United States OSWER (OS-120) EPA 230/09-89-067
Environmental Protection OTS (TS-799) December 1989
Agency OPPE(PM-221)
[&EPA Risk Communication
About Chemicals
In Your Community
Facilitator's Manual
And Guide
v>EPA
ITSDR
The Agency for Toxic Substances
and Disease Registry
I U.S. Department of
Transportation
Printed on Recycled Paper
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Additional cooies of tms manual are avai
Emergency Planning and Community
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EPA-230-09-89-067
Risk Communication
about Chemicals
in Your Community
A Manual for Local Officials
Facilitator's Guide
(includes Participant Manual)
December, 1989
Prepared by Susan G. Madden and Barry V. Bales
Lyndon B. Johnson School of Public Affairs at
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
V.
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Table of Contents
Page
1
3
11
17
33
40
Topic
Introduction/Purpose
How to Use This Manual
Introduction to Title III
What is Risk?
Commonly-Used Risk Descriptions
Characteristics of Risk
First Scenario: An Unplanned Release of a Chemical
Procedures with Hazardous Chemicals
Steps in the Emergency Plan
Where to Get Information
Sample news release
Characteristics of a Good Response
Second Scenario: Learning about Routine Releases
Emissions, Concentration, and Exposure
Determining Delayed Health Effects
Communicating Long-Term Risks
Enforcement and Citizen Involvement under Title III
Third Scenario: Storing Large Quantities
Planning for Hazardous Chemical Emergencies
Citizen Involvement in Community Risk Assessment
Conclusion/Summary
Seven Cardinal Rules of Risk Communication
Opportunity for Citizen Involvement
Personal Action Plan
Appendices
1. Glossary of Commonly Used Terms
2. References and Sources
3. Brief Description of Title III by Section
4. State Emergency Response Commission Title III Contacts
5. List of Extremely Hazardous Substances
6. Section 313 ToxicChemical List
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Risk Communication Resource Sheet
1. State Emergency Response Commission:
Chairperson
Phone
2.
Local Emergency Planning Committee:
Chairperson •
Other Members
. Phone
Phone
_Phone_
Phone
3.
Emergency Plan:
Coordinator or Director of Emergency Management for our town/county:
Phone
Designated contact for non-emergency personnel who have questions:
Phone
4. Who is authorized to direct citizens to evacuate or take other actions?
5. What are the elements of our response plan?
6. What are other resources (local, state, federal, university) on which I can call
in an emergency?
7. Which state agency/official receives reports under section 313?
8. Which state agency/official receives reports under section 312?
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Facilitator's Guide
r Time
Sample Times
0:00
OHA-1
V
INTRODUCTION AND PURPOSE
1 . Introduction/Pass out manuals
Introduce Yourself
Have participants introduce themselves
Briefly review the schedule for the day:
8:30 Introductions/Purpose
8:45 How to Use this Manual
8:55 Introduction to Title III
9:05 What is Risk
9:25 Scenario I: Accidental Release of a Chemical
9:55 Break
10:05 Scenario 2: Routine Releases
10:55 Break
1 1 :05 Scenario 3: Storing Large Quantities
1 1 :45 Summary and Conclusion
1 1 :55 Adjourn
2. Purpose of the Workshop
Give a brief explanation of why this workshop was planned -
a. the workshop was planned because citizens will ask
questions relating to risk - (as a result of accidents or Title
III)
b. to understand the different ideas people have about risk
(OH on cartoon, A-1)
c. because Title III is a different kind of regulation (briefly
review the reasons for this difference on pp. 1-2).
Note for Facilitator: The section on "Preparing to Run the
Workshop" is included at the end of this volume. Overheads
are found in that section.
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Introduction
&
Purpose
Purpose
"STATE RATES HIGH IN CANCER RISK
FROM FACILITY EMISSIONS"
"PLANT CHEMICAL SPILL FORCES
HUNDREDS TO EVACUATE"
Have you seen headlines like these recently? Do they raise
questions in your mind? If someone asked you about them,
could you answer the questions?
People are becoming more concerned about hazardous
materials in their communities and how these materials affect
their health and well being. Their concerns become most
pressing when there is an accident or a leaking waste site is
discovered, but they are also concerned about hazardous
chemicals they are exposed to every day. In response to these
concerns, local officials are increasingly called upon to respond
to questions about hazardous materials, including the risks they
pose and how to reduce those risks. For many local officials this
is a new role, one for which they may not be fully prepared.
This workshop manual will help you learn how to respond to
public questions about chemical risks. It also will help you find
additional assistance and information about hazardous
materials.
Recent federal legislation is likely to increase public awareness
and concern especially because of the-Emergency Planning and
Community Right-to-Know Act, which is Title III of the 1986
amendments to the "Superfund" Act.
Title III is not a typical regulatory program; it is part of an
innovative approach to managing environmental risk. It makes
a great deal of information available that has never been
provided before. The information is available to everyone—to
the public and to governments at all levels—about the presence
of hazardous chemicals in the community, about accidental and
routine releases of these chemicals, and about their storage.
The more citizens know about chemical hazards in their
communities, the better equipped they and their local
governments will be to make decisions and to take actions that
will protect their families and neighbors from unacceptable risks.
1
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Facilitator's Guide
Time
3.
d. Responsibilities you have - to respond to queries, formulate
an emergency plan
e. ASK QUESTION: How many of you have been asked
questions by citizens about hazardous chemicals or risk?
(call on one or two, end with saying we hope to provide some
strategies for dealing with those questions).
Program Review/Agenda:
Briefly outline the agenda for the day; i.e. go through manual, take a
break at a certain time, finish by a certain time, etc.
SAMPLE QUESTIONS:
1. "For whom is this manual and workshop intended"
1. Primarily for members of the Local Emergency Planning Committee,
(Skip if only state people are present)
2. Others who answer citizens' questions about risk
Let's review the manual we will be using today.
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The new information available under Title III is often complex,
and its application and interpretation requires work from all
those involved. It will cause citizens' existing concerns about
hazardous chemicals to become more focused, and public
officials will need to respond to these concerns. Title III
establishes an ongoing forum at the local level for community
discussion and action about hazardous chemicals. This forum
is the Local Emergency Planning Committee, or LEPC.
LEPC members may be called upon to respond to public
questions about the risks they are examining or to participate in
public meetings about those risks—meetings where people will
ask what the information means or about its significance for a
particular person or segment of the community. If you are a
member of the LEPC or participate in its work, you will be inter-
acting with the community as you work to analyze and mitigate
potential chemical hazards. Since LEPC membership by law
includes a variety of categories—emergency responders such
as firefighters and police, health professionals, the media,
industry representatives, transportation representatives, and
public interest groups—many different kinds of people with
many different backgrounds will find themselves answering
public questions. This manual is intended to help everyone who
may have to answer questions develop some useful strategies.
Preview The manual begins with a brief overview of the law and local
responsibilities. To illustrate situations and suggest ways to
respond, we will look at three kinds of mcidents that cause
citizens to seek out local officials. We will begin with an
accident, then expand our discussion to include more routine
events. These are not the only circumstances under which
citizens may seek out local officials and become involved in
considerations of risk in the community, but they illustrate ways
in which public officials might interact with the public.
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Facilitator's Guide
Time
0:20
OH A-2
OHA-3
HOW TO USE THIS MANUAL
1. How to use this manual
a. As a workbook b. For self-study c. As a valuable resource
2. Discuss briefly the workshop objectives. (OH on "Objectives", A-2)
"We will accomplish these objectives by
- considering some scenarios that are likely to generate questions
from the public,
- discuss appropriate response strategies,
- discuss steps you can take following this workshop that will better
prepare you to fulfill your responsibilities as risk communicators."
"Although the scenarios seem to put the LEPC in a reactive mode, it
is important to remember that LEPC's should do proactive risk
communication as well."
Question: "We have described our objectives for this workshop.
What additional objectives do you have that we have not covered?"
(Write their responses on a chalkboard or flipchart and leave them
posted during the session. Let them know if requests for subjects/
information will not be covered in this workshop, and suggest
alternative sources of information.)
-Note that this course is not designed to teach people to talk with
the media. This course is about talking to citizens, although some of
the lessons apply to the media. (See Appendix 2, section 2 for some
guides to working with the media.)
2. How the manual is organized (a quick review)
"For example, turn to the Table of Contents and see that the
Glossary is located under Appendix 1.
"It is important to remember that this manual is only one of the
resources available to help you in risk communications. We will
identify some of the other resources available to you as we
proceed today. They are also listed in Appendix 2"
3. Pass out and mention "7 Cardinal Rules" pamphlet.
Questions:
1. "Any other questions about the use of the manual or about the
agenda for the workshop?"
"In order to effectively answer questions, it is helpful to have information
in several areas. These are the areas we will cover during the course of
this workshop (OH A-3, Complete Pie). The first of these areas will be
a brief review of Title III. Please turn the next page."
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How to Use
This Manual
Objectives
How the Manual
is Organized
Resource
Guide
The manual can be used in three ways: first, as part of a work-
shop on answering citizen questions about hazardous
chemicals; second, as a stand-alone guide for local officials
unable to attend a workshop; and third, as a reference.
Reading or using the manual will help you:
•Know what kinds of questions citizens are likely to ask
—after an accident
—after learning about routine releases
—after learning that large quantities of substances are
stored nearby.
• Know the characteristics of a good answer to these
questions.
• Understand the kinds of information needed to answer the
questions and where that information may be found.
•Respond to the questions and identify some people in the
community who can help answer them.
• Identify opportunities for all sectors of the community to
participate in decisionmaking about potential risks from
hazardous chemicals.
The manual is written so that later topics build on material
presented earlier. Those using the manual for self-study will
need to identify the local and state resources described in this
manual.
This manual should be retained as a resource guide. The
materials are arranged so that specific information can be found
easily when needed. Specific times to review this manual would
be when an accident or a spill happens, when companies
submit their required Title III reports on hazardous chemicals, or
when the public or the media has concerns or questions to be
answered.
Remember, there are many other resources available to help
you respond to risk assessment questions and accidents, and
the early identification of these resources will help you fulfill your
official obligations in a safe and responsible manner.
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Facilitator's Guide
Time
0:25
OHB-1
OHB-2
TITLE III
1. Why we need to cover Title ill (OH on pie chart, B-1)
a. The first piece of information you need to know to effectively answer
citizens' questions about risk is about Title III.
b. Give a brief review of Title III, using information from the manual
and any other sources you feel appropriate. (Have them turn to
Appendix 3 and put up OH on Title III sections, B-2)).
"It is important to know the differences in what is required by the
different sections.
c. Emphasize that Title III is a different kind of law.
• not a typical regulatory law—standards require information rather
than performance
• provides citizens with information so that they can participate in
decisionmaking
• brings together different parts of community—government, indus-
try, citizens
2. Briefly highlight local officials' responsibilities under Title III.
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Introduction to
Title III
The Emergency Planning and Community Right to Know Act
was included as the third part or title of the Superfund Amend-
ments and Reauthorization Act of 1986. For this reason, it is
often called Title III." The law has four purposes (readers
should not use the following brief descriptions as the basis for
legal decisions about Title III):
(1) Emergency planning. Facilities that store or use any of
the 366 Extremely Hazardous Substances in excess of the
threshold planning quantity (TPQ) report this fact to the State
Emergency Response Commission (SERC) and LEPC. The
LEPC develops an emergency plan based on this and other
information.
(2) Emergency release reporting. Facilities must report to
the SERC and LEPC accidental releases in amounts over a
reportable quantity of the Extremely Hazardous Substances
and Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) hazardous
substances (which must also be reported to the National
Response Center).
(3) Hazardous chemical reporting. Facilities where any
hazardous chemicals are present in amounts over certain
reporting thresholds (often 10,000 pounds) must submit
Material Safety Data Sheets (MSDSs) or a list of chemicals
for which MSDSs are required as well as an annual chemical
inventory form to the local fire department, LEPC, and SERC.
(4) Creation of an emissions inventory. Manufacturing
facilities that use any of a different list of about 300 chemicals
in excess of reporting thresholds must report emissions to
EPA and designated state agencies.
As indicated, different sections of the law apply to different
facilities and different chemicals. Specific sections are listed in
Appendix 3.
In order for the law to work, industry, interested citizens,
environmental and other public-interest organizations, and
governments at all levels must work together to plan for
chemical accidents and to reduce the risk to the public from
releases of toxic chemicals into the environment. The law
represents a path-breaking approach to environmental
protection, because it assumes that the more citizens know
about chemical hazards in their communities, the better
equipped they and their communities will be to make decisions
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Facilitator's Guide
Time Sample Questions to Ask:
1. "Who is on the State Emergency Response
Commission and how would you contact them?"
(Give this information at this time if they don't know it.)
(Now have them turn to the first page after the Table of Contents
entitled "Risk Communication Resource Sheet." Explain that this
sheet has a dual function):
(1) to serve as a initial planning document by identifying the
basic information that needs to be collected, and
(2) to serve as a readily accessible resource sheet for many of
the names and numbers they will find useful for help in
responding to questions. (Of course they will have to update
frequently to serve this purpose). Also note that the second
Cardinal Rule is "plan." Here we are helping them plan.
Now, have them fill in the emergency coordinator's name and
number, mention that we will be filling more of this in as we go along,
and then turn back to page 5.)
2. "Has your Local Emergency Planning Commission designated
someone to handle questions concerning risk? The Chairperson?"
(If an LEPC member has not been designated then it may be the
Chairperson by default. The need to designate someone will be
discussed later.)
3. "Have you ever been called by citizens or press during an
environmental emergency? If yes, what sort of questions were you
asked?"
(It may be interesting to all present to know the types of questions
that were raised in such a case, but postpone full discussion until
similar questions are raised during the scenarios).
5
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Special
Provisions
for Local
Government
Officials
and take actions to protect their families and neighbors from
risks they feel are unacceptable.
Provisions of special concern to local officials include:
—The law required states to set up State Emergency Response
Commissions, or SERCs.
—SERCs were then required to establish local emergency
planning districts and Local Emergency Planning Committees,
orLEPCs.
—LEPCs must include among their members local elected
officials and staff with competence in health and emergency
response, industry representatives, media representatives, and
members of citizens groups.
—Facilities having more than certain quantities of any of the 366
Extremely Hazardous Substances must make themselves
known to SERCs and participate in the LEPC.
—As noted, facilities where hazardous chemicals are present in
certain quantities must submit MSDSs and inventories of the
chemicals to SERCs, LEPCs and local fire departments. An
MSDS describes the physical and chemical properties of the
substance as well as its health effects, appropriate safety
equipment, and emergency response measures.
—LEPCs must make the chemical inventories and the MSDSs
available to citizens who want to see them.
—LEPCs must develop a plan for responding to and avoiding
emergencies involving hazardous chemicals, drawing upon
the chemical inventories and other information provided by
facilities.
—Manufacturers must report their annual emissions of certain
toxic chemicals into the air, water, or land. The reports are
sent to the federal Environmental Protection Agency (EPA)
and to the designated state agencies. Citizens also have
access to these reports.
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Facilitator's Guide
Time
OHB-3
Title III makes use of three terms that often seem similar. They are:
(OH on definitions, B-3)
Toxic
Hazardous
Extremely hazardous
"You may understand the differences among these terms but it is
important to realize that the people you are talking to may not.
You must listen carefully to discern if what they say is really what
they mean."
(Title III can be covered quickly if most of the audience is already familiar
with the law - use your judgement based upon knowledge of the
audience)
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Defining Terms
The information now available to citizens under Title III is one of
the driving forces for citizen questions about hazardous
materials in the community. Sections below describe three
scenarios in which citizens have obtained Title III information.
