0
Mercury 1.0
Methanol 1.0 .
Methoxychlor 1.0
{Benzene, 1,1'-(2,2,2-trichloroethylidene)bis-4-methoxy-}
1.0
1.0
0.1
-------
109-86-4
96-33-3
1634-04-4
101-14-4
\ 101-61-1
101-68-8
74-95-3
101-77-9
78-93-3
60-34-4
74-88-4
108-10-1
624-83-9
80-62-6
90-94-8
1313-27-5
505-60-2 '
91-20-3
134-32-7
91-59-8
7440-02-0
7697-37-2
139-13-9
99-59-2
98-95-3
92-93-3
1836-75-5
51r-75-2
55-63-0
88-75-5
100-02-7
79-46-9
156-10-5
121-69-7
. 924-16-3
55-18-5
62-75-9
86-30-6
621-64-7
4549-40-0
59-89-2
759-73-9
684-93-5
16543-55-8
100-75-4
2234-13-1
20816-12-0
56-38-2
87-86-5
79-21-0
1.0
0.1
1.0
1.0
1.0
1.0
O.'l
1.0
2-Methoxyethanol 1 o
Methyl acrylate • 1 'o
Methyl tert-butyl ether 1.0
4,4'-Methylenebis(2-chloroaniline) 0 1
{MBOCA} ;
4,4'-Methylenebis(N,N-dimethyl) 0.1
benzenamine
Methylenebis (phenylisocyanate) 1.0
{MBI}
Methylerie bromide
4,4'-Methylenedianiline
Methyl ethyl ketone
Methyl hydrazine
Methyl iodide
Methyl isobutyl ketone
Methyl isocyanate
Methyl methacrylate
Michler's ketone
Molybdenum trioxide
Mustard gas •
{Ethane, 1,1'-thiobis[2-chloro-}
Naphthalene
alpha-Naphthylamine
beta-Naphthylamine
, Nickel
Nitric acid
Nitrilotriacetic acid
5-Nitro-o-anisidine
Nitrobenzene
4-Nitrobiphenyl
Nitrofen ,
{Benzene, 2,4-dichloro-1-(4-nitroprienoxvM
Nitrogen mustard 01
{2-Chloro-N-(2-chloroethyl)-N-methylethanaminB}
Nitrpglycerin . -'.» • '
2-Nitrbphenol
4-Nitrophenol
2-Nitropropane
p-Nitrosodiphenylamine
N,N-Dimethylaniline
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosodi-n-propylamine
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
• N-Nitroso-N-ethylurea
N-Nitroso-N-methylurea
N-Nitrosonornicotine
. N-Nitrosopiperidine
Octachloronaphthalene
Osmium tetroxide
Parathion - ,.„
{Phosphorothioic acid, o, o-diethyl-o-(4-ni
Pentachlorophenol 10
{PCP}
Peracetic acid 1.0
1.0
0.1
0.1
1.0
0.1
0.1
,1.Q
1.0
0.1
0.1
1.0
o 1
10
0.1
0.1
0.1
0.1
0.1
1.0
trophenyl) oster}
-------
108-95-2 Phenol 1.0
106-50-3 p-Phenylenediamine 1.0
90-43-7 2-Phenylphenol 1.0 ' .' •
75-44-5 Phosgene . -. 1.0
7664-38-2 Phosphoric acid 1.0
7723-14-0 Phosphorus (yellow or white) 1.0 -
85-44-9 Phthalic anhydride 1.0
88-89-1 Picric acid ,1.0
1336-36-3 ' Polychlorinated biphenyls 0.1
{PCBs}
1120-71-4 Propane sultone ;. 0.1
57-57-8 beta-Propiolactone 0.1 ,
123-38-6 Propionaldehyde 1.0
114-26-1 Propoxur - 1.0
{Phenol, 2-(1-methylethoxy)-, methylcarbamate}
115-07-1 Propylene -1.0
{Propene} * ,
75-55-8, Propyleneimine O.f
75-56-9 Propylene oxide 0.1
110-86-1 Pyridine 1.0 '
91-22-5 Quinoline 1.0 '
106-51-4 QUinone 1.0 . '.
82-68-8 Quintozene
{Pentachloronitrobenzene} 1.0
81-07-2 Saccharin (manufacturing, no supplier notification) 0,1
{1,2-Benzisothiazol-3(2H)-one, 1,1-dioxide}
94-59-7 Safrole 0.1
7782-49-2 Selenium 1.0
7440-22-4 Silver 1.0
1310-73-2 Sodium hydroxide (solution) 1.0
7757-82-6 Sodium sulfate (solution) 1.0
100-42-5 Styrene 0.1
96-09-3 Styrene oxide 0.1
7664-93-9 Sulfuricacid 1.0 '
100-21-0 . Terephthalic acid 1.0
79-34-5 1,1,2,2-Tetrachh-oethane 0.1
127-18-4. Tetrachlorbethylene 0.1 -..'.' .
{Perchloroethylene} ....
961-11-5 . Tetrachlorvinphos • § •. 1.0
{Phosphoric acid, 2-chloro-1- (2,3,5-tricrilorophenyl) ethenyl dimethyl ester}
7440-28-0 Thallium - 1.0 ' ;
62-55-5 Thioacetamide 0.1 -
139-65-1 4,4'-Thiodianiline ,'-."• 0.1 .
62-56-6 Thiourea 0.1 .
1314-20-1 Thorium dioxide 1.0 ' '
7550-45-0 Titanium tetrachloride 1.0 -
108-88-3 Toluene 1.0
584-84-9 Toluene-2,4-diisocyanate 0.1
91-08-7 Toluene-2,6-diisocyanate 0.1
95-53-4 o-Toluidine . , 0.1
636-21-5 . o-Toluidine hydrochloride 0.1
8001-35-2 Toxaphene ... 0.1
68-76-8 Triaziquone '0.1
{2,5-Cyclohexadiene-l ,4-dione, 2,3,5-tris(1-aziridinyl)-}
52-68-6 Trichlorfon .1.0 '
{Phosphonic acidl(2,2,2-trichloro-1 -hydroxyethyl)-,dimethyl ester}
120-82-1 1,2.4-Trichlorobenzehe 1.0
71-55-6 1,1,1-Trichloroethane ' 1.0
-------
79-00-5
79-01-6
95-95-4 .
88-06-2
1582-09-8
.95-63-6
126-72-7
51-79-6
7440-62-2
108-05-4
593-60-2
75-01-4
75-35-4
1330-20-7
108-38-3
95-47-6 -
106-42-3
87-62-7
7440-66-6
-12122-67-7
(Methyl chloroform)
1,1,2-Trichiorbethane < 10
Trichloroethylene i'o
2,4,5-Trichlorophenol 1.0
2,4,6-Trichlprbphenol o.1
Trifluralin 1.0
iB|"z|n.amine-2,6-dinitro-N,N-dipropyl-4-(trifluoromethy|.)-}
1,2,4-Tnmethylbenzene 1.0
Tris(2,3-dibromopropyl phosphate) 0 1
Urethane n 1 '
(Ethyl carbamate)
Vanadium (fume or dust) 1 o
Vinyl acetate 1 'rj
Vinyl brtomide 0.1
Vinyl chloride 01
Vinylidene chloride i'o
Xylene (mixed isomers) 1.0
m-Xylene -J.Q
o-Xylene -J'Q
p-Xylene "l'o
2,6-Xylidine L'Q
, Zinc (fume or dust)
Zineb
1.0
1.0
*-n icw , , . I .U
{Carbamodithioic acid, 1,2-ethanediylbis-, zinc complex}
-------
Reporting thresholds: •'.'.'
50!000p0inds for manufactured or processed substancesjJO.OOO pounds for
1 25'°00 P°indS f°r manufactured °r Processed substances; 10,000 pounds for
SECTION 313 CHEMICAL CATEGORIES
'
the namd
the
Antimony Compounds
Arsenic Compounds "
Barium Compounds
Beryllium Compounds
Cadmium Compounds -
Chromium Compounds -.--.-
Cobalt Compounds
Copper Compounds .
Lead Compounds ,
Manganese Compounds .
Mercury Compounds
Nickel Compounds '
Selenium Compounds >
Silver Compounds
Thallium Compounds
Zinc Compounds
Categories of chemicals- with special conditions: see EPA guidance
Cnlorophenols '
Cyanide Compounds
Glyeol Ether
Polybrominated Biphenyls . . ,
U.S. GOVERNMENT PRINTING OFFICE: 1990- 7 27 - 8 9 0
' 0
-------
INTRODUCTION
When confronted with
levels
.BB.
ss MH-^5'
s raise important
tion efforts. The re *
serious risk.
^•srs^
responses. p agency officials avoid similar
cncy^ ftates Environ
Evaluation, is to review the eJ5«r£. 2 1Cyf Plannmg/ and
communicate with the three lommun^Ls tl^S^ ?ffici^^ to
METHODOLOGY
approach, it looks retrospectively at ?h^h^ e Stl?d5r
failures, case studies SSL.? "s*.commu?i<=»ta.on successes and
t?^v^ea^1oW£~
identify precise
-------
likely to happen. They can, however, offer hVpotheses that may
then be the subject of more rigorous quantitative research.
The discussion ,of Clinton and Boyertown distills the
observations, judgments, and recommendations of those we inter-
viewed in Boyertown and Clinton, including federal, state, and
local officials; contractors; reporters? realtors; and citizen
leaders. (For a list of interviewees, see Appendix A.)
For the most part, the methodology for the case study 'of '
these two towns was the same. In Clinton, however, there was no
defined citizens group, and the owner of the "discovery" house
was never identified. Moreover, few citizens were mentioned by
name in the media, and local officials declined to reveal the
names of townspeople in order to protect confidentiality. We
felt that interviewing a non-representative sample of citizens
(for example, the one or two who revealed their names to the
press) would be more misleading than useful. Therefore, citizens
were not interviewed in Clinton.
A separate section of this report analyzes the events
surrounding the radon communication at Vernon, NJ in light of the
recommendations drawn from the study of Clinton and Boyertown.
