United States General Accounting Office

GAO Report to the Administrator of the

Environmental Protection Agency

June 1996 CHEMICAL

ACCIDENT SAFETY

EPA’s Responsibilities

for Preparedness,

Response, and

Prevention

G O A

years

1921 - 1996

GAO/PEMD-96-3

GAO United States

General Accounting Office

Washington, D.C. 20548

Program Evaluation and

Methodology Division

B-261768 

June 27, 1996

The Honorable Carol M. Browner

Administrator, Environmental

 Protection Agency

Dear Ms. Browner:

Over 10 years ago, a catastrophic chemical accident occurred in Bhopal,

India, which claimed the lives of thousands of residents, injured many

others, and displaced many more from their homes and businesses. The

magnitude of this event, coupled with an identified potential for similar

accidents in the United States, were catalysts for strengthening national

policy on chemical accident preparedness and response. Several specific

laws were passed, giving the Environmental Protection Agency a central

role in the implementation of chemical accident safety policy. The

National Response Team, chaired by EPA, provides support for local and

state officials who respond to chemical accidents. EPA also conducts

accident preparedness and prevention activities.

EPA’s role has been central in these areas. However, efforts to implement

chemical accident safety policy have not been comprehensively evaluated.

We examined the extent of EPA’s role in accident preparedness, response,

and prevention. Specifically, we assessed (1) EPA’s databases on accident

occurrence and impact, (2) EPA’s chemical accident preparedness

activities, (3) the effectiveness of EPA’s response to chemical accidents,

and (4) the steps EPA has taken to help prevent the occurrence of chemical

accidents.

Background Federal policy on chemical accidents has chiefly been formulated over the

last 25 years and is administered under five major specific acts. They are

the Comprehensive Environmental Response, Compensation, and Liability

Act of 1980, the Hazardous Materials Transportation Uniform Safety Act of

1990, the Emergency Planning and Community Right-To-Know Act of 1986,

the Clean Air Act Amendments of 1990, and the Clean Water Act as

amended by the Oil Pollution Act of 1990. Table 1 summarizes this

legislation and EPA’s responsibilities for chemical accident safety.

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Table 1: Environmental Legislation and

EPA’s Chemical Accident Safety

Responsibilities

Legislation Responsibilities

Comprehensive Environmental Response,

Compensation, and Liability Act of 1980

(CERCLA), P.L. 96-510

Clean up of hazardous waste sites and

land and inland waterway spills of

hazardous substances

Emergency Planning and Community

Right-To-Know Act of 1986 (EPCRA), P.L.

99-499

Facilitate state and local accident

contingency planning, public participation,

and access by individuals and

communities to information regarding

hazardous materials in their locales

Hazardous Materials Transportation Uniform

Safety Act of 1990 (HMTUSA), P.L. 101-615

Participate in the oversight of grants

awarded for the training and education of

hazardous materials employees

Clean Water Act as amended by Oil

Pollution Act of 1990 (OPA),

P.L 101-380

Facilitate contingency planning for the

petroleum industry including issuing

regulations for tank vessel and facility

response plans

Clean Air Amendments of 1990 (CAA), P.L.

101-549

Develop a list of at least 100 chemicals

that may result in significant harm to

human health or the environment

Develop accident prevention programs

EPA’s chemical accident planning and prevention responsibilities are

conducted by the Chemical Emergency Preparedness and Prevention

Office. The Office of Emergency and Remedial Response provides

resources for responding to accidents involving hazardous substances and

for those involving oil releases. (Oil accident planning and prevention

responsibilities are also the responsibility of this office, although these

issues are not addressed in detail in this report). While several federal

agencies have responsibilities for chemical accident safety policy, EPA

(along with the Department of Transportation [DOT] and the Occupational

Safety and Health Administration [OSHA]) has the primary regulatory

authority. Other EPA responsibilities include facilitating the efforts of local

emergency planners and assisting at accident sites when local resources

are insufficient. EPA provides training to local emergency responders and

works with Local Emergency Planning Committees (LEPCs) to share

information with communities.

Objectives, Scope,

and Methodology

In designing our evaluation, we found that EPA’s chemical accident safety

activities include accident preparedness, response, and prevention, and

thus we examined the following evaluation questions:

Page 2 GAO/PEMD-96-3 Chemical Accident Safety
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1. What have been the recent trends in accident occurrence and impact?

2. What are EPA’s accident preparedness activities?

3. How effectively does EPA respond to chemical accidents?

4. What steps has EPA taken to prevent the occurrence of chemical

accidents?

Many federal agencies play a role in chemical accident preparedness,

response, and prevention; however, our study is limited to EPA’s role. It is

also limited to accidents involving hazardous chemicals (including

petroleum products) produced by private industry. Radiological

substances are not included. A portion of the report is based on case

studies of six accidents that have occurred since January 1993. These

cases constitute significant accidents with major impact on human health

or the environment; EPA coordinators were on-site in each case. The

criteria for case selection included the occurrence of at least 5 injuries, 1

death, 100 evacuees, or $50,000 in property damage. The cases were evenly

split between fixed-facility and transportation accidents and included

urban and rural communities. We identified these cases through the

assistance of officials at the EPA regional offices.

We used multiple sources of information to address our four evaluation

questions. We synthesized information from EPA documents, legislation,

and National Response Team publications. We also utilized data from

three national accident databases: the Accidental Release Information

Program (ARIP), the Hazardous Materials Information System (HMIS), and

the Emergency Response Notification System (ERNS). In addition, we

obtained data from accident case site visits, including interviews with

state, local, and industry officials. Finally, we reviewed EPA’s Chemical

Safety Audit (CSA) Program database and interviewed pertinent federal

officials.

We conducted our evaluation between July 1994 and December 1995 in

accordance with generally accepted government auditing standards.

Results in Brief We found that EPA has vigorous programs for accident preparedness and

response. Legislation enacted during the last several years, however, has

shifted the agency’s primary focus to the prevention of chemical accidents.

Through risk management planning, the agency has conducted a number

Page 3 GAO/PEMD-96-3 Chemical Accident Safety
B-261768 

of efforts to further the prevention of accidents, including collaboration

with industry and professional associations.

EPA has developed a large repository of information on accident

prevention. A major barrier to the prevention of accidents, though,

remains the relative lack of involvement of community residents and some

sectors of industry. To maximize the potential for accident prevention,

information that facilitates prevention must be made available and used by

industry and the local level.

Principal Findings

Accident Occurrence and

Impact

The available data on chemical accidents do not provide clear evidence on

accident trends. While accidents do not appear to be getting more severe,

neither is there a downward trend pointing to effective accident

prevention activities. The data do suggest that the total number of

chemical accidents has been increasing over time, peaking at over 40,000

incidents occurring in 1994, but this may be attributable to more

aggressive reporting and increased economic activity.

For example, we found that as industrial production increases, the number

of fixed-facility accidents also increases. Similarly, for transportation

accidents, even after accounting for the increasing mileage being driven by

trucks, there is an increase in the reported number of chemical accidents.

Assuming continued economic growth, then, we can assume an increase in

the number of accidents, unless specific prevention measures are

implemented. However, the impact of fixed-facility and transportation

accidents, which includes deaths, injuries, and property damages, have

changed little over time. (Appendix I provides a complete discussion of

these results.)

Making definitive conclusions about how and why chemical accidents

occur is hindered by data quality problems. Unverified data are reported,

causal factors are not always included, and underreporting of accident

data exists. As shown in table 2, each of the databases used to chronicle

chemical releases has significant limitations.

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These limitations include unverified data, underreporting, and the

unavailability of data on the causes of accidents. (Appendix I provides a

full discussion of these limitations.)

Table 2: Information Included and Limitations of Chemical Release Databases

Database Information included Database limitations

Emergency

Response Notification

System (ERNS)

Initial reports of release data submitted to the National

Response Center, EPA regional offices, and until 1989,

U. S. Coast Guard field offices.

Release data are reported when events occur and

before they are verified, hence, ERNS is prone to

inaccuracies about the number of deaths, injuries,

economic damage, and chemicals involved.

An estimated 5 percent of reports are duplicated.

Causal information not always included.

Accidental Release

Information Program

(ARIP)

Information on the causes of the most serious or

potentially serious releases and preventive practices

before and after a release. Cases are identified

through ERNS, and data are collected through a

questionnaire.

Includes only accidents at fixed facilities and is limited

to those releases that involve injury and have off-site

impact, which are not representative of all release

cases. The vast majority of cases are excluded.

Database has not always been updated on a timely

basis.

Acute Hazardous

Events (AHE)

Accident information from secondary sources,

including newspapers, state government office files,

and EPA office files.

Information, collected from secondary sources, has not

been verified. (EPA cautions that such sources are

particularly prone to error.) 

