Volume XIII, Edition 6

June 1, 2013

GATEKEEPER NEWSLETTER
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, Arizona 85008-3495

Lou Trammell, Chair

Janice K. Brewer, Governor
http://www.governor.state.az.us/

http://www.dem.azdema.gov/
Mark Howard, Executive Director
http://www.azserc.org

What NOT to Do When Mercury
Spills:

Inside this
issue:
Federal regulations,
emergency protocols
not followed in West
Questions remain
about McLennan
County's LEPC - News
Channel 25 KXXVTV
How to Ship Manufactured Articles that
Contain Mercury [49
CFR 172.101]:
TRI Reporting of
Hydrogen Sulfide:
Shipping Chemicals?
Not So Fast
PHMSA proposed
rulemaking on inspection of packages and
other matters under
enhanced inspection
program
How to Describe Marine Pollutants on
Shipping Papers [49
CFR 172.203(l)]:

2

•

Never use an ordinary vacuum
cleaner to clean up mercury. The
vacuum will put mercury vapor into
the air and increase exposure. The
4
vacuum will be contaminated and
have to be thrown away.

• Never use a broom to clean up
mercury. It will break the mercury
6 into smaller droplets.
• Never pour mercury down the
drain. It may cause future problems
8 with plumbing repairs, or it could
contaminate the septic tank or sewage treatment plant.
• Never wash mercurycontaminated items in a washing
machine. The machine and the discharged water may become contaminated.
12 Never walk around if your shoes
may be contaminated with mercury. This will spread the contamination.
Mercury Recycling and Disposal
14 Options
10

Under RCRA, some widely generated hazardous wastes, including
mercury-containing wastes like certain spent batteries, thermostats, barometers, manometers, temperature
and pressure gauges, certain switches
and light bulbs, are designated as
"universal wastes." Businesses and

industries that qualify as universal waste handlers must follow specific requirements for
storing, transporting and disposing of these wastes. Households are exempt from these
regulations.
Note that some states and local
jurisdictions have elected to
pass regulations that are more
stringent than the federal hazardous waste regulations. Several states and municipalities do
not recognize the exemption for
households; others regulate all
fluorescent bulbs as hazardous,
regardless of their mercury
content. For example, Vermont
bans all mercury-containing
waste from landfills, including
mercury-containing waste generated by households.
Why Is Mercury a Concern?
Mercury in the air eventually
settles into water or onto land,
where it can be washed into
water. Once deposited, certain
microorganisms can change it
into methylmercury, a highly
toxic form that builds up in
fish, shellfish, and animals that
eat fish. Fish and shellfish are
the main sources of methylmercury exposure to humans. Me-

thylmercury builds up more in
some types of fish and shellfish
than others. The levels of methylmercury in fish and shellfish
depend on what they eat, how
long they live, and how high they
are in the food chain.
EPA works with the FDA and
with states and tribes to issue
advice to women who may become pregnant, pregnant women,
nursing mothers and parents of
young children about how often
they should eat certain types of
commercially-caught fish and
shellfish. Fish advisories are also
issued for men, women, and children of all ages when appropriate. In addition, EPA releases an
annual summary of information
on locally-issued fish advisories
and safe-eating guidelines to the
public. Fish is a beneficial part of
the diet, so EPA and FDA encourage people to continue to eat
fish low in methylmercury.
Another less common exposure
to mercury that can be a concern
is breathing mercury vapor.
These exposures can occur when
elemental mercury or products
that contain elemental mercury
break and release mercury to the
air, particularly in warm or
poorly-ventilated indoor spaces.

Page 2

LEPC Corner

GATEKEEPER

Federal regulations, emergency protocols not followed in West:
by BRETT SHIPP
WEST, Texas –– McLennan County officials did not follow federal regulations
requiring public officials to plan for a major
chemical incident such as last week's
deadly fertilizer plant explosion in West,
Texas, a News 8 investigation has found.
The finding raises serious questions regarding the decision to send first responders into a potentially explosive situation.
As a community still grieves the 15 killed
in the West Fertilizer Co. explosion, some
are questioning the planning that, according to federal law, was required to have
taken place under the Emergency Planning and Community Right to Know
Act.
Each business is required to report its hazardous chemicals to its county. West Fertilizer Co. had, in fact reported its ammonium nitrate to McLennan County. Next,
officials are required to set up what's
called a Local Emergency Planning Committee.
The LEPC's job, is to "develop an emergency response plan, review it at least annually, and provide information about
chemicals in the community to the citizens," the act reads.
"We usually meet once or twice a year,"
said Steve Howie, the Emergency Management Coordinator of Kaufman County.
Howie heads the Kaufman County LEPC
and said he is familiar with the dangers of
ammonium nitrate. A fertilizer storage
company similar to the one in West is located near downtown Terrell. He says
emergency responders in his community

are well aware that a fire in the fertilizer storage building means one
thing.
"If it's in the building housing 50,000
pounds of ammonium nitrate we are
going to evacuate the area and back
off," said Howie.
As of Dec. 31, 2012, there were
540,000 pounds of ammonium nitrate
at the West Fertilizer Co., federal
records show.
In July 2009, Bryan city and fire department officials ordered the
evacuation of almost the entire town
after a building full of
ammonium nitrate caught fire.
The fire chief knew that putting water
on the fire could make it worse "and
in some cases it can intensify to the
point of
exploding."
Richard Brown is a former Kaufman
County volunteer fire chief. He says
news of the fire responders’ death in
West has sickened him.
"It should not have happened,” said
Brown. “Those men should not have
been where they were."
Brown says county and fire officials
should have planned for the worst
and any fire that involves ammonium
nitrate should mean evacuation.
“They needed to inform their men of
the hazards,” said Brown. “They

needed to formulate a written response
plan to those types of hazards."
The federally mandated body of community leaders designed to plan for
such hazards did not exist in McLennan County. The official listed as the
head of the McLennan County LEPC
is County Judge Scott Felton. Felton,
appointed to the post last year, told
News 8 in an interview that he's never
heard of the LEPC.
McLennan County Emergency Operations Coordinator Frank Patterson said
he has no knowledge of an emergency
planning
committee or any meetings with officials in West about potential risks in
the community.
After requesting any evidence of LEPC
operations, meetings, plans of actions
or plans for evacuations, especially
with respect to hazards posed at the
fertilizer company in West, Patterson's
office said no such information exists.
Neither Patterson nor the McLennan
County Judge would speak on camera.
Both say they have been too busy helping the victims of West. The State Fire
Marshal's Office on Friday released a
statement saying no actions taken by
the firefighters in any way contributed
to the explosion.
E-mail bshipp@wfaa.com

