Building Bridges:

Recommendations for Effective Community Outreach from Chemical Industry Council of Illinois Responsible Care® State Outreach Panel State Outreach Panel

Paul Anderson - Illinois Institute of Technology Rosemary Ashworth - League of Women Voters of Illinois *Gerald Caamano - The Dow Chemical Company Wayne Chesson - Village of Channahon James Foster - Fort Transfer Company Greg Michaud - Illinois Environmental Protection Agency Don Gould - Will County Emergency Management Agency Michael Moomey - Illinois Department of Public Health Charlie Pajor - Nalco Chemical Company *John Paul ---- WCIA - TV William Peterson - Illinois State Senator Nicholas Schneider - The Nature of Illinois Foundation Frank Schreiber - Clearing Civic League Rich Stovall - Kendall County Farm Bureau Tim Lindsey - Illinois Waste Management Research Center Art Turner - Illinois State Representative George Vincent - C.P. Hall Company Carol Forrest - Panel Facilitator * retired from panel in 1996

Contents

Recommendation 1

Recommendation 2

Recommendation 3

Recommendation 4

Appendix A

Appendix B

These recommendations were developed by the Chemical Industry Council of Illinois (CICI) Responsible Care® State Outreach Panel (SOP), a diverse group composed of representatives from a number of public and private sector constituencies in the state of Illinois. The SOP's mission statement is:

"To act as an interface for insights between the chemical industry and state constituencies for the purpose of promoting communication and education about environmental, health, and safety issues, especially in terms of risk, using Responsible Care® and other outreach and environmental management initiatives."

The SOP began meeting on a quarterly basis in October, 1995 to discuss public perceptions and concerns about chemical manufacturing, transportation, and use in Illinois. Additionally, the SOP has examined chemical industry initiatives, including Responsible Care®, designed to improve the environmental and safety performance of chemical manufacturers and to increase public understanding of the industry. Meetings have been hosted by CICI member companies at their manufacturing and research facilities, with facility tours offered at the end of each session to familiarize SOP members with plant operations. During its first year, the SOP's discussions yielded a number of observations and recommendations that chemical manufacturers and other facilities that use or store chemicals might consider in regard to community outreach.

The SOP recognizes that public opinions about, and perceptions of, the chemical industry are based on many factors. These factors include misinformation or lack of information, differences of opinion regarding the potential risks posed by chemical manufacturing or use or the benefits provided by chemicals, and past incidents or practices involving the management of chemicals or chemical wastes. Thus, the SOP strongly recommends that facilities which manufacture or use chemicals engage stakeholders in their host communities in dialogues to discuss these important topics.

An effective community outreach program will stand a facility in good stead to deal with a wide variety of public interactions - from permitting activities and zoning board hearings to the discussion of information on a facility's risk management plan. Since the SOP recognizes that individual facilities and their host communities may have different needs, these recommendations provide general information that facilities can use to tailor approaches that are appropriate to meet their specific circumstances. A careful reading of this document should help managers and others charged with working with the public determine how well prepared they are to discuss environmental, health, and safety issues with their communities - and what additional steps they might consider to implement or maintain effective community outreach programs.

The Recommendations

#1 Establish outreach programs that are proactive, on-going, and based on two-way communication

Public perceptions are influenced by what the public hears, sees, and experiences - and if facility management doesn't engage in outreach activities, the public typically hears, sees, or experiences only the "bad news." Thus, facility management should reach out proactively to community residents and other stakeholders with information on environmental, health and safety performance, risk, and other issues involving chemical manufacturing and use. Communication between facilities and stakeholders should be conducted on an on-going basis.

Communication with the public should be a two-way process. Facility management needs to listen to stakeholders' concerns and suggestions and provide information to promote a substantive, on-going dialogue. Thus, the dialogue should seek to increase the public's overall understanding of facility operations and other environmental, health, and safety issues and increase facility management's understanding of stakeholders' concerns, opinions, questions, and issues. It should be noted that a facility communicator's attitude and his or her attention to the process of communication (e.g., willingness to listen as well as talk) can make or break the outreach effort.

