EmergencyResponsePlanning for Corporate and Municipal Managers
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tmergency Response Planning
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for Corporate and Municipal Managers
PAUL A. ERICKSON
Environmental, Health, and Safety Consulting Science Department Anna Maria College Paxton, Massachusetts
ACADEMIC PRESS San Diego
London
Boston
New York
Sydney
Tokyo
Toronto
Cover photograph: Collapse of Highland Tower, Selangor, Malaysia (1993). Courtesy of Dato’ Soh Chai Hock, Director General, Malaysian Fire and Rescue Services.
T h i s book is printed on acid-free paper.
@
Copyright 0 1999 by ACADEMIC PRESS All Rights Reserved. No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopy, recording, or any information storage and retrieval system, without permission in writing from the publisher.
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For Dato' Soh Chai Hock, Director General Fire and Rescue Services, Malaysia
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CONTENTS Preface
xiii
Scope of Emergency Response
Introduction 1 Key Factors Influencing Programmatic Emergency Response Programs 12 Extended Partnership 19 Proactive and Reactive Dimensions 23 Elements of Holistic Planning and Management
Introduction 25 Scope of Emergency Planning 26 28 Assessment of Hazard and Risk On- and Off-Site Management 37 Authority and Responsibility 41 Communication and Information HandlingProcessing Provisions and Support 46 Medical Treatment and Surveillance 48 51 Remediation and Review
44
The Emergency Response Plan
Introduction 53 Contents of Emergency Response Plan Implementation 76
58
Command
Introduction 82 Incident Command System 82 Adaptation of ICS to Other Command Structures Additional Considerations 100
97
vii
viii
5
Contents
Physical and Chemical Hazards
Introduction 103 Structural, Material, and Operational Sources of Hazards 110 Hazard Evaluation and Mitigation 119 Consolidation of Information and Database
6
104
Biohazards
Introduction 122 Bloodborne Pathogens 126 Universal Precautions 132 Exposure Control Plan 137 Nonbloodborne Pathogens 139
7
Medical Surveillance
Introduction 145 Surveillance Objectives and Concerns 145 Liaison with Medical Authority 154 Types of Medical Analysis 158 Programmatic Review 171 8
Personal Protective Clothing and Equipment
Introduction 172 Selection of PPC and PPE 173 Protective Clothing and Ensembles Respiratory Protection 195 Hearing Protectors 206
9
175
Personnel Training
Introduction 208 Proactive Management of Hazards: Corporate Perspective Incident Response Personnel 220
10
Hazard and Risk Reduction Strategies
Introduction 239 Mitigation Measures 243 All-Hazard Mitigation 254 Shift in Paradigm 2.58
II
Decontamination
Introduction
26.5
209
IX
Contents
Scope of Decontamination Plan 266 Emergency Decontamination 286
I2
Data and Information Management Introduction 293 Expert Software 295 Elements of In-Service Data and Information Base 306 Modular Approach to Database Design
13
297
Monitoring Strategies and Devices Introduction 313 Chemical Monitoring Technologies 3 14 Other Monitoring Technologies 322 Design and Implementation of Monitoring Program Proactive Industrial Monitoring 326
14
323
Terrorism Introduction 331 Potential Terrorist Weapons 332 Incident Site as Crime Scene 345 Threat and Risk Target Assessment Emergency Operations Plan 348
347
351
A
Glossary
B
FEMA Addresses
C
Regional and Area OSHA Ofices
D
States with Approved Occupational Safety and Health Plans 400
E
OSHA Consultation Directory
F
State Emergency Response Committees
G
FEMA Emergency Management Guide for Business and Industry
388 393
403 409
Introduction 423 426 Section l-Four Steps in the Planning Process Section 2-Emergency Management Considerations
440
Contents
X
Section 3-Hazard-Specific Information Section 4-Information Sources 467
H
OSHA Training Curriculum Guidelines I 9 10. I20 (Hazardous Waste Operations & Emergency Response) APP E (Nonmandatory)
Suggested General Criteria 470 Suggested Program Quality Control Criteria Suggested Training Curriculum Guidelines
I
457
472 476
Terrorism Incident Annex to the Federal Response Plan
Introduction 488 Policies 489 Situation 490 Concept of Operations 491 Responsibilities 496 Funding Guidelines 500 References (Not Otherwise Referenced in the FRP) 501 Primary Point of Contact
J
Presidential Decision Directive 39 (Unclassified)
United States Policy on Counterterrorism
K
503
National Fire Academy and Emergency Management Institute Courses Relatedto ConsequenceManagement
National Fire Academy (NFA) Courses 507 Emergency Management Institute (EMI)Courses For More Information 514
L
500
513
Emergency Procedures for Employees with Disabilities in Ofice Occupancies (U.S. Fire Administration: June 1995)
Review Panel 5 15 Introduction 516 Planning 519 522 Special EquipmentDevices Providing Assistance 527 Glossary 534 Resources 538
xi
Contents
M
How to Prepare for Workplace Emergencies (U.S. Department of Labor, Occupational Safety and Health Administration, 1995, Revised) Introduction 541 Purpose 541 Planning 542 Chain of Command 543 Communications 543 Accounting for Personnel 544 Emergency Response Teams 544 Training 545 Personal Protection 546 549 Medical Assistance Security 550 Some OSHA Requirements 550 Information and Consultation Services 552 Free On-Site Consultation 552 Voluntary Protection Program 553 553 Training and Education Other Sources of OSHA Assistance 554 554 State Occupational Safety and Health Plans
Index
557
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PREFACE Effective emergency response planning, whether for incidents that derive from natural causes or for those that derive from human actions, demands both persistent and consistent liaison and coordination among a large diversity of governmental agencies, response organizations, and community support resources. While it remains true that professional fire services continue to bear the day-to-day responsibility of responding to local disasters, it is also true that several factors in modern society converge toward a broader expansion of this responsibility into both public and private domains. These factors include: (a) the complexity of modern industries and technologies that are dependent on the continual development of new material sources of physical, chemical, and biological hazards and risks; (b) the on-going merging of dense population areas with diverse technology and production centers; and (c) the increasing availability of hazardous technologies and agents to those sociopaths who, whether as individuals or groups, are best described as terrorists. The increasingly global recognition that any incident--whether a hurricane or a bombing, an accidental release of a toxic industrial gas or a purposeful contamination of items essential for daily commerce--can be easily magnified in its toll of human life by the very way we conduct our lives and structure our societies has profound implications for the emergency planning process. This book addresses some of the more important of these implications, especially with regard to industrial and municipal planning and response. This book is not intended for practicing professional emergency response personnel but, rather, for corporate and municipal managers who must quickly come to understand their essential roles in both proactive and reactive emergency management in the midst of an as yet evolving partnership among Federal, state, and local governmental agencies as well as among public and private community sectors. This book is also intended for use in graduate and undergraduate classes and programs devoted to such issues as emergency planning and response, hazard and risk management, occupational safety and health, industrial loss control, environmental safety and health, and corporate risk management. Finally, this book should provide oo,,, Xlll
xiv
Preface
industrial health and safety consultants with essential guidance in designing and implementing effective contingency and/or emergency response plans for industrial clients. For both the design and the development of this book, I am indebted to many individuals~in particular, Dr. Robert Zukowski, for his persistent and thoughtful encouragement and advice; Dato' Soh Chai Hock, for sharing his professional insight and affording me his always enthusiastic support; and Augustine Koh, who by both his patient counsel and personal example continues to sustain (what I trust is) my best professional effort. In developing this book I have appropriated relevant materials I included in my previous book on occupational health and safety (Practical Guide to Occupational Health and Safety, Academic Press, 1996), and I have certainly drawn heavily upon my 25 years of experience as a full-time industrial consultant. However, I also give special recognition to vital sources of both printed and electronic publications that I have absolutely depended on throughout my writing, including U.S. Environmental Protection Agency, Centers for Disease Control, U.S. Public Health Services, Federal Emergency Management Agency, National Response Team, National Institute of Occupational Safety and Health, and Occupational Safety and Health Administration. Each of these agencies maintains excellent web pages and well-designed tools for accessing detailed databases and professional documents that are essential reading for any manager with responsibility for emergency response planning and management. I also single out for special recognition the U.S. Fire Administration, which not only maintains a superb reference library for professionals but also provides rapid, dependable, and extremely user-friendly means for accessing that library.
SCOPE OF EMERGENCY RESPONSE
INTRODUCTION
Emergency response is an integral component of routine corporate management that, while directly influenced by diverse regulations at all levels of government, is also influenced by nonregulatory considerations, including (a) obligations imposed by corporate insurance policies, (b) corporate and stakeholder concerns over tort liability, and (c) the demands of both ad hoc and formal in-plant safety committees. At the municipal level, emergency response planning and management have become increasingly complex tasks that, despite a long and distinguished historical development, are continually compounded by social, technical, and political developments, including (a) jurisdictional confusion among federal, regional, state, county, and municipal authorities, (b) the economic burden of maintaining adequately staffed, trained, and provisioned emergency response teams, (c) the sheer structural and operational complexity of modern municipalities, (d) the proliferation of sources and agents of potent public hazard, and, most recently, (e) widespread anxiety regarding the terrorist acts of politically motivated groups, as well as otherwise motivated individuals. In the United States, the primary Federal influence on corporate emergency response planning is through legislation governing the workplace generation of hazardous waste (Resource Conservation and Recovery Act; RCRA) and activities associated with uncontrolled hazardous waste sites [Comprehensive Emergency Response, Compensation and Liability Act (CERCLA, also known as Superfund) and the Superfund Amendments and Reauthorization Act (SARA)I, although other legislation and regulations also establish emergency response requirements, including the Clean Water Act (CWA), the Hazardous Material Transportation Act (HMTA), and the Chemical Process Safety Regulations (29 CFR 1910.119). I
I Scope of Emergency Response TABLE I. I
Key OSHA StandardsRelatedto EmergencyResponse(CFR: U.S.Code of Federal
Regulations)
Reference 29 29 29 29 29 29 29 29 29 29 29 29 29 29 29 29 29 29 29 29 29
CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR CFR
1910 1910.119 1910.119 App C 1910.119 App D 1910.120 1910.120 App A 1910.120 App C 1910.120 App D 1910.120 App E 1910.1027 App B 1910.1051 1910.1052 1926 1926.64 1926.64 App C 1926.64 App D 1926.65 1926.65 App A 1926.65 App C 1926.65 App D 1926.65 App E
Topic Table of contents Process safety management of highly hazardous chemicals Compliance guidelines and recommendations Sources of further information; non-mandatory Hazardous waste operations and emergency response Personal protective equipment test methods Compliance guidelines References Training curriculum guidelines; non-mandatory Substances technical guidelines for cadmium 1,3-Butadiene Methylene chloride Table of contents Process safety management of highly hazardous chemicals Compliance guidelines and recommendations Sources of further information; non-mandatory Hazardous waste operations and emergency response Personal protective equipment test methods Compliance guidelines References Training curriculum guidelines; non-mandatory
With respect to the health and safety of American workers involved in emergency response (Tables 1.1, 1.2, 1.3), key baseline regulations include 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response) and 29 CFR 1910.38 (Employee Emergency Plans), which contain appropriate cross-references to additional regulatory requirements (e.g., respiratory protection, alarm systems, eye and foot protection). Under 29 CFR 1910.120, a written emergency response plan must describe how an actual emergency will be handled to minimize risks to three groups of personnel: 1. employees engaged in cleanups at uncontrolled hazardous waste sites, 2. employees engaged in routine operations and corrective actions at RCRA facilities, and 3. employees engaged in emergency response without regard to location. If an employer does not allow employees to respond to an emergency in any manner except by evacuating premises, that employer must develop a
Introduction TABLE 1.2 Key OSHA StandardsRelated to Protection of Personnel (CFR: U.S.Code of Federal Regulations)
Reference
Topic
1910 Subpart ! App B Non-mandatory compliance guidelines Hazardous waste operations and emergency response 1910.120 Personal protective equipment test methods 1910.120 App A General description and discussion 1910.120 App B Compliance guidelines 1910.120 App C Training curriculum guidelines; non-mandatory 1910.120 App E General requirements 1910.132 Helicopters 29 CFR 1910.183 Pulp, paper, and paperboard mills 29 CFR 1910.261 Logging operations 29 CFR 1910.266 Telecommunications 29 CFR 1910.268 Electric power generation, transmission, and distribution 29 CFR 1910.269 Safeguards for personnel protection 29 CFR 1910.335 Medical surveillance guidelines for asbestos 29 CFR 1910.1001 App H Cadmium 29 CFR 1910.1027 Bloodborne pathogens 29 CFR 1910.1030 Ethylene oxide 29 CFR 1910.1047 Formaldehyde 29 CFR 1910.1048 Methytenedianiline 29 CFR 1910.1050 Methylene chloride 29 CFR 1910.1052 Table of contents/authority for 1915 29 CFR 1915 29 CFR 1915 Subpart I App A Non-mandatory guidelines Precautions and the order of testing 29 CFR 1915.12 Medical surveillance guidelines for asbestos 29 CFR 1915.1001 App I Table of contents 29 CFR 1926 Personal protective equipment 29 CFR 1926.28 Methylenedianiline 29 CFR 1926.60 Hazardous waste operations and emergency response 29 CFR 1926.65 Personal protective equipment test methods 29 CFR 1926.65 App A General description and discussion 29 CFR 1926.65 App B Compliance guidelines 29 CFR 1926.65 App C Training curriculum guidelines; non-mandatory 29 CFR 1926.65 App E Criteria for personal protective equipment 29 CFR 1926.95 General requirements 29 CFR 1926.300 Power-operated hand tools 29 CFR 1926.302 29 CFR 1926.551 Helicopters 29 CFR 1926.1101 Asbestos Medical surveillance guidelines for asbestos 29 CFR 1926.1101 App I 29 CFR 1926.1127 Cadmium 29 CFR 29 CFR 29 CFR 29 CFR 29 CFR 29 CFR 29 CFR
I Scope of Emergency Response TABLE 1.3 Key OSHA StandardsRelatedto MedicalSurveillanceof Personnel (CFR: U.S. Code of Federal Regulations)
Reference
Topic
,
29 CFR 1910.120 29 CFR 1910.120 App E 29 CFR 1910.1001 29 CFR 1910.1001 App H 29 CFR 1915.1001 App I 29 CFR 1910.1003 29 CFR 1910.1018 App C 29 CFR 1910.1025 29 CFR 1910.1025 App B 29 CFR 1910.1025 App C 29 CFR 1910.1027 29 CFR 1910.1027 App A 29 CFR 1910.1028 App C 29 CFR 1910.1043 29 CFR 1910.1044 29 CFR 1910.1044 App C 29 CFR 1910.1045 29 CFR 1910.1045 App C 29 CFR 1910.1047 App C 29 CFR 1910.1048 29 CFR 1910.1048 App A 29 CFR 1910.1048 App C 29 CFR 1910.1050 29 CFR 1910.1050 App C 29 CFR 1910.1052 29 CFR 1910.1052 App B 29 CFR 1926.60 29 CFR 1926.60 App C 29 CFR 1926.62 29 CFR 1926.62 App B 29 CFR 1926.62 App C 29 CFR 1926.65 29 CFR 1926.65 App C 29 CFR 1926.65 App E 29 CFR 1926.1101 29 CFR 1926.1101 App I '29 CFR 1926.1127 29 CFR 1990.151 2 9 CFR 1990.152
Hazardous waste operations and emergency response Training curriculum guidelines; non-mandatory Asbestos Medical surveillance guidelines for asbestos Medical surveillance guidelines for asbestos 13 Carcinogens (4-nitrobiphenyl, etc.) Medical surveillance guidelines Lead Employee standard summary Medical surveillance guidelines Cadmium Substance safety data sheet for cadmium Medical surveillance guidelines for benzene Cotton dust 1,2-dibromo-3-chloropropane (DBCP) Medical surveillance guidelines for DBCP Acrylonitrile Medical surveillance guidelines for acrylonitrile Medical surveillance guidelines for ethylene oxide Formaldehyde Substance technical guidelines for formaldehyde Medical surveillance for formaldehyde Methylenedianiline (MDA) Medical surveillance guidelines for MDA Methylene Chloride Medical surveillance for methylene chloride Methylenedianiline (MDA) Medical surveillance guidelines for MDA Lead Employee standard summary Medical surveillance guidelines Hazardous waste operations and emergency response Compliance guidelines Training curriculum guidelines; non-mandatory Asbestos Medical surveillance guidelines for asbestos Cadmium Model standard Model emergency temporary standard ....
