Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies (2011)

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Best practices reported by LEPCs in the survey conducted for this project, case studies, and interviews were overlaid on some of the most important concerns expressed by LEPCs for con- ducting HMCFS. “Promising practices” were compiled from direct reports of best practices by LEPCs in meeting critical HMCFS needs as well as logical progressions to fill identified gaps in the process. The 11 promising practices are: 1. Use HMCFS Objectives Checklist—Consists of an initial checklist of objectives that local entities have reported for their HMCFS. 2. Let HMCFS Objectives Guide Sampling—Identifies the appropriate balance between the desire for extensive data collection, the project’s objectives, and the realities of limited resources. 3. Let HMCFS Objectives Guide Precision—Matches the HMCFS project’s objectives with the level of precision of HMCFS data collection efforts. 4. Match Protection Level with HMCFS Objectives—Evaluates the extent of match between desired risk level (goals) for a community and the HMCFS project’s objective(s). This helps ensure consistency of project results with their ultimate purpose: ensuring public protection. 5. Stretch Limited Time and Resources—Suggests ways for funding an HMCFS using in-kind funding, volunteer participants, industry contributions, and sequenced HMCFS activities. 6. Consider Consecutive Year Studies—Deals with time constraints that can be associated with funding cycles. Shows how a more comprehensive and complete HMCFS can be con- ducted over several years. 7. Use Volunteers to Conduct HMCFS—Identifies key HMCFS project activities for LEPC members regardless of whether the HMCFS is done by the LEPC or by a contractor. 8. Use Existing Data Sources—Provides a list of potential existing data sources to help those conducting an HMCFS (especially first-timers) start the process. 9. Use Hotspots Analysis—Examines collocation of hazardous materials and human popula- tions in time and space. 10. Use Risk Communication Checklist—Includes a list of locations, people, or offices to con- sider for the communication of HMCFS results. 11. Demonstrate Local Risk—Suggests ways that risks associated with hazmat transportation through an area can be communicated to help local leaders understand the importance of taking preemptive actions, reducing risk, and mitigating consequences. D-1 A P P E N D I X D Promising Practices for Conducting an HMCFS

Promising Practice 1: HMCFS Objectives Checklist The HMCFS objectives checklist is comprised of an initial checklist of some of the objectives that local entities have reported for their HMCFS. Local entities simply review the components associated with the different outcomes and check those desired for their hazmat CFS. If a variety of objectives are identified, they may be applied independently to different corridors, routes, or route segments. At a mini- mum, discussion among participants about project objectives helps clarify the purpose of the HMCFS. The following advantages and disadvantages of using the checklist are provided. Objective Category Objective Component Awareness/Minimum Scenario Definition Maximum Scenario Definition Emergency Planning Comprehensive Planning Equipment Needs D.1 Use HMCFS Objectives Checklist Why is the HMCFS being conducted? There are many reasons local jurisdictions choose to con- duct an HMCFS, ranging from very general, such as enhancing awareness about whether hazmat transport is present in a community, to very specific, such as designating a hazmat transportation route. Many LEPCs use HMCFS results to learn about hazmat transport, conduct planning, or guide training exercises. Many other LEPCs also use HMCFS results to inform equipment needs. Some LEPCs use their HMCFS to conduct risk analysis for hazardous materials route designations or other applications. Understanding the objectives of the HMCFS corresponds with the types of decisions users hope to make based on the information. Too little information results in decisions based on insuffi- cient information, may lead to poor decision making and increases community risk. Too much information can result in misallocation of resources (i.e., time, money, and personnel effort) in the process of collecting the supporting data. Lack of clarity about objectives increases the likeli- hood that the HMCFS will fail to satisfy user needs. Promising Practice 1: Use HMCFS Objectives Checklist helps focus the effort on stated objectives given the realities of limited resources. D-2 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies  Increase awareness of hazmat transport for local officials, community groups, or general public.  Confirm or document existing knowledge about hazmat transport in jurisdiction.  Guide hazmat response training, preplan incident response.  Plan for hazmat incident prevention, response, and mitigation.  Assess risks for hazmat incidents in jurisdiction.  Develop and locate emergency notification, shelter, and evacuation warning and communication systems.  Community planning and zoning and infrastructure planning.  Identify hazmat response equipment deficiencies/needs.  Provide grant funding justification.

Promising Practices for Conducting an HMCFS D-3 D Potentially misses objectives that may arise but remain hidden during the early phase of the work. Can be overcome by periodic reflection on goals throughout the HMCFS process. D Explicit delineation of objectives may stifle creativity and innovation. Can be overcome by keeping commu- nication lines open and providing opportunities for innovative thinking. D May inadvertently encourage ignoring data inconsis- tent with objectives. Can be overcome by specific search for, and listing of, inconsistent data. D Conclusions made based on information may be more focused than actual operating conditions. Can be overcome by incorporating focused CFS goals into “operational conditions” during exercises and drills. Resource Scheduling Route Designation Legal Takings What other objectives might your community have for conducting an HMCFS? How do they relate to the objectives listed above? The Objectives Checklist has Advantages (A) and Disadvantages (D) A Focuses available resources on information required for objectives. Lowest data collection requirements mean reduced resource requirements. A Explicit delineation of the outcomes desired from the hazmat CFS. A Captures the goals and outcomes of the hazmat CFS implementation team. D.2 Let HMCFS Objectives Guide Sampling Some data, such as national-level estimates, should only be used to develop very general ideas about the nature and patterns of what might be travelling through a jurisdiction such as a city or county. Other data provide enough information to understand the local nature and patterns of hazmat transport in a jurisdiction, but not for specific times, locations, or individual hazmat commodities. At the highest level, data are very locally detailed and can be used to identify the particular nature and patterns of what has been observed in a jurisdiction, even for a specific net- work location, time of day, or hazmat commodity. Promising Practice 2: Let HMCFS Objectives Guide Sampling suggests some guidelines for how hazmat transport data should be sampled (that is, where, when, and how often data should be collected) in order to match the HMCFS project’s objectives.  Establish or increase hazmat response teams.  Schedule personnel, equipment, other resources.  Locate new public/high-occupancy facilities.  Designate hazmat routes or transport corridors.  Relocate public, high-occupancy, or industrial facilities.  Restrict access, operations, development, or other usage of high-risk locations. Objective Category Objective Component

