Testimony of Paul Orum, Working Group on Community Right-to-Know
Before the Subcommittee on Superfund, Toxics, Risk, and Waste Management of the Senate Environment and Public Works Committee
November 14, 2001    

Thank you for the opportunity to testify today.  I am Paul Orum, director of the Working Group on Community Right-to-Know.  Since 1989 I have worked with many non-governmental organizations in all 50 states that are concerned with efforts to reduce chemical hazards and toxic pollution.  

We are here about one fundamental question: will there be a federal program to reduce chemical industry hazards that endanger communities – whether from criminal activity or accidents – or will there not?  

The terrorist attacks of September 11 show plainly that chemical plants and refineries could suffer a worst-case fire or toxic gas release.  No longer can the chemical industry claim that a worst-case release is too improbable to occur.  No longer can the U.S. Environmental Protection Agency claim that hazard reduction is a local matter with no need for a national hazard reduction program.  No longer can the U.S. Department of Justice neglect its duty to review chemical security practices and to recommend ways of reducing vulnerabilities.  No longer can the federal government impede public information about dangerous industry practices while taking no obvious steps to eliminate and reduce those dangers.  No longer can anyone seriously propose that voluntary local programs are sufficient to fix the problem.   

Congress has an opportunity and a duty to fill a big hole in our laws by requiring chemical-using facilities to evaluate safer alternatives and use them wherever practicable.  The Chemical Security Act of 2001 (S.1602) proposes constructive steps toward a national prevention and chemical security program, and gives government the tools it needs to protect communities in the new era of terrorism.    

There is a big hole in our chemical safety laws.
People might think that the right programs are already in place, but they are not.  Currently, no federal law actively regulates the vulnerability zones that hazardous chemical facilities impose on surrounding communities (in terms of size, intensity, or population at risk).  Nor does any federal law require firms to even examine safer alternatives.  Nor is terrorism a specific planning element in the Risk Management Program established by the Clean Air Act.  Nor were regulatory thresholds under this act and other laws established with potential terrorism in mind.[i]   

No federal law systematically encourages inherently safer alternatives at facilities that could suddenly release dangerous chemical plumes into surrounding communities.  As a result, thousands of communities across the country have chemical hazards that may be wholly unnecessary.  Current laws, generally speaking, are limited to cleanup, planning, response, and risk management:  

Chemical site security is often poor.  
Both government reports and other incidents show serious security problems at chemical facilities.  In addition, Congress should by now have in hand an interim report from the Department of Justice (DOJ) on site security for chemical facilities and transportation.  Congress mandated this review in 1999 in the Chemical Safety Information, Site Security, and Fuels Regulatory Relief Act, with an interim report and recommendations due by August 2000.  DOJ is apparently ignoring this requirement.  Congress should make sure that DOJ produces this review and recommendations.[ii]  DOJ is preparing a voluntary self-assessment tool for use by industrial facilities.  This effort lacks a public docket.  It uses an “acceptable risk” methodology that does not consult people at risk in surrounding communities.  DOJ has not fulfilled a Freedom of Information Act request of July 30, 2001 on this project.  The Department has also not directly addressed detailed concerns raised by a dozen environmental and labor groups in a letter first sent in August 2000, despite repeated attempts (see attached letters).   

Chemical fires and spills occur frequently.  
Each year, companies in the United States report more than 25,000 fires, spills, or explosions involving hazardous chemicals to the National Response Center, a broad but incomplete federal record of mishaps involving oil or chemicals.[viii]  At least 1,000 of these events each year involve deaths, injuries, or evacuations.  Combined data from additional federal sources suggest that in 1998 there were over 100 deaths, nearly 5,000 injuries, and when including small spills, almost 50,000 incidents related to ordinary industrial use of chemicals in the United States.[ix]  Some analysts suggest that for each catastrophic chemical accident that causes a fatality, there are 30 lost-time incidents, 300 recordable incidents, and 30,000 near misses.[x]  Serious incidents often cost jobs, and uncounted people suffer long-term consequences from being exposed to the dangerous chemicals.  One estimate suggests costs of about $5 billion for major U.S. chemical accidents each year.[xi]        

