Emergency Planners Section

REQUIREMENTS OF SERCs, TERCs, AND LEPCs

LEPCs and SERCs are required to do many things. They have a duty of establishing procedures for receiving and processing requests for EPCRA information (Tier Two Reports, written follow-up reports, MSDSs, emergency plans, Form R Reports) from the general public. These procedures had to include the designation of an official to serve as coordinator for information. The public has an absolute Right to this information.

A State or local official acting in an official capacity may have access to Tier Two information by submitting a request to the SERC or LEPC. Upon receipt of this official's request, the SERC or LEPC will request the Tier Two information from the facility and provide it to the official. If the facility has already filed its Tier Two report, the SERC or LEPC will just provide it to the official.

If the general public requests a facility's Tier Two Report through the SERC or LEPC, and the Tier Two Report is already on file, the Tier Two Report must be available during normal business hours for review and copying. If the facility's Tier Two Report is not on file with the SERC or LEPC, AND the facility had reportable quantities of a chemical, the person requesting the Tier Two Report must include the general need for the information. The SERC or LEPC may request this information, but this is discretionary, and when it is received, make it available to the requesting person during normal business hours for review and copying. A SERC or LEPC must respond to a request for Tier Two information with 45 days. Written follow-up reports, MSDSs, emergency plans, and the regional emergency plan, however, must be available for public review during normal business hours.

EPCRA Regulations about Public Availability of EPCRA Information.

Organizing and Administrating Emergency Planning Districts

The SERCs appoint the LEPCs and supervise and coordinate the activities of the LEPCs. SERCs have the power to establish and determine the emergency planning districts in each state. In many states, each county is an emergency planning district. In some states, the emergency planning districts are broken into areas or regions that are not determined by county boundaries.

If the emergency planning areas involve more than one State, the SERCs of all the involved States may designate emergency planning districts and LEPCs by agreement. In such a scenario, the SERC must indicate which facilities subject to EPCRA reporting requirements are within this emergency planning district. A facility in this type of emergency planning district would not be expected to make the determination, or where to send its EPCRA reports.

SERCs may revise LEPC memberships, SERC memberships, and the emergency planning districts as it deems appropriate. It can make changes and adaptations. Interested persons may also petition the SERC to modify the membership of an LEPC.

The LEPC is an emergency planning body with jurisdiction over an emergency planning district. In most states, each county has an LEPC, and the emergency planning district is the entire county. In others, there are regional LEPCs, and there may be several counties or parts of counties in the LEPC district. The specifics of how the EPCRA law was implemented in the various states was left to the states, with some EPA oversight and review.

The LEPC is a volunteer group made up of representatives from certain interests charged with emergency planning duties. The EPCRA law requires that certain groups or organizations MUST be represented. The EPCRA law requires the LEPC to include, "at a minimum, representatives from each of the following groups or organizations: elected State and local officials; law enforcement, civil defense, firefighting, first aid, health, local environmental, hospital and transportation personnel; broadcast and print media; community groups; and owners and operators of facilities subject to [EPCRA]." {Note the commas and semicolons.}

Sometimes LEPCs do not have all of the members required by EPCRA, but it is easy to see why these diverse entities are needed for an LEPC and EPCRA to work. It is also easy to see that getting all of these diverse interests to the same meeting at the same time can present a problem. But effective emergency planning and preparedness is in the best interests of everyone. Since many of the LEPC members come from government positions, there can be political influences on LEPC decisions. The thought behind the volunteer committee was that emergency planning and preparedness is a mutual concern, and active public interest and participation in LEPC meetings is encouraged.

The EPCRA law requires the LEPC to appoint a chairperson, and to establish rules by which the LEPC must function. These LEPC rules must address provisions for public notification of LEPC activities, public meetings to discuss the emergency plan, public comments, response to such public comments by the LEPC, and distribution of the emergency plan.

REGIONAL EMERGENCY PLANS

The LEPC must complete an emergency plan that includes the information or takes into account the information from all the facility emergency plans submitted to it. The LEPC must review this LEPC emergency plan at least annually, or more frequently as changed circumstances in the community or at any facility may require. Ideally, if facilities are changing the amounts of EHS chemicals stored on-site, these changes will be communicated to the LEPC, fire department, and SERC immediately. The LEPC must publish the location and time of the annual meeting to review the overall emergency plan.

