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HomeMy WebLinkAboutMINUTES - 07261994 - H.2 � • I H. 2 TO: BOARD OF SUPERVISORS FROM: Mark Finucane, Health Services Director J ;. Contra "I Costa DATE: July 26, 1994 T County SUBJECT: The General Chemical Incident:One Year Later. Status Report from the Health Services Department on Follow-Up to the Incident SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATION: ACCEPT the attached report from the Director of the Health Services Department regarding follow- up activities in the wake of the General Chemical Corporation's accidental hazardous materials release incident that occurred on July 26, 1993. BACKGROUND: The General Chemical Corporation facility in Richmond accidently released sodium trioxide into the surrounding community on July 26, 1993. There is continuing concern that similar incidents could occur again, either in West County or in other industrialized areas of Contra Costa. That concern has galvanized the efforts of the Health Services Department; state legislators and local elected officials; the Community Awareness and Emergency Response (CAER) organization; more than a dozen federal, state and local agencies; environmentalists and community members in a renewed push to prevent accidental releases from occurring in the future, and to reduce the human health impact should accidental releases indeed occur. The attached report summarizes the status of the follow-up efforts to the incident on the anniversary date of the event. Steady progress has been made in responding to the General Chemical incident during this past year. The Center for Health in North Richmond, an expanded Community Notification System, and greater commitment to interagency coordination are hallmarks of the follow-up effort. Each of these efforts are significant benefits to Contra Costa as a whole, and North Richmond in particular. The report indicates that once coupled with effective legislation expanding the worker and community safety roles of Risk Management and Prevention Plans (RMPPs), the Health Services Department believes that the County's two primary goals, prevention of accidental releases and effective notification in the event of an emergency, will be promoted. FISCAL IMPACT: None CONTINUED ON ATTACHMENT: NO SIGNATURE " µ----� RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE _OTHER SIGNATURE(S): ACTION OF BOARD ON July 26 , 1994 APPROVED AS RECOMMENDED X OTHER X In addition to the above recommendation, IT IS BY THE BOARD ORDEREDthat a letter to Congressman George Miller transmitting the General Chemical Incident: One Year Later report and the Hazardous Materials Inter- agency Task Force Summary_.is AUTHORIZED. VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE UNANIMOUS (ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN. Contact Person: CC: ATTESTED July 26 , 1994 PHIL BATCHELOR, CLERK OF THE BOARD OF SUPERVISORS AND C NTY ADMINISTRATOR J BY DEPUTY 0.2. Contra Costa County The Board of Supervisors HEALTH SERVICES DEPARTMENT OFFICE OF THE DIRECTOR Tom Powers, 1st District Jeff Smith,2nd District a�...s,•;.-c_ o Mark Finucane, Director Gayle Bishop,3rd District '" == 20 Allen Street Sunne Wright McPeak,4th District . Martinez, Cw;ifornia 94553-3191 Tom Torlakson,5th District (510)370-5003 o: w County Administrator "a,- �• :: 's FAX(510)370-5098 �;•., .oma •�4 Phil Batchelor r°sya.�oUµ County Administrator July 26, 1994 To: Board of Sup rvisors From: Mark Finuc e Director, Health Services Department William Walker, MD G ,�JIL,14 Health Officer Subject: The General Chemical Incident: One Year Later. Status Report from the Health Services Department on Follow-Up to the Incident. Executive Summary Steady progress has been made in responding to the General Chemical incident during this past year. If there can be any positive outcome from such a community disaster it will be the gems left in its wake: the Center for Health in North Richmond, an expanded Community Notification System,and greater commitment to interagency coordination. Each of these efforts are significant benefits to Contra Costa as a whole, and North Richmond in particular. Once coupled with effective legislation expanding the worker and community safety roles of Risk Management and Prevention Plans (RMPPs), the Health Services Department believes that the County's two primary goals, prevention of accidental releases and effective notification in the event of an emergency, will be promoted. Background Exactly one year ago today, July 26, 1993, the General Chemical Corporation facility in Richmond accidently released sodium trioxide into the surrounding community. The incident, etched in the memories of the affected community, emergency responders, health care providers, elected officials, and others, was the worst accidental release of hazardous materials in recent county history. Merrithew Memorial Hospital&Clinics Public Health • Mental Health • Substance Abuse Environmental Health Contra Costa Health Plan Emergency Medical Services • Home Health Agency Geriatrics A-345 (2/93) Board of Supervisors General Chemical Incident: One Year Later Page 2 There is continuing concern that similar incidents could occur again, either in West County or in other industrialized areas of Contra Costa. That concern has galvanized the efforts of the Health Services Department; state legislators and local elected officials; the Community Awareness and Emergency Response (CAER) organization; more than a dozen federal, state and local agencies; environmentalists and community members in a renewed push to prevent accidental releases from occurring in the future, and to reduce the human health impact should accidental releases indeed occur. This report will summarize the status of these efforts to date. In sum, substantial progress has been made in the areas of community-based health services, community notification of emergency events, and coordination of interagency activities. However,while Health Services Department staff have been working diligently at Board direction to improve state law to prevent similar management, the core elements of proposed legislation (introduced by Assemblymembers Campbell, Bates and others) have not survived the legislative process, thus far. Community-Based Health Services The Center for Health in North Richmond, which has long been a dream of the Health Services Department and the community, is becoming a reality. In a settlement agreement reached between the County and the General Chemical Corporation, $800,000 are dedicated to the development fixed and mobile community health services. To date, the following has been accomplished: ♦ An eleven member Advisory Board has been appointed. All of the Advisory Board members live or work in North Richmond or the broader catchment area. The full Advisory Board has met twice and will continue monthly meetings. In addition, four committees have been established: Community Priorities, Site Selection, Architect Selection, and By-Laws, which will meet between full board meetings. ♦ Community priorities for the center are being investigated. Surveys will be distributed to key community informants such as homeowners and tenants associations, ethnic associations, senior and teen groups, women's clubs, and others. In addition, survey results from other health and community intervention efforts will be analyzed to inform the Advisory Board which issues should be prioritized by the Center for Health. ♦ The site selection process is in its initial stages. Committee members have toured potential locations, investigation into title ownership and other legal issues has begun, and the criteria for site selection are being finalized. Board of Supervisors General Chemical Incident: One Year Later Page 3 ♦ The architect selection process is nearing completion. At the time of writing this report, the Architect Selection Committee has met with a highly qualified architect and is recommending her approval to the full Advisory Board. The proposed candidate has designed several health centers throughout California and has published articles on the subject of ensuring community and client focused health center design. ♦ In addition, partially in response to the creative use of settlement funds to develop the Center for Health in North Richmond, and partially due to other efforts spanning several years, Dr. Wendel Brunner, Director