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 ------- ------- 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 ------- ------- 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? ------- ------- 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. 1 ------- 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. ------- 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. • ------- 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 ------- 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. ------- 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. ------- 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. ------- • 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. 8 ------- 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. ------- c 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 10 ------- 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: 11 ------- c 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 12 ------- 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? 13 ------- c 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 14 ------- 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. 15 ------- c 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. 16 ------- 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 17 ------- c 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. 31 ------- c 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 ------- 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 ------- c 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? 34 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 41 ------- 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 ------- 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 ------- 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 44 ------- 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. ------- 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. ------- 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. ------- ------- 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- ------- 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) ------- ------- 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. ------- ------- 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 ------- 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 ------- 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 ------- ------- 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 ------- ------- |