Introduction
5
written emergency action plan, which (in compliance with 29 CFR 1910.39) includes the following minimum elements: 9 emergency escape procedures and routes 9 procedures to be followed by employees who remain to operate critical plant operations before they evacuate 9 procedures to account for all employees after emergency evacuation has been completed 9 rescue and medical duties for those employees who are to perform them 9 the preferred means of reporting fires and other emergencies 9 names or job titles of personas or departments who can be contacted for further information or explanation of duties associated with emergency response Depending on relevant regulatory requirements, the overall in-plant responsibility for emergency response planning and implementation may be assigned to the "primary emergency response coordinator" (i.e., under RCRA regulations), the "site safety and health supervisor" (i.e., under 29 CFR 1910.120), or to any number of variously titled personnel having specialized knowledge and experience (Tables 1.4, 1.5, 1.6, 1.7). In many facilities, the facility manager or operations manager assumes all responsibility for emergency response activities. The key regulatory objective in assigning overall responsibility is to ensure that corporate authority is in fact commensurate with that responsibilityma requirement that is increasingly reflected in the consolidation of emergency response management duties within a corporate executive level function. At the broad level of the American Community and reflecting the consistent and widespread concern of the American public regarding chemical hazards, The Federal Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA; SARA Title III) requires municipal authorities to: 1. prepare for emergency releases of hazardous substances by appointing a Local Emergency Planning Committee (LEPC), 2. immediately notify the LEPC of any release of hazardous substances in quantities greater than prescribed levels, 3. prepare an inventory of hazardous substances to be submitted to the LEPC, and 4. prepare an annual report detailing the amounts of hazardous substances released to the environment or transported as waste. Under EPCRA, the LEPC must include, at the minimum, elected state and local officials, police, fire, civil defense, public health professionals, environmental, hospital, and transportation officials as well as representatives of facilities subject to emergency planning requirements, community groups,
6
I Scope o f E m e r g e n c y Response TABLE
1.4
Essential O n - S i t e E m e r g e n c y Response Personnel ( A d a p t e d f r o m N I O S H ,
U S C G , and EPA, 1985: O c c u p a t i o n a l Safety and H e a l t h G u i d a n c e Manual f o r H a z a r d o u s W a s t e Site A c t i v i t i e s )
Title
General Description
Project Team Leader
Reports to upper-level management; has authority to direct response operations; assumes total control over site activities.
Specific Responsibilities 9
9 9 9 9 9 9
Site Safety and Health Officer
Advises the Project Team Leader on all aspects of health and safety on site; recommends stopping work if any operation threatens worker or public health or safety.
9 9 9 9 9 9 9 9 9 9 9 9
9
Field Team Leader
May be the same person as the Project Team Leader and may be a member of the work party; responsible for field team operations and safety.
9 9 . 9
Prepares and organizes the background review of the situation, the Work Plan, the Site Safety Plan, and the field team. Obtains permission for site access and coordinates activities with appropriate officials. Ensures that the Work Plan is completed and on schedule. Briefs the field teams on their specific assignments. Uses the Site Safety and Health Officer to ensure that safety and health requirements are met. Prepares the final report and support files on the response activities. Serves as the liaison with public officials. Selects protective clothing and equipment. Periodically inspects protective clothing and equipment. Ensures that protective clothing and equipment are properly stored and maintained. Controls entry and exit at the Access Control Points. Coordinates safety and health program activities with the Scientific Advisor. Confirms each team member's suitability for work based on a physician's recommendation. Monitors the work parties for signs of stress, such as cold exposure, heat stress, and fatigue. Monitors on-site hazards and conditions. Participates in the preparation of and implements the Site Safety Plan. Conducts periodic inspections to determine if the Site Safety Plan is being followed. Enforces the "buddy" system. Knows emergency procedures, evacuation routes, and the telephone numbers of the ambulance, local hospital, poison control center, fire department, and police department. Notifies, when necessary, local public emergency officials. Coordinates emergency medical care. Manages field operations. Executes the Work Plan and schedule. Enforces safety procedures. Coordinates with the Site Safety Officer in determining protection level. Enforces site control. Documents field activities and sample collection. Serves as a liaison with public officials.
continues
and the media. A primary responsibility of the LEPC is to develop an emergency response plan that: 1. identifies facilities and transportation routes involved in the storage, use, or transport of specified hazardous substances,
Introduction TABLE
1.4~continued
Title Command Post Supervisor
Specific Responsibilities
General Description May be the same person as the Field Team Leader;, responsible for communications and emergency assistance.
9
Notifies emergency response personnel by telephone or radio in the event of an emergency. Assists the Site Safety officer in a rescue, if necessary. 9 Maintains a log of communication and site activities. 9 Assists other field team members in the clean areas, as needed. 9 Maintains line-of-sight and communication contact with the work parties via walkie-talkies, signal horns, or other means. 9
Decontamination Station Officer(s)
Responsible for decontamination procedures, equipment, and supplies.
Sets up decontamination lines and the decontamination solutions appropriate for the type of chemical contamination on site. 9 Controls the decontamination of all equipment, personnel, and samples from the contaminated areas. 9 Assists in the disposal of contaminated clothing and materials. 9 Ensures that all required equipment is available. 9 Advises medical personnel of potential exposures and consequences.
Rescue Team
Used primarily on large sites with multiple work parties in the contaminated area.
9
Depending on the size of the field team, any or all of the field team may be in the Work Party, but the Work Party should consist of at least two people.
9
Work Party
9
9
9 9
Stands by, partially dressed in protective gear, near hazardous work areas. Rescues any worker whose health or safety is endangered. Safely completes the onsite tasks required to fulfill the Work Plan. Complies with Site Safety Plan. Notifies Site Safety Officer or supervisor of unsafe conditions.
2. describes comprehensive emergency response procedures to be implemented both on- and off-site of any emergency incident, 3. designates a community coordinator and facility coordinator to implement the plan, 4. outlines emergency notification procedures, 5. describes methods for determining the occurrence of a release and the probable affected area and population, 6. describes community- and industry-owned emergency equipment and facilities and identifies persons responsible for these resources, 7. outlines evacuation plans, 8. describes a training program for emergency response personnel, and 9. presents methods and schedules for exercising emergency response plans. The promulgation of Federal requirements under EPCRA, which effectively extends a National concern and responsibility down to local
I Scope of Emergency Response
8
TABLE I.$ Optional On-Site Emergency Response Personnel (Adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities) Title
Specific Responsibilities
Scientific Advisor
9 Provides advice for field monitoring, sample collection, sample analysis, scientific studies, data interpretation, and remedial plans.
Logistics Officer
9
Plans and mobilizes the facilities, materials, and personnel required for the response.
9 9
Photographs site conditions. Archives photographs.
Financial/Contracting Officer
9
Provides financial and contractual support.
Public Information Officer
9
Releases information to the news media and the public concerning site activities.
Security Officer
=
Manages site security.
Recordkeeper
9
Maintains the official records of site activities.
Photographer
communities and, at that level, promotes an integration of regional and local governmental as well as private resources toward the objective of emergency planning and response, clearly reflects an on-going change in paradigm regarding historical distinctions between Federal and local interests and also between "natural" disasters and "human-made" emergencies (Fig. 1.1). Whereas the Federal Emergency Management Agency (FEMA) is most commonly known for its responsibility as the lead Federal agency within a consortium (National Emergency Management System) of 27 Federal agencies (and the American Red Cross) devoted to providing aid and assistance after major natural disasters (e.g., floods, storms, earthquakes), FEMA is today probably best understood as a key partner in the National Mitigation Strategy--a Federal programmatic initiative devoted to the development of additional partnerships among Federal, state, and local governments and private sector constituents, including the general public, for the express purpose of promoting local community safety. While the focus is still directed at so-called natural hazards, FEMA is also the lead agency of the National Arson Prevention Initiative (NAPI), a partnership that also includes the U.S. Department of Housing and Urban Development, the U.S. Department of Justice, and the U.S. Department
Introduction
9
TABLE 1.6
Off-Site Emergency Response Personnel (Adapted from NIOSH, USCG, and EPA, 1985:
Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities)
Title Senior Level Management
Multi-Disciplinary Advisors
Medical Support
Specific Responsibilities
General Description Responsible for defining project objectives, allocating resources, determining the chain-of-command, and evaluating program outcome.
Provide the necessary facilities, equipment, and money. 9 Provide adequate personnel and time resources to conduct activities safely. 9 Support the efforts of on-site management. 9 Provide appropriate disciplinary action when unsafe acts or practices occur.
Includes representatives from upper-level management and onsite management, a field team member, and experts in such fields as: 9 Chemistry 9 Engineering 9 Industrial hygiene 9 Information/public relations 9 Law 9 Medicine 9 Pharmacology 9 Physiology 9 Radiation health physics 9 Toxicology
9
Provide advice on the design of the Work Plan and the Site Safety Plan.
Consulting physicians
9
Become familiar with the types of materials on site, the potential for worker exposures, and recommend the medical program for the site.
Medical personnel at local hospitals and clinics
9
Provide emergency treatment and decontamination procedures for the specific type of exposures that may occur at the site; obtain special drugs, equipment, or supplies necessary to treat such exposures.
9
Provide emergency treatment procedures appropriate to the hazards on site.
9
Ambulance personnel
of the Treasury. The objectives of NAPI are to increase public awareness regarding practical means for preventing arson and to provide appropriate resources to individuals and communities throughout the nation. While there can be no doubt that emergency-related "partnerships" between diverse governmental agencies are sometimes the result of the need for coordinated intelligence gathering--as, for example, in a case of international terrorism, which may require the coordination of efforts of personnel from the Federal Bureau of Investigation (FBI), National Security Agency (NSA), Central Intelligence Agency (CIA), and various other U.S. Departments (e.g., Defense, Treasury, Transportation)--other factors also promote intergovernmental coordination as well as governmental and private sector partnerships. For example, "Civil Emergency Planning" (CEP), though long
10
I Scope of Emergency Response
TABLE
1.7
Additional Personnel That May Be Needed f o r Hazardous Waste Operations
(Adapted f r o m N I O S H , USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual f o r Hazardous Waste Site Activities)
Title
General Description
Bomb Squad Explosion Experts Communication Personnel
Environmental Scientists
Evacuation Personnel
Specific
Responsibilities 9 Advise on methods of handling explosive materials 9 Assist in safely detonating or disposing of explosive materials
Civil Defense organizations; local radio and television stations; local emergency service networks
9
Consultants from industry, government, universities, or other groups
9
Federal, state, and local public safety organizations
9 9 9
Help plan for public evacuation Mobilize transit equipment Assist in public evacuation
9 9 9
Respond to fires that occur on site Stand by for response to potential fires Perform rescue
Firefighters
9
Provide communication to the public in the event of an emergency Provide communication links for mutual aid
Predict the movement of released hazardous materials through the atmosphere, soil, and water resou rces 9 Assess the effect of this movement on air, groundwater and surface water quality 9 Predict the exposure of people and the ecosystem to the materials
Hazardous Chemical Experts
Consultants from industry, government, universities, or other groups
9 Advise on the properties of the materials on site 9 Advise on contaminant control methods 9 Advise on the dangers of chemical mixtures that may result from site activities 9 Provide immediate advice to those at the scene of a chemical-related emergency
Health Physicists
Experts in radiation health from industry, government, universities, or other groups
9
Industrial Hygienists
Consultants from industry, government, universities, or other groups
9 Conduct health hazard assessments 9 Advise on adequate health protection 9 Conduct monitoring tests to determine exposures to hazardous substances
Consultants from government or other local organizations
.
Meteorologists
Evaluate radiation health hazards and recommend appropriate action
worker
Provide meteorological information
Public Safety Personnel
County Sheriff, industrial security forces, National Guard, police, etc.
9
Toxicologists
Consultants from industry, government, universities, or other groups
9
Control access to the site
Advise on toxicological properties and health effects of substances on site 9 Provide recommendations on protection of worker health
II
Introduction
I
Nature
Accident Terrorism
F I G U R E I. I Basic dimensions and components of emergencies. Note that natural and humancaused emergencies can exacerbate one another.
an integral (albeit little noticed) part of the capability of the North Atlantic Treaty Organization (NATO), has emerged as an increasingly important resource for NATO partners in their effort to prevent human-made disasters, mitigate the consequences of natural calamities, and protect the population, national wealth, and environment. The rapidly expansive trend in the United States to conceptualize emergency response in terms of the requirements for practical prevention,
J2
I Scope of Emergency Response
efficient response, and effective mitigation, rather than in terms of type or source of threat (e.g., natural vs human-made hazards) or jurisdictional mandate (e.g., national, regional, local) is clearly paralleled in European, Pacific rim, and other nations as well as international organizations.
KEY FACTORS I N F L U E N C I N G P R O G R A M M A T I C EMERGENCY RESPONSE PROGRAMS
Essentially synonymous with "crisis management, .... disaster planning and management, .... civil emergency response," and "contingency planning," emergency response (which is inclusive of planning, management, and response functions) is subject to a wide range of social, economic, and technical factors. In most recent years, perhaps the more significant of these factors include: (a) public concern over hazardous chemicals, (b) international and domestic terrorism, (c) on-going development of a global economy, and (d) rapid developments in electronic communications.