of Public Health, has been appointed to the National Environmental Justice Advisory Board of the National Association for the Advancement of Colored People. The Health Services Department applauds the work of Dr. Brunner, and believes that his work reflects favorably on the commitment to environmental justice issues shared by the entire department. ♦ Finally, Ms. Elinor Blake has been hired as the Executive Assistant to the Hazardous Materials Commission. Ms. Blake brings with her a long track record of continuous commitment to community health and well-being. In her most recent appointment with the State Health Services Department, she spearheaded the effort to include an in-depth report on environmental justice issues and priorities in the California Comparative Risk Project report soon to be released. The report is intended to guide the State in developing hazardous materials programs and responses. Community Notification of Emergency Events The Health Services Department and the Office of Emergency Services have been intimately involved in expanding existing emergency notification services. At the time of the General Chemical incident, the Community Alert Network (CAN), a telephone call-down system, was in place and operational. It was used during the General Chemical incident and was largely effective to the extent that the system had phone line capability and access to telephone numbers. Note that the line capability of the system has doubled since the General Chemical incident and we hope that unlisted numbers, which currently are not part of the system, will be added in the future. However, the severity of the General Chemical incident focused the mission of the Health Services Department, the Office of Emergency Services, CAER and others to speed the development of the community alert system and enhance current community notification capability for chemical and other community emergencies. To that end, the following has occurred: Board of Supervisors General Chemical Incident: One Year Later Page 4 ♦ Appointment is complete of a Community Notification Advisory Board comprised of agency staff, industrial representatives and members of the community. This Advisory Board has hired a Project Manager who will oversee all aspects of the project's development. ♦ Commitment is secured to install warning sirens throughout the industrialized areas of Contra Costa. The development of a plan and process for siting the sirens is being finalized and the hiring of the engineering firm to install the sirens and other components of the notification system is underway. The sirens will sound for a one mile radius around a facility experiencing an emergency incident and are expected to be in place by the end of 1995. The installation of the sirens is Phase I of the project, and is being funded by industries located in all segments of the industrialized areas. The full cost for Phase I is expected to be close to $5 million. The on-going maintenance of the siren system will be paid for by the County and is expected to cost approximately $80,000 per year. ♦ A multi-lingual public education program is being developed. The program will be target the entire county and will be implemented through schools, neighborhoods, community groups and organizations, and through the media and other arenas of public contact. The initial educational campaign about all aspects of the community notification program will be funded under the Phase I financial commitment made by industry. Funding for the on-going public education under Phase II of the project is yet to be determined. ♦ Negotiations with Pacific Bell Telephone Company are underway on two items: (1) to print "shelter-in-place" instructions in the telephone books; and (2) to obtain unlisted telephone numbers at an affordable price to enhance the effectiveness of the CAN system. The Health Services Department will keep contact with the Board and other interested parties as these negotiations develop. Coordination of Interagency Activities Prior to the General Chemical incident, the Health Services Department had spearheaded the development of the Hazardous Materials Interagency Task Force (HIT). HIT's role to coordinate activities among emergency response and inspection agencies proved to be invaluable during and after the General Chemical emergency. Response agencies met daily to share information, compare results of investigations, and strategize on the most effective and comprehensive ways to respond in the short and long-term to the event. Each agency commented on the important role HIT played in shaping the government's response to the event,the enforcement efforts, and the settlement agreements. Board of Supervisors General Chemical Incident: One Year Later Page 5 Shortly after the General Chemical incident, Congressmember George Miller held a hearing of the Subcommittee on Oversight and Investigations of the House Natural Resources Committee. The hearing disclosed many aspects of the incident, and encouraged HIT to develop a summary report of each agency's post-event recommendations and testimony provided by key community organizations. This report will be forwarded to Congressmember Miller and the Board of Supervisors as soon as it is finalized. Congressmember Miller's staff has assured HIT that the Congressmember will promote the regulatory changes called for in the summary report in the appropriate Congressional arenas. Similar to the development of HIT,the Health Services Department has also initiated an "inter-industry" coordination effort. In conjunction with the County Administrator, the department convened more than 30 industrial leaders from the major industries throughout the county. The focus of the meeting was to recommend strongly that industry do more to prevent the occurrence of chemical accidents. They were encouraged to use a quality assurance/quality control model as developed in hospital systems to provide peer review and evaluation of chemical incidents and safety activities. A small group of industry leaders has continued to meet and is developing the guidelines for such a peer review effort. Cooperation on Legislative Efforts to Prevent Chemical Accidents Assemblymembers Campbell and Bates have each introduced important legislation to reform existing law in order to prevent accidental chemical releases. All of this legislation was endorsed and/or sponsored by the Board of Supervisors. The RMPP staff and the Executive Assistant to the Hazardous Materials Commission have worked diligently with Assembly staffpersons, the State of California Office of Emergency Services, the county lobbyist, and others to develop and promote the passage of this legislation. Unfortunately, key goals of the proposed legislation as originally proposed do not seem to successful at this time. From the perspective of the Health Services Department, the following issues should be addressed in legislation: ♦ Require advanced notification of RMPP staff prior to initiating changes that could affect the Off-Site Consequence Analysis of a facility as delineated in the facility's RMPP; ♦ Require "Management of Change" (MOC) operations for any significant change at a facility that could impact worker or community health and safety; Board of Supervisors General Chemical Incident: One Year Later Page 6 ♦ Fund the State of California Office of Emergency Services (OES) or the California Environmental Protection Agency to develop and implement regulations for RMPPs based on the guidance documents prepared by the Contra Costa County Health Services Department; ♦ Require the implementation of these regulations by Administrating Agencies (AAs) throughout the state, or give OES implementation capability if AAs fail to implement the regulations; ♦ Promote broad community awareness of RMPPs by requiring a public review, public meetings and public comment periods (with written responses for each comment to an RMPP) during the review of an RMPP. Although no piece of legislation or strict agency enforcement of regulations can guarantee prevention of chemical accidents, the Health Services Department believes that if these basic issues were to be adequately addressed in legislation and followed by industry, events like the General Chemical incident largely could be avoided. Certainly, the incident at General Chemical may have been prevented if pre-notification and MOC guidelines had been followed. The department is committed to continuing work with local legislators on these issues of state-wide importance. In addition, staff is following the development of RMPP regulations at the federal level. The department hopes to influence that legislation to promote prevention and public participation, and to ensure agency implementation of the regulations. N r Z ?Lv� = Contra Costa County T •• The Board of Supervisors HEALTH SERVICES DEPARTMENT OFFICE OF THE DIRECTOR Tom Powers,1st District Mark Finucane,Director Jeff Smith,2nd District } _ 20 Allen Street Gayle Bishop,3rd District Senna Wright McPaak,4th District j '.