Volume XIII, Edition 6

Page 3

PEPCON anniversary serves as reminder: Hazardous
materials emergencies could occur in Clark County
By Tovin Lapan
Twenty-five years ago this week — on
May 4, 1988 — explosions at the Pacific
Engineering Production Company of Nevada tore through the complex, killing two
and injuring more than 300.
A dark column of smoke rose from the
site, where ammonium perchlorate — used
to boost the performance of rocket fuel —
was produced. Debris rained down around
the area. The force of the blasts shattered
windows and doors around Henderson.
Three years after the PEPCON disaster, a
42-ton chlorine leak at Pioneer Chlor Alkali sickened more than 300 people and
led to mass evacuations.
Pioneer was in the Basic Management Inc.
complex, a 5,000-acre county island surrounded by the city of Henderson; PEPCON was situated nearby. A company
originally called Basic Magnesium Inc.
built the first chemical plants on the site in
1942.
The two accidents within three years
prompted county officials, who have jurisdiction over land-use decisions at the site,
to restrict development near the Basic
Management complex to create a buffer to
minimize injuries from any future accidents.
PEPCON eventually rebuilt in Utah. After
the PEPCON blast, Clark County commissioners attempted to encourage development of industrial sites farther away from
population centers, and the Apex site was
developed north of Las Vegas.
Kerr-McGee, a company that also made
ammonium perchlorate did move part of

its operation — the storage and mixing
facility — to a 3,400-acre site at Apex
but left the chemical manufacturing at
the Basic Management site. Ammonium perchlorate production ceased at
the site in 1998.
Today, companies with the largest
quantity of hazardous materials near
large population centers in the Las
Vegas Valley are still in the Basic
Management site or nearby, said Richard Brenner, Clark County Fire Department hazardous materials coordinator.
The site is home to Olin, which bought
the Pioneer facility; Tronox, formerly
part of Kerr-McGee, and Titanium
Metal Corp. The Thatcher Company of
Nevada is situated near the site and
also works with large quantities of
hazardous materials. The potential
danger at the facilities is mostly tied to
the use of chlorine, which can irritate
the respiratory system and eyes and in
larger concentrations cause vomiting,
lung damage and death. Chlorine gas is
a strong oxidizer, which may react
with flammable materials.
In 1986, the federal government passed
the Emergency Planning and Community Right-to-Know Act, which mandated specific measures to help communities plan for emergencies involving hazardous materials, including
establishing emergency response commissions in each state and requiring
certain facilities to cooperate with local

authorities on disaster plans.
Brenner has been working on plans for
hazardous material emergencies for
decades and also is part of the Nevada
State Emergency Response Commission. During his time working for both
Las Vegas and then Clark County, he
has worked with facilities around the
valley to develop emergency plans and
also mitigate the chance of a disaster
by encouraging some companies to use
different chemicals or processes.
"We have plans for everywhere we
know chemicals are stored," Brenner
said. "At Olin, we don't just drive onto
the facility. They meet you at the entrance, and you meet with their safety
people and there is a unified command.
They know the process better than we
do, so we plan together to address an
emergency and get it mitigated."
Brenner said a Henderson Industrial
Council that includes plant managers,
business owners and other community
members meets regularly to talk about
issues regarding the plants.
Here's a look at some of the plants and
other places in the valley where officials have planned for hazardous material emergencies:
Read more: http://
www.lasvegassun.com/news/2013/
may/03/clark-county-hazardousmaterial-sites/#ixzz2TqOn46hb

TRANSCAER® (Transportation Community Awareness and Emergency Response) is a voluntary national outreach effort
that focuses on assisting communities prepare for and respond to a possible hazardous material transportation incident. TRANSCAER® members consist of volunteer representatives from the chemical manufacturing, transportation, distributor, and emergency response industries, as well as the government. Visit: http://www.transcaer.com/state.aspx for more information.

GATEKEEPER

Page 4

Questions remain about McLennan County's
LEPC - News Channel 25 KXXV-TV:
WACO -

conducting drills.

In a special hearing on Wednesday, a state agency testified
before the Homeland Security
and Public Safety Committee,
and said McLennan County
does not have a Local Emergency Planning Committee
(LEPC).

The question was asked
why the West Fertilizer
Company never conducted
disaster drills knowing the
potential hazard.

Thursday, county officials met
with the media to clarify if the
claim was true, but at the end of
the meeting it still wasn't clear
if one exists.
A law by the federal government requires each county to
have a LEPC. The purpose of
the committee is to identify all
potential hazards throughout the
county, and develop a plan by

"I don't know. As many two
tier reports as we get, again,
you know, I don't look at
every single one of them or
read every single one of
them every single content
are passed off on the local
responders," said Frank
Patterson, Waco-McLennan
County Emergency Management Coordinator.
LEPC is part of the WacoMcLennan County Emergency Management team.

Patterson confirmed there is
an LEPC in a statement he
read.
"McLennan County has a
comprehensive emergency
management plan that meets
or exceeds the standards, that
includes response protocols
for all hazards, and we conduct exercise on this various
plans at least three times a
year. Each city is required to
sign off on this plan," Patterson said.
Patterson was also asked for
proof of the LEPC and if he
could name the chairman of
the committee.

Patterson said.
At the end, he was asked if
he understood the roles of
the LEPC, and he was told
by a county commissioner
he didn't have to answer
that question.
Patterson was asked on
Thursday afternoon if he
had any evidence a LEPC
existed, the evidence he
had on him were the minutes from past meetings
which are supposedly held
once a year. There are still
some questions to be answered
Thanks to Tim Gablehouse.

"I'd have to go and pull out
the minutes and find out,"

CAMEO Companion is now available for printing please contact:
State of Arizona Department of Corrections
Dirk Johnson, Account Manager
3107 W. Cambridge Avenue
Phoenix, AZ 85009
602-272-7600 Ext. 207
Toll Free: 800-992-1738
Fax: 602-272-1007
Cell: 602-388-7230
djohnso1@azcorrections.gov

Volume XIII, Edition 6

Page 5

UPDATE: HazMat Team Investigates Strange Odor in Leetsdale:
An Allegheny County Hazardous Materials team was summoned Tuesday night to
Leetsdale to investigate a mysterious smell
coming from a neighborhood garage.
Leetsdale Fire Chief Ernie Logan said the
odor turned out to be an acid spill in the
stand-alone garage at 169 Broad St.
The spill was contained to the building
and the owner, Bob Kunsak of Moon
Township, is now responsible for hiring a
hazardous materials team to clean up the
remaining spill.