Title III makes use of three terms that often seem similar. They
are:
Toxic - substances that are poisonous or can cause
adverse health effects. These are the substances
emissions of which are reported under Section 313 of
Title III.
Hazardous - substances that are toxic, corrosive,
flammable, or explosive. This is a general term, not
specific to Title III.
Extremely hazardous - a set of chemicals defined by
Title III as subject to reporting under Section 302,
because they could cause death or irreversible damage
after relatively short exposure to small amounts, •
generally in air.
As you talk with citizens, it is important to remember that they
may not know the differences among these terms as well as you
do. Listen to understand what they mean instead of
concentrating on the particular terms they might use.
We know that citizens are often very concerned about toxic and
hazardous chemicals in all these categories. Title III offers an
important new step forward in allowing and encouraging
citizens, working with government and industry, to participate in
managing these chemicals in their own communities.
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Facilitator's Guide
Time
0:40
OH C-1
WHAT IS RISK? (OH C-1) "The second piece of this informational pie,
so to speak, is information about risk"
1. Repeat workshop purpose: to discuss risk communication
strategies that they as local officials can use in responding to con-
cerns of the public.
Repeat here - and throughout the workshop - "You are appropriate
people to give out risk-related information. To be able to do this,
you should know something about the concept of "risk""
2. Briefly review the definitions of:
Risk
Environmental risk:
[You may wish to announce that we are not covering ecosystem risk
in this short workshop. While it can be a major concern in some
situations, we had to omit some important issues to keep the
workshop to a manageable length.]
3. Common Ways of Reporting Risk:
(Mention several of the ways listed on page 7).
Sample Questions to Ask:
1. "Which of these ways seem most meaningful to you?"
(Pause while several answer. Ask why they prefer a particular
format. This usually generates a good discussion. As an example, a
recent gathering of journalists preferred "The risk of neighbors getting
sick is higher with this waste site here than it would be if the waste
were not disposed here" while another group of LEPC and health
officials preferred "25,000 people die each year in accidents in their
homes".)
2. What does that tell you about how you might ask them (experts)
to give you information?
(It should be in the terms that best relate risk to you.)
"In the same way, you might want to report risk using several of the
ways mentioned on page 7, remembering that other people
understand risk in different ways."
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What is Risk?
Common Risk
Characterizations
"Risk" is a word that is used often when people talk about
hazardous chemicals in the community.
What is risk? A convenient definition is:
The likelihood of injury, disease, or death.
Environmental risk then refers to
The likelihood of injury, disease, or death resulting from
human exposure to a potential environmental hazard.
(In addition to human health, the environment itself may also be
at risk. We will not mention these risks below, but the
considerations are the same.)
Experts often use the definitions above. When experts are
asked to describe or characterize a risk, they use statements
like these:
• There is a lifetime risk of 1 in 65 of dying in a motor vehicle
accident.
• The range of risks in humans is between 100 and 1000
cancers per 1,000,000 people exposed.
• The chance of getting this disease is 1 x 10'7 (1 10-millionth,
or 1 in 10 million.)
• The risk to children is high relative to that for adults.
• 25,000 people die each year from at-home injuries.
• The risk of death from leukemia is 1 in 12,500 people per
year.
• The risk of cancer from indoor air is 600 times the risk from
tap water.
• An airplane crash involving 100 or more deaths is likely to
occur once in two years.
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Facilitator's Guide
Time
OHC-2
OHC-3
4. "Table 1 illustrates some of the features of risk that make it seem
'riskier1 to people. (OH on characteristics of risk, C-2.)
Voluntary—Driving Involuntary—Breathing polluted air
Natural—Radon gas in home Man-made—Chemical spill
"In a final assessment of risk, people will probably balance these fea-
tures of risk against the size of the risk estimates. (OH on When is
Risk Communication Most Difficult, C-3.)
When scientific estimates of risks that are familiar, controllable,
etc. are low,
or
when scientific estimates of risks that are unfamiliar,
uncontrollable, or unfair are high, then
people accept the scientific judgement readily. When the two
kinds of estimates disagree, risk communication becomes more
difficult for technically-trained people.
(e.g., In a community where most people work for the local
chemical plant, the risk is familiar and "everyone" benefits from
the plant. So scientists' estimates of low risks from emissions are
likely to be accepted. Put the same plant in a community where
most people do not work for that company, and the risk is likely to
be unfamiliar with no visible benefits. Accordingly, the same size
risk may be unacceptable to the second community.)
'When are people motivated to ask questions?"
When they perceive a personal threat (either immediate or long-
term).
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Table 1: Characteristics of Risk
(Factors on Right Increase Perception of Riskiness)
Voluntary
Driving a car
Natural <-
Radon in basement
Familiar
Household
cleansers
Chronic
Routine small
releases of chemicals
from a facility
Visible
Benefits
Dying hair
Controlled by
Individuals
Driving
Fair
Involuntary
Breathing air polluted
by a neighboring
factory
Man Made
Industrial
chemicals
Exotic
Genetically
engineered organism
Catastrophic
Large accidental
release of chlorine
gas from a plant
No Visible
Benefits
Incinerator effluents
Controlled by
Others
Industrial pollution
Unfair
The notion of "fairness" sums up many of the other aspects of
risk that make people feel special concern or "outrage." If a
person or community feels that it is bearing a lot of risk while
someone else is getting most of the benefits, then the risk will
seem especially unacceptable. Risk communicators must
understand these feelings, or they will not succeed in working
with the community to make good decisions about risk
reduction.
We also know that most people seek information about
hazardous chemicals only when something happens to make
them interested or cause them to believe that they are directly
affected.
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Facilitator's Guide
Time
We are going to look at several general scenarios that are likely to
generate risk-related questions:
1. During/after an incident
2. When they learn about routine releases
3. When they learn about stored substances
"In addition, we will consider some of the procedural types of questions that
citizens might ask. It is important to realize, though, that you may not be
able to answer every question about risk.
Some questions have no sure answers and others may be dependent
upon many different factors. This manual and workshop will help you
understand the kinds of responses that are appropriate and the
sources for information upon which you can call."
"Remember, these are not the only situations under which you might have
to do risk communication, nor are they intended to be completely realistic.
They are here as vehicles to facilitate discussion of communication
strategies."
"Any other questions about risk?" (Answer briefly; don't let the discus-
sion get too far off track or take much more than the allotted time)
"Let's look at the first scenario"
10
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Scenario 1: Unplanned Release of a Chemical
Questions citizens
ask about
hazardous
materials
We will use as examples three kinds of circumstances that may
cause citizens to become concerned enough about hazardous
chemicals in their communities to ask questions: during/after an
incident, when they learn about routine releases, and when they
learn about the many kinds of substances stored nearby. Most
questions will concern human health, but many citizens also will
ask questions about environmental and other possible effects of
chemical exposure or release. In addition to these substantive
questions about health or the environment, citizens also ask
many "procedural" questions about where they can obtain
additional information, why it was so difficult to get answers to
their questions, or how they can get involved in making sure
risks are managed properly.
Few public officials will be able to answer all these questions.
Some questions have no sure answers, and others can be
answered only in light of the particular conditions prevailing in
the community. However, this manual is intended to help users
understand the kinds of answers that are appropriate and find
sources for the factual information that is available. Keep these
questions in mind as you think about the scenarios from the
perspectives of government, industry, or citizen representatives
10
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Facilitator's Guide
Time
0:55
Scenario 1
"Please take a moment to read the first case (enclosed in the box)
regarding an unplanned release of a chemical. Let's assume that this
incident has occurred in this town". (Use the name of a real town.)
(You might be asked "Is this realistic?" The scenario was taken directly
from a real incident that was described in a professional journal.)
(Another question that participants might ask is "Will they really ask me
questions?" All LEPC members should know how to contact their local
public outreach coordinator for emergencies. Have the participants turn
to the Risk Communication Resource Sheet following the Table of
Contents and have them write in the appropriate name, if known.)
"Before we talk about the appropriate responses to the press, we should
discuss some of the procedures that are used in dealing with hazard-
ous chemicals."
Let's make an important distinction before we proceed. Answering
peoples' questions is different from responding to the emergency.
Our discussion will not concern the actual response but rather
how you might answer questions about the emergency. As part
of the answer people need to know about the planning process.
One other comment: We know that cities and other jurisdictions
smaller than the LEPC might have their own emergency response
plans. In our discussion we will be talking about the LEPC plan.
However, the principles for planning that we talk about here and that
are described in NRT-1 (the Orange Book) apply to all emergency
plans, not just those for the LEPC.
(Note: If you have an Apple Macintosh computer and CAMEO, you
could demonstrate the planning portions of CAMEO at this point.)
1. What are the hazardous chemicals involved in this incident?
"Title III requires most facilities that store any of 366 Extremely
Hazardous Substances in amounts greater than specified Threshold
Planning Quantities to notify the Local Emergency Planning
Committee and SERC. Turn to Appendix 5 to see this list."
"Do you need to memorize which substances are included in this list?
NO! Do you need to know where to find such a list if necessary?
YES!"
(While this list can be used, they should know that these lists are
not entirely static - on occasion chemicals are added to or deleted
from the lists.) "In this case, chlorine is a hazardous substance."
, - ,..- . ... - - - . - -~ ------- - - ._-:. ; **
11
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Scenario 1: Unplanned Release of a Chemical
Scenario 1
Procedures with
Hazardous
Chemicals
Unplanned Release of a Chemical
About 2:30 on a weekday afternoon you receive a telephone call from the
Directorof Emergency Managementtelling you that a chlorine 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 III requires any facility that stores any of 366
Extremely Hazardous Substances in amounts greater than
specified Threshold Planning Quantities to notify the Local
Emergency Planning Committee (LEPC) and the SERC. (Many
of these substances are also covered-by the annual toxic
chemical reporting requirements of Title III described above on
page 4.) A list of the Extremely Hazardous Substances
appears in Appendix 5.
2. The LEPC uses this information to plan for accident
prevention and for emergency response in case of an accident.
Individual facilities also should have their own emergency
response plans.
For some chemicals, including chlorine, there are professional
standards for the kinds of emergency warning systems and
emergency equipment that should be on hand.
3. The local emergency plan developed by the LEPC should:
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Facilitator's Guide
Time
The LEPC uses this information to plan for accident prevention and
for emergency response in case of an accident.
"Now, let's look at the steps of what a response plan should include.
Do you have an emergency plan? If yes, evaluate as we go through."
SOME OF THE STEPS IN AN EMERGENCY RESPONSE PLAN—briefly
review
(Remember, the focus of the workshop is not on the emergency plan, so be
careful that the discussion does not stray too far in this area.)
1. Emergency coordinator. Do you know who your emergency
coordinator is? (Fill in on Risk Communication Resource Sheet).
2. Means for notifying appropriate authorities (in rural areas this is
often the hospitals or sheriff's office).
(Review the remaining steps on page 12.)
"Remember that emergency plans are necessarily best guesses.
After an emergency you refine the plan in light of what happened.
Plans are always dynamic (changing) or they are not useful. The EPA
publication "It's Not Over in October" discusses on-going activities
associated with the plan."
"The callers will ask some of the kinds of questions that are mentioned on
page 12. They are likely to call you, as a local official, even if you are not
the best person to call in such a case."
(Review the material under "Citizens' questions" in the manual; it is
important to point out that an emergency coordinator's name should
be publicized. Remember, however, this is not a class on emergency
management. Go over this portion quickly. Resist the tempation for
the class to discuss response mechanisms; emphasize information
and risk communication.)
12
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Scenario 1: Unplanned Release of a Chemical
Some Steps in the
Emergency Plan
Citizens' Questions
• Designate a coordinator for emergencies—usually the
Director of Emergency Management or someone in the Fire
Department. (Note that many states have rules about first
responders that should have been considered as the plan
was developed.)
• Provide a means for notifying appropriate authorities.
• Provide a means for emergency responders to obtain
information about appropriate responses particular to
specific chemicals involved in the incident (including needs
for special equipment and clothing).
• Identify sources of necessary equipment and trained
personnel and describe procedures for bringing them to the
site.
• Specify the division of duties between the public and private
sector response personnel. (Many companies insist on
deploying their own specially-trained staff for accidents that
do not cross the plant boundary, in part to limit possible
liability for damages to non-employee emergency
responders).
(Although cities or other jurisdictions smaller than the area
covered by the LEPC could have their own plans, in this manual
we focus on the LEPC plan. The planning principles would be
the same for the smaller jurisdictions.)
In the chlorine spill, the plan has worked quite well. Authorities,
including you, have been notified, equipment mobilized, and the
problem treated. Your callers ask:
a. What's going on?
b. Am I at risk?
c. Should I evacuate?
d. What are you doing to mitigate the consequences?
Although citizens will call the elected official, he is not
necessarily the best person to provide answers. The person
designated as emergency coordinator should in turn have
designated a particular person or position in his office to be
the contact for non-emergency personnel who have
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Facilitator's Guide
Time
"One reason for having a designated person who is the central
source for information is because it will be impossible for each of
you and other involved officials to always have the most up-to-
date information. When several people are trying to respond to
questions, a lack of up-to-date information can result in different
answers which can cause unnecessary confusion and fear. This is
part of what happened at Three Mile Island. Remember, the speed
with which you can give an answer also helps your credibility."
(Cover"Wheretogetinformationtoanswerthesequestions",and
take the time to answer those questions if the answers are known.
The important thing for them to learn is that they should be familiar
enough with local procedures to be able to quickly tell callers
where to find the information needed.)
"What other sources of information are available to answer
citizens' questions?"(ldentify local and state health department
officials, federal sources, university resources, etc. Turn to the Risk
Communication Resource Sheet and have them fill in the new
information.)
Question for discussion: "Should industry be responsible for
answering the questions?"
For example, in Corpus Christi, Texas several chemical facilities
jointly support a telephone answering service that provides
routine information to callers concerning Title III and the member
companies. During an emergency, however, the line is provided
with a taped message that is updated frequently, so that callers
may learn the status of the accident.
Questions to ask: Is this kind of service appropriate? What are the
problems that might occur? Allow discussion if there is time.
OHD-1
Questions After the Event
1. What does a citizen want to know afterwards?
(Cover the questions likely to arise after an event. (OH D-1 on
questions after the event.)
13
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Scenario 1: Unplanned Release of a Chemical
Where to get
information to
answer these
questions.
Questions after
the event
questions. This person's name and especially phone number
should be emphasized to the media before any accidents occur.
(Many facilities are designating a particular contact person and
inviting the media to meet with that person on an informal basis
independent of any particular events. Public agencies could
adopt this approach, ensuring that the media are aware of
procedures and plans.) The elected official should refer almost
all calls to the appropriate contact person, since during an
emergency, it is often impossible to ensure that every office is
kept up to date on rapidly changing events.
Local officials should know about the system in place in their
own communities for emergency planning and response and be
prepared to talk about it with the public. You should know the
answers to these questions:
a. Who is the central contact person or where information
will be available?
b. Which departments, programs, or offices are responsible
for emergency response?
c. Who has authority to direct citizens to evacuate or take
other action?
d. What is their relationship to the Local Emergency
Planning Committee (LEPC)? Who is chairman of the LEPC
and what is the role of the LEPC during an emergency?
e. What 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
long time?
d. What are you doing to prevent it from happening again?
13
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Facilitator's Guide
Time (Have participants read the news release on page 14 as an example of
what an official in their position might release.)
Have participants stay on this page (news release) and put up the
OH D-2 overhead of characteristics of a good answer (D-2) to refer to as you
are discussing the press release.
Discuss:
1. Is this a realistic news release?
2. What is wrong with this press release?
(It doesn't sound the way a journalist would write, because all the
important information is not in the first couple of sentences.
Journalists will use a good press release as it stands; if it is not
written properly for their needs, they will rewrite it and may lose or
change something important in the process.)