� Martinez,C;dornia 94553-3191 Tom Torlakson,5th District (510)370-5003 FAx(510)370-5098 County Administrator Phil Batchelor r; County Administrator July 26, 1994 To: Board of Sup rvisors From: Mark Finu � Director, Health Services Department William Walker, MD G,,,,, ii �'u"`•/`� Health Officer Subject: The General Chemical Incident: One Year Later. Status Report from the Health Services Department on Follow-Up to the Incident. Executive Summary Steady progress has been made in responding to the General Chemical incident during this past year. If there can be any positive outcome from such a community disaster it will be the gems left in its wake: the Center for Health in North Richmond, an expanded Community Notification System,and greater commitment to interagency coordination. Each of these efforts are significant benefits to Contra Costa as a whole, and North Richmond in particular. Once coupled with effective legislation expanding the worker and community safety roles of Risk Management and Prevention Plans (RMPPs), the Health Services Department believes that the County's two primary goals,prevention of accidental releases and effective notification in the event of an emergency, will be promoted. Background Exactly one year ago today,July 26, 1993,the General Chemical Corporation facility in Richmond accidently released sodium trioxide into the surrounding community. The incident, etched in the memories of the affected community, emergency responders,health care providers, elected officials, and others,was the worst accidental release of hazardous materials in recent county history. MemtMw Memorial Mowat M Cwn= Pubic Health • M er+a,Heero+ • substance Abuse • EnvtmrvrWal Health Contra Cosa Health Pan • Emergency M"=f Serves • Morn.health Agency • C.enatnes A345 (2193) Board of Supervisors T General Chemical Incident: One Year Later Page 2 There is continuing concern that similar incidents could occur again, either in West County or in other industrialized areas of Contra Costa. That concern has galvanized the efforts of the Health Services Department; state legislators and local elected officials; the Community Awareness and Emergency Response (CAER) organization; more than a dozen federal, state and local agencies; environmentalists and community members in a renewed push to prevent accidental releases from occurring in the future, and to reduce the human health impact should accidental releases indeed occur. This report will summarize the status of these efforts to date. In sum, substantial progress has been made in the areas of community-based health services, community notification of emergency events, and coordination of interagency activities. However,while Health Services Department staff have been working diligently at Board direction to improve state law to prevent similar management,the core elements of proposed legislation (introduced by Assemblymembers Campbell, Bates and others) have not survived the legislative process, thus far. Community-Based Health Services The Center for Health in North Richmond, which has long been a dream of community residents and advocates as well as the Health Services Department, is becoming a reality. In a settlement agreement reached between the County and the General Chemical Corporation, $800,000 will be dedicated to the development fixed and mobile community health services. To date, the following has been accomplished: ♦ An eleven member Advisory Board has been appointed. The Advisory Board, which began meeting in June, will continue monthly meetings. In addition, four ad hoc committees have been established: Community Priorities, Site Selection, Architect Selection, and By-Laws. The committees are meeting between full board meetings. ♦ The community priorities committee is reviewing survey results from other health and community intervention efforts and will be making recommendations to the full Advisory Board on additional community priority-setting efforts that may be needed. ♦ The site selection process is in its initial stages. Committee members have toured potential locations. Investigation into title ownership and other legal issues has begun. And, the criteria for site selection are being finalized. Board of Supervisors General Chemical Incident: One Year Later Page 3 ♦ The selection of the architect is in process. ♦ In addition, partially in response to the creative use of settlement funds to develop the Center for Health in North Richmond, and partially due to other efforts spanning several years, Dr. Wendel Brunner, Director of Public Health, has been appointed to the National Environmental Justice Advisory Board of the National Association for the Advancement of Colored People. The Health Services Department applauds the work of Dr. Brunner, and believes that his work reflects favorably on the commitment to environmental justice issues shared by the entire department. o Finally, Ms. Elinor Blake has been hired as the Executive Assistant to the Hazardous Materials Commission. Ms. Blake brings with her a long track record of continuous commitment to community health and well-being. In her most recent appointment with the State Health Services Department, she spearheaded the effort to include an in-depth report on environmental justice issues and priorities in the California Comparative Risk Project report soon to be released. The report is intended to guide the State in developing hazardous materials programs and responses. Community Notification of Emergency Events The Health Services Department and the Office of Emergency Services have been intimately involved in expanding existing emergency notification services. At the time of the General Chemical incident, the Community Alert Network (CAN), a telephone call-down system,was in place and operational. It was used during the General Chemical incident and was largely effective to the extent that the system had phone line capability and access to telephone numbers. Note that the line capability of the system has doubled since the General Chemical incident and we hope that unlisted numbers,which currently are not part of the system, will be added in the future. However, the severity of the General Chemical incident focused the mission of the Health Services Department, the Office of Emergency Services, CAER and others to speed the development of the community alert system and enhance current community notification capability for chemical and other community emergencies. To that end, the following has occurred: o Appointment is complete of a Community Notification Advisory Board comprised of agency staff, industrial representatives and members of the community. This Advisory Board has hired a Project Manager who will oversee all aspects of the project's development. 