Section 303 of EPCRA requires the regional plan be developed and updated by the LEPC. The law is specific and necessary. It states, "The committee shall review such plan once a year, or more frequently as changed circumstances in the community or at any facility may require."

Each local emergency planning committee shall evaluate the need for resources necessary to develop, implement, and exercise the emergency plan, and shall make recommendations with respect to additional resources that may be required and the means for providing such additional resources.

The law requires that each emergency plan shall include (but is not limited to) each of the following:

Identification of facilities subject to the requirements of this subchapter that are within the emergency planning district, identification of routes likely to be used for the transportation of substances on the list of extremely hazardous substances, and identification of additional facilities contributing or subjected to additional risk due to their proximity to facilities subject to the requirements of this subchapter, such as hospitals or natural gas facilities.
Methods and procedures to be followed by facility owners and operators and local emergency and medical personnel to respond to any release of such substances.
Designation of a community emergency coordinator and facility emergency coordinators, who shall make determinations necessary to implement the plan.
Procedures providing reliable, effective, and timely notification by the facility emergency coordinators and the community emergency coordinator to persons designated in the emergency plan, and to the public, that a release has occurred.
Methods for determining the occurrence of a release, and the area or population likely to be affected by such release.
A description of emergency equipment and facilities in the community and at each facility in the community subject to the requirements of this subchapter, and an identification of the persons responsible for such equipment and facilities.
Evacuation plans, including provisions for a precautionary evacuation and alternative traffic routes.
Training programs, including schedules for training of local emergency response and medical personnel.
Methods and schedules for exercising the emergency plan.

If a new EHS is suddenly introduced into the industrial base of a community, the firefighters and emergency response infrastructure may need to get specialized training and equipment in order to safely and properly deal with a spill or a release of the new EHS chemical. This can be true if there is suddenly a much larger amount of an EHS in a community so that it warrants special consideration. Alternatively, there is no point buying gear and equipment needed to fight a chemical incident that won't happen. By reviewing the provided inventory of facilities' Tier Two information, the LEPC should be able to determine regionally what equipment and gear is needed. It is important to include likely transportation routes of toxic materials such as major roadways or railroads in the plan.

There is often a resource (money and time) problem with LEPCs. Some do not have a paid support staff. Others are underfunded. There are grants available from the EPA and FEMA for emergency planning, but they do not cover the entire cost. Although some of the LEPC members are paid staff from fire departments, emergency planning agencies, industry, state and local government, they are not often specifically assigned to work a large number of hours on LEPC-related work. The budgets of the paid government bureaucracies that have oversight of wastewater and hazardous wastes, which are very diluted when compared to the pure chemicals used as raw materials in today's industrial processes, compare starkly with the unpaid volunteers who have oversight of the purer, more concentrated chemicals, usually with more potential of toxic impact, that travel the roadways and are stored in facilities.

The SERC reviews the emergency plan prepared by the LEPCs under its jurisdiction. Then the SERC reviews all of these various LEPC emergency plans and makes recommendations on revisions to the emergency plans to ensure coordination of each LEPC's emergency plan with the plans of other emergency planning districts. Accidents can happen over LEPC boundary lines.

The regional response teams, which were created by CERCLA, may review and comment upon the emergency plan prepared by the LEPC, upon request from the LEPC. The Regional Response Team may also, upon request from the LEPC, review and comment on other issues related to the preparation, implementation, or exercise of the emergency plan.

There are excellent source materials for emergency planning provided by the National Response Team and available at no charge at the EPCRA Hotline. Anyone can call the Hotline -- it offers information to a broad audience of callers with diverse backgrounds and varying degrees of regulatory knowledge. To speak with Information Specialists about regulatory questions or to order documents, call:

(800) 424-9346 or DC Area Local (703) 412-9810 or TDD (800) 553-7672 or TDD DC Area Local (703) 412-3323 (Some of the EPCRA Hotline's Information and the Guide to EPA's Electronic Resources are available on the Internet at: http://www.epa.gov/epaoswer/hotline/netguide.htm

Ask for the NRT-1 "Hazardous Materials Emergency Planning Guide" published March 1987; and NRT-1A, "Criteria for Review of Hazardous Materials Emergency Plans" published in May 1988. These "orange books" are quite comprehensive, and comparing the LEPC's emergency plan to the comments and information in these guidebooks is a good idea. The NRT Hazardous Materials Planning Guide was updated in 2001. This 2001 update of the 1987 Hazardous Materials Emergency Planning Guide (NRT-1, "Orange Book") contains updated references to guidance on developing state and local emergency response plans. Brief references to recent legislation have been incorporated to encourage plan integration and coordination. This updated version of NRT-1 includes new guidance on integrating local emergency response plans prepared and updated by Local Emergency Planning Committees (LEPCs) with the planning requirements contained in recent legislation.