On the other hand, this release contains all the needed information -
who, what, when, where, why.
(After they have read the news release, have them identify specific
passages in the news release that answer some of the previous
questions that were discussed. Then, briefly cover the
characteristics of a good answer and the other sources of
information mentioned in the manual. Ask if there were any
important items left out of the news release or if they have any
suggestion that might make the news release more closely fit the
"characteristics". (One error in the response is that the person
calling to report did not have the right telephone number. This
problem was pointed out in paragraph 3 and the suggestion for
correcting it is included in paragraph 4.)
3. What role might LEPC play in drafting such a release for the
mayor?
One LEPC holds a press conference within 48 hours of each incident.
Another LEPC makes sure that three people are present for after-
incident press conferences: a public information officer, a technical
information specialist, and the person who was in command of
operations during the incident. Then all kinds of questions can be
answered accurately on the spot.
Note that the characteristics of a good answer respond to the Seven
Cardinal Rules that call for being honest and open, and for accepting
the public as a partner.
14
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Scenario 1: Unplanned Release of a Chemical
Sample
News Release
Of course, the answers differ for each incident. [Appendix 2
lists some sources for information about specific chemicals.] In
answering what is being done to prevent a similar accident from
occurring, officials may need to refer to state and local laws that
give them power to prevent accidents, such as inspections for
enforcing the building code.
For this incident, an official might issue a statement something
like this:
News Release
For release, Tuesday 9:00 AM. Office of the Mayor.
About 100 pounds of chlorine gas were accidentally released in the
basement of North High yesterday when a storage tank began to leak during
routine transfer of chlorine to the pool-cleaning system. The gas was
sucked into the air circulation system of the school, which was turned off five
minutes after the leak was detected. All 1100 people in the building were
outside within fifteen minutes. Although some people experienced difficulty
in breathing for several hours, and twenty people were treated at the
hospital, no one was admitted and no one is experiencing after effects now.
Chlorine can affect human health in two ways. In high concentrations that
may be present during accidents, it causes difficulty in breathing, choking,
coughing, chest pain, and sometimes nausea and vomiting. It also reacts
with moisture, including body moisture, to form acids that are very irritating
to skin, eyes, and mucous membranes. In yesterday's incident, no one
suffered any skin irritation because concentrations except in the basement
were not high enough. Once the symptoms of chest tightness or difficulty
in breathing have disappeared, there are no further health problems that we
are aware of associated with an exposure to chlorine.
Our city has a plan in place for responding to emergencies involving
hazardous chemicals. This plan worked well, with efficient and effective
response by the Fire, Emergency Management, and Volunteer Rescue
teams, although the first person calling to report the accident had some
trouble finding the right telephone number and right place to report. The city
has had a plan since 1973, but it has been revised and updated recently by
the Local Emergency Planning Committee. This committee was established
under a federal law that calls for emergency planning and public access to
data about hazardous chemicals.
In order to limit the likelihood that any further such incidents will occur, the
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Facilitator's Guide
Time
Sample Questions for Discussion
1. How might this differ if residents had to be told to evacuate?
2. Or if the chemical had exploded—for example, a gasoline truck?
15
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Scenario 1: Unplanned Release of a Chemical
Characteristics
of a good answer
School Board has agreed that transfer of chlorine will no longer be done
during school hours. Chlorine is also stored in large quantities at city
swimming pools and water and wastewater treatment plants. We have
reviewed our systems for detecting leaks and made sure they are all
working properly. We have also issued instructions that transfers of
chlorine at city pools will only occur when the pools are closed for the day
and will be made only by trained personnel. Finally, we have tried to
publicize the telephone number to which initial accident reports should be
made: it is 333-3333.
To prepare a good answer:
—describe the incident, the response, and other events
—describe the chemical itself, including short- and long-term
health effects of brief exposure at relatively high levels
—describe the health effects suffered in the incident and any
longer-term concerns
—summarize the good and bad points of the response
—describe actions being taken to reduce the likelihood of a
similar incident
There are a variety of sources of information about chemicals,
including their physical properties and possible health effects.
Some of these sources are listed in Appendix 2. Many public
libraries and local emergency response departments have
reference books that provide some of this information. The
Material Safety Data Sheets (MSDSs) that facilities must supply
to the LEPC on request also contain this information. EPA and
several private companies maintain computerized databases
with chemical information. CAMEO™, a computer program
developed with assistance from EPA, contains information
about more than 2700 chemicals. The National Library of
Medicine has toxicological information in computer databases
called TOXNET. These sources seldom contain any information
about long-term health effects of exposures that may occur
during an accident, because it is often the case that little is
known about them.
15
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Facilitator's Guide
Time
Summary
OH D-3 (Briefly review the summary of Scenario 1 with them, and ask if they have
any further questions before moving on. Show on OH D-3 the pieces of the
pie we have recently covered (hazardous chemicals, emergency response
plan, and characteristics of good answer)).
1:45
(Take a 15 minute break)
16
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Scenario 1: Unplanned Release of a Chemical
Summary
Citizens' concerns about an accidental release of a chemical
focus first on response to the emergency. Later, citizens want
to know what is being done to prevent a similar emergency from
arising again, and they want to know more details about the
health effects of exposure to the chemicals involved in the
accident. Prior to any incidents, local officials should ensure
that
—a plan has been developed
—a central source of information for the public has been
designated,
—they are aware of the procedures to be followed during an
emergency. (Filling out the Risk Communication Resource
Sheet at the beginning of the manual will help meet this
guideline.)
After incidents, local officials should be prepared to
—provide an evaluation of the effectiveness of the plan
—provide available information about health effects of the
chemical
—provide information about how citizens can become involved
in emergency planning and risk reduction through the
LEPC.
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Facilitator's Guide
Time
2:00
Scenario 2
"We have talked about some of the response strategies for
communicating information in the event of an accidental release.
Hopefully, you will not have to use this kind of strategy very often.
More likely, especially with the Title III requirements for identifying
hazardous substances in the community, you will be questioned
about routine releases reported under the Toxic Release Inventory .
.. which includes routine and unplanned releases even if the unplanned
releases don't become an emergency."
"Scenario 2 concerns such a case, building on the previous case.
Please take a moment to read the news article in your manual."
17
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Scenario 2: Routine Releases
Scenario 2
Learning about Routine Releases
As a result of the incident in scenario 1, the local media
become very interested in the hazardous chemicals in the
community. They obtain emissions reports from the state
agency assigned the responsibility of keeping them or from
EPA, which maintains the Toxic Release Inventory (TRI)
database. The TRI can be accessed through the National
Library of Medicine's TOXNET system. The following
newspaper article is an example of the kinds of information
being publicized.
Ourcity Daily News
325,000 Pounds of Four Toxic Chemicals Emitted Locally
Benzene, Chlorine, Pyridine, Ammonia Most Prominent
Industry Says, "Risk is Low"
Last year, fifteen local manufacturing facilities emitted more than 10,000
tons of toxic chemicals into the air, water, and land of Ourcity. The top
chemicals emitted (in pounds) were benzene (200,000), chlorine
(100,000), pyridine (10,000) and ammonia (15,000).
Benzene is a known carcinogen. Chlorine is a highly toxic chemical that
may cause severe respiratory problems. Chlorine was involved in the
recent accident at the North High School, causing evacuation of 1100
students and teachers. Pyridine is a reproductive toxin, causing
possible damage to reproductive organs, as well as having serious
effects on the central nervous system. Ammonia, a common household
cleaner, is irritating to eyes and the respiratory system.
Newspaper staff examined reports submitted by fifteen local
manufacturing facilities under the requirements of a federal law, the
Emergency Planning and Community Right to Know Act. The federal
Environmental Protection Agency requires facilities to disclose the
amount of toxic chemicals they release into the environment each year.
In addition to benzene, chlorine, pyridine, and ammonia, local facilities
emit more than 500,000 pounds per year of ethylene, creosols,
formaldehyde, and twelve other chemicals.
Tom Jones, senior safety engineer for Newtown Chemical Company,
noted that the emissions reported do not give cause for any alarm!
Benzene emissions by all fifteen companies, he said, are only one-tenth
of the benzene given off by automobiles in Ourcity. Jones also pointed
to a recent study by the State Environmental Department which showed
that total concentrations of benzene and seven other chemicals in
17
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Facilitator's Guide
Time
OHE-1
(After they have had time to read the case, discuss the citizen
questions likely to arise (OH on citizens' questions, E-1), and the
need to know additional information before answering such questions.
Follow the manual in a conversational style without reading the manual
word-for-word. This will be giving a great deal of information at one
time, so try to break it up with questions.)
"To answer the first two questions we need to discuss several terms."
1. "Emissions means the amount of a substance released from a
facility, and can be classified as either routine or accidental. In the
current case, what is the amount of emissions? (325,000 pounds)"
(An important point to make during the discussion of emissions is
that the emissions data are usually estimates themselves—not
the results of direct monitoring. This means that the data citizens
are asking about are not perfect. This is another reason to be
careful of overinterpreting it.)
18
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Scenario 2: Routine Releases
Citizens' Questions
Emissions
vs.
Exposure
Ourcity are well below state standards. In Ourcity, they have been
measured at about 20 parts per billion at the intersection of Broad and
Main Streets.
Rodney Smith of the State Environmental Department stated that the
department will be looking more closely at the emissions to see whether
they violate any state standards. "For now," he said, "we are just happy
to see the companies providing the reports, complying with the law.
Later we will use the data to examine whether we need regulatory
changes."
After reading such a news article, the questions that people are
likely to ask local officials include:
(1) What risk is posed by these exposures?
(2) Are these emissions the cause of (various health
symptoms)?
(3) Why are the plants allowed to emit these substances?
(4) Was the facility in compliance with state and federal laws?
(5) Are there other facilities in the area that have not reported
that also are emitting these substances? Should they be
reporting too?
(6) What other sources might lead to my being exposed to
these chemicals?
To answer the first two questions, we need to know about
• emissions, concentration, exposure, and dose
• toxicity
• acute, high-level vs. long-term, low-tevel exposures
• immediate vs. delayed risks
To answer questions 3 and 4, officials should know a little about
the present system for regulating emissions, the procedures for
getting information under Title III, and how citizens can begin to
work with industry to reduce emissions if that is what they want
to do.
An emission or release is the amount of a substance released
from a facility. Releases are usually classified either as
routine—small regularly released amounts that are planned to
be released as part of a manufacturing process—or as
accidental.
18
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Facilitator's Guide
Time
OHE-2
(We have found that the material on emissions, concentration,
exposure, and dose is very difficult to teach. However, it is very
important for the audience to be comfortable with the concepts.
You may wish to mention this again sometime during the
discussion.)
2. Concentration - (We are not given the concentration of the
release in this current case.)
3. Exposure (It is important to realize that the amount of exposure
and the amount of emissions are two separate measures because
emissions get diluted, broken down in the environment, or otherwise
changed.)
(Discuss briefly the paths by which emissions might affect a
person, using Figure 1 (OH E-2) in the manual on page 20.
Question: "By which route do you think people in this
community are most likely to be exposed? Why?" Continue
with discussion on kinds of exposure, kinds of effects, and why/
what they need to know about laboratory experiments.)
4. Dose (It is related to exposure, certainly, but will vary from person
to person).
5. Toxicity
Briefly discuss acute, high-level vs. long-term, low-level exposures
19
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Scenario 2: Routine Releases
Characteristics
of the chemical
Just because a facility emits some amount of a substance does
not mean that it affects anyone. Substances are diluted as they
are released into the air and water. The concentration is the
amount of the substance in a representative unit of the air,
water, or land, For example, due to automobile exhaust,
benzene may be found in the air of many cities in a
concentration of about 8 parts per billion. The concentration is,
of course, higher if emissions within a fixed time are higher and
other conditions remain the same. Concentrations also will tend
to be higher closer to the emission source.
Exposure happens when an individual comes in contact with a
substance Exposure can occur through breathing, drinking,
eating, and by direct skin contact. The amount of exposure is
determined by many factors, including the concentration of the
substance in the environment, how long the contact lasts, and
how often the exposure occurs.
Figure 1 shows the paths by which emissions might lead to
exposure. At each point, there are difficulties in determining
how much a person is exposed. This makes it hard to estimate
the risk.
Dose is the amount of the substance that actually enters the
body. The dose is related to exposure, but differs according to
individual susceptibilities and habits. The dose received from a
hazardous chemical in the environment is influenced by the
concentration, route of entry, length of exposure, presence of
other chemicals, and the ability of the body to break down the
substance.
Toxicity is a measure of how harmful a substance is to human
health or to plants or animals. Highly toxic substances have
adverse health effects at smaller doses.
An acute exposure is one that occurs over a short period of
time. It could be a large exposure such as might occur during
an accidental spill.
Long-term exposure can occur when a substance is present in
the environment over an extended period.
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Facilitator's Guide
Time
20
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Figure 1
EXPOSURE PATHWAYS
FOR HUMANS
Deposits on crops Deposjts Qn groun(j
Crop ingestion
Uptake by
/ aquatic foods
from / Sl>
water / / f^J\
Aquatic food ingestion
/
Volatilization from
water to air
Soil
ingestion
Inhalation
of dust
Milk ingestion
Dermal
absorbtion
from soil
Water ingestion
From "Assessing Risk at Superfund Sites,"
prepared by CH2M HILL
20
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Facilitator's Guide
Time
OHE-3
OHE-4
OHE-5
Let us stop a minute to review: (Ask someone to give an example of
each of the following; make up your own if they do not cover each, OH
E-3):
Emission
Concentration
Exposure
Dose
Toxicity
Determining delayed health effects
(Mention how and why test animals are used and the types of test
used (OH on health effects studies, E-4); it is important to realize
that results can tell us approximately how many people will get sick
or die but they can never tell us which people will).
(Highlight such things as:
Why are there such high doses?
How are the results interpreted for humans
Different test methods—in vitro, in vivo
Reason for using so few test animals (OH, E-5)
(As the number of test animals decreases, the dose needed to elicit a
significant response increases. If you are not comfortable explaining
this overhead you may wish to omit it.)
(Note to facilitator: Try not to lecture too much at this point; break up
the lecture with questions such as: What do you think are people's
reactions to animal tests? What happens when you talk about an
epidemiologic study? (Knowing the rate will not tell who is going to get
sick.))
(It is important to discuss that evidence about long-term effects is often
open to interpretation and citizens' questions regarding these should be
referred to appropriate health and research officials (local and state).
However, this evidence is often the best we have and, while not perfect,
should not be disregarded. When experts describe health effects to you,
you might want to ask how good their evidence is — how many tests
have been run or a judgement on their quality.)
21
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Scenario 2: Routine Releases
Determining delayed
health effects
Acute or short-term exposures may have immediate or acute
effects and may have long-term effects. The immediate effect
of the chlorine was to cause people to gasp and choke. We do
not know about any delayed effects of acute exposures to
chlorine.
Long-term, low level exposures also may cause health effects.
Usually these are delayed health effects that may not show up
for many years. Cancer and birth defects are often delayed
health effects.
The ways in which we learn about delayed health effects make
it difficult to discuss them with any certainty.
Most of our information about delayed health effects comes
from laboratory studies conducted on test animals. Usually
more than one species is used. Animals are exposed to the
substance in different ways, including eating, drinking,
breathing, or on the skin, and different groups are exposed to
different quantities. After some time, animals are examined to
see whether there are abnormal cells or other evidence of harm.
The number of these abnormalities in the test animals is
compared to that in unexposed control animals. Statistical tests
are used to determine whether the difference between the test
animals and the controls is "significant," or suggests that the
substance may have a health effect.
