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RE: 33/50-type and enhanced accident prevention audit program models needed - quickly!



EPA and other agencies (including OSHA, Coast Guard) with
responsibilities for emergency or contingency planning some years ago
agreed that facilities required to do such plans for them did not have
to do separate plans, but could do one integrated contingency plan.  The
intent is for the short, quickly consultable "core plan" of the ICP to
be actually useful in an emergency, and for there not to be six bulky
notebooks on the shelf that don't either prevent or help in response,
but which are there to ensure against a bad report when you get
inspected by the different agencies, and which are duplicative.  

So we promote the integrated and core plan approach, and have put
together outreach events with LEPCs.  One good idea is to have the LEPC
ask the local police to invite all the Tier II reporters.  Fire
department invitations are good, too.  And spread the word that every
citizen is welcome to participate in the LEPC.  Spread the word about
the public nature of Tier II information.  Remember that facilities with
Exhaps HAVE to participate in LEPC community emergency planning.  Use
the argument with businesses that if they aren't prepared, they will
have many costs - some communities charge afterwards for the emergency
trucks coming out.  If you've told them ahead of time enough information
so that they know they can send one truck and not five, you've saved $$.
If you've prevented the incident, $$.  If your preparation limited its
damage and allowed you to start operations up again quickly, $$.

But above all, this is an opportunity to draw attention to the
opportunity for the planning to be preventive, and the fact that the ICP
- and all the required plans (see the language of RCRA in particular) -
specifically call for a preventive approach.  This is where the techical
information on pollution prevention that we have all developed can be
inserted and integrated, so that people can be brought to see that an
emergency response plan that isn't combined with a real P2 effort -
which is like emergency planning at the source - is just not a good
plan.  "If the bomb isn't there in the first place, it can't go off."

We call it Preventive Emergency Planning, despite the unfortunate
acronym it makes.

-----Original Message-----
From: Magnuson.Leif@epamail.epa.gov
[mailto:Magnuson.Leif@epamail.epa.gov] 
Sent: Thursday, March 04, 2004 7:15 PM
To: p2tech@great-lakes.net
Subject: 33/50-type and enhanced accident prevention audit program
models needed - quickly!






Hey P2 techies:

I hope this message finds you well.

I need quick references, please. Ideally websites with reports
describing completed projects with results.

1) Please send me examples of successful 33/50-type programs done in the
last 10 years where a group of industries was challenged to reduce a
target list of chemicals X amt. by year Y.

2) Please send me examples of programs that involved enhanced
safety/accident prevention audits of facilities.

I've a got a community group that wants high risk toxics reduced and
accidents prevented and I am considering recommending these two
approaches.

Thanks.

Best...

Leif Magnuson
Pollution Prevention Coordinator
U.S. EPA Region IX, WST-7
75 Hawthorne St.
San Francisco, CA  94105
(415) 972-3286 Tel
(415) 947-3530 Fax
magnuson.leif@epa.gov
www.epa.gov/region09/p2


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