RTK or Left-To-Wonder?
Recommended Reading

Chemical Industry Continues to Resist Disclosure

Also see November 1998 - Monthly Update on RMP Electronic 
Submission (the meeting where it was announced that OCA (Offsite
Consequence Analysis) would NOT be available on the internet

I have made a copy of the January 6, 1999
40 CFR Part 68
Accidental Release Prevention
Requirements; Risk Management
Programs Under Clean Air Act Section
112(r)(7), Amendments; Final Rule available
for download in Acrobat pdf format (126k)

EPA's Chemical Accident Prevention and
Risk Management Planning (RMP) Webpage


RTK.NET Mail 496875  Jan 20 14:41:06 1999

Below is a useful reference on the chemical industry's efforts 
to impede the public's ability to communicate freely about 
chemical accident hazards in communities.  For more information, 


ACT, 112(r).

The Clean Air Act, 112(r), requires an estimated 66,000 
facilities that use extremely hazardous chemicals 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 (RMP).  Through public disclosure, 
Congress intended to prevent pollution, save lives, and 
protect property.  By law, this is public information, due to 
the U.S. EPA by June 21, 1999.

Nonetheless, some in the chemical industry and government 
are still resisting full disclosure and are working to restrict 
our freedom to communicate about chemical hazards.  They 
claim that "terrorists" will target facilities if worst-case 
scenarios are published on the Internet.  However, keeping 
information off the Internet does nothing to reduce actual 
hazards.  Yet neither the EPA, the security agencies, 
Congress, nor the chemical industry has a serious, 
quantifiable plan and timeline to prevent the hazards that 
chemical companies bring into communities.  Full 
disclosure of accident scenarios is necessary to overcome 
this institutional complacency, to encourage safer 
technologies, and to honor the public's right-to-know.  The 
freedom to communicate about chemical hazards is essential 
to reducing those hazards-in other words, to achieving real 

Below are sample objections and responses.  See more at 

[1] Worst-case scenarios provide a "blueprint" on how to 
sabotage industrial facilities.

No, that's a mischaracterization.  Risk Management Plans 
(RMP) do not include any information about how to 
sabotage an industrial facility-no technical data about how 
to cause a "worst-case" event, no tank locations, no plant 
security information, and no classified information.

[2] Keeping information off the Internet will prevent 
"terrorists" from targeting chemical plants.

No, that's disingenuous.  Any person already can get 
information about the largest and most dangerous facilities 
storing chemicals without using the Internet (or using 
information already on the Internet).  People can obtain 
information from the telephone book, direct observation, 
trade publications, industry public relations events, common 
sense, and other sources, all without using the Internet.

[3] Keeping information off the Internet will protect 

No, keeping worst-case scenarios off the Internet offers no 
real protection to communities.  To actually reduce hazards, 
companies must use safer chemicals, reduce dangerous 
storage, widen buffer zones, etc.  The freedom to 
communicate about chemical hazards enables people to 
learn about successes at similar facilities and communities 
elsewhere.  Only with full information and opportunities to 
act can facilities, employees, and communities reduce 
chemical hazards.  For this, the Internet is a necessary tool.  
(See also #10 below).

[4] Disclosing worst-case scenarios will compromise 
national security.

No, the U.S. EPA has specifically prohibited facilities from 
including any classified information in their Risk 
Management Plans (61 FR 31726).

[5] Publicizing worst-case scenarios increases security 
burdens on facilities.

No, companies' general duty to operate safely includes site 
security (Clean Air Act, 112(r)(1)).  Nothing in a Risk 
Management Plan increases this responsibility.

[6] Publicizing worst-case scenarios on the Internet 
causes a security risk.