1 Board of Supervisors General Chemical Incident: One Year Later Page 4 ♦ Commitment is secured to install warning sirens throughout the industrialized areas of Contra Costa. The development of a plan and process for siting the sirens is being finalized and the hiring of the engineering firm to install the sirens and other components of the notification system is underway. The sirens will sound for a one mile radius around a facility experiencing an emergency incident and are expected to be in place by the end of 1995. The installation of the sirens is Phase I of the project, and is being funded by industries located in all segments of the industrialized areas. The full cost for Phase I is expected to be close to $5 million. The on-going maintenance of the siren system will be paid for by the County and is expected to cost approximately $80,000 per year. ♦ A multi-lingual public education program is being developed. The program will be target the entire county and will be implemented through schools, neighborhoods, community groups and organizations, and through the media and other arenas of public contact. The initial educational campaign about all aspects of the community notification program will be funded under the Phase I financial commitment made by industry. Funding for the on-going public education under Phase II of the project is yet to be determined. ♦ Negotiations with Pacific Bell Telephone Company are underway on two items: (1) to print "shelter-in-place" instructions in the telephone books; and (2) to obtain unlisted telephone numbers at an affordable price to enhance the effectiveness of the CAN system. The Health Services Department will keep contact with the Board and other interested parties as these negotiations develop. Coordination of Interagency Activities Prior to the General Chemical incident, the Health Services Department had spearheaded the development of the Hazardous Materials Interagency Task Force (HIT). HIT's role to coordinate activities among emergency response and inspection agencies proved to be invaluable during and after the General Chemical emergency. Response agencies met daily to share information, compare results of investigations, and strategize on the most effective and comprehensive ways to respond in the short and long-term to the event. Each agency commented on the important role HIT played in shaping the government's response to the event,the enforcement efforts,and the settlement agreements. Shortly after the General Chemical incident, Congressmember George Miller held a hearing of the Subcommittee on Oversight and Investigations of the House Natural Resources Committee. The hearing disclosed many aspects of the incident, and encouraged HIT to develop a summary report of each agency's post-event recommendations and Board of Supervisors General Chemical Incident: One Year Later Page 5 testimony provided by key community organizations. This report will be forwarded to Congressmember Miller and the Board of Supervisors as soon as it is finalized. Congressmember Miller's staff has assured HIT that the Congressmember will promote the regulatory changes called for in the summary report in the appropriate Congressional arenas. Similar to the development of HIT,the Health Services Department has also initiated an "inter-industry" coordination effort. In conjunction with the County Administrator, the department convened more than 30 industrial leaders from the major industries throughout the county. The focus of the meeting was to recommend strongly that industry do more to prevent the occurrence of chemical accidents. They were encouraged to use a quality assurance/quality control model as developed in hospital systems to provide peer review and evaluation of chemical incidents and safety activities. A small group of industry leaders has continued to meet and is developing the guidelines for such a peer review effort. Cooperation on Legislative Efforts to Prevent Chemical Accidents Assemblymembers Campbell and Bates have each introduced important legislation to reform existing law in order to prevent accidental chemical releases. All of this legislation was endorsed and/or sponsored by the Board of Supervisors. The RMPP staff and the Executive Assistant to the Hazardous Materials Commission have worked diligently with Assembly staffpersons,the State of California Office of Emergency Services, the county lobbyist, and others to develop and promote the passage of this legislation. Unfortunately, key goals of the proposed legislation as originally proposed do not seem to successful at this. time. From the perspective of the Health Services Department, the following issues should be addressed in legislation: ♦ Require advanced notification of RMPP staff prior to initiating changes that could affect the Off-Site Consequence Analysis of a facility as delineated in the facility's RMPP; ♦ Require "Management of Change" (MOC) operations for any significant change at a facility that could impact worker or community health and safety; ♦ Fund the State of California Office of Emergency Services (OES) or the California Environmental Protection Agency to develop and implement regulations for RMPPs based on the guidance documents prepared by the Contra Costa County Health Services Department; t Board of Supervisors General Chemical Incident: One Year Later Page 6 ♦ Require the implementation of these regulations by Administrating Agencies (AAs) throughout the state,or give OES implementation capability if AAs fail to implement the regulations; ♦ Promote broad community awareness of RMPPs by requiring a public review, public meetings and public comment periods (with written responses for each comment to an RMPP) during the review of an RMPP. Although no piece of legislation or strict agency enforcement of regulations can guarantee prevention of chemical accidents, the Health Services Department believes that if these basic issues were to be adequately addressed in legislation and followed by industry, events like the General Chemical incident largely could be avoided. Certainly, the incident at General Chemical may have been prevented if pre-notification and MOC guidelines had been followed. The department is committed to continuing work with local legislators on these issues of state-wide importance. In addition, staff is following the development of RMPP regulations at the federal level. The department hopes to influence that legislation to promote prevention and public participation, and to ensure agency implementation of the regulations. DATE: I-Co, L 9 4 REQUEST TO SPEAK FORM (THREE (3) MINUTE LIMIT) Complete this form and place it in the box near the speakers' rostrum before addressing the Board. NAME: PHONE: /!T(C> 8-VES-2381 ADDRESS: CITY: I am speaking formyself OR organization: (����-ti s ' � ` •-- � .: . Check one: (NAME OF ORGANI/.ATION) ( I wish to speak on Agenda Item # -2- My My comments will be: general for against I wish to speak on the subject of I do not wish to speak but leave these comments for the Board to consider. Hazardous Materials Interagency Task Force Railroad Safety in the 1990's Summary of Railroad Safety Policy Issues to be Addressed at the Federal Level July 26, 1994 Executive Summary It is rare for a single event to serve as a turning point for new regulatory action, but the General Chemical incident of July 26, 1993 in Richmond, California is such an event. The General Chemical incident, which sent fuming sulphur trioxide into residential neighborhoods, was the worst incident in recent history in Contra Costa County, California, one of the most industrialized communities in the most populous state in the country. Approximately 24,000 individuals sought medical care. One year later, it serves as an excellent case study to evaluate the effectiveness of federal, state and local regulations in preventing and managing hazardous materials incidents in railcars. Several reports have documented the health and safety concerns raised by the General Chemical incident. Investigations by federal, state and local government agencies; and hearings conducted by Congressmember George Miller and Assemblymembers Campbell and Bates have lead to a series of recommendations regarding railcar safety. This report is a compilation of the insights, findings and recommendations made by several investigating bodies and adopted by the Contra Costa County Hazardous Materials Interagency Task Force (HIT).' This report augments the many diligent efforts to introduce and pass prevention-oriented legislation by the entire Contra Costa legislative delegation. I HIT is comprised of the following agencies: Contra Costa County Health Services Department; Bay Area Air Quality Management District; Regional Water Quality Control Board; California Environmental Protection Agency - Department of Toxic Substances Control; Office of the State Fire Marshall; California Occupational Safety and Health Administration; California State Lands Commission; California Department of Fish and Game; United States Coast Guard; and frequently the United States Environmental Protection Agency. Railroad Safety Recommendations Executive Summary - Page 1 To local enforcement officials, the General Chemical incident does not seem unique, nor unforeseeable. In many ways is seems a predictable outcome to a regulatory scheme that relies heavily on self-regulation by industry; responds