RTK Net - An Internet Resource for Workers
by Luis Vazquez, MPH
International Union, UAW, Health & Safety Department,
Detroit, MI
copyright, 1999
Do you work with toxic chemicals at your plant ? Do you live next to or near a industrial facility belching out mysterious toxic chemical vapors ? Want to know more about what you are being exposed to? Here’s a useful resource you won’t want to miss. The Right-to-Know network ( RTK Net ) provides publicly available information to union members, community groups, and others who want to know what industrial facilities are claiming to discharge up their stacks or ship out as hazardous waste.
RTK Net is an on-line computer network containing great volumes of data which industry must provide to the US Environmental Protection Agency on a periodic basis. The information provided by industry is made accessible by telephone (modem) or the Internet anytime, anywhere around the world, and best of all - RTK Net makes access to the information free of charge. The U.S. EPA maintains a similar search engine on the EPA website (http://www.epa.gov), with many of the same databases available. However, the RTK Net website is much easier to use.
When you log on to RTK Net via the World Wide Web, or via their dial-up phone number in Washington, D.C., their easy-to-use search software allows you to dig through numerous databases to find valuable data which may help you evaluate environmental conditions in your community, or perhaps the plant you work at. A search can be conducted for a particular workplace, a geographical area or zip code, or by Standard Industrial Classification (SIC) Code.
A geographical mapping program is available to be downloaded to PCs, to enable interested parties to plot out visually where facilities are located, thereby allowing individuals to estimate the hazardous chemical risks to particular communities. Many community groups have used this mapping program, along with U.S. Census and housing data, to outline Environmental Justice concerns. Frequently, facilities which use and discharge hazardous chemicals, and the dumps where hazardous chemicals are disposed of, end up being located in communities of color or communities where poverty and lack of political power are prominent.
Combining some of the information gathered from RTK-Net with another computer program called CAMEO, could be a very powerful tool for workers and community groups. CAMEO allows the user to create a “plume map”, which would show what are the potential results from a release of a toxic chemical. The user would enter into CAMEO the physical location of a plant, chemical names and quantities being released, air temperatures, wind speed, and a few other factors, and CAMEO will show graphically where the chemical is likely to go, and how much time it would take for the chemicals to dissipate. Emergency planners (who sit on Local Emergency Planning Committees - LEPC’s) use this computer program to define what to prepare for should a chemical release happen in their area of jurisdiction.
Also available on RTK Net are more than 300 New Jersey Department of Health Hazardous Substance Factsheets, which are an incredible resource for workers and community groups who want to know more details about particular chemicals they may find listed on Toxic Release Inventory reports. New Jersey factsheets can also be compared with information found on Material Safety Data Sheets. Many times people have found the information on these New Jersey factsheets to be more complete than what is found on MSDSs. They are much easier to read and understand, since they are written in layman’s terms, they are consistently formatted (you will find the same type of information in the same place on each New Jersey Factsheet), and they have a hazard summary on the front page, so there’s no need to dig through the factsheet for the essential information which may be necessary during an emergency.
RTK Net started in 1989 in support of the Emergency Planning and Community Right to Know Act (EPCRA), which mandated public access to the federally managed Toxic Release Inventory. The on-line service is operated by the Unison Institute and OMB Watch, two nonprofit organizations, and is funded by various government agencies, foundations, and individual contributions.
Of particular use and interest to union members and community organizations are the following environmental databases:
TRI ( EPA Toxic Release Inventory ) - For over 300 toxic chemicals (the EPA recently expanded the number of chemicals to be reported on), this database gives maximum chemical amounts stored on site, and information about how much is released to the environment, either routinely or as a result of spills or other incidents. Knowing about maximum amounts on-site can help people prepare for a “worst-case scenario”. It can help an emergency response planning group decide if there is enough response equipment and personnel to deal with an emergency involving the chemical(s) in question.
Facilities must report their releases of toxic chemicals to the TRI if the following four criteria are met:
1) They must be a manufacturing facility (primary SIC code in 20-39);
2) They must have the equivalent of 10 or more full-time workers;
3) They must either manufacture or process more than 25,000 lbs of the chemical or use more than 10,000 lbs during the year;
4) The chemical must be on the TRI list of 350 specific toxic chemicals or chemical categories. This list was recently expanded by the EPA.
One drawback to using TRI is that not all, or even most, toxic chemical pollution is reported in the Toxic Release Inventory. Another drawback is that only a limited number of hazardous chemicals are on the TRI reporting list.
PCS ( EPA Water Permit Compliance System ) - this will tell you what your employer/neighborhood plant is supposed to be testing for when they discharge chemicals to waterways or sewers. Also, this database will tell you if the company is in compliance with their water discharge permit, and any enforcement actions taken by authorities.