Database was developed only over a 5-year time

frame and is no longer active.

Hazardous Materials

Information System

(HMIS)

Chemical release data from transportation incidents.

The data are used to monitor DOT’s hazardous

materials transportation program.

Limited to the information that a transportation carrier

has knowledge of and reports. 

In some cases, information on chemicals may be

destroyed during the events surrounding the incident,

and it is likely that the carrier does not know what

material was being shipped.

There is no assurance that DOT is receiving all

incident reports as the reporting burden is placed

upon carriers.

Page 5 GAO/PEMD-96-3 Chemical Accident Safety
B-261768 

Accident Preparedness EPA administers programs to help local communities prepare for chemical

accidents, and one way the agency does this is by training local and state

responders. EPA exceeds its requirements by offering this training. Most of

those trained find it useful, but relatively few local responders have taken

the training, and state and local agencies may not have the resources to

provide it internally. However, national firefighter associations do provide

a significant amount of such training, thereby filling some of the gaps.

Under the Emergency Planning and Community Right-To-Know Act of

1986, EPA assists in developing accident preparedness programs for

industry, the states, and local communities. The act requires that state and

local communities be involved in emergency planning and response with

EPA in a facilitative role. Under the act, EPA was given a lead role in making

it possible for community residents to obtain information about

community chemical hazards. The provisions of the legislation rely on

public awareness to encourage the minimization of accident risks.

Specifically, Local Emergency Planning Committees are responsible for

informing community residents about the potential accident risks, but a

sizable number of them were not actively disseminating this information.

However, EPA has made accident data available to the public, industry, and

local and state governments through several sources, including the

Internet. (Appendix II discusses this issue in more detail.)

Accident Response EPA is required to assess the nature and seriousness of chemical accidents.

If neither the party responsible for the accident nor the locality or state

can handle the incident, EPA is required to take charge of response

operations. We examined a variety of chemical accident cases in which

EPA played a major role. The fixed-facility cases include chemical

explosions at plants in Ohio and Pennsylvania, while the transportation

accidents involved truck and train cases in Texas, California, and

Connecticut. (See appendix III for descriptions of these cases.)

One of EPA’s key functions is to assess the facts about a chemical accident,

such as the probable cause or causes and effects upon human health and

the environment. Typically, these efforts are used to facilitate accident

response by local or state authorities who are likely to have immediately

responded to the accident.1

 In the accident cases we examined, EPA

officials performed these functions and were commended for their efforts

by local responders.

1

As discussed previously, EPA has the authority to take control of accident response functions if local,

state, or other authorities are unable to handle an incident. However, in our cases, this did not occur.

Page 6 GAO/PEMD-96-3 Chemical Accident Safety
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As noted in the National Contingency Plan, EPA on-scene coordinators are

required to assess whether or not responsible parties or local and state

officials can handle incidents.2

 The length of response time varied

considerably (from fairly immediate to approximately 15 hours), but EPA

officials coordinated with on-site responders by telephone to ascertain

whether or not they were needed. In the case with the longest response

time, EPA coordinated with state officials and discovered that an

immediate response was unnecessary. In one transportation case, an EPA

coordinator arrived at the accident site 3 hours after it occurred and met

with the local fire department incident commander to discuss options for

managing the case. In this case, before the arrival of the EPA coordinator,

the local responders had immediately taken command of the incident by

alerting area residents and applying response procedures to contain the

accident.

The capabilities of local responders are very important, given that,

depending on the location of an incident, an EPA coordinator could take

several hours to reach the accident site. While on-scene coordinators are

stationed at the 10 EPA regional offices and at smaller facilities, they

cannot always be on-site immediately. As a result, local responders must

usually make initial assessments about the need for evacuation,

containment, and treatment technologies. Local authorities told us that

they usually do not have the chemical training or equipment to perform

these tasks, and they rely highly on EPA resources. As one local responder

noted, his background was in firefighting, not chemicals.

Under the National Contingency Plan, EPA is responsible for coordinating

response efforts among appropriate federal, state, and local agencies and

officials. In one transportation case, EPA participated in a meeting attended

by local, state, and other federal officials. The group decided to let a fire

burn out rather than treat it with materials that would contaminate a

nearby creek. In another case, EPA oversaw a cleanup function of

hazardous chemicals, but (as described by a local responder) did not

micromanage the event. For another transportation case, EPA was

described by a local fire department official as acting in a “support role,”

while state and local authorities conducted the direct response functions.

A road that was likely to be closed for a week was reopened within 72

hours because of the coordination efforts of EPA with those of the state

and other federal officials.

2

The National Contingency Plan is a federal preparedness plan developed over a number of years that

attempts to deal comprehensively with oil spills and hazardous substance accidents.

Page 7 GAO/PEMD-96-3 Chemical Accident Safety
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In all the cases, EPA and the technical assistance teams were heavily

involved in monitoring activities to ascertain the effects of the accident

upon the area’s environment. In accordance with the contingency plan,

this monitoring supported the local responders, who generally had less

expertise in this technical area. While local responders are usually able to

control some of the more obvious effects of an accident (such as fire),

they are less likely to have the expertise to mitigate such effects as

groundwater pollution and air emissions.

In summary, EPA was effective in assessing the incidents we studied and

coordinating response efforts. As noted by local responders, the EPA

officials were quite skilled at providing needed expertise and coordinating

response options, while not micromanaging any of the cases.

Under the National Contingency Plan, EPA is also responsible for ensuring

that local responders can handle the responsibility of making area

residents aware of accident risks and protecting natural resources from

harm. (The local responders’ inability to do so would effectively shift the

responsibility to EPA.) EPA was not involved in evacuating residents and

handling their concerns. Local officials directed evacuation efforts since

EPA officials often did not arrive on-site until several hours after the

incident. In the cases we examined, local resources were quite sufficient

for these efforts. However, in two cases, EPA officials did attend public

meetings following the incidents to advise citizens about accident

preparedness and prevention.

For one fixed-facility case, the head of the EPA regional office that had

jurisdiction for the accident personally attended a public meeting

regarding response and cleanup concerns. According to a local responder

in this case, the citizens were positively impressed that an official of this

rank attended the meeting. In the cases with natural resources at risk, EPA

officials contacted the appropriate trustees as required by the contingency

plan. For example, in one transportation case where a creek was

contaminated, an area water quality control board, the local county water

district, and the department of fish and game were contacted.

Given that community residents were at risk, media outlets were

interested in covering some of these cases. According to one local

responder, media representatives were very impatient with him in their

quest to obtain information. This responder relied upon the public

relations expertise of EPA. This responder noted that, in working with the

media, EPA was able to garner respect.

Page 8 GAO/PEMD-96-3 Chemical Accident Safety
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In summary, EPA was also able to ensure timely communication of

accident risks to the public. The agency’s ability to deal with the public

and media representatives was appreciated by local responders.

As noted above, EPA is charged with ensuring that the entity responsible

for the accident provides cleanup and pays associated costs. For all cases

in our study, we found that EPA was successful in meeting this

requirement. In most cases, those responsible engaged contractors who

worked with government officials to clean up the accidents.

Two of the cases we reviewed occurred in rural areas, which are unlikely

to have the technical resources to manage the response to chemical

accidents.3

 Furthermore, Local Emergency Planning Committees in rural

areas tend to be inactive or quasi-active, according to a recent study.4

However, in our cases, we found a high level of assistance given to such

areas by neighboring community fire departments, state officials, and

ultimately, EPA staff members and technical assistance teams. While such

assistance networks may not be formalized (as demonstrated by the weak

rural LEPC system), in the cases we examined, the assistance was

important in providing response resources to these areas, facilitating risk

communication, and following other mandated response procedures.

Accident Prevention As mandated by the Clean Air Act Amendments of 1990, EPA has developed

a risk management planning program regulation that requires facilities to

identify and plan for the possibility of chemical accidents. In developing

this program, EPA has conducted a number of efforts to obtain information

on accident prevention. The agency has worked with industry and

professional associations to understand the basics of process safety

management issues, which show that accidents are best prevented by

comprehensive management systems. The agency has also conducted a

number of outreach efforts. However, the agency has noted that the level

of demand for accident prevention information should be increased at the

industry and community levels.

The Clean Air Act Amendments of 1990, which added section 112(r),

require facilities handling regulated substances in quantities that exceed

specified thresholds to develop integrated plans for managing accidents,

which must be registered with appropriate parties and be made available

3

“Rural” is defined as an area with fewer than 2,500 residents.

4

See Nationwide LEPC Survey (Washington, D.C.: George Washington University Department of Public

Administration, Oct. 1994).

