"Report Card" for Your Local Emergency Planning Committee

In 1986, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA), which established several thousand Local Emergency Planning Committees (LEPC) across the United States.  These LEPCs were intended to identify chemical hazards, plan for emergencies, convey public information, and include all citizens.  But are the LEPCs working?  Many community activists believe that the mostly-volunteer LEPCs are not able to fulfill the vision of EPCRA, particularly for community involvement, hazard communication, and hazard reduction.  Below are some criteria for evaluating your LEPC.  (To locate your LEPC, see www.epa.gov/ceppo/lepclist.htm).

[/] Check each item completed by your LEPC.

Items completed:
 51 to 60  - Outstanding
 41 to 50  - Very Good
 31 to 40  - Good
 21 to 30  - Progressing
 11 to 20  - Mediocre
  0 to 10  - Non-functional

Has your LEPC...

1.  Goals
Established measurable outcome goals for -
[ ] reducing accidents?
[ ] reducing vulnerability zones and accident potentials?
[ ] improving emergency response and mitigation?
[ ] established goals for public access to chemical hazards information?
[ ] set process objectives (for funding, participation, communication, putting inherent safety before response, etc.) and annually evaluated progress toward achieving goals?

2  Structure and Process
[ ] achieved genuinely broad-based and balanced membership?
[ ] secured adequate funding sources and professional staffing (through legislation, agency budgets, donations, etc.)?
[ ] adopted a mission statement and by-laws?
[ ] held regular, well-attended meetings (at least quarterly)?
[ ] held formal meetings (advance agenda, written minutes)?
[ ] organized active subcommittees and established clear member roles?
[ ] maintained policy independence from the host agency?
[ ] produced an annual report (covering trends in accidents, hazards, enforcement, drills, site-specific risk reduction, etc.)?
[ ] utilized external resources such as other LEPCs and government agencies (e.g., to obtain training materials)?

3.  Community Hazards Analysis
(for facilities with extremely hazardous substances, EHS):
[ ] developed easily understood community maps showing EHS facilities, vulnerability zones, and transportation routes?
[ ] obtained needed EHS facility data through questionnaires, site visits, and document requests (using EPCRA 303(d)(3) authority)?
[ ] obtained worst-case and lesser release scenarios prepared under EPA's Risk Management Planning regulations?
[ ] obtained EHS facility process hazard analyses prepared under OSHA's Process Safety Management regulations?
[ ] asked transportation carriers to identify standard routes, storage areas, average amounts, and vulnerability zones?
[ ] identified critical facilities, vulnerable environments, and potentially exposed populations (e.g., schools, nursing homes, residential areas, workers on-site)?
[ ] reviewed hazard analyses with EHS facility managers and worker representatives (including shelter-in-place and evacuation needs)?
[ ] established computerized hazards analysis capabilities?
[ ] prioritized hazards (e.g., by vulnerability zone)?
[ ] independently reviewed or tested site security measures?

4.  Emergency Response Planning
[ ] submitted a site-specific emergency plan to the State Emergency Response Commission?
[ ] exercised the emergency plan and corrected identified weaknesses?
[ ] ensured coordination between EHS facilities and fire departments, as well as other emergency response organizations (police, hospitals, etc.)?
[ ] sponsored training for fire, medical, police, hazmat, and other response personnel?
[ ] ensured that hazard analyses are incorporated into fire department pre-plans?
[ ] established alert and warning systems (and coordinated systems among facilities)?
[ ] established means to determine the severity of a release, and the area and population likely to be affected?
[ ] planned shelters and evacuation routes?
[ ] designated community and facility emergency response coordinators?
[ ] maintained a current inventory of emergency response resources (equipment, facilities, and expertise)?
[ ] provided public education on protective actions (evacuation and shelter-in-place)?
[ ] evaluated the protective capacity of shelter-in-place structures?
[ ] acknowledged the limits of emergency response capabilities for protecting people, property, and the environment?

5.  Accident Prevention
[ ] promoted inherently safer technologies (involving safer chemicals, lower pressures or temperatures, less storage, fewer shipments, etc.)?
[ ] promoted "add-on" safety controls (e.g., secondary containment, automatic shutoffs, process alarms, etc.)?
[ ] promoted site security improvements (e.g., guards, fences, cyber barriers, independent audits, etc.)?
[ ] asked facilities to present progress reports on chemical hazard reduction projects?
[ ] provided the community hazard analysis to planning commissions, zoning boards, public works departments, citizen advisory councils, and other local entities?
[ ] acquainted facilities with hazard reduction resources (e.g., financing, expertise)?
[ ] convened seminars for facility personnel, union health and safety committees, etc.?
[ ] analyzed spills and response, and publicized lessons learned and best practices?
[ ] given public recognition for hazard reduction achievements (e.g., annual awards)?

6.  Community Right-to-Know
[ ] publicized availability of right-to-know information?
[ ] computerized data for ease of access and analysis?
[ ] established a convenient information request process?
[ ] provided Tier II chemical storage information as required?
[ ] communicated Risk Management Plan information to the public?
[ ] worked with the news media to publicize hazard maps and safer alternatives?
[ ] publicized the federal reading rooms (click here for a list of reading rooms)
[ ] publicized options for reducing vulnerability zones through safer technologies?
[ ] ensured that meetings are accessible and well publicized (time, place, agenda)?
[ ] worked with concerned communities at specific sites (e.g., through good neighbor agreements)?

7.  Enforcement
[ ] publicized reporting requirements to covered facilities and transportation carriers?
[ ] provided compliance assistance to facilities and carriers?
[ ] uncovered and prosecuted non-reporting firms?
[ ] pursued beneficial expenditures in settling citizen suits against non-reporting firms?

Compiled by:
Paul Orum, Working Group on Community Right-to-Know (202-544-9586), and
Stuart Greenberg, Environmental Health Watch (216-961-4646).