EPA-230-09-89-066
Risk Communication
about Chemicais
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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Table of Contents
Page
1
3
11
17
33
40
Topic
Introduction/Purpose
How to Use This Manual
Introduction to Title III
What is Risk?
Commonly-Used Risk Descriptions
Characteristics of Risk
First Scenario: An Unplanned Release of a Chemical
Procedures with Hazardous Chemicals
Steps in the Emergency Plan
Where to Get Information
Sample news release
Characteristics of a Good Response
Second Scenario: Learning about Routine Releases
Emissions, Concentration, and Exposure
Determining Delayed Health Effects
Communicating Long-Term Risks
Enforcement and Citizen Involvement under Title III
Third Scenario: Storing Large Quantities
Planning for Hazardous Chemical Emergencies
Citizen Involvement in Community Risk Assessment
Conclusion/Summary
Seven Cardinal Rules of Risk Communication
Opportunity for Citizen Involvement
Personal Action Plan
Appendices
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
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Risk Communication Resource Sheet
1. State Emergency Response Commission:
Chairperson Phone
2.
Local Emergency Planning Committee:
Chairperson
Other Members
. Phone
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?
7. Which state agency/official receives reports under section 313?
8. Which state agency/official receives reports under section 312?
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Introduction
&
Purpose
Purpose
"STATE RATES HIGH IN CANCER RISK
FROM FACILITY EMISSIONS"
"PLANT CHEMICAL SPILL FORCES
HUNDREDS TO EVACUATE"
Have you seen headlines like these 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 concerns become 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 federal legislation is likely to increase public awareness
and concern especially because of the Emergency Planning and
Community Right-to-Know Act, which is Title III of the 1986
amendments to the "Superfund" Act.
Title III 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.
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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 III
establishes an ongoing forum at the local level for community
discussion and 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.
Preview 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 of incidents that cause
citizens to seek out local officials. We will begin with an
accident, then expand 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 Manual
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.
• 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 answer them.
• Identify opportunities for all sectors of the community to
participate in decisionrnaking about potential risks from
hazardous chemicals.
The manual is written so that later topics build on material
presented earlier. Those using the manual for self-study will
need to identify the local and state resources described in this
manual.
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 of 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.
—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.
—Facilities having more than certain quantities of any of the 366
Extremely Hazardous Substances must make themselves
known to SERCs and participate in the LEPC.
—As noted, facilities where hazardous chemicals are present in
certain quantities must submit MSDSs and inventories of the
chemicals to SERCs, LEPCs and local fire departments. An
MSDS describes the physical and chemical properties of the
substance as well 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 to 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, water, or land. The reports are
sent to the federal Environmental Protection Agency (EPA)
and to the designated state agencies. Citizens also have
access to these reports.
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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.
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 well as 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 often when people talk about
hazardous chemicals in the community.
What is risk? A convenient definition is:
The likelihood of injury, disease, or death.
Environmental risk then refers to
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 above. When experts are
asked to describe or characterize a risk, they use statements
like these:
• There is a lifetime risk of 1 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 1Q-7 (1 10-millionth,
or 1 in 10 million.)
• The risk to children is high relative to that for adults.
• 25,000 people die each year from at-home injuries.
• The risk of death from leukemia is 1 in 12,500 people per
year.
• The risk of cancer from indoor air is 600 times the risk from
tap water.
• An airplane crash involving 100 or more deaths is likely to
occur once in two years.
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• The risk to this neighborhood from chemical releases at
Facility 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 the 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 risk that make it seem "riskier" to most people and gives brief
examples.
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Table 1: Characteristics of Risk
(Factors on Right increase Perception of Riskiness)
Voluntary
Driving a car
Natural <-
Radon in basement
Familiar
Household
cleansers
Chronic
Routine small
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
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
person 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, or they will not succeed in working
with the community to make good decisions about risk
reduction.
We also know that most people seek information about
hazardous chemicals only when something happens to make
them interested or cause them to believe that they are directly
affected.
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Scenario 1: Unplanned Release of a Chemical
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
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Scenario 1: Unplanned Release of a Chemical
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 Managementtelling you thatachlorine tank in the
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 air circulation 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.
Within fifteen minutes, your telephone starts ringing with questions from
frantic parents and the media. What should 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 likely to call you?
To answer people's questions, you must first know about the
plans and procedures for emergencies involving hazardous
chemicals.
1. SARA Title II! requires any facility that stores any of 366
Extremely Hazardous Substances in amounts 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 of Title III described above on
page 4.) A list of the Extremely Hazardous Substances
appears in Appendix 5.
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.
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:
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Scenario 1: Unplanned Release 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 limit 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 plan. 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
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Scenario 1: Unplanned Release of a Chemical
Where to get
Information to
answer these
questions.
Questions after
the event
questions. This person's name and especially phone number
should be emphasized to the media before any accidents occur.
(Many facilities are designating a particular contact person and
inviting the media to meet with that person 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 the 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 to the Local Emergency
Planning Committee (LEPC)? Who is chairman of the LEPC
and what is the role of the LEPC during an emergency?
e. WJiat are other sources of information to answer citizens'
questions?
In short, officials need to be familiar enough with local
procedures to be able to tell callers where 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 period and not during an emergency -
see Appendix 4.)
Another series of questions will arise after the event. Among the
most likely to be asked are:
a. How did this happen?
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?
d. What are you doing to prevent it from happening again?
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Scenario 1: Unplanned Release of a Chemical
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.
About 100 pounds of chlorine gas were accidentally released in the
basement of North High yesterday when a storage tank began to leak du ring
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 after effects 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
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Scenario 1: Unplanned Release of a Chemical
Characteristics
of a good answer
School Board has agreed that transfer of chlorine will no longer be done
during school hours. Chlorine is also stored in large quantities at city
swimming pools and water and wastewater treatment plants. We 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:
—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
—describe the health effects suffered 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 their physical properties and possible health effects.
Some of these sources are listed in Appendix 2. Many public
libraries and local emergency response departments have
reference books that provide some of this information. The
Material Safety Data Sheets (MSDSs) that facilities must supply
to the LEPC on request also contain this information. EPA and
several private companies maintain computerized databases
with chemical information. CAMEO™, a computer program
developed with assistance from EPA, contains information
about more than 2700 chemicals. The National Library of
Medicine has toxicological information in computer databases
called TOXNET. These sources seldom 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.
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Scenario 1: Unplanned Release of a Chemical
Summary
Citizens' concerns 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
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.
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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 of 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) were benzene (200,000), chlorine
(100,000), pyridine (10,000) and ammonia (15,000).
Benzene is a known carcinogen. Chlorine 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 a 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 reports submitted by fifteen local
manufacturing facilities under the requirements of a federal law, the
Emergency Planning and Community Right 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.
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 automobiles 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
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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
• emissions, concentration, exposure, and dose
• toxicity
• acute, high-level vs. long-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 ill, 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
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Scenario 2; Routine Releases
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 air and water. The concentration is the
amount of the substance in a representative unit of the air,
water, or land. For example, due to automobile exhaust,
benzene may be found in the air of many cities in a
concentration of about 8 parts per billion. 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 emission source.
Exposure happens when an individual comes in contact with a
substance Exposure can occur through breathing, drinking,
eating, and by direct skin contact. The 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 which emissions might lead to
exposure. At each point, there are 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 the body to break down the
substance.
Toxicity is a measure of how harmful a substance is to human
health or to plants or animals. Highly toxic substances have
adverse health effects at smaller doses.
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.
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 ife Qn ground
„, , , Uptake by
Sption / *>"* foods
from
Aquatic food ingestion
/ / I
Volatilization from
water to air .
\X
Dermal
absorbtion
from soil
Water ingestion
From "Assessing Risk at Superfund Sites,"
prepared by CH2M HILL
20
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Scenario 2: Routine Releases
Determining delayed
health effects
Acute or short-term exposures may have immediate or acute
effects and may have long-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.
Long-term, low level exposures also 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 delayed 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 effect.
Many people disregard laboratory studies because animals are
exposed to quantities of the substance that are so much higher
than humans ever would receive. Laboratory studies 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 more 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.
Some laboratory studies are conducted on tiny organisms in test
tubes. Scientists have learned that substances that affect the
growth of these organisms often have adverse human health
effects. Usually these "in vitro" ("in glass") studies are used to
screen chemicals; those that seem suspicious are further tested
on animals ("in vivo").
21
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c
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 risk for 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 "risk" 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 likely is it to happen
22
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Scenario 2°. Routine Releases
Risk levels
Toxicity
Expected number of deaths or disease per
year
How strong is the effect of exposure on
human health
(Adapted from Hance, Chess, and Sandman, "Improving Dialogue With
Communities" p. 64.)
In answering questions, people often confuse these factors
when attempting to put risks into context. In addition to these
risk factors, other characteristics we 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.
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.
3) Any comparisons of these concentrations with existing
government standards or other directly comparable
information. (Caution: Be careful when providing
comparisons with risks from other chemicals or activities. 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 between 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 Covello, Sandman, and Slovic
book mentioned in Appendix 2 gives 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 likely to be perceived as less
risky than unfamiliar or exotic ones. The multi-syllabic name
of a chemical, in contrast, might increase concern.
23
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c
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. Because 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
lower levels may have."
2) Are these emissions the cause of my unwanted health
effects?
Causation is the most difficult question officials are called upon
to consider. Except in well-conducted laboratory experiments,
causation 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 rate at which people will experience the unwanted
health effects, but can never tell which individuals will get sick.
Local officials should know how to get more information,
including specialists to whom they can refer these more specific
questions.
24
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Scenario 2- Routine Releases
Additional
Responses
How Safe Am B?
