Environmental Justice (EJ) is a priority of the EPA under the Biden Administration, and impacts extend well beyond increased public involvement as the “all-of-government” approach rolls out across the nation. Here are three key reasons to keep abreast of these developments:
- Title VI of the Civil Rights Act of 1964 – State agencies can lose federal funds if found to be out of compliance with Title VI nondiscrimination obligations. This brings tremendous pressure to bear on both regulatory agencies and the facilities they oversee. Civil Rights investigations are currently pending over recent permits issued to facilities by different state agencies.
- CLEAN Future Act Legislation – H.R. 1512, introduced in March of this year, proposes to define all areas with annual mean concentrations of PM2.5 of greater than 8 μg/m3 over the most recent 3-year period as an “overburdened census tract.” If passed, this bill would immediately prohibit new major sources in such areas, and shortly thereafter, prohibit permit renewals of major sources in these areas. (Note the current national standard is 12 μg/m3.)
- Increased Funding and Promotion of NGOs – The number, power, and reach of non-government organizations (NGOs) is expected to grow. This means a greater number of stakeholders to consider and more sophisticated and sustained involvement to accommodate.
For up-to-date information about EPA’s Environmental Justice funding opportunities, events, and webinars, you can subscribe to EPA’s Environmental Justice listserv by sending a blank email to: [email protected].
Join our live risk communication webinar hosted by the Air & Waste Management Association on Wednesday, Sept. 22, 2021. This risk communication primer will focus on the dynamics of risk communication and how to lay the groundwork for success.
Environmental Risk Communication: Principles and Practices for Industry
While standards of practice evolve and technology speeds forward, sound principles endure. In Environmental Risk Communication: Principles and Practices for Industry, we lay out the principles that govern sound communication and relationship building:
- Walk the Talk
- Set Goals
- Know Your Audience
- Deal with Emotional Elements First.
In addition, we offer time-tested best practices, tools of the trade, and lessons learned from the field. The book serves as both a grounding in sound principles and as a reference for navigating your way through risk communication efforts amid ever-changing communication landscapes.
For a limited time, receive 20% off when you order on-line through Routledge with the code FLR40.
Weed and Feed—A Springtime Reminder to Care for Your Stakeholders
Barely a month into spring, and the sweet pea vines I thought were eradicated last year are weaving menacingly around the peony shoots in my garden. It strikes me that “care and feeding,” the term used by public relations consultants for tending to stakeholder relationships, is sometimes not enough for growth and survival. If left unchecked, the peonies would certainly succumb to the vines’ crushing weight and theft of sunlight.
Like weeds (and unwanted sweet pea vines), any number of distractions, misunderstandings, and misinformation campaigns can choke the growth of new or fragile relationships. So, in addition to routinely tending to your desired stakeholder relationships, don’t forget to keep your eyes open for issues or antagonists that threaten from the sidelines. Everyone’s “stakeholder garden” is eventually thrust into the spotlight—whether due to a controversial permit application, a safety or environmental incident, an unexpected change in alliance, or some other trigger. If you are striving for best in show under challenging circumstances, keep up with the weeding alongside the feeding.
While apathy can be just as hard to overcome as outrage, the challenges arise from different human tendencies.
If you’ve ever had to communicate to stakeholders whose emotional reactions far outweigh a scientific risk, you know that listening and empathy are keys to success. But what about when you’re addressing stakeholders who are “underreacting” to risks, such as residents living in high-radon risk zones who don’t test their homes, or employees who wear respirators only when their supervisor shows up?
When you are communicating risk for the purpose of ratcheting up people’s concerns and prompting behavior, you’re practicing the opposite of outrage. You’re not helping people calm down, you’re trying to get them adequately concerned, so some of your challenges are going to be very different. Among the obstacles you will face:
- Cognitive Dissonance – We search for ammunition in support of our behaviors, even when we know they’re wrong.
- Habits – When natural negative consequences of unsafe practices (e.g., injury, death) are weak, delayed, or infrequent, our habits for taking shortcuts are positively reinforced over and over again.
- Confirmation Bias and Optimism Bias- Selective exposure and selective attention are our first lines of defense against information we don’t want to know about. Moreover, we all think that we’re smarter and luckier than the average person; yet, statistically, that can’t be true.
While some techniques for successfully overcoming these obstacles are consistent with overcoming outrage (e.g., providing more direct control to stakeholders and testing your messages first), others may require using techniques outside of tradition. These include:
- When making recommendations, frame minimum precautions with less protective and more protective options.
- Stress self-efficacy—when people are confident that they can do something, they will be more inclined to try.
- Be willing to capitalize on motivations that aren’t related to the issue, such as people’s desire for social acceptance.