Page 9 GAO/PEMD-96-3 Chemical Accident Safety
B-261768 

to the public. Facilities must identify chemical hazards, design and

maintain safe operating procedures, and minimize the consequences of

releases when they occur. EPA is required to develop a list of at least 100

substances that cause, or may be reasonably anticipated to cause, death,

injury, or serious adverse effects to human health or the environment

when released in the air. In addition, the act requires EPA to develop

“reasonable regulations and appropriate guidance” to provide for the

prevention and detection of accidental releases and for responses to such

releases. These regulations are required to include, as appropriate,

provisions concerning the use, operation, repair, and maintenance of

equipment to monitor, detect, inspect, and control releases, including

training of personnel in the use and maintenance of equipment or in the

conduct of periodic inspections. The regulations, issued in May 1996,

require covered facilities to prepare and implement risk management

plans that include a hazard assessment, a prevention program, and an

emergency response program. Specifically, the hazard assessment must

analyze the off-site consequences of the worst possible accident. In

addition, the risk management planning will improve accident information

reporting.

EPA has conducted several main activities geared toward risk management

planning efforts. These include conducting a review of emergency

systems, operating the Accidental Release Information Program and the

Chemical Safety Audit Program, initiating process safety management

activities, and conducting outreach efforts. These are described in greater

detail in appendix IV.

The Clean Air Act Amendments of 1990 required the establishment of the

Chemical Safety and Hazards Investigation Board to obtain information

about accidents that could be used to prevent future occurrences.

Modeled after the National Transportation Safety Board (NTSB), the CSHIB

was to consist of five members, nominated by the President and confirmed

by the Senate. The functions of the Board were to investigate the causes of

any fixed-facility accidental releases resulting in a fatality, serious injury,

or substantial property damage and to publicize results of the

investigations.5

The CSHIB has never become operational. The Senate has confirmed three

nominees; however, none has been sworn in. The administration proposed

rescinding the Board’s funding for fiscal year 1995, and its proposed

5

The Board was to enter into a memorandum of understanding with NTSB to ensure coordination of

functions and to limit duplication of activities, allowing NTSB to investigate transportation-related

chemical releases.

Page 10 GAO/PEMD-96-3 Chemical Accident Safety
B-261768 

budgets for fiscal years 1996 and 1997 requested no funds for the Board.

The administration stated it was including in its budget requests additional

funds for EPA and OSHA to enhance their investigation and prevention

efforts.

In January 1995, EPA and OSHA developed a memorandum of understanding

outlining their accident investigation program.6

 To carry out their

responsibilities, these agencies are undertaking joint accident

investigations and, on the basis of their experience, are developing an

investigation protocol. The memorandum of understanding will be

reexamined in light of their joint experience. The agencies will develop

criteria for selecting accidents for both joint and individual agency

investigations.7

 Public reports will detail findings on the causes of

accidents and provide safety recommendations.

The agencies also agreed to continue staff training in accident

investigation and to train staff on the new investigation protocol. Training

will be made available to other federal agencies, industry, labor, and other

interested parties. In addition, EPA and OSHA will establish an internal and

external expert review process, including “blue ribbon” panels of

stakeholders for reports and recommendations.

EPA can use information obtained in accident investigations in legal

proceedings brought against alleged industry violators, and the public, in

turn, could use this information in tort liability cases. However, if the CSHIB

conducted investigations, the public would be prohibited under the law

from using information in this manner, effectively weakening the “public

pressure” provisions of Community Right-To-Know legislation.

In summary, to prevent accidents, industry must be able to obtain quality

information. The replacement of the CSHIB with joint EPA/OSHA oversight

may meet this need if industry fully cooperates and if the agencies

undertake to fulfill the mandates of the Board.

Conclusions In this report, we examined several components of EPA’s chemical accident

safety policy, including accident preparedness, response, and prevention.

6

See EPA/OSHA Joint Accident Investigation Program (Jan. 18, 1995).

7

OSHA currently investigates incidents in which a worker is hurt; EPA investigates fixed-facility

environmental accidents with impacts outside of facilities. The joint accident investigation protocol

currently being developed will more specifically delineate each agency’s investigatory responsibilities.

As noted, transportation accident investigation is NTSB’s responsibility.

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Arguably, the prevention of accidents is the ultimate goal of agencies and

other organizations concerned with chemical accident safety policy.

Accident prevention activities, if effective, reduce risks to communities

and lower costs to municipalities and private organizations. As noted in a

report prepared for EPA by the Massachusetts Institute of Technology,

accident mitigation systems are expensive, while accident prevention can

be much less costly.8

One of the major barriers to accident prevention is inadequate information

and, perhaps most importantly, lack of demand for that information at the

local, state, and industry level. Information from prior accidents is

essential to take a “lessons learned” approach in preventing future

accidents. Furthermore, this information must be disseminated to

community residents, state governments, and industry. However, as noted

by EPA, the major challenge is to stimulate interest in accident prevention

at these levels. Oftentimes, community residents and industry officials do

not consider the importance of accident prevention until after an accident

occurs, which severely limits the extent of accident prevention activities.

As noted above, EPA directs several efforts to advance accident prevention

activities. For the risk management planning process, the agency has

developed a large repository of information on accident prevention issues,

especially on safety management procedures. EPA has utilized ARIP and the

CSA Program to support this effort. By working with industry, professional

associations, and academia, the agency has built a large amount of

expertise in this area.

However, a notable amount of this knowledge is not being utilized at the

community level. While EPA has outreach efforts, agency officials have

noted that some community residents and industry officials remain

unconvinced about the possibility of the occurrence of a chemical

accident.9

 As a result, the agency could improve the extent to which

“lessons learned” are provided to the local level.

Recommendations Based on these findings, we recommend that the EPA Administrator

(1) initiate improvements in prevention activities by increasing the extent

to which the “lessons learned” from risk management planning efforts are

8

See The Encouragement of Technological Change for Preventing Chemical Accidents: Moving Firms

From Secondary Prevention and Mitigation to Primary Prevention (Cambridge, Mass.: MIT Center for

Technology, Policy, and Industrial Development, July 1993).

9

One example of outreach efforts is EPA, Managing Chemicals Safely: Putting It All Together

(April 1992).

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conveyed to industry, state and local government and the public, and

(2) work with industry, state and local government, and the public to

stress the importance of how this information can be used to facilitate the

prevention of accidents.

Agency Comments EPA provided comments on a draft of this report. Most of the agency’s

concerns pertained to our findings on EPA accident prevention activities.

EPA suggested that our discussion of accident prevention did not provide

sufficient information on recent agency programs and activities. We

agreed with these comments and made appropriate changes.

EPA made several comments about the Accidental Release Information

Program. We had noted that accident trend information cannot be

developed from the program, and the agency responded that this is not the

program’s intent. However, we believe that trend information is a vital part

of understanding the causes of accidents. We had noted the program’s bias

toward larger events, and EPA told us that agency resources limit its

coverage. We concurred with this point and made the appropriate change

in the report. Several other technical changes were made throughout the

report where appropriate.

We are sending copies of our report to interested congressional

committees and to officials in EPA’s Chemical Emergency Preparedness

and Prevention Office and the Office of Emergency and Remedial

Response. We will also send copies to other interested parties, and we will

make copies available to others upon request. If you have any questions,

please call me at (202) 512-3092. Major contributors to this report are

listed in appendix V.

Sincerely yours,

Kwai-Cheung Chan

Director for Program Evaluation

 in Physical Systems Areas

Page 13 GAO/PEMD-96-3 Chemical Accident Safety
Contents

Letter 1

Appendix I 

Trends and Impact of

Accident Occurrence

16

Appendix II 

Chemical Accident

Preparedness

32

Appendix III 

Accident Case Study

Descriptions

35

Appendix IV 

EPA Prevention

Activities

39

Appendix V 

Major Contributors to

This Report

48

Tables Table 1: Environmental Legislation and EPA’s Chemical Accident

Safety Responsibilities

2

Table 2: Information Included and Limitations of Chemical

Release Databases

5

Table I.1: Incidents Reported to Emergency Response

Notification System

16

Figures Figure I.1: Total Incidents Reported to ERNS Compared to

Industrial Production

17

Figure I.2: Deaths and Injuries Reported to ERNS 18

Figure I.3: Total Property Damage Reported to ERNS 19

Figure I.4: Average Cost of Property Damage per Damage

Incident

20

Page 14 GAO/PEMD-96-3 Chemical Accident Safety
Contents

Figure I.5: Incidents by Transportation Mode 21

Figure I.6: Chemical Incident Rates—Highway 22

Figure I.7: Chemical Incident Rates—Railway (Freight)a 23

Figure I.8: Deaths by Transportation Mode (Highway) and

Incident Yeara

24

Figure I.9: Injuries by Transportation Mode and Incident Year 25

Figure I.10: Property Damage by Transportation Mode and

Incident Year

26

Figure I.11: Ratio of Deaths and Injuries to Total Transportation

Accident Reports

27

Figure I.12: Average Cost of Property Damage per Incident

Report

28

Abbreviations

AHE Acute Hazardous Events

ARIP Accidental Release Information Program

CAA Clean Air Act Amendments of 1990

CAMEO Computer Aided Management of Emergency Operations

CERCLA Comprehensive Environmental Response, Compensation,

and Liability Act of 1980

CSA Chemical Safety Audit

CSHIB Chemical Safety and Hazards Investigation Board

DOT Department of Transportation

EPA Environmental Protection Agency

EPCRA Emergency Planning and Community Right-To-Know Act of

1986

ERNS Emergency Response Notification System

HMIS Hazardous Materials Information System

HMTUSA Hazardous Materials Transportation Uniform Safety Act of

1980

LEPC Local Emergency Planning Committee

NTSB National Transportation Safety Board

OPA Oil Pollution Act of 1990

OSHA Occupational Health and Safety Administration

SARA Superfund Amendments and Reauthorization Act

SERC State Emergency Response Commission

Page 15 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

Below, we examine the recent trends in accident occurrence and impact.