We employed for this analysis a case study prepared by the
Eagleton Institute of Politics and the political science depart-
ment at Rutgers University.1 We chose to use this case study as
opposed to conducting our own research in Vernon because we felt
the case study adequately covered the incidents at Vernon.and we
did not want to "reinvent the wheel," disturbing participants
with another set of interviews. In addition, bur thrust was
applying the positive lessons learned in the other towns to a
situation like Vernon1s, and we felt that dwelling on the
specifics of the case would be less useful. ,
While attempting to be useful to agency practitioners, this
report is not derived from quantitative analysis and may not be
entirely free of bias. We sought to reduce bias during the
research for Clinton and Boyertown by using an identical inter-
view protocol for the individuals in each group of participants
(i.e., realtors, citizens, government officials, and contractors)
and by interviewing similar participants in each community. The
entire report was reviewed extensively by participants, academic
experts, and practitioners in state agencies and EPA. In the
case of Vernon, there may have been existing biases in the
original report that affected our analysis of it. .
-------
BOYERTOWN, PENNSYLVANIA
SUMMARY OF EVENTS
Boyertown ,
CLINTONf NEW JERSEY
131984
entered Philadelphia SLctriS c£!n f radiati°n detectors as
generating station,Pwh2re he worked KnrS (PECO) Lime^ck
engmeer. After sampling (in ^soonX ? SSn+1Or const^ction .
detected more than 2,ooo pCi/l of*?!*™ ?" ?£"!!•• re<^est)
Electric contacted officials at thJ P^nnin the.home' Philadelphia
Environmental Resources (PADER7 whoPennsy-Lvania Department of
December 26. PADER's ,?eadiSgs conf?™^!-, ^ Watras' ho*e °n
and on January 5, 1985 PADEP o^5? • f" ? PhHadelphia Electric' s
from the Secretary Nicholas DeH^1^ hancl-d«livered a letter
family ••vacate" Seir homS? DeBenedlct^ that recommended• thl ,\
testing to residents 'o* «£"£!» °S
-------
the homes in Clinton Knolls. >
/
NJDEP and the New Jersey Department of Health (NJDOH)
conducted a public meeting with Clinton residents and held a
number of "by invitation only" meetings to update homebwners of
Clinton Knolls while protecting confidentiality." in addition,
NJDEP staffed a part-time office in the municipal building. In
May EPA selected ten homes for remediation as part of a demon-
stration project and committed to providing diagnostic work-ups
for 20 more. By November environmental officials announced that
homes in the demonstration project had been remediated success-
fully to levels within the federal guidelines.
PUBLIC REACTION
Clinton
Gauging public reaction several years after an event is
problematic, at best. .The impressions of those involved become
more susceptible to distortion as time passes. However, the
observations of those we interviewed in Clinton are remarkably
similar, suggesting a fair degree of consensus about their.
perception of public reaction in this small town of 1,900 resi-
dents. Clinton, which is located in a relatively rural section
of Hunterdon County, includes a growing population of business
and professional people, particularly in the Clinton Knolls
section, a development with a population of about 500.
The discovery of high levels of radon in Clinton Knolls was
met with concern. Gerald Nicholls of NJDEP characterized public
response as "initially strong, fearful" based on the concern
shown at the first public meeting that attracted more than 300
people. He noted, however, that although people were deeply
concerned, no one "got overly emotional." In the words of Judy
Klotz of New Jersey Department of Health (NJDOH), "People were
sober, but not hysterical; they were willing to listen."
Terry Brennan of Camroden Associates, who worked in the
houses that were part of EPA's research project, noted that "The
people in Clinton didn't respond the way almost everyone else has
responded. It was a group of pretty different people getting
together in a difficult situation and working together." Brennan
also noted that he found more concerns from people about their
health than he usually encounters, due, he suspects, to the
extremely high radon levels found in Clinton Knolls.
Clinton real estate agents reported different impressions
about the initial reaction ranging from fear to apathy but
observed a more tempered response after a relatively short time.
Mickey Greco of Schlott Realtors said that clients" initial
reaction ("I don't want to know about it.... I'm going to hope
-------
nobody asks") changed as more houses were discovered with high
levels. According to Pat Catanzareti of.Wei-chert Realtors, the
early response was like "doomsday...shut our houses down and move
out of town," but as people learned more about remediation, it
"eased the fear that this was a\ perpetual situation." Both agree
that sales slowed down during that period—ialthough Greco notes
that the regional housing market had flattened during that time-
but that prices never really went down and the market has
rebounded completely. . ! ••-.""'!'• -:. '
While most, of those interviewed talked of the high level of
concern> Jim Drautman, a reporter for the Hunterdon Review.
suggests that the response may have been "too relaxed," that
people were hot as concerned as the data suggested they should
have been. Both Drautman and the other observers may be correct.
While those in Clinton Knolls showed a highjlevel of concern,
many interviewed acknowledged that the concern was 1-ess wide-
spread in the rest of Clinton and the surrounding area. John
Beckley, director of the Hunterdon County Health Department, also
noted that after an initial surge of concern, interest in the
issue clearly tapered off. However, he*noted that "One of the
positive effects of Clinton [is that] the Hxinterdon [County]
community has a better grasp of radon, its problems, and solu-
tions." . j" • •_
Although other research suggests that people often' respond
to radon risk with apathy, failing to mitigate even when con-
fronted with high readings, this does not seem to be the case in
Clinton Knolls.2 According to Nicholls,'all homeowners with
greater than 20pCi/l have mitigated. A mail survey conducted by
NJDEP's Mary Cahill in December 1986 elicited returns from 41 of
the 105 homeowners in Clinton Knolls for whom DEP had test
results. Of those respondents 23 had remediated and another 12
planned to remediate. (Five of the homeowners in houses EPA
remediated did not respond to the survey, suggesting that failure
to mitigate was not the sole reason homeowners did not respond to
the survey.)
Bpyertown , |
' ' . . . ' i , '•''.'' . ' '
Reaction in Colebrookdale Township is more difficult to
characterize. Traditionally/ the area was composed largely of
Pennsylvania Dutch families that have livedjthere for.genera-
tions. But the rapidly developing community has become increas-
ingly desirable to business people working in the Philadelphia
metropolitan area, because new highways makes the commute easier.
Jones of People Against Radon says that reaction to the radon
problem for the most part was split between | the response of "the
natives and the transplants,"with the "transplants" being more
concerned than the "natives."
Public meetings in Colebrookdale attracted hundreds of
-------
people and had an atmosphere that Margot Huntf, then working for
PADER, compared to the tension of a Superfund meeting. Bruce
Dallas, then of PADER, also characterized the response as
"potentially extremely disruptive." While PADER officials noted
the easing of tension at the first public meeting, citizens Jones
and Watras and Tell Tappan of Arix Sciences, Inc; suggested that
there was a fair amount of disbelief and mistrust. Watras
relates walking out of the public meeting and "hear[ing] the
general public say, 'These people aren't telling us the whole
truth.... They're holding" something back...."1
The "skepticism and hostility" also noted by Jonathan
Smoyer, the local emergency coordinator, may have been due, in
part, to the nature of the community. As Richard Rehrer of
Rehrer and Zuber Realty put it, "Most people living in the area
had no recollection of anyone ever dying of radon...." As with
Clinton, although real estate sales leveled off for a period of
time, since then "demand has far outstripped supply," according
to David Specht of Specht Realty, Inc. In fact, several of those
interviewed in Boyertown felt that residents were relatively
unconcerned about radon. LuAnn Reichert, Colebrookdale Township
Manager suggested that despite being initially upset, "Now
there's not nearly as much concern as there was initially. ,
People have in their head that it's been here for many years and
it's always going to be here...." ,
Because Colebrookdale Township marked the first discovery of
such high levels of naturally occurring radon, the uncertainties
that faced both the agency officials and Boyertown residents were
huge. As PADER's Thomas Gerusky .put it, the agency was initially
"out on a limb" without much guidance from federal agencies.
Although those interviewed, including real estate agents,
reporters, and local officials, praised the government's efforts,
some of the affected residents became sufficiently frustrated
with what they perceived as the state's inadequate handling of
remediation that they formed People Against Radon (originally
known as Pennsylvanians Against Radon). Some view People Against
Radon as a constructive force in the community, while others feel
it is neither particularly credible nor representative of the
community. Jones of People Against Radon claims that there are
still homes in the neighborhood with measurements ofover 200
pCi/1 that have not been remediated, but; Margaret Reilly of PADER
feels confident that homeowners with such high levels have
mitigated.
In sum, the public reaction to the discovery of radon seems
to have included apathy and concern in both Clinton and Boyer-
town, but the responses appear to be more extreme—and marked by
greater suspicion towards, the government—in Boyertown than in
Clinton. Although retrospective case studies cannot easily
define the extent to which specific variables influenced public
reaction, it is possible to suggest reasons for the differences.
-------
was
the opinion of Alfred ' »aic" w *™ ?S redu?ea ««
less likely to develop a ci>tizeii^«!?«r^S:Lden!ts w°uld have been
individual homes because^ by'thS S2P«! $*ih'tov rejnediation of
v_4..L. _ "*• <»**v»*i as »»a tras ". Tna,
quite dea abu wha should L^SSS"^' -^ theY were often
Communicating about risks is often situational. Therefore,
-------
these recommendations do not'deal with setting priorities or
developing compromises that are often important when government
officials deal with complex issues. Instead, the goal of these
guidelines is to provide a framework on which communication about
radon risk can be constructed, not to give explicit directions
for each situation. ;
A. Setting the Context
The effectiveness of a message depends not only on what is
said but also on the context in which it is transmitted, that is,
the actions and attitudes which accompany information that make
it more meaningful to people. The extent to which the message is
believable (and believed) can be tied closely to trust and
credibility, which may be linked to the recommendations below:
Al. Take both the environmental hazard and community concerns
seriously. Officials of both states reacted quickly, and soon
radon became the subject of high-level attention in the agencies
of both states. Money was "found" to provide testing, rules were
"broken" to cut through red tape,-staff were temporarily trans-
ferred to deal with radon, and high-ranking personnel started
routinely putting in 18-hour days.
Although what agencies said was important, they were judged
in large measure by what they dj^. In,both plinton and Boyertown
those interviewed stressed the importance of moving quickly once
the problem had been determined as serious. Just as important as
acting competently, was their being visibly competent and
committed. Both states held public meetings, had a staff out in
the field doing .testing, and established local offices.
As Judy Klotz of the New.Jersey Department of Health put it,
"The public saw a large number of high management, a very large
effort, a very intense participation and investment and immediate
turn around. Just in terms of what was visible, before anyone
opened their mouths, this was clearly seen as a big operation."
