Open Letter: 150 Groups Support Right-to-Know
March 21, 1997
Administrator Carol Browner
U.S. Environmental Protection Agency (1101)
401 M Street, SW
Washington, DC 20460
Dear Administrator Browner:
The undersigned organizations support an effective, national data system for Risk Management Plan (RMP) information, including worst-case accident scenarios, under the Clean Air Act, 112(r). This fundamental right-to-know information will inform communities about chemical accident hazards posed by industrial facilities, and about the safety systems that ensure there will not be an "American Bhopal." An easily accessible, national data system is critical to enable people at the local level to verify the submitted information, to obtain information on multiple vulnerable zones, and for other reasons.
Starting in 1999, some 66,000 facilities that use large amounts of extremely hazardous chemicals will publicly disclose worst-case accident scenarios as part of larger Risk Management Plans (RMP). The RMPs have three parts. First, a hazard assessment describes release scenarios, potential off-site consequences, and a five-year accident history. Second, a prevention program addresses basic safety procedures such as training, maintenance, and safety audits. Third, an emergency response program covers response plans, drills, and coordination with local planners. By law, the RMPs are public information; by EPA rule, they are accessible to "any person" (61 FR 31717).
Some industry representatives oppose a national, public data system that includes all parts of the RMP on the Internet. Without easily accessible and nationally comparable information at the local level, people will not be able to readily determine if a facility is reporting accurately. They will not be able to benefit from efficient education and training. They won't be able to create summary reports by chemical, industry, or geographic area, find out about hazard reductions achieved elsewhere in the country, or even get comparative information in the format they need. People need ready access, through the Internet and other means, to complete, national information to ensure that they are not isolated from developments elsewhere.
EPA must establish an effective national RMP information system to support both local uses and national needs (such as a Chemical Safety and Hazard Investigation Board). All parts of the RMP are important, including both worst-case and more-likely case release scenarios. Whereas the worst-case scenario indicates the inherent hazard of a chemical at a facility, the more likely-case scenario calculates risks if safety systems fail�a measure that is more easily softened or manipulated.
We therefore urge EPA to address the following concerns in designing the RMP data system. EPA must address how members of Local Emergency Planning Committees (LEPC), community groups, reporters, workers, state and Federal agencies, health professionals, researchers, or other interested persons will be able to:
Assure the integrity of RMP information through comparisons to data submitted elsewhere.
Learn about hazard reductions and prevention opportunities realized elsewhere in the country.
Identify vulnerable zones in neighboring jurisdictions, and produce summary reports by company, industry, or geographic area.
Measure reductions in accident potentials and improvements in inherent safety.
Assign priorities for risk reduction and target activities to the most important hazards.
Hold government accountable for effectively managing activities and measuring results (as called for in the Government Performance and Results Act of 1993).
Establish efficient, cost-effective management of RMP information, with linkages to other environmental, worker, and public health databases.
Conduct efficient education and training on the use of the RMP information.
Assure timely access to RMP information in all localities in the format that people need (on-line, on diskette, or on paper).
Obtain the information without burdening LEPCs or other local entities.
The RMP rule is the most important chemical accident prevention initiative in years. EPA must take responsibility for establishing adequate data management systems to handle the program. To implement an effective prevention program that serves local needs, EPA must remain committed to a fully accessible, national data system for RMP information.
Sincerely,
Cosigning organizations:
American Lung Association (Washington, D.C.), by Fran DuMelle
American Public Health Association (Washington, D.C.), by Ilisa Halpern
Arizona Toxics Information (Bisbee, Ariz.), by Michael Gregory
Asian Immigrant Women Advocates (San Francisco, Calif.), by Helen Kim *
Atlantic States Legal Foundation (Buffalo, N.Y.), by Sam Sage
Audubon Naturalist Society (Chevy Chase, Md.), by Neal Fitzpatrick
AWARE-Alliance Against Waste and Action to Restore the Environment (La.), by Liz Avants
Bay Area Action (Palo Alto, Calif.), by David Smernoff
Bhopal Action Resource Center (New York, N.Y.), by Ward Morehouse
Breast Cancer Action (San Francisco, Calif.), by Nancy Evans and Barbara Brenner
Bridge Alliance (Newburgh, Ind.), by Nan Hardin
California Communities Against Toxics (Rosamond, Calif.), by Jane Williams
California WORKSAFE! (San Francisco, Calif.), by Pam Tau Lee
Californians for Quality of Life (San Diego, Calif.), by Carolyn Chase
Calvert Group (Bethesda, Md.), by Kenneth Scott
Center for Environmental Health (San Francisco, Calif.), by Michael Green
Concerned Citizens of South Central Los Angeles (Calif.), by Melodie Dove
Council on Economic Priorities (New York, N.Y.), by Sara Baerwald
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Is this Sara a relative?