Hazardous Chemicals
Of approximately 16 million known chemical substances (including naturally occurring and human-made chemicals), about 60,000 are in daily commercial use in any technologically developed country. Until the mid 1970s, primary concern was focused on only a small number of these chemicals--specifically, on petrochemicals--even though the Federal Water Pollution Control Act (1974) did establish clear federal concern regarding the discharge of environmentally hazardous substances into the nation's waterways. In 1975, Congress enacted the Federal Hazardous Materials Transportation Act (HMTA), which was the first comprehensive attempt to regulate the transport of hazardous chemicals, following in 1976 with the Resource Conservation and Recovery Act (RCRA), which established a strong federal initiative to exert "cradle-to-grave" management of hazardous wastes. Within 2 years of the enactment of RCRA, the public became fully aware of the potential risks of hazardous wastes through the incident at Love Canal (Niagara Falls, New York), where residents finally had to be evacuated from houses built over an abandoned dumping ground used from 1947 to 1953 to bury industrial chemical wastes. In response to this incident, Congress enacted the Comprehensive Emergency Response, Compensation and Liability Act of 1980 (CERCLA; "Superfund"). Unlike RCRA, which focuses on waste management by existent facilities, CERCLA deals with chemically contaminated sites that are abandoned.
Key Factors Influencing Programmatic Emergency Response Programs
13
While the governmental and public consciousness of the potential risks of chemicals, whether those chemicals were of commercial value and legally defined as "materials" or had no commercial value and were defined as "wastes," expanded greatly between 1975 and 1980, that consciousness was confined primarily to the cleanup of hazardous waste sites and to determining the long-term effects of exposure to hazardous wastes. That changed on December 3, 1984, when a cloud of methyl isocyanate from a Union Carbide
manufacturing plant in Bhopal, India, killed more than 2,500 and injured an estimated 200,000 people. When the Bhopal tragedy was followed by an accidental chemical release on August 11, 1985, at another Union Carbide plant at Institute, West Virginia, public concern turned to alarm. Althoughthe West Virginia release was not serious, it underscored for many Americans the lack of information about hazardous substances in their communities and about the health hazards associated with exposure. It also focused attention on the inadequacies of emergencyresponse capabilities. --(Firefighter Safety StudyAct WorkingGroup, 1992) In 1986, as a direct result of the Bhopal incident, Congress passed the Emergency Planning and Community Right-To-Know Act (Sara Title III; EPCRA) which, for the first time, raised emergency response to chemical release to national as well as local preeminence. It should also be noted, moreover, that the Occupational Safety and Health Administration (established in 1972) was at the same time beginning to raise the consciousness of industry regarding the vital importance of integrating in-plant emergency response programs with concerns about chemical health and safety through specific regulations, especially regulations related to Hazardous Waste Operations and Emergency Operations (29 CFR 1910.120) and Employee Emergency Plans (29 CFR 1910.38)Ba trend that is manifest in OSHA regulations throughout the past 20 years, including OSHA's Laboratory Standard (29 CFR 1910.1450), Respiratory Protection regulations (29 CFR 1910.134), and Chemical Process Safety regulations (29 CFR 1910.119).
Terrorism
Historically, the word terrorism was typically restricted to acts of violence committed by politically motivated groups or foreign national agents, as in the destruction of the U.S. Marine barracks in Beirut (1983) or the bombing of Pan Am Flight 103 over Lockerbie, Scotland (1988). Until 1993, most Americans perceived terrorism as something to worry about only when traveling in other countries. However, with the February 1993 bombing of the World Trade Center in New York City, it was clear that terrorism had arrived in America. With the 1995 bombing of the Federal building in Oklahoma City, it became equally evident that not only could terrorism
14
I Scope of Emergency Response
occur in America, but that it could be carried out by Americans on each otherma fact underscored in 1996 by the apprehension of the "Unabomber" who, over a period of 17 years, had carried out his own brand of domestic terrorism. Today, terrorism is recognized more by its immediate consequences than by any specific intent of its perpetrators. After all, the motivation of the perpetrator of any terrorist act is absolutely irrelevant to the dead or to their survivors. Whether committed with political intent, out of personal rage, revenge, psychopathic pleasure, or any other dimension of depravity, terrorism is premeditated, covert violence against an unknowing, unprepared, and unnumbered public. While "home-grown extremists" have been categorized in terms made all too familiar by the mass media (e.g., white supremacist skinheads, neonazis, tax protesters, crazed constitutionalists, Ku Klux Klanners, militias, environmental anarchists), it must be understood that such categories by no means exhaust the possibilities. The simple fact is that the physical wherewithal for achieving widespread public harm and injury is increasingly available to more and more people. If, historically, it has been the bomb in the hands of a political extremist that served as the primordial image of the terrorist, that image is already supplanted by that of a canister of nerve gas in the hands of a religious zealot~which, in turn, will probably be soon supplanted by that of a piece of software in the hands of a disgruntled but highly knowledgeable employee.
Global Economy Traditionally, and despite the variability inherent in the political pluralism of individual societies, health and safety standards have been essentially the province of the nation. However, with the advent of a global economy and its consequent emphasis on an integrated paradigm of environmental quality and human health, national standards can be expected to become increasingly influenced by the realities of international business. Perhaps of particular relevance is the growing body of international manufacturing standards that encompass concern not only for quality assurance of products and services, but also for the impact of industrial processes and products on environmental quality and human health. The broad goal of the International Standards Organization (ISO)is to promote the development of standardization and related activities in the world with a view to facilitating international exchange of goods and services, and to develop cooperation in the sphere of intellectual, scientific, technological, and economic activity.
Key Factors InfluencingProgrammaticEmergencyResponsePrograms
15
In essence, the clear intent of ISO is to provision a company's entry into international trade on the basis of a facility audit, external confirmation of broad compliance with environmental quality and human health standards, and the public disclosure of managerial failings. Typically known within the internal community as the harmonizing of international environmental quality criteria, this objective can be expected to provide a major impetus to the examination and reevaluation of traditional paradigms that underlie conventional business, legal institutions, and contemporary national approaches to the management of health, safety, and the environment. Already there is significant international movement to (a) consider health, safety, and environment (HSE) as a holistic and integral component of Total Quality Management, (b) reexamine the constraints imposed upon the English common law (and its diverse, global legal progeny) by the now historically dated agricultural and early industrial preoccupation with questions of property, possession, and fault, (c) recast the goal of short-term profit to one of long-term sustainability, and (d) accomplish the wholesale expansion of the public's right of access to all information that impacts human health. It cannot be expected that, in light of such considerations, either the substance or the philosophy of the health and safety standards of any individual nation will long remain unaffected. Electronic Communication
The constantly expanding availability and affordability of sophisticated electronic communication and analytical devices present new opportunities as well as challenges to emergency management. At the level of in-plant prevention, computerized unit-process control and alarm systems are effective means for keeping dangerous production processes within safe operational limits and for providing both in-plant and community-wide emergency services with early warning of potential danger. During an actual emergency incident, these devices can play a key role in all phases of incident response, facilitating effective evacuation, on-site management of response personnel as well as off-cite backup services, and essential data retrieval and processing, including the use of expert computer programs for forecasting the air/ground/water transport of released chemicals and for the deployment of search and rescue personnel. While the potential value of sophisticated electronic devices for both emergency planning and response cannot be overemphasized, all of it is to no avail if industry does not employ it or train plant personnel in its effective use, or if community emergency services are not provided the appropriate hardware and software or sufficient funds for personnel training and equipment maintenance and upgrade.
16
I Scope of Emergency Response
While there are notable exceptions, it is fair to say that the members of a local fire department, for example, have greater access to the most advanced electronic data processing devices and techniques at home than they do within their department. It is also obvious that the greatest know-how and capability are in industry which, while being the very source of the vast majority of community-wide emergency incidents, continues to focus that know-how and capability on plant productivity, with too little attention given the role of electronic information processing to on-site emergency prevention and containment. A corollary to the value of modern electronic information processing to emergency planning and response is, of course, the misuse of that capability, whether by accident (as when a computerized process control and alarm system is mistakenly deactivated in the process of routine electrical work by a contractor) or on purpose. In 1992, the U.S. OSHA implemented its final rule that is most often referred to as the Chemical Process Safety Regulation, which is a much abridged name for the more formal appellation, "Process Safety Management of Highly Hazardous Chemicals, Explosives and Blasting Agents." The final rule actually consists of two major sets of regulations: one dealing with the management of explosive and blasting agents (29 CFR 1910.109), the other with the management of highly hazardous chemicals (29 CFR 1910.119). Section (1) of 29 CFR 1910.119 defines the objective of Management of Change (MOC). Those companies that handle any of more than 135 listed chemicals at or above so-called threshold quantities (pounds of chemical) must comply with the provisions of 29 CFR 1910.119. However, even a company that does not fall within the regulatory purview of the process safety regulations is well advised to consider the development of a management of change program~especially if it employs electronic or computerized means for controlling or alarming dangerous production processes. The basic objective of any management of change program is to ensure that good engineering principles and practices are always used when designing, constructing, operating, and maintaining facilities. This objective requires the recognition that even relatively small and seemingly innocuous changes associated with facility design, construction, operations, and maintenance may actually result in unacceptable health and safety hazards. The various techniques employed in a management of change program are basically those used in any hazard assessment and are crucial to ensuring the proper use and maintenance of electronically controlled and alarmed production processes. The practical implementation of a MOC program requires clear criteria for distinguishing between those changes in plant operations, design, and features that have no reasonable likelihood of resulting in a threat to health and safety and those that do.
Key Factors InfluencingProgrammaticEmergencyResponsePrograms
17
Under 29 CFR 1910.119, specific exemption from MOC requirements is granted any change that is a replacement in kind, which is any replacement of a part (i.e., equipment, machinery, or material) or procedures that satisfies ongoing design specifications that pertain to the performance or role of that part or procedure in plant processes involving regulated chemicals. Within the limited context of this regulatory authority, MOC procedures must address the following issues with regard to any change that is not a replacement in kind: 9 the technical basis for the proposed change 9 the impact of the change on safety and health 9 modification of operating procedures appropriate to the change and its related risks 9 the time period required for preparing and implementing the change 9 authorization requirements attendant to the change The usual means for addressing these issues is the integration of MOC procedures with existing in-plant approval and authorization procedures, especially standard internal work request and work order procedures. This approach is eminently practical whether a company falls within the jurisdictional purview of 29 CFR 1910.119 or, if not subject to these regulations, simply chooses to implement an MOC policy as one component of a comprehensive health and safety program, an option that is increasingly exercised by companies in the United States and elsewhere. In fact, MOC is widely recognized as a state-of-the-art business management practice regardless of legal authority. Where MOC is practiced routinely and regardless of regulatory jurisdiction, corporate decision-making procedures involving work requests and work orders provide specific lines of authority and responsibility for all potential changes, including those involving replace in kind (most often called change in kind) as well as changes not in kind. The typology of changes, inclusive of some range of changes from negligible to severe risk to health and safety, is precisely reflected by the increased level of authority required to implement the change. For example, Fig. 1.2 is an overview of an MOC procedure that provides for three basic types of changes, each type being defined essentially by the level of authority required to implement it: 9 Level 1: a change that may be authorized solely by the department supervisor who, on the basis of written criteria provided by the company, determines that the change is change in kind and thereby presents negligible hazard or risk. 9 Level 2: a change that does not meet the criteria for a Level 1 change and which, with the concurrence of the corporate safety officer, may be implemented by the department manager only after completion of a management
18
I Scope of Emergency Response
Global Enterprises, Inc. Management of Change Procedure
'ropose(
f-
I Criteria for Identifying 1 Level of Change
Change Initiator Refers Proposed Change to Safety Officer
v*e,2 J
[Le~ ;I 1 }
Change Initiator Issues Purchase or Work Order
t
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Department Completes Management Record of Change (MRC)
Safety Committee Completes Management Record of Change
I
I
I C Adh~
ommittee ] and/or | External | Experts
Procedure I Implement Change 1
I
PersonnelTraining Update SOPs & Records File MRC with Safety Officer
1
FIGURE 1.2 Example of industrial management of change procedure. A Level 1 change is a
"change in kind"; Level 2 and Level 3 changes involve increasing risk due to "changes not in kind" and require higher managerial authority to implement.
Extended Partnership
19
record of change, which is essentially a checklist that directs the manager's assessment of the change and its implementation; in this case, a Level 2 change is known to present more than a negligible health and safety risk, but one that is relatively uncomplicated and easily controlled. 9 Level 3: a change that does not meet the criteria for a Level I change and that, by its nature or complexity, is judged to require the attention of the highest corporate authority, including the safety officer, the safety committee, the facility manager and other selected corporate personnel, and, possibly, external consultants and experts. The criteria for identifying levels of change in Fig. 1.2 are included in Figs. 1.3 and 1.4.
E X T E N D E D PARTNERSHIP
Historically, the first line of defense against community disaster was the local fire brigade. Most often, it still is, and those paramount virtues of the fire fighter~bravery and self sacrifice~are among the most treasured values in any society. But, of course, modern societies are evermore becoming increasingly complex and the range of potential emergencies correspondingly expands, forcing greater specialization and bureaucratic compartmentalization within the traditional armoratoreum of emergency response. Today, no one group or organization is equipped by training, experience, knowledge, equipment, and legal mandate to deal with every type of emergency. Even though still the pivotal organization in most all emergencies, the fire department is but one member of an extended partnership (Fig. 1.5) that, despite historic distinctions between natural and human-made disaster, between local, state, Federal and even national jurisdictional authority, between public and private economic sectors, and between governmental and personal responsibility, must function as a smoothly integrated, albeit multifaceted, enterprise. The objectives of this extended partnership are, simply, to prevent, to prepare for, and to respond to situations that present serious risk to human health and safety. While Federal, state, and local authorities (as well as certain international authorities) have made significant advances in promoting crossjurisdictional partnerships, it is regrettably true that, by and large, industry has maintained a "not my job" mentality regarding emergency response~ despite the fact that, under regulations pursuant to the Resource Conservation and Recovery Act of 1976, hazardous waste generators must prepare contingency plans. In the more than 22 years since then, contingency planning has, of course, been continually expanded under various OSHA regulations, but it would appear that industry has typically substituted a rather
20
I Scope of Emergency Response
For Safety Officer's Use Only
Global Enterprises, Inc.
Log Number
[
,]
Process Code
l
]
Management of Change Request & Determination of Level
Name of Person Initiating Change Description of Proposed Change
Individuals Consulted Name
Department
I certify that I have consulted with the above Individuals for the purpose of completing the reverse side of this form. On the basis of the Information Included on this form, I determine that the proposed change described above ...
Is a Level
1 Change
Signature of Change Initiator
I--7 I I
Must be referred to the Global Safety
Officer for his determination
Date
I certify that I have reviewed this determination and hereby agree with the above determination.