• Several books are available in most public libraries. Among
them is the Concise Chemical Dictionary. 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 people by emphasizing the
difficulties in 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 four kinds 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 emissions through the LEPC.
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 widely. 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 provide information about risk
measurement, but each person must decide for himself or
25
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c
Scenario 2: Routine Releases
Other questions
about Scenario 2
herself whether a risk is acceptable—that is, whether
something seems "safe."
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 LEPC.
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?"
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
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Scenario 2°. Routine Releases
Present System
for Regulating
Emissions
To answer question 3, we need to know about the present
system for regulating emissions. Answering questions 4 and 5
requires obtaining and analyzing new information.
The Present System for Regulating Emissions
It is difficult to answer the question about why plants are allowed
to emit hazardous substances because of the intricacies of the
federal and state laws regulating toxic chemicals. Although the
emissions of many chemicals are indirectly controlled by air,
water, or land disposal regulations, few are subject directly to
specific federal emission permits or standards. Most EPA
regulations deal with ambient levels of chemicals (in other
words, they specify acceptable concentrations in the
community's air or drinking water — not the amounts of the
chemicals that can be released from a particular facility).
Where EPA does have regulations based on emissions, they
generally apply to classes of chemicals (volatile organic
compounds and particulate matter in the case of air; total
suspended solids and certain types of waste streams for water).
And in the handful of cases where EPA has established
emission permits or standards for specific chemicals, they apply
only to certain industries — not to all companies emitting those
chemicals. For example, EPA has established a national air
emission standard, or NESHAP, for benzene; but it applies only
to certain industries and to certain processes within those
industries. Therefore, to determine whether a particular
company is complying with the benzene standard, you would
need to know first, if the company is among the industries
subject to the standard; second, which of its processes are
regulated; and third, what percentage of the reported releases
are emitted from those processes.
Citizens may ask whether all the emissions have been reported.
The answer is no. Some facilities are not covered by the
requirements of Title III; others may not know that they need to
report; and still others may have decided not to do so.
27
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c
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
lists 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
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Scenario 2: Routine Releases
agencies are learning about emissions they may not have known about
before. This will provide a better basis for appropriate policy responses.
Because the information is also available to citizens, they have an
opportunity to participate in policymaking concerning emissions to a
greater extent than before. One way they can participate is by becoming
active in the Local Emergency Planning Committee."
To answer question 4—Is a particular facility in compliance
with state and federal laws? will require review of reports filed
by the facility with EPA or the appropriate state agency. Local
officials can provide citizens with telephone numbers where they
can obtain answers.
The answer to question 5—"Are there other facilities in the
area that have not reported that are also emitting these
substances?"— is largely procedural, although it should have
some substantive information if available:
"Probably. The Local Emergency Planning Committee, interested citizens,
and government agencies can use other information provided under Title III
and other laws to try to identify facilities that may be emitting substances.
Industry associations are also trying to get word out to their members
about the obligation to report. Citizens who live near manufacturing
facilities can certainly check with EPA or the [appropriate state agency that
receives reports under section 313] to see whether neighboring facilities
have reported. If not, they may talk to the facility manager to find out why.
Remember, section 313 covers only some chemicals, so many facilities
may have emissions they do not need to report. Also, facilities need not
report if they use chemicals in amounts below specified quantities. Among
the kinds of facilities that emit this chemical but are not included in the Title
III requirement are . Because there are many such facilities in our
community, there may be some cause for concern."
6) What other sources might lead to my being exposed to
these chemicals?
The answer to this question is related to the answer to question
5, but can be based more closely on the data available under
sections 312 and 313. The chemical inventories submitted to
the LEPC under section 312 tell what chemicals are stored in
the community, thereby providing some indication of the range
of possible exposures. More important, the emissions data
provided under section 313 provide some basic information
about which chemicals are disposed to which medium. If
aggregated for the whole community, these data can suggest
29
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c
Scenario 2: Routine Releases
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 at 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 on
how to get access to the TRI database. SERCs also have
access to a similar database maintained at EPA, and may be
able to provide some data to questioners.
30
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Scenario 2: Routine Releases
Summary of
Scenario 2:
Routine Emissions
Citizen concerns about the routine emissions reported under
Title III section 313 and described in the newspaper article
cover a broad range of complex issues. Officials without
specific expertise in these areas should not attempt to explain
the details, instead referring questioners to appropriate expert
sources. On the other hand, they should anticipate questions
and prepare replies, since citizens may become angry if
constantly told, "I cannot answer that. Please call so-and-so."
But don't make up an answer when you don't know.
Among the strategies for responding to questions about long-
term health effects where there is uncertainty about whether the
particular chemical causes a health effect and/or about whether
the emissions in question are related to particular citizens'
health problems are the following:
1. Risks or risk levels should be compared at two different
times, compared against a government standard, or compared
with different estimates of the same risk. Note that comparisons
with government standards, which are set using a combination
of political and scientific criteria, may be misleading—it is not
true that everything less than the standard is "safe" while
everything over it is "unsafe." Different risks, especially risks
with different characteristics, should not be compared. (See
above, page 8. For more on risk comparison, see Covello,
Sandman, and Slovic, "Risk Communication, Risk Statistics,
and Risk Comparisons.")
2. Questions of "safety" are difficult to answer, especially on the
basis of section 313 emiissions data alone. Different people
assess safety differently. However, statements describing how
you would or are behaving in the same circumstances in
combination with a description of the risk provide listeners with a
basis for their own comparisons. People should have an
opportunity to participate in determining whether existing levels
of safety are sufficient.
3. Concern about risks may really reflect concerns about power
or other political issues. Try to ascertain people's real concerns
and answer those. Many concerns are really about whether
procedures are fair and allow for adequate participation. Use
the Local Emergency Planning Committee (LEPC) as a forum
for all parties to work together.
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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 LEPC 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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Scenario 3: Storing Large Quantities
Scenario 3
Storing Large Quantities
About six weeks after publication of the article on emissions
data, the following article appears in the local newspaper.
Our city Daily News
100 of 366 Extremely Hazardous Substances
Present in Ourcity
Possibility of Serious Accidents Great
Emergency planning based on reports, but
only 70 reports filed: How 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.
Seventy different facilities in New County have reported that they store
these chemicals. Thirty of the chemicals are stored or used in quantities
greater than 100,000 pounds. Forty facilities reported using chlorine, the
chemical that spilled three months ago in the North High basement
causing the evacuation of 1100 students and teachers. The New County
Local Emergency Planning Committee, established under a new federal
law designed to prevent chemical accidents, 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
causing serious human harm. Facilities must report these and many
other hazardous chemicals under the federal Emergency Planning and
Community Right-to-Know Act. The reports 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 learned lhat:
• 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 all the facilities have reported that
should have.
33
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Scenario 3: Storing Large Quantities
Citizens' Questions
• Forty facilities store substances in quantities greaterthan 100 thousand
pounds, and some as much as 1 million pounds. If storage containers
leak, large quantities of chemicals could leach into the airorgroundwater.
Accidents involving many people are possible, mostly from fire or
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. According to a 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 leaking.
Industry spokesmen emphasized the care they use in storing and
working 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
with facilities to reduce the possibility of accidents further. They stated
that the emergency response plan updated under the same federal law
that requires submission of chemical inventories also ensures citizens'
safety.
Neighbors of plants are not so sure. "About once a month I hearthe sirens
overthere,"says Sharon Shivers, who lives in the Northridge neighborhood
near the Generic plant. "I think their storage is faulty but they don't want
us to know."
After reading this article, citizens might ask the following
questions:
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?
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Scenario 3: Storing Large Quantities
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 require 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 considered—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.
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. (The components of a
community-wide plan are described on page 12.)
Figure 2 shows a sample hazards analysis for an extremely
hazardous chemical at one site. If such an analysis is conducted
for all hazardous chemicals found in 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. VULNERABIUTY ANALYSIS
a. Vulnerable zone
b. Population within vulnerable zone
c. Essential services within zone
3. RISK ANALYSIS
(Initial Evaluation of Reporting
Facilities—Relative Hazards)
Chlorine
Water treatment plant
800 Ibs.
Poisonous; may be fatal if inhaled. Respiratory
conditions aggravated by exposure. Contact
may cause burns to skin and eyes. Corrosive.
Effects may be delayed.
A spill of 800 Ibs. of chlorine from a storage tank
could result in an area of radius-greater than 10
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-400 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—high
J
36
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REEVALUATION(PLANNING)
1. HAZARDS IDENTIFICATION
a. Chemical
b. Location
c. Maximum quantity that
could be released
d. Properties
2. VULNERABILITY 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. Consequences of environmental
exposure
e. Summary: likelihood/severity of
on site
Chlorine
No change
500 Ibs. (decrease)
No change
Zone decreases (new radius -1.0 miles) due to
smaller quantity released and use of urban dis-
persion model.
Decreases; total population in vulnerable zone is
12:50
None
Low-because chlorine is stored in an area with
leak detection equipment in 24 hour service with
alarms. Protective equipment is kept outside
storage room.
High levels of chlorine gas in the nursing home
arid factory could cause death and respiratory
distress. Bed-ridden nursing home patients are
especially susceptible. High severity of
consequences. However, gas is unlikely to
reach a nursing home under reevaluated release
conditions.
Possible superficial damage to facility
equipment and structures from corrosive fumes
(repairable).
Possible destruction of surrounding fauna and
flora.
Low/High. (The community would assess this
on a site- and incident-specific basis.)
37
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c
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
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Summary
The kinds of questions that storage raises are hard 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 time-
consuming work. After the data are obtained, citizens will still
have to work with experts to determine whether storage
methods and quantities are appropriate and whether health
effects are worrisome.