Promising Practice 2: Let HMCFS Objectives Guide Sampling Problem Understanding the objectives of the hazmat CFS helps identify the information required and the precision needed to make these types of decisions. Too little information results in decisions based on insufficient information; too much information may result in mis- allocated resources (i.e., time, money, and personnel effort). Promising Practice This promising practice helps identify the appropriate balance between the desire for extensive data and the realities of limited resources by providing a matrix for matching HMCFS objectives with sampling frameworks. See Appendix H for further information about sampling frameworks. Convenience sampling involves selecting observational units (network segments, locations, times, and frequencies of data collection) because of the ease associated with making observations. Convenience sampling can effectively be used to establish the existence of, but not the extent or distribution of, hazardous material in a community. Representative sampling involves selecting observational units to represent major groups of hazmat flows in a community. Representative samples are slightly stronger than conven- ience samples and can be used to reflect types of hazmat in a community, but cannot estab- lish magnitude of flow or the empirical likelihood of hazardous materials across a network. Cluster sampling involves selecting multiple representatives from major groups of observa- tional units. Clusters can be used to estimate the existence and magnitude of hazmat flows in a community. Observations may have limited generalizability beyond the empirical sample. Stratified and proportional samples involve selecting observational units in numbers pro- portional to those in the overall population. Hence, stratified and proportional samples are only possible when sufficient prior data exist to establish the proportions of various types of observational units. Stratified and proportional samples can be used to estimate the exis- tence and magnitude of HazMat flows. Since the sampling is based on existing data, strati- fied samples encounter some limitations in tracking new types or quantities of hazmat transport patterns. Most HMCFS objectives can be accomplished with low levels of data sampling. Random samples are the “gold standard” of sampling but are also generally impractical for most HMCFS applications. They involve selecting observational units in a truly ran- dom manner. Hence, no information is required on the type or quantities of flow and no limitations are encountered. When randomly selected data are distributed in time and space, random samples can prove quite ineffective use of data collection resources—due to travel between units and waiting for the next temporal unit to occur. A complete census involves observing all units in the universe as a whole. It is usually not logistically possible in most survey applications. However, in rare instances, a census of information is available or relatively easy to attain. For example, when hazmat flows are small or limited, it may be possible to observe all flows in a community. When available, a census meets all decision objectives but it is not usually recommended due to its constraints. The vertical axis of the following figure lists HMCFS objectives in terms of increasing com- plexity. Trace along the row of the highest HMCFS project objective until it is matched with the appropriate sampling framework. This helps identify data requirements and avoid misallocation of data collection resources. D-4 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies

Promising Practices for Conducting an HMCFS D-5 D.3 Let HMCFS Objectives Guide Precision The higher the level of precision used to collecting HMCFS data, the more effort is required. Promising Practice 3: Let HMCFS Objectives Guide Precision suggests a classifica- tion system that helps determine when the additional usefulness is warranted. It can be used The Objectives-Sampling Matrix has Advantages (A) and Disadvantages (D) A It matches the project’s objectives with the sampling procedure capable of pro- ducing information sufficient to achieve these outcomes. A It reduces chances of mis- allocating resources by collecting data that are not needed to achieve objective(s). A It reduces the likelihood of making decisions based on insufficient information. D It inhibits mid-stream adjustments, especially when objectives are broadened to include greater informa- tion requirements. This can be overcome by recogniz- ing when data are critical to achieve objectives and remaining flexible enough to change sampling frame- works for particular locations when warranted. D When little is initially known about hazmat flows in a community, it may be difficult to foresee how an HMCFS may be used, making identification of sam- pling frameworks more difficult. It can be overcome by recognizing that as more HMCFS information becomes available, the picture becomes clearer and objectives and sampling frameworks can become more defined. Sampling Framework Objectives Co nv en ie nc e R ep re se nt at iv e Cl us te r St ra tif ie d/ Pr o po rti on al R an do m Ce ns us Legal Takings and Route Designation < < < = = > Resource Scheduling, Equipment Needs, and Comprehensive Planning < < = = > > Emergency Planning < < = > > > Maximum Scenario Definition < = = > > > Awareness/Minimum Scenario Definition = = > > > > < Information collected using sampling framework is insufficient for objective(s) = Information collected using sampling framework matches objective(s) > Information collected using sampling framework exceeds requirements for objective(s)

to define data collection requirements for hazmat quantity (e.g., hazmat presence, relative hazmat quantity such as “small,” “medium,” and “large” quantities, or specific hazmat quantity such as number of gallons or pounds transported) and hazmat classification (e.g., whether or not it is hazmat, chemical/material class/division, UN/NA placard ID, or specific chemical/ material name). Promising Practice 3: Let HMCFS Objectives Guide Precision Problem Having extra data available can be nice when other needs arise. However, data collection can be expensive, and scarce resources can sometimes be misallocated if outcomes are based on more information than is needed. When decision outcomes use insufficient data, they are often challenged or fail to meet the objectives. The problem becomes, how to efficiently choose appropriate levels of precision (hazmat quantity and characterization) so that data can support the project’s objectives? Promising Practice This promising practice lets the objectives of the HMCFS guide the precision of hazmat transport data collection. This helps save resources while maximizing utility. When highly precise data are collected for low-level decision outcomes, the informa- tion content is overmatched with the desired outcome. Collecting less precise data can be sufficient for low-level outcomes but should not be “over-extended” to high-level decision outcomes. As the level of HMCFS objective increases, more precision is often required. The Objectives-Precision Matrix has Advantages (A) and Disadvantages (D) A It allows local entities to provide detailed informa- tion in focus areas. A It promotes efficient use of available resources in the conduct of HMCFS. D-6 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies D It has the potential to misallocate resources to areas not requiring attention or distract local entities from most serious hazmat flow issues in the area. This can be overcome by open, inclusive communication among local leaders, especially early in the HMCFS process. The vertical axis of the following figure lists HMCFS objectives in terms of increasing com- plexity. Trace along the row of the highest HMCFS project objective until it is matched with the appropriate precision levels for hazmat quantity and characterization. This helps identify data requirements and avoid misallocation of data collection resources.