Mostly-volunteer Local Emergency Planning Committees are no substitute for an urgent national effort to reduce chemical hazards.  
A recent study of 32 “active” Local Emergency Planning Committees (LEPC) found that “with a few exceptions, LEPCs do not believe they are positioned to effectively encourage facilities to reduce chemical hazards.”  Most of these LEPCs believe they “do not have the time, resources or expertise to encourage hazard reduction.”[xii]  Again, these were “active” LEPCs.  An earlier national survey found that 21 percent of LEPCs were “inactive,” 39 percent were “quasi-active,” 16 percent were “compliant,” and 24 percent were “proactive.”[xiii]  Among many additional barriers, LEPCs lack the authority and mandate for hazard reduction; can be hampered by dependent relations with industry; have no formal role in implementing Risk Management Planning; and can become discouraged by a perceived unwillingness of government and industry to act.  Many lack funding.  According to one report, “many LEPCs exist only on paper, and many others exist, but have not succeeded in meeting even their basic responsibilities.[xiv]  There is a role for local volunteer efforts, but these efforts are no substitute for a national chemical hazard reduction program, and indeed would benefit from the leadership provided by an effective national program.    

Only major policy changes will create a successful national effort.  
We need a national response to potential terrorism, not just voluntary self-assessment programs.  If site security at airports were voluntary, it wouldn’t make Americans feel very safe.  The following examples help illustrate the problem.  

The Chemical Security Act, S.1602, proposes constructive steps to fix the problem.  
The Chemical Security Act will give government the mandate and tools it needs to ensure that hazardous chemical industries reduce hazards and protect chemicals from theft or intrusion.  The act:  

This approach addresses the fundamental difference between preventing a hazard and controlling it.  There may not be safer alternatives to all chemical processes.  But the Chemical Security Act proposes a hierarchy of responses that covers all bases and in all cases will identify feasible measures to protect lives, property, and the environment.  

There are many opportunities for inherently safer technologies.  
Specific examples, recent reports, and government efforts all suggest that there are opportunities to reduce inherent chemical safety hazards.[xxi]  A few examples help to illustrate what is possible:  

EPA and DOJ could designate “high priority” categories in several ways.
The Chemical Security Act does not prejudge which industries EPA and DOJ will determine pose the highest hazard.  However there are several possible approaches, which EPA and DOJ could use in combination.  For example:  

People support a federal prevention role.  
A recent survey found that between 81 percent and 88 percent of people living within a one-mile radius of a Risk Management Plan facility would feel safer knowing that the EPA or the Occupational Safety and Health Administration were providing accident prevention and hazard reduction assistance to hazardous chemical industries.  This survey predated the September attacks.  The survey also found that between 50 percent and 67 percent of these “near neighbors” were unaware of the specific Risk Management Plan facility.[xxxii]  The Chemical Security Act will help assure people that the government is legitimately taking steps to protect them.  