Rather than providing sample answers, as we did in the other
scenarios, we can offer only general suggestions:
Officials can best answer most of these questions by
—referring to the plan and the procedures that went into
creating it, and
—referring to the sources within government where citizens
can work with government and industry.
39
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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.
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
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4. Be Honest, Frank and Open
* State your credentials; but do not ask or expect to be
trusted.
* If you do not know the answer or are uncertain, say so.
Get back to people with answers. Admit mistakes.
* Disclose risk information as soon as possible.
* Do not minimize 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.
5. Coordinate and Collaborate with Other Credible
Sources
* Take time to coordinate with other organizations or
groups.
* Devote effort and resources to the slow, hard work of
building bridges with other organizations.
* Try to issue communications jointly with other credible
sources.
Few things make risk communication more difficult than
conflicts or public disagreements with other credible sources.
6. Meet the Needs of the Media
* Be open with and accessible to reporters; respect their
deadlines.
* Provide risk information tailored to the needs of each
type of media.
* Prepare in advance and provide background material on
complex issues.
* Do not hesitate to follow up on stories with praise or
criticism.
* Try to establish long-term relationships of trust with
specific editors and reporters.
The media are frequently more interested in politics than in
risk; more interested in simplicity than in complexity; more
interested in danger than in safety.
7. Speak Clearly and with Compassion
Technical information and jargon are barriers to successful
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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 seern 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
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Opportunity for
Citizen Involvement
Plan of Action
One of the most important factors that affects people's
perceptions of risk is whether they feel in control. That is why
several of our suggestions for response to citizen questions,
especially when the questions cannot be answered with
unequivocal scientific information, is to offer people a means for
participating in decisionmaking about chemicals in their
communities. Local Emergency Planning Committees (LEPCs)
offer, or should offer, a logical place for such participation.
Because LEPCs include representatives from government,
industry, and citizen groups, they offer a good setting for
encouraging the different interests to work together.
Risk communicators should take every opportunity to suggest
direct ways in which individuals can take control to reduce their
exposures to hazardous chemicals, such as standing upwind
while filling the gas tank of an automobile.
Perhaps the single most important factor in communicating risks
is that the source be perceived as trustworthy and willing to
listen as well as talk. Other kinds of communication also benefit
from these characteristics. Public officials can improve their
effectiveness in many areas by learning the lessons of risk
communication: develop a relationship of trust with people
before some particular incident (such as a chemical spill)
occurs, and talk with, riot lp_, citizens. Although time-consuming,
this strategy will more than repay the costs when what would
otherwise be a divisive community issue is settled through
compromise and negotiation.
We have covered the things you need to do to more effectively
fulfill your role as a "risk communicator." How can you best use
this information back on the job?
Unfortunately, there is no "formula" or "master plan" that will
provide rote answers to every question you may ever face in
risk communications. The following steps are suggested,
however, as actions you can take starting today that will help
prepare you for your responsibilities in this area:
1. Set a time by which you will have filled in all of the
information on the "Risk Communication Resource Sheet" in the
front of the manual. Some of the information you already have;
43
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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 manual in 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 G. 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
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APPENDIX 1
Glossary of Commonly Used Terms
Absorbed dose--The amount of a chemical that enters the body of an organism.
Acute-Sharp, severe; having a rapid onset, severe symptoms, and a relatively short duration.
Acute exposure: a single exposure of relatively short duration.
Acute toxicity: the development of adverse health effects soon after a single exposure to a
substance.
Additive effect-Combined effect of two or more chemicals equal to the sum of their individual effects.
Ambient-Environmental or surrounding conditions.
Animal studies (sometimes called "laboratory studies")~lnvestigations using animals as surrogates
for humans, on the expectation that results in animals are pertinent to humans.
ATSDR-Agency for Toxic Substances and Disease Registry, part of the U.S. Public Health Service,
based in Atlanta, Georgia, 30333.
Carcinogen-A chemical that causes or induces cancer.
CAS registration number~A number assigned by the Chemical Abstracts Service to identify a
chemical.
Chronic-Occurring over a long period of time, either continuously or intermittently.
Chronic effect-effects that last a long time even if caused by a single acute exposure. (See also
delayed effect.)
Chronic exposure-long-term, low-level exposure to a to a chemical.
Concentration-the amount of the substance in a representative unit of the medium.
Delayed effect-an effect of exposure that does not occur for some time. Sometimes called a "chronic"
effect.
Dose-The amount of the sbustance that actually enters the body.
Dose-response-A quantitative relationship between the dose of a chemical and an effect caused by the
chemical.
Dose-response curve-graphical presentation of the relaioriship between degree of exposure to a
chemical (dose) and observed biological effect or response.
Emission or release-the amount of a substance released from a facility. Releases are usually
classified as routine-small regularly-released amounts that are planned to be released as part of a
manufacturing process-and accidental.
Endangerment assessment~a site-specific risk assessment of the actual or potential danger to human
health or welfare and the environment from the release of hazardous substances or waste. The
endangenment assessment document is prepared in support of enforcement actions under CERCLA or
RCRA.
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Environmental fate--The destiny of a chemical after release to the environment; involves
considerations such as transport through air, soil, and water; bioconcentration; degradation.
EPCRA--The Emergency Response and Community Right-to-Know Act of 1986; same as SARA Title III.
Epidemiological studies-Investigation of factors contributing to disease or adverse health effects in
human populations.
Exposure-Trie contact with a chemical 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 chemical in 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.
-In 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.
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Permissible dose-The dose of a chemical that may be received by an individual without the expectation
of a significantly harmful result.
RCRA--Resource Conservation and Recovery Act. Another federal statute concerning hazardous
substances.
Release-see "Emission."
Reversible effect~An effect that is not permanent; an especially adverse effect that diminishes when
exposure to a toxic chemical ceases.
Risk--The likelihood of injury, disease, or death.
Risk assessment-A qualitative or quantitative evaluation of the environmental and/or health risk
resulting from exposure to a chemical or physical agent (pollutant); combines exposure assessment
results with toxicity assessment results to estimate risk.
Risk estimate--A description of the probability that organisms exposed to a specified dose of chemical
will develop an adverse response (e.g., cancer).
Risk factor-Characteristic (e.g., race, sex, age, obesity) or variable (such as smoking, occupational
exposure level) associated with increased probability of an adverse health effect.
Route of exposure-the avenue by which a chemical comes into contact with an organism (e.g.,
inhalation, ingestion, dermal contact, injection).
SARA-Superfund Amendments and Reauthorization Act of 1986.
SERC-State Emergency Response Commission. Established under Title III.
Teratogenicity-The capacity of a physical or chemical agent to cause hereditary congenital
malformations (birth defects) in offspring.
Threshold-The lowest dose of a chemical at which a specifed measurable effect is observed and below
which it is not observed.
Title Ill-the common name for the Emergency Planning arid Community Right to Know Act of 1986,
which is Title III of the Superfund Amendments and Reauthorization Act.
Toxicity-The quality or degree of being poisonous or harmful to plant, animal, or human life.
TRI-Toxics (or Toxic Chemical) Release Inventory. The database containing annual toxic chemical
release reports submitted by certain manufacturing facilities, specified in Section 313 of EPCRA.
The TRI is available to the public in county libraries, through a national computerized database
maintained by the National Library of Medicine, and through regional EPA offices. See Appendix 2
for more information.
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APPENDIX 2
References and Sources
1. Title HI
Environmental Protection Agency. It's Not Over in October: A Guide for Local Emergency Planning
Committees. September 1988, written by thirteen organizations, representing federal, industry and trade
associations, public interest groups, and others.
Environmental Protection Agency. Chemicals in Your Community. September 1988.
Environmental Protection Agency. Community Right-to-Know and Small Business. September 1988.
Environmental Protection Agency. Toxic Chemical Release Inventory: Risk Screening Guide. July 1989.
Chemical Manufacturers Association. Title III Community Awareness Workbook.
Chemical Manufacturers Association. Community Guide to Title III.
Hadden, Susan G. A Citizen's Right to Know: Risk Communication and Public Policy. Boulder: Colo.:
Westview Press, 1989.
National Wildlife Federation. Reducing the Risk of Chemical Disaster: A Citizen's Guide to the Federal
Emergency Planning and Community Right to Know Act.
Working Group on Community Right to Know. What is the Emergency Planning and Community Right to
Know Act?
2. About Risk Communication
American Chemical Society, Department of Governmental Relations and Science Policy. A Handbook on
Chemical Risk Communication: Preparing for Community Interest in Chemical Release Data. Draft IV, 1
July 1988.
Covello, Vincent T., David B. McCallum and Maria Pavlova. Effective Risk Communication: The Role and
Responsiblity of Government and Nongovernment Organizations. Proceedings of the Workshop on the
Role of Government in Health Risk Communication and Public Education. New York:Plenum Press, 1988.
Covello, Vincent, Peter Sandman, and Paul Slovic. Risk Communication, Risk Statistics, and Risk
Comparisons: A Manual for Plant Managers. Washington, D.C.: Chemical Manufacturers Association,
1988.
Hance, Betty, Caron Chess and Peter Sandman. Improving Dialog with Communities: A Risk
Communication Manual for Government. Trenton: New Jersey Department of Environmental Protection,
1988.
Krimsky, Sheldon, and Alonzo Plough. Environmental Hazards: Communicating Risks as a Social
Process. Dover, Mass: Auburn House Publishing Co., 1988.
Sandman, Peter. Explaining Environmental Risk. Washington, D.C.: Environmental Protection Agency,
April 1986.
U.S. EPA, Office of Toxic Substances. Toxic and Hazardous Chemicals - Title III and Communities: An
Outreach Manual for Community Groups. Washington, D.C.: EPA. September, 1989.
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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.
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 toxicological 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 Doses: 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.