For an copy, go to http://itdomino1.icfconsulting.com/nrt/home.nsf/resources/RRTPages1/$File/cleanNRT10_12_distiller_complete.pdf

TERCs

Tribal Emergency Response Commissions (TERCs) are another consideration for LEPCs, SERCs, and fire departments. LEPCs, SERCs, and even fire departments may have to work out mutual aid agreements or information and resource-sharing agreements with Native American reservations to implement EPCRA. A SERC and LEPC will not have jurisdiction over facilities on tribal lands unless there is some form of legally-binding agreement allowing this jurisdiction.

An operator or owner of a facility on an Indian reservation may not be sure to whom the facility's chemical inventory report and facility emergency plan must be reported. It may unclear what entity is going to respond in the event of an incident involving hazardous chemicals. The public may be unclear about which entity to approach for Community Right-To-Know information. If a TERC exists, it must provide access to the same EPCRA information that SERCs and LEPCs must provide.

The TERC will not likely exist already as a legal entity on an Indian reservation, because EPCRA became law after most tribal lands were designated. A tribal board or governing committee will likely have to create laws or ordinances implementing EPCRA. This also provides an opportunity for the TERC to have more stringent regulations than EPCRA. It is a bad idea for a tribe to not have a TERC or some other entity with the powers a SERC or LEPC has under EPCRA. There are proportionately more industrial facilities on tribal lands in America than on non-tribal lands, in terms of land area used and population. A TERC might be the only entity a facility would need to report to under EPCRA if the TERC fulfills the duties of a SERC, LEPC, and fire department. A TERC will usually have the combined powers given to SERCs, LEPCs, and fire departments under EPCRA.

The Gila River Indian Community, which is located south of Phoenix, Arizona, has drafted a good example of an ordinance implementing EPCRA.

EPA has special programs to assist TERCs.

WRITTEN PLANNING RESOURCES FOR PLANNERS/RESPONDERS (LEPCs, SERCs, Fire Departments)

Alert & Notification
Emergency Management Institute
Student Manual September 1990
Federal Emergency Management Agency
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Facility Coordinator's Role and the LEPC
Student Manual April 1992
Emergency Management Institute
National Emergency Training Center
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Hazardous Materials Risk Communication
Emergency Management Institute
Instructor Guide
September 1990
Federal Emergency Management Agency
National Emergency Training Center
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Liability Issues in Emergency Management
Emergency Management Institute
April 1992
Federal Emergency Management Agency
National Emergency Training Center
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Hazardous Materials Workshop for EMS Providers
Emergency Management Institute
Student Manual
April 1992
National Emergency Training Center
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Risk Analysis
Emergency Management Institute
Student Manual
September 1990
National Emergency Training Center
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Facility Coordinator's Role and the LEPC
Emergency Management Institute
Student Manual
April 1992

National Emergency Training Center
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Hazardous Materials Exercise Evaluation Methodology (HM-EEM) and Manual
Federal Emergency Management Agency
October 1989
Interim Use
Hazardous Materials Branch (SL-NT-TH)
500 C Street, SW
Washington, DC 20472

Title III List of Lists
Consolidated List of Chemicals Subject to the Emergency Planning and
Community Right-To-Know Act (EPCRA) and Section 112(r) of the Clean Air Act,
as Amended
United States Environmental Protection Agency
Office of Solid Waste and Emergency Response
November 1998
www.epa.gov/ceppo

Hazardous Materials Emergency Preparedness Grant Program
Guidelines for Public Sector Hazardous Materials Training
March 1998

Hazardous Materials Information Management
Emergency Management Institute
Student Manual
September 1990
Federal Emergency Management Agency
National Emergency Training Center
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Hazardous Materials Response Teams
Emergency Management Institute
Instructor Guide August 1993
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

IAFF Hazardous Materials Department
Recruit Training Initiative
1750 New York Avenue, NW
Washington, DC 20006-5395
elamariaff@aol.com
http://www.IAFF.org
(202) 737-8484