Neighbors first smelled the odor in
the area of 169 Broad St. and alerted
the borough fire chief, who then notified the police.
Authorities responded around 8 p.m.
and determined a chemical-like smell
was coming from inside an old brick
garage near Mohawk Alley,
where vehicles and materials are
stored. The building was formerly a
repair facility years ago.
Authorities set up a staging area and

roped off the section of Broad Street
with caution tape. Crews remained on
scene until 1 a.m.
In addition to Hazmat and Leetsdale
police and fire, Allegheny County
Emergency Services, Cochran Hose
Co., Valley Ambulance, and the Department of Environmental Protection
responded. The Salvation Army also
responded with a mobile canteen truck.

Damaged nuclear plant in Japan leaks toxic water:
New York Times – (International)
Damaged nuclear plant in Japan
leaks toxic water. Around 120 tons
of highly contaminated cooling

water was estimated to have
breached the inner protective lining
of a storage pool that services the
damaged Fukushima nuclear power

plant in Japan. Source: http://
www.nytimes.com/2013/04/07/
world/asia/japan-nuclear-plantleaks-radioactive-water.html

EDC reaches major clean water settlement targeting
pollution from oil and gas field in coastal Ventura
County:
Santa Barbara Independent –
(California) EDC reaches major
clean water settlement targeting
pollution from oil and gas field in
coastal Ventura County. A subsidiary of Occidental Petroleum
Corporation reached an agreement

with the Environmental Defense
Center to improve stormwater runoff from the Rincon Grubb oil field
as well as provide warning and
additional water quality testing for
hydraulic fracturing. The settlement also requires a dedication of

$95,700 to the Northern Ventura
County Coast Watershed Fund for
the mitigation of pollutants to
coastal watersheds. Source: http://
www.independent.com/news/2013/
may/16/edc-reaches-major-cleanwater-settlement-targeting/

Industry Corner

Page 6

GATEKEEPER

How to Ship Manufactured Articles that Contain Mercury
[49 CFR 172.101]:
Shippers of materials using the
proper shipping name, mercury
contained in manufactured articles, may assume that shipping
these materials is straightforward and may even ask, “It’s a
thermometer or a thermostat,
how hard can shipping these
materials be?” To ship even
simple items such as these, you
must understand and comply
with the fairly complex shipping
rules that apply.
To begin with, when you look
up this proper shipping name in
DOT’s hazardous materials table (HMT), published at 49
CFR 172.101, you see an A and
a W in Column 1 – Symbols, of
the HMT entry. The A and W
indicate these items are only
regulated as a hazardous material if shipped by air or water. The exception to this rule is
that if the material (such as a
thermostat or thermometer)
meets the definition of a hazardous waste (required on a manifest by 40 CFR 262) or a hazardous substance (which exceeds the Reportable Quantity
of 1 lb for mercury), then the
shipment is a regulated hazard-

ous material.
Even if you have been shipping these items for years,
you may not be aware of
DOT’s final rule published
in the Federal Register on
January 7, 2013, which
made several changes in the
HMT entry for mercury
contained in manufactured
articles to harmonize the
entry with international
shipping standards. The
final rule made the following changes to the HMT
entry:
• Assigned UN3506 to
the entry, replacing previously assigned UN2809
(see Column 4 of the
HMT).
• Added 6.1 toxic label
requirement as a secondary
hazard, in addition to the
class 8 label requirement
already in place (see Column 6 of the HMT).
Added special provision
A191 (49 CFR 172.102),
applicable for aircraft shipments of these items (see
Column 7 of the
HMT). Special provision

A191 states the 6.1 toxic subsidiary risk label and the requirement to indicate the subsidiary risk on the shipping
paper are not required for
manufactured articles containing less than 5 kg (11 lb) of
mercury. Therefore, if air
shipment packages containing
these articles have less than
11 lb of mercury, they are not
required to have the 6.1 label,
whereas fully regulated
ground shipments must have
both the Class 8 and the Class
6.1 labels.

You may voluntarily comply
with the final rule changes
listed above immediately, but
you are required to comply
with the changes beginning
January 1, 2014.
You must also follow the
packaging instructions identified for this HMT entry at 49
CFR 173.164 (see Column 8
of the HMT). Among the
packaging instructions provided at 49 CFR 173.164,
several key points include: aircraft shipments must

be packaged in Packing
Group I (performance standard X) packages; shipments other than aircraft
must be packaged as Packing Group III; cargo shipments are not regulated if
each manufactured item
contains < 100 mg of mercury and are packaged so
that each package contains
< 1 gram of mercury. Be
certain to consult and follow all the 49 CFR 173.164
packaging instructions applicable for your specific
shipment.

Learn more about how to
ship hazardous materials
properly by attending Environmental Resource Center's DOT Hazardous Materials Training: The Complete Course seminar, DOT
Hazardous Materials Training: The Complete Course
webcast, or DOT Hazardous Materials Update webcast.

Tyson fined $4 million after accidental chemical
releases:
KFSM 5 Fort Smith – (National)
Tyson fined $4 million after accidental chemical releases. Tysons
Foods will pay close to $4 million
in fines in a settlement with the

federal government over the accidental release of chemicals at Tyson plants in four States that
caused injuries, property damage,
and one death. Source:

http://5newsonline.com/2013/04/05/
tyson-fined-4-million-after-accidental
-chemical-releases/

Volume XIII, Edition 6

Page 7

Tips for Safe Mercury Cleanup:
Mercury spills less than or equal to the
amount in a thermometer. EPA recommends
that the following procedures be followed to
clean up mercury spills less than or equal to the
amount in a thermometer:

•

Remove everyone, including pets, from
the area in which cleanup will take place. Do
not allow assistance from children.

•

IF you are using powdered sulfur, sprinkle
it over the spill area at this time. Powdered
sulfur may be purchased from laboratory,
chemical supply and hazardous materials response supply manufacturers. Please note that
powdered sulfur may stain fabrics a dark color.
Users should understand the product and how
to use it, and should not breathe in the powder. The sulfur does two things:

ο

It makes the mercury easier to see, since
there is a color change from yellow to brown.

ο
ο
ο

It keeps the mercury from vaporizing.
Put on rubber or latex gloves.

If there are any broken pieces of glass or
sharp objects, pick them up with care. Place all
broken objects on a paper towel. Fold the paper
towel and place in a Ziplock ® bag. Secure the
bag and label the bag accordingly.

