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Preventing “Double Disasters”

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Climate Justice Public Protections Responsive Government Air Chemicals Climate Environmental Justice Water

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A joint policy brief of the Center for Progressive Reform, Earthjustice, and the Union of Concerned Scientists

July 2021


It’s past time to address “double disasters” — hazardous chemical releases by industrial facilities that are worsened by inadequate action in the face of conditions of climate change and natural disasters. As the global climate crisis intensifies, coastal and inland communities are increasingly at risk of natural disasters. When industrial facilities in these communities fail to adequately prepare for extreme storms, wildfires, earthquakes, heat waves, floods, rising sea levels, and other natural disasters, hazardous chemicals stored onsite can ignite, explode, and there may be dangerous and even catastrophic releases that threaten the health and safety of workers and the public. This can lead to a cascading series of harms, including toxic chemical exposures, on top of the effects of the storm itself.

Officials of the U.S. Chemical Safety and Hazard Investigation Board (CSB), an independent federal agency, and other safety experts have highlighted the need for stronger action in response to these natural hazard-related technological (also known as “natech”) disasters. Members of the public are also calling for reform. Workers have cried out for action after being “locked in” at inadequately prepared chemical facilities during hurricanes. Fenceline communities — people who live near major industrial sites — have also demanded government action to end the “second storm” of pollution. This brief spotlights this urgent issue, proposes policy solutions, and calls on federal leaders to take bold and prompt action to solve this problem.

The U.S. Environmental Protection Agency (EPA) administers the Clean Air Act’s Accidental Release Prevention program, which regulates industrial facilities that use, store, and/or manage highly hazardous chemicals like hydrogen fluoride and chlorine. This program, commonly known as EPA’s Risk Management Program (RMP), is responsible for preventing hazardous chemical incidents and protecting workers and communities from death, injury, toxic exposure, property damage, and other harms. Sadly, it has a notorious history of failing to prevent serious chemical disasters; EPA has studied thousands of such incidents during the last decade, and more than 100 harmful incidents occur every year in the United States.

RMP Facilities at Risk

The RMP regulates about 12,331 chemical facilities in the United States, such as chemical manufacturers, oil refineries, water treatment plants, industrial agricultural facilities, and pulp and paper mills. About a third of these facilities are exposed to risks of wildfire, storm surge, flooding, and sea level rise, which are increasing dramatically as the climate changes. That means almost 4,000 facilities — many of which are near residential communities — face a greater threat of a natural disaster. Yet EPA’s regulatory program neither addresses climate change nor requires these facilities to take any specific actions to protect people from the cascading effects of natural disaster-related chemical releases or the cumulative and compounding hazardous exposures that can result.


CPR, Earthjustice, and UCS recommend that EPA require RMP facilities to:

  • Assess natech risks and implement prevention and mitigation measures, like backup power and safer equipment and systems.
  • Inform communities about natech emergency response plans.
  • Involve workers and their representatives in natech preparedness and response practices.
  • Monitor and collect toxic air emissions data in real time.

The organizations also call on EPA to:

  • Expand RMP coverage to more facilities in areas prone to natural disasters.
  • Build prompt implementation and compliance design into new rules.
  • Take and support actions to invest in community protection, enforcement, and infrastructure that are responsive to climate, equity, and justice.
Read the full brief.

Climate Justice Public Protections Responsive Government Air Chemicals Climate Environmental Justice Water