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Environmental Protection Agency. Toxic Chemicals: What They Are, How They Affect You. Chicago, IL:
U.S. Environmental Protection Agency, no date.
Fischhoff, Baruch, Sarah Lichtenstein, Paul Slovic, Stephen L. Derby, and Ralph Keeney (1981).
Acceptable Risk. Cambridge: Cambridge University Press.
Liroff, Richard A., Toxics in the Air. Washington, D.C.: The Conservation Foundation, 1987.
Marczewski, Alice E. and Michael Kamrin. Toxicology for the Citizen, 2nd ed. East Lansing, Ml: Michigan
State University, Center for Environmental Toxicology, 1987. (Write the Center for Environmental
Toxicology, C231 Holden Hall, Michigan State University, East Lansing, Michigan, 48824.)
Moses, Susan . Chemical Risk: A Primer. Washington, D.C.: American Chemical Society, 1984. A
pamphlet for nonscientists focuses on scientific issues involved in determining the health risks arising
from exposure to chemicals and mentions public perceptions of risk.
National Cancer Institute. Everything Doesnt Cause Cancer. Bethesda, MD: National Cancer Institute,
1984.
Ottoboni, M. ALice. The Dose Makes the Poison: A Plain-Language Guide to Toxicology. Berkeley, CA:
Vincente Books, 1984. A readable and concise introduction to risks from chemicals.
Sasnett, Sam K. A Toxics Primer. Washington, DC: League of Women Voters of the United States, no
date.
Toxicology Data Network System (TOXNET), National Library of Medicine (NLM). Online computerized
databases of toxicological information on specific chemicals. See Section 8 on databases for more
information.
Wexler, Phillip. Information Resources in Toxicology. New York: Elsvier Science Publishing Co.,1987.
Guide to literature, computer files, organizations, and activiites concerning toxicology.
5. Evaluation Methods for Use in Specific Communities
Brockbank, Brad, John Cohrsson, and Vincent T. Covello. A manual on risk assessment techniques for
decisionmakers and citizens. Washington, D.C.: Council on Environmental Quality, 1988.
CAMEO (Computer-Aided Management for Emergency Operations), (software)
Chemical Manufacturers Association.Cftem/ca/s in the Community: Methods to Evaluate Airborne Levels.
Washington, D.C.: CMA, 1988. Identifies methods used to evaluate emission leels of airborne chemicals
in the community. Intended for health professionals who can judge the most appropriate approach and
evaluate available data.
Environmental Protection Agency. Guide to Exercises in Chemical Emergency Preparedness Programs.
EPA, FEMA, and DOT. Technical Guidance for Hazards Analysis. December 1987.
National Response Team, Criteria for Review of Hazardous Materials Emergency Plans. (NRT1 -A)
May, 1988
National Response Team. Hazardous Materials Planning Guide. (NRT-1). March 1987.
Available by writing Hazmat Planning Guide, OS-120, EPA, 401 M Street, S.W., Washington, D.C. 20460.
Public Health Foundation, Environmental Health Program. Resource Guide for Environmental Health Risk
Assessment. Washington, D.C.: PHF, 1986. Organizational (Contact and other resource information to
assist professionals who are assessing risks from polluted environments.
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Rail, David P. Medicine for the Layman: Environment and Disease. Bethesda, MD: National Institutes for
HeaUh, 1982.
Sherry, Susan. High Tech and Toxics: A Guide for Local Communities. Washington DC: Golden Empire
Health Planning Center, 1985.
Working Group on Community Right to Know. Hazard Assessments and Plume Mapping Documents for
LEPCs.
6. State and Local Level Contacts and Resources (also see Appendix 4.)
Public Health Foundation, Environmental Health Program. Directory of State and Territorial Environmental
Health Services. Washington, D.C.: PHF, 1987. Updated annually and in possession of each state's
health department.
7. Waste Reduction
Irwin, Frances H. and Edwin Clark. America's Waste: Managing for Risk Reduction. Washington DC: The
Conservation Foundation, 1987.
Mufr, Warren and Joanna Underwood. Promoting Hazardous Waste Reduction: Six Steps States Can
Take. New York: INFORM, 1987.
Sarokin, David J., Warren Muir, Catherine G. Miller, and Sebastian R. Sperber, Cutting Chemical Wastes:
What 29 Organic Chemical Plants are Doing to Reduce Hazardous Wastes. New York: INFORM, 1985.
8. Databases.
National Library of Medicine (NLM), 8600 Rockville Pike, Bethesda, MD. 20894. 1-800-638-8480 or
301-496-6193. Databases are available online through a personal computer and modem connection, or
in a medical library.
TOXLINE. A collection of online bibliographic information convering the
pharmacological, biochemical, physiological, and toxicological 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
toxicology and related areas. The files include the Hazardous Substances Data Bank
(HSDB), the Registry of Toxic Effects of Chemical Substances (RTECS), 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.
CCINFOdisc is a compact disk with several toxic substances databases, including the
New Jersey Fact Sheets.
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APPENDIX 3
Brief Description of Title HI by Section
301 - establishes LEPCs and SERCs (State [Emergency Response
Commissions).
302 - requires facilities to notify the LEPC and SERC if they store more than
the threshold planning quantity of any of the extremely hazardous
substances.
303 - requires the LEPC to formulate an emergency plan.
304 - requires facilities that release more than a reportable quantity to notify
the LEPC and the SERC (and NRC for CERCLA hazardous substances).
311 - requires all facilities that store any hazardous substance in amounts
greater than 10,000 pounds (for hazardous chemicals) or 500 pounds or
the threshold planning quantity, whichever is less (for extremely
hazardous substances), to submit a chemical list or Material Safety Data
Sheet (MSDS) to the local fire department, LEPC, and SERC.
312 - requires an annual report including quantities of chemicals
characterized by hazard (Tier 1 report) or as individual chemicals (Tier II
report) to be submitted to the local fire department, LEPC, and SERC.
313 - An annual report by manufacturing facilities only of emissions to air,
water, or ground of chemicals on a list of about 300.
321 - in general, Title III does not preempt state laws; states and localities may
require supplementary information.
322 - allows manufacturers to claim chemical identity as trade secret if they
meet several conditions.
323 - allows some doctors, nurses, and public health officials to obtain even
information declared trade secret if they need it for treating patients and
they promise not to disclose the information further.
326 - provides for lawsuits under certain circumstances by citizens against
facilities that do not comply with the law and against agencies that do not
fulfill their duties, and allows state and local governments to sue facilities.
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Appendix 4
Contacts
The Emergency Planning and
Community Right-To-Know
Act of 1986
State Emergency Response
Commission/Title III
Contacts
November 1, 1989
Prepared by
The Emergency Planning and Community
Right-To-Know Information Hotline
For more information call
1-800-535-0202
(or (202) 479-2449 in the Washington, DC metro area)
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State Emergency Response Commission and
State-Designated Agencies for the
Emergency Planning and Community Right-to-Know Act
November 1, 1989
This list is the U.S. Environmental Protection Agency's listing of State Emergency
Response Commissions and State designated agencies for the Emergency
Planning and Community Right-to-Know Act. The EPA has verified each contact
individually. All addresses listed under State Commissions receive the Section
302 emergency planning notification and the Section 304 emergency release
notification unless otherwise specified. The State designated agencies receive
the submissions for the sections listed in their headings. If one address is listed
with no heading, the State commission receives all submissions for every section
of the Act. If an additional address is listed under the heading "Mailing Address,"
this address is to be used for mailings to the State Commissions other than the
P.O. boxes used for the form submissions.