Many people disregard laboratory studies because animals are
exposed to quantities of the substance that are so much higher
than humans ever would receive. Laboratory studies are done
this way in order to reduce the number of test animals used and
the time needed for the study; otherwise, studies would be
prohibitively expensive. Results from the high doses are used to
predict what would happen at more realistic doses. These
results may tell us approximately how many people will get sick
or die from particular exposure levels, but they can never tell us
which people will be affected.
Some laboratory studies are conducted on tiny organisms in test
tubes. Scientists have learned that substances that affect the
growth of these organisms often have adverse human health
effects. Usually these "in vitro" ("in glass") studies are used to
screen chemicals; those that seem suspicious are further tested
on animals ("in vivo").
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Facilitator's Guide
Time
"Some of the experts to whom these kinds of questions (about long-term
risks) can be referred would include local and state health officials,
university researchers, and EPA officials." (Turn to the Risk
Communication Resource Sheet if you have any new names to add.)
OH E-6 Back to the Questions (OH, E-6)
"Having talked about emissions, exposure, and risks, we can now try to
answer the first question - What risk is posed by these exposures? The
factors that contribute to the risk are listed on pages 22-23."
(Briefly review the factors contributing to risk).
22
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Scenario 2: Routine Releases
Answering health
effects questions
Epidemiological studies use data about humans who have been
exposed to a substance and data about their health to try to
determine whether a substance causes health problems. Such
studies are often difficult to interpret because people are
exposed to so many substances throughout their lives and
because the health effects of interest may not occur for many
years. Combined with laboratory evidence, however, it is often
possible to show that certain exposures cause unwanted health
effects in humans.
Because the evidence about long-term effects, when it is
available at all, is based on laboratory and/or epidemiological
studies it is often open to different interpretations. There is
never full proof about the cause of such effects. This may
create political controversy between people who believe the
chemical creates a risk for those exposed and those who
believe that the evidence is not good enough to suggest that
there is a risk. Citizens who want to discuss these questions
should be referred to appropriate experts. Officials should try
not to get caught in such arguments. Instead, they should try to
present whatever facts are available and provide ways for
opponents to work together to achieve acceptable policy
solutions.
Now we can turn back to some of the questions citizens ask:
1) What risk is posed by these exposures?
2) Are these emissions the cause of (various health
symptoms)?
1) What risk is posed by these exposures?
The word "risk" often carries different meanings for different
people. In communicating with the public, it is usually not
helpful to say, "the risk is high" or "the risk is low."
The factors contributing to the risk include:
Factor
Quantities
Concentrations
Exposures
Probabilities
Example
How much effluent was released
Parts per million
How much is likely to be
absorbed, inhaled, drunk
How likely is it to happen
22
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Facilitator's Guide
Time
"One way to answer the questions is to provide:
(Discuss from facing page.)
(Discuss the need to avoid comparisons with other chemicals or
activities, as discussed in the manual. Remind participants of the kinds
of risk statements they preferred on page 7. Some of these statements
provide a way of making comparisons. For example: Substance A and
Substance B are both found in our drinking water. The concentrations
are 2 ppb and 1 ppb respectively. The risk of getting cancer is twice as
high for this concentration of substance B as for the higher concentration
of substance A.
(Comparisons may be visual as well as numerical. Consider first
comparing the sizes of the United States and Russia in square miles.
The numbers are very large and hard to grasp when read out loud. In
contrast, laying a map of one nation over the other allows people to
make an approximate comparison very easily. Our goal is to make our
comparisons as clear as the overlying maps.)
23
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Scenario 2: Routine Releases
Risk levels
Toxicity
Expected number of deaths or disease per
year
How strong is the effect of exposure on
human health
(Adapted from Hance, Chess, and Sandman, "Improving Dialogue With
Communities" p. 64.)
In answering questions, people often confuse these factors
when attempting to put risks into context. In addition to these
risk factors, other characteristics we have noted on page 8
affect people's perceptions of risk, including how fair the risk
seems to be, who benefits and who bears the risk, and whether
the risk is voluntary or easy to understand.
One way to talk about risks of exposures is to provide:
1) A description of known health effects.
2) Any information about concentrations or levels of exposure.
3) Any comparisons of these concentrations with existing
government standards or other directly comparable
information. (Caution: Be careful when providing
comparisons with risks from other chemicals or activities. For
example, avoid making comparisons between risks such as
drinking water containing hazardous chemicals and the risk of
driving an automobile. Comparing dissimilar risks often makes
citizens angry, especially when the comparison is between an
involuntary risk such as drinking water containing hazardous
chemicals emitted by a facility and a voluntary risk such as
driving. However, people might find it useful to hear a
comparison of similar risks of two chemicals, both of which are
found in drinking water. The Covello, Sandman, and Slovic
book mentioned in Appendix 2 gives other good examples.)
4) In addition, people like to know why the chemical is present
in the community—that is, what it is being used for.
Remember, familiar risks are likely to be perceived as less
risky than unfamiliar or exotic ones. The multi-syllabic name
of a chemical, in contrast, might increase concern.
23
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Facilitator's Guide
Time
"Read the two sample answers provided to see if they adequately provide
the information we talked about." (Ask for discussion, can they think of
improvements?)
(The specific information about exposures known to cause leukemia is
another example of following the Cardinal Rule about honesty. Answers
should also reflect real listening to the audience.)
"Question 2 concerns causation, and that is one of the most difficult
questions you will be called upon to answer."
Briefly discuss the difficulties:
One other difficulty not mentioned in the participant manual is that often
particular health effects could be "caused" by any one of several
factors, rather than there being just one. For example, cancer may be
"caused" by chemical exposures, smoking, diet, or other factors.
Other difficulties:
Some people are more susceptible to the effects of toxic substances
because of age, previous illness, and inherited differences.
Same symptoms may be caused by different chemicals, so that a
particular health effect does not serve as an indicator of the
presence of a particular chemical.
Among the most common health effects from chemical exposures are
dizziness, headaches, tiredness, and nausea. (For more information on
causation, refer them to part 4 in Appendix 2.)
24
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Scenario 2: Routine Re/eases
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 tower 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 trfchloroethylene (TCE) is a chemical that is
emitted by local facilities into the water. TCE is used by these facilities as
a solvent and a compound in cleaning fluid and typewriter correction fluid.
In some laboratory tests on mice, TCE has been shown to have
reproductive effects at levels hundreds of times higher than the levels
found in our drinking water. We just do not know what effects exposure at
tower levels may have."
2) Are these emissions the cause 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 isle, 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.
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Facilitator's Guide
Time
Ask them the names of the local health department officials and/or
university professors to whom they can refer such questions (and have
them add the names to the Risk Communication Resource Sheet).
Briefly review some of the other responses mentioned.
Sample Questions
1. "What are the difficulties in determining causation?"
"Most officials eventually get asked whether the questioner's health
problems are the result of whatever exposure is in the public eye. This
is a very hard question, no matter how good (or bad) the scientific data."
(Review why it is so hard - see previous page.)
Page 25 suggests answers that can help people put risks in perspective.
"How safe am I?"
Questions such as this often indicate fear or uncertainty. It may be
appropriate for risk communicators to recognize and express empathy
before attempting to answer the question. For example: "I understand
your concerns for your safety," or "I know how you feel", etc.
25
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Scenario 2: Routine Releases
Additional
Responses
How Safe Am I?
• Several books are available in most public libraries. Among
them is the Concise Chemical Dictionary. Appendix 2 lists
some others.
•Local health department officials may not have the necessary
expertise but will know appropriate health officials at the state
level.
•Local universities have professors who are familiar with the
issues surrounding identification of long-term health risks.
Technical experts often anger people by emphasizing the
difficulties in establishing causation or the extent of scientific
uncertainty. Nevertheless, policy or legal decisions must often
be made even when these uncertainties exist. Sometimes it is
useful to respond to questions about individual symptoms and
emissions or exposures with four kinds of statements:
• Our scientific knowledge is not good enough for us to say
whether these exposures cause your symptoms.
• You can try to reduce the exposures by..'. (give specific
relevant directions such as drinking bottled water, keeping
windows closed, etc.)
• (If appropriate) Emissions constitute only a small portion of
most people's exposures.
• You have an opportunity to work with industry to reduce
these emissions through the LEPC.
Perhaps the most common question asked is some form of:
How safe am I?
As noted, individual exposures differ and individual
susceptibilities also differ. More important, individuals'
willingness to assume risks differ widely. In other words, safety
is a relative term. This is especially true when we consider the
non-quantitative aspects of risk, such as perceived fairness or
controllability. Local officials can provide information about risk
measurement, but each person must decide for himself or
25
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Facilitator's Guide
Time
(Stress that such questions can really not be answered definitively, since
safety is a relative term, but that they may wish to answer as a citizen,
rather than as an official, by qualifying how risk aversive they are.
Individuals' assessments of safety differ, and the only way to answer is to
tell:
a. what we know about health effects and
b. provide an individual assessment of safety for yourself.
'I drink the water" or "I let my children play outside"
and
"I am usually pretty conservative about these things, and I do not
drink the water. A friend of mine, on the other hand, drinks it all the
time."
(Also stress that citizens get angry when people refuse to answer an "how
safe am I" question. Answering questions in this way is responsive to the
last Cardinal Rule-speak with compassion.)
OHE-6
"Now let's get back to questions 3 and 4 that we asked some time ago.
(Keep up OH, E-6) In public meetings that EPA and other groups have
held, people asked, "If these substances are so toxic, why are they allowed
to be emitted at all?" To answer this, we need to know about the present
system for regulating emissions and how to obtain and analyze new
information. (Briefly review the Present System for Regulating Emissions.)
26
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Scenario 2: Routine Releases
Other questions
about Scenario 2
herself whether a risk is acceptable
something seems "safe."
-that is, whether
Without supplementary information, the emissions data
available under section 313 of Title III cannot answer questions
about safety. The data can help people choose the facilities,
media (air, water, land), or chemicals about which they would
like to know more, however. Among the other information that
would help determine whether the present level of safety is
adequate (or the present level of risk is low enough) are the
following things that affect the dose received : stack height, wind
velocity, temperature, known health effects, concentrations at
the fenceline, and the nature of the dose-response curve.
Perhaps the most important thing to remember is that because
safety is a relative term, community members must be involved
in decisions about the levels of safety they would like. One
important feature of Title III is that it provides people with initial
information to allow them to participate in such decisions,
especially through the 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:
"J drink the water, or "I let my children play outside."
An answer such as this is more effective when it includes a
recognition of people's feelings:
"I can see that you are very concerned about this. What are
your concerns and questions?"
In addition to questions about risk and safety, the newspaper
article about emissions data is likely to elicit questions about
existing government programs and enforcement:
3) Why are the plants allowed to emit these substances?
4) Is this facility in compliance with state or federal laws.
5) Are there other facilities in the area that have not
reported that are also emitting these substances?
26
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Facilitator's Guide
Time
(After reviewing the System for Regulating Emissions mention that one
way to respond to the question of "why are the plants allowed to emit
these substances" is because the current laws do not specifically
prohibit certain emissions and suggest that citizens get in touch with
their representatives in Congress to express their concern about toxic
releases.)
27
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Scenario 2: Routine Releases
Present System
for Regulating
Emissions
To answer question 3, we need to know about the present
system for regulating emissions. Answering questions 4 and 5
requires obtaining and analyzing new information.
The Present System for Regulating Emissions
It is difficult to answer the question about why plants are allowed
to emit hazardous substances because of the intricacies of the
federal and state laws regulating toxic chemicals. Although the
emissions of many chemicals are indirectly controlled by air,
water, or land disposal regulations, few are subject directly to
specific federal emission permits or standards. Most EPA
regulations deal with ambient levels of chemicals (in other
words, they specify acceptable concentrations in the
community's air or drinking water — not the amounts of the
chemicals that can be released from a particular facility).
Where EPA does have regulations based on emissions, they
generally apply to classes of chemicals (volatile organic
compounds and paniculate 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.
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Facilitator's Guide
Time
What does EPA do and what can you do as a citizen if you suspect
facilities of not following the law?
(Briefly review that section on p. 28.)
Have them read the sample answer to question 3 on page 28-29.
Does it sound realistic?
What would make it better?
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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
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Facilitator's Guide
Time
The answer to question 4 requires review of reports filed by the facility
with EPA or appropriate state agencies." (As officials, they should
know to whom they should refer such questions).
"A sample answer to question 5 is on page 29. This is included as a
suggestion for how your answers might be structured and is not intended
to be memorized or repeated verbatim. Please take a moment to read
through it."
"The answer to question 5, basically, is probably yes, because:
1. Some facilities are not required to (mention such things as non-
manufacturing facilities such as dry cleaners and gas stations
which may have serious emissions),
2. Others may not know they are required to, and
3. Still others may have decided not to report."
4. Also, not all substances are covered under the act. List of the
substances covered is in Appendix 6.
Sample Questions:
1. "What companies in this town have routine releases of
substances?
2. Do they all report? Have you already received inquiries about
these? What were they?"
(Discuss the EPA penalties (fines) and recourse by citizens lawsuits)
Example of EPA Enforcement
"As an example, EPA announced in December, 1988 almost $1.5
million dollars in fines against 25 companies for failing to meet the
new deadline for reporting chemical emissions. The Inland Steel
Company in Indiana was assessed the largest fine of $721,000 by
EPA for failing to report 33 different substances, ranging from
aluminum to xylene." (Paraphrased from New York Times
National, December 21,1988.)
Review question 6
29
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Scenario 2: Routine Releases
agencies are learning about emissions they may not have known about
before. This will provide a better basis for appropriate policy responses.
Because the information is also available to citizens, they have an
opportunity to participate in policymaking concerning emissions to a
greater extent than before. One way they can participate is by becoming
active in the Local Emergency Planning Committee."
To answer question 4—Is a particular facility in compliance
with state and federal laws? will require review of reports filed
by the facility with EPA or the appropriate state agency. Local
officials can provide citizens with telephone numbers where they
can obtain answers.
The answer to question 5—"Are there other facilities in the
area that have not reported that are also emitting these
substances?"— is largely procedural, although it should have
some substantive information if available:
"Probably. The Local Emergency Planning Committee, interested citizens,
and government agencies can use other information provided under Title III
and other laws to try to identify facilities that may be emitting substances.
Industry associations are also trying to get word out to their members
about the obligation to report. Citizens who live near manufacturing
facilities can certainly check with EPA or the [appropriate state agency that
receives reports under section 313] to see whether neighboring facilities
have reported. If not, they may talk to the facility manager to find out why.
Remember, section 313 covers only some chemicals, so many facilities
may have emissions they do not need to report. Also, facilities need not
report if they use chemicals in amounts below specified quantities. Among
the kinds of facilities that emit this chemical but are not included in the Title
III requirement are . Because there are many such facilities in our
community, there may be some cause for concern."
6) What other sources might lead to my being exposed to
these chemicals?
The answer to this question is related to the answer to question
5, but can be based more closely on the data available under
sections 312 and 313. The chemical inventories submitted to
the LEPC under section 312 tell what chemicals are stored in
the community, thereby providing some indication of the range
of possible exposures. More important, the emissions data
provided under section 313 provide some basic information
about which chemicals are disposed to which medium. If
aggregated for the whole community, these data can suggest
29
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Facilitator's Guide
Time
Sample Questions:
"What is the state agency that receives reports under section 313?"
Give the answer if they don't know it, and have them add it to the resource
sheet. Also discuss that if there are lots of companies not reporting then
there could be reason for concern. Mention some of the ones who don't -
gasoline stations, dry cleaners, others that you know of.
"You may not have the expertise to answer all of the questions we
have discussed, so you should know when and where to refer appropriate
questions. You should be prepared to give reasonable answers to
reasonable questions, since citizens may become angry if you defer all
questions."