Signature of Authorized Person
Date Pa~e 1 of 2
FIGURE 1.3
Example of a management of change form (request and determination of level).
21
Extended Partnership
Global Enterprises, Inc.
Management of Change Request & Determination of Level
The supervisor or manager of the department responsible for carrying out the proposed change must complete this form and submit the completed form to the Global Safety Officer
If the answer to each of the following questions is "no," the proposed change is a Level 1 change. If the answer to any question is "yes," the proposed change must be referred to the Global Safety Officer (or his designate). Will the Proposed Change ... 1. Require any modification of any of the following Global Programs: * Lockout/Tagout 9 Confined Space Entry * Hot Work Permit 9 Respiratory Protection * Bloodborne Pathogens 9 Hazard Communication * Laboratory Standard 9 Electrical Safety * Hazardous Waste Contingency Plan 9 Hearing Conservation Program 9 Process Safety Management 9 Ergonomic Safety 9 Good Manufacturing Processes 9 Personal Protective Clothing & Equipment 9 Stormwater Pollution Prevention 2. 3. 4. 5. 6. 7. 8. 9. 10. 11.
Require more than routine coordination with other departments Result in any change in equipment or piping Result in any change in structural design or physical layout Result in any change in raw materials or by-products Result in a significant change in energy consumption Result in any interruption of automatic or manual signaling devices or alarms, automatic process controls, alarms or instrumentation Interfere with the normal functioning of any safety or emergency equipment (e.g., sprinklers, ventilation, emergency lighting) Significantly affect the routine on-site work of external contractors or consultants Result in a significant change in operating procedures or process directions Result in a change in process parameters (e.g., temperature, pressure) beyond documented operational limits
YES
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NO
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Page2 of 2 FIGURE 1.4
E x a m p l e of a m a n a g e m e n t of c h a n g e f o r m (criteria for d e t e r m i n a t i o n of level).
T h i s is a c o n t i n u a t i o n of the f o r m d e p i c t e d in Fig. 1.3.
I Scope of Emergency Response
22
~ I
Disaster
Co~m~176 I ~va~Co~ I M~'~'F.c'O~ I f r i E'~'~~ I E,TSE~cO I~ove~~176 ~o''cese~'co I ~z~TT~" '~ ! F,reSe~,co
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FIGURE 1.5 Emergency response capability results from effective partnerships among public and private sector organizations.
complacent "paper-compliance" with these regulations in place of substantial commitment to the social objectives they represent. The rather dismal performance of industry at large is best highlighted by those companies that stand out as state-of-the-art companies regarding commitment to employee and community health and safety. Acting well beyond the literal requirements of specific regulations, such companies: 1. Coordinate directly with local fire departments, ambulance and EMT services, and hazardous chemical specialists in the design and imple-
Proactive and Reactive Dimensions
23
mentation of their in-plant emergency response plans. This coordination includes on-site inspections, the sharing of pertinent information regarding chemical inventories and hazardous in-plant operations and areas, and practice plant evacuations. 2. Review equipment and other material needs of local fire departments, with special emphasis on inadequacies due to specialized plant operations and hazardous materials. Where inadequacies are noted, such companies have actually provided local authorities with the specialized equipment (e.g., computers, radio communication devices, specialized protective clothing) and other materials. 3. Volunteer plant facilities and resources for training exercises conducted by local fire departments and other authorities, and jointly sponsor table-top exercises in which such authorities work directly with in-plant emergency response personnel in designing a coordinated response to mock emergencies. 4. Invite all community partners in emergency planning and response to plant-sponsored workshops and seminars that relate directly to health and safety issues of interest to the community at large. 5. Maintain contracts with private contractors, service providers, and vendors for 24-hour availability of specialized equipment, materials, and services that may be needed in case of a plant-related emergency. 6. Ensure by means of appropriate engineering controls and security measures that all sensitive hazardous operations and materials are fully safeguarded against unauthorized use or entry. 7. Actively encourage, promote, and reward the participation of facility employees in community-based emergency response activities. Such actions reflect, of course, serious commitments of time and possibly of money. However, any state-of-the-art company fully recognizes that any investment in the prevention of or timely response to an industrial emergency is minuscule relative to the very real benefits to be realized both by the corporation and by the community in which it functions.
PROACTIVE A N D REACTIVE D I M E N S I O N S
The on-going switch in paradigm of emergency response being solely the jurisdictional province of a particular agency to being the responsibility of an amalgam of governmental and private sector partnerships clearly reflects a growing realization that any emergency, whether natural or humanmade, is not simply an event, but a societal phenomenon--not simply an isolated incident, but a product of social circumstance. From this perspective, a flood (for example) is not an emergency. A flood becomes an emergency
24
I Scope of Emergency Response
only in terms of the devastation it causes in terms of human life and property. Moreover, ke); factors that influence the degree of human risk are not simply hydrological and meteorological variables, which are beyond human control, but also those political, economic, and social variables that influence the location of dwellings within flood plains and land use policies that can dramatically affect runoff storage capacity . . . variables that are subject to human control. As long as the focus of emergency response is only on the "incident" as opposed to the "circumstance" in which the emergency occurs, emergency response must be viewed as an essentially reactive exerciseman unacceptable approach that relegates a certain number of human deaths per year and certain degrees of human misery per community to essentially an act of God. However, if the focus is in fact more on the circumstances of an emergency than on the incident itself, emergency response is seen to encompass both proactive and reactive strategies that, in combination, can effectively reduce the needless loss of human life and all its attendant trauma. Over the last three decades of the 20th century, there has been significant and steady progress in the long historical effort to transform emergency response into a combined proactive and reactive endeavor and, in combination with the new emphasis on intergovernmental and governmental and private sector partnerships, to imbue that endeavor with practical planning, managerial, legal, and enforcement tools. There can be no question that this progress has occurred as a result of what some see as an erosion, and others see as an on-going maturation of traditional western values regarding property and personal rights. Whether at the national or international level, it is not likely that such contrary perceptions will soon (or ever can) be resolved. Meanwhile, there is everywhere a growing understanding that the continually expanding complexity and interconnectiveness of the social milieu in which we all live requires a significantly more holistic approach to emergency response than has previously been the case. Simply put, even the most rigid attitudes and philosophies tend to change in the midst of disaster.
ELEMENTS OF HOLISTIC PLANNING AN D MANAG EM ENT
INTRODUCTION Whether at the level of the community or individual corporation, emergency response planning and management require the coordination of a wide range of information, services, and materials. Clearly, much of the information required and the services and materials needed in the response phase are highly specific with regard to location and attendant circumstances. However, there are certain aspects of emergency response planning and management that are categorically appropriate to all emergency response efforts and that may therefore be called universal elements of holistic planning and management, including: 9 Scope of Emergency Planning: It is essential that planning proceed from the premise that the objective of planning is inclusive of (a) the prevention of an emergency, (b) preparation for the occurrence of an emergency, and (c) actual response to an emergency. 9 Assessment of Hazard and Risk: Hazard assessment is the identification of potential harm and injury, while risk assessment is the probability of harm and injury to specific persons and groups. Hazard assessment is a necessary first step toward realistic risk assessment, but the estimation of actual risks also depends upon the analysis of potential exposures of defined persons and groups to individual hazards. 9 On- and Off-Site Management: While the site of an actual emergency is typically taken to be the location of actual response efforts, those efforts trigger many activities that affect off-site locations. In some instances, 25
26
2 Elements of Holistic Planning and Management
the off-site sequellae of a distantly located emergency can be more disastrous than on-site consequences. This is particularly the case when an act of terrorism is involved and the strategy is to implement a series of interrelated but individually staged incidents. 9 Authority and Responsibility: Whether in prevention, preparation, or response phases, emergency response planning must be built on absolutely clear lines of authority and responsibility. During the response phase, this is usually referred to as "Incident Command." 9 Communications and Information Handling: Communications and information handling are key activities throughout prevention, preparation, and response phases of emergency planning and management. 9 Provisions and Support: Provisions are the equipment, supplies, and materials that are immediately on-hand to prevent or contain an emergency incident. Support from off-site sources, including governmental agencies and private contractors, must also be provided for in any comprehensive emergency management program. 9 Medical Treatment and Surveillance: Medical treatment and surveillance are inclusive of all first-aid and subsequent medical treatment of acutely affected victims as well as long-term follow-up examinations to monitor for emergent chronic health effects. 9 Remediation and Review: Both during and after an emergency incident, appropriate remedial actions must be taken to protect against further harm or injury due to secondary effects of the emergency (e.g., structural damage, runoff of hazardous materials, hazardous debris); remedial actions also include those taken to recharge or replace supplies and materials depleted in the initial response effort. All remediation efforts should be given first priority in the comprehensive review and evaluation of the emergency incident. Each of these elements requires comprehensive examination of diverse types of information, including information and data related to procedures, operations, equipment, and materials. Within individual corporations, they may well require reconsideration of normal chains of command and procedures which, after all, typically reflect the needs of productivity and quality control as opposed to the real needs of effective emergency management. At the level of the community, the complexity of these issues and concerns is typically constrained by legal jurisdictional authority among governmental authorities and agencies. SCOPE OF EMERGENCY P L A N N I N G
The acronym HSE (health, safety, environment) is frequently used in the international literature to denote the paradigm of Integrated Environ-
Scope
of EmergencyPlanning
27
mental Planning and Management. This paradigm, essentially formulated by the United Nations Conference on Environment and Development (UNCED), commonly known as the Earth Summit (Rio, 1992), is based on a broad consensus that the management of human health and safety and the management of environmental quality can be carried out more efficiently when both efforts are integrated. This consensus is expressed in the 1992 U.N. Earth Summit Agenda and has important social ramifications for both public and private sector decision making: The primary need is to integrate environmental and developmental decisionmaking processes. To do this, governments should conduct a national review and, where appropriate, improve the processes of decision-making so as to achieve the progressive integration of economic, social, and environmental issues in the pursuit of development that is economically efficient, socially equitable and responsible, and environmentally sound. (1992 Earth Summit Agenda 21, p.66)
While the terms occupational safety and health (OSH), environmental safety and health (ESH), and environmental quality (EQ) are still commonly used to focus, respectively, on workplace, nonworkplace, and environmental contributions to human health and safety, it is widely understood that such distinctions may often obscure rather than clarify dynamic linkages (Fig. 2.1) between environmental processes and attributes, human
Envir~
!/
9 Products & Processes 9 Attributes
" ESIH
EQ ---
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_-
/
(
i"
~.
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, I,' I I
I
,
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FIGURE 2.1 Holistic view of dynamic linkages between the environment, community, and workplace (EQ, environmental quality; ESH, environmental safety and health; OSH, occupational safety and health). Heavy solid lines represent issues historically addressed by U.S. regulations; heavy dotted lines represent issues likely to be given increased regulatory attention; light dotted lines indicate basic operational or functional relationships.
28
2 Elements of Holistic Planning and Management
activities (e.g., work), and human health and safety. It is precisely these dynamic linkages that must inform any comprehensive approach to emergency planning and response. For example, if the focus of planning efforts becomes simply the knockdown of a structural fire in a manufacturing plant, it is likely that relatively little attention will be given to the management of the water runoff that results from firefighting activities. However, such runoff may contain hazardous chemicals that, if allowed to infiltrate into ground- or surfacewater supplies, may result in a subsequent emergency involving contaminated drinking water. Another example might be an emergency incident involving the release into the community of toxic vapors or particulates as a result of a highway accident involving a chemical tank truck. While the obvious emergency incident is the accident scene, less obvious is the possibility that some of those vapors or particulates may become entrained into the ventilation systems of even distantly located downstream plants and other facilities m which may result in subsequent chronic effects on workers. By focusing our attention upon interconnected environmental, community, and workplace dynamics, the HSE paradigm requires emergency planning and response to give specific and detailed attention to the fact that any emergency incident is also a systemic threat, with possible consequences that can extend well beyond the particular spatial or temporal coordinates of the incident itself.
A S S E S S M E N T OF H A Z A R D A N D RISK
The term hazard (Fig. 2.2) is sometimes used to define a source of potential harm or injury and, sometimes, the potential harm or injury itself. Thus, a silo containing plastic chips or grain or any other raw materials may be said to be a hazard because, having entered the silo, a worker might become engulfed and subsequently asphyxiated; the hazard also may be defined as the engulfment or the asphyxiation. This double meaning of the word hazard (i.e., the silo itself or the dangers that exist within a silo) often results in a confusion of cause and effect. However used, the word hazard always denotes a possibility or potential. This is what differentiates a hazard from a risk. Whereas a hazard is a possible (or potential) harm or injury (or an immediate precursor to harm or injury), risk is the probability that a person or group will actually experience a specific hazard. As the probability that individual persons or groups will experience the harm or injury of a specific hazard, risk depends upon exposure of those persons or groups to the actual hazard. Emergency response planning, whether at the corporate or the municipal level, begins with a comprehensive inventory of hazards
Assessment of Hazard and Risk
29
Hazard & Risk Assessment !
I
Hazard Assessment 9 Identification of materials released or present on site 9 Physical & health hazards 9 Acute & chronic effects 9 Target organ effects
Exposure Analysis 9 Amounts of materials released to environment 9 Material transport & transformation 9 H u m a n populations at risk 9 Routes of entry
Risk Assessment 9 Risk Factors 9 Potential for toxic effects 9 Potential for other health effects 9 Social equity
FIGURE 2.2
Elements of hazard and risk assessment.
and proceeds in a stepwise fashion to the analysis of exposure and, finally, the estimation of risk. As shown in Fig. 2.3, the assessment of hazards, exposure, and risk may be considered the first of three phases of decision making required for devising effective emergency response policies and procedures that form the basis of the emergency response or action plan: 9 Risk Assessment Phase: identification of the potential sources cause of emergencies and the types and degrees of risk to be experienced the work force, the public at large, and emergency response personnel 9 Safety Judgment Phase: establishment of levels of protection to provided to persons at risk during an emergency 9 Make-Safe Strategy Phase: formulation of specific procedures achieving decided levels of protection
or by be of
30
2 Elementsof HolisticPlanningancNManagement (Sources ]
/ / Types & f "~ IofHazards i / Persons| ~ J
("
~1
|Degreeof|
/
Risk I I Assessment I L Phase~
/ rSocial _ &.]
[Regulatory] ~ Standards
I
;j IL ~
Values
)
Safety~ "
I Judgementl Phase J
] Making-SafeI J Strategy I ~ Phase/
LI
Policies &
Procedures
FIGURE2.3 Phasesof decisionmakingin emergencyresponseplanning.