ο

Use a squeegee or piece of cardboard to
gather mercury beads. Use slow sweeping motions to keep mercury from becoming uncon-

trollable. Use a flashlight to look for any
additional mercury beads that may be sticking to the surface or in small cracked areas
of the surface.

ο

Use the eyedropper to collect or draw
up the mercury beads. Slowly and carefully
squeeze mercury onto a damp paper towel.
Place the paper towel in a Ziplock® bag
and secure. Make sure to label the bag.

ο

After removing the larger beads, put
shaving cream on top of a small paint brush
and gently blot the affected area to pick up
smaller, hard-to-see beads. Use sticky tape
to pick up any remaining glass fragments. Place the paint brush and duct tape
in a Ziplock® bag and secure. Make sure to
label the bag.

ο

Place all materials used for the
cleanup in a trash bag. Place all mercury
beads and objects into the trash bag. Secure
trash bag and label bag. Remember to remove gloves and place in trash bag.

ο

Contact your local health department
or your local fire department for proper
disposal in accordance with local, state, and
federal laws.

ο

Remember to keep a window open for
at least 24 hours after your successful
cleanup. Continue to keep pets and children
out of cleanup area. If sickness occurs, seek

medical attention immediately.
Mercury can be cleaned up easily from wood,
linoleum, tile, and any other like surfaces. If
a spill occurs on carpets, curtains, upholstery,
or other like surfaces, these contaminated
items should be thrown away in accordance
with the proper disposal practices. Only cut
and remove the affected portion of the contaminated carpet for disposal.
Mercury spills more than the amount in a
thermometer. EPA recommends that the
following procedures be followed to clean up
mercury spills more than the amount in a
thermometer:

•
•
•
•

Isolate the area.
Turn down temperature.
Open windows.

Don't let anyone walk through the mercury.

•

Don't vacuum.
Contact a fire department or public health
official.
Mercury spills greater than 1 pound (lb) (2
tablespoons). EPA requires that the National
Response Center must be contacted any time
1 lb or more of mercury is released into the
environment. The National Response Center
operates a 24-hour hotline at 800-424-8802.

Penalties Increased for Violating Federal Hazmat Laws and
Regulations:
or a regulation, order, special permit or approval issued under that law. MAP-21 provides that the following updated civil penalties apply to violations occurring on or after
October 1, 2012:

The US Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) announced that the increased
maximum civil penalties for safety violations of
Federal hazardous materials transportation law
and the regulations issued under that law that
lead to death, serious injuries or extensive property damage are now in effect. The increased
penalties are being published in revisions to
PHMSA’s regulations and reflect statutory
changes in the Moving Ahead for Progress in
the 21st Century Act (MAP-21).

•

“These laws exist to keep people safe, and the
increased penalties will help us make sure that
those who knowingly violate the rules will be
held accountable,” said US Transportation Secretary Ray LaHood.

•

Civil penalties are assessed for knowingly violating a hazardous material transportation law

The maximum civil penalty is increased
from $55,000 to $75,000 for knowingly violating Federal hazardous material transportation law

•

The maximum civil penalty for knowingly violating laws and regulations that result in death, serious illness, severe injury to
any person or substantial destruction of property is increased from $110,000 to $175,000
The $250 minimum civil penalty has
been eliminated
The civil penalty for violations related to
training has reverted to $450

“Hazmat safety regulations exist to keep
people, property, and the environment safe,
and it is our responsibility to enforce these
laws,” said PHMSA administrator Cynthia
Quarterman. “When someone breaks the
rules, it puts us all at risk. The consequences
for doing so should be substantial enough to
discourage misconduct.”
MAP-21 builds on the Department’s efforts
to improve safety across all modes of transportation. Adjustments to civil penalties were
authorized in the Hazardous Materials Transportation Safety Improvement Act of 2012,
the section of MAP-21 that provides PHMSA
with resources it needs to carry out its critical
safety mission. The rule was published in the
April 17, 2013, Federal Register.

Page 8

GATEKEEPER

TRI Reporting of Hydrogen Sulfide:
The reporting thresholds for
H2S are 25,000 pounds manufactured or processed or 10,000
pounds otherwise used.
Reporting is required if a facility meets either of these thresholds, is in a specific industrial
sector (e.g., manufacturing,
mining, electric power generation), and employs 10 or more
full-time equivalent employees.
The EPA has developed online
tools to help owners and operators determine if they are subject to TRI reporting and make
their submissions online.
Paper submissions may also be
made, but the Agency has a
strong preference to keep the
entire process electronic. More
information on the mechanics of
reporting is here.
H2S uses
H2S is a colorless, flammable,
extremely hazardous gas with a
rotten egg smell. Common
names for the gas include sewer
gas, stink damp, swamp gas,
and manure gas. It occurs naturally in crude petroleum, natural
gas, and hot springs. In addition,
H2S is produced by bacterial
breakdown of organic materials
and human and animal wastes
(e.g., sewage). Industrial activities that can produce the gas

include petroleum/natural
gas drilling and refining
and processes associated
with wastewater treatment,
coke ovens, tanneries, and
kraft paper mills. H2S can
also exist as a liquid compressed gas.
H2S has few important
commercial uses. However, it is used to produce
sulfur, one of the most
commercially important
elements. About 25 percent
of all sulfur is obtained
from natural gas and crude
oil by conversion of onethird of the H2S to sulfur
dioxide.
TRI history
H2S was added to the TRI
list of chemicals in a final
rule published December 1,
1993. About 8 months
later, the EPA issued an
administrative stay of the
TRI requirement for H2S to
review issues stakeholders
brought to the Agency’s
attention after promulgation.
Specifically, in its proposed
rule, the EPA cited chronic
respiratory effects as the
“chronic human health effects” criterion for the list-

ing; but in the final rule, the
Agency switched that criterion to chronic neurotoxic
effects. In other words, the
public had no opportunity to
comment on the actual human
health effect the EPA used to
support the listing. The EPA
viewed this as a valid objection to the final rule.
Members of the regulated
community also said that the
EPA diverged from past listing practice by not including
an exposure analysis in the
decision to list H2S (i.e., the
listing was based on the toxicity of the substance rather
than the risk of people being
exposed to it).
While not agreeing that the
exposure analysis decision
was inconsistent with past
practice, the Agency saw
enough merit in the two objections to issue the administrative stay on the rule that
required H2S reporting under
the TRI. The stay only suspended the effectiveness of
the listing rule; the rule was
not withdrawn and was reactivated as it was originally written.
Chronic health effects
In lifting the stay, the EPA

reiterates that its technical
evaluation shows that H2S
can reasonably be anticipated to cause chronic
health effects in humans. The Agency states
that chronic health effects
have been observed in
laboratory animals exposed
to low levels of H2S. In
addition, the EPA states
that the technical evaluation shows that the toxicity
of H2S can reasonably be
anticipated to cause significant adverse effects in
aquatic organisms. “As an
aside,” stated the Agency
when lifting the stay, “EPA
notes also that it believes
that the above findings
clearly demonstrate the
correctness of the
Agency’s final decision in
December 1993 to list hydrogen sulfide on the EPCRA section 313 toxic
chemicals list based on the
listing criteria in EPCRA
sections 313(d)(2)(B) and
(C).
“By lifting the stay, communities will have more
information about this
toxic chemical,” the
Agency adds.