ERNS ( EPA Emergency Response Notification System ) - this database tells you which companies have filed a report when they have spilled or released a chemical on an emergency basis, that is, if they file a report at all. This information is especially useful when critiquing a company’s preparedness for potential future chemical release incidents by finding ways to prevent similar events from occurring.
BRS ( EPA Resource Conservation and Recovery Act Biennial Reporting System ) - this database tells you types and quantities of hazardous chemicals shipped offsite from a facility, and lists the disposal facilities where they supposedly end up.
DOCKET ( EPA Civil Litigation ) - this database identifies companies who are or have been sued in court for illegal environmental activities, by the US Department of Justice on behalf of the EPA. This database does not include information about criminal cases, only civil suits brought against companies.
CERCLIS ( EPA CERCLIS Superfund Information System ) - CERCLIS is the Comprehensive Environmental Response, Compensation, and Liability Information System. This database contains information about hazardous waste sites, all potential Superfund sites, as well as “Proposed” and “Final” sites that have been listed on the National Priority List (NPL). This database contains records on about 40,000 sites covered by CERCLA. CERCLA (enacted in 1980), and it’s amendments (SARA - enacted in 1986) are US Government Acts which established broad authority for the government to respond to problems posed by the release, or threat of release, of hazardous substances, pollutants, or contaminants. CERCLA also imposed liability on those responsible for releases and provided the authority for the government to undertake enforcement and abatement action against responsible parties.
How can you use the information contained in these databases?
Union members can use these databases to find out about their company’s environmental record, if one exists. The potential for hazardous chemical releases can be analyzed by workers and community groups. Participation in emergency response and evacuation planning is more effective when workers and community members take an active role and have the necessary information at hand. For instance, if a company is required to file annual Toxic Release Inventory reports with the EPA, they must also include information about maximum quantities of TRI chemicals they store on site. Workers can then use this detail to analyze a company’s preparedness for a “worst-case scenario”, by having the proper emergency response equipment on-site, by having a properly trained emergency response team, and by having a workable emergency response or evacuation plan. Workplace emergencies involving hazardous chemicals are covered by various OSHA standards in addition to EPA requirements.
Union Health & Safety Representatives, International Representatives, and Industrial Hygienists can use the data to be better prepared when inspecting a workplace, and thereby helping these worker representatives to better represent the union members. Information from the various RTK Net databases can be used as a basis for asking questions about industrial operations, storage and handling procedures for hazardous chemicals, worker health and safety training, and other job aspects.
Community groups and citizens can use the data to identify and learn more about potential chemical hazards posed by facilities located in their communities, and then enter into partnerships with businesses to bring about constructive changes, such as reductions in the use of toxic chemicals. As a result of public pressure and use of the environmental databases, one of the impacts of putting this information on-line has been to get companies to voluntarily reduce the amounts of toxic chemical emissions from their facilities.
Another use of the information on RTK Net is for labor, environmental, and community groups who would like to ensure that companies are in compliance with environmental reporting requirements. Companies which are not in compliance with EPA regulations are subject to substantial fines. An example of non-compliance is when a company fails to report entirely, or underreports discharges of TRI chemicals. Some environmental groups have been successful in getting companies to report their discharges, and even to reduce toxic chemical usage, just by threatening to sue the companies for not complying with federally mandated reporting requirements.
Union organizers may find environmental information on their organizing prospects useful by giving some background that would normally not be accessible, and which companies certainly would like to withhold.
What are the potential pitfalls?
If a workplace is smaller, or does not use quantities of hazardous chemicals which exceed reporting thresholds, there may be no environmental record on RTK-Net or the EPA website. Another dead-end may occur when a company reports their environmental data under a parent company’s name rather than their own. In this case, a geographical or SIC search would be better to conduct.
Having information, or access to information is one thing, being able to use it effectively is another. Of course, any recording system could have erroneous information entered into it. All of EPA’s chemical reporting schemes require companies to be honest and open about what they are reporting, but not all companies are.
Training in how to use the data garnered from RTK-Net would be useful, in addition to the user having a basic understanding of EPA rules and regulations. Digging through EPA’s rules and regulations could be tedious and time consuming, and not a favorite activity for time-strapped union reps. Data interpretation may require a specialist, but RTK-Net does provide a users manual on request, and will also provide some training and technical assistance. Once you have data in hand, the EPA can be consulted directly regarding the meaning of the data. Labor/environmental coalitions may find mutual benefits in conducting joint research into workplaces.