Within the limitations of the available data on chemical accidents, we

profile the frequency of chemical accidents between 1987 and 1994 and

their seriousness (as measured by deaths, injuries, and property damage.)

Accident Occurrence

Chemical Incident

Releases

Table I.1 and figures I.1 through I.3 display information on initial

notifications of chemical incident releases reported to the Emergency

Response Notification System.1

Table I.1: Incidents Reported to Emergency Response Notification Systema

Year 1987 1988 1989 1990 1991 1992 1993 1994

Total reports 26,662 28,554 33,337 34,185 35,483 35,693 37,204 39,817

Reports involving deaths 84 110 128 99 124 126 122 134

Total deathsb 1,147b 455b 201 148 162 163 159 185

Deaths per thousand total

reports

43 16 6 4 5 5 4 5

Reports involving injuries 520 569 751 688 732 690 772 921

Total injuries 2,673 1,656 2,360 1,963 1,933 1,743 2,025 2,730

Injuries per thousand total

reports

100 58 71 57 54 49 54 69

aThe search for this information, which is based on initial notification data and may be subject to

change, was performed on May 1, 1995, and reflects data as of that date.

bFigures for 1987 and 1988 include human and animal deaths.

As shown in table I.1, the number of fixed-facility accident reports has

been rising steadily over the period 1987 to 1994, from 26,662 to 39,817.

However, according to EPA officials, more aggressive accident reporting

may have contributed to this increase. In addition, industrial activity has

steadily increased over this time frame; as a result, the level of accident

frequency also rose.

1

ERNS data are gathered as a part of initial accident notification.

Page 16 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

Figure I.1 presents the results of a model where a measure of economic

activity (an industrial production index developed by the Federal Reserve

Board) is used to test the effect upon accident frequency.2

 The figure

demonstrates that as industrial production increases, the number of

accidents also increases as more opportunities exist for such events to

occur. Thus, without specific interventions aimed at accident prevention,

the number of accidents would be expected to increase in the future,

assuming continued economic growth.

Figure I.1: Total Incidents Reported to

ERNS Compared to Industrial

Production

Number of accidental releases

20000

25000

30000

35000

40000

1987 1988 1989 1990 1991 1992 1993 1994

Industrial Production Index (Year)

Source: EPA and Federal Reserve Board.

2

We conducted a statistical analysis utilizing a regression model that demonstrated that, on average, a

1-percent increase in economic activity (as measured by an industrial production index) was

associated with a 2.24-percent increase in the number of accidental releases.

Page 17 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

Reported incidents can vary greatly in their severity. The number of initial

reports of accidents involving deaths has varied between 84 and 134.

These reports have not followed a clear trend from 1987 to 1994, although

the number of reported deaths has remained in a fairly narrow range since

1989 (prior to that year, ERNS data included nonhuman deaths as well as

human deaths). The number of initial reports involving injuries has ranged

from 520 to 921, while the number of total injuries has ranged from 1,656

to 2,730. Figure I.2 chronicles the numbers of deaths and injuries reported

to ERNS.

Figure I.2: Deaths and Injuries

Reported to ERNSa Number of deaths and injuries

0

500

1000

1500

2000

2500

3000

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

Deaths

Injuries

aCalendar years 1987 and 1988 include human and nonhuman deaths.

Source: EPA.

Page 18 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

As shown in figure I.3, initial reports of total property damage

(standardized to 1994 dollars) have ranged from approximately $6 million

to slightly over $15 million.

Figure I.3: Total Property Damage

Reported to ERNS 1994 constant dollars (millions)

0

5

10

15

20

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

Source: EPA.

To demonstrate the seriousness of these chemical accidents, we

developed the following two ratios for each year: deaths per thousand

total reports and injuries per thousand total reports. The results of those

calculations, also presented in table I.1, show that while the number of

reported cases has been increasing over time, the number of deaths per

thousand reports has remained fairly constant since 1989. The estimated

number of injuries per thousand reports reached a high point in 1987, but

has remained fairly constant since then.

Page 19 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

We also calculated the average cost of property damage (as estimated in

initial reports) per report involving such damage. Figure I.4 provides the

results. The average cost has varied from slightly less than $40,000 to well

over $70,000, dropping significantly in 1992 and remaining fairly steady in

1993 and 1994.

Figure I.4: Average Cost of Property

Damage per Damage Incident In 1994 constant dollars

0

10000

20000

30000

40000

50000

60000

70000

80000

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

Source: EPA.

Therefore, while the number of reported chemical accidents has been

increasing, overall—with the exception of property damage costs—their

outcome, as measured by initial reports, has changed little over time.

Furthermore, the apparent increase in accident occurrence may partially

be the result of more aggressive reporting of these accidents and

increasing levels of production.

The above analyses focus upon actual accident impacts. We also analyzed

the extent to which populations were at risk during chemical accidents. To

accomplish this, we obtained data from ERNS on the number of people

evacuated (by the time of the initial report) between 1991 and 1994.3

 In

3

This information was not collected before 1991.

Page 20 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

1991, approximately 34,000 people were evacuated. This decreased to

19,000 in 1992, grew to 28,000 in 1993, and fell back to about 17,000 in

1994. While chemical accidents have maintained relatively low actual

impact, these evacuation figures suggest that, in the judgment of those

responsible for evacuations, the potential for harm is fairly high.

Transportation Accidents Figures I.5 through I.12 summarize information about chemical accidents

from 1987 until 1994 for highway, railway, and “other” (including air and

water) transportation modes. These data are adapted from the Hazardous

Materials Information System, maintained by the Department of

Transportation. As shown in figure I.5, highway accidents have been the

most common and have risen fairly steadily from about 5,000 to 14,000

incidents over this time frame.

Figure I.5: Incidents by Transportation Mode

Number of incidents

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

11000

12000

13000

14000

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

Highway

Railway

Other (air, water)

Source: DOT.

Page 21 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

As demonstrated in figure I.6, even after accounting for the increasing

mileage being driven by trucks (rates per billion truck miles), there is an

increase in the reported number of chemical accidents.

Figure I.6: Chemical Incident

Rates—Highwaya Incident rate per billion miles

0

3.000

6.000

9.000

12.000

15.000

1987 1988 1989 1990 1991 1992 1993

Calendar year

aData for 1994 are not available.

Source: DOT.

Page 22 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

Railway cases have held fairly constant (approximately 1,000 per year),

while other accidents have slightly risen in recent years to approach the

number of railway cases. After accounting for mileage for railway cases

(figure I.7), a slight downturn in incident rates is found.

Figure I.7: Chemical Incident

Rates—Railway (Freight)a Incident rate per million miles

0

1.000

2.000

3.000

4.000

1987 1988 1989 1990 1991 1992 1993

Calendar year

aData for 1994 are not available.

Source: DOT.

Page 23 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

Figure I.8 depicts deaths from chemical transportation accidents. These

resulted only from highway incidents, peaking in 1988 at 19 and ranging to

as low as 8.

Figure I.8: Deaths by Transportation

Mode (Highway) and Incident Yeara Number of deaths

0

5

10

15

20

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

aThere were no reported deaths for railway, air, or water.

Source: DOT.

Page 24 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

As shown in figure I.9, the injury toll for highway accidents involving

chemicals has risen markedly since 1988 to as high as 500, although it

declined in 1994 to approximately 400. Injuries from railway accidents

have generally been increasing over time, while injuries attributed to other

modes have remained fairly constant since 1989.

Figure I.9: Injuries by Transportation Mode and Incident Year

Number of injuries

0

50

100

150

200

250

300

350

400

450

500

550

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

Highway

Railway

Other (air, water)

Source: DOT.