DOT Temporarily Reduces Hazmat Registration Fees:
The DOT is required to adjust
the amount of the annual registration fee to account for any
unexpended balance in the Hazardous Materials Emergency
Preparedness (HMEP) Fund.
Due to an unexpended balance
that has accumulated in the
Fund, the DOT’s Pipeline and
Hazardous Material Safety Administration (PHMSA) is lowering the registration fees for reg-

istration year 2013-2014 for
persons that transport or
offer for transportation in
commerce certain categories and quantities of hazardous materials.
For registration year 20132014 the fee for a small
business or not-for-profit
organization is revised to
be $125 (plus a $25 proc-

essing fee), and for all other
businesses the fee is $1300
(plus a $25 processing fee).
After the 2013-2014 registration year, the registration fees
will return to 2012-2013 registration year levels.
In order to make the change
effective for the 2013-2014
registration year and thus
draw down the unexpended

balance as soon as possible, PHMSA issued final
rule without a prior notice
of proposed rulemaking in
accordance with good
cause exemption specified
in the Administrative Procedures Act.

Volume XIII, Edition 6

Page 9

More Money Budgeted to Enforce OSHA Regulations:
Acting Secretary of Labor Seth
D. Harris released the US Department of Labor's fiscal year
2014 budget request,
The president's budget for the
Department of Labor requests
$12.1 billion in discretionary
funding. It invests in programs
that improve services for workers and job seekers by modernizing the federal job training
system and creating employment opportunities for the long
-term unemployed and lowincome adults and youths. The
request devotes significant
resources to putting our veterans, particularly those with
disabilities or other significant
barriers to employment, back
to work. It provides improved
re-employment services that
enable individuals newly separated from the military to successfully transition into civilian careers.
As the economy changes,
training and employment programs must innovate and adapt
to effectively help American
workers gain needed skills.
The FY 2014 budget proposes
a new Universal Displaced
Worker program that will
reach more than a million
workers a year with a set of
core services, replacing two
more narrowly-targeted programs and ensuring that all
dislocated workers receive
high-quality job search assistance.
In addition, the budget request
provides $150 million for a
competitive Workforce Inno-

vation Fund to test new
evidence-based workforce
development strategies and
bold systemic reforms coming from states and localities. Of that amount, $50
million will be used to
identify strategies to help
veterans, military family
members, and members of
the National Guard and
Reserve, and $10 million
will be focused on identifying effective strategies to
improve outcomes for disconnected youths. The
budget proposes $8 billion
for a Community College
to Career Fund, to be administered jointly with the
US Department of Education, that will invest in partnerships between community colleges and business
to train workers for goodpaying jobs in high-growth
and high-demand industries. It would begin in
2015 as a successor to the
Trade Adjustment Assistance Community College
and Career Training program.
The department's request is
focused on helping the long
-term unemployed get back
to work. It includes a $4
billion Re-employment
NOW program, which incorporates a number of
reforms to help Unemployment Insurance claimants
and other long-term unemployed individuals get back
to work more quickly, and
a $12.5 billion Pathways
Back to Work Fund to

make it easier for workers to
remain connected to the
workforce and gain new skills
for long-term employment. In
addition, the budget provides
$25 million to encourage innovative states to come forward with new and better
strategies to return UI beneficiaries to work. The budget
also proposes reforms to put
state UI systems on the path
to solvency.
Highlights of the FY 2014
budget request include:
• An additional $5.8 million for Mine Safety and
Health Administration enforcement programs to pursue
strategies that prevent death,
disease, and injury from mining, and $2.5 million to implement recommendations
from the internal review conducted in the wake of the Upper Big Branch Mine disaster
• An additional $5.9 million to bolster OSHA’s enforcement of the numerous
laws that protect workers and
others from retaliation for
reporting unsafe and unscrupulous practices
• Nearly $14 million to
combat the misclassification
of workers as independent
contractors, which deprives
workers of benefits and protections to which they are
legally entitled and puts lawabiding businesses at a disadvantage against employers
who violate the law
• An additional $3.4 million for the Wage and Hour
Division to support greater

enforcement of the Fair Labor Standards Act and the
Family and Medical Leave
Act
• $5 million for the creation of a State Paid Leave
Fund to assist workers who
need to take time off to care
for a child or other family
member
An initiative to encourage
companies to fully fund
their pension benefits by
authorizing the Pension
Benefit Guaranty Corp.
board to adjust premiums
and take into account the
risks that different retirement plan sponsors pose to
their retirees. Under the initiative, the PBGC is estimated to save $25 billion
over the next decade.
Finally, the department's FY
2014 budget request continues existing efforts to enhance program effectiveness
and improve efficiency. The
department will invest in
program evaluations to be
overseen by the chief
evaluation officer and requests increased authority to
set aside funds from major
program accounts for more
evaluations. These investments will provide the department with valuable information about strategies
and approaches that work so
that resources can be allocated strategically.