30
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Scenario 2: Routine Releases
the routes by which people might be exposed to particular
chemicals. The newspaper article in which the emissions are
reported for this scenario does not consider the medium to
which the chemicals are emitted, but this information is readily
available from the forms submitted to EPA and state agencies.
Because the answer to this question rests on considering data
for all local facilities at the same time, officials may feel that they
are unable to answer it—they lack the time to do the necessary
calculations. In anticipation of such questions and needs,
Congress required EPA to computerize the emissions data. The
Toxic Release Inventory (TRI) database is available to the
public at modest cost. It contains all the emissions reports and
allows users to examine the data in a variety of ways, including
adding up all emissions of a particular chemical to a particular
medium in a city or county. Appendix 2 provides information on
how to get access to the TRI database. SERCs also have
access to a similar database maintained at EPA, and may be
able to provide some data to questioners.
30
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Facilitator's Guide
Time
Summary
In summary, know when to refer specific questions about complex
issues, but also be prepared to answer reasonable questions. Citizens
get angry if repeatedly told "I cannot answer that".
1. Comparisons with government standards can sometimes be
misleading - it is not true that everything less than the standard is safe
while everything over the standard is unsafe.
2. Questions of safety can never completely be answered; safety is
a matter of interpretation - you can communicate about safety by giving
a personal safety comparison.
3. Remember that concerns about risk often reflect concerns about
power or other issues such as fairness.
4. Examples of taking control of risk:
a. Stand upwind at the gas station. Ask the station to put the tabs
on the gas pump handle so you can walk away and not breathe
the fumes.
b. Go to the LEPC and ask them to help you work with a facility.
5. Help people understand why the chemical is present in the
community in the first place. It also helps to explain for what common
products these chemicals are used.
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Scenario 2: Routine Releases
Summary of
Scenario 2:
Routine Emissions
Citizen concerns about the routine emissions reported under
Title III section 313 and described in the newspaper article
cover a broad range of complex issues. Officials without
specific expertise in these areas should not attempt to explain
the details, instead referring questioners to appropriate expert
sources. On the other hand, they should anticipate questions
and prepare replies, since citizens may become angry if
constantly told, "I cannot answer that. Please call so-and-so."
But don't make up an answer when you don't know.
Among the strategies for responding to questions about long-
term health effects where there is uncertainty about whether the
particular chemical causes a health effect and/or about whether
the emissions in question are related to particular citizens'
health problems are the following:
1. Risks or risk levels should be compared at two different
times, compared against a government standard, or compared
with different estimates of the same risk. Note that comparisons
with government standards, which are set using a combination
of political and scientific criteria, may be misleading—it is not
true that everything less than the standard is "safe" while
everything over it is "unsafe." Different risks, especially risks
with different characteristics, should not be compared. (See
above, page 8. For more on risk comparison, see Covello,
Sandman, and Slovic, "Risk Communication, Risk Statistics,
and Risk Comparisons.")
2. Questions of "safety" are difficult to answer, especially on the
basis of section 313 emissions data alone. Different people
assess safety differently. However, statements describing how
you would or are behaving in the same circumstances in
combination with a description of the risk provide listeners with a
basis for their own comparisons. People should have an
opportunity to participate in determining whether existing levels
of safety are sufficient.
3. Concern about risks may really reflect concerns about power
or other political issues. Try to ascertain people's real concerns
and answer those. Many concerns are really about whether
procedures are fair and allow for adequate participation. Use
the Local Emergency Planning Committee (LEPC) as a forum
for all parties to work together.
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Facilitator's Guide
Time
OH E-7 (OH on pie, E-7)
"We have covered information on many areas that will help you in commu-
nicating about risk. As we look a t the next scenario on storing large
amounts of chemicals we will discuss two additional areas of information
that are important."
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Scenario 2: Routine Releases
4. Where possible, indicate ways people can control risks.
They may be able to take some personal preventive action such
as drinking bottled water and using pesticides more carefully
around the home, or they may be able to join the LEPC or other
community groups to act collectively against a risk.
5. Help people understand why the substance is present in the
community in the first place. Familiar risks seem less worrisome
than unfamiliar ones. Long chemical names are usually
unfamiliar. Explaining what familiar items the chemical is used
to manufacture may help people balance the risks and benefits.
32
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Facilitator's Guide
Time
2:40
Scenario 3
"Another type of situation is likely to result in citizen or press questions -
that is the storage of large quantities of hazardous substances. This
third scenario deals with a news article on this situation. Please take a
moment to read through this news release and then we will discuss
different response strategies."
(Allow participants 1-2 minutes to read the article.)
33
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Scenario 3: Storing Large Quantities
Scenario 3
Storing Large Quantities
About six weeks after publication of the article on emissions
data, the following article appears in the local newspaper.
Ourcity 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 that:
• Seventy facilities have submitted inventories. The federal law covers all
commercial facilities that store hazardous chemicals in amounts greater
than 10,000 pounds. There are 400 members of the Ourcity Chamber of
Commerce. Charles Smith, president of Ourcity Citizens Against Toxics,
stated that it seems likely that not all the facilities have reported that
should have.
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Facilitator's Guide
Time
OHF-1
"Now, let's look at some of the questions citizens are likely to ask.
(Read the questions listed; OH on questions, F-1)
To answer most of these will require some understanding of the
emergency planning process and how we assess potential risks
posed by facilities that store and use hazardous chemicals. Section
303 of Title III requires the Local Emergency Planning Committee to
formulate a plan for emergency response."
34
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Scenario 3: Storing Large Quantities
Citizens' Questions
• Forty facilities store substances in quantities greaterthan 100 thousand
pounds, and some as much as 1 million pounds. If storage containers
leak, large quantities of chemicalscould 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 by the 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 thatthe annual inspections of facilities storing hazardous chemicals
convinced them that chemicals are properly stored. They are working
with facilities to reduce the possibility of accidents further. They stated
that the emergency response plan updated under the same federal law
that requires submission of chemical inventories also ensures citizens'
safety.
Neighbors of plants are not so sure. "About once a month I hearthe sirens
overthere," says Sharon Shivers, who lives in the Northridge neighborhood
near the Generic plant. "I think their storage is faulty but they don't want
us to know."
After reading this article, citizens might ask the following
questions:
1) Are the hazardous materials used by nearby facilities stored
properly? What is the chance of leaks developing?
2) How likely are stored materials to be involved in an
accident?
3) If they are released, what kinds of health or other hazards
do they present?
4) Can we reduce the amounts of these materials that are
stored in order to reduce risk?
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Facilitator's Guide
Time
OHF-2
"To plan for emergencies, LEPCs will follow the following steps:
Identify hazards (determine the ways in which facilities store and
use hazardous chemicals)
Conduct a vulnerability analysis using worst case assumptions
Complete a risk analysis based on hazard identification and
vulnerability analysis
Work with these high-priority facilities to refine the hazards
identification.
"An example of a hazards analysis is on pages 36-37. (OH, F-2,
which summarizes Figure 2.)
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Scenario 3: Storing Large Quantities
Planning for Hazardous
Chemical Emergencies
5) What about the danger from chemicals stored by facilities
that didn't have to report because they had less than 10,000
pounds?
Answers to these questions require some understanding of the
process by which we plan for hazardous materials accidents
and how we assess potential risks posed by facilities that store
and use hazardous materials. Some of the questions raise
issues we have already considered—providing information
about health effects and opportunities for citizens to participate
in planning and risk reduction activities.
Section 303 of Title III requires the Local Emergency Planning
Committees (LEPCs) to formulate a plan for emergency
response. In order to make a realistic plan, LEPCs must first
learn where and what chemicals are stored. The chemical
inventories submitted under sections 311 and 312 and the lists
of extremely hazardous substances submitted under section
302 provide this information.
To plan for emergencies, LEPCs follow these steps:
1. Identify Hazards: using information provided by facilities,
determine the ways in which they store and use hazardous
chemicals.
2. Conduct a vulnerability analysis: using credible worst case
assumptions, determine a vulnerability zone and identify
special facilities within that zone such as nursing homes or
schools or special problems such as a drinking water source.
3. Work with high-priority facilities to refine and re-evaluate the
hazards identification and vulnerability analysis.
4. Complete a risk analysis: make a rough estimate of risks
based on hazard identification and vulnerability analysis and
likelihood of releases. Then, integrate this information into a
community-wide emergency plan. (The components of a
community-wide plan are described on page 12.)
Figure 2 shows a sample hazards analysis for an extremely
hazardous chemical at one site. If such an analysis is conducted
for all hazardous chemicals found in the community, it will
35
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Facilitator's Guide
Time
This is taken from the Green Book, which is a followup to the Orange
Book NRT-1 about emergency planning. This is a sample hazards
analysis for one extremely hazardous substance at one site.
Note that a properly-conducted hazards analysis provides answers to
each question on page 34. You might read these questions, asking (or
showing) participants where in the hazards analysis each question is
answered. For example:
1. Are the hazardous materials stored properly? This is answered by
the risk analysis under 3 on page 37.
The other questions on p. 34 are:
2. How likely are stored materials to be involved in an accident?
3. If they are released, what health or other hazards do they present?
4. Can we reduce the amounts stored?
Although both pages look alike, they are different. The first page is
the initial screening. The second page is the revaluation after the
facility changes from storing 800 Ibs to 500 Ibs. (which changes the
vulnerability zone).
A goal should be to do at least the initial screening for all chemicals and
facilities, then identify those that have the highest risk for the follow-up
screening. It is an on-going process.
36
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Figure 2
SAMPLE HAZARDS ANALYSIS FOR ONE
EXTREMELY HAZARDOUS SUBSTANCE
AT A HYPOTHETICAL SITE
(REPEAT THIS ANALYSIS FOR EACH EHS AND SITE IN THE COMMUNITY)
INITIAL SCREENING
1. HAZARDS IDENTIFICATION
(Major Hazards)
a. Chemical
b. Location
c. Quantity
d. Properties
2. VULNERABILITY 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
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Facilitator's Guide
Time
37
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REEVALUATION(PLANNING)
1. HAZARDS IDENTIFICATION
a. Chemical
b. Location
c. Maximum quantity that
could be released
d. Properties
2. VULNERABILITY ANALYSIS
a. Vulnerable Zone
b. Population within vulnerable zone
c. Essential services
3. RISK ANALYSIS
a. Likelihood of hazard occurrence
b. Consequences if people are exposed
c. Consequences for property
d. Consequences of environmental
exposure
e. Summary: likelihood/severity of
on site
Chlorine
No change
500 Ibs. (decrease)
No change
Zone decreases (new radius -1.0 miles) due to
smaller quantity released and use of urban dis-
persion model.
Decreases; total population in vulnerable zone is
1250
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
and 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.)
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Facilitator's Guide
Time
'Now, returning to the questions:
Having done the plan, reviewed the company reports on
chemicals, and completed the hazards analyses, do you have
enough information to answer the first question? (Are hazardous
materials stored properly?) -
How about the second question? (Sample answer: "Based on the
vulnerability analysis that we conducted with company X and the review
of its emergency response plan, it appears that the company has
established adequate measures to safequard against accidental
releases.")
The other questions? Which if any will need to be referred?
SAMPLE QUESTIONS
1. "Is there such a plan for this community?"
(If yes, solicit specific illustrations from the audience as you briefly
review each of the steps in the plan. If no, then as you review, mention
that they should be thinking of what would be involved in accomplishing
each step.)
2. What are the political realities of dealing with such issues as
releases and storage of hazardous chemicals?
On the one hand, a total ban on all hazardous chemicals/substances
would insure the public safety but would severely impact the business
community and inhibit economic development; on the other hand,
unrestricted growth and an overly-permissive attitude toward these
materials could result in a public catastrophe.
What are the right balances for which to strive?
(Purpose here is to be sensitive to the issues involved. Most people are
surprised when they learn how much and how many different
substances are being stored, especially in non-manufacturing rural
areas.)
38
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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 aftera?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 step! outlined above, it should be able to assist in
answerhg the question about proper storage.
i
It is diffbult to estimate the chance of leaks or accidents. This
questi(jfi is answered by describing the planning process, which
both ejcourages facilities to store their hazardous chemicals in
the bet way and sets up a plan for minimizing damage that
mightesult if an accident does occur.
i
Agaii in answering questions about accidents, it is important to
remmber the risk characteristics listed on page 8. People feel
mop confident when it seems that all likely causes of accidents
haw been considered and planned for, because the risks seem
mire controllable, better understood, and less likely to be
^astrophic.
n'lity owners and managers have the final say over reducing
tie amounts of stored hazardous chemicals. The LEPC can
ppvide a forum in which citizens can voice concerns to industry
r|>resentatives and work with them to get these amounts
rduced. Many facilities are willing to do this after they see the
rsults of a vulnerability analysis. They may find out that their
iijentory costs decrease as well by having less of each
rpardous chemical on hand.
l
li)rmation about the health effects of individual chemicals will
a) be available through the LEPC, health professionals in
s^e and local health and environment departments, poison
o|rol centers, and academic institutions, or through the
rerences listed in Appendices 2 and 4.
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Facilitator's Guide
Time
Summary
(review)
While there may be more information needed to answer some types of
questions, these pieces of information should equip you to answer
most questions about risk.
J
39
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Summary The kinds °f questions that storage raises are hard to answer.
Because each facility and each community is different, the
answers can only be obtained by working carefully through the
specific data provided by local facilities. This is very time-
consuming work. After the data are obtained, citizens will still
have to work with experts to determine whether storage
methods and quantities are appropriate and whether health
effects are worrisome.
Rather than providing sample answers, as we did in the other
scenarios, we can offer only general suggestions:
Officials can best answer most of these questions by
—referring to the plan and the procedures that went into
creating it, and
—referring to the sources within government where citizens
can work with government and industry.
39
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Facilitator's Guide
Time
3:00
Summary and Conclusion
"The Seven Cardinal Rules, from the pamphlet by Vince Covello and
Frederick Allen mentioned earlier, are an effective way of summarizing
what we have discussed today. (Remind them that they already have a
stand-alone copy of the Seven Cardinal Rules; since this manual has a
copy of those rules, they should give their stand-alone pamphlet to
someone back home who can benefit from it).
1. Accept and Involve the Public as a Legitimate Partner
Is this logical or is it just a platitude?
Are there times when you cannot involve the public? (Yes) When?
(Have them give examples).
2. Plan Carefully ...
3. Listen to the Public's Specific Concerns
Remember the "outrage" factors we discussed earlier - people's
expressed concerns may only be an indication of deeper concerns
such as "This is not fair."
Also, remember that you may need to use a variety of different ways
of talking about risk, depending upon the audience.
40
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Summary &
Conclusion
The "Seven Cardinal Rules of Risk Communication," written by
Vincent Covelio and Frederick Allen and available in an EPA
pamphlet are reprinted here. They both summarize and add to
the information presented in this manual.
1. Accept and Involve the Public as a Legitimate Partner
* Involve the community early.
* Involve all parties that have an interest or stake in the
issue.
* Remember, you work for the public.
The goal of risk communication should be to produce an
informed public that is involved, interested, reasonable,
thoughtful, solution-oriented, and collaborative.
2. Plan Carefully and Evaluate Your Efforts
* Begin with clear, explicit objectives.
* Evaluate the information you have about risks and know its
strengths and weaknesses.
* Identify and address the particular interests of different
groups.
* Train your staff — including technical staff — in
communication skills.
* Practice and test your messages.
* Evaluate your efforts and learn from your mistakes.
3. Listen to the Public's Specific Concerns
If you do not listen to people, you cannot expect them to
listen to you. Communication is a two-way activity.
* Do not make assumptions about what people know,
think, or want done. Take the time to find out what
people are thinking.
* Let all parties with an interest in the issue be heard.
* Identify with your audience. Put yourself in their place
and recognize their emotions.