National Association of SARA Title III Program Officials (NASTTPO)
P.O. Box 142482
Austin, TX 78714-2482
http://www.geocities.com/capitolhill/6286/index.htm
Email - paula.mckinney@tdh.state.tx.us

Handbook of Chemical Hazard Analysis Procedures
Federal Emergency Management Agency
Publications Office
500 C. Street, S.W.
Washington, D.C. 20472

Hazardous Materials Emergency Planning Guide March 1987
NRT-1
National Response Team
G-WER/12,2100 2nd Street SW,
Washington, D.C. 20593

FEDERAL INTERNET PLANNING RESOURCES

The National Response Team maintains a web-site with more than just planning information. The National Response Team and the federal family have developed products and publications that you can access here: www.nrt.org.
Link to EPCRA Regulations http://www.epa.gov/docs/epacfr40/chapt-I.info/subch-J/

The EPA's Chemical Prevention and Preparedness Office maintains a site at http://www.epa.gov/ceppo/

Information about CAMEO training can be found at http://www.epa.gov/swercepp/pubs/camtrain/camtrain.htm

FACILITIES AND EMERGENCY PLANNERS

The LEPCs somehow have to identify facilities subject to emergency planning requirements, but there is still widespread non-compliance with EPCRA reporting requirements nationwide. Estimates of facility non-compliance range from 30 to 50 to 70% non-compliance. Part of the problem is the widespread lack of information about the law and its requirements. LEPCs also may not have the resources, or a good concept of the methodology, to find noncompliant facilities.

For those facilities in compliance or wanting to learn more, written publications are available.

Facility Coordinator's Role and the LEPC
Student Manual April 1992
Emergency Management Institute
National Emergency Training Center
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Title III List of Lists
Consolidated List of Chemicals Subject to the Emergency Planning and
Community Right-To-Know Act (EPCRA) and Section 112(r) of the Clean Air Act, as Amended
United States Environmental Protection Agency
Office of Solid Waste and Emergency Response
November 1998
www.epa.gov/ceppo

Facilities should also be advised to call the EPCRA Hotline. Anyone can call the Hotline -- it offers information to a broad audience of callers with diverse backgrounds and varying degrees of regulatory knowledge. To speak with Information Specialists about regulatory questions or to order documents, call:

(800) 424-9346 or DC Area Local (703) 412-9810 or TDD (800) 553-7672 or TDD DC Area Local (703) 412-3323

(Some of the EPCRA Hotline's Information and the Guide to EPA's Electronic Resources are available on the Internet at: http://www.epa.gov/epaoswer/hotline/netguide.htm)

TRAINING PROGRAMS FOR LOCAL EMERGENCY RESPONSE AND MEDICAL PERSONNEL

Chronically short of resources, LEPCs AND SERCs often find themselves mostly focusing on trying to arrange emergency responder and medical personnel training.

There may be other issues involved if the specialized training or equipment needed for a new chemical process in the community puts a sudden or large financial burden on the emergency response infrastructure. Some communities believe that facilities creating the extra financial burden for effective chemical emergency preparedness should pay for the extra burden. Others may expect the taxpayers to pay. There might not be the fire department budget to adequately purchase the needed protective gear for firefighters or the specialized equipment needed. 85% of all fire departments are volunteer. These issues are political and priority decisions for the community.

ARRANGING EMERGENCY RESPONDER TRAINING

Much of the efforts of emergency planners are to arrange for training of emergency responders. Emergency planners will be asked by firefighters and fire departments about available training, and sometimes have to coordinate training for emergency and first responders. Since 85% of firefighters are volunteer firefighters, FREE training can be very useful and a life-saver.

IAFF

The International Association of Fire Fighters (IAFF) offers free training, Go to the association's homepage at http://www.IAFF.org and click on HAZMAT, or just click on http://www.iaff.org/iaff/HAZMAT/hazmat.html.

The IAFF provides training by firefighters for firefighters, more or less peer training. Much of this is funded by grants from NIOSH (60%), EPA (18%) DOE (14%) and DOT (8%). The training is federally funded and FREE.

IAFF has produced 17 training programs to date, including all levels of training required by the Occupational Safety and Health regulations, and even some "Special Hazard" programs. The program components include texts, 35mm slides, videos, transparencies, handouts, and more. Since 1991, IAFF has directly trained over 20,000. Another 700,000 have been indirectly trained using IAFF materials.