A Baerwald supporting our Right-to-know
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Open Letter: 150 Groups Support Right-to-Know
March 21, 1997
Administrator Carol Browner
U.S. Environmental Protection Agency (1101)
401 M Street, SW
Washington, DC 20460
Dear Administrator Browner:
The undersigned organizations support an effective, national data system for Risk Management Plan (RMP) information, including worst-case accident scenarios, under the Clean Air Act, 112(r). This fundamental right-to-know information will inform communities about chemical accident hazards posed by industrial facilities, and about the safety systems that ensure there will not be an "American Bhopal." An easily accessible, national data system is critical to enable people at the local level to verify the submitted information, to obtain information on multiple vulnerable zones, and for other reasons.
Starting in 1999, some 66,000 facilities that use large amounts of extremely hazardous chemicals will publicly disclose worst-case accident scenarios as part of larger Risk Management Plans (RMP). The RMPs have three parts. First, a hazard assessment describes release scenarios, potential off-site consequences, and a five-year accident history. Second, a prevention program addresses basic safety procedures such as training, maintenance, and safety audits. Third, an emergency response program covers response plans, drills, and coordination with local planners. By law, the RMPs are public information; by EPA rule, they are accessible to "any person" (61 FR 31717).
Some industry representatives oppose a national, public data system that includes all parts of the RMP on the Internet. Without easily accessible and nationally comparable information at the local level, people will not be able to readily determine if a facility is reporting accurately. They will not be able to benefit from efficient education and training. They won't be able to create summary reports by chemical, industry, or geographic area, find out about hazard reductions achieved elsewhere in the country, or even get comparative information in the format they need. People need ready access, through the Internet and other means, to complete, national information to ensure that they are not isolated from developments elsewhere.
EPA must establish an effective national RMP information system to support both local uses and national needs (such as a Chemical Safety and Hazard Investigation Board). All parts of the RMP are important, including both worst-case and more-likely case release scenarios. Whereas the worst-case scenario indicates the inherent hazard of a chemical at a facility, the more likely-case scenario calculates risks if safety systems fail�a measure that is more easily softened or manipulated.
We therefore urge EPA to address the following concerns in designing the RMP data system. EPA must address how members of Local Emergency Planning Committees (LEPC), community groups, reporters, workers, state and Federal agencies, health professionals, researchers, or other interested persons will be able to:
Assure the integrity of RMP information through comparisons to data submitted elsewhere.
Learn about hazard reductions and prevention opportunities realized elsewhere in the country.
Identify vulnerable zones in neighboring jurisdictions, and produce summary reports by company, industry, or geographic area.
Measure reductions in accident potentials and improvements in inherent safety.
Assign priorities for risk reduction and target activities to the most important hazards.
Hold government accountable for effectively managing activities and measuring results (as called for in the Government Performance and Results Act of 1993).
Establish efficient, cost-effective management of RMP information, with linkages to other environmental, worker, and public health databases.
Conduct efficient education and training on the use of the RMP information.
Assure timely access to RMP information in all localities in the format that people need (on-line, on diskette, or on paper).
Obtain the information without burdening LEPCs or other local entities.
The RMP rule is the most important chemical accident prevention initiative in years. EPA must take responsibility for establishing adequate data management systems to handle the program. To implement an effective prevention program that serves local needs, EPA must remain committed to a fully accessible, national data system for RMP information.
Sincerely,
Cosigning organizations:
American Lung Association (Washington, D.C.), by Fran DuMelle
American Public Health Association (Washington, D.C.), by Ilisa Halpern
Arizona Toxics Information (Bisbee, Ariz.), by Michael Gregory
Asian Immigrant Women Advocates (San Francisco, Calif.), by Helen Kim *
Atlantic States Legal Foundation (Buffalo, N.Y.), by Sam Sage
Audubon Naturalist Society (Chevy Chase, Md.), by Neal Fitzpatrick
AWARE-Alliance Against Waste and Action to Restore the Environment (La.), by Liz Avants
Bay Area Action (Palo Alto, Calif.), by David Smernoff
Bhopal Action Resource Center (New York, N.Y.), by Ward Morehouse
Breast Cancer Action (San Francisco, Calif.), by Nancy Evans and Barbara Brenner
Bridge Alliance (Newburgh, Ind.), by Nan Hardin
California Communities Against Toxics (Rosamond, Calif.), by Jane Williams
California WORKSAFE! (San Francisco, Calif.), by Pam Tau Lee
Californians for Quality of Life (San Diego, Calif.), by Carolyn Chase
Calvert Group (Bethesda, Md.), by Kenneth Scott
Center for Environmental Health (San Francisco, Calif.), by Michael Green
Concerned Citizens of South Central Los Angeles (Calif.), by Melodie Dove
Council on Economic Priorities (New York, N.Y.), by Sara Baerwald
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Is this Sara a relative?