Craig also noted how important it was that "we instilled a
feeling of confidence that we knew what we were doing." For
example, the EPA research team and contractors examined 56 houses
in 5 days. According to Craig,, homeowners where "amazed" when
within,several days, they reported what they found to homeowners
in one of the many homeowners' meetings conducted by state
officials. Homeowners' surprise at such swift action may have
reflected their expectations that government wouldn't move that
quickly. ,
However, government officials not*only took the need to
reduce radon risk seriously, they took the homeowner concerns— ,
even those not directly related to health—very seriously. Both
Pennsylvania and New Jersey officials discussed concerns related
to property values at length internally, at public meetings, and
8 . • •'. • .
-------
with homeowners on a one-to-one basis TK!*™ ±-i
' -
A2. Release information earlier rather thaln later Tn H««.W'
°n °f j}efdin9 to release information but having a greaJ
^t0 "»' ThU!b' SOme SJ-rvS?^
information as early as they did.
'.. Several of the realtors interviewed wowld have preferred for
officials in both states to withhold information until thJ5 had
message is not confusing. (see guideline 82;
A3. While reassuring some members of the commTonitv also
ISec??n?lert ^ °5herS- Gove^ent offlcSTS fetS Boyertown
Sli?i K °" were understandably very concerned about how to tell
he oflen f elt'th^1^0^ ?f nickin^ them. As Nulman e^plainJd^
ne often felt the tug to tell people "this is nothing to get
-------
panic]cy about" but at the same time he didn't^ want to "make the
problem less than it is." It is a natural tendency in explaining
a serious risk such as radon to want to "backpedal," according to
Tappan.
' To make sure that homeowners took action, Nulman was widely
quoted as saying, "If people don't get their houses checked, they
should get their heads checked.n Pennsylvania and New Jersey
both offered free testing in the area surrounding the discovery
house (which Pennsylvania later expanded to cover the entire
'Reading Prong). However, some of those interviewed admit that
for understandable reasons they paid-more attention to reassuring
people with "hot houses" than to making sure other homeowners
tested. In Clinton, says Drautman, who is a physicist as well as
a reporter, "I think all of us played ."it's a fixable problem1 ,
too hard. What we're saying now and what DEP is saying now, that
everybody in this county ought to test, I think we probably
should have been saying from the start." In Boyertown, efforts
to reassure might have been confusing. For example, PADER's
initial press release states radon "...is not a danger to the
general population..." and a statement by an agency spokesperson
in the Boyertown Area Times suggests that radon was "not a public
health problem." Both statements were easily susceptible to
misinterpretation.
To strike' the appropriate balance between reassuring people
and alerting them, government officials must be clear about their
communication goals. Goals may evolve throughout the process of
interacting with community; however, the greater the initial
clarity, the more likely the goals will be met. "Damage con-
trol"—communicating without planning or planning with the
primary goal of keeping the phones quiet—is not sufficient,
particularly when people are apt to respond complacently. The
experiences in Boyertown and Clinton suggest that agencies should
make explicit the communication goal of alerting people to radon
risk and then develop a communication strategy to meet that goal.
(See Guideline Cl for more on goals and planning.)
A4. Develop a teaa effort among government officials. There was
near unanimity in €hose interviewed in Clinton that Mayor
Nulman's taking a leadership role in Clinton lent great credib-
ility to the efforts of state and federal officials. While
Deieso considers Nulman a "statesman," unique in his willingness
to exert leadership rather than to assign blame, Nulman suggests
that DEP also influenced his willingness to cooperate by main-
taining daily contact, giving him home phone numbers, briefing
him before the press and in general being "very careful, con-
siderate, truthful." ."••..';..
Perhaps just as important, state officials showed eagerness
to develop a partnership with the mayor, despite the obvious
disparity in technical expertise. In fact, a type of parity was
10 ..,'•••
-------
established between Nulman's understanding of* community concerns
and the state's: technical expertise, so that ; decisions were made
cpllaboratively. Nulman suggests that one of the keys tS lucSels
in Clinton was "great commitment to, solving the prbblem ralher
than anyone winning, so when there was a pj oblem. . .people went
inside the team, rather than turning it into a win-lSse situa-
tion." Beckley also- noted that NJDEP alerting him prior to the
jedia announcement and involving him in the process^ Jrly on "was'
r***?^1?* °5 *«•* ••>**** from the beginning the DEP made I*
a priority to advise us every step of the way." T--
ooi v ?Unt also.sPent considerable time talking with the
Colebrookdale Township board of commissioners -prior to alertina
the media— and continued to alert them prioir to any public
announcements--there was not the same participation by local
officials. This may be due, in part, to the board of commis-
sioners generally playing less of a central! leadership role in
IS? r° kdalj^han NUlman did in Clinton. Hunt also suggests
that local officials may also have been reluctant to takfe a lead
role on such a politically sensitive issue.: Finally/township
officials smoyer and Reichert received the impress ioA that thS
problem^ was^ too serious and technical for them to play a sig-
nificant rola-. This suggests that agency officials might need to
emphasize the potentially valuable role local official! can play°
„,. 4.1? b°J? Pennsylvania and New Jersey the agencies went to
great lengths to coordinate state efforts with high level task
forces. They also spent considerable energy enlisting coopera-
tion from federal agencies. This may have been easier in New
Jersey's case because radon was a recognized problem, and a
certain amount of cooperation already existed among state and
federal agencies on the issue. Perhaps just as important *
because of Boyertown, EPA had policies and procedures in place.
AS. Allow for two-way communication with tlae community. Both
Pennsylvania and New Jersey officials made concerted efforts to
develop a dialogue with the community, thus by most accounts
helping to reduce tension. Community meetings were marked by
lengthy guest ion and answer sessions, and all government offi-
«™onS?fnt hours.on F16 Phone listening to j people's concerns and
personally conveying test results. In Clinton, continuing
questions about health risks led to a session for homeowners on
health risks. In fact, the Saturday meetings held fairly
regularly for homeowners in Clinton at .times were reported to be
closer to an informal discussion than a government-sponsored
meeting. ;
Informal communication and networks may have been almost as
important as public meetings and briefings. \ Brennan tells the
story of a homeowner who was not included in the EPA research
project and felt particularly angry because he thought he had the
highest radon level. Brennan not only corrected the mispercep-
11
-------
tion but made it a point to stop by and meet With the homeowner
and the contractor. Both Watras and Jones p^int out the impor-
tance of the private, off-the-record conversations they had with
government officials.
'However, Watras suggests that PADER's message in public
meetings was more general and technical, rather than specific to
people's concerns. Nulman also suggests that NJDOH's discussions
with him were easier to follow than their formal presentations.
Although it's obviously easier to talk to individuals than to: go
on-the-record in public meetings, officials may want rto strive to
develop a similar sense of openness and willingness to respond to
concerns. -'••'.;.
A6. Protect confidentiality of individuals while encouraging
homeowners to talk with each other. The principle in both
Pennsylvania and New Jersey of safeguarding the^confidentiality
of test results is now accepted practice. Officials went to
great lengths to protect the confidentiality of homeowners by
using unmarked cars, dressing informally, carrying equipment in
non-descript bags, and withholding identifying information from
the media. , . ,
However, a distinction needs to be made between protecting
the identity of individuals and needlessly encouraging secrecy.
Cahill feels that her sampling was made easier by people talking
to each other about the program before she got to the door, and
Brennan also noted informal networks among people that may have
helped to reduce the stress. While NJDEP protected confiden-
tiality by requiring homeowners to show invitation letters for
"homeowner-only" meetings, these meetings by virtue of their
intimacy may have also helped people to support each other and
maintain a sense of community.
Further, it is important to be clear that the reason for
confidentiality is to protect the privacy of homeowners/ so it is
not mistaken for government's trying to keep information from the
community. In Boyertown, efforts to respect homeowners' privacy
may have lent the situation an air of secrecy that was misinter-
preted by homeowners, according to Jones. ,
A7. Anticipate how your actions will look to those outside the
agency. Government officials often deal with public reaction to
actions which seem logical, fair, and consistent to those in the
agency but appear otherwise to those outside. Rather than deal
with the confusion after the action has been taken, agencies can
anticipate the reaction and (a) modify the action or (b) ac-
knowledge in advance that the action might be misconstrued and
explain it.
For example, in order to reduce charges of inequity and
potential conflict with the community, NJDEP and EPA spent
12 '•."/',
-------
.
eandahad0?^iCOmnUnitieS ^W-EPA h^s recoSSeAded
and had little response; he suggests onlv nan- iaiiv
coufl "jirt^LI Se Sor
l9h and«« P«son moved out,"
AS. Acknowledge and deal with people's feelings. Officials in
13
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both states recognized that people might be oVerly alarmed about
concerns ranging from health risks to property values. They
attempted to deal directly with people's concerns and spent
considerable effort transmitting caring as well as facts.
' As Hunt put it, "The agency's goal ,was to empathize with
people." In both Pennsylvania and New Jersey officials at all
levels spent considerable time "hand-holding," including extreme-
ly lengthy conversations with-people about issues other than
those within the agencies' mandates. NJDEP went so far as to
remove an employee from the radon information line who wasn't
able to help people talk through their concerns.
Cahill noted the importance of "taking a different approach
with homeowners based on their reaction." In essence, Cahill and
others tried to calm down homeowners who seemed overly excited
and to "wake up" those who seemed insufficiently motivated to
take action.
While indicating concern goes a long way towards creating
good relationships between the agency and people involved,
credibility is ultimately built by the translation Into action.
As NJDEP's Deieso put it, "From the first public meeting on, we
promised, and then delivered." , -
Individuals' previous faith in government may also affect
the extent to which trust is built during a particular situation.
For example, because Watras generally has faith in government,
which was bolstered by first-hand impressions of PADER represen-
tatives as "concerned and caring," Watras was willing to give
them the benefit of the doubt in many instances. However,
government may have to spend more effort on building trust and
credibility with others in the community who are less trusting to
begin with.
B. Explaining the Risk
A great deal of research has been conducted concerning ways
to present information about radon risk most effectively.4 The
following recommendations derived from the case studies suggest
some additional concerns for officials to consider when explain-
ing radon risk.