IAFF's training is "defensive," not "offensive. It is designed to protect the health and safety of emergency responders and firefighters dealing with chemical emergencies. It involves the integration of safety principles designed at protecting health, first responder operations, and defensive skills.

IAFF's training uses direct training and instructor training, and course distribution, all free of charge.

The IAFF uses the Internet to advance its training. Case studies have been posted there, and course updates can actually be downloaded and inserted into courses that have been previously supplied, updating the older curricula. There is also refresher training available. A multimedia approach is used now also, including CD-ROMs and Powerpoint Presentations.

The future directions of IAFF's training include course updates, first responder awareness, and technician level training. Domestic Preparedness (Weapons of Mass destruction/Terrorism) training is also being prepared.

IAFF wants to expand its direct training, and has a special Recruit Training Initiative to train new firefighter recruits early in their careers. This IAFF training is FREE, and provides 24 contact hours of a highly informative and interactive training program. It provides basic defensive skills in HazMat operations, and exceeds the requirements of OSHA 1910.120 and NFPA 472 standards. This Recruit Training Initiative includes the provision of two top-quality instructors who have received extensive training in all aspects of Hazardous Materials Training for First Responders curriculum; and includes all the materials (text, slides, videos) needed for the training program at no cost to the sponsoring department. Up-to-date, revised, materials are sent every two years. The package includes field-tested pre and post course exams. This course strongly emphasizes health and safety principles for firefighters and paramedics.

Other programs offered by IAFF are Confined Space and EMS.

State of Oregon-Sponsored Website: www.hmep.com

The state of Oregon has created a website with the information, knowledge, and training to meet the needs of HMEP grantees. This web site is being developed and funded as a 'grass roots' effort by the State of Oregon's Local Emergency Planning Committee (LEPC). The intent is to provide HAZWOPER training and information for all states currently receiving funds under HMEP. The site invites planning professionals to review the site and email comments and suggestions and help them make this site more responsive to the needs of planning professionals.

The site provides: Training: Online Course/Examinations and a Catalog of training materials. Regulations: The latest up-to-date OSHA, NFPA, DOT, and EPA regulations. Important Links: Links to FEMA/HMEP and other important web sites for information critical to safety personnel.

Discussions for Professional Planners: Join a discussion group and interact with instructors, industry experts and other HAZWOPER personnel. Opportunities to Download: Download free courseware and other information, including MSDSs and Worker Right-To-Know materials. HAZOPS Refresher Training Certification: Refresher training and testing for Hazardous Materials Operations Level, NFPA 472 and 29 CFR 1910.120(q)8.

This site even allows training and training administration in its databases. The site's HAZMAT Operations Level Refresher course and competency test meets 29CFR 1910.120(q)8 and the NFPA 472 Standard (Operations Level).

Administrators can direct their students to this website, which will train and quiz the students at their convenience, and keep a record for the administrators. Access to the course and the test results are provided via an authorized login/password. There are plenty of quizzes. The website can quiz and re-quiz the same student on the same module, scrambling the questions and answers so that the only way to actually pass the quiz is to understand the material. The script even has voice support--it reads to you. The site offers twelve modules and a comprehensive final exam. Each examination is unique, with questions drawn randomly from an Operations Level Question Database.

This training and administrative tracking is quite a useful service, especially for resource-poor LEPCs and volunteer firefighter organizations in frontier and rural areas. Time spent on the road to a distant training can now be spent at an Internet site, available 24 hours a day. Firefighters can refresh their training while at the station waiting for a call. If they must close out and respond, the site will save their work where they left off.

The website address is: www.hmep.com

National Fire Academy Website

The National Fire Academy maintains a website on the FEMA site at http://www.usfa.fema.gov/nfa/

Through its courses and programs, the National Fire Academy (NFA) works to enhance the ability of fire and emergency services and allied professionals to deal more effectively with fire and related emergencies. The Academy's delivery system is diverse. Courses are delivered at the resident facility in Emmitsburg, Maryland, and throughout the Nation in cooperation with State and local fire training organizations and local colleges and universities.