Risk AssessmentPhase The risk assessment phase (often called simply "hazard assessment") is highly influenced by the concerns and considerations broadly attendant to the Bhopal (India) tragedy in which 4000 people died and 30,000-40,000
Assessment of Hazard and Risk
3I
persons were seriously injured due to a leak of toxic gas at a Union Carbide pesticide p l a n t ~ a n event that, in the United States, became a prime motivation of the development of the Chemical Process Safety Regulations (29 CFR 1910.119). Even where these regulations do not specifically apply, they provide an excellent overview of the broad scope of modern emergency planning and are thereby highly instructive for any emergency response manager. Various analytical techniques are germane to this phase~each of them providing different means for identifying potential sources of workplace emergencies and persons potentially at risk. Standard techniques (Fig. 2.4) include (a) preliminary hazard analysis, (b) what-if analysis, (c) hazard and operability analysis, (d) failure modes and effects analysis, (e) fault and even tree analysis, and (f) human reliability analysis. Preliminary Hazard Analysis focuses on the hazardous materials and major processing areas of a plant in order to identify hazards and potential accident situations. It requires consideration of plant equipment, the interface among plant components, the operational environment, specific plant operations, and the physical layout of the plant. The objective of this technique is to assign a criticality ranking to each hazardous situation that may be envisioned, even in the absence of specific information about plant design features or operational procedures. It is particularly useful for identifying broadly defined causal chains (e.g., fire in materials processing can lead to explosion and release of toxic vapors; release of toxic vapors will be to the ambient atmosphere, and may threaten homes abutting company property) that can then be subjected to more detailed analysis. What-ifAnalysis requires experienced personnel to formulate a series of questions that must be evaluated with respect to potential hazards identified in the preliminary hazard analysis. Typical questions might be of the type, "What if pump 23-b shuts off?" and "What if the operator forgets to empty the overflow tank at the end of the week?" The basic strength of this approach is to define more precisely specific causal chains that can lead to an emergency. Hazard and Operability Analysis depends upon detailed information on the design and operation of the facility. In using this technique, the assessment team uses a standard set of guide words that, when combined with specific process parameters, lead to resultant deviations that may result in an emergency heath and safety situation. For example, the guide word "less" might be combined with the process parameter "pressure" to produce the resultant deviation "low pressure." The assessment team may then focus on the possible causes of low pressure (e.g., in a reactor) and the possible consequence of that low pressure (e.g., change in the rate of chemical reaction in the reactor). Failure Modes and Effects Analysis is closely related to "what if analysis." This technique focuses on the various failure modes of specific
32
2 Elements of Holistic Planning and Management
Hazard & Risk Assessment
Techniques
Preliminary Hazard Ij Analysis What-If Analysis
[ i ~
Hazardous materials & processes; criticality ranking Identification of causal chains leading to emergency
Hazard & Operability l Analysis I
Detailed analysis of plant design & operations
Failure Modes & I
Detailed analysis of effects of failure of equipment
Effects Analysis
Fault & EventTree 1~"-------~ Analysis Human Reliability I ~ ~ : : ~ Analysis I FIGURE 2.4
Modeling of design, procedural and human errors leading to event
Detailed analysis of effects of errors by personnel
Examples of formalized hazard and risk assessment techniques.
equipment and the effects of such failures on plant operations and human health and safety. Examples of questions that reflect this type of analysis when applied, say, to a control valve in a reactor vessel might include: What are the possible consequences of the control valve failing in the open position? In the closed position? What are the possible consequences if the control valve leaks while in the open or closed position? Fault Tree Analysis and Event Tree Analysis involve graphically modeling accidents and failures in equipment and personnel. In fault tree analysis, a specific accident or plant failure (e.g., release of a toxic gas) is defined and all design, procedural, and human errors leading to that event (called the "top event") are graphically modeled in a fault tree. The fault tree allows the analysis to define and rank particular groupings of external factors, equipment failures, and human errors (which are called "minimal cut sets")
Assessment of Hazard and Risk
33
that are sufficient to lead to the top event. While fault tree analysis focuses on failures in equipment or personnel that lead to the top event, event tree analysis focuses on how successes or failures of specific in-place safety equipment, devices, and procedures may contribute to a developing emergency. This type of analysis is typically used to analyze very complex processes that incorporate several layers of safety systems or emergency procedures. Human Reliability Analysis is generally conducted in parallel with other techniques, which tend to be equipment-oriented. This type of assessment focuses on factors that influence the actual job performance of personnel. In such an assessment, detailed descriptions of task requirements, the skills, knowledge, and capabilities necessary for meeting each requirement, and error-prone situations that may develop during task performance are combined to isolate specific factors that, if ignored, might result in an emergency. It is important that considered factors not be limited to those that are directly related to workplace conditions (e.g., ambient noise levels, which might affect a worker's concentration; work schedules, which can result in inattention due to fatigue), but are inclusive of the universe of factors that may influence workplace performance (e.g., personal financial difficulties, marital problems, substance abuse). Regardless of the individual technique (or combination thereof) employed, the risk assessment process must consider potential sources of emergency that derive from other than plant operations, including storms and floods, area-wide fires and chemical releases, and terrorist acts. With regard to the latter, it is advisable that particular attention be given to the fact that a perceived emergency may well be a "blind" to another. For example, a telephoned bomb threat is likely to result in a plant evacuation within a matter of minutes, followed closely by the arrival of fire, police, and/or other specialized investigatory and emergency response units. However, it may be the evacuating personnel or the emergency response personnel, not the physical facility, who are the real targets of the threat. Given this possibility, the prudent planner would ensure the implementation of appropriate procedures for detecting explosive or toxic charges that may be planted in evacuation assembly areas or precisely where emergency vehicles are likely to enter the premises.
Safety Judgment Phase Having identified potential sources of emergencies as well as contributing factors and populations at risk, emergency planners must establish criteria regarding appropriate levels of protection for each at-risk population. This is a very difficult task precisely because it requires that judgments be made directly affecting the safety of human beings. The simple fact is that
34
2 Elements of Holistic Planning and Management
there is no such thing as "1009/0 guaranteed protection" for all. The mere act of evacuating a group of people from a building puts some of those people at great risk of suffering a heart attack or a fall-related injury; panic can kill as effectively as fire. Of course, individual physical and psychological conditions that ensure some differential distribution of risks regardless of any effort to the contrary are not excuses for inaction. In fact, it is precisely the recognition of a differential distribution of risks that becomes the basis of an effective emergency response plan. In the United States, regulatory guidance (OSHA and EPA) regarding the level of protection for personnel having specific responsibility in an emergency involving hazardous chemicals is based on the following typology of emergency responders, which includes members of so-called HAZMAT (for "hazardous materials") teams. The designation HAZMAT always denotes personnel who are expected to perform work in close proximity to a hazardous substance while handling or controlling actual or potential leaks or spills, and should not be confused with other emergency personnel, such as members of a fire brigade. 9 Level 1: responders who are not likely to witness or discover a hazardous substance release and to initiate an emergency response sequence by notifying the proper authorities 9 Level 2: police, firefighters, and rescue personnel who are part of the initial response to a release or potential release of hazardous substances 9 Level 3: HAZMAT technicians, who are the first level specifically charged with trying to contain a release of hazardous substances 9 Level 4: HAZMAT specialists, who respond with and provide support to HAZMAT technicians and have more specific knowledge of hazardous substances 9 Level 5: On-scene incident commanders or senior officials in charge, who assume control of the emergency response incident scene and coordinate all activities and communications The various levels of responders indicated above can be cross-referenced with various levels of protective ensembles (Table 2.1) to meet regulatory requirements regarding personal protective clothing and equipment, such as the requirements of 29 CFR 1910.120. While the above typology of responders gives heavy emphasis to protection from hazardous chemicals, other types of emergency situations and job tasks require other regulatory inputs to the planning process, such as 29 CFR 1910.156 standards that specifically apply to members of a fire brigade. In the process of coordinating with community-based emergency responders, including local fire departments, particular attention should be given to the adequacy of protective clothing and equipment available to external responders with respect to the specific hazards associated with corn-
TABLE 2. I Protective Clothing That May Be Included in Ensembles for Hazardous Waste Operations (Adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities) Level of Protection Overview of and Equipment Protection
Conditions for Use and Limitations
The highest A available level of Recommended: respiratory, skin, 9 Pressure-demand, and eye full-facepiece SCBA protection or pressure-demand supplied air respirator with escape SCBA 9 Fully encapsulating, chemical resistant suit 9 Inner chemicalresistant gloves 9 Chemical resistant safety boots/shoes 9 Two-way radio
The chemical substance has been identified and requires the highest level of protection for skin, eyes, and the respiratory system based on either:
Optional: 9 Cooling unit 9 Coveralls 9 Long cotton underwear 9 Hard hat 9 Disposable gloves and boot covers
9
B
-The same level o f - . respiratory protection but less skin
9
Chemical-resistant
9
clothing Inner and outer chemical-resistant
9 9 9
gloves Chemical resistant safety boots/shoes Hard Hat Two-way Radio
Optional: 9 Coveralls 9 Disposable boot
9
9
Recommended: 9 Pressure-demand, full facepiece SCBA or pressure-demand supplied air respirator with escape SCBA
measured (or potential for) high concentration of atmospheric vapors, gases, or particulates, or site operations and work functions involving a high potential for splash, immersion, or exposure to unexpected vapors, gases, or particulates of materials that are harmful to skin or capable of being absorbed through the intact skin.
protection than Level A. This the minimum level recommended for initial site entries 9 until the hazards 9 have been further identified.
Substances with a high degree of hazard to the skin are known or suspected to be present, and skin contact is possible. Operations must be conducted in confined, poorly ventilated areas until the absence of conditions requiring Level A protection is determined. Fully encapsulating suit materials must be compatible with the substances involved.
The type and atmospheric concentration of substances have been identified and require a high level of respiratory protection, but less skin protection. This involves atmospheres -- with IDLH concentrations of specific substances that do not represent a severe skin hazard, or -- that do not meet the criteria for use of air-purifying respirators. Atmosphere contains less than 19.5 % oxygen. Presence of incompletely identified vapors or gases is indicated by direct-reading organic vapor detection instrument, but vapors and gases are not suspected of containing high levels of chemicals harmful to skin or capable of being absorbed through intact skin. Use only when highly unlikely that the work will generate either high concentrations of vapors, gases, or particulates or splashes of material will affect exposed skin.
covers
9 9
Face shield Long cotton underwear
continues
36
2 Elements of Holistic Planning and Management
TABLE 2. I ~continued
Level of Protection Overview of and Equipment Protection C Recommended: 9 Full-facepiece, air
9 9
9 9 9
purifying, canister equipped respirator Chemical resistant clothing
Conditions for Use and Limitations
The same level
9
of skin protection as LevelB, buta lower level of
9
respiratory protection
Inner and outer chemical resistant gloves Chemical resistant safety boots/shoes Hard hat Two-way radio
. 9 9
Atmospheric contaminants, liquid splashes, or other direct contact will not adversely affect any exposed skin. The types of air contaminants have been identified, concentrations measured, and a canister is available that can remove the contaminant. All criteria for the use of air-purifying respirators are met. Atmospheric concentration of chemicals must not exceed IDLH levels. The atmosphere must contain at least 19.5 % oxygen.
Optional: 9 Coveralls 9 Disposable boot covers 9 Face shield 9 Escape mask 9 Long cotton underwear
D Recommended: 9 Coveralls 9 Safety boots/shoes 9 Safety glasses or chemical splash goggles 9 Hard hat
No respiratory protection; minimal skin protection
9 9
The atmosphere contains no known hazard. Work functions preclude splashes, immersion, or the potential for unexpected inhalation of or contact with hazardous levels of any chemicals. This level should not be worn in the Exclusion Zone. The atmosphere must contain at least 19.5 % oxygen.
Optional: 9 Gloves 9 Escape mask 9 Face shield
pany operations. This is often a critical concern because the local fire firefighter or other local responder, who is usually the first responder to an emergency, typically does not have direct access to the kind of personnel protection devices that are standard equipment for a formal HAZMAT, which can often arrive on-site only well after an emergency has progressed. In many cases, for example, local firefighters will not be equipped with chemically impervious protective clothing that would be required to retrieve personnel trapped within a facility where highly toxic chemicals are used or stored. In some situations, corporations have purchased such cloth-
On- and Off-Site Management
37
ing and maintain it for use by local firefighters. Sometimes a company may also supply the local fire department with additional materials and specialized equipment, including antidotes to toxic chemicals used on-site, specialized monitoring devices, and materials that firefighters can use to disinfect clothing and equipment contaminated by especially dangerous chemicals.
Making-Safe Strategy Phase In this phase, the objective is to assess and select from alternative means for achieving the standards and objectives previously identified and, finally, to develop specific policies and procedures that govern all aspects of emergency response. As shown in Fig. 2.5, policies and procedures should address three basic types of emergency response activities: (a) preparation activities, which are undertaken immediately upon discovery of a potential or actual emergency and prior to the initiation of any response; (b) response activities, which include all efforts to control the emergency and provide assistance to affected persons; and (c) follow-up activities, which focus on postemergency actions to bring the facility or emergency site back to a state of emergency readiness, including revisions to emergency plans necessitated by the experience of the now-past emergency. It must here be emphasized that the usual tendency is for companies to concentrate on the response to an emergency at the expense of attention given to both preparatory and follow-up actionsmwhich is an extremely dangerous approach to emergency planning. Effective emergency planning always requires equally serious attention to all three types of actions. A checklist of basic issues that must be addressed in any comprehensive emergency response plan is included in Table 2.2.
ON- AND OFF-SITE MANAGEMENT Proactive and reactive emergency response activities are essentially exercises in risk management. The basic generic steps of risk management, shown in Fig. 2.6, including ( 1 ) identification of risk exposure, (2) evaluation of risk potential, (3) ranking and prioritization of risks, (4) determination and implementation of control actions, and (5) evaluation and revision of actions and techniques, are equally applicable to the specific site of an emergency incident and to any off-site areas that may be impacted (directly or indirectly) by the known emergency. Just as a comprehensive holistic approach to risk management requires consideration of both on- and off-site sources of hazard to the community and environment (Fig. 2.7), so does it require consideration of the potential implications of a particular incident on distantly located community resources
38
2 Elementsof Holistic Planningand Management Notify on-site personnel about the Incident
p R
Size-up the situation based on available Information
el
Request aid from outside
sources Allocate personnel & equipment for response
Y
Y
Survey and assess casualties
Survey and assess hazards I
E
S P 0 N S E
f
Stabilize ~ victims
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Extricate victims
,
Contain Extinguish~ hazard hazard J
J
........................................
Decontaminate victims ............................................
Transport & ~.treat victims J
i O L
T "I
Evacuate Evacuate I site | nearby ~ personnell public
V
Replace or rejuvenate damaged or exhausted equipment
Document the incident
Review and revise site safety and contingency plans FIGURE 2.5 Basictypes of emergency response operations.