You should check out the RTK-Net website at the following URL:
http://www.rtk.net
If you want access to the data by directly dialing in with your modem, the telephone number is (202) 234-8570 (8,N,1)
RTK-Net’s phone number is (202) 234-8494, fax (202) 234-8584, and their mailing address is 1742 Connecticut Avenue, NW, Washington, D.C., 20009
Examples of information downloaded from RTK Net
The first example is that of a 1993 Toxic Release Inventory (TRI) report on American Tape in Marysville, MI, UAW Local 1149. This site was of particular interest since American Tape was identified as the second largest discharger of the flammable and toxic chemical toluene in the State of Michigan. This facility would be a good candidate for toxic chemical use reduction, perhaps by switching to a water-based adhesive.
FACILITY REPORT ( TRI DATA )
search used- Facility name: AMERICAN TAPE*
City: MARYSVILLE
State: MI
Year: ALL
TRI ID: ALL
Level of Detail: HIGH
Output Type : Text
Reporting Year: 1993
---------------------------------------------------------------------
Facility Name: AMERICAN TAPE CO.
Address: 317 KENDALL AVE. MARYSVILLE, MI 48040
County: ST CLAIR Lat/Long: 0425304 / -822853
EPA ID: MID061862926 TRI ID: 48040MRCNT317KE
D&B Number: 103512893
Public Contact: JORDAN THOMPSON Phone: (810) 364-9000
Primary SIC: 2671
All SIC Codes: 2671
NPDES IDs: MI0039021
Parent Company: NA D&B #: NA
Year: 1993 EPA Region: 05
---------------------------------------------------------------------
Breakdown of releases and waste generation (by chemical) follows:
Chemical Name: TOLUENE
CAS Number: 000108883 (Name: AMERICAN TAPE CO.)
Maximum Amount On Site: 100,000 - 999,999 LBS (Year: 1993)
Medium Release (lbs) Destination or Method Used
------------ -------------- --------------------------
FUGITIVE AIR 299,716
STACK AIR 4,162,511
OFF-SITE 48,041 TO: ROSS INCINERATION SERVICES INC.
GRAFTON, OH
USING: INCINERATION/THERMAL TREATMENT
Total 4,510,268
Generation of production-related waste in lbs (On=on-site, Off=off-site)-
Year: (*=projected) 1992 1993 1994* 1995*
Rel. or Disp: 3,911,016 4,462,257 4,430,052 3,571,229
Recycled On: 16,944,571 16,303,027 17,113,141 17,455,404
Energy On: 0 0 0 690,000
Treated Off: 28,842 48,041 52,170 43,260
Total: 20,884,429 20,813,325 21,595,363 21,759,893
Non-production-related waste: 0 (accidental or remedial)
Total waste generated : 20,813,325 (Production & Non-Production)
Production Ratio: 1.14
"Rel. or Disp" above = quantity released on-site or disposed off-site
"Energy" above = quantity burned for energy recovery
Chemical Name: ZINC COMPOUNDS
CAS Number: N982 (Name: AMERICAN TAPE CO.)
Maximum Amount On Site: 10,000 - 99,999 LBS (Year: 1993)
Medium Release (lbs) Destination or Method Used
------------ -------------- --------------------------
OFF-SITE 250 TO: ROSS INCINERATION SERVICES INC.
GRAFTON, OH
USING: INCINERATION/THERMAL TREATMENT
OFF-SITE 250 TO: LAIDLAW ENVIRONMENTAL SERVICES INC.
CORUNNA ONTARIO, CANADA
USING: INCINERATION/INSIGNIFICANT FUEL VALUE
OFF-SITE 250 TO: ROSS INCINERATION SERVICES INC.
GRAFTON, OH
USING: INCINERATION/INSIGNIFICANT FUEL VALUE
OFF-SITE 26,096 TO: ST. CLAIR COUNTY LANDFILL
SMITHS CREEK, MI
USING: LANDFILL/DISPOSAL SURFACE IMPOUNDMENT
Total 26,846
Generation of production-related waste in lbs (On=on-site, Off=off-site)-
Year: (*=projected) 1992 1993 1994* 1995*
Treated Off: 29,675 26,769 25,350 22,400
Total: 29,675 26,769 25,350 22,400
Non-production-related waste: 0 (accidental or remedial)
Total waste generated : 26,769 (Production & Non-Production)
Production Ratio: 1.14
Totals for all chemicals for AMERICAN TAPE CO.