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ALABAMA
State Commission:
J. Danny Cooper, Co-Chair
Alabama 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: LG. Linn (205)271-7700
E. John Williford (205) 271 -7931
ALASKA
Dennis Kelso, Chair
Alaska State Emergency Response
Commission
P.O. Box O
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
AMERICAN SAMOA
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
International Number (684) 633-2331
Section 311/312 & 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, Executive Director
Arizona Emergency Response Commission
Division of Emergency Services
5636 East McDowell Road
Phoenix, AZ 85008
(602)231-6326
ARKANSAS
State Commission:
Randall Mathis, Director
Arkansas Department of Pollution Control and
Ecology
P.O. Box 9583
8001 National Drive
Little Rock, AR 72219
(501) 562-7444
Contact: John Ward
(501)562-7444
Section 311/312 & 313 Submissions:
Becky Bryant
Depository of Documents
Arkansas Department of Labor
10421 West Markham
Little Rock, AR 72205
Contact: Becky 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
Director, Office of Emergency Services
2800 Meadowview Road
Sacramento, CA 95832
(916)427-4287
Section 302, 304, 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 Shulock
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
Stats 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):
(303) 377-6326
Section 302, 304, 311/312 & 313
Submissions:
Colorado Emergency Planning Commission
4210 East 11th Avenue
Denver, CO 80220
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, CT 06106
(203) 566-4856
DELAWARE
State Commission:
Patrick W. Murray, Chair
Delaware Commission on Hazardous Materials
Department of Public Safety
P.O. Box 818
Dover, DE 19903
Contact: George Frick (302) 736-3169
Section 302 Submissions:
Dpminick Petrilli, Acting Director
Division of Emergency Planning and
Operations
P.O. Box 527
Delaware City, DE 19706
(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 COLUMBIA
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
Contact: Eve Rainey
-------
GEORGIA
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
Atlanta, GA 30334
(404) 656-6905
Emergency Release Number (800) 241-4113
GUAM
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:
Roland Solidio
Guam EPA
P.O. Box 2999
Aguana, Guam 96910
(671)646-8863
HAWAII
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
(808) 548-2076
(808) 548-5832
Contact:
Samir Araman
Mark Ingoglia
(808) 543-8249
(808) 543-8276
Section 313 Submissions:
John C. Lewin, M.D., Chair
Hawaii State Emergency Response
Commission
Hawaii State Department of Health
P.O. Box 3378
Honolulu, HI 96801-9904
(808) 548-6505
State Commission:
Idaho Emergency Response Commission
State House
Boise, ID 83720
(208) 334-5888
Section 311/312 & 313 Submissions:
Idaho Emergency Response Commission
State House
Boise, ID 83720
Attn: Jenny Records
Contact: Jenny Records (208) 334-5888
ILLINOIS
State Commission and Section 311/312
Submissions:
Oran Robinson
Illinois Emergency Response Commission
Illinois Emergency Services & Disaster Agency
Attn: Hazmat Section
110 East Adams Street
Springfield, IL 62706
(217)782-4694
Section 313 Submissions:
Joe Goodner
Emergency Planning Unit
Illinois EPA
P.O. Box 19276
2200 Churchill Road
Springfield, IL 62794-9276
(217) 782-3637
INDIANA
Skip Powers, Director
Indiana Emergency Response Commission
5500 West Bradbury Avenue
Indianapolis, IN 46241
(317)243-5176
IOWA
State Commission & Section 302
Submissions:
Ellen Gordon, Chair
Iowa Disaster Services
Hoover Building, Level A
Room 29
Des Moines, IA 50319
(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, IA 50319
(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 Hea|th and Environment
Right-to-Know Program
Mills Building, 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: Karl Birns
KENTUCKY
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 Title 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 Sudbraok 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 Broening Highway
Baltimore, MD 21224
(301)631-3800
MASSACHUSETTS
Arnold Sapenter
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
MICHIGAN
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 55155
(612) 643-3000
MISSISSIPPI
J.E. Maher, Chair
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501
Fondren Station
Jackson, MS 39296-4501
(601)960-9973
Contact: Bill Austin
MISSOURI
Dean Martin, Coordinator
Missouri Emergency Response Commission
Missouri Department of Natural Resources
P.O. Box 3133
Jefferson City, MO 65102
(314)751-7929
Mailing Address:
Dean Martin
Missouri Emergency Response Commission
Missouri Department of Natural Resources
2010 Missouri Boulevard
Jefferson City, MO 65109
MONTANA
Tom Ellerhoff, Co-Chair
Montana Emergency Response Commission
Environmental Sciences Division
Department of Health & Environmental
Sciences
Cogswell Building A-107
Helena, MT 59620
(406)444-6911
Contact: Guy Youngblood
NEBRASKA
Clark Smith, Coordinator
Nebraska Emergency Response Commission
Nebraska Department of Environmental Control
P.O. Box 98922
State House Station
Lincoln, NE 68509-8922
(402) 471-2186
Emergency Number (After-hours): (402) 471 -
4545
NEVADA
State Commission and Section 311/312
Submissions:
Joe Quinn
Nevada Division of Emergency Management
2525 South Carson Street
Carson City, NV 89710
(702)885-4240
Emergency Release Number (After Hours &
Weekends): (702) 885-5300
/
Section 313 Submission:
Bob King
Division of Emergency Management
2525 South Carson Street
Carson City, NV 89710
(702) 885-4240
NEW HAMPSHIRE
Gerorge L. Iverson, Director
State Emergency Management Agency
Title III Program
State Office Park South
107 Pleasant Street
Concord, NH 03301
(603) 271-2231
Contact: Leland Kimball
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NEW JERSEY
State Commission:
Tony McMahon, Director
New Jersey Emergency Response
Commission
SARA Titte 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
Ssction 304 Submissions:
New Jersey Emergency Response
Commission
SARA Trtte 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 Trtte 111 Section 313
Department of Environmental Protection
Division of Environmental Quality
Bureau of Hazardous Substances Information
CN-405
Trenton, NJ 08625
(609) 292-6714
NEW 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
Section 302, 304, 311/312 & 313
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 CAROLINA
State Commission:
Joseph Myers, Chair
North Carolina Emergency Response
Commission
116 West Jones Street
Raleigh, NC 27603-1335
(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 27603-1335
(919) 733-3867
(800)451-1403 (In NC General Information
Only)
Contacts: Vance Kee
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 Rydell
-------
COMMONWEALTH of NORTHERN
MARIANA ISLANDS
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, CNMI96950
International Number (670) 322-9529
Section 313 Submissions:
Russell Meecham, III
Division of Environmental Quality
P.O. Box 1304
Saipan, CNMI 96950
(670) 234-6984
OHIO
State Commission and Section 311/312
Submissions:
Ken Schultz, Coordinator
Ohio Emergency Response Commission
Ohio Environmental 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
Emergency Response Commission
Office of Civil Defense
P.O. Box 53365
Oklahoma City, OK 73152
(405)521-2481
Contact: Aileen Ginther
OREGON
Ralph M. Rodia
Oregon Emergency Response Commission
c/o State Fire Marshall
3000 Market Street Plaza
Suite 534
Salem, OR 97310
(503) 378-2885
PENNSYLVANIA
State Commission:
Richard Rodney
Pennsylvania Emergency Response
Commission
SARA Title III Officer
PEMA Response and Recovery
P.O. Box 3321
Harrisburg, PA17105
(717) 783-8150
Emergency Release Number — 24 hours (717)
783-8150
Section 311/312 Submissions:
Pennsylvania Emergency Response ,
Commission
c/o Bureau of Right-to-Know
Rm 1503
Labor and Industry Building
7th & Forrester Streets
Harrisburg, PA 17120
(717)783-2071
Section 313 Submissions:
James Tinney
Bureau of Right -To- Know
Room 1503
Labor and Industry Building
7th & Forrester Streets
Harrisburg, PA 17120
(717) 783-2071
PUERTO RICO
Sliate Commission and Section 311/312
Submissions:
Mr. Santos Rohena, Chair
Puerto Rico Emergency Response
Commission
Environmental Quality Board
P.O. Box 11488
Sernades Juncos Station
Santurce, PR 00910