39
On- and Off-Site Management T A B L E 2.2 Checklist of Basic Issues to Be Addressed in Detail in Any Emergency Response Plan
1. Description of type of emergency and minimum information required 2. On- and off-site notification requirements 3. On- and off-site responsible personnel 4. Criteria for evaluating levels of emergency 5. Evacuation requirements 6. PPC/PPE by Task 7. Personnel Monitoring Requirements 8. Communication and Information Processing 9. On- and off-site control procedures 10. Emergency medical care and surveillance 11. Post-emergency actions and documentation
I Step I
People: deaths; illnesses & injuries; health exposures Apparatus & Vehicles: accidents; malicious acts; damage due to mechanical failure; operator error
Identify Risk Exposure
Occupancies/Facilities: natural diasters; fires; malicious acts; failures in proper use/procedures
Equipment: theft; damage from use; damage from misuse; failures in proper use/procedures
Step 2 I Evaluate Risk Potential
t
Iml
Step 3
!
Rank and Prioritize Risks I
I
Step4 Determine& Implement Control Actions
Step 5
I
Risk Attributes: severity; probability;, cost; practicality Context: authority, responsibility;, socio-political [.. expectations
Factors: predicted effect; time required to implement; time
/
required to achieve results; effort required; associated costs; insurance costs; expense funding; cost/benefit; legal mandate
Monitor & Evaluate:
[
Evaluate & Revise Actions and Techniques
Probability: local; national; international experience Severity: fatality;, injury;, illness; operational loss; financial loss
J J
9changes in risk exposure identified in Step 1 9 unanticipated problems that may arise from selected control actions (Step 4) 9 changes in circumstances (each step)
F I G U R E 2.6 Five key steps in developing a risk management program (adapted from U.S. Fire Administration, 1966: Risk Management Practices in the Fire Service [FA-166]).
40
2 Elements of Holistic Planningand Management
Environment Community
Main Plant
Off-Site Operations
FIGURE 2.7 Direct and indirect risks to the community due to industrial on- and off-site operations. Indirect risks are due to impacts of incident on environmental resources (e.g., air, water) that can lead to subsequent exposures of the public to hazardous contaminants.
and dynamics. This approach is particularly important, of course, in cases of terrorism where one or more incidents may be planned primarily to draw attention away from a primary target. However, even where terrorism is not involved, any incident in one location can increase risks at other locations~ as, for example, when an extensive fire in one part of the community leaves the rest of the community with reduced fire response capacity. While the term site control typically refers to response activities undertaken on the site of (or in the immediate vicinity of) a specific incident, off-site management effort must be simultaneously directed not only to ensure the proper back-up of that on-going emergency response effort, but also to manage additional potential risks for the remainder of the community. Of the seven common sources of emergency response failure shown in Fig. 2.8, most (if not all) become evident in a particular site-specific response. As serious as these failures may prove to be in terms of any particular incident, their importance is greatly magnified in terms of the potential needs of effective off-site management. For example, while the lack of an established chain of command may impede if not prevent effective and efficient response to a particular, sitespecific incident, it almost guarantees the vulnerability of the rest of the community to even greater devastation through a well planned and coordinated sequence of terrorist acts. Another example is when, due to the extent of a particular emergency that essentially depletes the response resources of an urban area, additional reserve resources must be temporarily drawn from surrounding communities
41
Authority and Responsibility Lack of coordination between emergency services and other community support services
Lack of established chain of command; lack of uniform command signals; lack of standard terminology
Interference with site operations by crowds of curious public as well as standby response personnel
Effective Emergency
Failure
Looting by the public and/or response personnel
Response
No standardization of equipment used by different responding agencies
Inadequate training of primary response personnel
Uncontrolled access to site by politicians and mass media personnel
FIGURE 2.8 Commoncauses of failure in emergencyresponse operations.
to deal with any additional potential emergency. Depending upon the training, experience, and technology of these reserve resources, they may not be able to deal effectively with additional emergencies that may occur during the interval of the ongoing emergency.
AUTHORITY
AND RESPONSIBILITY
At the heart of any bureaucracy, whether explicitly stated or, as most often the case, only to be inferred from organizational structure, is the distinction between authority and responsibility--the first being, in essence, the right to exact the obedience of others while exercising the prerogatives of independent determination and judgment, while the latter is the duty or obligation to be met through the exercise of that authority. One implies the other and, in consequence, the concepts of authority and responsibility become intimately interconnected in both the encuhurated expectations of
42
2 Elements of Holistic Planning and Management
everyday life and the more formal principles and doctrines that guide institutional behavior. Of course, the marvel of all cultural traditions is that they are often easily "short-circuited"--modified to meet the demands of new experience or, as may often be the case, simply ignored. With regard to corporate attitudes toward health and safety risks, it would appear that the traditional sense of the need for a commensurate balance between authority and responsibly has much more frequently been purposely ignored than usefully modified. Despite a growing number of exceptions, the corporate employee who is assigned programmatic environmental or health and safety responsibility (and, therefore, responsibility for in-house emergency response) is typically a low-level manager, supervisor, or technician who has little if any discernible authority over--or measurable influence on--key corporate decision-making or over any substantive planning or production-related process. In such a situation, it is not surprising that the so called "safety officer" usually becomes preoccupied with actual health and safety incidents and regulatory compliance failures rather than effectively managing a comprehensive health, safety, and emergency response programwor that the workplace continues to be the focus of governmental and social concern about community health and safety and environmental quality. The only practical way by which to ensure that the authority of corporate safety officials is in fact commensurate with their responsibility is to extend that authority to whatever extent required for the effective managerial control of the sources of health and safety hazards and of all circumstances, including emergency planning and response, that may contribute to or be affected by potential human exposure to those hazards. State-of-the-art companies today understand that this approach requires that significant health and safety responsibility, especially responsibility for emergency planning and response, be matched with high-level executive authority. At the operational level of governmental agencies and community services, the concentrated effort to manage the diverse difficulties inherent in any bureaucratic structure of authoritative responsibility has been toward the implementation of the so called "Incident Command System" (ICS). ICS is essentially a management system that can be used in any incident regardless of kind or size, including: 9 9 9 9
Fires, HAZMAT incidents, and multicausal incidents Single and multiagency law enforcement incidents Multijurisdiction and multiagency disaster responses Search and rescue missions
Authorityand Responsibility 9 9 9 9
43
Oil spill response and recovery incidents Air, rail, water, or ground transportation accidents Planned events (e.g., celebrations, parades, concerts) Private sector emergency response
Capable of expansion or contraction, the ICS management system consists of five basic functions (Fig. 2.9), including (a) Command, (b) Operations, (c) Planning, (d) Logistics, and (e)Finance and Administration, which are equally pertinent to emergency planning and response undertaken either by governmental agencies or by private sector corporations. Perhaps the most important of the key features of ICS (which is discussed in detail in Chapter 4) is that the individual designated as the Incident Commander (IC) has absolute responsibility for all functions, even if the IC chooses to delegate authority to perform selected functions to other persons. It is of vital importance, therefore, that the adoption of ICS for emergency
planning and response be undertaken only when the IC is provided absolutely clear and comprehensive authority and support necessary to achieve the objectives of emergency planning and support.
Command Operations Planning Logistics Finance & Administration
~~
~ ~ ~ ~
Sets objectives and priorities Has overall responsibility at incident or event .
.
.
.
9 Conducts tactical operations to carry out plan 9 Develops tactical objectives & organization 9 Directs all resources 9 Develops action plan to accomplish objectives 9 Collects and evaluates information 9 Maintains resource status ,
i
Provides support to meet incident needs 9 Provides resources and all other services needed to support the incident
i
,,.
9 Monitors costs related to incident ...
9 Provices accounting, procurement, time recording, and cost analysis
FIGURE 2.9 Duties and responsibilities of five major functional components of the incident command system (adapted from National Interagency Fire Center, 1994: Incident Command System National Training Curriculum, Module 3 [NFESNo. 2443]).
44
2 Elements of Holistic Planning and Management
COMMUNICATION AND INFORMATION
HANDLING~PROCESSING
In both planning and response phases of emergency management, there must finally be reliance upon human judgment. While the soundness of human judgment can be assessed by various criteria that typically pertain to the specific person exercising judgment (e.g., range of practical experience, demonstrated theoretical expertise, flexibility of approach in different contexts), the essence of sound judgment becomes most often most clearly evident in the manner in which information is specifically and efficiently marshaled toward the actual achievement of objectives. In this sense, there can be no effective emergency planning and response without fastidious attention to communication and to information handling and processing, including the mechanical and electronic wherewithal as well as those components related to substantive content and format, software, and computerized databases. Examples of key communication and informational needs for emergency planning and response include: 9 Alarm and alert systems and devices (e.g., facility evacuation alarms; process control alarms; safety alert devices for SCBA ensembles; automatic notification of community fire, HAZMAT and rescue services; inplant monitoring systems) 9 Line, radio, and oral communication devices/procedures (e.g., interand intraresponse teams and units; incident command and community resources; public address and mass-media; communication reliability, security, redundancy, and backup) 9 Chemical databases (e.g., on-site chemical inventories, chemical attributes, required personal protective clothing (PPC) and equipment (PPE), accepted disposal techniques) 9 Computerized modeling (e.g., air dispersion models) and information retrieval systems (e.g., virtual reality systems for directed entry into buildings) 9 Hardcopy information files (e.g. Material Safety Data Sheets, plant and responder personnel rosters, inventory of at-risk persons and resources in general area, location of access roads and entries, location of sensitive environmental resources, structural components and attributes of facilities, location of in-plant hazards) In any particular incident, much of the information required for effective emergency response actually exists, but is either located or formatted in such a manner as to preclude its timely use. For example, Fig. 2.10 is an example of a chemical inventory containing information about a company's stock chemicals as required under U.S. OSHA Hazard Communication
45
Communication and Information Handling/Processing
Global Enterprises, Inc. Chemical Inventory Department Quality Control Laboratory
Date July 19, 1996
Authorization Elizabeth Kohl
1, 3-Phenyiguanidine Route(s): Inhalation; Absorption; Surface Contact Hazard(s): Irritant; Sensitizer; Toxic Target Organ(s): Skin; Eye; Mucous Membranes; Respiratory Tract
2-Butoxyethanoi Route(s): Inhalation; Ingestion; Absorption; Surface Contact Hazard(s): Combustible; Irritant; Toxic; Teratogen Target Organ(s): Skin; Eye; Mucous Membranes; Kidney; Liver; Blood; Respiratory Tract; Reproductive System; Lymphatic System 2, 4, 6-Trichlorophenoi Route(s): Inhalation; Ingestion; Absorption; Surface Contact Hazard(s): Irritant; Toxic; Carcinogen Target Organ(s): Skin; Eye; Mucous Membranes; Respiratory Tract
Aeetophenetidin
Route(s): Inhalation; Ingestion; Absorption; Surface Contact Hazard(s): Irritant; Toxic; Carcinogen; Teratogen; Mutagen Target Organ(s): Skin; Eye; Mucous Membranes; Lung; Kidney; Bladder; Respiratory Tract, GI Tract; Reproductive System; Nervous System
Ceric Ammonium Nitrate Route(s): Inhalation; Ingestion; Surface Contact Hazard(s): Oxidizer; Irritant; Toxic Target Organ(s): Skin; Eye; Mucous Membranes; Respiratory Tract
Page 3 of 65
FIGURE 2.10 Sample page from a corporate chemical inventory that includes chemically specific health and safety information.
(29 CFR 1910.1200) and Laboratory (29 CFR 1910.1450) Standards. The format of information depicted in Fig. 2.10 would not typically be useful to an Incident Commander in the midst of an actual emergency. However, such information is most often computerized, and therefore the database could
46
2 Elements of Holistic Planning and Management
easily be managed so as to produce, for example, a printed list of all flammable and corrosive liquidsma list that could be of immediate use to emergency response teams. The production and availability of such a printed list depend, of course, on appropriate liaison between corporate officials and emergency responders prior to an actual plant emergency. PROVISIONS A N D SUPPORT
In the vast majority of hazardous incidents, it is highly unlikely that sufficient supplies of material resources (provisions) or appropriate personnel (support) will be immediately available to meet the needs of emergency responsemespecially when that response requires highly specialized expertise, materials, or equipment, or when the incident involves potential risk to large numbers of people or extends over an extensive geographical area. Moreover, because even a seemingly small and well-contained incident may suddenly escalate to a major incident or develop in an unforeseen manner, it is necessary that emergency planning at both corporate and municipal levels includes detailed plans for obtaining, as necessary, provisions and support beyond those that are readily available and under the direct control of the incident commander. In this regard, emergency planning (and training) must be guided by the assumption of a worst-case scenario for the incident. Just what constitutes the worst-case scenario for a potential incident cannot, of course, be precisely defined except in the specific context of an actual incident. However, certain categorical circumstances must always be considered, including: 9 In-plant work-shift schedules (resulting in variable availability of personnel who can serve as initial responders) 9 Holidays, local events (e.g., parades), and highway traffic congestion 9 Severe weather conditions 9 Concurrent disasters in local area (or region) 9 Local or regional power failure 9 Disruption of primary means of transportation 9 Significant risk to large portions of the public 9 Significant risk to environmental resources (e.g., public water supplies) 9 Overwhelmed local medical treatment or temporary housing facilities 9 Potential involvement of special facilities/populations (e.g., hospitals, schools, day-care centers, nursing homes) Table 2.3 includes a variety of resources that may need to be obtained from external sources, including public and private sources. In addition to
47
Provisions and Support TABLE
2.3 Potential Resources for Rescue Teams (Adapted from U.S. Fire Administration, 1995: Technical Rescue Program Development Manual [FA-159])
Supplier Construction/heavy equipment companies; state and local public works agencies Rental companies Lumber yards Association of Engineers Communications Emergency equipment suppliers Schools, churches, Red Cross, food suppliers Funeral homes and medical examiners Helicopter terminals Military/National Guard Transport companies Utility companies Bottled water companies
Resource Backhoes; cranes; air compressors; dewatering pumps; dozers; loaders; welders; bobcats; generators; cherry pickers; tractor trailers; lighting; heavy tools; cutting and breaching equipment Light tools; lighting; generators; air compressors Lumber; cutting equipment Civil engineers; electrical engineers; fire protection engineers Television stations; radio stations; ham radio groups Sandbags; hazardous waste removal firms; vacuum trucks Disaster centers; food; shelter Morgueservices Medevac; rescues; aerial photography; personnel and supply transport Personnel; equipment Equipment and supply transport; refrigerated trucks Utility shut-off Bottled water
these sources, both municipalities and corporations should consider establishing formal mutual assistance agreements among local organizations to ensure the timely availability of necessary resources. This approach is particularly useful where there is a local concentration of similar or related industries, such as deep-water ports, technology parks, and industrial centers. In addition to material resources, informational resources must also be identified and effectively integrated into the emergency planning process. Informational resources include public and private services of local, regional, national, and (increasingly) international scope (Table 2.4). While many of these services are organized on the basis of specific types of hazards (e.g., poisons, biological hazards, pesticides), a growing number of professional organizations provide and share information on the basis of specific types of industry (e.g., pharmaceutical manufacturers, electroplators). At the local level, an important pool of valuable information and resources is available for purposes of emergency response planning through individual corporate plans (Table 2.5) already developed to meet specific regulatory requirements (e.g., Chemical Hygiene Plan, Hazard Communication Plan). In some nations, some of these corporate plans are required to be filed with community authorities. For example, in the United States, the
2 Elements of Holistic Planning and Management
48
TABLE 2.4 Information Services (Adapted from U.S. Fire Administration, 1994: EMS Safety: Techniques and Applications [FA-144/April 1994])
Information Services CHEMTREC
Tel: 800-424-9300 A private service providing information about chemicals involved in transportation accidents
ATSDR (Agency for Toxic Substances and Disease Registry) Tel: 404-488-4100
A 24-hour service that provides toxicological information and HAZMAT incident guidance
CDCP (Centers for Disease Control and Prevention) Tel: 404-633-5313 Provides information about biological and disease-related hazards
Local Poison Center Regional centers that cover all regions in the United States
NPTN (National Pesticide Telecommunications Network)
Tel: 800-858-7378 A 24-hour service for information related to pesticide exposures and accidents
NRC (Nuclear Regulatory Commission)
Tel: 301-951-0550 A 24-hour service for information re~]ardin~ radioactive materials
corporate contingency plan developed in compliance with U.S. EPA hazardous waste regulations must be made available to the local fire chief and other authorities (including corporate-designated medical facilities). However, regardless of specific regulatory requirements regarding coordination with local authorities, most corporations develop extensive information and detailed plans that, if made more generally available, would significantly expand local emergency response capacity. The sharing of such information and related material resources beyond the requirements of individual laws and regulations is probably most feasible through individual mutual assistance agreements among corporations as well as between corporations and local community authorities.