D.4 Match Protection Level with HMCFS Objectives Planning for everything can often result in planning for nothing! When resources are limited, trying to plan for every possible outcome may result in the limited utility of what is accom- plished. Too little information results in decisions based on insufficient information; too much information may result in misallocation of resources (i.e., time, money, and personnel effort). Four levels of public protection (risk) goals are considered: complete protection (all risks), max- imum protection (possible risks), reasonable protection (probable risks), and general protection (most likely risk). D.4.1 Complete Protection The goal at this level is to protect the public from all risk. The standard of protection is zero risk tolerance. This standard was implemented under the Delaney Clause of the 1958 amend- ment to the Food, Drug and Cosmetic Act of 1938. Named after the Congressman Delaney of New York, the language of the bill called on the FDA to prohibit the use of chemical food addi- tive(s) that induce cancer in humans or animals (15). This criterion was applied to herbicides and pesticides in processed foods until 1996, when the Delaney Clause was removed. Emergency responders are often caught up in the desire to provide complete protection from all potential harm, including environmental harm. This is especially prone to occur when minimal informa- tion is known about a jurisdiction’s hazmat flows. Fundamentally, the zero-tolerance policy fails to recognize human mortality, vulnerability, and that bad things happen. Promising Practices for Conducting an HMCFS D-7 Hazmat Quantity Hazmat Characterization Objectives Ha zm at P re se nc e R el at iv e Qu an tity (e. g., # tru ck s, pla ca rds , o r sm al l, m ed iu m , a nd la rg e qu an tit ie s) Sp ec ifi c Qu an tity H az m at Y es /N o Cl as s/D iv isi on U N /N A P la ca rd ID Sp ec ifi c M at er ia l/C he m ic al Legal Takings and Route Designation < = = < < = = Resource Scheduling, Equipment Needs, Comprehensive Planning, Emergency Planning, and Maximum Scenario Definition < = > < = = > Awareness/Minimum Scenario Definition = = > = = > > < Information collected at precision level is insufficient for objective(s) = Information collected at precision level matches objective(s) > Information collected at precision level exceeds requirements for objective(s)

D.4.2 Maximum Protection This goal seeks to protect the public from all possible risk(s) and does not spend resources on the impossible or unforeseeable. This protection standard was originally cast from the con- gressional mandate for maximum public protection in the disposal of the unitary chemical stockpile (16). This risk was eventually standardized in the magnitude of 10−8, or greater than one chance per hundred million. Protection at this level is often characterized in the selection of protective actions for the public, including large-scale or general evacuations. D.4.3 Reasonable Protection This goal seeks to protect the public from all probable risk(s), eliminating risks with very low potential from consideration. This standard of public protection was originally cast in the Nuclear Regulatory Commission (17) language pertaining to the licensing of nuclear waste disposal for which applicants must assure that the proposed site, design, facility, closure, and institutional con- trols are adequate to provide reasonable assurance of protection to the general public. This risk was operationally defined as in the magnitude of 10−6 or greater than one per million. Providing rea- sonable protection might involve matching protective actions for various populations in a position to be directly harmed near the incident, including shelter-in-place protection for institutional pop- ulations and limited evacuation for mobile populations. D.4.4 General Protection This goal seeks to protect the public from risks that are most likely to occur under normal oper- ations. This standard of protection of the public is often used as the legal standard of negligence. Operators that fail to plan for these relatively common accidents with magnitudes of 10−4 or greater than one in a hundred thousand in routine operations would certainly be held account- able. In the railroad, computing, and chemical industries, this is often referred to as “five–nines” reliability. There are many such incidents, and routine tank-car or tank-truck incidents where flammable fluids are involved would be among them. Protection for these accidents is typically confined to the protection of emergency responders. Promising Practice 4: Match Protection Level with HMCFS Objectives describes how local entities can match desired level of risk with HMCFS objectives. Promising Practice 4: Match Protection Level with HMCFS Objectives Problem Once a jurisdiction’s desired level of protection and HMCFS project objectives have been defined, evaluating whether they are matched to each other can help ensure consistency of project results with their ultimate purpose: ensuring public protection. Promising Practice The objectives provide a focus for the HMCFS process but they also have direct implica- tions for the results of the study and the hazard management in the area. The desire of precise and exhaustive data is seldom realistic. A balance is achieved by matching the objectives with the protection levels of interest in the study area. D-8 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies

Emergency planning often uses accident scenarios for a given area to test preparedness across a distribution of accidents. Less specific outcomes require very little, mostly generic scenarios, but more precise detailed data are required for more specific out- comes. Awareness requires very little occurrence information, while route adjustments and takings have intense data requirements. This guidebook considers four levels of planning scenarios: complete protection from all risks, maximum protection from possi- ble risks, reasonable protection from probable risks, and general protection from most likely risks. Identify Boundary Conditions The vertical axis of the figure below illustrates HMCFS objectives in terms of increasing complexity. Trace along the row of the highest objective used for your HMCFS until it is matched with the desired level of protection. Matching the HMCFS objective(s) with the desired protection level helps the core team recognize the limits of the study. Promising Practices for Conducting an HMCFS D-9 Protection Level Considered Objectives Complete Maximum Reasonable General Legal Takings and Route Designation < < < = Resource Scheduling, Equipment Needs, and Comprehensive Planning < < = = Emergency Planning < = = = Maximum Scenario Definition < = = > Awareness/Minimum Scenario Definition = > > > < Too conservative—more decision weight is given to low-likelihood events than is warranted. = Matched—objectives are matched with protection level and corresponding risk. > Over-generalized—there is more information than needed for objectives. The Objectives-Protection Matrix has Advantages (A) and Disadvantages (D) A It matches the goals and objectives with the planning standard appropriate for these types of decisions. A It reduces chances of wasting resources to collect data that are not needed to reach decisions objective(s). A It reduces the likelihood of making decisions on insufficient information. D It inhibits mid-stream adjustments, espe- cially when decision outcome(s) are broadened to include greater informa- tion requirements. This can be overcome for special circumstances through focused, more in-depth investigations where needed, but are appropriately adhered to overall.