It is important to note that many things can trigger public interest in a facility. For example, virtually any physical change or new activity at a facility can raise public questions or concerns. The expansion of a facility can lead to questions regarding increased chemical storage or use or increased generation of waste or emissions. Other activities, such as increased truck traffic or changes in traffic schedules, can also raise questions among community residents. Failure by managers to communicate about such changes can lead to speculation and to the spread of misinformation and public concerns. Thus, facility management needs to anticipate public interest. Managers should communicate regularly with their neighbors, elected officials, and other community stakeholders regarding new aspects of facility operations.

Appendix B at the end of this document includes a list of the types of questions members of the public frequently ask about facilities.

#2 Communicate effectively about risk*

Most community outreach programs will involve both routine communication to build and maintain knowledge and relationships, and risk communication to discuss risks that may be associated with facility emissions or the potential for accidents.

Communicating effectively about risk is vital to promoting substantive discussions regarding the manufacture, transport, and use of chemicals. Perceived risks need to be identified and responded to, not dismissed out of hand. Additionally, failure to disclose or admit risks that do exist undermines the credibility of facility management and the industry as a whole. Risk must be discussed in a forthright manner that informs the public without causing undue alarm.

The following are important considerations for communicating with the public about risk:

1. Public responses to risk or perceived risk may be based on emotions rather than facts.
2. People fear what they do not understand - and the chemical industry seems mysterious to the public.
3. Many members of the public automatically equate the term "chemical" with "toxic", "hazardous", or "dangerous".
4. People tend to be more concerned over risks they can't control (involuntary risks) than risks that they bring upon themselves.
5. Avoid using "absolutes" to describe risk. List some instances as "low risk" as opposed to "safe".
6. Avoid jargon - use words and examples from everyday life.
7. If you do not know the answer to a question, be prepared to seek out the information and follow up with the person who asked the question.
8. Be aware that some answers, however technically sound, may not satisfy some people. Additionally, some questions regarding risk may not have definitive answers.
9. Keep messages short and to the point.
10. Expect that stakeholders may raise the concept of cumulative effects when discussing risk.
11. Be prepared to answer questions about risks posed by products.
12. A reasonable effort should be made to keep lines of communication open, regardless of whether stakeholders are accepting the risk information.

An important aspect of effective risk communication is establishing and maintaining credibility. Maintaining credibility requires communicating the bad news as well as the good news. The public is more sophisticated about environmental matters than it used to be. People need to be given information that provides enough detail, including pros and cons, to reach their own conclusions.

Facility management needs to consider the effects that different types of spokespersons have on public acceptance of information. For example, although facility managers are typically the primary spokespersons, other employees often have a special credibility that can increase acceptance of information. Additionally, companies or facilities should work with third-parties, who can corroborate or verify that what is communicated about environmental, health, and safety issues is true. Such third-parties can include:

• elected officials
• emergency responders
• environmental organization representatives
• non-elected community leaders (opinion leaders)
• state agency staff

Communicate in a balanced and open manner

Another important aspect of effective risk communication is communicating in an open and balanced manner. Communication should be neither defensive nor sugar-coated. Facility management should not avoid communicating about difficult topics, such as risk. Facility managers should also discuss the beneficial uses of their products and the safeguards that are built into their facilities to reduce risk or potential risk to human health and the environment. Facility management should recognize that there are many things about industrial processes that the general public might not know. To promote an informed dialogue, it is important to share information on how chemicals and wastes are managed.

Place information in context

Facilities should place the information they provide into a context that will allow the public to better understand its significance. For example, information on emissions should be accompanied by information on production, so that the public can determine whether emissions reductions are due to decreases in operations or to pollution prevention. Similarly, industry-wide information, such as reductions in over-the-road accidents, should be tied to constant data, such as accidents per miles traveled, so that the public knows whether a decrease in accidents effects safer transportation or reductions in the number of shipments.

* This document uses the term "risk" primarily in the general sense, to refer to the possibility or probability of danger or harm from nonspecific sources. The term is also used in several instances to refer to specific risks, such as those associated with measurable exposures to specific chemicals.