March 21, 1997
Administrator Carol Browner
U.S. Environmental Protection Agency (1101)
401 M Street, SW
Washington, DC 20460
Dear Administrator Browner:
The undersigned organizations support an effective, national data system for Risk Management Plan (RMP) information, including worst-case accident scenarios, under the Clean Air Act, 112(r). This fundamental right-to-know information will inform communities about chemical accident hazards posed by industrial facilities, and about the safety systems that ensure there will not be an "American Bhopal." An easily accessible, national data system is critical to enable people at the local level to verify the submitted information, to obtain information on multiple vulnerable zones, and for other reasons.
Starting in 1999, some 66,000 facilities that use large amounts of extremely hazardous chemicals will publicly disclose worst-case accident scenarios as part of larger Risk Management Plans (RMP). The RMPs have three parts. First, a hazard assessment describes release scenarios, potential off-site consequences, and a five-year accident history. Second, a prevention program addresses basic safety procedures such as training, maintenance, and safety audits. Third, an emergency response program covers response plans, drills, and coordination with local planners. By law, the RMPs are public information; by EPA rule, they are accessible to "any person" (61 FR 31717).
Some industry representatives oppose a national, public data system that includes all parts of the RMP on the Internet. Without easily accessible and nationally comparable information at the local level, people will not be able to readily determine if a facility is reporting accurately. They will not be able to benefit from efficient education and training. They won't be able to create summary reports by chemical, industry, or geographic area, find out about hazard reductions achieved elsewhere in the country, or even get comparative information in the format they need. People need ready access, through the Internet and other means, to complete, national information to ensure that they are not isolated from developments elsewhere.
EPA must establish an effective national RMP information system to support both local uses and national needs (such as a Chemical Safety and Hazard Investigation Board). All parts of the RMP are important, including both worst-case and more-likely case release scenarios. Whereas the worst-case scenario indicates the inherent hazard of a chemical at a facility, the more likely-case scenario calculates risks if safety systems fail�a measure that is more easily softened or manipulated.
We therefore urge EPA to address the following concerns in designing the RMP data system. EPA must address how members of Local Emergency Planning Committees (LEPC), community groups, reporters, workers, state and Federal agencies, health professionals, researchers, or other interested persons will be able to:
Assure the integrity of RMP information through comparisons to data submitted elsewhere.
Learn about hazard reductions and prevention opportunities realized elsewhere in the country.
Identify vulnerable zones in neighboring jurisdictions, and produce summary reports by company, industry, or geographic area.
Measure reductions in accident potentials and improvements in inherent safety.
Assign priorities for risk reduction and target activities to the most important hazards.
Hold government accountable for effectively managing activities and measuring results (as called for in the Government Performance and Results Act of 1993).
Establish efficient, cost-effective management of RMP information, with linkages to other environmental, worker, and public health databases.
Conduct efficient education and training on the use of the RMP information.
Assure timely access to RMP information in all localities in the format that people need (on-line, on diskette, or on paper).
Obtain the information without burdening LEPCs or other local entities.
The RMP rule is the most important chemical accident prevention initiative in years. EPA must take responsibility for establishing adequate data management systems to handle the program. To implement an effective prevention program that serves local needs, EPA must remain committed to a fully accessible, national data system for RMP information.
Sincerely,
Cosigning organizations:
American Lung Association (Washington, D.C.), by Fran DuMelle
American Public Health Association (Washington, D.C.), by Ilisa Halpern
Arizona Toxics Information (Bisbee, Ariz.), by Michael Gregory
Asian Immigrant Women Advocates (San Francisco, Calif.), by Helen Kim *
Atlantic States Legal Foundation (Buffalo, N.Y.), by Sam Sage
Audubon Naturalist Society (Chevy Chase, Md.), by Neal Fitzpatrick
AWARE-Alliance Against Waste and Action to Restore the Environment (La.), by Liz Avants
Bay Area Action (Palo Alto, Calif.), by David Smernoff
Bhopal Action Resource Center (New York, N.Y.), by Ward Morehouse
Breast Cancer Action (San Francisco, Calif.), by Nancy Evans and Barbara Brenner
Bridge Alliance (Newburgh, Ind.), by Nan Hardin
California Communities Against Toxics (Rosamond, Calif.), by Jane Williams
California WORKSAFE! (San Francisco, Calif.), by Pam Tau Lee
Californians for Quality of Life (San Diego, Calif.), by Carolyn Chase
Calvert Group (Bethesda, Md.), by Kenneth Scott
Center for Environmental Health (San Francisco, Calif.), by Michael Green
Concerned Citizens of South Central Los Angeles (Calif.), by Melodie Dove
Council on Economic Priorities (New York, N.Y.), by Sara Baerwald
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Is this Sara a relative?
