regulations and trying to understand them is one thing but having hands on experience is the best way to evaluate the situtation.

I recently spent an afternoon with Jeffrey Knowlton, the fire chief of the Warren Township Fire Department going through the requirements of the Superfund Amendments and Reauthorization Act (SARA Title III) and how it effects our fire department. The fire chief showed me

the large books of Material Safety Data Sheets (MSDS) which is constantly up-dated from the various companies in our township. Each time there is additional information about one of the hazard materials that is stored in our township the companies must send an up-dated MSDS to the fire department. These sheets must be kept up todate in the files at the fire department so current information is available to the firemen if they are responding to a hazardous materials emergency.

SARA Title III requires a minimum of twenty-four hours a year training on hazardous materials by every member of the fire department This is in addition to the required training hours set by the State of Ohio. Maybe this doesn't sound all that difficult but remember we

are talking volunteer personnel who are giving of their personal time to help serve the public. Besides the training hours the fire department is also responsible for emergency calls, equipment and building upkeep and fund raising events. The majority of the fire departments in the State of Ohio are volunteers working with a very small budget. This means these people are giving up family time as well as their own leisure time to help provide fire protection to our township residents. It is getting to the point that they don't want to be told they have to give up more of their time for training.

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On August 1, 1988 Mr. Knowlton presented a letter to the Board of Warren Townships expressing his concern about the future of the fire department. Part of his letter read.." the newest and possibly

the most devasting threat to the existence of volunteers is regulations. One example is the new SARA Title III legislation. This law requires

many training hours to be completed for anyone responding to a hazardous material incident. To do this in addition to fire and EMS training Then there are the new NFPA safety standards.

is almost impossible.

Even though I agree with these standards, they can be intimidating to many volunteers and the pressure there is to comply."

He went on

to remind the board of trustees that it is their responsibility to provide fire protection to the residents of Warren Township and that they must provide the safest possible environment for the fire

personnel and the residents.

is in jeopardy.

He feels the future of the fire department

Is a paid fire department going to be necessary to

comply with all the paper work and the training requirements? That will mean an increased budget which will take a substantial increase in property taxes to meet.

Mr.

Knowlton's future plans do not include service as fire chief for our volunteer fire department after December 31, 1988. He cites too much time, too many regulations and the added responsibilites as the reasons for his decision.

We have qualified personel in our fire

department but will there be someone who will want to take on the

responsibilites that have haunted Mr. Knowlton these past years?

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Closing Statement

As you can see, just two of the federal mandates have placed a tremendous burden on Warren Township. The regulations are unrealistic for a small government to comply. As it stands now, federal agencies have ignored the Regulatory Flexibility Act as far as small governments are concerned. This leaves the officials of small governments to accept tremendous liability while attempting to choose between either complying with the regulations, which I have stated are clearly impossible, or disobeying the law. The Regulatory Flexibility Act has provided a way to help overcome that problem.

Just as Mr. Knowlton stated that he agreed with the standards set, I also agree that these regulations are for the betterment of our country. But somewhere, someone has to use 'common sense" to make these regulations apply where it is possible to comply.

Mr. Chairman and members of the Committee, I urge you to look into the compliance of the Regulatory Flexibility Act by various federal agencies. I thank you on behalf of the National Association of Towns and Townships, the Ohio Townships Association, and Warren Township, for your time to listen to my concerns about the regulations handed down to small governments from the federal government.

I would like to thank you for allowing me to participate in your senate hearing on the Regulatory Flexible Act on September 14, 1988. I appreciated the time your committee spent listening to the problems that small governments are experiencing due to federal regulations.

I am enclosing my answer to the additional question concerning the environmental clean-up and protection since the transfer of responsibilities to the local governments. I hope this will help your committee in their investigation.

Thank you again for the privilege to testify before your committee on governmental affairs.

jlb

enclosure

Yours truly,

beardmere

Joan L. Beardmore

Township Clerk

1.

SENATOR GLENN'S

QUESTIONS FOR THE RECORD

Mrs. Joan L. Beardmore

Please use your experience as clerk of Warren township to comment on whether actual environmental clean-up and protection has benefited or been harmed by the transfer of responsibilities to local governments?

Answer:

The benefits of the environmental clean-up and protection has been that the local government officials are closer to -> the situtation because they live in the area and their interest would be greater.

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The problems caused by the transfer of the responsibilities to local governments are the financial responsibilities for providing the personnel, equipment, etc. for immediate cleanup. The fire chief is concerned about needing additional equipment if a spill was to occur on one of our state routes and who would pay these people doing the work until money could be collected from the company who had the spill. The budgets of townships could not handle providing such services. We are working closely with the Washington County Diaster Services to use all the services available should such an emergency occur but the potential is there for a situtation that would be devastating to our township.