#3 Use a variety of community outreach activities and communication vehicles

There are a number of options for reaching out to the community and communicating with stakeholders. Outreach programs should be tailored to include a variety of activities and communication vehicles that reach all segments of the community. A goal of the outreach program should be to build relationships with a broad base of community residents and other stakeholders - not just with the media and emergency responders. Potential audiences for community outreach include:

• chambers of commerce
• church leaders
• civic groups
• community advocacy groups
• educators
• emergency responders
• employees
• farm bureaus
• industrial and commercial neighbors
• league of women voters
• legislators
• local environmental groups
• local public officials
• media
• minority, ethnic, or non-English
• peaking groups
• national environmental groups
• other industries/companies not involved with Responsible Care®
• regulatory agencies
• residential neighbors
• school children
• support industries

To reach a wide range of stakeholders, facility management should utilize outreach programs that include activities that "take involvement to the people" rather than expect stakeholders to come to the facility - or approach its management - for all activities. Care should also be taken to determine what types of activities or communication vehicles are most appropriate and will be best received in a particular community.

Community outreach activities may be initiated and implemented by the facility, or they may involve participating in community functions involving other organizations. The following list includes examples of some of the techniques and activities that can be employed to reach out to community stakeholders:

• one-on-one meetings
• informal, small group meetings
• formal, large group meetings
• public hearings
• open houses and tours
• fact sheets, brochures, and other written information
• lectures and speeches
• involvement in local organizations
• outreach to schools
• community advisory panels
• booths and displays at county fairs, chamber of commerce fairs, or other local events
• press releases and media briefings

# 4 Share the concepts on environmental, health, and safety improvements that have been developed under Responsible Care®

The practices under Responsible Care® and similar industry initiatives, notably those under the pollution prevention and product stewardship codes, enhance environmental, health, and safety performance. Responsible Care® practices under several of the codes include requirements for outreach both to the community and to other stakeholders, including suppliers, customers, government, distributors, and transporters. These requirements are designed both to improve environmental, health, and safety performance related to Responsible Care® member companies' commercial activities and to enhance emergency preparedness by communities, pollution prevention by government and other companies, and the responsible management of products and wastes by customers.

The SOP believes that the Responsible Care® practices provide benefits to health, safety, and environmental protection that should be shared with customers, suppliers, and other stakeholders that manage chemicals, including small companies and government entities. Thus, the chemical industry and individual companies should include activities in their outreach programs that share this knowledge with others in government and industry to improve health, safety, and environmental protection throughout Illinois.

Appendix A

Public availability of risk management plans is likely to heighten interest in- - and concern about - chemical facilities

These recommendations provide information on community outreach that would benefit virtually any facility faced with any number of different issues. This section provides insights from the SOP regarding the public availability of risk management plans (RMP) and the special issues RMPs may raise among the public.

The RMP requirements will no doubt create interest in or concern about many facilities that either have not previously engaged in community outreach or whose outreach programs have been limited in scope. Such facilities should begin now using the concepts discussed earlier in this document to reach out to a broad base of stakeholders in their communities to prepare them to receive the RMP information.

Public stakeholders, such as emergency response organizations, health care institutions, and other public entities that would be involved in a response if an accident were to occur, should be involved in facilities' risk management planning processes from the beginning, when plans are initially being prepared. Facility management should also work with these public stakeholders when designing their communication programs and involve them in communicating with other community stakeholders. Not only is involvement of public stakeholders important to add credibility to the facility's communication, residents must feel confident that local leaders and public agencies will know what to do if an accident were to occur. Community residents need to know that everyone who may be involved in responding to an accident will be prepared and have the necessary training to get them through safely.

Other observations the SOP believes facilities should consider regarding the impending public availability of RMP information are as follows:

1. Expect that the media will pick upon facilities' worst-case release scenario "plume maps" (areas of potential impact).
2. Facilities will need to reconcile the messages: "Chemicals are good, but here's our "plume." Facilities will need to close the gap in perception that these two divergent messages will cause.
3. Chemical accidents - or the potential for chemical accidents - represent involuntary risks. Thus, the public is likely to react more negatively than it would in the case of voluntary risk, even though the actual risk of an accidental release with serious consequences may be very small.
4. People are likely to want to see that facilities' plumes of potential impact are shrinking over time because of increased pollution prevention and process improvements. Additionally, stakeholders will want to see that accidents are being prevented - they will not want to see the emphasis placed on emergency response.
5. Keeping a "low profile" will not insulate a facility from public interest in its RMP. Facility management needs to work with the public, both to make information available proactively and to answer questions or address concerns that arise.

