Our organization is deeply concerned over discussions surrounding the issue of EPA not providing full disclosures of (RMPs) Risk Management Plans. We very much appreciate the opportunity to appear before you today. The question of full disclosure of Risk Management Plans is of vital importance to our organization, our members, and the communities in which they live. We feel that if we are ever to have effective, ongoing hazard reduction. These plans must be fully disclose to encourage safer technologies, honor the public's right to know, and to overcome the complacency of the chemical industry, that has allowed it to produce no serious plan and timetable to reduce hazards.
The Clean Air Act requires the Environmental Protection Agency (EPA) to implement a program to assist in the prevention of chemical accidents. EPA developed the Risk Management Program Rule. This Rule requires some 66,000 facilities that manage sufficient amounts of hazardous materials to develop a RMP and file it with EPA. These facilities include chemical manufacturers, refineries, water treatment facilities, ammonia refrigeration, propane storage, and semiconductor fabrication. A projected 85 million people live within a five-mile radius of a RMP facility.
The Clean Air Act also requires that EPA make this information available to the public. Our organization became very concerned in November when we discovered that EPA had made the decision on November 6, 1998 to not allow full access to RMP information. We have expressed our concern about EPA's ability to effectively deliver full access to Risk Management Plans in joint correspondence with other groups to EPA Administrator Carol Browner.
Our main of concern surrounding full discourse is our members, their families and the communities in which they live. Our members are the first respondents to the site of a manufacturing accident at their worksite. They also may work at a site near an incident, next door, across the street, or five miles away, but near enough to be affected. Currently, not enough effort has been placed on hazard reduction, for our organization to readily accept limited discourse on hazardous materials that our members work, or live near.
There is also the issue of manufacturing security. It is to our advantage as an organization that represents workers in this arena that we can say to workers, their families, and the community, that these facilities have nothing to hide. We can tell workers that these facilities are working towards reducing hazards, their RMPs are available in any form they need ``electronic or other'' to provide the information needed to show that they are really working towards hazard reduction. We believe that it is not the knowledge that is harmful, but the lack of knowledge that has at times created mass hysteria and rushes to judgment.
Although numbers vary, depending on the source of statistics and period of time examined, there is no doubt about the effects of chemical accidents on human lives. Year after year, large numbers of people are killed or injured. In addition, the numbers for those suffering the long-term consequences of exposure must also be counted.
Currently, the Chemical Safety Board is reviewing or investigating accidents in Arizona, Arkansas, California, Florida, Georgia, Idaho, Iowa, Louisiana (3), Maryland, Michigan (2), Missouri, New Jersey (2), New York, Ohio (2), Oklahoma, Oregon, Pennsylvania (2), South Dakota, Texas, and Washington State (2), as of February 3, 1999. The last three months of 1998 the Chemical Safety Board begin four incident investigations. Of those four:
10-13-98: Five employees injured, local residents advised to shelter in their homes;
10-24-98: Seven workers were killed;
11-25-98: Six workers were killed; and 12-11 -98: Seven workers were killed.
That is a total of 20 workers who were killed on the job in the last three months of 1998. These numbers are clear and the message they send should be equally clear, we need to work harder at reducing hazards and it is our belief that full disclosure is the beginning step.
We believe that there are many valid and important uses for RMP information by people who live, work and conduct business well beyond the immediate community where a facility is located. RMP information can be useful in the following ways:
To learn about vulnerability zones and prevention practices in similar facilities in different states;
To verify reported information by comparing data submitted elsewhere; To hold government accountable for reducing hazards nationwide;
To develop studies on chemical hazards;
To develop effective accident prevention programs;
To develop and conduct effective education and training programs; To link other worker safety and public health database; and To determine which facilities might pose "Year 2000" risks.
Just as we believe strongly that our members, their families, and the communities they reside in will be made safer by these full disclosures, we do not believe that they are being placed in danger of sabotage or terrorism.
In earlier discussions with EPA, the industry and everyone else agreed that a "professional terrorist" would not be deterred by keeping this information off the Internet. (For earlier discussion, see www.epagov/swcrccpp/pubs/rmprpt.html_look under Section 2.B. "Location of RMP. Info [Internet Issues]).
Risk Management Plans 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. Anyone can get readily available information regarding the largest and most dangerous facilities that store chemicals, without using the Internet. Also, keeping worst-case scenarios off the Internet offers no real protection to communities. Communities can only be protected when companies use safer chemicals, reduce dangerous storage, widen buffer zones and provide full information.
Chemical accidents have no respect for geographic boundaries. We must have the freedom to communicate concerning chemical hazards, if we are to have real hazard education. Only with full information disclosure and opportunities to act can facilities, employees, and communities reduce chemical hazards.
In conclusion, I would like to reiterate the following points:
Industry should and must produce a serious quantifiable plan and timeline to reduce hazards; and
Full disclosure of RMPs is the key tool needed to access the impact of hazard reduction programs and activities.
Thank you for allowing me the opportunity to speak on behalf of PACE to explain our position to you today on this important issue.