D-10 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies D.5 Stretch Limited Time and Resources Depending on the level and type of information needed, as well as the effort required to obtain that information, an HMCFS can range from a simple, low-cost effort to one that is very com- plex, involving the expenditure of a large amount of monetary or personnel resources. After identifying what needs to be done, the next step is to identify how it is going to be done, and who is going to do it. Promising Practice 5: Stretch Limited Time and Resources discusses options for funding an HMCFS. Promising Practice 5: Stretch Limited Time and Resources Problem Limited time and resources are often critical, especially for medium-to-large local entities where resources are limited, but hazmat flows are often large and complex. Such local entities may experience the funding “squeeze” from both ends. Resources to conduct HMCFS are often limited but at the same time critical to completing and implementing results. Grant mechanisms for the conduct of HMCFS—such as federal grant funding through the Hazardous Materials Emergency Preparedness (HMEP) Program (via SERCs)—may require matching funds. Local entities often lack experience using match funding mechanisms. They may not know that such funds are available, or do not under- stand mechanisms by which matching funds can be obtained and implemented. Improving local understanding about the use of matching funds through hard and/or soft matches (e.g., volunteer participation) is an important promising practice. Promising Practice LEPCs were established under EPCRA to implement the planning and recordkeeping aspects of the Act. Most LEPCs are voluntary in nature, and funding for their activities tends to be sparse and difficult to come by. The most common funding sources for LEPC activities include: volunteers, donated services, local government funding, grants, supple- mental environmental projects, and industry donations. The U.S.DOT’s HMEP grants are one way to fund an HMCFS. These grants carry a match requirement. The non-federal match requirement for HMEP grant funds is 25% of the grant value (this equals 20% of the total project cost). This match may be either a hard match (e.g., cash) or a soft match (e.g., in-kind contribution). OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments (18), defines match funding requirements for local entities that use federal grant funds, including HMEP grants. Most LEPCs rely heavily on volunteers and members for in-kind match contributions, such as volunteer hours. In-kind funding is not limited to hours that volunteers spend counting vehicles. An exam- ple of the activity categories, personnel, and rate calculation is shown below. Note that the activities, number of personnel, effort, and rates are hypothetical and provided as a summary spreadsheet example only. They may not reflect the activities, effort, or rates at any particular LEPC. Volunteer participants—Community volunteers for an HMCFS may include members of the Community Emergency Response Ream (CERT) or Citizen Corps Councils (CCCs), first responders, scout groups, college students, as well as members of the general public. Smaller and rural LEPCs often have the advantage in community support for this type of

volunteer contribution. Residents of these types of jurisdictions tend to be “vested” in the community and, as a result, are more apt to participate. Many LEPCs undertake an HMCFS due to third-party interest. These third parties also make good sources for in-kind matching resources (e.g., if a school district has a vested interest, they may be willing to pay bus drivers a few extra hours to become observers along their routes). Industry contributions—Some LEPCs receive industry donations (e.g., in the form of mem- bership dues) to augment local government contributions and to meet matching require- ments for grants. Industries may also make personnel available for participation in the HMCFS project. The following table is a potential, but not exhaustive, checklist of in-kind match, hard match, and other match sources. Match sources must document how they supported the HMCFS. Specific matching requirements can be found in OMB Circular A-87. In-Kind Match Sources (Volunteer Time) Hard Match Sources Other  Municipal Admin.  Planning Staff  Fire Department  Police Department  Health Department  Hospital  Comm. Advocates Promising Practices for Conducting an HMCFS D-11 Activity Personnel No. Effort Rate* In-Kind Value Notes Supervisors 6 2 hrs $50/hr $600 Line Staff 4 2 hrs $30/hr $240 Kickoff Meeting Clerical Staff 1 4 hrs $20/hr $80 Does not include mileage to/from meeting or meals Supervisor 1 8 hrs $50/hr $400 Line Staff 8 20 hrs $30/hr $4800 Clerical Staff 2 5 hrs $20/hr $200 Training and Data Collection Mileage 340 mi $0.50/mi $170 Supervisors 6 2 hrs $50/hr $600 Line Staff 4 2 hrs $30/hr $240 Line Staff 4 2 hrs $30/hr $240 Analysis, Application, Presentation Clerical Staff 2 2 hrs $20/hr $80 Example: review project results and ID equipment needs. Does not include mileage or meals. Total $7650 Matches $30,600 grant at 25% match requirement * Hypothetical rates. May reflect fully loaded rates with benefits, administrative costs, and overhead, not just base salaries. Matching funds must be documented according to OMB Circular A-87.  County Admin.  Zoning Commission  Emergency Mgt.  Sheriff’s Department  Industry Personnel  HazMat Carriers  CERTs  State (Emerg. Mgt., Environ., Trans., Hwy. Patrol, Other Agencies)  County  Municipal  Industry  Private  Mileage  Postage  Phone  Facilities  Meals  Mat’ls. & Supplies Sequenced HMCFS—Local entities experiencing the funding “squeeze” could consider sequenced efforts that are individually more limited in scope in any given funding year but accomplish the comprehensive HMCFS over a several-year period. This is particularly pertinent for LEPCs with staff limitations, local entities that rely on grant funding, or LEPCs that are conducting more extensive HMCFS efforts (e.g., either with broader, more interrelated jurisdictional coverage or level of detail). For example, a 2-year project might see an LEPC review and evaluate existing information and identify target areas for

collection of new data in the first year, and then collect and analyze the new data in the second year. Other possibilities might focus on one mode of transportation in one fund- ing year and another mode in subsequent years, or focus on one corridor in one year and another thereafter. Using Matching Resources has Advantages (A) and Disadvantages (D) A Donations from industry help fund HazMat CFS effort and provide incentive for industry participation and commitment. A In-kind contributions used in lieu of hard matches provide matching funds and assure participation of interested parties. A Even small in-kind contribu- tions can contribute to the overall commitment and promote buy-in to the process. A Volunteers and in-kind contributions are often easier to coordinate in rural jurisdictions. D.6 Consider Consecutive-Year Studies Many locations have seasonal traffic variations associated with industrial, agricultural, or other economic bases. As identified in FHWA’s Traffic Monitoring Guide, it is important to keep the following in mind: Truck traffic patterns are governed by a combination of local freight movements and through-truck movements. Extensive through-truck movements are likely to result in higher nighttime truck travel and higher weekend truck travel. Through-traffic can “flatten” the seasonal fluctuations present on some roads, while creating seasonal peaks on other roads that have nothing to do with economic activity asso- ciated with the land abutting that roadway section. . . . Local truck traffic can be generated by a single facil- ity such as a factory, or by a wider activity such as agriculture or commercial and industrial centers. These “point” or “area” truck trip generators create specific seasonal and day-of-week patterns much like recre- ational activity creates specific passenger car patterns. Truck trips produced by these generators can be highly seasonal (such as from many agricultural areas) or fairly constant (such as flow patterns produced by many types of major industrial plants) (14, Section 4, Chapter 3, Permanent/Continuous Classifiers section, Create Initial Factor Groups subsection, paragraphs 1 and 3). The annual grant funding cycle through the HMEP Grant Program creates challenges for col- lecting HMCFS data for more than one or two seasons, unless multi-year efforts are specifically programmed through a state’s SERC (and then funding is contingent on appropriation of HMEP funds and approval of funding administrators) or conducted using other funding sources. How- ever funded, partitioning a complex HMCFS over several years can provide an incremental D-12 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies D Because donations from industry are often volun- tary and rely on the generosity and ability of the local industry to contribute, they can vary from year to year and project to project. This can be overcome by actively engaging donors in the process. D In-kind contributions can be very difficult to track and coordinate. This can be overcome by setting up effort tracking systems and careful record keeping. D Volunteer workforces may prove difficult to coor- dinate and supervise, particularly in large, complex metropolitan areas. This can be offset by the added buy-in from the workforce for the project and the goals of the LEPC. D Volunteer data collection has limited quality control. This is best overcome by training, including stressing the importance of accuracy and care required in making hazardous materials observations.