(809) 722-1175
(809)722-2173
Section 313 Submissions:
SERC Commissioner
Title III-SARA Section 313
Puerto Rico Environmental Quality Board
P.O. Box 11488
Santurce, PR 00910
(809) 722-0077
RHODE ISLAND
State Commission:
Charles Givens, Acting Executive Director
Rhode Island Emergency Response
Commission
State House Room 27
Providence, Rl 02903
(401) 277-3039
Emergency Release 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 Air and Hazardous Materials
291 Promenade Street
Providence, RI 02908
Attn: Toxic Release Inventory
(401) 277-2808
Contact: Martha Mulcahey
SOUTH CAROLINA
State Commission and Section 302
Submissions:
Stan M. McKinney, 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
Columbia, SC 29201
(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) 465-2138
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-Capitol Station
Austin, TX 78711-3087
(512) 463-8527
Contact: Priscilla Seymour
State Commission:
Lorayne Frank, Director
Comprehensive Emergency Management
P.O. Box 58136
1543 Sunnyside Avenue
Salt Lake City, UT 84158-0136
(801) 584-8370
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Section 311/312 & 313 Submissions:
Neil Taylor
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
(801)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-51
9th and Columbia Building
Oiympia, WA 98504
(206) 753-5625
Contact: Bill Bennett (206)459-9191
(800) 633-7585 (in WA)
Section 311/312 and 313 Submission:
John Ridgway, Chair
Washington State Department of Ecology
Hazardous Substance Information Office
MS-PV/11
Oiympia, WA 98504
(206) 438-7252
WEST VIRGINIA
Carl L. Bradford, Director
West Virginia Emergency Response
Commission
West Virginia Office of Emergency Services
State Capital Building 1, Rm. EB-80
Charleston, WV 25305
(304) 348-5380
Emergency Release Number (304) 348-5380
Contact: BillJopling
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, VI 00802
(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, VA23219
(804) 225-2513
WASHINGTON
State Commision:
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 7865
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 Emergency Management Agency
Comprehensive Emergency Management
P.O. Box 1709
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
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APPENDIX 5
Extremely Hazardous Substances
CAS Number Chemical Name
75865 ACETONE CYANOHYDRIN
1752303 ACETONE THIOSEMICARBAZIDE
107028 ACROLEIN
79061 ACRYLAMIDE
107131 ACRYLONITRILE
814686 ACRYLYL CHLORIDE
111693 ADIPONITRILE
116063 ALDICARB
309002 ALDRIN
107186 ALLYL ALCOHOL
107119 ALLYLAMINE
20859738 ALUMINUM PHOSPHIDE
54626 AMINOPTERIN
78535 AMITON
3734972 AMITON OXALATE
7664417 AMMONIA
300629 AMPHETAMINE
62533 ANILINE
88051 ANILINE, 2,4,6-TRIMETHYL-
7783702 ANTIMONY PENTAFLUORIDE
1397940 ANTIMYCINA
86884 ANTU
1303282 ARSENIC PENTOXIDE
1327533 ARSENOUS OXIDE
7784341 ARSENOUS TRICHLORIDE
7784421 ARSINE
2642719 AZINPHOS-ETHYL
86500 AZINPHOS-METHYL
98873 BENZAL CHLORIDE
98168 BENZENAMINE, S-(TRIFLUOROMETHYL)-
100141 BENZENE, 1-(CHLOROMETHYL)-4-NITRO-
98055 BENZENEARSONICACID
3615212 BENZIMIDAZOLE.4.5-DICHLORO-2-
(TRIFLUOROMETHYL)-
98077 BENZOTRICHLORIDE
100447 BENZYL CHLORIDE
140294 BENZYL CYANIDE
15271417 BICYCLO[2.2.1 ]HEPTANE-2-
CARBONITRILE, 5-CHLORO-6-
((((METHYLAMINO)CARBONYL)OXY)IM
534076 BIS(CHLOROMETHYL) KETONE
4044659 BITOSCANATE
10294345 BORON TRICHLORIDE
7637072 BORON TRIFLUORIDE
353424 BORON TRIFLUORIDE COMPOUND WITH
METHYL ETHER (1:1)
28772567 BROMADIOLONE
7726956 BROMINE
1306190 CADMIUM OXIDE
2223930 CADMIUM STEARATE
7778441 CALCIUM ARSENATE
8001352 CAMPHECHLOR
56257 CANTHARIDIN
51832 CARBACHOL CHLORIDE
26419738 CARBAMIC ACID, METHYL-, O-(((2,4-
DIMETHYL-1.3-DITHIOLAN-2-
METHYL)METHYLENE)AMINO)-
1563662 CARBOFURAN
75150 CARBON DISULFIDE
786196 CARBOPHENOTHION
57749 CHLORDANE
470906 CHLORFENVINFOS
7782505 CHLORINE
CAS Number
Chemical Name
24934916 CHLORMEPHOS
999815 CHLORMEQUAT CHLORIDE
79118 CHLOROACETIC ACID
107073 CHLOROETHANOL
627112 CHLOROETHYL CHLOROFORMATE
67663 CHLOROFORM
542881 CHLOROMETHYL ETHER
107302 CHLOROMETHYL METHYL ETHER
3691358 CHLOROPHAC1NONE
1982474 CHLOROXURON
21923239 CHLORTHIOPHOS
10025737 CHROMIC CHLORIDE
10210681 COBALT CARBONYL
62207765 COBALT, ((2,2'-(1,2-ETHANEDIYLBIS
(NITRILOMETHYLIDYNE))BIS(6-
FLUOROPHENOLATO))
64868 COLCHICINE
56724 COUMAPHOS
5836293 COUMATETRALYL
95487 CRESOL, o-
535897 CRIMIDINE
4170303 CROTONALDEHYDE
123739 CROTONALDEHYDE, (E)-
506683 CYANOGEN BROMIDE
506785 CYANOGEN IODIDE
2636262 CYANOPHOS
675149 CYANURIC FLUORIDE
66819 CYCLOHEXIMIDE
108918 CYCLOHEXYLAMINE
17702419 DECABORANE(14)
8065483 DEMETON
919868 DEMETON-S-METHYL
10311849 DIAL1FOR
19287457 DIBORANE
111444 DICHLOROETHYL ETHER
149746 DICHLOROMETHYLPHENYLSILANE
62737 DICHLORVOS
141662 DICROTOPHOS
1464535 DIEPOXYBUTANE
814493 DIETHYL CHLOROPHOSPHATE
1642542 DIETHYLCARBAMAZINE CITRATE
71636 DK3ITOXIN
2238075 DIGLYCIDYL ETHER
20830755 DK3OXIN
115264 DIMEFOX
60515 DIMETHOATE
2524030 DIMETHYL
PHOSPHOROCHLORIDOTHIOATE
77781 DIMETHYL SULFATE
75183 DIMETHYL SULFIDE
99989 DIMETHYL-p-PHENYLENEDIAMINE
75785 DIMETHYLDICHLOROSILANE
57147 DIMETHYLHYDRAZINE
644CJ44 DIMETILAN
534521 DINITROCRESOL
88857 DINOSEB
1420071 DINOTERB
78342 DIOXATHION
82666 DIPHACINONE
152169 DIPHOSPHORAMIDE, OCTAMETHYL-
298044 DISULFOTON
514738 DITHIAZANINE IODIDE
541537 DITHIOBIURET
-------
CAS Number Chemical Name
316427 EMETINE, DIHYDROCHLORIDE
115297 ENDOSULFAN
2778043 ENDOTHION
72208 ENDRIN
106898 EPICHLOROHYDRIN
2104645 EPN
50146 ERGOCALCIFEROL
379793 ERGOTAMINETARTRATE i
1622328 ETHANESULFONYL CHLORIDE, 2-
CHLORO-10140871 ETHANOL, 1,2-
DICHLORO-, ACETATE \
563122 ETHION
13194484 ETHOPROPHOS
538078 ETHYLBIS(2-CHLOROETHYL)AMINE
371620 ETHYLENE FLUOROHYDRIN
75218 ETHYLENE OXIDE
107153 ETHYLENEDIAMINE
151564 ETHYLENEIMINE
542905 ETHYLTHIOCYANATE
22224926 FENAMIPHOS
122145 FENITROTHION
115902 FENSULFOTHION
4301502 FLUENETIL
7782414 FLUORINE
640197 FLUOROACETAMIDE
144490 FLUOROACETIC ACID
359068 FLUOROACETYL CHLORIDE
51218 FLUOROURACIL
944229 FONOFOS
50000 FORMALDEHYDE
107164 FORMALDEHYDE CYANOHYDRIN
23422539 FORMETANATE HYDROCHLORIDE
2540821 FORMOTHION
17702577 FORMPARANATE
21548323 FOSTHIETAN
3878191 FUBERIDAZOLE
110009 FURAN
13450903 GALLIUM TRICHLORIDE
77474 HEXACHLOROCYCLOPENTADIENE
4835114 HEXAMETHYLENEDIAMINE, N.N'-DIBUTYL-
302012 HYDRAZINE
74908 HYDROCYANIC ACID
7647010 HYDROGEN CHLORIDE (Gas Only)
7664393 HYDROGEN FLUORIDE
7722841 HYDROGEN PEROXIDE (Conc.> 52%)
7783075 HYDROGEN SELENIDE
7783064 HYDROGEN SULFIDE
123319 HYDROQUINONE
13463406 IRON, PENTACARBONYL-
297789 ISOBENZAN
78820 ISOBUTYRONITRILE
102363 ISOCYANIC ACID, 3,4-DICHLOROPHEN YL
ESTER
465736 ISODRIN
55914 ISOFLUORPHATE
4098719 ISOPHORONE DIISOCYANATE
108236 SOPROPYL CHLOROFORMATE
625558 ISOPROPYL FORMATE
119380 ISOPROPYLMETHYLPYRAZOLYL
DIMETHYLCARBAMATE
78977 LACTONITRILE
21609905 LEPTOPHOS
541253 LEWISITE
58899 LINDANE
7580678 LfTHIUM HYDRIDE
109773 MALONONITRILE
CAS Number
Chemical Name
12108133 MANGANESE, TRICARBONYL
METHYLCYCLOPENTADIENYL
51752 MECHLORETHAMINE
950107 MEPHOSFOLAN
1600277 MERCURIC ACETATE
7487947 MERCURIC CHLORIDE
21908532 MERCURIC OXIDE
10476956 METHACROLEIN DIACETATE
760930 METHACRYLIC ANHYDRIDE
126987 METHACRYLONITRILE
920467 METHACRYLOYL CHLORIDE
30674807 METHACRYLOYLOXYETHYLISOCYANATE
10265926 METHAMIDOPHOS
558258 METHANESULFONYL FLUORIDE
950378 METHIDATHION
2032657 METHIOCARB
16752775 METHOMYL
51382 METHOXYETHYLMERCURIC ACETATE
80637 METHYL 2-CHLOROACRYLATE
74839 METHYL BROMIDE
79221 METHYL CHLOROFORMATE
624920 METHYL DISULFIDE
60344 METHYL HYDRAZINE
624839 METHYL ISOCYANATE
556616 METHYL ISOTHIOCYANATE
74931 METHYL MERCAPTAN
3735237 METHYL PHENKAPTON
676971 METHYL PHOSPHONIC DICHLORIDE
556649 METHYL THIOCYANATE
78944 METHYL VINYL KETONE
502396 METHYLMERCURICDICYANAMIDE
75796 METHYLTRICHLOROSILANE
1129415 METOLCARB
7786347 MEVINPHOS
315184 MEXACARBATE
50077 MITOMYCIN C
6923224 MONOCROTOPHOS
2763964 MUSCIMOL
505602 MUSTARD GAS
13463393 NICKEL CARBONYL
54115 NICOTINE
65305 NICOTINE SULFATE
7697372 NITRIC ACID
10102439 NITRIC OXIDE
98953 NITROBENZENE
1122607 NITROCYCLOHEXANE
10102440 NITROGEN DIOXIDE
62759 NITROSODIMETHYLAMINE
991424 NORBORMIDE
OORGANORHODIUM COMPLEX(PMN-82-
147)
630604 OUABAIN
23135220 OXAMYL
78717 OXETANE, 3,3-BIS(CHLOROMETHYL)-
2497076 OXYDISULFOTON
10028156 OZONE
1910425 PARAQUAT
2074502 PARAQUAT METHOSULFATE