Bl. Make sure your message consistently emphasizes the potential
seriousness of the problem and what people can do about it.
Government officials in Clinton consistently gave what Michael
Drewniak of the Hunterdon Democrat called the "bad news" (radon
is a serious problem) and the "good news" (you can do something
about it).
The dual nature of the message seems particulary important
. 14 • ' ' - ' "• ' .,'•'
-------
.
important to transform stress into meaningful action for
^^^
^^
sss*^ gf c^^
it was a problem that had been dealt Sit* i;h
^^
srsaas- as/way pss. •-„
the ?his we'?JP lo *
T . . —•* -«-7-«.~*'^i.i_, WIAO.J.C ctft\ ana coniractors were
evaluating homes for the research project, they told people "If
immediately. Keep'your windows open and that^ill^ake^o^to a
^£^0 ^gtj^0^ ^Sirsj^rss^Kr^id
B2. Acknowledge uncertainty while being cl«ar about
senousness of the risk, in both Pennsylvania Ind N
S?^^?SererS h°^d that agen^ °«i<=ials seemeS far mo
credible because they admitted uncertainties about health risks
As Beckley suggests, "DEP told the truth. .. j They said *wJ Son- t
know' when they didn't. ... That's the sort j of publiS posture
that leads one to trust." Schneider also pointed out that in
However, the uncertainties must be placed in context to
Jv?i^C?n^Sin? Pe°ple un«^essarily. For exampLnilhougS '
Sealof «^o^f5°m occuPati?nal health studies involves a great
suaaeSts ?ha? JfJ9 ^esswork( Agencies feel the evidence strongly
?£iIuSL2^ J °n 1S a ser>ous ris*- Klot;z attempted to put
this uncertainty in perspective by saying scientists felt far
™Snv S?n5idenV?OUt the risks of rad°n ^han S2 SsklposS by
jany of the substances people are concerned about in their
drinking water in New Jersey. .Klotz stressed the importance of
JS SX?ing ^certainties ^t "being clear about prio?ities" so
^L«0JK0m 1une,ab°Ut the Potential for seHous health risks
nS?!?n thf°u9h. clearly. Stressing the uncertainties without
putting them into context can create the appearance that the
agency is revealing less than it knows, when, in fact? the agency
15
-------
is attempting to be forthcoming. •-.••*
f
Nulman took a pragmatic approach to explaining uncertainty
by suggesting that regardless of the doubts, people should take
action: "This is one of the few environmental hazards that you
can do something about. Why ignore it?...Why not remove all
doubt?" •• • .-
Klotz noted the importance of addressing the uncertainties
of translating risk probabilities to the individual level by t
anticipating "confusion ahead of time by saying we can't tell you
exactly what your individual risk is."
B3. Put risk in perspective. Many interviewees stressed the
importance of comparing radon risks, to those more familiar to
people. Pete Shellem, then of the Pottstown Mercury, emphasized
the importance of "giving comparative data so people could make
their own choices." Jones felt frustrated and confused about
radon until the comparative risks were explained to her.
Government officials, reporters, and citizens for the most
part preferred comparing radon to smoking than to other everyday
risks. (Comparing other environmental problems to smoking is
strongly discouraged because it compares a risk taken voluntarily
to those which are imposed, such as industrial pollution. How-
ever, comparing radon-risk to smoking may be effective because:
(a) Natural risks feel less unfair than those "imposed" by
government or industry; (b) Government was taking the problem
seriously and using the comparison to alert people rather than to
trivialize the risk; and (c) The outcome in both Cases is lung
cancer, which provides a stronger base for the comparison.)
According to William Belanger, radiation specialist with the EPA,
"Maggie Reilly had come up with the conversion that 20 pCi/1 was
equal to about one pack a day and that was a big thing we used to
communicate risk because everybody was pretty aware of the risks
of smoking..."
Officials noted that it is helpful to give people guidance
about their levels but to avoid calling levels "safe" or "dan-
gerous." Comparing readings to the federal action level of 4
pci/l is critical to putting the risk in context. However, Klotz
cautioned that it was important not to suggest that levels below
4 were "safe" or above 4 were "dangerous." Instead the EPA
approach to correlating ranges with other information might be
more useful. (EPA ic funding further research on this subject.)
. -. •* , •
When officials are confronted with a new risk as in Boyer-
town, rarely are there established, uniform action levels.
However, it may be useful to give information about levels of
contamination that triggered actions in similar situations. For
example, Tappan felt it critical in the absence of uniform
federal guidance to tell Boyertown homeowners the readings that
16
-------
the
spent in the home must be factored in.
JJ°^ever' an these comparisons must be] used cautiously so
0?e??^e • S?^ thef r,risk accurately rather than to Y
or trivialize .risks. In order to represent the risk
use
B4. Be forthright about the risk. Althoug^ it may be uncomfort-
able to discuss risks with people facing high levels of radon
contamination, people cope better with information than without
As Jones explained "They said "You may not like what I hJve ?b
SSni.?°?i T Z ^ 1A11 ? aSk iS that y°U'be truthful and
honest.'" According to Belanger, there areiways to put the risk
information into context so that it is less frightening than lust
simply numbers: «I told her [Jones] not only the cSan?e?Sf '
dying of cancer, but a little more information.... ri asked]
how long have you lived in this house? '.. .and looked at ohe-vear
risks... and said 'let's calculate what the risk is???.' ?? was
^d likf t0 ?ee' but * wasn'^ spectacular..?."
the explanation of the risk relieved Jones' mind,
that Belanger's explanation helped her a
4.^ ' i B,einf forthright about the risks also way ; be important so
that_people take the risk seriously. "I think you nLd to be
right up front with them> be very honest....! Many homes still
exist out there where there is a true health hazard," says
-
ni co^cef?s other than health risks. When motivating
people to test and mitigate, consider directly addressing
concerns about property values. According to those we inter-
viewed, many people other than those with very high readings seem
to be equally, if not more concerned, about questions related to
property values than they are about health risks. "Most of the
homeowners were more interested in whether the house could be
fixed if there was a problem," according to tappan.
17
-------
. - . • ' • '
According to some we interviewed, government might go even
further and use property values as a means to .motivate people to
mitigate. Tappan states, "I've found the best way to get the
public's interest—is to relate it to the value of their
property A home is probably the biggest investment they have
in their lives, and they should protect that investment." A
number of government' officials'say they informally urge people to
think of property'values if the health risk does not motivate
them to remediate. But Belanger suggests ihe would feel more
inclined to take this approach if he had some data about property
values before and after mitigation. Realtor Greco said that her
agency's emphasis was on advising people to find out and reme-
diate before they went to contract to avoid problems later on.
B6. Address people's immediate concerns first. Then back up and
fill in the scientific concepts. According to Klotz, the
homeowner's meeting dealing with health risks was somewhat
confusing and lengthy because NJDOH explained conceptual informa-
tion about risk and embedded in those explanations more specific
information about radon risk. Instead, Klotz and others we
interviewed suggested that it makes more sense to address
people's concerns directly and then give the scientific explana-
tion. As Klotz put it, "Answer the questions in the context of
[the science], but don't try to give a more formal conceptual
lesson until their emotional needs have been expressed." .' ,
Questions raised in New Jersey and Pennsylvania included:
"My daughter is 20 years old and has been living here all her
life. You say the latency period is 20 years. Does this mean
she is going to get cancer now?"
"What should we do about children's toys that have been in
basements with very high radon levels?"
"Is there more lung cancer found in-our area?"
"Will people have to leave their homes?" s
"What about children?"
"What about real estate values?"
People also had many basic questions about remediation
including concerns about how-to's, contractors, and financing.
Officials in both states were asked questions for which they
didn't yet have answers. Experience of agency practitioners
suggests that, in such cases, officials need to be clear about
why they don't.know the answer and, when possible, indicate what
they are going to do to find out an answer.
?' •
- • ' ' 18 ' •-.''. .•.'.••.
-------
:
that Others get their h°m*s tested! Greol pointed out
-
r sr
of the pressure off the Clinton area. > rong/ lt: took some
i , '
•SfAh ?? ?S doWn-to-earth as possible. Nulman suggested that
•
to concerns on a personal level. All
evolved stressed the importance of being "the
a.ir'ST^sr^
to mitigate." while the officials were oleir abort the di?
ference between "polioy" and their personal isenslof the si
'-*1" erS°nal
the situation more
C. Holding Public Meetings
^™«*e public meetings in Boyertown and Clinton, by all
accounts, were critical not bnlv for r.rtr.vo^«« ,•«*—1,4.4..
!neytonl
and co»»unity residents
'
19
-------
hinges on the factors discussed in the preceding sections and the
following: ,
Cl. Plan Meetings carefully. Both New Jersey and Pennsylvania
officials spent considerable time in top level, interagency
meetings determining approaches to policy issues before the first
public meeting. In addition, NJDEP and NJDOH devoted time, both
separately and jointly, to clarifying goals for the meeting,
outlining an agenda, determining who was responsible for mate-
rial, developing approaches to explaining information, and an-
ticipating likely questions and potential responses, PADER's
Hunt also coordinated a "dress rehearsal" prior to the,first
meeting. "I couldn't overemphasize the need to sit down and
develop a good plan and...properly rehearsed agendas so everyone
is well aware of what the other person is going to say," states
Tappan. , ' . - -
New Jersey officials emphasized the need for clear goals for
the meeting, such as conveying the "good news, bad news" message
explained in guideline Bl. Telling people what they can" do may
be as essential as explaining to homeowners the seriousness of
the problem. Also key was giving a sense of both government's
competence and the importance of the community in solving the
problem. "We wanted them to leave with the notion that this is
not an untenable situation, and while we may not have all the
answers to the problem, we were going to work collectively and
cooperatively on it," says Nicholls. During a crisis, when there
seems to be little time to discuss goals, it may be even more
important to clarify them; when the situation is tense, there is
less margin for error. Anticipating and planning for events that
might occur, as NJDEP did by discussing in advance policies for
evacuation of homeowners, can relieve some Of the pressure and \
prevent some of the problems that may arise from "flying by the
seat of the pants."
Agencies need to pay particular attention to preparing
presentations that may be confusing or problematic, such as
explanations of health risks, which many of those interviewed
said easily became overly complex and technical.