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Footnotes
[i] For example, a one-ton cylinder of chlorine falls below the Risk Management Planning thresholds set by EPA, but can create levels of chlorine gas two miles off-site that are considered “immediately dangerous to life and health.”  Department of Energy, “Example Process Hazard Analysis of a Department of Energy Water Chlorination Process,” DOE/EH-0340.
[ii] Letter to the Attorney General from Senator Harry Reid of June 14, 2001; letter to the Attorney General from Senators Frank Lautenberg and Max Baucus of February 11, 2000; and, letter to the National Institute of Justice from Senator James Jeffords of August 24, 2001.
[iii] Agency for Toxic Substances and Disease Registry, Industrial Chemicals and Terrorism: Human Health Threat Analysis, Mitigation and Prevention.
[iv] “Much Work Remains at Blue Plains, Officials Say,” Washington Post, November 8, 1999.
[v], “Chemical Industry Rallies to Security Needs, But Perhaps Too Late, Experts Say,” Newhouse News Service, 2001.
[vi] Judith Bradbury, Environmental Technology Division, Pacific Northwest National Laboratory, U.S. Department of Energy, 1999.]
[vii] Testimony of Joan Claybrook, Advocates for Highway and Auto Safety and Public Citizen, before the Senate Subcommittee on Surface Transportation and Merchant Marine, Senate Committee on Commerce, Science, and Transportation, October 10, 2001.
[viii] National Response Center.  The NRC is the central federal agency to which chemical companies and transporters report oil and chemical spills.  Reports to the NRC cover incidents small and large.  Reports are initial and subject to verification and change.
[ix] Sam Mannan, Michela Gentile, and Mike O’Connor, “Chemical Incident Data Mining and Application to Chemical Safety Trend Analysis,” Mary Kay O’Connor Process Safety Center, Texas A&M University, 2001.
[x] Mannan, et. al, adapted from Richard H. Squire, “Zero Period Process—A Description Of a Process to Zero Injuries,” Process Safety Progress, March 2001.
[xi] Larry Collins, Carmen D’Angelo, Craig Mattheissen, and Michael Perron, Estimating Chemical Accident Costs in the United States: A New Analytical Approach. 
[xii] National Institute for Chemical Studies (Charleston, W.V.), “Local Emergency Planning Committees and Risk Management Plans: Encouraging Hazard Reduction,” prepared for U.S. EPA, Chemical Emergency Preparedness and Prevention Office (#CX 824095), June 2001.
[xiii] George Washington University, Department of Public Administration, Nationwide LEPC Survey, 1994.
[xiv] Resources for the Future, The Future of Local Emergency Planning Committees, 1993.
[xv] U.S. Public Interest Research Group and Working Group on Community Right-to-Know, At Risk and In the Dark: Will Companies in Our Communities Reduce Their Chemical Disaster Zones?, June 1999.
[xvi] Environmental Defense, National Environmental Trust, OMB Watch, Sierra Club, Unison Institute, U.S. Public Interest Research Group, and Working Group on Community Right-to-Know, Hazard Reduction Challenge, June 1999.
[xvii] “Toxic Chemicals’ Security Worries Officials,” Washington Post, November 12, 2001.
[xviii] Radian Corporation, Air Dispersion Model Assessment of Impacts From a Chlorine Spill at the Blue Plains Wastewater Treatment Plant (Final Report), December 15, 1982.
[xix] American Chemistry Council, Chlorine Institute Inc., and Synthetic Organic Chemical Manufacturers Association, Site Security Guidelines for the U.S. Chemical Industry, October 2001.
[xx] The Pollution Prevention Act, 42 U.S.C.A. 13101(b), made it “the national policy of the United States that pollution should be prevented or reduced at the source whenever feasible” followed by a hierarchy of waste management options.
[xxi] General sources on inherently safer design include:  Health and Safety Executive (of the United Kingdom), Technology Division, Designing and operating safe chemical reaction processes (www.hse.gov.uk); and, Trevor Kletz, Process Plants: A Handbook for Inherently Safer Design, 1998. 
[xxii] The Directive on the Major Accident Hazards of Certain Industrial Activities (the “Seveso Directive”) requires member countries to ensure that manufacturers prove a “competent authority” to identify major hazards, adopt appropriate safety measures, and inform, train, and equip employees.  Directive guidance adopted in 1997 addresses inherent safety.
[xxiii] U.S. Environmental Protection Agency, Chemical Accident Prevention: Site Security (EPA-K-550-F00-002), February 2000.
[xxiv] Gerard I.J.M. Zwetsloot and Nicholas A. Ashford, “The Feasibility of Encouraging Inherently Safer Production in Industrial Firms,” to be published in Safety Science.  Zwetsloot is a professor at Erasmus University Rotterdam, Netherlands.  Ashford is a professor at Massachusetts Institute of Technology.
[xxv] New Jersey Department of Environmental Protection, Communication from Reggie Baldini, September 19, 2001.
[xxvi] American Electric Power, Press Release, December 18, 2000.
[xxvii] Information provided by Stuart Greenberg, member, Cuyahoga County (Ohio) Local Emergency Planning Committee, 1998.
[xxviii] National Institute for Chemical Studies, Ibid.
[xxix] National Chemical Safety Program, Mary Kay O’Connor Chemical Process Safety Center, Texas A&M University, Annual Assessment Report – 2001 (Draft Report); Neither the NCSP nor the National Chemical Safety Roundtable have endorsed as final the figures in this draft report.
[xxx] U.S. Environmental Protection Agency, Priority Risk Areas for CEPP Activities, June 1995.
[xxxi] James Belke, U.S. Environmental Protection Agency, “Chemical accident risks in U.S. industry – A preliminary analysis of accident risk data from U.S. hazardous facilities,” September 25, 2000
[xxxii] National Chemical Safety Center, Mary Kay O’Connor Chemical Process Safety Center, Texas A&M University, Survey of Public Trust and Community Interaction, 2001.  This survey contacted over 700 people in randomly selected households near facilities that use, manufacture, or distribute chemicals around the United States. 

Additional Testimony of Paul Orum, Working Group on Community Right-to-Know
In Response to Questions from Senator Jon Corzine Concerning the Chemical Security Act, S.1602.
January 15, 2002

The questions and answers below expand upon previous testimony provided on November 14, 2001 before the Senate Environment and Public Works Subcommittee on Superfund, Toxics, Risk, and Waste Management.

