RTK or Left-To-Wonder?
Risk Management Plan Maps Now Online.
RTK Net's Online Risk Management Plan Database.
EPA RMP Query page.
Download Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (174K PDF format).
Note: I apologize if you find some bad links. I am working to update the links as quickly as possible. April 29, 2000 - EPA changed many directories and file names since I originally created these links. All of the RMP meeting links (below) have now been updated and should be good.
Worst Case Scenario maps and data already on the internet
Draft: January 28, 1999 (Links updated May 10, 1999), text updated November 18, 1999.
Risk Management Plan (RMP) & Offsite Consequence Analysis (OCA)
EPA will not fully disclose the data from their latest Chemical Accident Prevention and Risk Management Planning (RMP) project to the public over the internet. The Chemical Safety Information, Site Security and Fuels Regulatory Relief Act forbids releasing the Offsite Consequence Analysis (OCA) portion of the reports on the internet. If fully disclosed, this data would finally fulfill the promise of the Toxics Release Inventory (TRI). It would provide immediate access over the internet to the worst case scenario of accidental toxic release for 66,000 (this number has been somewhat reduced because the above act also removes propane from reporting requirements) industrial facilities across the U.S. TRI was a response to the devastating chemical accident in Bophal, India that killed thousands of innocent people along with the growing awareness in the U.S. that chemical factories and other industries here posed the same potential for disaster. The TRI was a step in the right direction, making public the toxic releases of industrial facilities, but did little to make us aware of the potential for catastrophic accidents except in the most general manner.
A Little Background on TRI
TRI was not meant to be a direct regulatory tool. Rather its intent was to place toxic information in the hands of the public who might then bring pressure upon industry to reduce its releases of toxics. When the 1987 TRI report was released dozens of community groups analyzed the data and published reports and many newspapers published articles. In 1996 I began an annual mapping on the internet of TRI releases in my home county, Santa Cruz, mapping all releases from the first year of reporting to the present. This led to my creating the interactive mapping component for EDF's Chemical Scorecard. The Scorecard allows anyone access to maps and information about TRI facilities and the chemicals they release nationwide. Polluting industries were put in the public eye. Over the years this has resulted in a reduction in TRI releases though it has also resulted in increased transfers of toxic materials to other communities - but that is another issue that I will save for a subsequent discussion. Nonetheless, national reporting of TRI and access to national TRI data over the internet and on CD-Rom products - full disclosure - has resulted in increased awareness of the toxics in our communities. This awareness has led to a doubling of the number of chemicals reported, increases in the types of industries that must report, proposed lowering of some reporting thresholds, cradle to grave accounting of industrial toxics and, arguably, the creation of EPA's RMP/Offsite Consequence Analysis (OCA).
Industry Claims Threat of Terrorism
Now, twelve years after the initial year of TRI reporting, the RMP information that would give us the knowledge to protect ourselves against such disasters is to be made available. A component of RMP is the Offsite Consequence analysis (OCA). Sadly, industry has made a concentrated effort to thwart full dissemination of this information. Their assault on our Right-To-Know was a success - to a degree. EPA has decided (now it is law - see above link to congressinal act) that the OCA will not be available on the internet because it would make these facilities targets for terrorism and place nearby neighborhoods in jeopardy. Yet, most of the information including name of facility, address of facility, and the chemicals they have on-site will be available on the internet (view the RMP*Info prototype) as well as RMP*Comp, the program facilities use to calculate their OCA! If terrorism was the real threat, this would be all the information terrorists would need.
Not Terrorism but Full Public Disclosure
It is unlikely that terrorism is the threat that industry really worries about. Rather the threat that they most fear is increased public disclosure - more Right-To-Know. You can follow the link to a telling statement by the Vice-President of the U.S. Chamber of Commerce on this issue. In the Final Report of the Electronic Submission Workgroup several members advocating free access said that less than full disclosure of the RMP/OCA data is a greater risk to communities than terrorism. Their comments are worth repeating here:A second group of Workgroup members believe that there should be unlimited Internet access to all RMP data. Their argument is simple: the RMP is community right-to-know information and should be made available to the public. They cite the language in the law, which specifies that EPA shall make RMP data "available to the public." From their point of view the "hazard" comes from the chemicals that are present in the community, not from the information about the chemicals being publicized. In fact, they believe a successful RMP program, including full disclosure of OCA data, will reduce the inherent hazards in the community.Also, many courageous citizens and groups have made valiant efforts to prevent this from happening. I have provided links to their comments and websites below. Also, there are many resources now available to us on the internet that will help us obtain and understand this information and even perform our own OCA for various facilities.
They note that there are many valid and important uses for RMP information by people who live well beyond the immediate community where a facility is located. A community might want to compare one of their facilities to another similar facility in another State to see how their facility compares in terms of vulnerability zones and prevention practices. Researchers will use the RMP information to develop comparative studies on chemical hazards and effective accident prevention programs. Public interest groups anticipate that the data will be critical to their work in reducing accident risks throughout the country.