in an often piecemeal fashion to safety issues after problems occur; under-funds government inspection and surveillance programs; and disperses ultimate responsibility among several agencies without coordination, communication or accountability. These problems likely are at the core of railcar incidents in California and throughout the United States. Until there is regulatory reform, such incidences will continue to occur. Many gaps in federal, state and local regulations are clearly evident from the investigations, hearings and reports following the General Chemical incident. .While the post-incident follow-up activities focused on the specific health and safety problems associated with this specific leak, it is evident that rail safety problems are in many ways generic - the problems affect rail safety nation-wide. All of the HIT agencies were intimately involved in responding to the General Chemical incident. While most of the agencies are not experts in railroad safety issues, the experience of managing the General Chemical emergency raised many collective concerns about a myriad of railroad safety issues in this country. This report reflects the collective wisdom of many hours of debriefing the incident by responding agencies and members of the community. Not every agency concurs with every recommendation identified in this report, however each recommendation represents a concern of a majority of the HIT agencies. The HIT agencies acknowledge that additional experts in railroad safety issues likely will identify both answers to some of the concerns presented in this report, or critical issues that have been missed by the agency representatives active in HIT. Nonetheless, this report is an accurate reflection of the experience of local enforcement agencies dealing with a major railroad incident that caused serious health problems for thousands of people. The power of this collective experience should not be overlooked due to inadvertent technical inaccuracies. HIT hopes this report is received in this light by Congressional and agency fact-finders, and others. Organization of this Document This document is organized by the following categories: Health, Environmental Justice, Planning, Enforcement, Public Participation, Notification, Risk Management/Assessment, Training, Safety, Storage, Tank Car Design, Data Management. In addition, several agencies have finalized reports of investigations on the General Chemical incident; a bibliography of those reports are included at the end of this document for further information and documentation. The bibliography also includes a list of agencies that are still developing reports on the General Chemical incident. Railroad Safety Recommendations Executive Summary - Page 2 Priority Issues With this background, several priority action areas have been identified that need to be addressed at the federal level: (1) Greater authority is needed at the local level to regulate local health and safety concerns regarding railroads without federal preemption of the regulation and/or enforcement efforts. (2) Federal and state enforcement abilities must be improved with more aggressive regulations, and with greater enforcement personnel at the local level. (3) Regulatory reform efforts should focus initially on the following issues: (a) Augment placarding requirements to include more detail on chemicals such as the specific chemical, appropriate storage conditions, pressure standards, and emergency response protocols. (b) Review the distinctions between the "transportation" and the "storage" of chemicals. Local enforcement agencies have no jurisdiction over the "transportation" of hazardous chemicals even though these chemicals may be located within an agencies' jurisdiction for several days or weeks. (c) Review the standards, frequency and recordkeeping requirements for the training of workers who handle hazardous materials. (4) Increase information sharing and communication between federal and local enforcement agencies during hazardous materials incidences. While the United States Coast Guard should be commended for its excellence as the Federal On Site Coordinator, not all federal agencies were equally as accessible or cooperative. Next Steps and Suggested Follow-up Activities The following action steps are suggested: (1) Call for in-depth investigation into the regulatory structures that govern railroad safety issues. Such an investigation can be conducted by the General Accounting Office or another investigatory arm of Congress. The investigation should focus on the effectiveness of the statutes in preventing accidents; the enforcement role played by the federal and state inspectors; and the appropriate mix of federal, state and local regulation to best address local health and safety needs. Railroad Safety Recommendations Executive Summary - Page 3 (2) Convene railroad experts, both within and out of government, to discuss inter- and intra-agency coordination issues regarding railroad safety from the point of view of worker health and safety; environmental protection; public health protection; and other concerns. (3) Design a more effective fee structure to develop and enforce adequate and effective safety regulations. (4) Develop a system for the federal government to draw upon the expertise of state and local governments which have responded to railroad emergencies. Conclusion Local emergency response agencies are on the front-line of managing hazardous materials incidents that have the potential to negatively affect large segments of the community. The expertise of these agencies, both in light to the General Chemical incident and in light of years of emergency management responsibilities, should inform federal policy makers regarding the potentially deadly hazards facing workers and the public. The HIT agencies hope that this report provides insight and spurs response at the federal level to local needs. For more information about HIT or the contents of this report, please contact William Walker, MD; Contra Costa County Health Officer (510) 370-5012. Bibliography Hazardous Materials Incident. General Chemical Corporation, Federal Railroad Administration, February 22, 1994. Hazardous Materials Accident/Incident Investigation. General Chemical Corporation, Public Utilities Commission, October 22, 1993. Inspection Reports, State of California, Department of Industrial Relations, Division of Occupational Safety and Health. July 26, 1993 - October 15, 1993. July 26th General Chemical Oleum Release, Contra Costa County Health Services Department, August 9, 1993. Living With Risk: Communities & the Hazard of Industrial Contamination, Subcommittee on Oversite and Investigations, Committee on Natural Resources, December 9, 1993. Railroad Safety Recommendations Executive Summary - Page 4 Preliminary CBE Review of Chemical Disaster Prevention Issues Following the Toxic Gas Release from General Chemical, Citizens for a Better Environment, August 10, 1993. Draft Documents (HIT understands that both documents will be released in the near future. Contact the agency directly for more information). Federal On-Scene Coordinator's Report, United States Coast Guard Marine Safety Office, San Francisco Bay, Alameda, California. Report to the Governor on the General Chemical Incident, California Environmental Protection Agency. Railroad Safety Recommendations Executive Summary - Page 5 Hazardous Materials Interagency Task Force Railroad Safety in the 1990's Summary of Railroad Safety Policy Issues to be Addressed at the Federal Level July 26, 1994 Summary..of Recommendations Health 1. Provide a mechanism to study the potential health effects which may result from emergency incidences involving hazardous materials on railroads. 2. Require the United States Envirnmental Protection Agency (EPA) or the Centers for Disease Control (CDC)to establish epidemiologic methodology for evaluation of the health effects,which would assist in developing more information on the long-term effects of acute exposure to chemicals released into the environment after railcar accidents. 3. Develop analytical and sampling procedures for acutely hazardous chemicals that may be released. Provide training on these procedures. 