People are often more concerned about trust, credibility,
competence, control, voluntary fairness, caring and
compassion than mortality statistics or quantitative risk
assessment.
40
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Facilitator's Guide
Time
4. Be Honest, Frank and Open
Know when to refer to other sources of information.
5. Coordinate and Collaborate with Other Credible Sources
We've talked about some of these sources - local and state health
officials, university researchers, etc. Refer to the list they have
been working on.
6. Meet the Needs of the Media
Remember to communicate risk in several ways since different
people will understand it differently
41
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4. Be Honest, Frank and Open
* State your credentials; but do not ask or expect to be
trusted.
If you do not know the answer or are uncertain, say so.
Get back to people with answers. Admit mistakes.
* Disclose risk information as soon as possible.
* Do not minimize or exaggerate the level of risk.
* Lean toward sharing more information, not less — or
people may think you are hiding something.
Trust and credibility are difficult to obtain. Once lost they are
almost impossible to regain completely.
5. Coordinate and Collaborate with Other Credible
Sources
* Take time to coordinate with other organizations or
groups.
* Devote effort and resources to the slow, hard work of
building bridges with other organizations.
* Try to issue communications jointly with other credible
sources.
Few things make risk communication more difficult than
conflicts or public disagreements with other credible sources.
6. Meet the Needs of the Media
* Be open with and accessible to reporters; respect their
deadlines.
* Provide risk information tailored to the needs of each
type of media.
* Prepare in advance and provide background material on
complex issues.
* Do not hesitate to follow up on stories with praise or
criticism.
* Try to establish long-term relationships of trust with
specific editors and reporters.
The media are frequently more interested in politics than in
risk; more interested,in simplicity than in complexity; more
interested in danger than in safety.
7. Speak Clearly and with Compassion
Technical information and jargon are barriers to successful
41
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Facilitator's Guide
Time
7. Speak with compassion
And finally, there is an overriding assumption about risk
communication, perhaps an informal eighth rule:
"Know what you are talking about!"
Most of these rules are based on common sense, and while they are
necessary for effective risk communication—and all kinds of
communication—they cannot guarantee it.
There will be successes and failures. Remember that if a particular
instance of risk communication does not go well, it can be taken as an
opportunity to learn what not to do next time.
42
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communication with the public.
Be sensitive to local norms, such as speech and dress.
Use vivid, concrete images that communicate on a
personal level. Use example and anecdotes that make
technical risk data come alive.
Use simple, non-technical language.
Use risk comparisons to help put risks in perspective; but
avoid comparisons that ignore distinctions that people
consider important.
Acknowledge and respond (both in words and with
actions) to emotions that people express — anxiety,
fear, outrage, helplessness.
Always try to include a discussion of actions that are
under way or that can be taken. Tell people what you
cannot do. Promise only what you can do, and be sure
to do what you promise.
If people are sufficiently motivated, they are quite capable
of understanding complex risk information, even if they
may not agree with you.
Regardless of how well you communicate risk information,
some people will not be satisfied.
These rules seem to be only common sense. Yet it is surprising
how often they are violated when communicating about risk.
Following them does not guarantee effective risk
communication. On the other hand, it is unlikely that you will
communicate effectively without them. There is also an
informal eighth rule, which underlies all the others:
Know what you are talking about.
Since no one person can be expected to know everything, we
have tried to provide sources for additional information as well
as sample answers to questions in which you refer citizens to
these sources.
Talking to people about risk is difficult. Certain buzzwords or
ideas such as "cancer" often set off reactions that may be too
strong. Many familiar chemicals that people use every day may
have more serious effects than some of the unfamiliar
chemicals they will hear about under Title ill. Public officials
must try to help citizens keep these risks in perspective.
42
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Facilitator's Guide
Time Remember that peoples' perceptions of risk are often related to the
perceptions of control - One way of increasing that control is by
sharing information on risks and courses of action.
Stress the opportunity for citizen involvement on the LEPC.
Summary and Plan of Action
"We have spent the last few hours discussing your role as a risk
communicator, and have suggested strategies for responding to citizen
concerns.
OH F-3 (Put up Pie OH, F-3) We have talked about the pieces of the pie, so to
speak, that are necessary to effectively answer questions regarding risk.
It has not been our attempt to make you an expert in risk analysis and
emergency response - rather it has been our aim to make you aware of
the kinds of questions you as local officials are likely to receive,
and to suggest the resources that are available to you in helping to
answer these questions."
Review Objectives:
Our objectives for today were: (As you read these off, mention how we
achieved these; also read off their objectives, if there were any, and
how we accomplished these as well) (You might wish to refer to page
3)-
43
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Opportunity for
Citizen Involvement
Plan of Action
One of the most important factors that affects people's
perceptions of risk is whether they feel in control. That is why
several of our suggestions for response to citizen questions,
especially when the questions cannot be answered with
unequivocal scientific information, is to offer people a means for
participating in decisionmaking about chemicals in their
communities. Local Emergency Planning Committees (LEPCs)
offer, or should offer, a logical place for such participation.
Because LEPCs include representatives from government,
industry, and citizen groups, they offer a good setting for
encouraging the different interests to work together.
Risk communicators should take every opportunity to suggest
direct ways in which individuals can take control to reduce their
exposures to hazardous chemicals, such as standing upwind
while filling the gas tank of an automobile.
Perhaps the single most important factor in communicating risks
is that the source be perceived as trustworthy and willing to
listen as well as talk. Other kinds of communication also benefit
from these characteristics. Public officials can improve their
effectiveness in many areas by learning the lessons of risk
communication: develop a relationship of trust with people
before some particular incident (such as a chemical spill)
occurs, and talk with, not la, 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.'1 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;
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Facilitator's Guide
Time
'But where do you go from here?"
1. "So that you can get the most out of this workshop, it is important
that you continue to develop and update these resources.
2. Action Plan. As it says in the manual, we can't give you a set
formula for dealing with all problems, but we can identify some of the
resources that will be necessary to know under almost any
circumstances. The action plan on pages 43-44 mentions some of
these needed information items." (Turn to the page following the table
of contents and have them write in the information that has already
been identified during the workshop. Challenge them to complete the
remainder of the resource sheet by a suggested date. Then turn back
to pages 43-44 and review the remainder of the steps.)
3 'The remainder of the steps in your plan of action should be the
minimum that you do as part of your continued learning in this area."
"How can you best encourage citizens to participate in
decisionmaking about chemicals in this community?"
Get involved in the LEPC. When answering concerned citizens'
questions, offer the opportunity for participating in the LEPC.
(Pass out the evaluation form and ask them to complete it. As a facilitator,
you may wish to do a follow-up evaluation 3-6 months after the workshop
asking whether the course made any difference in what they have been
doing: Are they doing more risk communication? Are they doing it
differently than before? Do they feel more comfortable in their roles as risk
communicators? Etc.)
(Please let Ann Fisher or Susan Madden know the results of these
evaluations if you think they contain useful suggestions for revising the
manual.)
(Thank them for coming and offer any additional assistance that you are
willing to give.)
44
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other information might take some "digging." This resource
sheet will provide a quick reference to many of the contact
people who are knowledgeable about emissions, releases,
stored substances, etc. Update this resource sheet annually.
2. Obtain copies of this manual for persons involved in your
emergency plan.
3. Initiate contact, if you have not already done so, with
members of your Local Emergency Planning Committee, and
learn more about their activities.
4. Keep this manual in an accessible place for periodic review
and/or in case of emergencies.
Please let us know your successes in communicating about risk,
and what works most effectively. Contact:
Ann Fisher
Office of Policy Planning & Evaluation, PM-221
Environmental Protection Agency
Washington D.C. 20460
(202) 382-5500
Susan G. Madden
LBJ School of Public Affairs
The University of Texas at Austin
Austin, Texas 78713
(512)471-4962
Steve Finefrock
National Emergency Training Center
Building N
Room 242
Emmitsburg, Maryland 21727
(301)447-1282
44
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APPENDIX 1
Glossary of Commonly Used Terms
Absorbed dose-The amount of a chemical that enters the body of an organism.
Acute-Sharp, severe; having a rapid onset, severe symptoms, and a relatively short duration.
Acute exposure: a single exposure of relatively short duration.
Acute toxicity: the development of adverse health effects soon after a single exposure to a
substance.
Additive effect-Combined effect of two or more chemicals equal to the sum of their individual effects.
Ambient—Environmental or surrounding conditions.
Animal studies (sometimes called "laboratory studies")--lnvestigations using animals as surrogates
for humans, on the expectation that results in animals are pertinent to humans.
ATSDR-Agency for Toxic Substances and Disease Registry, part of the U.S. Public Health Service,
based in Atlanta, Georgia, 30333.
Carcinogen-A chemical that causes or induces cancer.
CAS registration number-A number assigned by the Chemical Abstracts Service to identify a
chemical.
Chronic—Occurring over a long period of time, either continuously or intermittently.
Chronic effect-effects that last a long time even if caused by a single acute exposure. (See also
delayed effect.)
Chronic exposure-long-term, low-level exposure to a to a chemical.
Concentration-the amount of the substance in a representative unit of the medium.
Delayed effect~an effect of exposure that does not occur for some time. Sometimes called a "chronic"
effect.
Dose-The amount of the sbustance that actually enters the body.
Dose-response-A quantitative relationship between the dose of a chemical and an effect caused by the
chemical.
Dose-response curve-graphical presentation of the relaionship between degree of exposure to a
chemical (dose) and observed biological effect or response. :
Emission or release-the amount of a substance released from a facility. Releases are usually
classified as routine-small regularly-released amounts that are planned to be released as part of a
manufacturing process-and accidental.
Endangerment assessment-a site-specific risk assessment of the actual or potential danger to human
health or welfare and the environment from the release of hazardous substances or waste. The
endangenment assessment document is prepared in support of enforcement actions under CERCLA or
RCRA.
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Environmental fate--The destiny of a chemical after release to the environment; involves
considerations such as transport through air, soil, and water; bioconcentration; degradation.
EPCRA-The Emergency Response and Community Right-to-Know Act of 1986; same as SARA Title III.
Epidemiological studies-Investigation of factors contributing to disease or adverse health effects in
human populations.
Exposure--The contact with a chemical or physical agent. This contact can occur through breathing,
drinking, eating, and by direct skin contact.
Extrapolation-Estimation of unknown values by extending or projecting from known values.
Extremely hazardous substances-Chemicals that have the potential for causing death or irreversible
toxicity after relatively short exposure to small amounts. (They are acutely toxic.) On the basis
of toxicity, generally in air, EPA has identified the list of the chemicals in Appendix 5.
Latency-Time from the first exposure to a chemical until the appearance of an adverse health effect.
LC50-the concentration of a chemical in air or water that is expected to cause death in 50 percent of
test animals living in that air or water.
LD50-The dose of a chemical by a specific exposure pathway (eating, breathing, injection, or absorbed
by the skin) that is expected to cause death in 50 percent of the test animals so treated.
LEPC-Local Emergency Planning Committee. Local body established under Title III.
LOAEL-Lowest-Observed-Adverse-Effect Level; the lowest dose in an experiment that produced an
observable adverse effect.
Laboratory studies-Studies of the effects of chemicals on animals or cells.
-In vitro studies-Studies of chemical effects conducted in tissues, cells or subcellular extracts
from an organism (i.e., not in the living organism).
-In vivo studies-Studies of chemical effects conducted in intact living organisms.
Long-term exposure-This occurs when a substance is present in the environment around a person
over a long period of time.
MSDS-Material Safety Data Sheet. A description of the chemical, physical, and health effects of a
chemical along with methods for protection and emergency response written for workplace settings.
Materials balance--An accounting of the mass flow of a substance from sources of production, through
distribution and use, to disposal or distribution, and including any releases to the environment.
Mutagen-An agent that causes a permanent genetic change in a cell other than that which occurs during
normal genetic recombination.
NOAEL-No-Observed-Adverse-Effect Level; the highest dose in an experiment that did not produce an
observable adverse effect.
NRC-National Response Center, 1-800-424-8802.
Pathogen-Any disease-causing agent, usually applied to living agents.
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Permissible dose--The dose of a chemical that may be received by an individual without the expectation
of a significantly harmful result.
RCRA--Resource Conservation and Recovery Act. Another federal statute concerning hazardous
substances.
Release-see "Emission."
Reversible effect--An effect that is not permanent; an especially adverse effect that diminishes when
exposure to a toxic chemical ceases.
Risk--The likelihood of injury, disease, or death.
Risk assessment-A qualitative or quantitative evaluation of the environmental and/or health risk
resulting from exposure to a chemical or physical agent (pollutant); combines exposure assessment
results with toxicity assessment results to estimate risk.
Risk estimate--A description of the probability that organisms exposed to a specified dose of chemical
will develop an adverse response (e.g., cancer).
Risk factor-Characteristic (e.g., race, sex, age, obesity) or variable (such as smoking, occupational
exposure level) associated with increased probability of an adverse health effect.
Route of exposure-the avenue by which a chemical comes into contact with an organism (e.g.,
inhalation, ingestion, dermal contact, injection).
SARA-Superfund Amendments and Reauthorization Act of 1986.
SERC-State Emergency Response Commission. Established under Title III.
Teratogenicity-The capacity of a physical or chemical agent to cause hereditary congenital
malformations (birth defects) in offspring.
Threshold-The lowest dose of a chemical at which a specifed measurable effect is observed and below
which it is not observed.
Title lll--the common name for the Emergency Planning and Community Right to Know Act of 1986,
which is Title III of the Superfund Amendments and Reauthorization Act.
Toxicity-The quality or degree of being poisonous or harmful to plant, animal, or human life.
TRI-Toxics (or Toxic Chemical) Release Inventory. The database containing annual toxic chemical
release reports submitted by certain manufacturing facilities, specified in Section 313 of EPCRA.
The TRI is available to the public in county libraries, through a national computerized database
maintained by the National Library of Medicine, and through regional EPA offices. See Appendix 2
for more information. '
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APPENDIX 2
References and Sources
1. Title in
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., DavkJ B. McCallum and Maria Pavlova. Effective Risk Communication: The Role and
Responsibly 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 fa Community Groups. Washington, D.C.: EPA. September, 1989.
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3. About Specific Chemicals
Chemical Manufacturers Association. Chemical Referral Center. 1-800-262-8200.
CAMEO (Computer-Aided Management for Emergency Operations). (Software-contains descriptions,
health effects information, and emergency response information for more than 2400 chemicals.)
Department of Transportation. Emergency Response Guidebook. Lists about 1,000 substances by
name and DOT identification number, giving hazards and isolation distances. Available from Office of
Hazardous Materials Transportation, DMH-50, RSPA, DOT, 400 7th Street, S.W., Washington, D.C.
20590.
Environmental Protection Agency. Common Synonyms for Chemicals Listed under Section 313 of the
Emergency Planning and Community Right-to-Know Act of 1986. December 1988.
Illinois EPA. Chemical Information Sheets. Springfield, III, 1986,1987.
Massachusetts Department of Environmental Quality Engineering. Layperson's Guide to Reading
MSDSs: Boston, Mass.
Michigan Department of Natural Resources. Chemical Summaries. East Lansing, Michigan.
New Hampshire Department of Health and Human Services. Health Information Summaries. Concord,
N.H.
New Jersey Department of Health. Hazardous Substance Fact Sheets. Trenton, N.J. (Distributed by
EPA to SERCs.]
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.
Wexier, 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.C/je/n/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
Health, 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 Reductbn. Washington DC: The
Conservation Foundation, 1987.
Muir, Warren and Joanna Underwood. Promoting Hazardous Waste Reduction: Six Steps States Can
Take. New York: INFORM, 1987.