approach to a more complete outcome using resources available and it can allow for collecting seasonal data. Promising Practice 6: Consider Consecutive-Year Studies covers how an HMCFS can be scaled over several years to address scheduling and resource limitations, which may be particularly applicable in large jurisdictions. Promising Practice 6: Consider Consecutive-Year Studies Problem Limited timeframes often create artificial temporal boundaries for conducting an HMCFS. Local entities apply for grants to conduct the study, receive funding in the early months of the fiscal year, collect data during the late spring/early summer, and report results in the fall, leaving out seasonal traffic variations. Promising practice One way to deal with these time constraints is to plan a more comprehensive and complete HMCFS over several years. Through these project phases, the HMCFS pro- duces additional information each year and also considers the need for seasonal adjustments, more detailed work along certain corridors, or investigating specific con- cerns raised by third parties in interviews. Several examples of activities are shown in the following table. Example Activities I II III Year 1 Study of primary corridor(s): Study of primary corridor(s): Study of primary corridor(s): spring–summer existing data only spring–summer • Interview key informants about other areas of concern • Identify key concerns not addressed by baseline • Present results from baseline study • Plan Year 2 activities Year 2 Study of primary corridor(s): Study of primary corridor(s): Study of secondary fall–winter collect new data corridor(s): spring–summer • Conduct focused investigations to address critical concerns • Update baseline study with expanded information • Brief critical CFS stakeholders • Plan Year 3 activities Year 3 Study of secondary Study of primary corridor(s): Investigate potential for corridor(s): spring–summer fall–winter seasonal variation: fall–winter (key corridors) • Focus on overall analysis • Plan response(s) in terms of adjustments to: hazmat routes, comprehensive planning, emergency equipment needs, and emergency plans/operations Promising Practices for Conducting an HMCFS D-13

Consecutive-Year Studies have Advantages (A) and Disadvantages (D) A They allow local entities to collect more detailed information over time. A They promote efficient use of available resources. A They allow for local feedback and two-way communication among key stakeholders. A They can focus on the most serious hazmat flow issues raised in the area over time. A They identify new and unknown issues through feedback with stakeholders. D.7 Use Volunteers to Conduct HMCFS Coordinating volunteers and keeping them engaged through a complex HMCFS can be a chal- lenge. Promising Practice 7: Use Volunteers to Conduct HMCFS presents issues particularly relevant to LEPCs for conducting an HMCFS using volunteer participation. Promising Practice 7: Use Volunteers to Conduct HMCFS Problem The LEPC is a focal point for hazmat emergency management and preparedness in local jurisdictions. An LEPC is made up of volunteers from the community it serves. LEPC membership includes representatives selected by the local governmental entities and is approved by the SERC. The LEPC membership must include local officials, police, fire, civil defense, public health, transportation, and environmental professionals, as well as representatives of facilities subject to the emergency planning requirements, commu- nity groups, and the media. Keeping this critical group of community leaders involved in the HMCFS is essential to a well-informed study that is able to meet the project’s objectives. Promising Practice The voluntary composition of, and participation in, the LEPC are both the greatest strength and weakness of the committee. In an active LEPC, each member brings unique perspectives to the committee, and the diverse public and private views of the commu- nity being represented. The equal representation of views and knowledge is the commit- tee’s greatest strength. Additionally, the diversity of the committee provides increased resources and allows the committee to become a mechanism for collaboration between various industry and the community interests. Some LEPCs suffer from passive participation. This lack of participation is often the result of members or potential members—or the entities that they represent—not D-14 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies D Data for any given place may be less current as they are not collected every year. This is offset because more detailed data are obtained in the long-run, especially in places where there is little year-to-year variation in hazmat transport. D They require long-term commitments from participants or participant organizations and can be challenging to coordinate and supervise, particularly in large, complex metropolitan areas. This can be offset by the buy-in that committed organizations provide to the effort and the LEPC’s ongo- ing activities.

understanding the importance of the committee’s functions. The consequence of this lack of participation is a weak or inactive LEPC that struggles to fulfill its responsibilities to the community. Hence, participation by the LEPC in the HMCFS is important to the success of the study. Demands on LEPC volunteers can be time consuming, and without the cooperation and support of local government and industry, finding qualified volunteers and members can be a daunting task. Because an LEPC is voluntary in nature, LEPCs are often unmanned and under-funded as noted in the 2001 National Institute of Chemical Studies report to the EPA regarding LEPCs and risk management plans (19). This study examined how LEPCs could use risk management plans to improve community safety and promote hazard reductions. The study found that encouraging hazard reductions was recognized as a logical role of many LEPCs, and there were a number of challenges and concerns that hindered them from implementing that role. Among the concerns were: lack of mandate under EPCRA, lack of resources, lack of technical expertise, unclear responsibili- ties, public apathy, and lack of support. The study team recommended a number of ways that the EPA could address LEPC concerns and strengthen their role in hazard reduction. LEPC-conducted HMCFS—When an LEPC conducts its own HMCFS it fosters the active par- ticipation of its members in the emergency planning process. Participation of committee members in a commodity flow study is achieved especially through member participation in project planning, data collection, analysis, and other HMCFS activities. Contractor-conducted HMCFS—Some LEPCs may also choose to hire an outside entity to conduct the study. If an outside contractor is used to collect the data and conduct the study, the LEPC still needs to be actively involved in the study. Involvement by the com- mittee in the process increases the understanding of the process and can also be used as part of the match that may be required by grants. LEPC Participation Checklist There are various activities in which LEPC members can be involved throughout the HMCFS process. The following checklist is not intended to be comprehensive or exhaus- tive, but rather suggests the kind of activities that may assure LEPC participation in the process. LEPC members may be asked to  Provide HazMat transport data;  Provide or augment planning support;  Provide or augment logistic support;  Provide facilities for planning meetings, training, and analysis;  Recruit and/or coordinate volunteers;  Volunteer for data collection efforts;  Provide expertise in consultant roles throughout the process;  Provide input to the contractor about the purpose and use of the study;  Provide input about historical events or special local situations that may not be readily known;  Provide assistance to the contractor in acquiring data (e.g., LEPCs are able to more readily access data from Tier II companies and some transporters such as rail and barge companies);  Provide input on whether site locations for data collection sites meet the needs of the jurisdiction; Promising Practices for Conducting an HMCFS D-15