4. Provide resources to facilitate the development of levels of concern for acutely hazardous chemicals that may be released into the air. 5. Devote greater resources to research into the impact of long-term exposure to both permitted and unpermitted releases of hazardous materials. Particular consideration should be given to the health effects on women and children; many affected communities have a high percentage of households headed by women. Environmental Justice 1. Develop guidelines to identify communities with a high potential for excessive exposure to toxic substances. Such communities should be characterized as non-attainment areas, and proposed projects which may deal with hazardous materials could be required to meet a lower level of significant risk. 2. Develop a process to identify multiple simultaneous sources of environmental exposures in low-income and people of color communities. Railroad Safety Recommendations - Page 1 3. Take further steps to prevent, mitigate and redress environmental injustices. Congress should include environmental justice language when it reauthorizes major environmental statutes,including the Comprehensive Environmental Response,Compensation,and Inability Act,' the Resource Conservation and Recovery Act' and the Clean Air Act? However, Congress should not ask EPA and other agencies to carry out environmental justice programs without allocating adequate resources to perform the work. Planning 1. Foster a comprehensive government-wide approach to the management of hazardous materials. Multiple agencies regulate hazardous materials, including EPA, OSHA and the Department of Transportation, and a government-wide coordination strategy is required if risks from hazardous materials and bureaucratic overlap are to be minimized. 2. Federal, state and local governments must similarly work together more closely to streamline accident response and to implement health, safety and environmental protection legislation to eliminate existing loopholes. However, new initiatives should not fragment the regulatory process further or add unreasonable burdens to the operations of industry. 3. Both the states and federal government should allocate additional resources to the approximately 3,800 LEPCs that have been established nationwide, which are critical to effective accident response and community involvement. 4. Propose legislation to adopt or expand the concept of California's Railroad Accident Prevention and Immediate Deployment Force (RAPID)plan to allow for a RAPID response to hazardous materials incidents that occur throughout the states. 5. In the proposed federal RMP regulations, expand the statutory definition of a "modified facility" to include any substantial modification to the number or process uses, and further define "appurtenance". 6. Require revision of all state plans dealing with hazardous materials incident response to be consistent with California's Standardized Emergency Management System (SEMS) and Incident Command System. .7. Create.an ad hoc interagency committee to review, assess, and recommend changes to emergency planning and response efforts at the state and federal levels. 142 U.S.C. §§ 11001-11050 (1988). 2 42 U.S.C. §§ 6901-6992k (1988 & Supp. II 1990) 3 42 U.S.C. §§ 7401-7671q (1988 & Supp. 11 1990). Railroad Safety Recommendations - Page 2 8. Create an interagency committee to provide recommendations to the EPA and the state's Office of Emergency Services (OES) on the development of an effective and equitable statewide mutual aid plan for hazardous materials emergency response. 9. Review all currently ongoing safety reviews of rail cars undertaken by various public agencies. 10. Develop at the Federal level (EPA) standard levels of concern used in determining the concentration of a chemical that could impact the public. 11. In the proposed federal. RMP regulations, Develop standard guidelines for the preparation of off-site consequence analysis. Include the worst credible or the worst case scenario for a chemical release, and the potential impact on surrounding communities. 12. Require states to develop specific deadlines for preparing plans by.facilities, and for agency review of plans submitted under the Risk Management Prevention Program(RMPP) or its equivalent. 13. Require states to adopt federal RMP guidelines once promulgated. These guidelines should serve as a minimum compliance standard. 14. Require development of community evacuation plans for each facility preparing an RMP. 15.Require emergency response agencies at the federal and state levels to establish specific procedures for communicating with the media during an incident. 16. Require facilities to update the RMPs Off-Site Consequence Analysis (OSCA) and the response plans whenever the handling, storage methods, or chemicals deviates from the norm. 17. Impose a user fee on railroads to cover state enforcement agencies' costs of regulating rail safety. 18. Increase state enforcement agency staffing of rail safety inspection positions, with additional funds to be provided by the user fee. 19. Require DOT to reclassify various chemical compounds not presently classified as "hazardous". 20. Create meaningful state-level oversight and accountability for chemical disaster prevention and emergency planning. Railroad Safety Recommendations - Page 3 21. Reorganize the geographic boundaries of the LEPCs so they cover less area and can more effectively discharge their responsibilities of coordinating the activities of the administrating agencies. 22. In the proposed federal RMP regulations, require administering agencies to sufficiently fund their administration of the RMP programs. 23. Require detailed evacuation plans and advanced community education for hazardous materials emergencies. 24. Railcar regulations and the jurisdiction of different agencies should be reviewed, and a report of gaps and solutions provided to the public. 25. Investigate "revolving-door" between the railroad industry and the Federal Railroad Administration. Concern has been expressed that the FRA may be a"captured"agency that either fails to adequately enforce existing railroad regulations or does not develop sufficiently effective regulations. If the latter is true,the enforcment responsibilty delegated to the states would be equally as ineffective. 26. Increase training and funding to improve emergency response activities after transportation accidents involving hazardous materials and wastes. 27.Require states to designate lead agencies for all areas of hazardous materials emergency response to coordinate with federal agencies effectively. 28. Develop inter-agency agreements of jurisdictional boundary lines which delineate the Coast Guard's primary responsibility over discharge and releases into navigable waterways from vessels and waterfront facilities and EPA's responsibility for discharges and releases originating from land side sources. The boundary line should be the coastal shoreline. Such boundaries should be identified for regions of the country which rely on coastal roads, bridges, railways or highways to divide their respective zones. 29. Develop a short-course in hazardous materials emergency response issues for media personnel covering hazardous materials emergencies. The training should cover issues such as: the hazards present on site, the health and safety reasons for limiting media access to decontimination and exlusion areas, etc. Ensure that this training information is distributed to all municipal, county and state agencies and entities that could be involved in a response. Enforcement 1.Augment placarding requirements to include more detail on chemicals such as the specific chemical, appropriate storage conditions, pressure standards, and emergency response protocols. Railroad Safety Recommendations - Page 4 s 2. Clarify how long a hazardous material can be in a rail tank car "in transportation" after which it is considered"stored"at a facility. Consider differing time allowances for hazardous materials with greater toxicity. 3. Provide enhanced penalties for the release of a hazardous material into the environment. In order to assess penalties that reflect the actual seriousness of the violation, penalties should be based on quantitative assessments. 4. In the proposed RMP regulations, require amended RMPs to be submitted at the same time a business-practice is modified with civil and criminal penalties for failure to submit a RMP in a timely fashion. 