Sarokin, David J., Warren Muir, Catherine G. Miller, and Sebastian R. Sperber, Cutting Chemical Wastes:
What 29 Organic Chemical Plants are Doing to Reduce Hazardous Wastes. New York: INFORM, 1985.
8. Databases.
National Library of Medicine (NLM), 8600 Rockville Pike, Bethesda, MD. 20894. 1-800-638-8480 or
301-496-6193. Databases are available online through a personal computer and modem connection, or
in a medical library.
TOXLINE. A collection of online bibliographic information convering the
pharmacological, biochemical, physiological, and toxicological effects of drugs and
hazardous chemicals. For information: MEDLARS Management Section at the NLM
address given above.
Toxicology Data Network System (TOXNET). A computerized system of files oriented to
toxicology and related areas. The files include the Hazardous Substances Data Bank
(HSDB), the Registry of Toxic Effects of Chemical Substances (RTECS), and the
Environmental Protection Agency's Toxic Chemical Release Inventory (TRI). For
information, contact the NLM at the address given above.
CCINFOdisc. Canadian Centre for Occupational Health and Safety.
CCINFOdisc is a compact disk with several toxic substances databases, including the
New Jersey Fact Sheets.
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APPENDIX 3
Brief Description of Title III 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: LG. 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 WestMarkham
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
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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. Shetton, 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
Stats 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
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GEORGIA
State Commission:
Mr. J. Leonard Ledbetter, Ghair
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:
SamirA/aman
Mark Ingoglia
(808) 543-8249
(808) 543-8276
Section 313 Submissions:
John C. Lewin, M.D., Char
Hawaii State Emergency Response
Commission
Hawaii State Department of Health
P.O. Box 3378
Honolulu, HI 96801-9904
(808) 548-6505
IDAHO
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. Box19276
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 ,
DesMoines, IA 50319
(515)281-3231
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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, IA50319
(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 Roor
109 S.W. 9th Street
Topeka, KS 66612
(913) 296-1690
Section 302 & 304 Submissions:
Karl Birns
Kansas Department of Health and Environment
Right-to-Know Program
Mills 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 Roor
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
18Rei!lyRoad
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 Sudbrook Lane, East
Pikesville, MD21208
(301)486-4422
-------
Section 302, 304, 311/312 & 313
Submissions:
Marsha Ways
State Emergency Response Commission
Maryland Department of the Environment
Toxics Information Center
2500 Broening Highway
Baltimore, MD 21224
(301) 631-3800
MASSACHUSETTS
Arnold Sapenter
c/o Title Three Emergency Response
Commission
Department of Environmental Quality
Engineering
One Winter Street, 10th floor
Boston, MA 02108
(617) 292-5993
For LEPC Information: Jack Callahan (508) 820-
2060
MICHIGAN
Title III Coordinator
Michigan Department of Natural Resources
Environmental Response Division
Title III Notification
P.O. Box 30028
Lansing, Ml 48909
(517)373-8481
MINNESOTA
Lee Tischler, Director
290 Bigelow Building
450 North Syndicate
St. Paul, MN 55155
(612) 643-3000
MISSISSIPPI
J.E. Maher, Chair
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501
Fondren Station
Jackson, MS 39296-4501
(601) 960-9973
Contact: Bill Austin
MISSOURI
Dean Martin, Coordinator
Missouri Emergency Response Commission
Missouri Department of Natural Resources
P.O. Box 3133
Jefferson City, MO 65102
(314) 751-7929
Mailing Address:
Dean Martin
Missouri Emergency Response Commission
Missouri Department of Natural Resources
2010 Missouri Boulevard
Jefferson City, MO 65109
MONTANA
Tom Ellerhoff, Co-Chair
Montana Emergency Response Commission
Environmental Sciences Division
Department of Health & Environmental
Sciences
Cogswell Building A-107
Helena, MT 59620
(406) 444-6911
Contact: Guy Youngblood
NEBRASKA
Clark Smith, Coordinator
Nebraska Emergency Response Commission
Nebraska Department of Environmental Control
P.O. Box 98922
State House Station
Lincoln, NE 68509-8922
(402)471-2186
Emergency Number (After-hours): (402) 471-
4545
NEVADA
State Commission and Section 311/312
Submissions:
Joe Quinn
Nevada Division of Emergency Management
2525 South Carson Street
Carson City, NV 89710
(702) 885-4240
Emergency Release Number (After Hours &
Weekends): (702) 885-5300
Section 313 Submission:
Bob King
Division of Emergency Management
2525 South Carson Street
Carson City, NV 89710
(702) 885-4240
NEW HAMPSHIRE
Gerorge L. Iverson, Director
State Emergency Management Agency
Title III Program
State Office Park South
107 Pleasant Street
Concord, NH 03301
(603)271-2231
Contact: Leland Kimball
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NEW JERSEY
State Commission:
Tony McMahon, Director
New Jersey Emergency Response
Commission
SARA Title III Project
Department of Environmental Protection
Division of Environmental Quality
CN-405
Attn: 304 Notification
Trenton, NJ 08625
(609) 292-6714
Emergency Number: (609) 292-7172
Section 302, 311/312 Submissions
New Jersey Emergency Response
Commission
SARA Title 111 Project
Department of Environmental Protection
Division of Environmental Quality
CN-405
Trenton. NJ 08625
(609) 292-6714
Section 304 Submissions:
New Jersey Emergency Response
Commission
SARA Title III Project
Department of Environmental Protection
Division of Environmental Quality
CN-027
Trenton, NJ 08625
(609) 292-6714
Section 313 Submissions:
New Jersey Emergency Response
Commission
SARA Title ill 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 Germane, 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 (919)733-3844
Emily Kilpatrick (919)733-3865
NORTH DAKOTA
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, CNMI 96950
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-DeWutf
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
Pennsylvania Emergency Response
Commission
SARA Title III Officer
PEMA Response and Recovery
P.O. Box 3321
Harrisburg, PA 17105
(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
Rm1503
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
State Commission and Section 311/312
Submissions:
Mr. Santos Rohena, Chair
Puerto Rico Emergency Response
Commission
Environmental Quality Board
P.O. Box11488
Sernades Juncos Station
Santurce, PR 00910
(809)722-1175
(809) 722-2173
Section 313 Submissions:
SERC Commissioner
Title HI-SARA Section 313
Puerto Rico Environmental Quality Board
P.O. Box 11488
Santurce, PR 00910
(809) 722-0077
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
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, Rl 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
UTAH
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 Taybr
Utah Hazardous Chemical Emergency
Response Commission
Utah Division of Environmental Health
288 North 1460 West
P.O. Box 16690
Salt Lake City, UT 84116-0690
(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
Olympia, 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
Olympia, 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: Bill Jopling
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 Commlsion:
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 5370,7
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 BENZU 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 CHLOROPHACINONE
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(U)
8065483 DEMETON
919868 DEMETON-S-METHYL
10311849 DIALIFOR
19287457 D1BORANE
111444 DICHLOROETHYL ETHER
149746 DICHLOROMETHYLPHENYLSILANE
62737 DICHLORVOS
141662 DICROTOPHOS
1464535 DIEPOXYBUTANE
814493 DIETHYL CHLOROPHOSPHATE
1642542 DIETHYLCARBAMAZINE CITRATE
71636 DIGITOXIN
2238075 DK3LYCIDYL ETHER
20830755 DIGOXIN
115264 DIMEFOX
60515 DIMETHOATE
2524030 DIMETHYL
PHOSPHOROCHLORIDOTHIOATE
77781 DIMETHYL SULFATE
75183 DIMETHYL SULFIDE
99989 DIMETHYL-p-PHENYLENEDIAMINE
75785 DIMETHYLDICHLOROSILANE
57147 DIMETHYLHYDRAZINE
644644 DIMETILAN
534521 DINITROCRESOL
88857 DINOSEB
1420071 DINOTERB
78342 DK3XATHDN
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 ERGOTAMINE TARTRATE
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 LITHIUM 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 METHYLMERCURIC DICYANAMIDE
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
0 ORGANORHODIUM 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 Chemical Name
4418660 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 PHOSACETIM
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(I-METHYLETHYL)AMINO)ETHYL) O-
ETHYL ESTER
2665307 PHOSPHONOTHIOIC ACID, METHYL-,O-(4-
NITROPHENYL) O-PHENYL ESTER
3254635 PHOSPHORIC ACID, DIMETHYL 4-
(METHYLTHIO) PHENYL ESTER
2587908 PHOSPHOROTHIOIC ACID.O.O-DIMETHYL-
5-(2-(METHYLTHIO)ETHYL)ESTER
7723140 PHOSPHORUS
1.0025873 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 CYANIDE
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 P YRIDINE, 2-METH YL-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
131522 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 TETRACHLORIDE
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
129066 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
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
De Minimus Concentration
(percent)
0.1
0.1
1.0
1.0
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
1.0
1.0
0.1
0.1
0.1
Aluminum (fume or dust)
Aluminum oxide
2-Aminoanthraquinone
4-Aminoazobenzene
4-Aminobiphenyl
1 -Amino-2-methylanthraquinone 0.1
.0
.0
.0
Ammonia
Ammonium nitrate (solution)
Ammonium sulfate (solution)
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
{Tribro mo methane}
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
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 1.0
Chlorine dioxide 1.0
Chloroacetic acid 1.0
2-Chloroacetophenone 1.0
Chlorobenzene 1.0
Chlorobenzilate 1.0
{Benzeneaceticacid,4-chloro-.alpha.-(4-chlorophenyl)-alpha.-hydroxy-,ethyi
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
Cresoi (mixed isomers)
m-Cresol
o-Cresol
p-Cresol
Cumene
Cumene hydroperoxide
Cupferron
0.1
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
Diazo methane 1.0
Dibenzofuran 1.0
1,2-Dibromo-3rchloropropane 0.1
fDBCP}
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
1,4-Dichlorobenzene 0
3,3'-Dichlorobenzidine 0
Didilorobromomethane 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-Dichloropropylene 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
Dtethanolamine 1.0
Di-(2-ethylhexyl) phthalate 0.1
{DEHP}
DjfthyI phthalate 1.0
Diethyl sulfate 0.1
3,3'-Dimethoxybenzidine 0.1
•" 4-Dimethylaminoazobenzene 0.1
3,3'-Dimethylbenzidine 0.1
{o-Tolidine}
Dimethylcarbamyl chloride 0.1
-------
57-14-7
105-67-9
131-11-3
77-78-1
534-52-1
51-28-5
121-14-2
606-20-2
117-84-0
123-91-1
122-66-7
106-89-8
110-80-5
140-88-5
100-41-4
541-41-3
74-85-1
107-21-1
151-56-4
75-21-8
96-45-7
2164-17-2
50-00-0
76-13-1
76-44-8
118-74-1
87-68-3
77-47-4
67-72-1
1335-87-1
680-31-9
302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
78-84-2
67-63-0
80-05-7
7439-92-1
58-89-9
108-31-6
12427-38-2
7439-96-5
7439-97-6
67-56-1
72-43-5
1,1-Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-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
0.1
1.0
0.1
0.1
1.0
{Urea, N,N-dimethyl-N'-[3-(trifluoromethyl)phenyl]-}
Formaldehyde 0.1
Freon113 1-0
{Ethane, 1,1,2-trichloro-1,2,2-trifluoro-}
Heptachlor 1.0
{lAS.ey.S.S-Heptachloro-Sa^JJa-tetrahydro^J-methano-IH-indene}
Hexachlorobenzene 0.1
Hexachloro-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
Isopropyl 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, 1,1l-(2,2,2-trichloroethylidene)bis-4-methoxy-}
-------
109-86-4 2-Methoxyethanol 1.0
96-33-3 Methyl acrylate 1.0
1634-04-4 Methyl tert-butyl ether 1.0
101-14-4 4,4'-Methylenebis(2-chloroaniline) 0.1
{MBOCA}
101-61-1 4,4'-Methylenebis(N,N-dimethyl) 0.1
benzenamine
101-68-8 Methylenebis (phenylisocyanate) 1.0
{MBI}
74-95-3 Methylene bromide 1.0
101-77-9 4,4'-Methylenedianiline 0.1
78-93-3 Methyl ethyl ketone 1.0
60-34-4 Methyl hydrazine 1.0
74-88-4 Methyl iodide 0.1
108-10-1 Methyl isobutyl ketone 1.0
624-83-9 Methyl isocyanate 1.0
80-62-6 Methyl methacrylate 1.0
90-94-8 Michler's ketone 0.1
1313-27-5 Molybdenum trioxide 1.0
505-60-2 Mustard gas 0.1
{Ethane, 1,1'-thiobis[2-chloro-}
91-20-3 Naphthalene 1.0
134-32-7 alpha-Naphthylamine 0.1
91-59-8 beta-Naphthylamine 0.1
7440-02-0 Nickel 0.1
7697-37-2 Nitric acid 1.0
139-13-9 Nitrilotriacetic acid 0.1
99-59-2 5-Nitro-o-anisidine 0.1
98-95-3 Nitrobenzene 1.0
92-93-3 4-Nitrobiphenyl 0.1
1836-75-5 Nitrofen 0.1
{Benzene, 2,4-dichloro-1-(4-nitrophenoxy)-}
51-75-2 Nitrogen mustard 0.1
{2-Chloro-N-(2-chloroethyl)-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-Dimethylaniline 1.0
924-16-3 N-Nitrosodi-n-butylamine 0.1
55-18-5 N-Nitrosodiethylamine 0.1
62-75-9 N-Nitrosodimethylamine 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-Nitrosomorpholine 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-Nitrosbpiperidine 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
{POP}
79-21 -0 Peracetic acid 1.0
-------
108-95-2 Phenol 1.0
106-50-3 p-Phenylenediamine 1.0
90-43-7 2-Phenylphenol 1.0
75-44-5 Phosgene 1.0
7664-38-2 Phosphoric acid 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
85-44-9 Phthalic anhydride 1.0
88-89-1 Picric acid 1.0
1336-36-3 Polychlorinated biphenyls 0.1
{PCBs}
1120-71-4 Propane sultone 0.1
57-57-8 beta-Propiolactone 0.1
123-38-6 Propionaldehyde 1.0
114-26-1 Propoxur 1.0
{Phenol, 2-(1-methylethoxy)-, methylcarbamate}
115-07-1 Propylene 1.0
{Propene}
75-55-8 Propyleneimine 0.1
75-56-9 Propylene oxide 0.1
110-86-1 Pyridine ' 1.0
91-22-5 Quinoline 1.0
106-51-4 Quinone 1.0
82-68-8 Quintozene
{Pentachloronitrobenzene} 1.0
81-07-2 Saccharin (manufacturing, no supplier notification) 0.1
{1,2-Benzisothiazol-3(2H)-one, 1,1 -dioxide}
94-59-7 Safrole 0.1
7782-49-2 Selenium 1 -0
7440-22-4 Silver 1.0
1310-73-2 Sodium hydroxide (solution) 1.0
7757-82-6 Sodium sulfate (solution) 1.0
100-42-5 Styrene 0.1
96-09-3 Styrene oxide 0.1
7664-93-9 Sulfuric acid 1.0
100-21-0 Terephthalic acid 1.0
79-34-5 1,1,2,2-Tetrachlroethane 0.1
127-18-4 Tetrachloroethylene 0.1
{Perchloroethylene}
961-11-5 Tetrachlorvinphos 1.0
{Phosphoric acid, 2-chloro-1- (2,3,5-trichlorophenyl) ethenyl dimethyl ester}
7440-28-0 Thallium 1.0
62-55-5 Thioacetamide 0.1
139-65-1 4,4'-Thiodianiline 0.1
62-56-6 Thiourea 0.1
1314-20-1 Thorium dioxide 1.0
7550-45-0 Titanium tetrachloride 1.0
108-88-3 Toluene 1.0
584-84-9 Toluene-2,4-diisocyanate 0.1
91-08-7 Toluene-2,6-diisocyanate 0.1
95-53-4 o-Toluidine 0.1
636-21-5 o-Toluidine hydrochloride 0.1
8001-35-2 Toxaphene 0.1
68-76-8 Triaziquone 0.1
{2,5-Cyclohexadiene-1,4-dione, 2,3,5-tris(1-aziridinyl)-}
52-68-6 Trichlorfon 1.0
{Phosphonicacid,(2,2,2-trichloro-1-hydroxyethyl)-,dimethyl ester}
120-82-1 1,2,4-Trichlorobenzene 1.0
71-55-6 1,1,1-Trichloroethane 1.0
-------
79-00-5
79-01-6
95-95-4
88-06-2
1582-09-8
95-63-6
126-72-7
51-79-6
7440-62-2
108-05-4
593-60-2
75-01-4
75-35-4
1330-20-7
108-38-3
95-47-6
106-42-3
87-62-7
7440-66-6
12122-67-7
(Methyl chloroform)
1,1,2-Trichloroethane
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
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.