Members who favor full, unlimited access to RMP data argue that the threat of potential terrorism does not outweigh the public's right to full access of RMPs. They also question whether restricting information (as opposed to reducing the actual hazards) provides any real barrier to terrorism. They argue potential terrorists could calculate the vulnerable zone around a facility and estimate how many people are at risk without RMP*Info by combining existing EPCRA reports with EPA guidance on vulnerability analysis and software mapping programs. Larger facilities are already highly visible from the road and, in some cases, containers are clearly labeled. In addition, circles of vulnerability are more frequently being published in newspapers, and may be put on the Internet through newspapers going on-line. Even with the RMP, some argue that it wouldn't be very useful to an amateur terrorist because the RMP will only provide the address of the facility and the name and quantity of the hazardous substance, but not the specific location of the substance on site.
Very Limited Access
It is doubtful that EPA will release even the RMP data (without OCA) to the public in its raw form (so far this is true - data is only available one facility at a time). Rather, one will use programs such as RMP*Info to submit requests for information on a single facility or small geographic area. Supposed terrorists will still be able to easily find out information about specific facilities, but this will thwart any efforts to make comparisons between regions, industries and the like on a national level. It will also thwart efforts by researchers to do more comprehensive studies on the distribution of toxics in our society. This is what concerns industry most - nationwide public disclosure - not vulnerability to terrorism.
Environmental Justice Research
This should also be of great interest to environmental justice researchers, like myself, who use federal data to study the relationships between demographics and toxics. Many who use this data acknowledge that the data available in usable form represents only a small portion of the potential toxic risks that communities face. Full release of RMP and OCA would place a much more complete database in the hands of researchers allowing much more comprehensive investigations of environmental inequality, hopefully leading to more equitable distribution of the negative environmental aspects of production as well as leading to a reduction in the total amounts of toxics produced and used in our communities.
Cumulative Exposure Project
Another related database that will increase our knowledge of exposure to toxics in our communities is EPA's Cumulative Exposure Project (CEP). Data for the cumulative effects of toxics from multiple sources were collected at the census tract level and analyzed by EPA. The raw data was to be available in October, 1998. Now it is to be available to the public in February, 1999. This data is ideally suited to environmental justice research. I have heard rumors that the data has already been released to at least one national environmental group. Maybe more. I would appreciate it if anyone can confirm this and help make the data more widely available as soon as possible (I obtained this data as a response to a FOIA request - it is now available upon request from thedd website below). The Final Report (revised 12/98) Modeling Cumulative Outdoor Concentrations of Hazardous Air Pollutants is available for download at http://www.epa.gov/oppecumm/air/air.htm.
To receive EPA updates on RPM software and other issues related to RMP subscribe to the official EPA-RMP listserv by sending the message, "SUBSCRIBE EPA-RMP YOURFIRSTNAME YOURLASTNAME" to [email protected]
If you have questions, comments, or insight into this issue I'd love to hear from you. Please contact me at [email protected]. The links follow:
RMP "Worst Case Scenario" of Chemical Accident Maps already on the internetThe EPA, FBI, Industry and the Subcommittees on Health and Environment and Oversight and Investigations of the House Commerce Committee fear that MAPS LIKE THESE will increase the risk of a terrorist attack. These maps have been on the internet for at least a year.
Links Related to February 10, 1999 House Subcommittee Hearing on RMP
- Letter Defending Freedom of Information Act
- Lawmakers Weigh National Security Issues and the Net
- Letter from organizations committed to preserving the public's right to know
- Testimony of Paul Orum Working Group on Community Right-to-Know
Recent related links in our Environmental Disclosure News and Enviro-Newsflash
- May 10, 1999: Contra Costa County facilities present their Worst Case Scenarios on Wednesday, May 12, 1999.
- May 8, 1999: Whitehouse proposes bill limiting distribution of Worst Case Scenario information.
- April 29, 1999: CMA, House Leaders Want Chemical Disaster Scenarios Off-Line.
- April 29, 1999: DUPONT RELEASES "WORST CASE SCENARIO - THOUSANDS COULD DIE.
- March 22, 1999: Deadline for risk-management plan for chemicals draws close
- March 17, 1999: Congressional hearing on EPA's Risk Management Program under section 112 (r) of the Clean Air Act
- March 16, 1999: Chemical Safety Board Presents Y2K Report to Senate Special Committee - dowload the full report
- February 27, 1999: A First Look At The 600K Report: Commercial Chemical Incidents In The United States, 1987 - 1996
"Why The 600K Report? Why, indeed? Why does the industrial equivalent of two 737 airplanes "crash" year after year, killing all passengers (256 people)? And why does no one seem to notice?" (Note: this link has been bad lately. You can download this report directly from our website in PDF format, but beware -- it is a large 1.4mb file -- right click and save)
- February 25, 1999: MAKING THE CONNECTION: Y2K & "WORST CASE SCENARIO" - Testimony by Gerald V. Poje, Ph.D. U.S. Chemical Safety and Hazard Investigation Board on Y2K and chemical plants - "85 million Americans live, work and play within a 5 mile radius of 66,000 facilities handling regulated amounts of high hazard chemicals"
- February 25, 1999: Y2K increases potential for chemical plant problems yet EPA and congress work to limit chemical plant information
- February 22, 1999: Your right to know: Local plants reveal their worst cases, prevention efforts Friday under new federal law
- February 21, 1999: RMP Chemical Accident "Worst Case Scenario" Maps Already on Internet
- February 13, 1999: Does the Web Promote Terrorism?