Page 10

GATEKEEPER

Shipping Chemicals? Not So Fast ...
The EPA requires that anyone who
manufactures, imports, or exports
hazardous chemicals must comply
with TSCA. The Act requires that
anyone who wants to manufacture
or import a chemical not listed on
the TSCA list of chemicals must
notify the EPA at least 90 days
before producing or importing the
new chemical substance. TSCA
also imposes reporting requirements for anyone who exports
hazardous chemicals subject to
TSCA. TSCA's rules are enforced
by both the EPA and the U.S. Department of Homeland Security's
Bureau of Customs and Border
Protection (CBP).
Mercury
The Mercury Export Ban Act
(MEBA) amended TSCA to prohibit the export of elemental mercury from the United States effective January 1, 2013. The Act is
intended to reduce the availability
of elemental mercury in domestic
and international markets. By reducing the supply of elemental
mercury in commerce, the Act
aims to reduce the use of mercury
in small-scale gold mining and for
other commercial purposes globally.
In addition, federal agencies are
prohibited from conveying, selling,
or distributing elemental mercury
that is under their control or jurisdiction. This includes stockpiles
held by the Department of Energy
(DOE) and the Department of Defense.
The Act also required the DOE to
designate facilities for long-term
management and storage of elemental mercury generated within
the United States.
The MEBA applies to elemental
mercury, not mercury compounds.
The EPA does not consider the
materials listed below, for example, to generally fall within the
scope of the export and federal
agency transfer bans:

• Products (consumer and nonconsumer), including discarded
products;
•

Dental amalgam (predosed

capsule form);

• Scrap metal and used
electronics;
• Media (including
groundwater, surface water,
soils, and sediment) and debris that are managed for implementing cleanup;
• Reference materials in
which the mercury occurs as
contamination in media (e.g.,
soil, sediment, water, sludge);
• Industrial, commercial,
and remediation residuals;
and
• By-products of coal combustion.
Note, however, that the EPA
believes that any export or
federal agency transfer of
materials containing elemental mercury, including the
above examples, with the
intent to recover the elemental
mercury for resale or reuse
would be banned. This is consistent with the purposes of
the MEBA.
In addition to the examples
above, the MEBA specifically
excludes from the bans transfer and export of coal that
may contain elemental mercury.
PCBs
No person may import polychlorinated biphenyls (PCBs)
or PCB items for disposal
without an exemption issued
under the authority of TSCA.
No person may export PCBs
or PCB items for disposal
without an exemption, except
that PCBs and PCB items at
concentrations less than 50
parts per million (ppm) may
be exported for disposal.
For example, the EPA may
grant an exemption to a specific petitioner to export PCBs
for use in small quantities for
research and development, or
an exemption may be granted
for the import of a small
quantity of existing PCB fluids from electrical equipment

for analysis.
The EPA must receive a petition
for an exemption from the PCB
prohibition on imports and/or
exports 60 days before engaging
in these activities (40 CFR
761.80).
PCBs and PCB items of unknown concentrations are treated
as if they contain greater than 50
ppm (40 CFR 761.97).
The following PCB shipments
are not considered exports or
imports:

• PCB waste generated in the
United States, transported outside the customs territory of the
United States (including any
residuals resulting from cleanup
of spills of such wastes in transit) through another country or
its territorial waters, or through
international waters, and returned to the United States for
disposal. Examples of such territories and possessions are Guam,
American Samoa, the Commonwealth of the Northern Mariana
Islands (CNMI) including Saipan, and the U.S. Virgin Islands.
• PCB waste in transit, including any residuals resulting
from cleanup of spills during
transit, through the United States
(e.g., from Mexico to Canada,
from Canada to Mexico).
• PCB waste transported
from any state to any other state
for disposal, regardless of
whether the waste enters or
leaves the customs territory of
the United States, provided that
the PCB waste or the PCBs from
which the waste was derived
were present in the United States
on January 1, 1979, and have
remained within the United
States since that date.
This exemption allows U.S.
territories and possessions that
fall outside of the definition of
"customs territory of the United
States" to dispose of their PCB
waste in the mainland of the
United States where facilities are
available that can properly dispose of PCB waste.

Pesticides
All hazardous chemical exports, including pesticides,
must meet the federal hazardous chemical requirements
under TSCA. In addition, the
EPA has additional export
requirements for nonregistered pesticides. Companies
manufacturing pesticides for
export to another country
must comply with specific
labeling and notification rules
under the Federal Insecticide,
Fungicide, and Rodenticide
Act (FIFRA) regulations.
When it comes to environmental compliance, the Environmental Manager's Compliance Advisor is your
"peace of mind" guide to
environmental protection
agency (EPA) regulations at
40 CFR. This plain-English
newsletter gives you practical
compliance advice on every
key environmental compliance topic and acronym from
CERCLA ... RCRA ...
NESHAPS… NPDES ... to
SPCC.
Join the thousands of environmental professionals who
have counted on the Advisor
newsletter's practical advice
and best practice case studies
for almost 25 years.
As part of your subscription,
you will receive a quarterly
insert. This added feature,
EHS & Your Business, will
help you inform senior management and other key decision makers in your company
of business-critical developments in the field of environment, health, and safety
(EHS). Each quarterly insert
will spotlight one strategic
and timely issue as well as
briefly highlight the most
important EHS legal developments that could affect your
business operations, EHS
strategy, and EHS ROI.

Volume XIII, Edition 6

Page 11

Company President Pleads Guilty to Crimes Resulting in
Employee’s Death:
.The former president of Port
Arthur Chemical and Environmental Services, LLC,
(PACES), has pleaded guilty in
federal court to occupational
safety crimes which resulted in
the death of an employee, announced Ignacia S. Moreno,
Assistant Attorney General of
the Justice Department’s Environment and Natural Resources Division, and John M.
Bales, US Attorney for the
Eastern District of Texas.
Matthew Lawrence Bowman,
41, of Houston, pleaded guilty
to violating the Occupational
Safety and Health Act (OSH
Act) and making a false statement. Bowman admitted to not
properly protecting PACES
employees from exposure to
hydrogen sulfide, a poisonous
gas resulting in the death of
truck driver Joey Sutter on
December 18, 2008. In addition, Bowman admitted to directing employees to falsify
transportation documents to
conceal that the wastewater
was coming from PACES after
a disposal facility put a moratorium on all wastewater shipments from PACES after received loads containing hydrogen sulfide.
“Bowman’s actions showed a
preference for profit above the
safety of his employees, putting them and the public in life
threatening situations by not
properly identifying the dangerous materials PACES was
handling,” said Assistant Attorney General Moreno. “The
Justice Department will continue to vigorously enforce

laws enacted for the protection of human health and
the environment.”
“In this day and age, it
seems inconceivable that
workers would be exposed
to the level of danger that
was routine at PACES,”
said US Attorney
Bales. “Mr. Bowman’s
actions as the leader of the
company were more than
just cavalier, they were
criminal and he is being
held to account. We continue to grieve for the needless loss of life and the pain
and suffering of Mr. Sutter’s family and friends.
This investigation and
prosecution is the result of
an excellent combined effort of the identified agencies and I am grateful for
their hard work.”
“The plea agreement
reached today sends a
strong signal to all who
would illegally transport
hazardous materials,” said
Max Smith, regional Special Agent-in-Charge, US
DOT, Office of Inspector
General. “Working with
our law enforcement and
prosecutorial colleagues,
we will continue our efforts
to ensure safety in the
transport of these materials
and vigorously pursue those
who violate the law.”
“Laws regarding the safe
and legal handling of hazardous materials are in
place for a reason—to save
lives,” said Ivan Vikin,