56382 PARATHION
298000 PARATHION-METHYL
12002038 PARIS GREEN
19624227 PENTABORANE
2570265 PENTADECYLAMINE
79210 PERACETICACID
594423 PERCHLOROMETHYLMERCAPTAN
108952 PHENOL
97187 PHENOL, 2,2'-THIOBIS(4,6-DICHLORO-
-------
CAS Number
4418660
Chemical Name
PHENOL, 2,2'-THIOBIS[4-CHLORO-6-
METHYL-
64006 PHENOL, 3-(1-METHYLETHYl)-,
METHYLCARBAMATE
58366 PHENOXARSINE, 10,10'-OXYDI-
696286 PHENYL DICHLOROARSINE
59881 PHENYLHYDRAZINE HYDROCHLORIDE
62384 PHENYLMERCURY ACETATE
2097190 PHENYLSILATRANE
103855 PHENYLTHIOUREA
298022 PHORATE
4104147 PHQSACETIM
947024 PHOSFOLAN
75445 PHOSGENE
732116 PHOSMET
13171216 PHOSPHAMIDON
7803512 PHOSPHINE
2703131 PHOSPHONOTHIOIC ACID,,METHYL-, O-
ETHYLO-(4-
(METHYLTHIO)PHENYL) ESTER
50782699 PHOSPHONOTHIOIC ACID, METHYL-, S-(2-
(BIS(1 -METHYLETHYL)AMINO)ETHYL) O-
ETHYL ESTER
2665307 PHOSPHONOTHIOIC ACID, METHYL-,O-(4-
NITROPHENYL) 0-PHENYL ESTER
3254635 PHOSPHORIC ACID, DIMETHYL 4-
(METHYLTHIO) PHENYL ESTER
2587908 PHOSPHOROTHIOIC ACID.O.O-DIMETHYL-
5-(2-(METHYLTHIO)ETHYL)ESTER
7723140 PHOSPHORUS
10025873 PHOSPHORUS OXYCHLORIDE
10026138 PHOSPHORUS PENTACHLORIDE
1314563 PHOSPHORUS PENTOXIDE
7719122 PHOSPHORUS TRICHLORIDE
57476 PHYSOSTIGMINE
57647 PHYSOSTIGMINE, SALICYLATE (1:1)
124878 PICROTOXIN
110894 PIPERIDINE
5281130 PIPROTAL
23505411 PIRIMIFOS-ETHYL
10124502 POTASSIUM ARSENITE
151508 POTASSIUM CYAN IDE
506616 POTASSIUM SILVER CYANIDE
2631370 PROMECARB
106967 PROPARGYL BROMIDE
57578 PROPIOLACTONE, beta-
107120 PROPIONITRILE
542767 PROPIONITRILE, 3-CHLORO-
70699 PROPIOPHENONE.4-AMINO
109615 PROPYL CHLOROFORMATE
75569 PROPYLENE OXIDE
75558 PROPYLENEIMINE
2275185 PROTHOATE
129000 PYRENE
140761 PYRIDINE, 2-METHYL-5-VINYL-
504245 PYRIDINE, 4-AMINO-
1124330 PYRIDINE, 4-NITRO-, 1 -OXIDE
53558251 PYRIMINIL
14167181 SALCOMINE
107448 SARIN
7783008 SELENIOUS ACID
7791233 SELENIUM OXYCHLORIDE
563417 SEMICARBAZIDE HYDROCHLORIDE
3037727 SILANE, (4-
AMINOBUTYL)DIETHOXYMETHYL-
7631892 SODIUM ARSENATE
7784465 SODIUM ARSENITE
CAS Number
Chemical Name
26628228 SODIUM AZIDE (Na(N3))
124652 SODIUM CACODYLATE
143339 SODIUM CYANIDE (Na(CN))
62748 SODIUM FLUOROACETATE
131Ł>22 SODIUM PENTACHLOROPHENATE
13410010 SODIUM SELENATE
10102188 SODIUM SELENITE
10102202 SODIUM TELLURITE
900958 STANNANE,ACETOXYTRIPHENYL-
57249 STRYCHNINE
60413 STRYCHNINE, SULFATE
3689245 SULFOTEP
3569571 SULFOXIDE, 3-CHLOROPROPYL OCTYL
7446095 SULFUR DIOXIDE
7783600 SULFUR TETRAFLUORIDE
7446119 SULFUR TRIOXIDE
7664939 SULFURICACID
77816 TABUN
13494809 TELLURIUM -
7783804 TELLURIUM HEXAFLUORIDE
107493 TEPP ''
13071799 TERBUFOS •>.-".."•'
78002 TETRAETHYL LEAD
597648 TETRAETHYLTIN
75741 TETRAMETHYL LEAD
509148 TETRANITROMETHANE
10031591 THALLIUM SULFATE
6533739 THALLOUS CARBONATE
7791120 THALLOUS CHLORIDE
2757188 THALLOUS MALONATE
7446186 THALLOUS SULFATE
2231574 THIOCARBAZIDE
39196184 THIOFANOX
297972 THIONAZIN
108985 THIOPHENOL
79196 THIOSEMICARBAZIDE
5344821 THIOUREA, (2-CHLOROPHENYL)-
614788 THIOUREA, (2-METHYLPHENYL)-
7550450 TITANIUM TETRACHLOR1DE
584849 TOLUENE 2,4-DIISOCYANATE
91087 TOLUENE 2,6-DIISOCYANATE
110576 TRANS-1.4-DICHLOROBUTENE
1031476 TRIAMIPHOS
24017478 TRIAZOFOS
1558254 TRICHLORO(CHLOROMETHYL)SILANE
27137855 TRICHLORO(DICHLOROPHENYL)SILANE
76028 TRICHLOROACETYL CHLORIDE
115219 TRICHLOROETHYLSILANE
327980 TRICHLORONATE
98135 TRICHLOROPHENYLSILANE
998301 TRIETHOXYSILANE
75774 TRIMETHYLCHLOROSILANE
824113 TRIMETHYLOLPROPANE PHOSPHITE
1066451 TRIMETHYLTIN CHLORIDE
639587 TRIPHENYLTIN CHLORIDE
555771 TRIS(2-CHLOROETHYL)AMINE
2001958 VALINOMYCIN
1314621 VANADIUM PENTOXIDE
108054 VINYL ACETATE MONOMER
81812 WARFARIN
1290136 WARFARIN SODIUM
28347139 XYLYLENE DICHLORIDE
1314847 ZINC PHOSPHIDE
58270089 ZINC, DICHLORO(4,4-DIMETHYL-
5((((METHYLAMINO)
CARBONYL)OXY)IMINO)PENTANENITRILE)
-------
APPENDIX 6
SECTION 313 TOXIC CHEMICAL LIST FOR REPORTING YEAR 1988
Toxics Release Inventory Chemicals
(including Chemical Categories)
Alphabetical Chemical List
CAS Number Chemical Name
De Minimus Concentration
(percent)
75-07-0
60-35-5
67-64-1
75-05-8
53-96-3
107-02-8
79-06-1
79-10-7
107-13-1
309-00-2
107-05-1
7429-90-5
1344-28-1
117-79-3
60-09-3
92-67-1
82-28-0
7664-41-7
6484-52-2
7783-20-2
62-53-3
90-04-0
104-94-9
134-29-2
120-12-7
7440-36-0
7440-38-2
1332-21-4
7440-39-3
98-87-3
55-21-0
71-43-2
92-87-5
98-07-7
98-88-4
94-36-0
100-44-7
7440-41-7
92-52-4
111-44-4
542-88-1
108-60-1
103-23-1
75-25-2
Acetaldehyde
Acetamide
Acetone
Acetonitrile
2-Acetylaminofluorene
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Aldrin
0.1
1.0
0.1
1.0
0.1
1.0
{1,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexachloro-1,4,4a,
5,8,8a-hexahydro-(1 .alpha., 4.alpha.,4a.beta.,5.alpha., 8.alpha.,8a.beta.)-}
Allyl chloride 1.0 .
Aluminum (fume or dust) 1.0
Aluminum oxide 1.0
2-Aminoanthraquinone 0.1
4-Aminoazobenzene 0.1
4-Aminobiphenyl 0.1
1 -Amino-2-methylanthraquinone 0.1
Ammonia 1.0
Ammonium nitrate (solution) 1.0
Ammonium sulfate (solution) 1.0
Aniline 1.0
o-Anisidine 0.1 .
p-Anisidine 1.0
o-Anisidine hydrochloride 0.1 ..'....-•
Anthracene 1.0
Antimony 1.0
Arsenic 0.1
Asbestos (friable) 0.1 *
Barium 1.0
Benzal chloride 1.0
Benzamide 1.0
Benzene 0.1
Benzidine 0.1
Benzoic trichloride 0.1
(Benzotrichloride)
Benzoyl chloride 1.0
Benzoyl peroxide 1.0
Benzyl chloride 1.0
Beryllium 0.1
Biphenyl 1.0
Bis(2-chloroethyl) ether 1.0 ,
Bis(chloromethyl) ether 0.1
Bis(2-chloro-1-methylethyl) etherl .0
Bis(2-ethylhexyl) adipate 0.1
Bromoform 1.0 ,
-------
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
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. Basic 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
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0,1
1.0
1.0
1.0
0.1
1.0
1.0
{1 H-lsoindole-1,3(2H)-dione, 3a,4,7,7a-tetrahydro-2-[(trichloromethyl)thio]-}
Carbaryl 1.0
{1-Naphthalenol, 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
Chlorine dioxide
Chloroacetic acid
2-Chloroacetophenone
Chlorobenzene
Chlorobenzilate
{Benzeneacetic acid,4-chloro-.alpha.-(4-chlorophenyl)-alpha.-hydroxy-,ethyl
ester}
Chloroethane 1.0
{Ethyl chloride}
Chloroform 0.1
Chloromethane 1.0
{Methyl chloride}
Chloromethyl methyl ether 0.1 ,
Chloroprene 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
Cobalt
Copper
p-Cresidine
Cresol (mixed isomers)
m-Cresol
o-Cresol
p-Cresol
Cumene
Cumene hydroperoxide
Cupferron
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
{Benzeneamine, N-hydroxy-N-nitroso, ammonium salt}
Cyclohexane 1.0
2,4-D 1.0
{Acetic acid, (2,4-dichlorophenoxy)-}
Decabromodiphenyl oxide 1.0
Diallate 1.0
{Carbamothioic acid, bis(l-methylethyl)-, S-(2,3-dichloro-2-propenyl) ester}
2,4-Diaminoanisole 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-Dibromoethane 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
3,3'-Dichlorobenzidine 0.1
Dichlorobromomethane 1.0
1,2-Dichloroethane 0.1
{Ethylene dichloride}
1,2-Dichloroethylene 1.0
Dichloromethane 0.1
{Methylene chloride}
2,4-Dichlorophenol 1.0
1,2-Dichloropropane 1.0
1,3-DichIoropropylene 0.1
Dichlorvos 1.0
{Phosphoric acid, 2,2-dichloroethenyl dimethyl ester}
Dicofol 1.0
{Benzenemethanol, 4-chloro-alpha.-(4-chlorophenyl)-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'-Dimethoxybenzidine 0.1
4-Dimethylaminoazobenzene 0.1
3,3'-Dimethylbenzidine 0.1
{o-Tolidine}
DimethylcarbamyI 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-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
n-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 thiourea
Fluometuron
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
1.0
0.1
1.0
1.0
0.1
0.1
0.1
1.0
{Urea, N,N-dimethyl-N'-[3-(trifluorometriyl)phenyl]-}
Formaldehyde 0.1
Freon 113 1.0
{Ethane, 1,1,2-trichloro-1,2,2-trifluoro-]
Heptachlor 1.0
{1,4,5,6,7,8,8-HeptachIoro-3a,4,7,7a-tetrahydro-4,7-methano-1H-indene}
Hexachlorobenzene 0.1
Hexachioro-1,3-butadiene 1.0
Hexachlorocyclopentadiene 1.0
Hexachloroethane 1.0
Hexachloronaphthalene 1.0
Hexamethylphosphoramide 0.1
Hydrazine 0.1
Hydrazine sulfate 0.1
Hydrochloric acid 1.0
Hydrogen cyanide 1.0
Hydrogen fluoride 1.0
Hydroquinone 1.0
Isobutyraldehyde 1.0
Isopropyi alcohol 0.1
(manufacturing-strong acid process, no supplier notification)
4,4'-lsopropylidenediphenol 1.0
Lead 0.1
Lindane 0.1
{Cyclohexane, 1,2,3,4,5,6-hexachloro-,(1 .alpha.,2.alpha, 3.beta.,4.alpha.,
S.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-}
-------
.0
.0
.0
0.1
.1
1
109-86-4 2-Methoxyethanol 1.
