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Working Group on Community Right-to-Know
comment on proposed RMP "worst case
scenario" rule.

Fair Use Statement

Return to main RMP proposed rule page and send your own comment.


Deadline June 8

Please take five minutes now to defend our right-to-know and freedom to communicate about dangerous chemical-industry practices where we work, live, play, or go to school.

The Environmental Protection Agency (EPA) and the Department of Justice (DOJ) have proposed to severely restrict public access to chemical accident scenarios that show what could go wrong at facilities that use extremely hazardous chemicals.

Please see background below, then fax or e-mail (by June 8) your objections to EPA and DOJ! (Fax and e-mail addresses below).

We suggest, in your own words, including some or all of the following:

1. Your name, organization, address, and interest in preventing chemical accidents.

2. The proposed rule:

 Confirms that dangerous chemical industry practices threaten workers and nearby communities, and that the potential for criminal activity compounds these dangers.

 Acknowledges that community right-to-know reduces hazards.

 Fails to honor the public's right-to-know and does nothing to decrease existing dangers to workers and communities.

 Fails to show how many lives EPA and DOJ expect to save by keeping accident scenarios off the Internet, and balance this against lives saved through full disclosure.

 Ignores the legal mandate for EPA and DOJ to protect people from potential hazards.

 Establishes a tracking system for people who request public information, raising privacy concerns.

 Restricts people to viewing but not copying public documents to which they have legal access.

 Negates the benefits of national right-to-know data that enables people to identify best practices in other communities and then demand best practices at local facilities.

 Fails to establish a "read-only" information system as required (and easily achieved through the reading rooms that the agencies are proposing).

 Creates a dangerous precedent that threatens other right-to-know data involving environmental or public health hazards.


The Environmental Protection Agency (EPA) and Department of Justice (DOJ) have jointly proposed restrictive new rules for public access to information on toxic chemical hazards in communities.

The Clean Air Act of 1990 requires more than 15,000 facilities that use extremely hazardous substances to tell workers and the public what could happen in a chemical accident, from the most-likely accident to a worst-case scenario. These scenarios are part of larger Risk Management Plans.

However, by the mid-1990s, a few voices in the chemical industry still argued against public disclosure. They worked to involve the government's security agencies and raised alarm about putting hazard scenarios on the Internet. This strategy shifted attention from corporate responsibility to fear of the Internet.

Raising fear of the Internet does nothing to improve worker and public safety; rather, it fosters a paranoid "Chemical McCarthyism" that openness is dangerous to society. However, facility design and chemicals determine the need for site security and safety, not the amount of information on the Internet.

We argue that secrecy invariably breeds incompetence and complacency, while right-to-know (with regulations) spurs innovation to reduce hazards. Moreover, the information in these plans is entirely inadequate to create a chemical incident; no tanks, valves, staffing, security, or similar information is included.

Further, many facilities hazard scenarios are already on the Internet (at ). Some newspapers publish stories on the Internet that inform their readers about local chemical hazards. In addition, people can identify chemical plants from direct observation, the phone book, satellite images, trade publications, industry public relations events, common sense, and other sources without using the Internet.

Nonetheless, in August 1999, Congress responded by partially restricting the hazard scenarios (in S.880). At the same time, this measure did almost nothing to reduce chemical industry hazards or improve site security at chemical plants. (The lone safety provision requires DOJ to study site security at chemical plants. However, the DOJ has not even begun this security study, with an interim report due in early August.)

On April 27, 2000 the EPA and DOJ jointly announced in the Federal Register proposed rules to carry out this law (page 24833). However, the proposal does not carry out the law's balancing test between the benefits and risks of disclosure. Instead, EPA and DOJ go to extraordinary lengths to keep companies' danger assessments off the Internet. The proposed rule restricts people to viewing, but not copying, hazard scenarios for ten facilities per month at reading rooms that could be hundreds of miles away. People could also view the data under the supervision and discretion of local officials. Both options are very burdensome on citizens and under-funded local emergency responders. In addition, members of Local Emergency Planning Committees could face fines of up to $1 million for giving out copies of the data.

Meanwhile, each year, an estimated 250 Americans die in chemical accidents.

Fax, e-mail, or mail a short letter (on or before June 8) to:

Attn: Docket No. A-2000-20

Environmental Protection Agency
Office of Air and Radiation
Docket and Information Center
Ariel Rios Building, M6102
1200 Pennsylvania Ave, NW
Washington, DC 20460

Fax: (202) 260-4400
E-mail: [email protected]
Phone: 202-260-7548 (if problems or to confirm receipt)

For more information:
See the Federal Register, page 24833, April 27, 2000. See (lengthy) basis documents at (warning: this is a very large 1.9mb PDF document) and

See our issue-specific web site at

Prepared by Working Group on Community Right-to-Know 218 D Street, SE; Washington, DC 20003; (202) 544-9586.

Working Group on Community Right-to-Know
218 D Street, SE; Washington, DC 20003
Phone: 202-544-9586; Fax: 202-546-2461

Return to main RMP proposed rule page and send your own comment.

Didn't find what you are looking for? We've been online since 1996 and have created 1000's of pages. Search below and you may find just what you are looking for.

Michael R. Meuser
Data Research & GIS Specialist is an independent firm specializing in GIS project development and data research. We created the first U.S. based interactive toxic chemical facility maps on the internet in 1996 and we have been online ever since. Learn more about us and our services.

Have a project in mind? If you have data, GIS project or custom shapefile needs contact Mike.

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