5. In the proposed RMP regulations, provide penalties in the event that a business entity fails to file an RMP or files an inadequate or fraudulent plan. 6. Require fire chiefs to set standards for the timely unloading of hazardous materials from tank cars as allowed pursuant to the Uniform Fire Code § 79.809(c)4 (flammable liquids) and recommend similar requirements for hazardous materials. 7. Explore the delegation of enforcement authority for hazardous material health and safety regulations to CCCHSD via a Memorandum of Understanding (MOU) with Cal/OSHA. (Cal/OSHA would retain its existing authority in this area as well.) 8. Move swiftly to find qualified candidates selected for their public safety experience to fill the five-member Chemical Safety Board created by the Clean Air Act Amendments of 1990. The Chemical Safety Board will investigate accidental releases of hazardous chemicals. 9. Review regulations requiring document production during investigation of regulatory violations and/or safety practices. Questions have been raised regarding the extent of document production required of railroads during.federal, state or local agency investigation and/or enforcement activities. A review and critique of the production requirements seems warranted. 10. Identify unregulated hazards associated with military facilities. Recent Executive Orders from President Clinton have indicated that military facilities should be treated in the same manner as any other industrial facility for purposes of environmental safety and regulatory 4 Uniform Fire Code § 79.809(c) states, 'Tank vehicles and tank cars shall be unloaded as soon as possible after arrival at point of delivery and shall not be used as storage cars. Tank cars shall be unloaded only on private sidings or railroad siding facilities equipped for transferring the liquid between tank cars and permanent storage tanks. Unless approved by the chief, a tank car shall not be allowed to remain on a siding at point of delivery for more than 24 hours while connected for transfer operations." (Emphasis added). Railroad Safety Recommendations - Page 5 enforcement. There are indications that military facilities either may be explicitly exempted from railroad safety regulations or that they are treated in such a manner that they are exempted by default. A survey of enforcement requirements covering military installations should be conducted to explain to local administering agencies the scope of unregulated activity occurring within this jurisdiction, and an analysis of the potential public health and safety hazards thus created. 11. Explain any exemptions from federal regulations pursuant to 49 CFR § 107.103. to local administering agencies so they can be evaluated for their impact on emergency preparedness. 12. Require state enforcement agencies to identify local safety hazards and propose regulations to eliminate or reduce the hazards. 13. Establish minimum inspection standards of every 180 days for equipment in yards'and every year for main line track. 14.Encourage states to significantly increase penalties for emissions of a hazardous material or AHM which results in a public nuisance. 15. The trend towards the breaking up large railroads into smaller companies increases concerns about the effectiveness of self-regulation by industry. The smaller lines may not have adequate resources to address safety issues. 16. Require annual inspections for railroad tank cars, similar to those required for highway tank cars, on safety issues such as pressure guages, hydrology, etc. The results of the inspections should be recorded, dated and signed and kept attached to the tank car at all times. Public Participation 1. Develop for the public, non-technical information regarding the health effects of commonly used chemicals which may be released into the environment. 2.In proposed RMP regulations,require that reports developed by facilities regarding actual and potential chemical releases are readily available to the public. 3. Provide for public input in the post-incident critique process. 4. Congress and the federal agencies should improve public access to information, and should consider expanding reporting provisions under the Emergency Planning and Community Right-to-Know Act of.1986. EPA should initiate pilot programs using newer information technologies,like the"Right-to-Know"Network and INTERNET,to disseminate Railroad Safety Recommendations - Page 6 r environmental and public health data to the public. The pilot schemes should focus on addressing environmental injustices. 5. In the proposed federal RMP regulations, worst case toxic release scenarios should be required to be publicized. 6. Each accident is unique, requiring Local Emergency Planning Committees (LEPCs), the agencies most familiar with regional conditions,to coordinate response and provide effective leadership when an accident occurs. LEPCs should also work year- round to educate and involve the public in prevention programs. Notification 1. Require expanded technical capability of State Warning Centers, or their equivalent, within the state Offices of Emergency Services, so that staff expertise will be available to assess the potential impact of a release, and have the technological capacity to immediately forward the corresponding notifications to all other appropriate state agencies. 2. Require expanded notification coverage of State Warning Centers, or their equivalent, to include all public agencies which may have jurisdictional interests. 3.Require inclusion within the risk management analysis information,regarding the average and maximum annual storage of hazardous materials in rail cars. 4. Require that facilities provide immediate access to responsible public agencies, information about the amount, type, storage, and use conditions of any hazardous materials within that facility. 5. Require facilities to report the typical and maximum annual storage of hazardous materials in rail cars. 6. Assure each community potentially affected by off-site releases has an adequate notification and alert system for chemical emergencies. 7. Develop railcar regulations regarding shipping paper requirements for the transportation of hazardous materials. In particular, require that specific information be carried in the engine of any train transporting hazardous materials. 8. Require that in situations in which there may be two Federal On-Site Coordinating (FOSCs) agencies, that both prospective FOSCs be notified by the National Response Center. Railroad Safety Recommendations - Page 7 Risk Management/Assessment 1. In the proposed RMP legislation,incorporate the concepts of"inherent safety"for process safety management into the risk management and prevention process provisions. 2. Propose regulations at both state and federal levels requiring handlers to review and revise their risk management and prevention plan no less than 30 days prior to a modification materially affecting the handling of an acutely hazardous material. 3. Establish a process whereby industry devotes additional resources to the development of safer alternatives to the acutely hazardous materials currently used in industrial processes. Reducing use of hazardous materials is the most effective long-term policy to improve community safety. 4. Enforce federal law requiring administrating agencies and LEPCs to do cumulative hazards analyses. 5. Enforce statutory deadlines for EPA to produce required research studies on the dangers of hydrogen fluoride and hydrogen sulfide gas. Document the worst case catastrophic impacts of releases of these materials. Training 1. Develop training requirements for workers loading and unloading tank cars, so that employees recognize critical points at which appropriate action is necessary to prevent uncontrolled releases of the tank car's contents. 2. Develop and adopt acceptable training requirements related to the normal process operations and emergency response operations for the railroad. These would apply to both public and private sectors. 3. Modify current regulations to ensure that first responders are adequately trained and certified competent to respond. Require similar training for plant personnel. 4. Propose legislation to define public agency emergency response teams, mandating and requiring periodic reviews of minimum training requirements for effectiveness. 