 Serve as a study liaison to media outlets;  Review results to assure broadest possible appropriate application;  Present to, and discuss results with, local entities;  Serve as critical informants; and  Lead/coordinate data collection effort(s) at specific locations, or at some particular time period. Volunteer HMCFS Participation has Advantages (A) and Disadvantages (D) A It provides understanding and insight into types of hazardous material travers- ing the jurisdiction and patterns of flow. A Volunteer involvement increases the understanding of the process by the LEPC. A Participation can also be used as part of the match that may be required by grants. A Participation in the HMCFS is likely to increase interest by members in the functions of the committee, which promotes a more active LEPC. A Contact by LEPC members with industry during the study can be used as a mechanism for recruiting new members to the committee. A Participation in an HMCFS can demonstrate utility and thereby help retain existing LEPC members. D.8 Use Existing Data Sources Even for the experienced, remembering the numerous sources of data can be onerous. Promising Practice 8: Use Existing Data Sources presents a summary of existing data sources that allow users to tabulate the availability and relevance of different data sources and can help to determine where focus needs to be placed for collection and evaluation of exist- ing data. The checklist is not exhaustive of all the information sources included in this guidebook. Promising Practice 8: Use Existing Data Sources Problem The task of identifying relevant existing data sources can seem daunting. Local leaders report “not knowing where to start” in the early phases of an HMCFS. D-16 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies D Commodity flow studies conducted inter- nally may compromise objectivity as local entities and leaders inject concerns. This may be overcome by assigning roles in HMCFS that are independent of on-going political or agency roles. D Commodity flow studies conducted by an outside source may discourage par- ticipation. This is best overcome by using contractors with a record of encouraging participation and specifi- cally asking local officials to participate in the process. D Participation in the study process may bur- den already overworked and overcommit- ted volunteers. This is overcome by allowing volunteers to limit participation, lead others, and supervise others in the completion of assigned tasks. This takes advantage of special skills and knowledge sets and reduces overall burden.

Promising Practice A list of potential sources can help those conducting an HMCFS (especially first-timers) to start the process. Review each source on the list to identify whether it has data applicable to your jurisdiction, HMCFS objective, and data requirements. There are many sources of data and any list (including this one) cannot pretend to be complete. Federal sources of data are the most comprehensive in terms of the types of data available. State data sources vary but can be nearly as comprehensive and more relevant to local concerns. Local sources are often unique to each locality. They include data provided by good cor- porate neighbors, but efficiently obtaining these data can depend on personal relation- ships and contacts. Federal sources of data include data on transportation and accidents, hazardous materi- als, mapping, emergency preparedness, and population exposure. Hence, data archived by U.S.DOT agencies (PHMSA, FHWA, FMCSA, BTS, STB, and FRA), the U.S. Department of Homeland Security (FEMA and USCG), U.S. Census Bureau, NTSB, U.S. Geological Survey, U.S. Department of Agriculture, and National Oceanic and Atmospheric Administration are often found to be useful. State sources of data often include many of the same types of data as the federal sources, on transportation and accidents, hazardous materials spill/incidents, and emer- gency response and preparedness. Data are often archived in state departments of trans- portation, the highway patrol agencies, environmental quality or natural resources agencies, and emergency management agencies. Local sources of data include county and municipal offices, as well as local private corporations. The county judge’s office, local mayor’s office, and even the chamber of commerce can often provide data about growth/decline and geo-location of local popu- lations. Local sheriffs’ departments, police departments, fire departments, and emergency managers can often provide information about recent (and sometimes historical) acci- dents and events. Local industry participants are often active in the LEPC and can be engaged to provide relevant data. Many of these people can provide insight into poten- tial issues of concern through key informant interviews. The Existing Data Source Checklist has Advantages (A) and Disadvantages (D) A It provides a starting place for data acquisition efforts. A It helps avoid some important sources being overlooked. Promising Practices for Conducting an HMCFS D-17 D It is not to be interpreted as exhaustive—the HMCFS will develop other data or data sources as shown to be relevant. This can be overcome by thinking of the checklist as a place to begin the search for existing information rather than an exhaustive list of data sources. Remember that no list can be exhaustive in this ever-changing information age. D Data from some sources may require validation and “cleaning” to accurately reflect the local situation— data cannot always be taken at face value, and these are no exception. This is overcome by examining data for apparent inconsistencies and making appropriate corrections based on other relevant information.

Applicability to Local HMCFS Not Not Low High Existing Data Sources Avail. Appl. Appl. Appl. Prior CFS     Adjacent Jurisdiction CFS     Electronic Sources FEMA HAZUS-MH     FHWA Freight Analysis Framework     BTS National Transportation Atlas Database     PHMSA Incidents Reports Database     FMCSA Nat’l Hazmat Route Registry/Maps     FHWA Highway Performance Monitoring System     Census Bureau Vehicle Inventory and Use Survey     FMCSA SAFER Company Snapshot     PHMSA Company Registration Look-Up Tool     STB Carload Waybill Sample     FRA Rail Safety Data     PHMSA National Pipeline Mapping System     USCG Marine Casualty and Pollution Database     Census Bureau Census     USGS National Map     USDA Web Soil Survey     NOAA National Climatic Data Center     BTS Commodity Flow Survey     FHWA National Statistics and Maps     BTS Freight Data/Statistics     NTSB Accident Reports     FMCSA Crash Statistics     USACE Reports (various)     Shippers and Receivers Facility A: __________________________     Facility B: __________________________     Etc. D-18 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies

Carriers Class I RRs: BNSF, CN, CP, CSX, KCS, NS, UP     Class II RRs: Regional: _____________________     Class III RRs: Shortline, Port & Terminal, etc.     Pipelines     Waterways     Airlines     Other Local, State, Tribal, or Federal Agencies Emergency Management/Response     Environmental Protection     Homeland Security     Transportation and Public Works     D.9 Use Hotspots Analysis A hotspots analysis is a way to relate four critical components of hazmat risk analysis: time, space, hazardous materials, and people (or the environment). The analysis can help identify times and places where the co-location needs special attention. Hotspots, which are discussed in Promising Practice 9: Use Hotspots Analysis should be easily understood and self evident in that little inter- pretation is required. Promising Practice 9: Use Hotspots Analysis Problem Using the HMCFS to identify unique areas of concern in the local area provides insight into critical issues in emergency management, including hazmat route designation, resource allocations, and potential consequences. Yet, local entities may not know how to interpret data to identify associated hotspots—specific areas of concern or unique risks. Promising Practice Areas of potential concern are identified by an overview of risks associated with the transport of hazmat over the transportation network. Determining specific areas of concern is done by a hotspots analysis. Possible Hotspot Analyses Planning for emergency response capabilities: This analysis determines the existing coverage of hazmat response equipment and facilities and determines where current and future gaps exist. Promising Practices for Conducting an HMCFS D-19 Applicability to Local HMCFS Not Not Low High Existing Data Sources Avail. Appl. Appl. Appl.

Hazards identification: This analysis determines locations where hazmat incidents occur at elevated levels. This may result in finding locations along the transportation network or locations at, or near, fixed facilities. Land use compatibility: This analysis determines locations where hazmat-related land uses and adjacent land uses are not compatible. This is important when considering rede- velopment or new development of land uses adjacent to hazmat routes, industrial areas or facilities where hazardous material is prevalent, and high-risk areas. Data and Resource Needs The data required for this type of analysis come from various sources and are largely a factor of the complexity of the desired analysis. Most, if not all, of the hazmat-related data, such as fixed facility locations and commodity flows, come from the data collection portion of the commodity flow study. Hotspots analysis goes beyond the hazmat-specific data, and requires additional data integration to supplement already acquired data. Hotspots analysis data are spatial in nature; that is, they represent something geographi- cally identified, such as transportation networks or streams. In addition to spatial data, there are also temporal data, such as hourly traffic flows on targeted roadways, hours of operation of certain fixed facilities, or seasonal traffic patterns. The following table pro- vides an inventory of data items that may be useful in a hotspots analysis. The simplest way to identify relationships between data sources is to examine existing printed maps. This task may be more easily accomplished by using resources available on the Internet, such as online maps. Many online maps have multiple data items identified, such as schools or rivers, in addition to transportation networks. Types of Data: Geographic • Transportation  Road and intersection locations and characteristics  Infrastructure (bridges, drainage, etc.)  Traffic volumes and mixes  Truck counts  Rail lines, sidings, and yards  Truck stops  Port or intermodal facilities  Traffic accident locations  Highway-rail grade crossings • Hazmat/Emergency Response  Spill and/or release locations  Hazmat incidents  Designated hazmat routes  Fixed facilities  Hazmat commodity flows  Fire stations/emerg. response teams  Military installations  Other emergency response facilities/resources D-20 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies • Human  Population locations  Schools  Parks and recreation locations  Hospitals  Colleges/universities  Employment centers  Future growth/development areas  Tourist/cultural points of interest  Land use/zoning  Special needs populations • Business  Business locations where hazmat is produced, shipped, and/or received  Business parks or clusters  Local/regional development locations • Environmental  Drinking water sources  Habitat: oceans, lakes, rivers, wetlands, etc.  Land coverage, topography and soils

Types of Data: Temporal • Hourly traffic flow distribution  By roadway and/or roadway type  Truck volumes • Hourly/seasonal LOS, congestion Types of Data: Other • Interviews  Fire, police, and emergency response  Industry and business representatives  Transportation providers  General public Promising Practices for Conducting an HMCFS D-21 • Hours of operation  Facilities, businesses, etc.  Schools, employment centers, etc. • Weather conditions  Daily/seasonal temperatures  Daily/seasonal wind conditions  Daily/seasonal precipitation It is also important to investigate the online resources that are available from local and regional planning entities. Many now have online thematic maps and online GIS maps that are avail- able at no charge. On a national level, the USGS maintains “The National Map,” which is an online GIS map viewer capable of displaying a wide variety of spatial data for use in a spatial analysis. Electronic geographic features and locations may require “ground-truthing” or confirmation with local observations. For-purchase professional GIS software is also a valuable resource for hotspots analysis. These packages are capable of displaying the data layers in a single output and also have powerful built-in functions that perform complex spatial analyses. Hotspots Analysis Procedures Clarify analysis needs: Current Internet and GIS software allows for complex analysis to be performed; however, the project’s data analysis needs may warrant a simpler solution using existing printed maps, databases, and charts. Data coordination: The data requirements largely correlate to the hotspots analysis complex- ity. Users can identify both required and desired data sources for the analysis from the data source inventory above. Local, regional, or state planning organizations may already have data available in formats easily incorporated into the hotspots analysis. Perform analysis: Hotspots analyses are largely spatial in nature. Displaying the data layers in relation to each other is the critical initial component of the analysis. Using the mapping or software resources allows for evaluation of many data elements to identify the hotspots within a focused study area. Periodic monitoring: Changing conditions on roadways and development patterns necessitate periodic review of the hotspots analysis. Regular reviews allow for minor adjustments to an existing analysis compared to entirely reformulating the analysis after conditions have signifi- cantly changed. Example—San Diego Hazardous Material Commodity Flow Study The San Diego Hazardous Material Commodity Flow Study, conducted by the EPA and published in June 2001 (28), contains a chapter on hotspots. The report indicates that hotspot analysis will assist in emergency preparedness for the region by determining the

“placement for hazardous materials response equipment and facilities, and training priorities for emergency responders.” The hotspots discussion addresses the following: • San Diego Geography—includes a mention of the population growth experienced in the region and expected growth levels, major redevelopment areas in the study area, and hazardous material spills; • Environmentally Sensitive Areas—includes the water supply and resources in the area; • Human Sensitive Areas—includes schools, hospitals, public places (parks, etc.), and densely populated areas near heavy hazmat traffic flows; and • Customhouse Brokers—includes warehouses operated by customhouse brokers that deal with hazmat shipments. For the analysis, maps are utilized that show the relationships between the transporta- tion infrastructure (i.e., roads, rail), environmentally sensitive areas (i.e., streams, lakes), human sensitive areas (i.e., hospitals, schools), emergency response facilities (i.e., fire stations, police stations), and cumulative reported hazmat spills for a 5-year period. A zoomed-in portion of the map included in the San Diego report follows. D-22 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies Source: U.S. Environmental Protection Agency, San Diego: Hazardous Material Commodity Flow Study, June 2001, p 44.