C2. Choose carefully those who will represent: the agency and
coordinate their roles. Public meetings are important not only
to convey information but to give the community direct access to
government officials. While community residents generally don't
have a lot of experience assessing technical information, they
have a great deal of experience evaluating others' credibility.
In fact, homeowners' judgments about the "messenger" may
determine whether they believe the message. Thus, agencies
should consider choosing spokespeople based on technical exper-
tise and ability to communicate effectively and sensitively.
Nulman suggests that Nicholls, who is a radiation physicist
20
-------
with a teaching background, was a "good plus* at the first rmhi *„
~a^ie°^^^
&^^^
how to count picocuries. ...» However, Tappan counsel! ?hat it is
equally dangerous to rely on non- technical is taff who are not
entirely familiar with the subject matter, and he advises that
"*"1 b* "well-advis«<* .to lean o '
,communicati°ns training for technical staffT
>>Y °n"?oln9 advice and feedback from community rela-
policy a serve as members of the teak developing radon
Tappan noted that sometimes it might be .wiser to rely on a
?o «ion??? kej?person at a. Public meeting to Deduce confusion Sue
to "conflicting information." Others suggested that includina
spokespeople with expertise in particular areas-tor exampli
TiSS^i?" a*dhealth risks-can be essential to give meaningful
n™£~ i°n* vln fa°?' NJDEP officia^ suggested that having a
number of spokespeople enabled them to clarify ambiguities and
correct misimpressions that individual speakers might have failed
to notice. However, they emphasized the need to coordinate
presentations carefully to avoid confusion and, duplication.
Tappan suggested that sometimes it's appropriate for
agencies to bring in outside experts who can lend credibility.
C3. Consider involving local representatives as spokespeople.
Local spokespeople who already have credibility with the com-
2S5t3L?an- I™1**? element °f trust to the statements of outside
officials. As Deieso put it, "Many times wet will go into a
meeting and the mayor is up there with us but it's very clear
™™J^ ^-n°* theumay°r's aeetirig.... [But JNulman] provided an
opportunity for what had to be said, and he fully supported
everything we were saying.... The flavor was * Trust these
peoplfe; I trust them..;.'" Nulman felt that "If the public went
?owJ ™« in! ^*f* Wf^ a 9°od ef f Active partnership between the
town and the state, that they weren't being given a line, and
that there was a good plan, then the meeting! served a purpose."
Almost everyone interviewed gave Nulman of Clinton a larae
measure of credit for helping to turn the stress into problem-
solving. As Beckley suggests, "tensions kept turning back to
facts.,.. He did not get on a soapbox and emotionalize it, [but]
said they were going to work together to lick it." While this
type of role can be played by officials from oxitside of the
community, local officials who are respected in their communities
21
-------
are probably more likely to have the necessary credibility.
'
C4. Anticipate questions, address those concerns in initial
presentations, and leave plenty of time for additional questions.
The initial public meetings in both Pennsylvania and New Jersey
allotted substantial amounts of time for questions—at least as
long as the presentations—and officials stayed as long as
necessary to address community concerns.
Klotz suggested that presentations are most effective ix -
they anticipate and address homeowners' immediate questions (see
guideline B6). Deieso remembers New Jersey officials asking each
other in advance "What are you going to say when they ask...?"
and reviewing each other's responses. In both Pennsylvania and
New Jersey agencies did some homework to respond to likely
questions such as those regarding the lung cancer rate in the
area.
While public officials grapple with issues at a policy or
public health level, homeowners' concerns are quite personal.
Although their questions may be posed in intensely personal
terms, such questions often reflect the concerns of many others
in the room and give agency officials an opportunity to clarify
statements made earlier. While some questions may be better
answered one-on-one after the meeting, Jones stressed the
importance of being able to respond to bottom-line, personal
questions publicly to avoid confusion and frustration.
C5. Use meetings to encourage people to take action. Agencies
in both New Jersey and Pennsylvania used the public meetings not
only to reassure people about high levels but to make it easy for
them to test their homes. In Clinton testing kits were dis-
tributed at the meeting, and in Boyertown residents were en-
couraged to call PADER to have technicians come out and test.,
C6. Hold meetings frequently in times and settings comfortable
to the community and continue ongoing dialogue with the com-
munity. Craig emphasized the importance of frequent communica-
tion, instead of waiting to release a final report, in order to
update homeowners on progress in their community. Frequent
meetings and ongoing communication also provide an opportunity to
reinforce the messages of previous meetings, build'trust, and
allow community residents to exchange information.
In both states meetings were held in the immediate community
during hours when homeowners could easily attend. Although New
Jersey officials were initially skeptical of Nulman's suggestion
for holding meetings on Saturday mornings, the timing worked out
well, adding an atmosphere of informality and allowing people to
bring their children instead of having to hire babysitters.
People also responded favorably to the agency officials going out
of their way to be helpful: "People said 'Thank you for coming up
22
-------
WaS •*,•!«, J- :»** dented scathing,
•. .., • - ':••'-• . ,, ' .'. ' . . . • - '
• ' • • • ' • ' ' (. ' ". •
C7. Debrief and evaluate meetings. Some of the am*n™
- sass fi
and
and
attitudes or potential misunderstandings early. In addition
evaluation might have confirmed whethe? off icLls- p^rceptiShs of
community response were/in faction target, lome o? ?he
interviews for this study, for example, revea] ed conf lictina
impressions of public response at the Boyertovm a52tS»r Lv.
definitive feedback could have provided a StSr^J^bf
homeowners; understanding of thS radon 'probiS? tSS? motivation
^?f Sis^.^!-
Evaluation need not be elaborate to accomplish these
;;-*^,00"^ lnClUde Short deb^iefing seiSons Imong
rL?fflS12iS a?d on*-page questionnairesrcompleted by 9
residents at the close of the meetings.5 . • )•• "
facV' NJDOH's Susan Klucharich developed a questionnaire
overcome by asking for feedback at meetings.]
D. Communicating with the Media
... Government officials in both states were extremely leerv of
™S™edi5 fictionalizing the story of extraordinarily high
radon levels. On the other hand, as Dallas suggested, "We felt
thii*"01^!"* aspeCt was education, -and the press could help us do
this." in fact, even a well-attended public m«»etina attracts
SS^.5Sr5i°L2LSe5S45l!""^i ^™"W ""
t of public meetings to others who
agency officials dealing with Clinton and Boyertown
arwa*. ~~, j^ generaj ^Q. be wnat NJDEP' s Jim
situation like
_. , , r • ,^~~ —•.• '^j«r*««»*s«* wv« J>/
-------
this," realtors, perhaps more sensitive to thte immediate impact,
were nearly uniformly dismayed by what they perceived as the
media's over-attention to the sensational aspects of the problem.,
Nearly everyone who was interviewed regarding media coverage in
Clinton also drew a clear distinction between TV and newspaper ,.
stories, voicing great concerns about TV reporters' disruption of
residents' lives, predictions of doom, and inappropriate
coverage.
Many of the suggestions in the, preceding sections may be
helpful to improving media coverage. The following.are specific
to dealing with the media: ;
Dl. Alert local officials prior to the press and consider
involving then as spokespeople. Officials in both states were
scrupulous about briefing local officials prior to taking the
story to the media. In Pennsylvania, Hunt called township
supervisors individually to discuss the situation prior to
briefing them in the presence of a reporter contacted by Hunt.
New Jersey officials briefed Nulman, and he then chose to take
the lead in dealing with reporters who were congregating outside
his office. While NJDEP officials were quoted about technical
concerns, Nulman gave a personal perspective that may have helped
reassure readers: "...This is not the time for mothers to clutch
their children and run into the streets."
* '
D2. Initiate contacts with the media rather than delaying
notification. Continue contact. As discussed earlier, delaying
release of a story is likely to dp more harm than good. Ac-
cording to Staples, "The longer you wait to notify the media, the
more they will be curious about why you delayed. The more'
government lets people in on the action, the more they will
respect government for forthrightness."
Neither Pennsylvania nor New Jersey officials notified the
media through a technical briefing or press conference. In
Pennsylvania a press release was issued several days after the
briefing in the presence of the reporter. In Clinton, as Staples
put it, "Reporters began to hear the jungle drums. They were one
step ahead of our putting together a coherent presentation."
Staples acknowledged that, although the NJDEP by all accounts did
an excellent job of responding to inquiries, such a presentation
might have been useful, particularly if more than a small number
of local papers were involved. As Drewniak suggested, "If we
don'.t have all the information, [sources] will see the story and
say 'that's not the whole picture.1 Just tell me the whole
picture and we can avoid this from the outset."
Reporters in both states gave officials credit for being
accessible throughout the story, but some agreed that holding
technical briefings might have been useful. For example,
although reporters talked afterwards with officials about the
24 ' "• -. .. ' . ' ' .'
-------
information conveyed to homeowners in close*:! Meetings, formal
briefings might have led to additional coverage useful to
homeowners outside of Clinton Knolls. Craig also suggests call-
in shows as a good way to raise awareness, respond to homeowner
concerns, and promote dialogue., . i .• .
TV reporters may be particularly prone to run'stories about
radon as a "time bomb" and to project fear about property values.
This may be due, in part, to the nature of the medium, which is
forced to cover complex stories in short film bites. The
negative focus may also be due to out-of-town reporters being
less concerned about avoiding panic. Althought concerned about TV
reporters' tendency to. blow the story out of proportion, Nulman
decided they would do the story with him or without him and the
story would be better with his perspective than without.
" - L '•',."-..
In fact, media consultants generally agree with Nulman that
the best defense is a good offense; the mosi: effective way to
temper a negative story is to supply the positive side, with
visuals for TV, if possible. Officials are now in a better
position to temper "gloom and doom" stories with examples of
successful remediation and the booming economies in both Clinton
and Boyertown. While local reporters might!want to highlight the
"new" problem in the area,, officials can explain the standard
approaches to dealing with radon. In addition, government
officials can supply TV reporters with visuals that are more
appropriate than "For Sale" signs might be.! For example, they :
can show how a radon detector or ventilation fan works. While
these visuals might not replace shots of "For Sale" signs, they
might help give the story a bit more balance. Working to help
reporters cover the story more appropriately is far less time-
consuming than trying to correct misinformation after the story
has run. I
" ' ' ' • i' ' '. A ' . •'
D3. Be as clear, down-to-earth, and quotable as possible. Early
media reports have the potential to set the i stage for the story,,
framing it so that homeowners respond with appropriate concern.