5. Require workers whose job requirements include actual response to attain training equivalent to the specialist/technician curriculum provided by the California State Training Institute, or comparable training institutions. Railroad Safety Recommendations - Page 8 T 6. Federal OSHA should require swifter completion of workplace safety reviews required by Congress in the 1990 Clean Air Act amendments. These reviews will help identify potential risks in the workplace and reduce the risk of accidents. 7. Regulations must be developed to require company follow-up on employee identified concerns regarding railcar safety issues. 8. Require that workers in areas where Acutely Hazardous Materials (AHMs) are present, to be fully trained through intensive, certified safety programs offering 80 or more hours. 9. Assess the current status of worker training to identify gaps. 10. Consult with trade unions which have extensive information on worker health and safety training. 11. Cross-train FRA and state inspectors on all parts of railroad safety inspections. 12. Infuse the inspection program with an enforcement ethic. 13.Develop the equivalent of a National Training Standard performance based standard for loaders and unloaders of hazardous materials. 14. Ensure that employee training covers the following issues: temperature of plant steam systems; frequency for monitoring the pressure gauge installed in air/vent lines; appropriate steps to take in the event of overheating and overpressurization of the rail car; recognition of the difference between true tank pressue compared to static gauge pressure on air/vent lines. Safety 1. Propose legislation that will require or allow state-level Occupational Safety and Health Administrations to adopt the Federal Process Safety Standards. 2. Require state agencies that enforce Federal Railroad Administration regulations to include expenditures for railroad safety personnel specifically dedicated to hazardous materials inspections and enforcement. 3. Require that regulations be established by state agencies that enforce Federal Railroad Administration regulations to include provisions for allocating special hazardous materials fees, pro-rated to tons of hazardous materials carried in the State, to amortize the additional hazardous materials inspector positions needed. Railroad Safety Recommendations - Page 9 4. Regulations must be developed to provide a check system for the unloading of oleum or other chemicals from tank cars. 5. Promulgate regulations regarding the prevention of collision of tank cars during loading and unloading operations. A safety risk can occur if a string of stationary tank cars is accidently rear-ended/bumped during loading or unloading operations. The collision could result in a domino effect that dislodges and/or breaks the pipes involved in the transfer of chemicals. 6. Review and revise as necessary federal regulations for end-of-track safety barriers. 7. Require facilities to provide containment/control systems that are designed to preempt all emissions. 8. Review requirements for rail cars loaded with hazardous materials to determine if additional safety precautions are needed. 9. Product-specific procedures should be standardized in regulations for the loading and unloading of hazardous materials. 10. Monitor and document the loading and unloading of hazardous materials. Record procedures taken, container pressure and flow rates. 11. Regulate the contents of the Injury and Illness Prevention Program as it applies to loading and unloading of hazardous materials. 12. Require the use of rupture disks that are rated to withstand appropriate levels of pressure to adequately protect workers during loading and unloading operations. 13. Require all employees to be trained in emergency response procedures; minimum experience and competency levels for personnel should be established. 14. Require personal protective equipment, including self-contained breathing apparatus, appropriate to the chemicals being handled are available for all employees. 15. Require diversion of relief or vent dischages from rupture disks to an isolated loction away from employees work areas. 16. Require a scrubbing system connection from the relief or vent discharges from rupture disks. 17. Require periodic inspection and testing of relief valves since the materials may have a corrosive effect on the valves. Railroad Safety Recommendations - Page 10 • Storage 1. Eliminate current loopholes in laws governing the storage of hazardous materials in rail tank cars. Industry should also be required to provide advance notice of new operations, in addition to complying with all RMPP requirements. 2. Require the Federal Railroad Administration to evaluate whether additional safety measures are needed for the storage of hazardous materials, and additionally evaluate the benefits/disadvantages of rail cars versus fixed storage facilities. 3. Clarify railcar regulations to emphasize local regulatory oversight for inspection and limitations in maximum amounts on site at one time. 4. Modify railcar regulations to provide centralized inventories of amounts of materials stored, time stored, locations, etc. 5. Modify railcar regulations to provide the phaseout of storage of AHMs near neighborhoods. 6. Provide clear demarcation of the transition from when a material is considered in transportation and when a material is considered delivered to a facility. Ensure narrow timeframes, but allow for exemptions from the timeframes if accompanied by specified safety procedures. Tanker Car Design 1. Require that tanker cars which require pressurization or heating of a product for the loading, unloading or transportation be equipped with pressure/vacuum relief devices as well as pressure and temperature monitors. 2. Develop regulations to prevent the heating of products above the optimum temperature for the rupture disks prior to unloading. 3. A method for determining the temperature of a product inside a tank car during the unloading process should be developed and required. 4. Evaluate the scope of regulations requiring pressure safety valve rather than rupture disks for the loading and unloading of oleum and other select chemicals. Investigate the benefit of adding additional chemicals to this regulation. 5. Improve DOT design specifications for tank cars: how often the specifications must be updated; what standards of safety must be met; and what types of tests must be conducted Railroad Safety Recommendations - Page 11 r to ensure a design is specifically suited to the product to be transported. Data Management 1. Develop guidelines for record keeping of health effects believed to be a result of a chemical release, and require physicians to report such health effects. 2. Improve management of environmental information at the EPA. According to the General Accounting Office, "EPA is an agency with hundreds of information systems that are mostly separate and distinct, with their own structures and purposes.This plethora of systems impairs EPA's ability to easily share mutually beneficial information across program boundaries, fosters data duplication, and precludes more comprehensive, cross-media assessments of environmental risks and solutions." 3. EPA should assist Local Emergency Planning Committees in obtaining Toxic Release Inventory data and other information available on database including EPA's Computer-Aided Management of Emergency Operations software and the Right-to- Know Network. 4. Develop a Memorandum of Understanding between the Department of Energy and Regional Federal On Site Coordinators to facilitate the use of Air Release Advisory Capability (ARAC) modelling to assist in determining the degree of potential health risk in areas affected by hazardous materials incidences. Conclusion Local emergency response agencies are on the front-line of managing hazardous materials incidents that have the potential to negatively affect large segments of the community. The expertise of these agencies,both in light to the General Chemical incident and in light of years of emergency management responsibilities,should inform federal policy makers regarding the potentially deadly hazards facing workers and the public. The HIT agencies hope that this report provides insight and spurs response at the federal level to local needs. For more information about HIT or the contents of this report, please contact William Walker, MD; Contra Costa County Health Officer (510) 370-50.12. Railroad Safety Recommendations - Page 12