Page 25 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

As shown in figure I.10, property damage estimates show no clear trend

for highway and railway chemical accidents, although other modes have

consistently caused little damage.

Figure I.10: Property Damage by Transportation Mode and Incident Year

1994 constant dollars (millions)

0

5

10

15

20

25

30

35

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

Highway

Railway

Other (air, water)

Source: DOT.

Page 26 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

To depict the seriousness of these transportation accidents, we calculated

ratios that demonstrate the number of deaths and injuries per 1,000

reports. As shown in figure I.11, the ratio of deaths to total reports is fairly

flat, while the ratio of injuries to total reports does not follow a clear

trend.

Figure I.11: Ratio of Deaths and

Injuries to Total Transportation

Accident Reports

Ratio per 1,000 reports

0

5

10

15

20

25

30

35

40

45

50

55

60

65

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

Death ratio

Injury ratio

Source: DOT.

Page 27 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

We also calculated the average cost (in dollars) of property damage per

report involving such damage. Figure I.12 shows that the average property

damage for transportation accidents has ranged from approximately

$1,800 to $5,000, peaking in 1987.

Figure I.12: Average Cost of Property

Damage per Incident Reporta In 1994 constant dollars

0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

1987 1988 1989 1990 1991 1992 1993 1994

Calendar year

aIncludes highway, railway, air, and water.

Source: DOT.

Database Limitations ERNS data are compiled from initial reports of accident data submitted to

the National Response Center, EPA regional offices, and until 1989, U.S.

Coast Guard field offices.4 ARIP data are gathered by sending survey

questionnaires to facilities that have reported serious chemical releases

through ERNS. This information is gathered to develop accident prevention

programs. The AHE database contains accident information from

secondary sources, including newspapers, state government office files,

and EPA office files. HMIS contains chemical accident data from

4

Typically, the National Response Center is contacted by a representative of the party responsible for

the accident, local response personnel, individuals that notice the consequences of a release, or a

witness to the accident.

Page 28 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

transportation incidents; the information is used to monitor DOT’s

hazardous materials transportation program.

EPA has identified several factors that seriously limit the extent of chemical

accident data reliability and validity.5

 The agency has noted that there is

significant evidence of data underreporting. Many accidents are not

reported to federal authorities. In some cases, those involved in accidents

have been unaware of reporting requirements.

There has been no independent verification of information provided from

industry; much of the data are based upon estimates that cannot be readily

validated. Reports and surveys completed by facilities may not disclose

what could be self-incriminating information. There are inconsistencies

among various industry officials who report information: questions are not

uniformly interpreted among all respondents and technical expertise

varies. Thus, information about accidents is largely incomplete, often

lacking details regarding such basic technological issues as type of

production process involved.

Situational factors, such as management issues and policies, are not

routinely reported. These could provide unique reasons as to why

accidents occur, and accident scenarios could then be developed. Having

incomplete data makes it difficult to learn about accidents.

Information is not systematically gathered on “near misses,” which

eliminates a wide range of knowledge on accident potential. According to

a recent study on accident prevention conducted by the Massachusetts

Institute of Technology, the data reporting systems that exist are

somewhat duplicative and also incompatible.6

 Terms differ among

databases, such that variables cannot be linked or otherwise combined for

analysis. This problem is compounded by the different time periods that

the databases cover. For example, ERNS has been in existence since 1986,

while AHE data were compiled for only 5 years (1982-86).7

In response to these problems, EPA published, in September 1995, a users’

guide to federal accident release databases. This document describes each

database, including the data fields, reporting criteria, and points of

5

See A Review of Federal Authorities for Hazardous Materials Accident Safety, EPA (Dec. 1993).

6

See The Encouragement of Technological Change for Preventing Chemical Accidents, MIT (1993).

7

See Environmental Protection: EPA’s Problems With Collection and Management of Scientific Data

and Its Effort to Address Them (GAO/T-RCED-95-174; May 12, 1995) for a general overview of EPA’s

problems with gathering and managing data on pollutants.

Page 29 GAO/PEMD-96-3 Chemical Accident Safety
Appendix I 

Trends and Impact of Accident Occurrence

contact. It also identifies common information among the databases to

allow users to cross-search for information on a particular accident. EPA

has also made accident databases accessible via the Internet.

Trend analyses with these accident data are difficult to construct. While

the existing databases give frequency counts of accidents, they do not

allow us to determine how these counts relate to changes in industrial

production. For example, an increase in the number of accidents could be

a result of increased levels of production rather than a marked decrease in

factory safety.8

The accident databases have specific inherent problems. The ERNS

database is prone to inaccuracies. Accident data are reported to ERNS

when events occur and before the information is verified.9 As a result, at

the time of reporting, it may be unclear how many casualties resulted, the

extent of economic damage, or the types of chemicals involved. Duplicate

reports may also exist within ERNS, estimated at 5 percent of the total

cases.

The ARIP database depicts a limited subset of accidents.10 Cases meeting

specific criteria are included, but the vast majority of cases are excluded,

and the cases included are not statistically representative of all accident

cases.

At one point, ARIP was not updated on a timely basis. Until July 1995, the

most recent data that could be accessed from ARIP were from 1993. As

noted by an EPA official, contractual problems involving a private company

delayed the updating of the database, which generally maintains a 6-month

to 1-year lag time. However, according to EPA, that problem has now been

resolved.

The AHE database, compiled from secondary sources, has not been

verified. EPA cautions that such sources are particularly prone to error.

8

Companies generally produce a mix of product types. Different products utilize different types of

chemicals, and the “product mix” changes over time. Assuming that chemical types are associated with

varied levels of accident risk, an increase in the use of certain chemicals may result in a greater risk of

an accident. Currently available accident data do not account for the extent of product mix.

9

EPA has noted that ERNS does have the capability to capture follow-up information on releases and

spills, but more resources would be required to collect such information. Currently, parties

responsible for incidents are not required to report updated data.

10Generally, accidents are included if significant off-site impact (death, injury, evacuations,

shelter-in-place) or environmental damage (wildlife kills, significant vegetation damage, soil

contamination, ground and surface water contamination) occur.

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Appendix I 

Trends and Impact of Accident Occurrence

Furthermore, the AHE database covers only a 5-year time frame, and it is no

longer active.

The HMIS database is limited to the information that a transportation

carrier has knowledge of and reports. In some cases, information on

chemicals may be destroyed during the events surrounding the accident,

and according to a DOT official, a driver or train operator may not know

what materials are being shipped. Furthermore, DOT has no assurance that

it is receiving all accident reports as the reporting burden is placed upon

carriers.

Page 31 GAO/PEMD-96-3 Chemical Accident Safety
Appendix II 

Chemical Accident Preparedness

The national strategy on chemical accident safety policy depends heavily

on local communities to prepare for chemical accidents. EPA provides

resources aimed at furthering the mission of this strategy. Generally

stated, EPA depends upon Local Emergency Planning Committees to

prepare communities for chemical accidents and, in turn, provides

assistance to them. EPA provides various tools, publications, and technical

assistance to LEPCs. However, as noted in a recent national survey of LEPC

members, many of them are unfamiliar with these resources.1 For

example, one-third of LEPC members are unfamiliar with the software

system that is used to map accident hazards, and nearly 30 percent of the

LEPC members are unfamiliar with the most well-known EPA publications,

such as NRT1 Planning Book, Green Book and Chemicals in the

Community.

2

 Other publications, such as Managing Chemicals Safely,

Opportunities and Challenges, and Making It Work have even lower

familiarity ratings.

Local Emergency Planning Committees are required to maintain a number

of functions. They must

• have a chairperson,

• have an emergency coordinator,

• have an information coordinator,

• have members representing local interest groups,

• hold formal public meetings,

• advertise meetings to the public,

• design an emergency response plan,

• have a plan incorporating at least nine key elements, and

• review the plan once a year.

The 1994 survey of LEPCs found that these organizations, generally, have

filled the leadership positions, held meetings, maintained committee

membership, and correctly developed and maintained their emergency

plans. However, the study found that public communications mandates are

not followed to a significant extent. For example, less than half of the

LEPCs publish newspaper notices of the public availability of their

emergency plans, and only 70 percent of them advertise meetings to the

public. The study also found that rural and small town LEPCs tend to be

quite inactive and could profit from additional resources and guidance.

1

Nationwide LEPC Survey, GWU (Oct. 1994).

2

The software system is Computer Aided Management of Emergency Operations (CAMEO).

Page 32 GAO/PEMD-96-3 Chemical Accident Safety
Appendix II 

Chemical Accident Preparedness

A study from Tufts University reported that LEPC communication with the

public was passive and unidirectional; only modest attempts were made to

facilitate citizen understanding of title III data on chemical hazards.3

 One

impetus for the passage of EPCRA was the lack of public knowledge about

chemical accident safety issues, so this finding suggests that such

knowledge could still be limited.