Considerations for communication in support of RMP information include the following:

The worst-case release scenario information is likely to create substantial concern over something that is unlikely to happen. Thus, facility management will need to educate the public regarding what the worst-case represents and use alternative release scenarios to work with stakeholders on more plausible release and response scenarios.

Follow up worst-case release scenario presentations with explanations of safety devices by the plant personnel who work with the processes every day. Many of the activities listed under recommendation 3 would provide opportunities for plant personnel to communicate this type of information to the public. Hearing from actual employees about how they safe guard plant operations gives stakeholders a clearer idea of how the facility is run.

Outreach efforts should extend to those persons who are potentially affected as well as to those who perceive that they may be affected, even if the plume is unlikely to reach them. When a facility encounters resistance or concern, it is important to address the issue and not brush it off or ignore it. Instead, bring people who are concerned inside the process to see first-hand the safety procedures and emergency response plans that are used to manage risk.

RMP information needs to be made widely available. Facilities should consider making their information available through libraries, schools, and municipal offices, as well as through the Internet.

Community Outreach and the Public Availability of Risk Management Plans

The SOP recommendations are especially important in light of the impending reporting, and subsequent public availability, of risk management plans (RMPs) under Section 112(r) of the Clean Air Act. The RMPs will provide information on potential offsite consequences from accidental releases of certain toxic or flammable chemicals, as well as information on emergency preparedness, employee training, facility maintenance, and other aspects of facility operations.

In the preamble to the final rule for the Accidental Release Prevention and Risk Management Program, EPA states that with the RMP requirements, "EPA continues the philosophy that it embraced in implementing the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). Specifically, EPA recognizes that regulatory requirements, by themselves, will not guarantee safety. Instead, EPA believes that information about hazards in the community can and should lead public officials and the general public to work with industry to prevent accidents....EPA intends that officials and the public use this information to understand the chemical hazards in their community and then engage in a dialogue with industry to reduce risk. In this way, accident prevention is focused primarily at the local level where the risk is found."1

RMPs must be submitted to a central point designated by U.S. EPA by June 21, 1999. They will be made available to the public. The SOP believes that facilities need to consider the EPA's intent as well as the regulatory requirements for RMPs and begin discussing this information with their communities now. Proactive discussion of risk management planning is important both so that community stakeholders can have input into planning activities and to mitigate concerns that would no doubt arise if stakeholders were to receive RMP information without the additional insights into facility operations they would gain from an active community outreach program.

1 Federal Register, Vol. 61, No. 120, June 20, 1996, pp.31669-31670.

Appendix B

Questions Plant Managers should be prepared to answer

What kind of chemicals do you have at your plant?

What do you make at your facility?

What is your emergency response plan?

What are your air emissions?

Describe the provisions you have in place for emergencies.

What toxic materials do you use?

Are you inspected by the EPA?

What do you do here and am I safe talking to you this instant?

What are the health concerns associated with your facility and your products?

What are you doing to make sure I'm safe?

What's going to happen in the long term in regard to health and the environment?

How will I know about releases from your plant?

What is the plant going to do to nearby property values?

If you had a release, what would the short-term and long-term environmental effects be?

What is your history of spills and releases?

Do you live near the plant? If not, why not?

What are you doing in regard to pollution prevention and protecting the environment?

Do the chemicals you handle have an effect on children?

What are the routes of exposure?

What happens to the chemicals you don't use?

Why should I believe you?

Describe the safety performance of your employees. How many job-related illnesses or injuries do your employees experience?

How long is your facility going to be operating in the area?

Why is that wind sock up there?

What is that smoke that I see coming out of your plant from time to time?

What is that odor I smell sometimes?

What do your sirens mean?

Can residents have access to the facility to see what's happening?

Are you planning to undergo construction or expansions?

I see you are adding on to your plant. What does this mean in terms of safety? Are you going to store more chemicals?

Copyright 1997 by Chemical Industry Council of Illinois (CICI). Responsible Care® is a registered service mark of the Chemical Manufacturers Association.

For copies of this report, contact CICI, 9801 West Higgins Road, Suite 515, Rosemont, IL 60018, 847-823-4020.