Be First. Be Right. Be Credible.
That’s the advice printed across Crisis Emergency Risk Communication (CERC) guides based on a core principle of communicating in a crisis—limit information to the three most important things. Copies of the Centers for Disease Control guides were shared by Dr. Elizabeth Felter of the University of Pittsburgh Graduate School of Public Health in a May 2017 presentation at the Allegheny County Health Department.
“Only about 5 to 15 percent of information gets through to people in a disaster because of the high mental noise,” said Felter. “People take in, process and act on information differently than under normal circumstances.”
Key crisis communication tips shared by Dr. Felter:
- Use positive language. People may only remember a few words, so instead of “Don’t take the elevator,” they may only hear “elevator.”
- Don’t wait for all the facts. People tend to “anchor” to the first source of information in a crisis. It’s OK to tell what you know for certain and what you will share as soon as you know.
- Express empathy. People make up their minds about whether they trust you in mere seconds. And 50 percent of what they consider is based on whether they think you care about them.
- Plan and test and plan. Ninety percent of your communication planning should be done PREcrisis. Test your plan, and be brutally honest in assessing performance.
- Don’t ignore social media. Mobile aps and social media combined now make up the main source of people’s information in an emergency. At a minimum, post a Frequently Asked Question page—it can help take the place of the bygone phone bank script.
In today’s society of information overload and social media wildfires, those tasked with communicating about environmental issues may be tempted to take a back seat or shell out big bucks for the latest in public relations wizardry. Both approaches could prove costly and damaging in the long run. The fact is, the makings for sound communication and stakeholder engagement lie within your organization. Regardless of the size of a company or its budget, every organization can strengthen its communication foundation in three key ways:
Invest in understanding—Despite decades of communication research proving otherwise, we still engage in discussions as if our audience shares our same knowledge and perspective. Even the smallest investment in understanding stakeholders’ perspectives pays big dividends in the effectiveness of dialogue.
Prepare tangible plans—Without mandates and compliance deadlines, communication efforts can suffer from back-burner syndrome. Tangible plans with feedback loops protect communication investments and ensure an organization stays positioned for success.
Commit to principled engagement—Efforts seen as mere reputation polishing can set an organization back further than where it started with its stakeholders. When engaged through an earnest and transparent process, stakeholders are more receptive to effective, two-way dialogue.
With the dust settled on OSHA’s adoption of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in its Hazard Communication Standard (HCS) regulations, EPA has now incorporated the revised HCS language into its hazardous chemical reporting regulations.
The revisions affect the reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA), specifically, hazardous chemical inventory form reporting (Section 312) and list reporting (Section 311). In conjunction with adopting OSHA’s new HCS classification system, EPA made a few minor corrections to the hazardous chemical reporting regulations (such as website address updates).
The revised regulations now refer to both MSDS—Material Safety Data Sheets, as well as SDS—or “Safety Data Sheets,” the updated OSHA term for documents that provide information on the properties of hazardous chemicals and how they affect health and safety in the workplace. The more substantial revision is that the five existing hazard categories used by EPA in EPCRA reporting are being replaced with specific GHS hazard classes as well as four hazards adopted by OSHA but not listed in the GHS.
EPA noted in the background section of the final rule that closer correlation with OSHA’s HCS and GHS will provide greater clarification to the regulated community and facilitate emergency planning. Prior to OSHA adopting the GHS, chemical producers were able to use whatever language or format they chose in providing necessary information, so different companies could use different language to describe the same hazards. Now, downstream users will find consistent signal words, pictograms and hazard statements in all communications.
The compliance date for using the new classifications is January 1, 2018.
EPA has issued a draft update of the RCRA* Public Participation Manual. The manual, which replaces a 1996 edition of the document, explains how public participation works in the RCRA permitting process (including corrective action), and how community members, regulators and industry can collaborate to make it more effective.
The revisions to the document reflect current regulations, policies, and practices, presenting new information about technical assistance, environmental justice, social media, and other topics that have come to the forefront since the 1996 edition. For many years, RCRA permitting programs have primarily focused on issuing permits. More recently, however, the majority of hazardous waste management facilities are already permitted. Permit maintenance and modifications now account for most of the permitting activity today. Thus, the 2016 manual includes updated and expanded information about permit modifications and best practices for site-specific public participation.
EPA is requesting input from the public about specific enhanced approaches, as well as innovative projects that will facilitate public participation and address the perception of diminishing public interest. Comments should be sent by Friday, September 9, 2016, to [email protected].
RCRA – the Resource Conservation and Recovery Act, the law governing management of hazardous and non-hazardous waste.