Downplaying the health risks may reassure people, but also
promotes denial of a potentially serious problem. Some early
press reports quoted PADER representatives as saying "This, is not
a public health problem" and that radon was j"...not a danger to
the general population." While the intent ikay have been to point
out that the radon problem is tied to individual homes, such
statements can be confusing. As discussed earlier, it may be
mote useful to stress what can be done, and what government is
doing, to solve the problem. (Admittedly, this might have been
difficult in Boyertown due to the uncertainty surrounding mitiga-
tion soon after the first hot spot was discovered.) Sources can
point out explicitly what people can do to have their homes
tested and the cost, if any. !'•'•..'.
Reporters covering Clinton gave New Jeirsey sources high
25
-------
marks for being down to earth and understandable. "What [Sta-
ples] did best was to put it in terms that you could write in a
newspaper-for a layman...very informational and quotable,"
according to Drewniak. Nulman had a knack of putting the message
in quotable statements people still recall. While most worked
well1, he regrets saying that Clinton was not a "Love Canal"—the
negative assertion might have made the image more, rather than
less meaningful.
Anticipating reporters' questions can help prepare useful,
coherent answers. Staples suggests that NJDEP appeared know-
ledgeable to reporters because as a former reporter he was able
to predict what they would want to know and work with Nicholls to
develop appropriate responses.
D4. Maintain .the confidentiality of homeowners, but consider
ways to help reporters cover mitigation. As discussed earlier,
all government officials stressed the importance of maintaining
homeowners' confidentiality. Staples suggests that government
should treat homeowners' test results with the same degree of
confidentiality that doctors treat their patients'.
PADER tried very hard, but failed, to keep Watras' identity
confidential as he requested. Reporters, knowing that Watras
worked for Philadelphia Electric and the general location of the
home, were able to track him down relatively quickly. New Jersey
officials may have been more successful protecting confiden-
tiality because less identifying information was known about the
"discovery" house. .
Newspaper reports of Clinton briefly noted that the home-
owners' identities were withheld due to state policy. However, a
report in the Reading Eagle, that state officials "flatly refused
to identify the family..." made officials sound furtive. Because
reporters are particularly suspicious of any attempts by govern-
ment to withhold information, government officials may need to
stress why identifying information is being withheld, using the
doctor-patient relationship as an analogy. Reporters are
unlikely to be dissuaded from trying to track identities, but
they may be less likely to accuse the state of secrecy.
While reporters in Clinton acknowledged that they could
cover the story adequately without knowing homeowners' iden-
tities, Drewniak pointed out that it was far more difficult to
write stories on remediation without examples. „ He felt that to
get beyond basic information, he 'needed to talk to a homeowner
who had remediated to discuss mitigation explicitly. Because
"success stories" might encourage more people to test and
remediate, it might be worthwhile for government officials to
make it easier for reporters to cover remediation. Craig
suggests that officials ask homeowners if they would be willing
to speak to the press and, if so, give homeowners the telephone
26 - •..-''':' • ' ,
-------
numbers of reporters. Thus, officials could kever be accused of
giving out identities and the decision remalfes the homeowner's?
Officials could also conduct remediation workshops or briefinas
that would give reporters better "news pegs." y&
IN CONCLUSION i ,
It is_not especially noteworthy that hindsight suggests ways
agencies might have communicated:more effectively. It is far
more noteworthy that when faced with tremendous pressure and
uncertainty the agencies communicated as well as they did. In
both cases that effectiveness was due in large measure to'
officials' commitment to; dealing with what they perceived as a
serious health hazard. But nearly all government officials
suggested that circumstances beyond their control—some used the
word "luck"—played a large part. In truth] if Watras hadn't
fortuitously .worked for Philadelphia Electric, radon might yet be
waiting to sound alarms. j. .
Officials connected with Clinton attribute their success to
circumstances that;are difficult to replicate. The team was
remarkable: a mayor with outstanding leadership, abilities-who
was more interested in solving problems than casting blame; a
radiation physicist with teaching experience; a press officer
with extensive reporting experience; and other officials who were
not only competent but by all accounts extremely personable and
approachable. The hot spot was discovered vrhen homeowners could
open their windows to reduce their .levels, thus reducing their
fear and,the pressure on government officials. And just as
important, government officials had the benefit of the experience
in Boyertown. As Deieso suggests, this combination of cir-
cumstances may never occur again. However, larmed with the
lessons learned, during the Clinton situation, government offi-
cials may be able to cope better with communities where the
circumstances are less ideal. ,
27
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-------
VERNON, NEW JERSEY f
, , . ' •" • „ i 1 • • ' . ••
- '"•'.- .!'"•' ~ ' •
In June 1986 NJDEP officials unveiled ja plan to deposit a
blend of radium contaminated soil and "clean dirt" in a quarry in
Vernbn, New Jersey. The result was a government official's
nightmare-. In the following months the proposal precipitated
opposition in the form of a stormy public meeting attended by
approximately 3,000,, a rally that attracted 10,000, and a
demonstration at the Governor's mansion that brought demonstra-
tots out in a caravan of hundreds of cars, i
It is an understatement that public response in Vernon to
radium-contaminated soil differed from that; in Clinton and
Boyertown to naturally occurring radon. In! fact, a NJDEP offi-
cial suggests that the only thing Vernon and Clinton had in
common was "the r word." .While the situation in Vernon was
admittedly quite different than in the other communities, the
following analysis suggests why public reaction in Vernon might
have been so different and the extent to which the lessons
learned in Clinton and Boyertown might haveYrelevance to situa-
tions such as Vernon. As described in the Methodology section of
this report, the events of Vernbn and quotations from the
participants are derived from a study conducted by Rutgers
University's Eagleton Institute of politicst
SUMMARY OF EVENTS
The radium-contaminated soil, which NJDEP tried to dispose
of in Vernon, resulted from excavation around homes in Montclair,
New Jersey. These homes had been built on contaminated fill from
the radium ore processing industry that existed in New Jersey in
the early 1900s. The excavation was part of a, pilot study
initiated by NJDEP in May 1984 to reduce what state and federal
officials judged to be the significant health risks resulting
from gamma radiation and radon in these homes, which are desig-
nated as part of a Superfund site. Although NJDEP had secured a
permit in advance of excavation for out-of-state disposal of the
soil, that plan was blocked by court challenges. By the time
NJDEP tried to dispose of the soil in Vernon, there were 5,000
barrels on front lawns of homeowners in Montclair. Another
10,000 barrels were temporarily stored in K«arny, New Jersey,
which was bitterly opposed,by some members of that community.
Thus, even before Vernon was propbsed as a '[host community," the
situation in Montclair and disposal of the radium-contaminated
soil was a high profile issue in the state.!
NJDEP's idea of blending the contaminated soil with clean
soil and then burying it was investigated by an engineering firm
with a mandate from NJDEP to complete the on-going study in one
week. Before Vernon was chosen as the site ifor soil blending and
• • . ':. • 28 ' • .'••".''
-------
burial, the concept was endorsed by NJDEP's. Sjcience Advisory
Board, five scientists appointed to give NJDEP input on scien-
tific issues, as well as by many Montclair officials. According
to a NJDEP press release, Vernon was chosen after study of 900
sites, and nosed put another quarry site because restoring the
quarry in Vernon would add 100 acres to park land. Although
later disputed by the Vernon community, the agency felt that soilr
blending would reduce the risk of the Montclair soil to a minimal
level. '.. - '
The residents did not know in advance that their community
'was. being considered as host for the dirt. According to the
Eagleton study, "It was not until Commissioner Dewling met :with
town officials on the eve of the public announcement that anyohe
in Vernon knew of NJDEP's plan." Commissioner Dewling, surprised
that local officials invited the media to what he considered a
closed meeting, "simply announced that the Vernon quarry had been
chosen to host the blended dirt," rather than discussing v^ith
municipal officials how to proceed. Within days the Vernon
township attorney had filed suit to block the soil-blending plan.
At the next township meeting the mayor took an active role in
urging community opposition to the plan and appointed a group of
citizens to advise the township. A delegation of citizens met
with NJDEP and, dissatisfied with NJDEP's response, formed-a
citizen group with the stated goal of keeping the soil out of
Ve.rnon. Citizen opposition .built to a public meeting in July of
approximately 3,000 people, followed by a large protest at the
Governor's mansion. In late July a rally to oppose the disposal
of the soil was attended by 10,000 people. Meanwhile, NJDEP
asked the group of citizens appointed by the mayor to review
NJDEP documents in hopes the committee would agree that the
blending plan was safe. Because a "radical faction" of Vernon
residents threatened violence, civil disobedience training was
offered as an alternative by a New York-based group, which
crganized its own protest rally of 3,500. In November NJDEP
publicly announced that soil blending and disposal would not take
place in the Vernon quarry.
ANALYSIS OF PUBLIC RESPONSE
The response of the Vernon community was obviously marked by
anger. The question is why.
One of the ironies of the events in Vernon is that Vernon
residents protesting the disposal of soil in the quarry in their
community were potentially at risk from naturally occurring radon
in their homes. Research indicates that most homeowners in New
Jersey, including those in areas more likely to be at risk, do
not plan to test.6 Therefore it is extremely likely that the
overwhelming majority of the thousands of protesters had not
taken.action to test for naturally occurring radon. In short,
29 ' -' •" '
-------
Vernon residents reacted strongly to what NJDEP considered a
negligible risk—the soil-blending plan—and;failed to respond to
a potentially serious one—naturally occurring radon. In
addition, although several of the same officials were involved in
both cases, Vernon residents responded with]far more anger to
NJDEP officials than did the Clinton community. There are a
number of compelling reasons for these different reactions.
. The story of citizen opposition in Vernon is not essentially
a story about radon. It is a showdown between an agency and a
community over an agency decision. NJDEP was perceived as
importing an outside risk, as opposed to taking action to
mitigate an existing one as in Clinton. While the agency firmly
believed the risk of the blended soil was negligible, the
community disputed the agency's process for bringing this risk to
their town,(which was called by the mayor a!violation of the
town's civil rights) as well as its assessment of the magnitude
of the risk. In addition, according to Larainne Koehler, health
physicist with EPA Region II, the residents!of Vernon had already
been engaged in a longstanding battle with NJDEP regarding the
presence of satellite earth stations in the I community. As a
result, says Koehler, residents were "already sensitized-^-however
unfairly—against DEP." ;
1 • " \ ' ' V '
The events of Vernon illustrate (a) community resentment
towards imposed risk? (b) the tendency to view imposed risks as
more objectionable and therefore riskier .than voluntary or
natural risks which pose the same or greater threat; and (c) the
community's commitment to fight the. agency on any grounds.7 in
the case of Vernon, the contamination happened to be radioactive
soil. In truth, the exact nature of the contaminant probably was
relatively unimportant. !
