Under EPCRA, facilities that maintain specified quantities of certain hazardous chemicals are required to annually submit chemical inventory forms to state and local emergency response officials to help them prepare for and respond to chemical incidents. The information to be provided includes (1) an estimated range of the maximum amount of specified hazardous chemicals present at the facility at any time during the preceding calendar year, (2) an estimated range of the average amount of these chemicals present daily, and (3) the location in the facility of the specified chemicals. Inventory forms are required for approximately 500,000 materials. See appendix II for an example of a chemical inventory form. Additionally, EPCRA requires the formation of local emergency planning committees whose members include, at a minimum, local police, fire, civil defense, public health, environmental, and transportation officials, as well as representatives of facilities subject to the emergency planning requirements, community groups, and the media. There are approximately 3,500 local emergency planning committees across the nation. Under the act, the committees are required to develop and periodically review emergency response plans for their communities that, among other things, identify chemical facilities and outline procedures for response personnel to follow in the event of a chemical incident. The chemical facilities are required to supply emergency response information to the local emergency planning committee for incorporation into the emergency response plans. While this report does not specifically address them, EPCRA also has other provisions designed to provide local responders with information about chemical hazards. For example, facilities must notify local responders if there is a release of a specified quantity of certain hazardous substances, and facilities must submit to EPA a toxic chemical release inventory covering releases that occurred during the preceding calendar year. Under the Clean Air Act, chemical facilities maintaining more than a specified amount of a regulated substance must register risk management plans with EPA headquarters at least every 5 years. Regulated substances include 77 toxic substances, such as ammonia and chlorine, and 63 flammable substances, such as butane and hydrogen. A risk management plan includes documentation that the facility has (1) completed a hazard assessment that incorporates a 5-year accident history, by substance by site, and an evaluation of potential consequences to surrounding communities of chemical releases that includes the worst-case scenario; (2) developed a prevention program that includes facility safety precautions and maintenance, monitoring, and employee training measures; and (3) developed a response program that outlines emergency health care procedures, employee training measures, and procedures for informing the public and local agencies responsible for responding to chemical releases. The act requires that risk management plans be submitted to local agencies or entities responsible for preparing for or responding to chemical releases. EPA’s implementing regulations for risk management plans require chemical facilities to coordinate emergency response plans created under their emergency response programs with community emergency response plans. The members of the emergency response community we contacted have varied views on the adequacy of the information reported in chemical inventory forms and risk management plans and on the manner in which that information is delivered. Most members of the community believe that information provided in chemical inventory forms and risk management plans is adequate to meet the needs of local responders, but some do not share this view. In addition, many members made suggestions to improve the usefulness of the information. Finally, some members of the community question the usefulness of the manner in which the federally required information is delivered. Local responders in most of the communities we contacted believe that the information in the chemical inventory forms and the risk management plans is generally adequate to help them prepare for and respond to chemical incidents. Responders from eight of the communities find the information in the inventory forms to be adequate and said they use it in different ways, such as to identify specific chemicals at facilities, determine the location of stored chemicals, and analyze the potential effects of a chemical release on the surrounding community. Responders from seven communities find the information in risk management plans adequate. Some responders said they use the information in the plans to develop community emergency response plans, one reported using it to develop a “quick action” plan to share with other responders, and others said they use it to conduct planning activities at facilities. Representatives from five national organizations told us they believe the federally required information is generally adequate to help local responders prepare for chemical incidents. Representatives from the American Chemistry Council, the Federal Emergency Management Agency, the National Volunteer Fire Council, and the National Association of State Fire Marshals said that the information in the chemical inventory form is useful and critical in preparing for chemical incidents. They said that the chemical inventory form helps responders by identifying the extent of facilities’ emergency response capabilities. Regarding risk management plans, representatives from the American Chemistry Council and the National Volunteer Fire Council stated that the plans are useful in identifying small facilities that store and use dangerous chemicals, such as chlorine, that were not previously required to report federal information, and in identifying the resources responders would need to respond to chemical incidents. Local responders from a few communities question the adequacy of the information. Local responders from three communities said they have particular concerns about the accuracy and currency of