Releases and Transfers (in lbs) -
Fugitive air : 299,716
Stack Air : 4,162,511
Off-site Transfer: 74,887
Total : 4,537,114 (Year: 1993)
Amounts of production-related waste generated (in lbs, for current year)-
Released On-site or Disposed Off-site: 4,462,257
Recycled On-site : 16,303,027
Treated Off-site : 74,810
Total Production-Related Waste : 20,840,094
Total Non-Production-Related Waste : 0
Total Waste Generated : 20,840,094
The second example is of an incident which occurred at EMS-Togo, a manufacturer of coatings, adhesives, and sealants located in Taylor, MI, UAW Local 157. This example is important because of the potential for explosion or excessive worker exposure to the solvents Methyl Ethyl Ketone and acetone. This company later discontinued manufacturing solvent-based adhesives.
DISCHARGER REPORT (ERNS DATA)
search used- Discharger: EMS TOGO CORPORATION
City: TAYLOR
County: ALL
State: MI
Year: 1990
Level of Detail: HIGH
---------------------------------------------------------------------
Basic spill information-
Date: 04/16/1990 Time: 2300
Street: 20219 NORTH LINE RD City: TAYLOR State: MI Zip:
Discharger information-
Discharger: EMS TOGO CORPORATION Type: PE
Street: 20219 NORTH LINE RD
City: TAYLOR State: MI Zip: 48180
County: WAYNE EPA Region: 05
Discharger Phone: 2nd Phone:
Material spilled: METHYL ETHYL KETONE
Amount spilled: 260 GAL or 1,742 lbs
Material spilled: ACETONE
Amount spilled: 260 GAL or 1,716 lbs
---------------------------------------------------------------------
Further information follows-
Environmental media involved (T/F or True/False)-
Air: T Land: F Water: F Groundwater: F Facility: F Other: F
Waterway/other: ATMOSPHERE
Transport Mode: Fixed Vehicle ID:
Causes of incident (T/F or True/False)-
Trans. accident: F Equipment failure: F Dumping: F Unknown: F
Operator Error: F Natural Phenomenon: F Other cause: F
Event Description-
A MIX TANK FOR THE PRODUCTION OF ADHESIVES OVERHEATED WHEN IT WAS NOT SHUT DOWN AT END OF DAY, BOILED OFF ITS CONTENTS
Miscellaneous-
THIS CO. MANUFACTURES ADHESIVES, THE MIXER THAT BOILED OFF THE CHEMS USED IN THE PROD. PROCESS, NORMALLY WOULD NOT DO THIS.
Action taken-NONE
How was spill found?: O (O=occured, D=discovered, P=planned)
Caller wanted confidentiality (T/F): F
Call received at- Date: 04/17/1990 Time: 1604
The third example is of a Emergency Response Notification System (ERNS) report on Moeller Manufacturing in Livonia, MI, UAW Local 157. This ERNS report indicates the manufacturer was allowing workers to dispose of drums of metalworking fluids on the site by puncturing drums and letting it seep into a drain - an illegal operation. Inspection of this facility by UAW Health & Safety Department staff led to recommendations for improvement of working conditions. When the company disregarded the recommendations, workers and the Local Union filed complaints with Michigan OSHA, which earned the company numerous citations for the very items the union pointed out.
DISCHARGER REPORT (ERNS DATA)
search used- Discharger: MOELLER*
City: LIVONIA County: WAYNE State: MI
---------------------------------------------------------------------
Basic spill information-
Date: 08/22/1989 Time: 1430
Street: 12173 MARKET ST.
City: LIVONIA State: MI Zip:
Discharger information-
Discharger: MOELLER MFG. Type:
Street: 12173 MARKET ST.
City: LIVONIA State: MI Zip:
County: WAYNE EPA Region: 05
Discharger Phone: 2nd Phone:
Material spilled: DDM FLUID, COOLANT, OTHER
Amount spilled: 1 BBL or 350 lbs
Material spilled: TOXIC MATERIAL
Amount spilled: 0 UNK
---------------------------------------------------------------------
Further information follows-
Environmental media involved (T/F or True/False)-
Air: F Land: T Water: T Groundwater: F Facility: F Other: F
Waterway/other: STORM DRAIN
Transport Mode: Fixed Vehicle ID: NONE
Causes of incident (T/F or True/False)-
Trans. accident: F Equipment failure: F Dumping: T Unknown: F
Operator Error: F Natural Phenomenon: F Other cause: F
Event Description-
DRUM DUMPING
Miscellaneous-
OWNER HAS TOLD JANITORS TO PUNCH HOLES IN BOTTOM OF DRUM WHEN FULL AND LET TOXIC MATERIAL RUN INTO DRAIN. THIS IS DONE REGULARLY BEHIND THE BLDG.
Action taken- NONE
Caller wanted confidentiality (T/F): F
Call received at- Date: 08/22/1989 Time: 1430
Information gathered for this article comes from the RTK Net website, and US EPA web pages
LV/mkh/opeiu494afl-cio
1/14/99