No, worst-case scenarios help communities plan for and 
prevent chemical hazards.  Publication does not create these 
hazards.  Journalists do not cause the chemical hazards 
about which they inform readers.  The Augusta (Ga.) 
Chronicle, for example, published toxic plume maps from 
industry's own PR event (at http://augustachronicle; search 
for "Planning for the Worst Maps" in October 1997).  
Companies must take responsibility for the hazards they 

[7] The EPA is taking sufficient steps to reduce chemical 

No, the U.S. EPA has never used its clear legal authority 
under the Clean Air Act, 112(r)(7)(A) and 112(r)(9), to 
reduce the hazards that the chemical industry brings into 
communities.  Nor do the security agencies, Congress, or 
industry have a serious, quantifiable program to prevent 
these hazards.

[8] The industry is taking sufficient steps to reduce 
chemical hazards.

No, the industry has no quantifiable public pledge and 
timeline to reduce worst-case vulnerability zones.  Yet 
companies can reduce hazards by using safer chemicals, 
reducing process pressures or volumes, adding secondary 
containment or automatic shutoff devices, widening buffer 
zones, etc.

For example, a water treatment plant can replace volatile 
chlorine gas with bleach, ozone, or ultraviolet light 
disinfectants.  A manufacturer can produce and use up 
methyl isocyanate-the Bhopal chemical-without storing 
this dangerous chemical.  A company can replace flammable 
solvents with safer water-based materials.  Unavoidably 
hazardous industries can widen community buffer zones, 
such as by moving ammonia tanks away from populated 

[9] An EPA-funded study says putting information on 
the Internet increases risks.

No, this is highly inaccurate.  The study, by AEGIS, 
estimated relative risk using an undefined "x" as the 
baseline risk-but if "x" is very small (as experts believe), 
then two times "x" is also tiny.  Remarkably, AEGIS 
omitted from its analysis any benefits from disclosing 
chemical hazards to workers, fire departments, and the 
public.  Further, the report did not explain why use of the 
Internet would be necessary to target an industrial facility, 
nor did it identify any examples of people using the Internet 
to do so.  The chemical industry funded a subsequent 
AEGIS study.

[10] Providing only local worst-case scenarios satisfies 
the public's right-to-know.

No, without ready access to national information people 
won't be able to:
[o] Learn about hazards in other jurisdictions where 
relatives live or children go to school;
[o] Learn about safety improvements at similar facilities in 
other communities;
[o] Prioritize correction of "year-2000" computer failures 
that may cause an accident;
[o] Verify reported information by comparing data 
submitted elsewhere;
[o] Hold government accountable (as under the Government 
Performance and Results Act of 1993) for reducing hazards 
[o] Link other national environmental, worker safety, and 
public health databases;
[o] Conduct efficient education and training across many 
[o] Analyze trends by geographic area, chemical, company, 
or industry;
[o] Obtain timely access to information in all localities in 
the needed format-on-line, on diskette, or on paper;
[o] Avoid needless information access burdens on local 

[11] Chemical accidents are infrequent.

No, every fifteen minutes in the U.S., on average, a 
chemical fire, spill, or explosion is reported through the 
EPA's Emergency Response Notification System, or 38,305 
incidents in 1997.  Of these incidents, more than 1,000 
caused death or injury.  Further, current trends in 
infrastructure disinvestment and corporate downsizing are 
eroding safety.  A reader survey by Industrial Safety and 
Hygiene News found that "78 percent believe accidents are 
more likely as employees work longer hours, handle new 
assignments, and fear for their jobs."  In addition,"year-
2000" computer problems pose new hazards.  The 
GartnerGroup, which advises businesses worldwide, 
estimates that 50 percent of companies in the chemical 
processing industry "will experience at least one mission 
critical system failure" due to date-related computer failures, 
which can lead to chemical accidents.  Finally, health and 
safety figures often exclude both long-term health effects 
and contract employees (who are less familiar with facilities 
and have higher rates of accidents).

Prepared by the Working Group on Community Right-to-
218 D Street, SE; Washington, DC 20003.  Phone: (202) 

Paul Orum
Working Group on Community Right-to-Know
218 D Street, SE;  Washington, DC  20003
Ph: (202) 544-9586; E-mail: [email protected]

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