the chemical information they receive. For example, responders from two communities said that they do not know if the information in the risk management plans they receive is accurate and that there is no way to be sure. (As discussed in a subsequent section of this report, because EPA has performed limited verification of risk management plans, the agency does not have a complete picture of the accuracy of most of the plans.) Responders from the third community commented that the information in chemical inventory forms is outdated and that they have found errors in these forms. In addition, local responders from five communities commented that they receive such a large amount of information that it is difficult to manage. Responders from two of these communities stated that the risk management plan is too large to be taken to the scene of an incident and that responders have difficulty locating important information in the plan. As a result, most local responders said they prefer to use the chemical inventory form when responding to a chemical incident. An EPA official stated that the risk management plan was intended to serve many purposes, including providing a community with information to assist in development of an emergency response plan and providing responders with hazard information that might not be available from other sources. However, the agency did not design the risk management plan specifically to be used at the scene of an incident. Regarding the national organizations, four representatives said that the information is not adequate to assist local responders for various reasons. One reason cited was that the information is not current and accurate. For example, the International Fire Marshals Association has concerns about the accuracy of facilities’ analyses of community impacts contained in the risk management plans. Another reason is the large amount of information responders receive. For example, a representative from the National Emergency Management Association said that the risk management plan contains too much information, which makes it difficult for responders to know what information is necessary. In light of the events of September 11, 2001, we asked members of the emergency response community about the adequacy of chemical information to assist them in responding to chemical incidents involving terrorists. The community has diverse opinions about this issue as well. Local responders from six communities believe the chemical information they receive would be adequate to assist them in the event of a chemical incident caused by terrorists. For example, some said that the chemical information that responders need is the same whether an incident is caused accidentally or by a terrorist act. Responders from two communities said they would consider the information adequate if it had been reviewed and found accurate. Finally, responders from two communities said they did not have adequate chemical information to respond to a terrorist incident but did not provide suggestions to improve the information. We also asked national organizations for their opinions on the adequacy of chemical information to help responders in the event of a terrorist incident, and three provided comments. The representative for the Chlorine Institute said that the information is sufficient. A representative from one organization, the National Association of Emergency Medical Technicians, said that the outcomes of accidental and terrorist-related chemical releases would be similar but that the latter may pose additional threats to the responders. A representative from the third organization, the National Emergency Management Association, stated that communication between federal law enforcement agencies and local emergency responders is more important in the event of a terrorist incident than the adequacy of federally required chemical information. Although most of the members of the emergency response community that we contacted said the federally required information was adequate, these members generally want more specific information on more chemicals. Their suggestions included (1) lowering or eliminating the thresholds of hazardous chemicals that trigger the requirement for facilities to report them and expanding the list of chemicals to be reported; (2) changing the focus of the risk management plan from worst-case scenario to probable- case scenario; and (3) requiring chemical facilities to report exact quantities of chemicals, rather than ranges, on the chemical inventory form. Members of the emergency response community also had suggestions, not relating specifically to the federally required chemical information they received, that they believe would improve their ability to respond to chemical incidents. Many members of the emergency response community made suggestions that they believe would improve the quality of the information reported. Local responders from six communities believe that the thresholds for chemical inventory forms and risk management plans are set too high and suggested that EPA revisit this issue for the most dangerous chemicals. A responder from one community stated that all chemicals on the lists of hazardous substances are dangerous and that chemical facilities should report them if they have them in any quantity. Local responders from another community believe that the threshold for petroleum products should be lowered because these products account for the majority of hazardous incidents in their community. Local responders from three communities suggested expanding the list of chemicals required to be reported in chemical inventory forms and risk management plans. For example, responders from one community would like to see mining chemicals regulated. Representatives from several national organizations shared the following concerns: Representatives from the International Association of Fire Fighters commented that the thresholds for reporting hazardous chemicals are set too high. Representatives from the National Volunteer Fire Council suggested that the thresholds should be reviewed on a regular basis.