Special Agent in Charge of
the US EPA’s criminal enforcement program in Texas.
“The defendant admitted that
his actions directly led to the
death of one of his employees. This plea demonstrates
that EPA and its partner agencies, the Texas Commission
on Environmental Quality’s
Environmental Crimes Unit
and the Department of Transportation’s Office of the Inspector General, will prosecute anyone whose actions
place the public at risk.”
According to information
presented in court, Bowman
was president and owner of
PACES, located in Port Arthur, Texas, and CES Environmental Services (CES)
located in Houston. PACES
was in operation from November 2008 to November
2010, and was in the business
of producing and selling caustic materials to paper mills.
The production of caustic
materials involved hydrogen
sulfide, a poisonous gas. According to the National Institute for Occupational Safety
and Health, hydrogen sulfide
is an acute toxic substance
that is the leading cause of
sudden death in the workplace. OSHA requires employers to implement engineering and safety controls to
prevent employees from exposure above harmful limits
of hydrogen sulfide.
Bowman was responsible for
approving and directing
PACES production operations, the disposal of hydro-

gen sulfide wastewater, and
ensuring implementation of
employee safety precautions. In some cases, Bowman personally handled the
investigation of workrelated employee injuries,
directed the transportation
of PACES wastewater, and
determined what safety
equipment could be purchased or maintained. In the
cases at issue, hazardous
materials were transported
illegally with false documents and without the required placards, with placarding being critical to ensure the safety of first responders in the event of an
accident or other highway
incident. Beyond these violations, PACES workers
were not properly protected
from exposure to hazardous
gases and the exposure resulted in the deaths of two
employees who were truck
drivers at the PACES facility, Joey Sutter on December 18, 2008, and Charles
Sittig on April 14, 2009.
Bowman and PACES were
indicted by a federal grand
jury on July 18, 2012.
Bowman faces up to five
years in federal prison and a
fine of up to $250,000 at
sentencing. A sentencing
date has not been set.
Charges remain pending
against PACES with the
corporation facing fines of
up to $500,000 per count.

Page 12

GATEKEEPER

PHMSA proposed rulemaking on inspection of packages
and other matters under enhanced inspection program:
SUMMARY: PHMSA is proposing to address certain matters identified in
the Hazardous Materials Transportation Safety Act of 2012
related to the Department's enhanced inspection, investigation, and enforcement authority.
Specifically, we are proposing
to amend the opening of packages provision to include requirements for perishable hazardous material; add a new noti-

fication section; and add a
new equipment
section to the Department's
procedural regulations. For
the mandates to address
certain matters related to
the Department's enhanced
inspection, investigation,
and enforcement authority,
we are proposing no additional regulatory changes.
We believe that the Department's current rules that
were previously established

through notice and comment
rulemaking and existing
policies and operating procedures thoroughly address
the hazmat transportation
matters identified by Congress. These inspection and
enforcement procedures will
not change the current inspection procedures for
DOT, but will augment
DOT's existing enforcement
procedures and allow the
Department to respond im-

mediately and effectively to
conditions or practices that
pose serious threats to
life, property, or the environment. As this rule affects
only agency enforcement
procedures, it therefore results in no additional burden
of compliance costs to industry.
DATES: Comments must be
received by July 22, 2013.

How to Describe Hazardous Substances on Shipping
Papers [49 CFR 172.203(c)]:
Unfortunately, whatever can spill, will
spill. When a spill occurs in transportation,
drivers need to know when the DOT or the
EPA requires that the incident be reported
to the National Response Center. Each of
the agencies have different criteria that
trigger this report. The EPA requires that
the report be made if there is a release of a
reportable quantity (RQ) of a hazardous
substance.
A hazardous substance is a material identified on the hazardous substance list (49
CFR 172.101 Appendix A) that is shipped
in a quantity per package that equals or
exceeds the RQ identified on the
list. According to 49 CFR 172.203(c),
when shipping a hazardous substance, you
must add the letters RQ to your shipping
paper, either before or after the basic description. For example:

•

RQ, UN 2809, Mercury, 8, III
UN 1090, Acetone, 3, II, RQ

If the name of the hazardous substance is not included in the basic
description, you must add it in association with the basic description. If
your material consists of more than
one substance that equals or exceeds
the RQ, then add the names of at
least two hazardous substance components, identifying those with the
lowest RQs. For example:
• RQ, UN 3082, Environmentally
hazardous substance, solid, n.o.s., 9,
III (Dicofol)
UN 1139, Coating solution, 3, II, RQ
(benzene, xylene)

Add the RQ designation only when
you are shipping a hazardous substance
in quantities that equal or exceed the
RQ. Make the RQ determination on a
per package basis. Also, if shipping a
non-bulk package containing a hazardous substance, mark RQ and component information on the package in
accordance with 49 CFR 172.324.
Customized on-site or webcast training
is a practical and cost-effective way to
get your employees the DOT hazardous materials training that they
need. Contact Environmental Resource Center at 1-800-537-2372 for
more information.

Volume XIII, Edition 6

Page 13

IATA Operator Variation for Lithium Batteries Shipped by
Air [IATA DGR 2.8.3, Operator Variation FX-07]:
Air shipments of lithium batteries are subject to the International Air Transport Association’s (IATA) Dangerous
Goods Regulations
(DGR). Section 2 of the DGR
contains State and Operator

Variations, imposed by a
country (state) or an airline
(operator), and can be more
stringent than the IATA
regulations that normally
apply.

When shipping lithium batteries, the first step is to find
the proper shipping name in
column B of the IATA dangerous goods list. Next, look
for the applicable packing
instructions (PI) in columns

G through L of the
list. Packing instructions 965970 apply to shipments of
lithium batteries on passenger
and cargo aircraft.

Each of the packing instructions
is divided into the following
sections:
General Requirements –
Applicable to all battery shipments assigned to that packing
instruction.
Section I/IA – Together
with the General Requirements, applicable
to the fully regulated,
Class 9 battery shipments assigned to that
packing instruction.
Section IB (only in PI 965
and 968) – Together
with the General Requirements, applicable
to the Section II bat-

teries that exceed
the limits found
in Tables 965-II
and 968-II, Class
9 battery shipments assigned to
that packing instruction.
Section II – Together
with the General
Requirements,
applicable to the
excepted, battery
shipments assigned to that
packing instruction.

the Shippers Declaration for
Dangerous Goods (SDDG),
and Section II batteries are
exempted from the requirement to use a SDDG.