The Administration can easily identify high-priorities from the vulnerabilities that Risk Management Plan (RMP) facilities pose to workers and surrounding communities. The chemical industry has for several years proclaimed that disclosing worst-case chemical release scenarios on the Internet would provide a "blueprint" or "roadmap" for terrorists.[1,2] Proponents of this theory explicitly claimed that a terrorist could use a database of worst-case scenarios to realize "one-stop shopping" for "targeting quality" information.[3] The Department of Justice amplified this claim in testimony and reports.[4] The House Commerce Committee held hearings titled "Internet Posting of Chemical 'Worst Case' Scenarios: A Roadmap for Terrorists."[5] Congress implicitly accepted the roadmap theory in restricting public access to the worst-case scenarios in 1999.[6] Given this history, it is perplexing that anyone would now claim that the Administration could not identify high priority facilities for preventing chemical site terrorism.

In setting priorities, EPA and DOJ should read the blueprint and follow the roadmap. According to one industry analysis, the roadmap consists of bringing together three elements: chemical inventory, worst-case assessment, and population at risk.[7] These three elements present EPA and DOJ a means to identify high-priority facilities for chemical terror prevention. Indeed, the DOJ is already working with EPA's complete database of Risk Management Plans (RMP*Info). Congress should ask EPA and DOJ to provide the appropriate committee(s) with the RMP roadmap, including populations at risk. Congress needs the roadmap from EPA and DOJ to make informed decisions. Reducing these vulnerabilities will provide a basic measure of progress on homeland security.

At the same time, to ensure that the Administration effectively identifies high priorities, Congress should define minimum standards in the Chemical Security Act. Without such a default "backstop," the Administration may not set priorities that protect public safety. The Chemical Security Act should therefore require EPA and DOJ to consider by default as high-priority those facilities that put any person off-site at risk of death or serious injury. Alternatively, the Act could define as high-priority any facility that puts more than a specified number of persons at risk. The Act could then require those facilities to either drop below a threshold number of persons at risk or justify why they cannot do so and apply mandatory site security standards. Using an objective standard, such as population at risk, would ensure that inherent safety changes (involving production) are selected by the company and not, as industry charges, by the government. Facilities that are unable to meet the objective population standard, however, should meet rigorous, mandatory site security standards established by the government to prevent chemical terrorism. In addition, S.1602 currently directs EPA and DOJ to address threats to national security, critical infrastructure, and threshold quantities of substances of concern (to which could be added worker safety, in consultation with the Department of Labor, and environmental protection.) This authority enables the EPA and DOJ to select particular industry sectors and substances of concern for additional scrutiny.

As noted in my testimony, EPA identified in 1995 some 2,000 "high priority/high risk facilities and areas" for attention to prevent chemical releases.[8] In this analysis, EPA used a number of criteria for selecting priority risk areas, including industrial concentration, population density, accident history, transportation density, environmental justice, sensitive environments, and natural disasters. The agency also selected 19 high priority substances based on chemical toxicity, volatility, production volume, accident history, and vulnerability zones. To my knowledge, however, the agency has not targeted any hazard reduction assistance to the high priority facilities and has no plans to do so.

Unfortunately, DOJ has not produced as required a site security review that could help identify high priority sectors and substances.[9] Neither has EPA promulgated required rules that would enable an independent "qualified researcher" to identify priorities.[#10] Nor has the chemical industry suggested which industry sectors or substances may require attention for improved security (other than the three factors noted above: chemical inventory, worst-case assessment, and population at risk). Identifying priorities is not the problem; getting government and industry to act is the problem.

The tragedy of September 11 made clear not only the vulnerability of major buildings and symbolic sites, but also the vulnerability of the nation's chemical facilities. However, there is little reason to believe that the security agencies can accurately assess the probability (i.e., "risk") of all potential terrorist attacks on chemical facilities. Indeed, on September 11 the security agencies once again were unable to effectively anticipate major developments, despite major resource expenditures for security programs. Any program to protect the public against chemical terrorism must acknowledge that security agencies: a) cannot foresee all potential attacks among all potential chemical targets, b) cannot warn facilities in advance of all specific attacks, and c) cannot anticipate the nature of all such attacks. In the new era of terrorism, it is decidedly inappropriate to base security decisions on the ability to predict probability (risk); to do so is to base public protection on false assurances. Chemical security programs must therefore address the potential consequences of industrial releases, including the potential worst-case release in which all safety controls and active mitigation measures fail or are disabled.