An additional map displays the development and redevelopment activities in the region. Although not mapped against hazmat-related data, such as spills, this type of coordina- tion between economic development, land use planning, and emergency planning works to provide a safer community. Conducting A Hotspots Analysis has Advantages (A) and Disadvantages (D) A It provides a mechanism to combine multiple data layers into a single tool for analysis. A Many data sources and analysis tools are available online. D.10 Use Risk Communication Checklist Communication with stakeholders is a critical element of a successful HMCFS. Promising Practice 10: Use Risk Communication Checklist provides a list of entities with which HMCFS communication may be considered. Promising Practice 10: Use Risk Communication Checklist Problem Limited communication of HMCFS restricts its utility for the community as a whole and the opportunity for feedback and validation. Promising Practice Locations, people, or offices to consider for the communication of the completed HMCFS are listed by group in the table that follows. Risk Communication Checklist Identify the user/user group communities in each category that will receive an HMCFS briefing, presentation, or training session focused on the results of the study. This check- list is not intended to be a comprehensive list of all people or offices that should receive a copy of the HMCFS but rather a list of potential users and user groups to be considered and expanded upon to meet unique local needs. Promising Practices for Conducting an HMCFS D-23 D Costly GIS software purchase may be required if free resources are not adequate for analysis. Run- ning GIS software requires sufficient computer systems. Complex systems and analysis can require specialized skill sets. These can be overcome by use of free software such as QGIS, which is a mul- tiplatform, GIS package available on the Internet, or by the use of overlays done by hand over/on printed area maps. Emergency Planning and Response/ Other Departments:  LEPC/TERC members  Fire departments  Police & sheriffs’ departments  SERC and other state agencies  Hospitals and public health officials  Community planning offices  Transportation planning offices  School officials  Other LEPCs in area  Federal agencies

Using a Risk Communication Checklist has Advantages (A) and Disadvantages (D) A Suggests a comprehensive list of potential HMCFS users. A Identifies groups of offices, officials, and people that may have a vested interest in the HMCFS outcomes. A Identifies groups of offices, officials, and people that could be approached to support the HMCFS effort. D.11 Demonstrate Local Risk Using the results of the HMCFS to inform the public, public officials, and community lead- ership is one very useful outcome of the HMCFS process. Implementation involves actively engaging various groups of interested parties, stakeholders, community leaders, industry, and other end users. Demonstrating local risk also can be a key element to obtaining support of local leaders for addressing hazmat emergency planning and response needs, including funding sup- port. Promising Practice 11, Demonstrate Local Risk encourages users to employ the HMCFS results to demonstrate local risk. Promising Practice 11: Demonstrate Local Risk Problem As predominantly volunteer organizations, LEPCs often report limited support for their activities. Because of low probabilities associated with initiating events (catastrophic inci- dents), emergency managers often report difficulty attaining support from local authori- ties and the public for emergency planning. Compared to routine activities, demonstrating the need for new equipment, expanded personnel, or enhanced training is difficult when the likelihood of the needs being realized is perceived to be low by decision makers. Promising Practice Communicating the risks associated with hazmat transportation through an area can help local leaders understand the importance of preemptive actions for risk reduction D-24 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies Public Administration:  County commissioners  City manager offices  Mayors’ offices  Council members  County judges General Public:  Public meetings  Local media (newspaper/TV/radio)  Internet  Public library  Newsletters to local residents D Checklists may limit the dissemination of the HMCFS by substituting for innovative approaches some LEPCs use in such circumstances (e.g., hazmat fairs, or brochures/ posters/flyers, targeted presentations). This is overcome by encouraging innovative approaches to two-way risk communication among stakeholders. D Some unique circumstances may suggest keeping HMCFS information confidential; however, journalists and the public can file a Freedom of Information Act request. This is overcome by redacting sensitive material from the HMCFS in unique cases where pub- lic safety may be harmed or sensitive information disclosed.

and mitigation. Certainly, risks that have greater likelihoods than others will require attention with high priority, but the relative likelihood of lower probability events may not compete with everyday routine activities. Hence, trying to demonstrate hazard potential with low-probability risk often meets with frustration. Focus on outcomes and their associated consequences for people in the community. Give the consequences a human quality. For example, rather than “the expected loss of life from such an accident is 3.6 people,” present the loss as a parent, child, and the child’s friend—the only child of their neighbors. How would the decision maker feel if it hap- pened on their street, to their child? Make it personal. Point out especially vulnerable populations with special needs. Remember the risk may have equal likelihoods of occur- rence, but the same consequence is not uniformly valued. Consider the value associated with the deaths of various people (e.g., an infant, a father, a single mother, a homeless man, a high-school senior, or a senior citizen). Use the media to help the public understand the risks in the area. LEPCs have media members to help get the message out. Enlist their help in composing the message and getting the attention it deserves. Make a big deal of it when short falls are not improved by making local leaders responsible for their decisions. Be sure to compliment leaders when they are responsive. Demonstrating Local Risk Use empirical data where possible to characterize the distribution of risk in the commu- nity and show statistically where the risks of interest are located in the distribution rela- tive to other known risks. Characterize the consequences of the risk in terms of the anecdotal evidence when possi- ble. For example, the loss of a hazmat team member is a life-time of earnings that can be calculated until a typical retirement date; it can be a detriment to morale on the team and in the department and may even lead to turnover issues if it is related to decisions made in the organization. In some cases, it may mean children growing up without one parent and the outcomes associated with that situation. Demonstrating Local Risk has Advantages (A) and Disadvantages (D) A Gaining attention for hazmat issues can help attain equip- ment and personnel, change hazmat routes, and engage in better community planning to enhance preparedness and decrease the likelihood of serious accidents. Promising Practices for Conducting an HMCFS D-25 D Dramatic overload can result when dealing with technical subjects that involve high risks and low probabilities. This can be overcome by keeping discussions about risks and probabilities of conse- quences realistic. D The desire to bring attention to hazmat risks may lead to the temptation of embellishing HMCFS results. In the long run, this can create misunder- standings and result in loss of credibility. This can be avoided by sticking to the facts about what was observed and the HMCFS project’s limitations.