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
-------
Risk
about Chemicals
in Your Community
A Manual for Local Officials
Preparing to Run the Workshop
December, 1989
Prepared by Susan G. Madden and Barry V. Bales
Lyndon B. Johnson School of Public Affairs at
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
-------
-------
Facilitator's Manual
Purpose
Self-Study
Option
Workshop
Option
About the
Audience
Purpose of the Manual/Workshop
Risk Communication about Chemicals in Your Community was
written to help local officials learn methods for responding to
public questions about hazardous substances and related
incidents in the community and identify additional resources
available to those officials. Risk communication has taken on
new importance because so much new information has become
available since passage of the Emergency Planning and
Community Right to Know Act, also known as SARA Title III.
The manual has been written so that it can be used as a self-
study guide. This has the advantage of making distribution of
the manual easier, perhaps reaching people who can not
attend a works|op. Its disadvantage is that the objectives of
the manual may not be accomplished, because there is no
guarantee that sett-study participants will review the entire
manual, and self-study lacks the reinforcement that comes from
interacting with other participants and the facilitator.
The manual is most effective if it is used first in a workshop
setting. There is-a greater likelihood that the material will be
covered in a workshop and it provides an opportunity for the
participants to share experiences as well as meet with some of
the people involved in the emergency response plans. A
workshop also allows the introduction of other materials
pertinent to the subject that could be valuable to the
participants. The main disadvantages of a workshop are the
need for a facilitator and the potential difficulty of getting the
target audience to attend.
Facilitators need not be experts in Title III areas, but knowledge
of these areas will help focus discussions. Experience in
leading small group discussions will make the job of facilitating
this workshop a great deal easier.
Any educational effort should be designed to fit the audience for
which it is intended. This manual is primarily for members of
the Local Emergency Planning Committee, because they may
be the ones expected to'respond to citizens' questions about
chemical risks. The audience may include local government
administrators whose primary responsibility is Title III/
environmental concerns, state officials involved in emergency
-------
Facilitator's Manual
response, and others whose interest and participation in local
environmental concerns might put them in the position of
communicating about risk. However, the workshop will not be
effective if generalized to ail of these groups, since knowledge
level and interests vary widely. As a facilitator preparing to lead
a workshop, it is helpful to know the answers to the following
questions about the primary audience:
1. What incentives/motivations do the intended participants
have for attending this workshop?
2. What information, ideas, and strategies is it realistic to
expect them to have when they leave (i.e., what are our
learning objectives)?
3. What techniques and strategies will help accomplish these
learning objectives?
Questions 2 and 3 will be addressed under "Workshop
Objectives" and "Facilitating Suggestions." Answers to question
1 depend on adult learner characteristics and the specific
needs/motivations of local government officials. Although these
may seem like obvious points, it is important to keep them in
mind while preparing to facilitate this workshop.
Adult learners tend to be problem-centered, which means they
evaluate educational opportunities with the criteria of "Why do I
need to know this?" and "How will this help me in my job
tomorrow?" Research shows that adults are most interested in
educational activities that can help them with immediate
problems; workshops dealing with problems that are not
perceived as immediate often attract few participants, especially
if attendance is voluntary.
Our primary audience, Local Emergency Planning Committee
members, have a wide range of backgrounds. LEPC members
include, by law, elected officials, health professionals,
emergency response professionals, industry representatives,
law enforcement and civil defense representatives, firefighters,
environmental and transportation officials, the media, and
community groups. Although some of them will be experts in
some areas of this manual, few will be expert in all areas, and
fewer still will have experience in communicating about risks.
-------
Facilitator's Manual
Objectives
Keeping in mind our audience, the manual focuses on what they
need to know to effectively answer questions regarding risk.
This manual concentrates on communication strategies and
identifying sources of information to help in this communication
rather than on highly technical and detailed discussions of risk
analysis and emergency response.
As risk communicators, logical outcomes of the workshop (or
self-study) will be for participants to have a general
understanding of:
•Title III,
• the process involved in responding to accidental spills/
emissions,
• how to identify readily accessible resources to which they
can turn for help, and
• communication strategies for responding to risk-related
questions.
Specifically the objectives are to help the participants:
•Know what kinds of questions citizens are likely to ask
—after an accident
—after learning about routine releases
—after learning that large quantities of hazardous chemicals
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 decisionmaking about potential risks from
hazardous chemicals.
-------
Facilitator's Manual
Facilitation
Suggestions
Being a facilitator for this workshop doesn't mean you have to
know everything about every topic mentioned, or that you have
to prepare a lecture or a briefing. It does mean that you will
know more about all the topics covered than any one person in
your workshop, and that you will be the workshop's leader. You
will ask questions to stimulate discussion, summarize the major
points, and keep the group from straying too far from the
subject. You also will tell them when it is time to move on. You
probably will find that you learn a lot while being a facilitator too,
so have fun!
You should become thoroughly familiar with the contents of the
participant manual before the workshop. The Facilitator's Guide
for each section is on the left-hand side of the page in the
facilitator's version of the participant manual. The participant
version will not have the Facilitator's Guide sheets. The
suggestions for leading discussions and the "Sample Questions
to Ask" are just that - suggestions and samples. As facilitator
you decide what to include and what to omit.
Keeping the principles of adult learning in mind, it is important to
avoid reading long passages directly from the text. A thorough
knowledge of what is to be covered will allow you to lead
discussions in a conversational style, capitalizing on your own
and the participants' experiences.
The following are suggestions for helping you prepare to lead
this workshop:
1. Thoroughly review the participant manual, learning what
is covered in the various sections and in the Appendices.
2. As you review the manual, read the Facilitator's Guide to
see what suggestions for questions and comments you
would like to use. The comments in the Facilitator's Guide
will be approximately opposite from the corresponding
sections in the participant manual.
3. Make notes on your copy about additional comments and
questions you wish to include (from local newspapers,
periodicals, planning documents, etc.) as well as highlighting
things on the participant side of trie manual that you wish to
stress. Using key words as cues to prompt discussion will
help avoid a reliance on reading text during the workshop.
IV
-------
Facilitator's Manual
4. Find out the information needed to complete the
Facilitator's Resource Sheet included at the back of this
section. As you read through the manual and Facilitator's
Guide, make notes to yourself about when to refer to your
Facilitator's Resource Sheet.
5. Learn your "presentation" well enough that you do not
need to refer constantly to the manual, and so that you know
what is coming up on succeeding pages/sections to assist
you in making transitional statements.
Note: The pages at the end of this section can be photocopied on
transparency sheets and used with an overhead projector during
the presentation. The number in the lower right hand corner of
each page is referenced in the Facilitator's Guide at the appropriate
place in the presentation. It is often helpful to use a variety of
different aids in teaching - blackboard, overhead projector, flipchart
pad, etc. - but an overhead projector is not essential if one can not
be obtained or if you, as facilitator, choose not to use one. You may
want to prepare flipchart pages as an alternative.
You will notice a series of pie charts on "Information needed to
answer questions" that are suggested for transparencies. It is
easier to motivate adults if they understand why what they are
learning is important. This series of pie charts can help the
participants understand why it is necessary to cover each of the
subjects included.
Self-study is an option but it is less effective to conduct the
workshop strictly and only by what is included in the participant
manual. Bring your own examples and illustrative comments to
supplement what is covered by the manual, and encourage
discussion to address specific local concerns/cases.
Under Facilitator's Guide on the left-hand side of the page in
the manual are suggestions for discussions as well as sample
questions that can be asked during each major topic. Do not be
constrained by what is mentioned - it is there as a guide only.
A good resource for more specific suggestions on facilitating
small-group learning is The Modern Practice of Adult Education
by Malcolm Knowles (Cambridge, The Adult Education
Company, 1980).
-------
Facilitator's Manual
Logistics
Time/Place
Audience
Equipment/
Supplies
As a facilitator, you may have responsibility for making logistical
arrangements for the workshop, and will need to confirm them
even if that responsibility is assigned to someone else. Factors
to consider include:
1. Arranging a time and place for the workshop.
This will be about a three-hour program, and should be
scheduled to fit your audience's needs. It can be done in the
morning, afternoon, or evening. A sample agenda is shown
following the Facilitator's Resource Sheet In this section.
Possibilities for meeting rooms can include a local government
office building, public library, public school, or college
classroom.
2. Inviting the audience.
The primary audience will be members of the Local Emergency
Planning Committee. You may wish to include the mayor, city
council, county judge, county commissioners, city and county
managers, department heads, elected officials, local and state
health officials and State Emergency Response Commission
members. It is the responsibility of the facilitator to initiate the
invitations to attend.
3. Equipment/supplies arrangements: Access to a chalkboard
or flipchart pad on stand would be helpful. If nametags are to
be used, have them on hand. Additionally, each participant
should have his/her own participant manual. An overhead
projector with screen and extension cord should be in the room
if you wish to use it. Other resources such as EPA reports,
industry reports on hazardous materials, and relevant news
articles should be collected in advance and on hand.
4. Obtain or make enough copies of the pamphlet "The Seven
Cardinal Rules of Risk Communication" (see Appendix 2 for
source) for each participant.
5. If possible, arrange to have coffee, soft drinks, and juice
available for the breaks. The participants will appreciate it, and
it may prevent some from wandering off during the breaks.
A good resource for more details on logistics planning is
Program Development and Evaluation, by R. Caffarella (New
York: Wiley & Sons, 1988).
VI
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Facilitator's Manual
Evaluation
It helps to plan for future workshops if you know what worked
well and what mistakes to avoid. Thus, have the participants fill
out an evaluation form (a sample is shown following the Sample
Agenda in this section). Besides, thinking through their
responses for the evaluation reinforces the main points of the
workshop.
VII
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Facilitator's Resource Sheet
Certain information gathered before the workshop will help insure that the participants leave with valuable
resources and a start on their post-workshop plan of action. Identifying the names and information
requested below will help you prepare to facilitate this workshop. References to this sheet will be made at
appropriate times in the Facilitator's Guide.
The following information should be collected for the city, county, and state for which you will be
conducting a workshop.
1. The State Emergency Response Commission:
Contact person: Agency
Address: Phone
2. Does this state have rules about first responders that should be considered when emergency plans
are enacted? (Yes or No) If answer is "I don't know," whom might you call to find out
about the first responder rules?:
Contact person: Agency
Address: Phone
3. What are the major industries in the areas from which the participants are drawn? What particular
substances are associated with these industries?
4. Who in this city is responsible for emergency response?
Contact person: Agency
Address: Phone_
5. Who has authority to direct citizens to evacuate or take other action?
Contact person: Agency
Address: Phone.
(continued)
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6. Who Is the chairperson of the Local Emergency Planning Committee (LEPC)
Contact person: Agency
Address: Phone_
7. Who are local health department people on whom you can call?
Contact person: Agency
Address: Phone_
Others:
8. Who are local university professors who have knowledge in these areas? (Chemists, environmentalists,
etc.) List:
9. Which state agency/official receives reports under Section 313?
Contact person: Agency
Address: Phone,
10. Which state agency/official receives reports under Section 312?
Contact person: Agency
Address: Phone_
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Sample Agenda
The following is a sample agenda for the workshop with a starting time of 8:30 a.m.
This should be used as an estimate only; actual times may vary.
8:30 a.m. Introductions/Purpose
8:45 a.m. How to Use this Manual
8:55 a.m. Introduction to Title III
9:05a.m. What is Risk
9:25 a.m. Scenario 1: Accidental Release of a Chemical
9:55 a.m. Break
10:05 a.m. Scenario 2: Routine Releases
10:55 a.m. Break
11:05 a.m. Scenario 3: Storing Large Quantities
11:45 a.m. Summary and Conclusion
11:55 a.m. Adjournment
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"Risk Communication about Chemicals in Your Community"
A Workshop for Local Officials
EVALUATION
1. What is your current position?.
2. Do you participate in Title III activities? If so, which activities, and are they part of your job or
are they voluntary?
Participate? _Yes No
Part of Job? Yes No
What activities?
3. Are you involved in any risk communication activities? If so, list.
4. The workshop had five stated objectives. They are listed below. Please rate each one on how
well the objective was accomplished using the following scale: 5= exceeded expectations; 4=
accomplished objective well; 3= accomplished objective partially; 2= accomplished objective only
a little; 1= did not accomplish the objective.
Rating Workshop Objectives
a. Know what kinds of questions citizens are likely to ask under three sets of
circumstances.
b. Know the characteristics of a good answer to these questions.
c. Understand the kinds of information needed to answer the questions and where that
information may be found.
d. Be able to respond to the questions and identify some people in the community who
can help answer them.
e. Identify opportunities for all sectors of the community to participate in decisionmaking
about potential risks from hazardous chemicals.
5. Overall, how would you rate this workshop?
Very favorable
.Favorable
_Good
Fair
Poor
6. What parts of the manual need more information? What parts are especially good?
-------
7. Was there enough interaction in this workshop?
8. Who else do you think should attend this workshop?
9. Would you be interested in facilitating such a workshop? If yes, please write your name,
address and phone number, or give it to the facilitator on a separate piece of paper.
10. Other comments and suggestions you have about this workshop? Please use the back if
necessary.
-------
The following pages can be photocopied to make
transparencies for an overhead projector.
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Risk Communication
Brief Description of Title HI Reporting Provisions
by Section
301—establishes LEPCs and SERCs (State Emergency Re-
sponse Commissions).
302—requires facilities to notify the SERC and the LEPC 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 the threshold
reporting quantities to notify the LEPC and the SERC.
311—requires all facilities that store any hazardous sub-
stance in amounts greater than 10,000 pounds (less for
Extremely Hazardous Substances) to give a chemical list
or set of Material Safety Data Sheets (MSDSs) to the fire
department, LEPC and SERC.
312—requires these facilities also to file an annual chemical
inventory by hazard category or chemical.
313—requires an annual report by manufacturing facilities
only of emissions to air, water, or ground of chemicals on a
list of about 300.
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EXPOSURE PATHWAYS
FOR HUMANS
Deposits on crops Deposjts Qn gro(jn(j
Crop ingestion
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X ^ic foods
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Risk Communication
Background Information for Questions
Questions
What risk is posed by exposures to routine
emissions?
Do these emissions cause health effects?
Emissions
Concentration
Toxicity
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Dose
Other
chemical
characteristics
Risk/
Health
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'Risk Communication
Three Kinds of Evidence
about
Health Effects of Chemical Exposures
Tiny organisms-
in vitro
(in a test tube)
Laboratory animals-
in vivo
(in live animals)
Epidemiologic
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3. RISK ANALYSIS
(Initial Evaluation of Reporting
Facilities—Relative Hazards)
Relative to potential hazards of other
reporting facilites—high
F2
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