Existing federal regulations do not address terrorism prevention to the extent envisioned in S.1602. Existing regulations are from a different, pre-terrorism era. These regulations did not, as a rule, address terrorism in selecting covered substances, thresholds, and industrial sectors. Those few security measures that are contained in current regulations are not equivalent to those contained in S.1602 and are plainly insufficient to prevent chemical terrorism. To be sure, no existing federal law regulates the scope and extent of the vulnerability zones that chemical facilities present to surrounding communities in terms of distance, chemical intensity, or populations at risk. Further, current laws do not require companies to assess safer alternatives to practices that can send toxic fumes into nearby schools or neighborhoods. In addition, many existing chemical safety laws do not address terrorism involving industrial chemicals (such as programs that regulate food quality, flammable fabrics, pesticide registration, pollution permits, and drugs and cosmetics).

The Clean Air Act (CAA) contains certain authorities that EPA could use to address chemical terror prevention. Section 112(r) established the Risk Management Planning (RMP) program to prevent accidents involving extremely hazardous substances.[11] However, EPA did not consider chemical terror prevention when selecting the chemicals, thresholds, and processes regulated under the RMP program. Nor did EPA include any requirement for firms to identify safer technologies in the RMP program, despite vigorous prompting from environmental and labor organizations.[12] In addition, the CAA section 112(r)(7)(a) provides EPA authority to compel dangerous chemical facilities to reduce worst-case chemical vulnerabilities imposed on surrounding communities. However, the agency has never used this authority and has no plans to do so.[13] Congress should ask EPA to explain if the CAA 112(r)(7)(a) is for some reason insufficient to reduce the chemical terror vulnerabilities that hang over many communities. Alternatively, if this authority is sufficient, Congress should ask the agency to explain when it intends to use it. If the CAA 112(r)(7)(a) is to contribute to chemical terror prevention, Congress will apparently have to make this provision mandatory, not optional, and direct EPA to use it and to include inherent safety solutions.

The Clean Air Act's general duty clause, Section 112(r)(1), enables EPA to bring enforcement cases if a firm fails to identify and use available inherently safer technologies that reduce the possibility of chemical terrorism.[14] However, EPA has never used the general duty clause where a firm has failed to reduce unnecessary chemical hazards. Further, EPA's implementation of the general duty clause does not adequately address terrorism prevention in several ways. First, EPA's guidance does not clearly identify a structured process by which firms should identify, document, and select inherently safer options. Second, EPA's guidance necessarily follows "generally accepted" or "recognized" industry practices - which routinely subject communities to extremely hazardous substances stored in large, dangerous amounts. Third, EPA's guidance does not set forth the agency's expectations for firms to prevent criminal releases, which may dissuade EPA from enforcing the general duty if a firm fails to take sufficient security precautions. These shortcomings, together with the agency's pervasive inactivity on inherent safety, illustrate the need for much more direct and vigorous Congressional intervention to ensure that the agency incorporates and uses design for inherent safety and terrorism prevention in general duty enforcement.

Aside from these unused Clean Air Act authorities, federal environmental laws and regulations are plainly insufficient to prevent terrorism involving extremely hazardous chemicals:

The American Chemistry Council's voluntary "Site Security Guidelines for the U.S. Chemical Industry," recently released with SOCMA and the Chlorine Institute, are neither intended nor suited to protect public health and safety. Voluntary chemical site security is no more appropriate than voluntary airport security, and is no more likely to succeed. Voluntary efforts can economically penalize industry leaders who do a thorough job and reward laggards who don't. The ACC's voluntary industry guidelines also suffer major deficiencies. The guidelines:

As noted in my testimony, studies and case examples show that site security measures do fail. Beyond these examples, CBS New York recently broadcast a tape of journalists easily entering a chemical tank farm.[34] Other observers have noted that terrorists or drunks could use high-powered rifles to pierce and explode chemical storage tanks even without penetrating site security.[35] An industry publication points out in graphic terms the vulnerabilities to terrorism of refineries and other facilities that use hydrofluoric acid.[36]

Voluntary approaches are plainly insufficient. Current voluntary efforts have not led many chemical manufacturers to reduce the size of the danger zones that their facilities impose on surrounding communities (in terms of vulnerable distance, population at risk, or toxic intensity). For example, as noted in my testimony:

In the past, chemical industry representatives have insisted that voluntary initiatives such as Responsible Care should not be used to oppose government actions. In the words of John Holtzman, a former director of public affairs at the American Chemistry Council (then the Chemical Manufacturers Association):