Whether appropriate or not, the community took the /risk very
seriously, while the agency was seen as dismissing both the risk
and community concern about it. Marianne Reilley, a member of
the citizen group and one of the residents aippointed by the mayor
to review NJDEP actions, charged that NJDEP (dismissed citizen
fears by calling the soil "just dirt." Thus, the agency, which
was likely to be cast by the town as a villain for importing the
risk, was viewed even more suspiciously for failing to respond to
what the community felt were legitimate concerns. By responding
belatedly to what it considered the inappropriate reaction of
residents, the agency may have increased citizen hostility, and
unwittingly helped to ensure that Vernon residents would perceive
the agency even more negatively. Although-the agency may have
intended a softer approach with the community and felt sandbagged
by the media and town officials from the outset, the agency's
actions spoke more loudly to the community tfhan its intentions.
' I '•-..'
Vernon residents didn't merely oppose tine soil-blending
plan, they opposed the agency. On the other hand, with naturally
30
-------
occurring radon, there is no enemy, no target that can be
identified with moving the risk or charged with unfairness for
importing the problem from one community to another. Thus the
risk is apt to be seen as less threatening, less .unfair, and
ultimately less serious. Furthermore, as discussed in the
following section, government officials took the risk of natural-
ly occurring radon seriously in Clinton and Boyertown, further
reducing the likelihood of the agency being cast as villains or
the community becoming overly alarmed.
The mayors of both Clinton and Vernon also took lead roles
in shaping community response. The mayor of Clinton, who viewed
NJDEP officials as part of the solution to his community's radon
problem, not as part of the problem, made a commitment to work
with NJDEP officials and urged community residents to do the
same. On the other hand, the mayor of Vernon, who could easily
view NJDEP as part of the problem rather than as part of the
solution, worked against NJDEP to eliminate the problem from his
community and urged community residents to do the same. Thus,
while both mayors might have seen themselves as working to
protect their communities, the mayor of Clinton both reassured
people about the level of the risk and urged citizens to test and
mitigate for' radon. The mayor of Vernon acted to protect the
community by alarming people further about the risk and suggest-
ing actions people could take to fight both the risk and the
agency that sought to impose it.:
There may have been other factors which influenced the
reaction of Vernon residents and distinguished it from their own
reaction (or Clinton's reaction) to naturally occurring radon.
For example, people are likely to perceive, their homes as "safe"
places. It may be difficult to convince them that something they
can't see or smell makes their homes hazardous.8 On the other
hand, the Vernon community's perception of the risk was in-
fluenced by highly publicized images of drums on Montclair lawns
and all the negative connotations that accompany chemical drums.
In addition, the potential risk in Vernon was ultimately from an
industrial source, which is likely to be viewed as inherently
more dangerous than a "natural" risk.
Risks that are not susceptible to individual control are
also apt to be seen as more threatening.9 While naturally
occurring radon can be mitigated by the individual, the perceived
threat in Vernon seemed entirely under government control. In
Clinton government officials increased the community's sense of
control—and reduced the likelihood of undue alarm—by suggesting
ways individuals could test and mitigate. Officials further
helped the risk seem less threatening--and increased the com-
,munity's trust in NJDEP~by providing other actions for people to
take, such as calling NJDEP's information line, talking to NJDEP
staff at the municipal building, attending homeowners' meetings,
etc. In contrast, in Vernon people responded to a lack of
31
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individual control over the risk by collective resistance to
government's control. Thus, the individual1 actions people could
take—from signing a petition to taking part in civil dis-
obedience training—were suggested by those'who opposed the soil
blending and NJDEP. . j
RECOMMENDATIONS i
The central issues in Vernon were ones!of equity and
control. The agency attempted to impose a risk on the community,
Seeing the risk as negligible and therefore acceptable. In turn,
the community resisted the imposition of the risk, the agency's
definition of the risk as minimal, and the agency's right to
determine the acceptability of the risk. While the agency spent
considerable energy attempting to convince the community that the
risk was negligible, the community remained skeptical and
continued to fight both the risk and the agency that sought to
impose it without consultation. Thus, the scenario in Vernon has
far more in common with the siting of hazardous waste facilities
than it does with alerting communities to radon risk.
The successful interactions with the communities of Boyer-
town and Clinton are unlikely to hold the key to siting, when
years of research and a multiplicity of /models around, the country
have failed to yield clear answers. Although the experiences in
Boyertown arid Clinton do not suggest ways to ensure that an
agency can successfully site a facility or a quantity of slightly
contaminated dirt, they can suggest ways to!avoid needlessly
increasing the tension between agencies andjcommunities. The
following brief analysis suggests which recommendations from the
case studies of Boyertown and Clinton may h^ye relevance to
siting situations such as Vernon's. j
Setting the Context I
" . . ,'.-"" ]
As illustrated by Vernon, communities often perceive risks
differently than agencies. But the problem|doesn't end there. An
agency's response to the risk is understandably based on the
agency's assessment of the risk, not the community's assessment.
For example, NJDEP did not arrange information, telephone lines,
staffing of an on-site office, and EPA support in Vernon as it
did in Clinton because agencies are less likely to commit such
resources to problems they consider less serious.
In contrast, government agencies discovered the radon hazard
in Boyertown and Clinton and essentially rode into town to
protect homeowners from the threat. Because agency officials
were aware that the town could mistakenly cast them as villains,
they worked diligently to cast themselves in positive terms. The
agency officials' response to the community also differed from
' - ' ;32 ''•'•"" \ ' , ' '
-------
their response in Vernon, in large part, because of agency
officials' assessment of the risk. The agency took community
concerns very seriously> because the officials considered the
risk serious. ' ,
Unfortunately, when agencies seem to be responding lightly
to risks that communities see as serious, they thereby increase,
rather than decrease, the disparity in the perceptions between
the community and the agency. When faced with what it perceives
as agency unwillingness to take its concerns seriously, the
community will often, as in the case of Vernon, increase its
insistence that the risk is unacceptable and continue to raise
the level of its opposition.
Agencies are thus faced with a dilemma. If a community
perceives a risk as serious but the agency perceives the risk as
minimal, a minimal response from the agency is likely to .further
alarm and anger the community. However, agency officials are
understandably reluctant to make large commitments of agency
resources to problems they see as minimal. While there is no
easy way to deal with this conundrum, agencies need to recognize
early those problems which communities are apt to view more
seriously than the agency. In particular, agencies should -
realize that risks imposed by outside sources are more likely
both to be resented and to.be seen as serious.
' ' * ' • '• ' "-'•'.'-
At minimum, agencies should look towards involving com-
munities in decision-making processes that are as equitable as
possible. As Deputy Commissioner Michael Catania suggests, "We
should attempt a restoration of faith. That is what the advisory
board [citizens and .scientists appointed by NJDEP after the
events of Vernon to make recommendations about disposal of the
barrels of'soil from Montclair] is trying to do. Instead of our
consultant doing the work, we should have the people from the
towns and environmentalists participate...."
Agencies must become particularly aware of the effect their
actions (or inaction) will have on the community (guideline A7)
and strive even more diligently to allow two-way communication
with the community (guideline A5). (While NJDEP did schedule
availability sessions with the community, they were held after a
decision had been made. Hence, they were too little, too late
for the community to feel like dialogue was taking place.) Just
as important, communities must be given information quickly, so
the agencies,1, withholding of information is not allowed to become
a key issue (guideline A2). In addition, agencies must work even
harder to gain the trust of local officials, while realizing that
close teamwork between the officials imposing a risk and those
being handed a risk is quite unlikely. However, failure to treat
local officials with a great deal of sensitivity and considera-
tion is apt to increase hostility and distrust (guideline A4).
- 33 ).'.•'
-------
Finally, agencies need to do careful science
confident the risk is trivial. : ;:^
even when they're
an agency sees a risk
Explaining the Risk
The events in Verrion suggest that when _., f __ „ ^
as less serious than the community does, agency efforts focused
on proving the minimal nature of the risk may be ineffective at
best and explosive at worst. An agency's insistence that its
view of the risk is "right" and the community's is "wrong" is
likely to escalate the power struggle. ^Instead, agencies should
give equal attention to setting the context for explaining the
risk and.bui.lding credibility with the community.1" As' Grace
Singer, chief .of NJDEP's Community Relations Bureau, ac-
knowledged, by the time of the public hearing "the town was in
such an ugly mood, almost nothing would have satisfied them."
Alerting people to risks they view with; apathy differs from
reassuring people about risks they view wit:hj alarm. Reassuring
people is particularly difficult if the goal! of agency officials
is to push them to also accept the risk, as Jin Vernon> rather
than to mitigate the risk, as in Clinton and Boyertown. Regard-
less, officials are better off leading with the uncertainties
rather than waiting for community residents jto point them out,
further undermining trust in the agency (guideline B2).-'Similar-
ly, officials should be seen as being forthright about the risk,
even if the risk is minimal (guideline B4) . The resentment in
Reilley's remark shows the risk officials run by .failing to
acknowledge the uncertainty: "In Montclair it was hazardous,
contaminated soil. Here it becomes 'just dirt.1" Although
officials believed the risk of the Montclair! soil would be
reduced to insignificant levels through blending, their response
seemed to the community to deny that the soil had ever been a
risk. •• ' ; . ' .- ••" '. ". ••' J . .-••• ; •
When^an agency seeks to explain a risk it believes is
minimal to an audience that believes the risk is serious, the
agency must be very cautious about how it puts the risk in
perspective (guideline B3). Unlike the casej of naturally
occurring radon, officials must guard against comparing risks
that people take voluntarily with those that are imposed, such as
the soil-blending plan. Thus, comparisons 'ojf. ssmoking (a volun-
tary risk) to soil blending (an involuntary risk) would have made
people even angrier. Similarly, comparisons; which seem intended
to trivialize the risk will be resisted by the community, as will
statements that imply that community residents can't adequately
comprehend the nature of the risk. As another citizen leader
explained, "What kind of mentality do they think we have? If
it's 'just dirt,« why move it?"