The partnership of EPA and local communities in supporting local

preparedness activities is not very strong or consistent. To be effective,

local accident preparedness depends upon effective communication

between EPA, local and state agencies and departments, and the public.

Federal law places a significant responsibility upon LEPCs to prepare

communities for chemical accidents, but the LEPCs have not sufficiently

communicated the risks associated with such accidents to the public. As a

lead federal agency with responsibilities in accident response, EPA has a

large role in ensuring that the federal-local relationship works properly. To

examine how these linkages could be improved, EPA sought the advice of

experts in the field. These experts have suggested that EPA should bolster

its efforts to assist the LEPCs in carrying out the requirements of title III of

the Superfund Amendments and Reauthorization Act (SARA).4

 They

suggested that EPA take an active role in evaluating LEPC performance, in

assisting LEPCs in identifying possible funding sources, and in assessing the

extent to which LEPCs have utilized information. Overall, the participants

stressed the growing importance of LEPCs in managing chemical accident

risk, especially as industry is required to develop Risk Management Plans

in accordance with the Clean Air Act Amendments of 1990.

Despite these weaknesses, nearly 80 percent of LEPCs are functioning and

do execute many of their main responsibilities. Of these functioning LEPCs,

a majority have filled their leadership positions and committee

appointments. In addition, most hold regularly scheduled meetings and

have completed and submitted emergency response plans to the

appropriate State Emergency Response Commission, which serves as a

link between LEPCs and EPA.

5

3

Risk Communication and Community Right-To-Know: A Four Community Study of SARA Title III,

Tufts University Center for Environmental Management (Mar. 1991).

4

The Future of Local Emergency Planning Committees: Report of a September 13-14, 1993 Meeting.

Session sponsored by the Center for Risk Management at Resources for the Future, Washington, D.C.

(The 30 participants represented federal, state, and local government, labor unions, the press, LEPCs,

and State Emergency Response Commissions [SERCs].)

5

These commissions have the authority and resources necessary to implement federal law for chemical

accident preparedness.

Page 33 GAO/PEMD-96-3 Chemical Accident Safety
Appendix II 

Chemical Accident Preparedness

Despite the relative weakness of the LEPCs in communicating the risks of

accidents to the public, EPA has made accident data from ERNS available to

the public, industry, and governmental agencies through three different

methods. ERNS data can be obtained by contacting the manager of the

database, by calling an information line, or by accessing the Internet.

Page 34 GAO/PEMD-96-3 Chemical Accident Safety
Appendix III 

Accident Case Study Descriptions

Below, we present detailed information about the accident cases

examined for this report. Cases 1 through 3 involve fixed facilities, while

cases 4 through 6 are transportation accidents.

Fixed-Facility

Accidents

Case 1 In summer 1993, a building exploded at a chemical plant in Elyria, Ohio.

This plant produces organic peroxides used as catalysts in plastic

production. These peroxides are highly flammable and very reactive. The

explosion occurred as workers combined two chemicals, which ruptured

two tanks of sulfuric acid. The accident was caused by an overheated

pump that went dry and ignited a nearby chemical tank. A fire followed

the explosion and burned down the building and an adjacent one. Local

and state officials were immediately dispatched to the scene. About 30

minutes after the first explosion, a second one occurred, severely

damaging another building in the same plant.

A chemical cloud was released after the explosions, and several thousand

area residents were evacuated from area neighborhoods.1

 The chemical

cloud resulted from the release of two chemicals from ruptured supply

pipes. Although no deaths resulted from the incident, approximately 75

people were treated for minor respiratory difficulties and acid vapor

burns.

The EPA on-scene coordinator and technical assistance team arrived on the

site within 5 hours of the first explosion.2

 At the time of their arrival, the

chemical cloud was drifting in a northern direction, toward a housing

development. The EPA official and technical assistance team monitored the

air, and results suggested that area residents were not in danger. Within 10

hours of the first explosion, the fire was extinguished and no

contaminants were found in the air. Cleanup efforts began, and residents

were allowed to return to their homes.

1

Estimates range from 4,000 to 7,000.

2

The teams are comprised of EPA contractors that assist in emergency response functions, such as

sampling and monitoring.

Page 35 GAO/PEMD-96-3 Chemical Accident Safety
Appendix III 

Accident Case Study Descriptions

Case 2 In spring 1994, an explosion occurred in a plant processing area at a large

petroleum plant in Bel Pre, Ohio, and three employees were killed. It

caused two buildings and a tank farm to catch fire.

Several EPA regions became involved in the response effort. Within 2 hours

of the incident, the EPA on-scene coordinator arranged for a technical

assistance team to fly over the area to assess the situation. The team

discovered that several 300,000-gallon styrene tanks were on fire, with

flames shooting as high as 400 feet. Foam was used in an attempt to

suppress the fires.

Additional technical assistance teams were dispatched by the EPA staff.

The smoke plume was observed approximately 25 miles north of the

accident site. However, evacuation efforts were limited to the immediate

area, where 1,500 people were temporarily displaced.

Within 8 hours of the incident, significant progress had been made in

extinguishing the fires. Air monitoring continued until most of the fires

had been contained, while water sampling continued for several more

hours. Samples were submitted for analysis.

Case 3 In summer 1994, an explosion occurred at a chemical manufacturing plant

in Bristol Township, Pennsylvania. Local responders arrived within a few

minutes and found heavy smoke and employees trapped inside. Within 30

minutes, the county hazardous materials team was requested to respond,

and the county emergency management coordinator was en route to the

scene. Approximately 150 area residents were evacuated.

Within 2 hours, all victims were removed; these included three employees

of the plant who were injured. Forty others were taken to the hospital as a

precaution. Within 2 hours, EPA officials and contractors had begun to

monitor the air and water quality. EPA was assisted by the U.S. Coast

Guard and county officials. The incident did not escalate beyond the initial

explosion and fire, although the scene was secured by the local

responders for 2 days.

Page 36 GAO/PEMD-96-3 Chemical Accident Safety
Appendix III 

Accident Case Study Descriptions

Transportation

Accidents

Case 4 In spring 1994, an 18-wheel tractor-trailer truck carrying a large quantity of

the chemical aldicard veered off the road, struck a highway sign, and

caught fire. This accident, which occurred in a suburb of Dallas, killed the

driver of the vehicle. No other casualties were reported.

An EPA regional office, in the vicinity of the accident, received word of the

accident through media reports. Within 2 hours, an EPA on-scene

coordinator and technical assistance team were at the site conducting

monitoring activities. These officials worked with state, county, and local

officials to contain the accident.

Because of a toxic plume, city fire department officials evacuated at least

5,000 residents downwind of the site. Early the next day, sampling results

confirmed that no danger existed for the area, so the evacuation order was

lifted.

Case 5 Early in 1994, a freight train derailed in Fremont, California. Because of

poor lubrication, the railcars were unable to negotiate a curve and the

train derailed. The derailed cars struck a large beam and two containers of

hazardous materials fell into an adjacent creek, which serves as a source

of drinking water for area residents. One of the containers caught fire and

burned for several hours. An estimated 3 million gallons of water were

contaminated. Within 4 hours, an EPA on-scene coordinator arrived and

met with the local responders. Several other government officials were

involved in the case, including state, county, and federal responders in

addition to EPA. A railway representative was also on-site. No injuries were

reported.

Within 10 hours, the fire burned out. The responders implemented a plan

to flush the contaminated water into the sewer. Within 2 days, the

sampling of surface water revealed no detection of chemicals.

Groundwater was sampled for a much longer period of time; by the end of

the third month, the concentration of chemicals was below the maximum

contaminant levels for drinking water.

Page 37 GAO/PEMD-96-3 Chemical Accident Safety
Appendix III 

Accident Case Study Descriptions

Case 6 In spring 1994, a dump truck collided with a gasoline tanker in Montville,

Connecticut. The dump truck gouged a large hole in one of the gasoline

tanker’s fuel compartments. The accident caused an explosion and fire,

resulting in the death of the dump truck driver and injuries to five people.

Two of the injured were hospitalized. Several homes and a small motel

were evacuated. The escaped gasoline went into a brook and ignited,

burning about half an acre of wetlands. Several telephone poles and utility

lines were burned down, and five other vehicles were severely damaged.

Several area fire departments responded quickly, and the fire was

extinguished within 2-1/2 hours. Later, state officials arrived to supervise

cleanup operations. Early the next morning, an EPA on-scene coordinator

arrived along with a technical assistance team. Groundwater and air

monitoring was initiated, and the tests indicated no contamination.

However, the soil was contaminated; it was excavated and replaced with

clean soil within 2 days of the accident.