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Footnotes
[1] American Chemistry Council (FKA Chemical Manufacturers Association), The Terrorist Threat in America, April 1998.
[2] Coalition for Effective Environmental Information, Government Accountability for Environmental Information Policy, 1999.
[3] American Chemistry Council, Part Two, p. 9.
[4] Statement of Robert M Burnham, Federal Bureau of Investigation, before the Senate Committee on Environment and Public Works, March 16, 1999; and, U.S., Department of Justice, Assessment of the Increased Risk of Terrorist or Other Criminal Activity Associated With Posting Off-Site Consequence Analysis Information on the Internet, April 18, 2000.
[5] U.S. House of Representatives, Committee on Commerce, February 10, 1999.
[6] Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (Public Law 106-40).
[7] Arthur F. Burke, DuPont Corporation, Communication of Risk Management Plan Information: Some "Principles & Concerns," March 4, 1997.
[8] U.S. Environmental Protection Agency, Priority Risk Areas for CEPP Activities, June 1995.
[9] 42 U.S.C. 7412(r)(7)(H)(xi).
[10] 42 U.S.C. 7412(r)(7)(H)(vii)
[11] 42 U.S.C. 7412(r)
[12] U.S. Environmental Protection Agency, Supplemental Notice of Proposed Rulemaking, "Accidental Release Prevention Requirements: Risk Management Programs Under Clean Air Act Section 112(r)(7); Proposed Rule," 60 Federal Register 13525, March 13, 1995; and EPA public hearings, March 31, 1995.
[13] Personal communication of Jim Makris, Director, Chemical Emergency Preparedness and Prevention Office, U.S. Environmental Protection Agency, December 17, 2001.
[14] 42 U.S.C. 7412(r)(1)
[15] 42 U.S.C. 6901 et seq.
[16] 40 CFR 264.14, 265.14.
[17] Paul R. Kleindorfer, Harold Feldman, and Robert A. Lowe, Accident Epidemiology in the U.S. Chemical Industry: Preliminary Results from RMP*Info, Center for Risk Management and Decision Processes, The Wharton School, University of Pennsylvania, March 6, 2000.
[18] 40 CFR 766, 790-799
[19] 42 U.S.C. 7403(f)
[20] OSH Act, Section 6; 29 CFR 1910.119
[21] Presentation of John Murphy, U.S. Chemical Safety and Hazard Investigation Board, Reactive Chemicals Hazard Investigation, Draft Work Product, November 9, 2001.
[22] Paul R. Kleindorfer, Harold Feldman, and Robert A. Lowe, Accident Epidemiology and the U.S. Chemical Industry: Preliminary Results from RMP*Info, Center for Risk Management and Decision Processes, The Wharton School, University of Pennsylvania, March 6, 2000.
[23] OSH Act, Section 6; 29 CFR 1910.1200
[24] Occupational Safety and Health Administration, Process Safety Management of Highly Hazardous Chemicals.
[25] 42 U.S.C., Chapter 103
[26] 42 U.S.C., Chapter 116
[27] National Institute for Chemical Studies (Charleston, W.V.), Local Emergency Planning Committees and Risk Management Plans: Encouraging Hazard Reduction, prepared for U.S. EPA, Chemical Emergency Preparedness and Prevention office (#CX 824095), June 2001.
[28] 42 U.S.C. 7401 (Public Law 106-40)
[29] Working Group on Community Right-to-Know et al, letters to the Attorney General of August 14, 2000; April 23, 2001; June 15, 2001; and, September 27, 2001 (www.rtknet.org/wcs).
[30] 42 U.S.C. 13101 et seq. (Public Law 101-508)
[31] 42 U.S.C. 5101 et seq. 66
[32] Federal Register 32420 66
[33] Federal Register 59220
[34] CBS Channel 2 New York City, Chemical Plant Security Story, November 26, 2001.
[35] Violence Policy Center, Voting From the Rooftops, October 2001.
[36] Neil C. Livingstone, et al, American Bophals (SIC), Energy Safety Council (Washington, DC).
[37] Environmental Defense, National Environmental Trust, OMB Watch, Sierra Club, Unison Institute, U.S. Public Interest Research Group, and Working Group on Community Right-to-Know, Hazard Reduction Challenge, June 1999.
[38] U.S. Public Interest Research Group and Working Group on Community Right-to-Know, At Risk and In the Dark: Will Companies in Our Communities Reduce Their Chemical Disaster Zones?, June 1999.
[39] Chemical Marketing Reporter, What's in a Logo, January 6, 1992.