MEDICAL TREATMENT AND SURVEILLANCE
In any incident, there are several distinct groups of potential victims that must be considered for possible medical treatment and surveillance"
49
Medical Treatment and Surveillance TABLE 2.$ Example of Table of Contents for Corporate Chemical Hygiene Plan Pursuant to 29 CFR 1910.1450
Chemical Hygiene Plan Table of Contents
1. Introduction 2. Responsibility 3. Standard Operating Procedures (general) 9 Personal Preparation & Behavior 9 Preparation of Work Area & Equipment 9 Maintenance of Work Area 9 Emergencies 9 Ordering Chemicals 9 Receiving Chemicals 9 Transporting Chemicals 9 Storing Chemicals 9 Using Chemicals 9 Using Extremely Hazardous Chemicals 4. Standard Operating Procedures (Chemically Specific) 9 Compressed Gases 9 Corrosive Chemicals 9 Flammable Chemicals 9 Extremely Hazardous Chemicals 9 OSHA Listed Chemicals
continues
9 On-site victims (i.e., persons who are present on-site at the time of the incident and who are immediately at risk) 9 On-site emergency response personnel (i.e., initial or subsequent responders who, though prepared to respond to the emergency, are nevertheless subject to risk; this group includes firefighters, HAZMAT and other specialized (e.g., EMT) teams 9 Off-site emergency response personnel (personnel who, though offsite, may be at risk due to contamination (chemical/biological) of evacuated victims (e.g., hospital personnel, ambulance personnel) or to fugitive toxic fumes/particles 9 Off-site general public (any other off-site person who may become at risk due to air or water contamination directly or indirectly related to the incident, through contact with similarly contaminated persons, or through contact with facilities used as temporary shelters/housing for contaminated victims)
50
2 Elements of Holistic Planning and Management TABLE 2.5--continued
Chemical Hygiene Plan
Table of Contents (continued) 5. Methods for Limiting Exposure 9 Engineering Controls 9 Fume Hood Inspection 9 Personal Protective Clothing & Equipment 9 Emergency Equipment 6. Availability of Data & Information 7. Personnel Training 8. Medical Surveillance 9 Exposure Determination 9 Methods of Surveillance 9 Documentation 9. Determination of Health Hazards 9 Acute Hazards 9 Chronic Hazards 10. Special Issues 9 Prior Approval for New Chemicals 9 Chemicals Generated in Laboratory
Appendices
Historically, emergency response planning has typically focused on providing on-site victims the medical treatment and surveillance appropriate for acute physical injury and psychological trauma. However, it has become increasingly evident (especially with respect to terrorism) that treatment and surveillance related to chemical and biological contamination of both onand off-site victims are critical, and demand equal regard for acute and chronic injury and disease. Even in the absence of terrorism, the increasing global dependence on industrial chemicals and the rapid development of biotechnology increases the probability that industrial incidents will result in increasing numbers of the general public being at risk due to dangerous chemical and biological exposure. In this sense, our historic experience with providing medical treatment to large populations simultaneously subjected to the geographically extensive acute risks of storms, floods, and earthquakes provides limited instruction for providing medical treatment and surveillance to large popu-
Remediation and Review
5J
lations simultaneously subjected to both the acute and the chronic hazards of chemical and biological agents.
R E M E D I A T I O N A N D REVIEW
Whatever the operational or even regulatory definition of an emergency response incident, the actual incident is multidimensional, consisting of (a) preceding events, (b) the primary event that precipitates emergency response, (c) all actions taken during the response effort, and, finally, (d) all circumstances resultant from the response effort. Remediation is inclusive of all actions undertaken during and after the response effort (c and d, above) to minimize harm and injury due to the secondary effects of the emergency. For example, the incident may be essentially defined as a structural fire; however, runoff water resultant from fighting that fire may contain toxic chemicals, and remedial actions must be taken to contain and properly dispose of that contaminated water. Also, it may be necessary to demolish remaining structures that may have become unsound. With similar regard for managing risk both during and after the incident, it is incumbent upon the emergency planner to consider a wide range of additional issues, including: 9 Off-site management of crowds and management that might not only interfere with the specific response effort, but also result in other public and personal risks 9 Implementation of facility and local community evacuation 9 Assessment of injuries and allocation of victims to first-aid and subsequent medical treatment 9 Decontamination of personnel, equipment, materials, and facilities that may have become contaminated during the emergency response 9 Containment and ultimate disposal of contaminated soil, water, structural and inventory materials 9 Preservation of scene for subsequent criminal investigation 9 Recharge and/or replacement of exhausted, damaged, or proveninadequate emergency response materials, supplies, and equipment 9 Documentation of all response efforts 9 Documentation of possible exposures of response personnel (for use in subsequent long-term medical surveillance of response personnel) 9 Retraining of personnel in light of actual response performance 9 Review and revision of existing emergency response plans and response procedures in light of the incident
52
2 Elements of Holistic Planning and Management
Perhaps the major difficulty in ensuring a comprehensive assessment of remediation and review efforts is that, in an actual incident, various authorities (including corporate and public personnel) play diverse roles and are subject to different jurisdictional constraints. From the perspective of corporate and municipal managers, it is therefore essential (a) to conduct a comprehensive and intensive postincident debriefing of all responding agencies and authorities, and (b) to integrate resultant findings, information, and recommendations into subsequent emergency response planning and training activities.
THE EMERGENCY RESPONSE PLAN
INTRODUCTION
While there are numerous formats for emergency response plans promulgated by various agencies, laws, and regulations (e.g., U.S. Fire Administration, U.S. Environmental Protection Agency, EPCRA, RCRA, 29 CFR 1910.1200), it is clear that no single format can be sufficient for preparing for and responding to all potential emergency incidents. In this regard, legally mandated formats typically include minimum categorical requirements, with specific details left to be decided by the operational organization having primary responsibility for site-specific facilities and situations. This is not to say that there are no objective criteria for evaluating an emergency response plan. Certainly, any reasonable plan must include certain provisions, including such vital elements as emergency evacuation procedures, methods for accounting for personnel, rescue and medical services, reporting requirements, and chain of command. However, of paramount importance in any plan is that specificity of circumstance which can only be addressed adequately by on-site personnel. Unfortunately, the flexibility necessarily afforded by regulatory authority to industry is all too often misinterpreted. The tendency, especially where industry perceives itself to be over-regulated, is to conform (if at all) to the minimum regulatory requirements and, by so doing, consider that minimum compliance to be sufficient for regulatory objectives. Where de minimus regulatory compliance becomes the measure of the attainment of regulatory objectives, the usual self-fulfilling prophecy unfolds~more and more detailed regulations are developed by frustrated governmental agencies, and industry, perceiving itself increasingly burdened by unreasonable regulators, focuses more and more on simple minimal 53
54
3 The Emergency Response Plan
compliance. During this on-going and (most often) increasingly heated political confrontation, lives are lost that otherwise might have been saved. In the United States as well as in some other nations having highly diverse, overlapping political jurisdictions and operational authorities, it is perhaps understandable that persons tend to see the prevention of and response to community emergencies (as well as personal emergencies) as the primary responsibility of public agencies and public services. However, other nations take another approach. For example, in Malaysia, the prime responsibility for preventing and responding to a community risk is specifically and legally assigned to the person(s) who causes that risk. Malaysian fire and rescue services, as well as all other public emergency response services, respond in the same professional manner as these services do in the United Stateswthe difference is that industry knows that industry (and not a public agency or service) has primary responsibility to do whatever is necessary, first, to prevent an incident and, second, to provide appropriate initial response; hence industry, being so clearly accountable, adopts a de minimus approach to human health and safety only at certain and severe financial and criminal risk. Regardless of political system, cultural tradition, or stage of economic development, nations today are partners in a global village that is increasingly subject to the risks of sophisticated technologies employed by specialized industries typically located in major metropolitan areas. Whatever the first cause of a particular emergency, whether earthquake, typhoon, terrorist act, or simple accident, that emergency is highly likely to involve (directly or indirectly) industrial chemicals or materials, with potentially devastating effects on whole communities. But no emergency appears instantaneously. As shown in Fig. 3.1, any potential emergency evolves over longer or shorter periods of time, most often presenting warnings that, if recognized and properly acted upon, can preclude the development of an actual crisis. Those who are in the best position to recognize the early and progressive warning signals of an impending crisis are precisely those people on-site where the emergency begins. Typically, these are not the personnel of some governmental agency or public emergency response service but, rather, the workers and administrators in the facility wherein the crisis begins or in the facility that may be affected by an out-of-control emergency that develops elsewhere. Even where industry realizes and accepts its primary responsibility for preventing, preparing for, and responding to emergencies, there is too often a misconception of the purpose of a fully developed, written emergency response plan. The purpose of the written emergency response plan is not to document what should be done but, rather, to train personnel how to perform their specific emergency responsibilities. Prevention, preparation, and response requirements that are defined by the emergency response plan must
Introduction
55
\
Pre-Crisis
9 Recognize Potential Problem
9 TakeCorrectiveAction
_.•
Warning
9 RecognizeDangerSigns 9 Take Immediate Action
,,,
[~
Crisis
Transition
....
~
Avoid
,,,
9
Respond Contain Damage
j
i-~'~-~~
Post-Crisis c ~ .
.
9 Returnto Normalcy
Repetition ,
Increasing Magnitude of Incident
,,,=
,,
u,. v
FIGURE 3.1 Typical phases in the development of a crisis. Note that appropriate corrective actions taken at early signs of impending crisis can prevent or mitigate the actual crisis.
be translated by training into on-the-job performance and, as necessitated by revisions to the plan, by retraining (Fig. 3.2). After all, a crisis is not the appropriate time to read a manual--a crisis demands immediate, premeditated, pretested action.
FIGURE 3.2 Pyramid of effort in emergency planning. Note that the vast majority of effort must be given to prevention and preparation.
56
3 The
EmergencyResponsePlan
Regarding the development of an emergency response plan that is truly proactive as well as reactive and also one that is effective and practical, it is useful to reemphasize as well as expand upon five basic principles. These principles focus on the issues of responsibility and training discussed above, but also on important correlates to responsibility and training, including communication, practice, and command. I. Proper Emergency Planning Begins with the Owners, Operators, and Managers of the Facility Involved in or Contributing to a Potential or Actual Emergency
Employers must take primary responsibility for the workplace health and safety of their employees and for the potential risks that their operations present to the larger community. Meeting this responsibility requires the development, implementation, and periodic testing of an emergency response plan that details (a) the potential sources of hazards, (b) specific steps to be taken by employees to prevent or respond to an emergency, and (c) necessary coordination and liaison with local, national, and other competent authorities. 2. An Emergency Response Plan Is Only as Good as the Training Given to the Personnel W h o Must Implement the Plan
Periodic, in-depth training and practice drills must be conducted with the objective of ensuring that personnel respond immediately and appropriately to potential and actual emergencies. This training must include the evacuation of nonessential personnel as well as the proper use of equipment and procedures by first responders. It is particularly important to coordinate selected in-plant training exercises with local competent authorities, such as the fire services and medical/ambulance services. Where time constraints on community services permit, it is highly desirable to involve such services in actual in-plant training sessions, especially sessions that focus on procedures for coordinating on- and off-site response. 3. Communication Plays an Especially Vital Role in both the Prevention of and the Response to Any Emergency
In-plant communication among personnel, managers, and first responders as well as external communication with competent local authorities must be specifically channeled for the purpose of immediately providing key information to persons authorized to make decisions. During an actual emer-
Introduction
57
gency, such information includes (but is not limited to) the in-plant location of hazardous chemicals and other potential hazards (such as electrical or radioactive hazards), the number and location of trapped or evacuated personnel, and immediate medical needs.
4. On-Going Facility Audits and Practice Drills Are Essential for Updating and Refining an Emergency Response Plan
Audits of the physical plant, procedures, equipment, and conditions should be continually conducted to identify and remedy potential emergencies. Audits should be conducted by personnel specifically authorized to ensure that corrective action is immediately taken. Corrective actions should be documented and periodically reviewed along with the results of evacuation and first responder drills to ensure appropriate revisions of the emergency response plan.
5. There Can Be No Proper Emergency Response without the Existence of a Practiced, On-Site Chain of Command
Primary and alternate facility emergency response coordinators must be designated so as to ensure their earliest possible presence on-site during an emergency. It is the responsibility of the facility emergency response coordinator to (a) implement and direct all response activities included in the facility emergency response plan and (b) provide whatever aid, assistance, and information may be required by external responding authorities, such as fire services and police. Whenever the external emergency response authority may take command of the emergency, the facility emergency response coordinator will ensure that he will act only upon the specific direction or with the approval of that authority. The development of an emergency response plan begins with a comprehensive overview of the facility (Fig. 3.3) that includes (a) all on-site an and off-site operations, (b) the industrial, commercial, community, and environmental surroundings of the facility and its operations, (c) the analysis of potential hazards associated with facility operations as well as of potential human and environmental targets of those hazards, and (d) the identification of all community and in-plant emergency response resources available for managing both potential and actual emergencies. The corporate plan for conducting emergency response must integrate these considerations into clear, concise directions for implementing immediate and effective response.