Page 38 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

This appendix provides an elaboration on EPA’s accident prevention

activities. These activities include a review of emergency systems, ARIP and

CSA Program, process safety management, and outreach efforts conducted

by the agency.

Emergency Systems

Review

Before the enactment of the Clean Air Act Amendments of 1990, EPA

conducted a review of emergency systems used to monitor, detect, and

prevent chemical accidents.1

 The review focused on 21 chemicals chosen

from the list of extremely hazardous substances developed under SARA.

2

 A

panel of experts reviewed the preliminary findings and made suggestions.

The findings and recommendations were submitted to the states for

comment and were also reviewed by officials from industry, trade

associations, other Federal agencies, and environmental interest groups.

EPA found that prevention of chemical accidents requires a comprehensive,

integrated approach. Such an approach must consider the hazards of the

chemicals in question, the process’ hazards, the capabilities of the site’s

personnel, and the possible impact on the community.

A comprehensive approach requires that management be committed to

installing, maintaining, and updating appropriate technologies and

providing personnel training. In addition, the facility should be involved

with the local community, with industry, and with professional groups in

order to show its commitment to safety. These findings were consistent

with those of industry and professional organizations, including the

Chemical Manufacturers Association, American Petroleum Institute, and

the Center for Chemical Process Safety.3

 On the basis of this report, EPA

recommended that industry take the primary responsibility for preventing

accidents and ensuring the safety of its workers and the public health of

the community. In addition, a recommendation was made to form a

Chemical Accident Prevention advisory committee to develop a strategy

for implementing the prevention of chemical accidents.

1

See Review of Emergency Systems, Report to Congress, Section 305(b) Title III Superfund

Amendments and Reauthorization Act of 1986, EPA Office of Solid Waste and Emergency Response

(June 1988).

2

In order to begin identifying facilities to be covered by the new SARA requirements, EPA was directed

to develop a list of extremely hazardous substances. Facilities using certain threshold quantities of

such substances are covered.

3

In addition to EPA’s programs, private industry has established various initiatives geared toward

accident prevention. The Chemical Manufacturers’ Association, a trade group representing the

chemical industry, utilizes their “Responsible CARE” program to promote safe chemical

manufacturing, transportation, and disposal. The American Petroleum Institute, through the

“Strategies for Today’s Environmental Partnership” program, promotes the reduction of accidental

petroleum spills, fires, and explosions.

Page 39 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

The emergency systems review study (completed in 1988) recommended

that LEPCs increase public awareness of accident prevention issues.

However, as discussed in the letter, studies of LEPCs completed as recently

as 1994 find that accident risk issues are not well communicated to

community residents. Placing accident prevention responsibilities upon

industry does not complete the other important link of community

involvement. Such an approach to accident prevention is less likely to be

effective if risks are not communicated to the public.

ARIP and CSA

Program

Accidental Release

Information Program

Both ARIP and the CSA Program are based on findings from the emergency

systems review. ARIP focuses on accident prevention by collecting data on

the causes of accidents, and the CSA Program is used to encourage

accident prevention and identify problem areas that may result in

accidents.4 ARIP is an information collection tool begun by EPA in 1986 to

obtain data on accidents so that past history could be used to prevent such

incidents in the future. As noted by EPA, this program is designed to serve

many purposes, including

• Identifying problems (that is, facilities showing a persistent pattern of

small releases that may foreshadow more severe future releases) and

alerting facility management to the problem;

• Heightening corporate awareness and involvement in preventing

accidental releases through a thought-provoking questionnaire;5

 and

• Providing LEPCs and SERCs with important information useful both in

preparing emergency response plans mandated by title III and in working

with facilities to reduce hazards through prevention.6

As EPA has recently noted, ARIP provides significant information in the risk

management planning process required by the Clean Air Act Amendments

4

In addition, EPA maintains an oil pollution prevention team, which is charged with preventing

petroleum accidents in underground storage tanks.

5

EPA sends ARIP questionnaires to facilities that report significant or frequent releases to the National

Response Center, if these releases fit under the confines of the program.

6

See Why Accidents Occur: Insights From the Accidental Release Information Program, EPA Office of

Solid Waste and Emergency Response (July 1989).

Page 40 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

of 1990. To that end, ARIP serves to provide data in the development of risk

management plans for accident prevention.

With ARIP, information on the causes of serious accidents and preventive

practices before and after an accidental release is collected. ARIP includes

information on the most serious or potentially serious releases.7

 Generally,

accidents are included if significant off-site impact (death, injury,

evacuations) or environmental damage (wildlife kills, significant

vegetation damage, soil contamination, ground and surface water

contamination) occurs.8 ARIP information is combined into a national

database, and analyses are disseminated to personnel involved in chemical

accident activities in industry, in EPA regional offices, and in the

community. The ARIP database contains information on approximately

4,700 serious chemical incidents that have occurred since 1987. The

overall response rate to the questionnaire is nearly 100 percent.

After identifying an incident that meets the criteria, EPA sends a

questionnaire to the facility, requesting the following information: the

chemical and amount released; the environmental media affected; and the

number of injuries, evacuations, and deaths.9

 In addition, information is

gathered on the duration of the release, the conditions preceding the

release, the existence of any hazard assessment, and actions taken to

prevent a recurrence.

EPA distributes bulletins to state and local officials that present ARIP data.

This information includes discussions of accident causes and the steps

taken to prevent them. EPA regions use ARIP data as one of the bases for

selecting facilities for the Chemical Safety Audit Program (see below).

Finally, analyses of ARIP have also been used to set policy and prepare

legislation. For example, ARIP data were used by EPA headquarters to

prepare the list of facilities that will be required to comply with the Risk

Management Plans mandated under the Clean Air Act Amendments of

1990, section 112(r).

7

ARIP is intended to include reported incidents of CERCLA hazardous substances or EPCRA

extremely hazardous chemicals. Further details on ARIP can be found in EPA’s Federal Authorities for

Hazardous Materials Accident Safety (Dec. 1993).

8

See Accidental Release Information Program (ARIP) Fact Sheet, EPA (Nov. 1993).

9

Facilities are initially identified from data provided to ERNS.

Page 41 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

Since no other accident databases provide comprehensive information on

the causes of accidents, EPA relies heavily on ARIP to help meet its

prevention responsibilities. EPA refers to the program as “the best available

database on the causes of, and means of preventing, chemical accidents.”10

The Accidental Release Information Program exhibits three major

limitations in furthering the EPA accident prevention goals. The first

limitation is the fairly narrow scope of the program. The database includes

only a limited subset of accidents. Reports are biased toward larger, more

severe, and more frequent releases.11 While these requirements include

“extremely hazardous” substances, some problematic chemicals are still

ignored, increasing the accident vulnerability of industries with less

common production processes. For example, accidents associated with

flammable or petroleum products are excluded. As noted above, one of the

purposes of ARIP is to uncover national trends of accidentally released

chemicals and how they happen. However, since ARIP exclusively focuses

on serious releases, any national trends in accidents that may be

widespread but that are not considered “serious” will not be documented.

EPA has noted that ARIP is not designed to obtain national trends on

accident occurrence. In addition, no other databases provide trend

information. We believe that this greatly limits the extent to which

accident occurrence can be understood.

The second limitation stems from the point, noted above, that a major

purpose of ARIP is to provide information for Local Emergency Planning

Committees to use to promote accident prevention by industry. However,

LEPCs are quite weak in carrying out their public communications

responsibilities. The Community Right-To-Know provisions of SARA title III

provide the mechanism to increase the public’s awareness of chemical

hazards, thereby encouraging community involvement in responding to

and preventing chemical accidents by, for example, lobbying industry to

take the necessary preventive steps.12 However, three major studies have

shown fairly weak communications between LEPCs and the community.13

10Why Accidents Occur (July 1989), p. 13.

11EPA has noted that ARIP’s bias toward more serious releases is intentional. Agency resources do not

allow smaller events to be included, therefore larger accidents are surveyed to maximize the amount

of information obtained from each facility.

12As a result of the Community Right-To-Know provisions, information on toxic chemicals is made

available to the public. These provisions authorize public involvement in emergency response

planning. They require that the public have access to data that allows them to take appropriate actions.

13See Communicating With the Public About Hazardous Materials: An Examination of Local Practice,

EPA (Apr. 1990); Risk Communication and Community Right-To-Know, Tufts University (Mar. 1991);

and Nationwide LEPC Survey, GWU (Oct. 1994).

Page 42 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

With such weak linkages, the public is unlikely to be aware of the

important prevention data gathered by ARIP, especially given the reliance

that EPA has on the program to promote accident prevention. However, as

EPA has noted, the risk management planning process requires the use of

accident history data that may be used to encourage local action on

accident hazards.