ARRANGING MEDICAL PERSONNEL TRAINING

Getting the requisite health and hospital representation on an LEPC is a good first step, but there must be extensive follow-though work to make sure that the medical community has the resources, and the back-up, to handle a large-scale chemical accident or disaster. The plume from a chemical spill or fire involving chemicals can force the evacuation of the hospital or facilities needed to handle the injured. Some chemicals require specific antidotes, and the time to start procuring these antidotes is not when the accident has occurred. Burns, even chemical burns, require specialized treatment. Effective planners must take steps to assure that there will be adequate treatment facilities, i.e. enough beds and medicine, to handle a large-scale chemical accident.

There are some very helpful publications regarding these issues:

Hazardous Materials Workshop for Hospital Staff
Emergency Management Institute
Instructor Guide
July 1993
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

Managing Hazardous Materials Incidents
A Planning Guide for the Management of Contaminated Patients
Volume I Emergency Medical Services
Volume II Hospital Emergency Departments
Volume III Medical Management Guidelines for Acute Chemical Exposures
Agency for Toxic Substances and Disease Registry
Division of Toxicology
Emergency Response and Scientific Assessment Branch (E57)
1600 Clifton Road, N.E.
Atlanta, Georgia 30333
(404) 639-6360

Hospital Emergency Department Management of Radiation Accidents
Emergency Management Institute
National Emergency Training Center
Student Manual 1984
16825 South Seton Avenue
Emmitsburg, Maryland 21727
(301) 447-1282

ENFORCEMENT

Any SERC or LEPC may bring civil suit against an owner or operator of a facility for failure to provide Tier Two information or for failure to provide emergency planning information needed for regional emergency plans. A SERC or LEPC may have options under state or county law independent of federal law, if these laws have been passed in their locality. Some states have not provided local enforcement power to their LEPCs and SERCs. EPA can be asked to enforce the emergency planning laws, but some EPA regions are more proactive in this regards than others.

OTHER SERC DUTIES AND POWERS

SERCs may make decisions to designate additional facilities that must report under EPCRA, after proper public notice and opportunity for comment. If this happens, though, it is the responsibility of the SERC (or the Governor) to notify the facilities of the new requirements. An example of this would be to expand the emergency planning requirements of EHS facilities to those that have non-EHS chemicals.

Owners and operators of facilities with EHS chemicals at or above the threshold planning quantity (TPQ) were required to notify the SERC of jurisdiction that the facility has these EHS chemicals no later than mid-1987. After that, the owner or operator of any new facility with EHS chemicals at or above the TPQ, or of an established facility that begins having EHS chemicals above the TPQ, the notification that these EHS are there must be submitted to the SERC within 60 days.

The SERC must pass on this EHS facilities information to the EPA, even additional those facilities required under expanded state law EPCRA reporting requirements.

COMMUNICATING RISK

Studies of LEPCs have shown they are not very good at communicating risk to their communities. The Clean Air Act Amendments, Section 112r, the Risk Management Plan (RMP) was passed by Congress in part to address this. [LINK TO Clean Air Act 112 R notification section]

LEPCs will be provided the RMPs filed by facilities, but the funding to incorporate these RMPs into the tasks of the LEPCs is not being proportionately provided, if at all.

RMP Audit Guidance -
This 94 page guidance document is written for EPA, State and local officials who will be auditing facility RMPs for compliance with 112(r) of the Clean Air Act. Industry representatives may find the check list at the back of the document particularly helpful should their facility be slated for an audit in the future. It is available at http://www.epa.gov/ceppo/pubs/audit_gd.pdf

EPCRA and OSHA Linked

OSHA's relatively new directive CPL 2-2.59A (http://www.osha-slc.gov/OshDoc/Directive_data/CPL_2-2_59A.html) along with its news release (http://www.osha.gov/media/oshnews/apr98/osha98163.html) specifically instructs its inspectors to verify if the employer/owner/operator has reported their EPCRA reportable hazardous materials AND coordinated its emergency action plan with the local fire department having jurisdiction.

The OSHA inspector will ask the employer if the facility has EPA reportable quantities of hazardous substances, and, if they do, whether the facility notified the LEPC of the hazardous substances. The OSHA inspector will also ask the employer if the facility has experienced any chemical releases in excess of reportable quantities, and will ask the employer for information regarding the facility's emissions inventory. This information would establish the quantities and types of hazardous substances at a facility and provide documentation through EPA's reporting requirements. The OSHA inspectors are instructed to make referrals, as appropriate, in writing to the EPA Regional Office.