The following piece is written by Isaac Lello-Smith, a student at Cornell University and a BlueGreen Alliance intern. It is part of his testimony at a U.S. Environmental Protection Agency (EPA) hearing today in support of changes to the agency’s Risk Management Program that are designed to protect workers, first responders and communities around industrial chemical facilities.
I trust the EPA to protect the fundamental right of all Americans to a healthy environment. I feel that the Risk Management Program (RMP) is a particularly important element of the EPA’s larger function, and I urge you not to delay the implementation of the modified Risk Management Program rule.
Back at Cornell, I do a lot of work in outdoor education bringing people together to build functioning teams. I’d like to draw from my team-building experience to explain why I think the amended Risk Management Program is common sense and should be implemented immediately.
First, let’s treat the EPA, chemical facility workers, first responders, emergency planning committees and community members as a team. We’ll assume that everyone involved wants to keep everyone else safe.
A logical first question for the team is: are we doing a good job keeping people safe? Over the last 10 years, there have been at least 58 deaths, 17,000 injuries, and 500,000 evacuations and shelter-in-place orders resulting from accidents at chemical plants reporting to the RMP. This team must do better.
The next step is to figure out how we can improve. If I come across a non-functioning team, nine times out of ten, it’s because its members need to communicate more openly and effectively with one another. As I understand it, that is precisely the purpose of the modified RMP rule—to increase communication and coordination between RMP facilities, Local Emergency Planning Committees and emergency responders, in part through the secure exchange of information about facilities and response capacities.
In outdoor education, when a team fails to meet its goals, we debrief as soon as possible about what when wrong, and how we can do better in the future. I see a direct parallel to the incident investigation and root cause analysis portion of the RMP rule. If something went wrong, or came close to going wrong, facilities work to identify how a similar error could be avoided in the future.
A logical first question for the team is: are we doing a good job keeping people safe? Over the last 10 years, there have been at least 58 deaths, 17,000 injuries, and 500,000 evacuations and shelter-in-place orders resulting from accidents at chemical plants reporting to the RMP. This team must do better.
Finally, in outdoor education, we greatly value listening, because self-feedback is notoriously unreliable. Enter independent third-parties and compliance audits. If there has been a reportable accident, or an implementing agency suspects that the facility is in danger of an accident, it is critical that an expert independent party review the facility conditions, procedures and practices.
Each of these aspects of the Risk Management Program rule is common sense and should not be delayed. This is one team that cannot afford to make preventable mistakes.