- January 23, 1999: POLLUTERS WAR AGAINST CLEAN AIR STANDARDS
- January 20, 1999: Chemical Industry Continues to Resist Disclosure
- January 20, 1999: EPA's Chemical Accident Prevention and Risk Management Planning (RMP) webpage
- January 20, 1999: Federal Register pdf file - RMP final rule
- October 19, 1998: Fears of Terrorism, Chemicals Clash as EPA Considers Web Site
- September 19, 1998: The Wall Street Journal Interactive Edition -- September 3, 1998
- September 18, 1998: Risk Reduction Imperiled by Proposed Disaster Secrecy
- September 17, 1998: Document from Arthur F. Burk, Senior Safety Fellow, DuPont Company on terrorism and chemical reporting
- September 17, 1998: Document from Pam Nixon, Accident Prevention Subcommittee member on terrorism and chemical reporting
- September 16, 1998: United States Chamber of Commerce vice-president William Kovacs says, "the use of the Internet by extreme environmentalists and greater amounts of public disclosure law will create fear and allow the sabotage of industries."
- September 15, 1998: EPA Data on Internet Will Increase Threat Of terrorism, Industry- Sponsored Study Says
EPA Whistleblower. What happens when an EPA employee promotes increased Right-To-Know in a community.
EPA Cummulative Exposure Project. Click on the menu item "AIR", then click on the icon "Maps and Data."
Aegis Research Corporation. This firm published the report, Security Study: Analysis of Terrorist Risk Associated with Public Availability of Offsite Consequence Analysis Under EPA's Risk Management Plan that led EPA to its decision.
You may order this free report from National Service Center for Environmental Publications. Use EPA publication number EPA550R97003.
Chemical Accident Prevention and Risk Management Planning (RMP) main website.
RMP*Info and RMP*Submit System Development. Two EPA computer programs used by facilities to submit their RMP and OCA data and for the public to retrieve that information (without the OCA) via the internet.
RMP*Comp is a free program from NOAA that you can use to complete the offsite consequence analyses OCA yourselves. Please let me know if this program becomes unavailable and I will make it available here.
RPM*Submit page - more detail. You can download the program here. http://www.epa.gov/ceppo/rmpsubmt.html
RMP*Info page - see a prototype of the query page here.
The Working Group on Community Right-to-Know has worst case scenario maps of some DuPont facilities and much more critical information on their website.
Final Report of the Electronic Submission Workgroup, June 18, 1997. This report precedes the workgroup meetings listed below.
Monthly Status Updates on RMP Electronic Submission Phase II
Accident Prevention Subcommittee Meeting Summaries, Materials, Comments, Decisions
- September 1999
- March 1999
- February 1999
- January 1999
- December 1998
- November 1998 (Decision not to put OCA on internet)
- October 1998
- September 1998
- August 1998
- July 1998
- May 1998
- April 1998
- March 1998
- February 1998
- December 1997
- November 1997
- October 1997
- September 1997
- August 1997
- July 1997
November 9, 1998
September 9, 1998
- Meeting Summary
February 3, 1998
- Meeting Summary
- Discussion Paper for the February 3, 1998, CAA 112(r) Accident Prevention Sub-Committee Meeting
- Attachment #1
- Timothy R. Gablehouse, Chair, Jefferson County Local Emergency Planning Committee
December 17, 1997
- Meeting Summary
- Jack Weaver, Director, Center for Chemical Process Safety (CCPS)
- Timothy R. Gablehouse, Chair, Jefferson County Local Emergency Planning Committee
- Jerry Scannell, President, National Safety Council
- Art Burke, E.I. DuPont De Nemours & Co. Inc.
- Pam Nixon, Kanawha-Putnam Emergency Planning Committee
- Chemical Manufacturers Association
May 9, 1997 Meeting
- Meeting Summary
- May 9th Agenda
- Accident Prevention Subcommittee Members
- Electronic Submission Workgroup "Discussion Paper". This paper details five controversial and highly visible issues which the ElectronicSubmission Workgroup has selected to focus the discussion.
- Public Outreach One-pager. This paper is provided to stimulate ideas in preparation for the discussion on agenda item IV, "How to expand public outreach and understanding in the risk management program"
- Litigation Issues One-pager. This paper is provided for your information. It summarized the status of the litigation cases with the Risk Management Program.
- Changing Inventories One-pager. An issue has come up that will most likely require a modification to the RMP rule. The RMP rule does not account for the continuously changing inventories of some facilities, such as warehouses. This paper explains the issue.
- ISO 14,001 Overview. One of the topics the Accident Prevention Subcommittee asked for further discussion on was ISO 14,001. Although we couldn't fit a full discussion of this topic into the agenda, this paper summarizes the topic and explains the focus of the proposed ISO 14,001 pilot study.
December 11, 1996
September 24, 1996
RTK or Left-To-Wonder?