96-33-3 Methyl acrylate 1.
1634-04-4 Methyl tert-butyl ether 1.
101-14-4 4,4'-Methylenebis(2-chloroaniline)
{MBOCA}
101-61-1 4,4'-Methylenebis(N,N-dimethyl) 0.
benzenamine
101-68-8 Methylenebis (phenylisocyanate) 1.0
{MBI}
74-95-3 Methylene bromide
101-77-9 4,4'-Methylenedianiline
78-93-3 Methyl ethyl ketone
60-34-4 Methyl hydrazine
74-88-4 Methyl iodide
108-10-1 Methyl isobutyl ketone
624-83-9 Methyl isocyanate
80-62-6 Methyl methacrylate
90-94-8 Michler's ketone
1313-27-5 Molybdenum trioxide
505-60-2 Mustard gas
{Ethane, 1,1'-thiobis[2-chloro-}
91-20-3 Naphthalene
134-32-7 alpha-Naphthylamine
91-59-8 beta-Naphthylamine
7440-02-0 Nickel
7697-37-2 Nitric acid
139-13-9 Nitrilotriacetic acid
99-59-2 5-Nitro-o-anisidine
98-95-3 Nitrobenzene
92-93-3 4-Nitrobiphenyl
1836-75-5 Nitrofen
{Benzene, 2,4-dichloro-1-(4-nitrophbnoxy)-}
51-75-2 Nitrogen mustard 0.1
{2-Chloro-N-(2-chIoroethyl)-N-methylethanamine}
55-63-0 Nitroglycerin 1.0
88-75-5 2-Nitrophenol 1.0
100-02-7 4-Nitrophenol 1.0
79-46-9 2-Nitropropane 0.1
156-10-5 p-Nitrosodiphenylamine 0.1
121-69-7 N,N-DimethylaniIine " 1.0 •
924-16-3 N-Nitrosodi-n-butylamine 0.1
55-18-5 N-Nitrosodiethylamine 0.1
62-75-9 N-Nitrosodimethyiamine 0.1
86-30-6 N-Nitrosodiphenylamine 1.0
621-64-7 N-Nitrosodi-n-propylamine 0.1
4549-40-0 N-Nitrosomethylvinylamine 0.1
59-89-2 N-Nitrosomorphoiine 0.1
759-73-9 N-Nitroso-N-ethylurea 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
16543-55-8 N-Nitrosonornicotine 0.1
100-75-4 N-Nitrosopiperidine 0.1
2234-13-1 Octachloronaphthalene 1.0
20816-12-0 Osmium tetroxide 1.0
56-38-2 Parathion 1.0
{Phosphorothioic acid, o, o-diethyl-o-(4-nitrophenyl) ester}
87-86-5 Pentachlorophenol 1.0,
{PCP}
79-21-0 Peracetic acid 1.0
0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
0.1
1.0
0.1
0.1
0.1
1.0
0.1
0.1
1.0
0.1
0.1
-------
108-95-2
106-50-3
90-43-7
75-44-5
7664-38-2
7723-14-0
85-44-9
88-89-1
1336-36-3
1120-71-4
57-57-8
123-38-6
114-26-1
115-07-1
75-55-8
75-56-9
110-86-1
91-22-5
106-51-4
82-68-8
81-07-2
94-59-7
7782-49-2
7440-22-4
1310-73-2
7757-82-6
100-42-5
96-09-3
7664-93-9
100-21-0
79-34-5
127-18-4
961-11-5
7440-28-0
62-55-5
139-65-1
62-56-6
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
95-53-4
636-21-5
8001-35-2
68-76-8
52-68-6
120-82-1
71-55-6
Phenol 1.0
p-Phenylenediamine 1.0
2-Phenylphenol 1.0
Phosgene 1.0
Phosphoric acid 1.0
Phosphorus (yellow or white) 1.0
Phthalic anhydride 1.0 v;
Picric acid 1.0 «Kv
Polychlorinated biphenyls 0.1
{PCBs}
Propane sultone 0.1
beta-Propiolactone 0.1
Propionaldehyde 1.0
Propoxur 1.0
{Phenol, 2-(1-methylethoxy)-, methylcarbamate}
Propylene 1.0
{Propene}
Propyleneimine 0.1
Propylene oxide 0.1
Pyridine 1.0
Quinoline 1.0
Quinone 1.0
Quintozene
{Pentachloronitrobenzene} 1.0
Saccharin (manufacturing, no supplier notification) 0.1
{1,2-Benzisothiazol-3(2H)-one, 1,1-dioxide}
Safrole
Selenium
Silver
Sodium hydroxide (solution)
Sodium sulfate (solution)
Styrene
Styrene oxide
Sulfuric acid
Terephthalic acid
1,1,2,2-Tetrachlroethane
Tetrachloroethylene
{Perchloroethylene}
Tetrachlorvinphos
0.1
1.0
1.0
1.0
1.0
0.1
0.1
1.0.
{Phosphoric acid, 2-chloro-1- (2,3,5-trichIorophenyl) ethenyl dimethyl ester}
Thallium 1.0
Thioacetamide 0.1 ,
4,4'-Thiodianiline 0.1
Thiourea 0.1
Thorium dioxide 1.0
Titanium tetrachloride 1.0
Toluene 1.0
Toluene-2,4-diisocyanate 0.1
Toluene-2,6-diisocyanate 0.1
o-Toluidine 0.1
o-Toluidine hydrochloride 0.1
Toxaphene 0.1
Triaziquone 0.1
{2,5-Cyclohexadiene-1,4-dione, 2,3,5-tris(1-aziridinyl)-}
Trichlorfon 1.0
{Phosphonic acid,(2,2,2-trichloro-1-hydiroxyethyl)-,dimethyl ester}
1,2,4-Trichlorobenzene 1.0
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-Trichloroethane
Trichloroethylene
2,4,5-TrichlorophenoI
2,4,6-TrichIorophenol
Trifluralin
1.0
1.0
1.0
0.1
1.0
{Benzenamine, 2,6-dinitro-N,N-dipropyl-4-(trifluoromethyl)-}
1,2,4-Trimethylbenzene 1.0
Tris(2,3-dibromopropyl phosphate) 0.1
Urethane 0.1
(Ethyl carbamate)
Vanadium (fume or dust) 1.0
Vinyl acetate 1.0
Vinyl bromide . 0.1
Vinyl chloride 0.1
Vinylidene chloride 1.0
Xylene (mixed isomers) 1.0
m-Xylene 1.0
o-Xylene 1.0
p-Xylene 1.0
2,6-Xylidine 1.0
Zinc (fume or dust) 1.0
Zineb 1.0
{Carbamodithioic acid, 1,2-ethanediylbis-, zinc complex}
-------
Reporting thresholds:
Calendar year 1988: 50,000 poinds for manufactured or processed substances; 10,000 pounds for
otherwise used.
Calendar year 1989: 25,000 poinds for manufactured or processed substances; 10,000 pounds for
otherwise used.
••;irr.
-^•r-
SECTION 313 CHEMICAL CATEGORIES
Section 313 requires emissions reporting on the chemical categories listed below, in addition to the
specific chemicals listed above. The metal compounds listed below, unless otherwise specified, are
defined as including any unique chemical substance that contains the named metal (i.e., antimony,
copper, etc.) as part of that chemical's structure. For further definitions of the other compounds, consult
EPA guidance documents.
Chemical categories are subject to the 1 percent de minimis concentration unless the substance involved
meets the definition of an OSHA carcinogen.
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.
Chlorophenols
Cyanide Compounds
Glycol Ether
Polybrominated Biphenyls
U.S. GOVERNMENT PRINTING OFFICE: 1990— 727-890/ 0
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