Finally, on at least one occasion, data gathered for ARIP were not updated

on a timely basis. Because of organizational difficulties, the lag time in

obtaining the data can be as great as or longer than 1 year. Until July 1995,

the most recent data for ARIP were from 1993, limiting the extent to which

new information on accident prevention can be quickly disseminated.

Recently, however, this situation has been corrected, and the data are

being updated regularly. Furthermore, EPA is providing accident data

online through the Internet.

Chemical Safety Audit

Program

The Chemical Safety Audit Program was started by EPA in 1988 as a means

of identifying the causes of accidental releases of hazardous chemicals and

ways to prevent them. The program seeks to obtain information about

industrial safety practices; promote safety awareness among industry;

share safety information with communities, companies, and other

interested groups; and develop a database with the results of safety

audits.14

Under CERCLA, EPA has the authority to enter a facility and obtain

information. Between the beginning of fiscal year 1989 (the beginning of

the CSA Program) and the close of fiscal year 1994, EPA had undertaken 281

chemical safety audits and completed 270 audit reports and was

conducting as many audits as agency resources allowed.15 Audit teams

have reviewed more than 175 hazardous chemicals, including 159 CERCLA

hazardous substances and 69 listed in EPCRA as extremely hazardous

substances.

An important element of the CSA Program is the development of personnel

with the expertise to conduct safety audits. EPA has trained about 800

people in the analysis of process hazards, standard operating procedures,

prevention and mitigation systems, safety audits, incident investigation,

and interview techniques. These training sessions include EPA personnel as

14See Chemical Safety Audit Program: FY 1994 Status Report, EPA (May 1995).

15An EPA official stated that agency resources allow approximately 60 safety audits to be completed

each year.

Page 43 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

well as state and local staff.16 Audited facilities are selected in various

ways; EPA does not require regions to select audit sites in a prescribed

manner.17 Selection factors, to a certain extent, depend on the priorities of

the region.18 Nationwide, about 50 percent of the facilities targeted are

identified through the ARIP database because of their history of accidental

releases. Proximity to sensitive populations, high population density, or an

industry’s concentration in an area are also considered in the selection of

audit sites. EPA regional offices may target certain processes or chemicals.

Furthermore, an audit might be initiated at the request of a citizen or state

or local government or from other agency referrals.

The audit entails a review of facility process characteristics, emergency

planning and preparedness activities, hazard evaluation, release detection

techniques, and several other areas. In particular, the facility’s community

emergency response planning procedures for public notification of

releases are studied.19

Results of the audit are detailed in a report that is available to other

facilities, trade associations, community groups, and state and local

officials. Weaknesses as well as strengths in preventive practices (both

operational and managerial) are discussed, along with recommendations

for improvement.

Facilities are also chosen for audit under the CSA Program based on public

requests and local concern. For example, citizens in a community can

work through their LEPC to request an EPA audit. This procedure is

authorized under the Community Right-To-Know provisions of SARA title

III. However, citizens are unlikely to realize the risks associated with

facilities in their communities, and LEPCs are not very effective in

promoting the availability of this information. As noted in a recent study,

most functioning LEPCs receive few inquiries from community residents.20

16This program is designed to develop chemical safety audit expertise both within and outside EPA,

although only EPA staff are authorized to enter facilities.

17There are two important requirements for audit site selection: (1) A facility may be entered only if

there has been a release outside facility walls, or if there is “reason to believe” that there is a threat of

a release of a CERCLA hazardous substance; and (2) A facility with pending or active legal actions

against it must be identified through the Office of the Regional Counsel and the SERC to ensure that an

audit would not interfere with such actions. (See Chemical Safety Audit Program [May 1995].)

18For example, EPA Region 6 (which includes Texas, Oklahoma, Arkansas, New Mexico, and

Louisiana) has concentrated on facilities on the gulf coast because of their potential for incidents

associated with natural disasters such as hurricanes.

19The Chemical Emergency Preparedness and Prevention Office has provided regions with a Guidance

Manual for EPA Chemical Safety Audit Team Members (June 1993), which details the elements of the

audit and has a framework for the report.

20Nationwide LEPC Survey, GWU (Oct. 1994).

Page 44 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

During a 12-month period (June 1993-June 1994), more than 40 percent of

the LEPCs received no inquiries, while only a quarter received more than

six. This apparent lack of public concern can result in fewer requests for

audits, which may limit EPA’s effectiveness.

EPA makes presentations to trade associations and other industry groups,

community groups, and state and local officials on the lessons learned

from the CSA Program. However, an EPA official told us that only about 20

such presentations are made each year, which limits the exposure of this

information.

EPA follows up on some, but not all, of the safety audits. According to an

EPA official, of the 10 EPA regions, five conduct follow-up procedures to

some extent, although only three of these conduct this activity extensively.

As a result, only about 20 percent of cases are followed up, and the EPA

official estimates that 80 percent of audited recommendations in these

cases are implemented. While some follow-up does occur, EPA has no

formal mechanism to ensure feedback from facilities on their adoption of

EPA recommendations. Facility compliance with recommendations is, for

the most part, voluntary, so there is no assurance that they will be

implemented.21

Process Safety

Management

Process safety management is used to identify the potential risks at a

facility and establish a systematic method for reducing those risks. EPA has

incorporated this approach in the risk management planning regulations

issued under the Clean Air Act Amendments of 1990. EPA believes that

process safety management, over time, will improve facility safety. The

agency envisions implementation of the program as a philosophy that must

be embraced by both management and workers.22 Although the chemical

safety management program may vary from facility to facility, all programs

perform the following:

• Take an inventory of hazardous materials at the site;

• Review the entire production process;

• Undertake studies to identify potential hazards, to assess the likelihood of

accidents, to evaluate their potential consequences, and to address the

serious problems first;

• Establish and follow a regular program of preventive maintenance;

21However, if serious problems are found during the audit, EPA has sufficient authority to remedy

them.

22See Managing Chemicals Safely, EPA (March 1992).

Page 45 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

• Develop standard operating procedures and training programs for

employees;

• Manage changes in the operation so that accidents do not occur as a result

of changes;

• Investigate and document accidents and near-accidents;

• Develop emergency response plans and coordinate them with local

emergency planners; and

• Share information with the local community.

Many of these components of chemical safety management already exist in

some facilities (such as training); the idea of chemical safety management

is to bring them together into a coordinated policy strongly supported by

top management.

EPA provides funding to the American Institute of Chemical Engineers’

Center for Chemical Process Safety to conduct projects on process safety

management. This center has representatives from 80 companies

worldwide.

As stated previously, accident prevention activities undertaken by industry

become more effective through strong communication links between

industry, LEPCs, and community residents. Industry’s commitment to

process safety management and communication of risks along with public

participation in understanding and acting on the risks are essential.

EPA Outreach Efforts As noted in a recent study commissioned by EPA, gaps in information

severely limit firms’ ability to prevent accidents.23 According to this study,

firms tend to lack information on the hazards inherent in current

production processes, the alternative technologies that would lessen

accident risk, and the costs of serious accidents. However, EPA has been

conducting a number of outreach efforts designed to better inform

industry about the hazards essential to accident prevention. For example,

the agency has produced documents for industry that provide technical

guidance for hazard assessment, chemical profiles, and

information-sharing requirements.

In addition, the agency conducts special studies of chemicals and writes

advisories that are distributed to the LEPCs. A recent example of this

practice is the Hydrogen Fluoride Study (on a widely used and highly toxic

23See The Encouragement of Technological Change for Preventing Chemical Accidents, MIT

(July 1993).

Page 46 GAO/PEMD-96-3 Chemical Accident Safety
Appendix IV 

EPA Prevention Activities

and corrosive substance) reported to Congress in 1993. EPA found that

accidental releases of this chemical can be prevented through process

safety management principles and recommended that facilities handling

this substance work closely with the LEPCs to increase public awareness

for adequate emergency response. This report also was distributed to all

industries that use this chemical (about 500 facilities).

The agency also works with organizations such as the Center for Chemical

Process Safety, an association of 80 chemical companies worldwide. EPA

provides the Center with funding to do special projects such as a primer

for LEPCs and a book on putting process safety management in

nontechnical language. In addition, EPA works closely with the American

Institute of Chemical Engineers, which provides technical resources to the

agency. Other EPA prevention activities include funding university studies

and working with small businesses that have little knowledge of

chemicals. EPA advises them on the safe management of hazardous

substances.

Page 47 GAO/PEMD-96-3 Chemical Accident Safety
Appendix V 

Major Contributors to This Report

Program Evaluation

and Methodology

Division

Marcia G. Crosse, Assistant Director

Lawrence S. Solomon, Senior Evaluator

Nila Garces-Osorio, Social Science Analyst

Robert E. White, Project Adviser

Venkareddy Chennareddy, Referencer

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