UN 3480 Lithium Ion Batteries and UN 3090 Lithium
Metal Batteries prepared in
accordance with DGR Section IB are required to have a
SDDG with each shipment. FX-07 also requires
that the SDDG for these shipments be marked with “IB”
in the authorizations column
or in the additional handling
information section.

In each packing instruction,
Section I requires the use of

According to PI 965 and
968 (for lithium ion and
lithium metal batteries), you
are not required to use a
SDDG, when your shipment
qualifies for Section IB of
these packing instructions.
However, if you ship lithium batteries via FedEx, a
SDDG could still be required. Federal Express
operator variation FX-07
requires that shipments of

Learn more about how to
ship batteries by attending
Environmental Resource
Center’s How to Ship Batteries by Ground and Air webcast.

GATEKEEPER

Page 14

How to Describe Marine Pollutants on Shipping Papers
[49 CFR 172.203(l)]:
Marine pollutants are chemicals
that are dangerous to aquatic
life. Personnel who transport
marine pollutants need to know
when they are handling these
materials so they can take appropriate precautions to prevent and
respond to releases that can endanger aquatic life. Moreover, if
a material is not otherwise identified as a hazardous material, it
nevertheless is a hazardous material if it meets the definition of a
marine pollutant. For example,
cadmium sulfide is a cadmium
compound that has an LD50 well
over 300 mg/kg, so it does not
meet the criteria for classification
as a toxic (6.1) hazardous material, nor does it meet the criteria
for any of the other hazard
classes. However, it is listed on
the marine pollutant list and is
therefore a candidate for classification as a hazardous material.
Marine pollutants are listed in 49
CFR 172.101 Appendix
B. Mixtures and solutions con-

taining these materials with concentrations of at least 10% marine
pollutants or at least 1% severe
marine pollutants (designated with
PP) are defined as marine pollutants. Marine pollutants are regulated by DOT in bulk packages for
all modes of transportation
(ground, air, water), and in nonbulk packages shipped by vessel
(water).
When you ship marine pollutants,
you must include the words Marine Pollutant with the basic description on the shipping paper,
according to 49 CFR 172.203
(l). For example:
UN 2802, Copper chloride,
8, III, Marine Pollutant
If the proper shipping name you
are using does not identify the
name of the component that makes
a material a marine pollutant, you
must add that component name in
parentheses to the basic description. In cases where there are two
or more components that contrib-

ute to the marine pollutant status,
you must add the names of at least
two components contributing to the
hazard. For example:
UN 1263, Paint, 3, III, Marine
Pollutant (triethylbenzene)
UN 3082, Environmentally
hazardous substance, liquid (cadmium sulfide,
isodecyl diphenyl phosphate), 9, III, Marine Pollutant
In addition to declaring marine pollutants on shipping papers, you must
apply the marine pollutant mark to
packages when required by 49 CFR
172.332. For international shipments by air and vessel, you must
consult and follow the international
rules that apply.
For more information on DOT requirements for shipping papers, attend Environmental Resource Center’s DOT Hazardous Materials
Transportation course or webcast.

Governor's Tribal Community Outreach:
Visit: http://azgovernor.gov/eop/TribalOutreach.asp for agency contact information.
Tribal Program Link:
http://www.epa.gov/region09/indian

Tribal news:
http://www.navajohopiobserver.com/

Tribal Program Newsletter:
http://www.epa.gov/region09/indian/newslet.html

LET’S HEAR FROM YOU!
Send us your inputs and feedback on the newsletter; including, exercises and other LEPC related activities in which
you've been involved. Let us know what you’d like to see in future editions. Talk to us! We appreciate your input
and look forward to hearing from you!
Sincerely,
Mark Howard
Executive Director
Commercial products and services are mentioned for informational purposes only and should not be construed as
AZSERC endorsements.

COMMISSIONERS:

ARIZONA EMERGENCY RESPONSE COMMISSION
5636 E. MCDOWELL ROAD
PHOENIX, AZ 85008-3495
PHONE: (602) 464-6346
FAX:
(602) 464-6519

Visit us on the web:www.azserc.org
AZSERC STAFF
Mark Howard

Executive Director

Roger Soden

HAZMAT Program
Coordinator

Paul Culberson

Sylvia Castillo

Will Humble

ADHS Acting Director

Henry Darwin

ADEQ Director

John Halikowski

ADOT Director

Robert Halliday

ADPS Director

DESIGNEES:
Mark Howard

ADEM

Don Herrington

ADHS

Veronica Garcia

ADEQ

David Denlinger

ADPS

Sonya Herrera

ADOT

ADVISORY COMMITTEE:
Corporation Commission

- Tom Whitmer

Industrial Commission

- Darin Perkins

Admin Asst III

State Mine Inspector

- Joe Hart

State Fire Marshal

- Bob Barger

Radiation Regulatory Agency

- Aubrey Godwin

Department of Agriculture

- Jack Peterson

our Organization

The AZSERC was established by
Arizona Law (Arizona Revised Statutes-Title 26, Chapter 2, Article 3)
and is tasked with the implementation of the Emergency Planning and
Community Right to Know Act
(EPRCA) in Arizona.
This Commission oversees 15
Local Emergency Planning Committees and supports community, industry and government and academia
in: planning, release and incident
reporting, data management guidance for inventory reporting, public
disclosure of information about hazardous chemicals in Arizona as well
as development of training and outreach programs.
The Commission supports individual agency goals and objectives.

ADEM Director (Chair)

Web Portal/
Technology
Coordinator

Chrissy McCullough Admin Asst III

About

Lou Trammell

This is accomplished through the
receipt and coordination of emergency notifications of chemical releases, collection and provision of
chemical inventory information to
interested parties, training and grants
programs.
Additionally, the AZSERC provides consultative services, conducts
and participates in workshops and
coordinates development and review
of plans and programs for 15 Local
Emergency Planning Committees.
Further, the AZSERC serves as a
state clearinghouse for hazardous
chemical emergency preparedness
and planning activities and information through coordination with federal, tribal, state, local governments,
industry and community interest

Arizona Fire Chiefs Association
-Mesa FD

- Brady Leffler

-Yuma FD

- Jack McArthur

Asst. State Attorney General

- Jeffrey Cantrell

SRP

- Daniel Casiraro

Intel Corporation

- Randy Holmes

APS

- Monica Ray

Private Sector

- David
McWilliams

GATEKEEPER NEWSLETTER:
MARK HOWARD – EDITOR IN CHIEF
CHRISSY MCCULLOUGH - EDITOR