34
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Perhaps most important, officials need to deal with people's
immediate .concerns, and as in Clinton and Boyertown should,be
prepared to discuss issues that may be traditionally considered
outside the agency's purview (guidelines B5 and B6). For
example, in Clinton and Boyertown agency officials discussed
concerns about property values and took steps to address those
concerns. However, .the Eagleton case study suggests that agency
officials were less tolerant in Vernon of concerns about property
values. "...At face value a lot of things look like a-community
is outraged for environmental, reasons...and for health reasons,"
said Assistant Commissioner Donald Deieso, who implied that
community leaders' interest in plans for building condominiums
near the site might have been at the root of their opposition.
In truth, however, most communities that feel a risk is
being imposed without "due process11 are likely to oppose that
risk on any grounds possible. Because,the agency's and the
community's notion of due process differ, it is wise to solicit
community input on procedures. Most efforts to make the com-
munity understand risk as the agency does are unlikely to be
successful if the community feels vulnerable, angry, and un-
trusting. -
Holding Public Meetings
Most of the recommendations for holding public meetings that
were cited earlier in this report also apply in situations such
as Vernon. When dealing with a hostile community it is even more
important to plan meetings well, choose spokespeople carefully,
anticipate questions, and evaluate the meeting. However, public
meetings in a community that is largely angry and greatly
committed to opposing an agency, as in Vernon, are not very
conducive to constructive dialogue, it is very difficult for
them to be anything but confrontations that give both sides an
opportunity to go on the record. To the extent possible, in
situations where the community is likely to be hostile, agencies
should hold small, informal problem-solving meetings with those
affected. These meetings are apt to be more constructive if they
are part of a decision-making process rather than merely an
opportunity for the public to respond to a decision the agency
has already made.11
Communicating with the Media
Most of the recommendations from Boyertown and,Clinton also
extend to situations such as Vernon. However, as with public
meetings, by the time the issue is a battle, fighting it out in
the press is unlikely to help the community better appreciate the
agency's position. On the other hand, if an agency fails to
implement the recommendations such as alerting the press early—
' • 35 :'. '.•'';.•'.,•
-------
but after public officials—and making clear,*quotable state-
ments, the agency may worsen the^ situation. ',
A FINAL NOTE
Attempts to import a risk to a community, even a small risk,
will often elicit opposition. Failing to involve the community
in the decision-making process will virtually guarantee it. Once
the risk.and the agency are perceived as "the enemy," changing
that image is very difficult. Implementing!the suggestions from
the examples of Bdyertown and Clinton may not help,tremendously.
However, failing to implement the suggestions will worsen the
situation. When communities are extremely sensitive to risk,
agencies need.to respond even more sensitively—while recognizing
that their efforts,may not be immediately rewarded by greater
respect from the community. ! ,
36
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NOTES .•{'.•
r •
* • ' -
1. Van Horn, Carl, Jim Berzok, and Caryn Paul, "It's Just Dirt:
A Case Study of Radium-Contaminated Soil in New Jersey,"
' Eagleton Institute of Politics, Rutgers University, May
1987. , ' - "
2. Weinstein, Neil D., Peter M. Sandman, and Mary Lou Klotz,
"Public Response to the Risk from Radon, 1986," Division of
Environmental Quality, New Jersey Department of ,
Environmental Protection, January 1987.
3. It should be noted that Pennsylvania has since abandoned its
low interest loan program that elicited little response.
While low response may have been another indication of
homeowners' complacency, it may have been due, in part, to
other factors. For example, Jones pointed out that the
process for obtaining such loans was extremely burdensome.
4. Some of the analysis and research about explaining radon
risk: , -
Chess, Caron, "Recommendations for the New Jersey Department
of Environmental Protection's Radon Communications Program:
A Working Document," Office of Science and Research, New
Jersey Department of Environmental Protection, Trenton, NJ,
April 1986.
Edelstein, Michael R., and Valari Boyle, "Media and the
Perception of Radon Risk," in William Makofske and Michael
Edelstein, eds., Radon and the Environment (Mahwah. NJ:
Institute for Environmental Studies, Ramapo College of New
Jersey, 1986), pp. 233-240.
Fisher, Ann, Kerry Smith, Bill Desvousges, and Reed Johnson,
"EPA Radon Communication Studies: What Have We Learned?"
Workshop on "Communicating the Radon Risk: The Roles of
Journalists, Scientist, and Public Health Officials in
Informing the Public about Radon," New York University
Science and Environmental Reporting Program and Georgetown
University Medical Center Institute for Health Policy
Analysis, New York, NY, March 13, 1987. ,
Johnson, F. Reed, and Ralph A. Luken, "Radon Risk Informa-
tion and Voluntary Protection: .Evidence from a Natural
Experiment," Risk Analysis. 1987, pp. 97-107.
"Radon Risk Communication Project Interim Report," Program
Evaluation Division, Office of Policy, Planning, and
Evaluation, U.S. Environmental Protection Agency, October
27, 1987.
37
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7.
8.
1' Nel1' D-' Peter M-
----» ,—•— • ~«.*«*«aia, and Peter
in Fall 11988 from the Environ-
Program, Rutgers University.
i ••
Mary
Protection, January 1987,1
and Edu«ting!the Public About
, Eugene , Oregon , May 1985.
Sandman, Peter M. , Neil p. Weinstein, aind M.L. Klotz
1I "
9. Slovic, p.19.
10.
datal.l on. building the context1 for explaining risk
B' k'
11. Ibid.
38
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APPENDIX
LIST OF INTERVIEWEES
-------
*<- f.
-------
BOYERTOWN INTERVIEWEES '
Federal Government
William Belanger
Regional Radiation Representative
Air Management Division
Region III
US Environmental Protection Agency
Philadelphia, PA
Stanley Laskowski
Deputy Regional Administrator
Region III
US Environmental Protection Agency
Philadelphia, PA
State Government
Bruce Dallas
Formerly: Press Secretary
PA Department of Environmental Resources
Harrisburg, PA
Presently: Associate Director
Associated Petroleum Industries of PA
Harrisburg, PA
James Fox .
Public Health Physician
Division of Environmental Health
PA Department of Health >
Harrisburg, PA
Thomas M. Gerusky
Director
Bureau of Radiation Protection
PA Department of Environmental Resources
Harrisburg, PA
Margot Hunt
Formerly: Director of Community Relations
Office of the Secretary
PA Department of Environmental Resources
Harrisburg, PA
Presently: Vice President
Enviroservices, Inc.
Devon, PA
James Logue
Director
Division of Environmental Health
PA Department of Health
Harrisburg, PA
-------
Margaret Reilly
Chief, Division of Environmental Radiation
Bureau of Radiation Protection
PA Department of Environmental Resources
Harrisburg, PA
Local Government
LuAnn Reichert .
• Township Manager ;
Colebrookdale Township
New Berlinville, PA
Jonathan Smoyer , I .'
Emergency Coordinator for Colebrookdale Township
Director Bldgs, Grounds & Transportation
Muhlenberg School District ; ,
Boyertown, PA 1
Contractors
Tell Tappan
Vice President, Sciences Division
Arix Corporation
Grand Junction, CO
Realtors
' Richard Rehrer
Rehrer & Zuber Realty
Gilbertsville, PA
David Specht
Specht Realty, Inc.
Pottstown, PA
Reporters
Bill Bradley
Reporter
Reading Eagle/Reading Times
Reading, PA
Mary Jane Schneider
Editor
Boyertown Area Times
Boyertown, PA
-------
-4 • * * . •=->
Peter Shellem
Formerly: reporter, Pottstown Mercury
Pottstown, PA
Presently: reporter
Patriot News
Carlisle, PA
Citizens
Kay Jones
President
People Against Radon
Boyertown, PA
Stanley Watras
Sr. Construction Engineer
Limerick Generating Station
Boyertown, PA
-------
CLINTON INTERVIEWEES
Federal Government
Alfred "Chick" Craig
Senior Science Advisor for Radon :
Air & Energy Engineering Research Laboratory
US Environmental Protection Agency !
Research Triangle Park, NC
State Government
Mary Cahill :_
Radiation Physicist
Radiation Protection Branch .
NJ Department,of .Environmental Protection
Trenton, NJ
Donald A. Deieso
Assistant Commissioner for Environmental
Management and Control- ;
NJ Department of Environmental Protection ,
Trenton, NJ i
Judy Klotz
Coordinator of Radon Projects
Division of Occupational and Environmental Health
NJ Department of Health . J ,•
Trenton, NJ
Susan Klucharich
Formerly: Health Educator Radon Project |
Division of Occupational and Environmental Health
NJ Department of Health j
Trenton, NJ ;
Presently: Office of Patient Education
M.D. Anderson Hospital and Tumor institute :
Houston, TX '•-'-:'
Gerald P. Nicholls I
Assistant Director for Radiation Protection Programs
Radiation Protection Branch j . .
Division of Environmental Quality ' ' ; ' _
NJ Department of Environmental Protection ;
Trenton, NJ i
James Staples
Public Information Officer
NJ Department of Environmental Protection !
Trenton, NJ
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Local Government
Robert Nulman
Mayor . ' • ' .. •.".•' '
Clinton, NJ
' • • . - - .
John Beckley .
Director
Hunterdon County Health Department
Flemington, NJ ,'- '-
Contractors
Terry Brennan
Camroden Associates
Rome, NY
Jim Davidson
President
Radon Detection Services!
Ringoes, NJ
Realtors
Pat Catanzareti
Assistant Manager
Wei-chert Realtors
Clinton, NJ
Mickey Greco
Manager
Schlott Realtors
Clinton, NJ
Reporters
Jim Drautman ,
Reporter
Hunterdon Review
Clinton, NJ
Michael Drewniak
Formerly: staff Writer
Hunterdon County Democrat
Flemington, NJ
Presently: Staff Writer
The Courier-News
Flemington Bureau
Flemington, NJ
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Jeanette Rundquist
Formerly: Reporter
The Courier News
Bridgewater, NJ
Presently: Reporter
The Star-Ledger
Somerville, NJ "
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