58
3 The Emergency Response Plan
Facility 9 9 9 9 9
Processing Receiving Storage Handling Shipping
9 By-Products 9 Waste Management 9 Management of Change
Facility Environs
U
Hazard Determination 9 9 9 9 9
I
Community
Emergency Services
On- & Off-Site Operations Hazard Class/Category Source & Magnitude Target Population Target Environmental Resources
i ! In-Plant Emergency J I Other Communky Response Team Resources
I
Information/Data 9 Evacuation 9 MedicalTreatment
9 Responsibility/Authority
9
9 Clean-Up/Resupply 9 Training
9 Reentry 9 Documentation
9 Supplies/Equipment 9 FirstAid
FIGURE 3.3 sponse plan.
I
Key informational components of a comprehensive corporate emergency re-
C O N T E N T S OF E M E R G E N C Y RESPONSE PLAN
The organization and contents of emergency response plans can vary considerably, depending upon the responsibility and needs of the particular facility or organization that develops the plan. Basic emergency services (e.g., fire, search and rescue, medical) often adapt essentially generic plans (Fig. 3.4) to conform to individual circumstances. Different industrial facilities may also do the same, modifying generally available basic formats to
Contents of EmergencyResponsePlan
59
I ~ 10. Demobilization ]___ 9. Maps r ' r "~ I s. Safety Plan F-/ I | 7. Traffic Plan m I/ I [&Medical ~_[ 6. Air Ops. ]---J/ I _ l . ~ /4. C o m m n n i c a t i o n s ~ 3 / ] | 3. Assignments (~ 1-1 .~ ~/ 1/
I:lObeetiv, . ~_~2.0r~an,afion/ / Incident
Action Plan
[ /
[//
FIGURE 3.4 Typical contents of an incident action plan (adapted from National Interagency Fire Center, 1994: Incident and Event Planning [Module 11:I-3000, NFES No. 2460]).
meet specific requirements regarding type of industry, number of personnel, and nature of industrial hazard. Regardless of the type of facility, an emergency response plan for an industrial facility should contain (at a minimum) the following basic categories of information: 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9
Objectives Responsibility and Authority Distribution of Plan Emergency Equipment and Supplies Location of Data/Information Assessment of Hazards General Procedures Notification Procedures Evacuation Procedures Containment Procedures Special Procedures (e.g., fire, explosion, flood, toxic gas release) Equipment Shutdown Return to Normal Operations Training Documentation Informational Appendices
An example of the more detailed information typically included under each of these broad headings is included in Table 3.1. While the detailed format and informational contents of any emergency response plan must be finally based on site-specific details, it is worth examining each of the sections included in Table 3.1 in order to give proper emphasis to key considerations.
60
3 The EmergencyResponse Plan TABLE 3. I Exampleof Detailed Tableof Contents for a ComprehensiveEmergency Response Plan ....
Global Enterprises, Inc. Emergency Response Plan Table of Contents 1. Introduction A. Objectives: Regulatory Compliance B. Objectives: In-Plant Safety and Health Program C. Objectives: Personnel Training D. Objectives: Community Health and Safety 2. Responsibility and Authority A. Preparation, Review and Update of Plan B. Primary and Alternate Response Coordinators C. Liaison with Community Services D. Liaison with Local Industry E. In-Plan Emergency Response Team F. Communication with Media G. Personnel Training Program H. Facility Audits I. In-PlantHazard and Risk Assessment J. Hazardous Waste Management K. Liaison with Contractors (for special emergency related services) L. Maintenance of Documentation M. Overview of Emergency Response Organization 3. Distribution of Plan A. Facility Personnel B. Community Services 4. Emergency Equipment and Supplies A. EmergencyContainment Equipment and Supplies B. Personal Protective Clothing and Equipment C. Fire Fighting Equipment D. Medical Supplies E. Monitor and Alarm Systems F. Equipment and Supplies Available through Mutual Assistance Programs G. Equipment and Supplies Available through Contractors
continues
Introduction
While one of the objectives of the corporate emergency response plan may well be regulatory compliance, it is important that industry understand that proper emergency response planning is an integral component of plant design and operations. In this regard, the emergency response plan must be
61
Contents of Emergency Response Plan TABLE 3. I --continued
Global Enterprises, Inc. Emergency Response Plan Table of Contents (continued) 5. Location of Data/Information A. Chemical Inventory B. Material Safety Data Sheets C. Layout of Facility (with access points) D. Floor Plans E. Location of Hazardous Areas/Materials F. Catchments and Drains G. Site and Area Topography H. Sensitive Natural Resources in Plant Vicinity 6. Assessment of Hazards A. Hazardous Stock Chemicals, Energy, Materials & Conditions B. Materials Safety Data Sheets & Other Specifications C. Hazards & Risks Associated with Facility Environs D. Hazards & Risks Associated with Off-Site Operations E. Process By-Products F. Summary of Hazards & Risks: Types, Potential Target Populations, Potential Target Environmental Resources, and Management Strategies 7. Potential Emergency: General Procedures A. Audits (type; frequency; responsibility; documentation) B. General Personnel (responsibility; chain-of-command; documentation) 8. Actual Emergency: Notification Procedures A. Notification of Emergency Response Coordinator and Team B. Activation of Evacuation Signal C. Notification of Community Services D. Notification of Other Potentially Affected Facilities/Persons E. Notification of Contractors (for emergency supplies/equipment) F. Notification of Mutual Assistance Partners
continues
viewed as a key means of meeting facility obligations regarding (a) employee health and safety, (b) personnel training, and (c) community (including both human and environmental) health and safety--obligations that may be made subservient to other production and business objectives only at everincreasing financial and criminal risk to corporate management. The emergency response plan must therefore begin with clear statements with regard
62
3 The Emergency Response Plan
TABLE 3. I mcontinued
Global Enterprises, Inc. Emergency Response Plan
Table of Contents
(continued)
9. Actual Emergency: Evacuation Procedures A. Primary and Secondary Routes of Evacuation B. Location of Alternate Assembly Points C. Communication Requirements D. Monitoring Personnel During Evacuation & Assembly Points E. Decontamination and Medical Service Procedures F. Temporary Shelter/Housing G. Post Evacuation Procedures 10. Actual Emergency: Containment Procedures A. Communication Requirements B. Ventilation Systems C. Berms D. Absorbent Materials E. Fire Barricade F. Temporary Runoff Storage G. Temporary Storage of Other Hazardous Materials H. Follow-Up Procedures 11.Actual Emergency: Special Procedures A. Fire/Explosion B. Flood C. Storm D. Electrical E. Toxic Gas Release F. Fugitive Hazardous Particles G. Power Failure H. Operational Unit Failure I. Hazardous Waste Release 12.Actual Emergency: Equipment Shutdown A. In-Plant Authorized Persons B. Requirements of In-Plant & Community Response Services C. Protocols and Specifications continues
to corporate recognition of and commitments to these objectives. In some jurisdictions, such statements are considered by legal authority to establish legally binding, contractual commitments between the facility and regulatory authority, employees, and the general public.
63
Contents of Emergency Response Plan TABLE 3. I --continued
Global Enterprises, Inc. Emergency Response Plan Table of Contents (continued) 13. Return to Normal Operations A. Determination of Safe Conditions B. Re-entry C. Replace of Emergency Supplies & Materials D. Clean-Up & Decontamination E. Testing of Safety Devices, Monitors, Alarms, and Structural Integrity F. Equipment Start-Up 14 Training A. General Requirements for All Personnel (1) Proper Housekeeping and Behavior (2) Spill Containment (3) Proper Reporting Procedures (4) Alarms and Waming Devices (5) Chemical Hazards (6) Other Hazards (7) Evacuation Procedures B. Additional Requirements for In-Plant Emergency Response Team (1) Use and Maintenance of Fire Fighting Equipment (2) Use and Maintenance of personal protective Equipment & Clothing (3) Decontamination Procedures (4) Use and Maintenance of Monitoring Devices (5) Use and Maintenance of Communication Equipment (6) Proper Equipment Shut-Down and Start-Up Procedures (7) Confined Space Rescue (8) First Aid & Cardio-Pulmonary Resuscitation (CPR) C. Programmatic Elements (1) Frequency and Level of Training (2) Announced and Unannounced Drills (3) Coordinated Training with Community Services (4) Evaluation of Training
continues
Responsibility and Authority Over the past decade, regulatory agencies (in the United States as well as in an increasing number of other countries) have given much emphasis to the importance of identifying specific individuals who have both the respon-
64
3 The Emergency Response Plan TABLE 3. I --continued
Global Enterprises, Inc. Emergency Response Plan Table of Contents (continued) 15. Documentation A. B. C. D. E. F. G.
Facility Audits Regulatory Agency Audits Non-Emergency Corrective Measures Emergency Incidents: Description and Debriefing Personnel Training Medical Surveillance of In-Plant Emergency Response Personnel In-Plant Chemical Exposures
Appendices 9 9 9 9 9 9 9
Chemical Inventory General Layout of Facility and Environs Floor Plans Location of Hazardous Wastes and other Hazards Location of Fire Hose Connections and Fire Extinguishers Training Schedule for In-House Personnel Training Evaluations
sibility and the corporate authority for ensuring compliance with regulatory requirements. There can be no question that proper emergency planning and response demand effective and efficient management of a myriad of detailed information, diverse personnel and skills, and precisely defined procedures in perilous and confusing circumstances. Just who must do what, and when? and Where and how must he do it? are therefore the quintessential questions to be immediately answered and acted upon in emergency response; this cannot be done where there is no clear designation of responsibility and authority, or where there is no commensurate authority for a given responsibility.
Distribution of Plan
In some nations, regulations require the distribution of emergency response plans to specific individuals and organizations (e.g., in the United States, regulations regarding contingency plans developed under RCRA). Regardless of jurisdictional authority, it is recommended that emergency re-
Contentsof EmergencyResponsePlan
65
sponse plans be distributed among all persons and organizations having primary and support responsibility in order to (a) ensure the proper sharing of important information and standard procedures, (b) provide a basis for continual feedback regarding proposed revisions and refinements, and (c) provide an essential tool for conducting coordinated training and practice among diverse facility an community responders. However, the distribution of emergency response plans should also be influenced by two key considerations: 1. As plans are revised and refined, it is possible that various members of facility and community response services and teams will maintain different versions of the same plan. This could result in disastrous confusion. It is therefore necessary that the distribution process include a means of recalling and destroying versions of the plan that have become superseded. 2. Various members of facility and community response services and teams do not need copies of the complete plan. For example, community hospitals certainly do not require information on in-plant evacuation routes, while information on potential in-plant chemical exposures is absolutely essential. Provisions should be made, therefore, to provide appropriate components of the plan to individual services. It is especially important to coordinate with individual services to ensure not only that they receive appropriate information, but also that they receive the information in a format that facilitates efficient use.
Emergency Equipment and Supplies
The number, type, description, and location of all emergency equipment and supplies must be clearly identified, including on- and off-site equipment and supplies. Where specific items are available through mutual assistance programs or through prearranged contractor services, realistic estimates of availability (i.e., time to site) must also be included. Additional key considerations include: 1. The availability of any item is a function not only of its location but also of its state of readiness. The actual availability of an item must therefore be estimated in light of documented (or otherwise assured) adherence to testing, maintenance, and replacement schedules. 2. Depending upon the development of an actual crisis, different types of equipment and supplies may be needed, as well as different numbers or amounts. Appropriate emergency response planning must therefore take into account a range of potential emergency scenarios and corresponding demands on equipment and supplies. A typical approach is to designate equipment and supplies as being on-line, reserve, and backup. Such
66
3 The Emergency Response Plan
designators may also be used with regard to personnel as well as other emergency services. 3. Other factors governing the actual availability of off-site resources include, of course, inclement weather, traffic congestion, power and communication failures, and the simultaneous occurrence of local and regional multiemergencies. Emergency response planning for an industrial facility that does not take these possible factors into account cannot be considered realistic. To ensure realistic planning, any facility is well advised to include a worst-case scenario among the various response scenarios to be addressed by the plan.
Location of Data/Information
Data and information drive emergency response. Put another way, emergency response conducted in the absence of data and information is simply well-intended guesswork that will most likely result in significant loss of human life. During an emergency, the first duty of facility management is to provide appropriate and precise data and information to responders. Planning for an emergency therefore requires concentrated effort to ensure that needed data and information will be immediately available to responders, regardless of circumstance. Section 5 of the Table of Contents depicted in Table 3.1 focuses on data and information most pertinent to plant layout, contents, and physical environs that must be used by incident commanders to choose among alternative strategies. Much of this information is typically included in various formats the appendices to the written emergency response plan--different formats being used to meet different needs. During the planning phase, careful attention must be given to the following questions: 1. Is provision made for locating the information where it can be immediately and safely retrieved during even the worst-case scenario for an actual emergency? [Note: it may be necessary to provide for alternative locations, and for specially designed storage areas to protect contents from loss or injury due to the emergency.] 2. Are data and information up to date? [Note: special effort must be given to ensuring that data and information regarding structural features of the facility and the location of specific types of hazards (e.g., electrical, chemical) are accurate.] 3. Are data and information in a format that is immediately usable for responders? [Note: this requires previous coordination and liaison with
Contents of Emergency Response Plan
67
incident commanders. Format, here, refers not only to the organization of the data and information, but also to the physical medium containing the information. For example, floppy disks are not likely to be appropriate in the midst of an actual emergency; neither are hard copy materials that, under heavy rain, will quickly become tissue paper or, in the case of maps and diagrams, varicolored smears of water-soluble multicolor inks.] Assessment of Hazards
Just as data and information drive the actual emergency response, so does the assessment of hazards (Table 3.2) drive the entire process of planning for emergency response. If the assessment of hazards is inadequate, the emergency response plan is also inadequate, regardless of any apparent sophistication of the plan. Minimal criteria for evaluating the assessment of hazards include: I. Comprehensiveness of Assessment
9 Is there consideration of not only hazardous stock materials, but also by-products (i.e., materials produced as intermediaries of operational processes) and combustion products (i.e., vapors, fumes, gases, mists, and particles produced as a result of burning stock materials or by-products) ? 9 Is there consideration of not only the hazards associated with chemicals and other materials (biological) that may present risk to employees and/or the surrounding public and environment, but also those hazards (e.g., structural, mechanical, electrical, cryogenic) that may present risk to emergency responders? 9 Is there consideration of hazards associated with off-site as well as on-site operations of the facility? 9 Is there consideration of hazards and risks to employees and incident responders that may emanate from other neighboring facilities or sources? 2. Application of Assessment 9 How are hazards related to on- and off-site target human populations? 9 How are hazards related to on- and off-site target environmental resources? 9 What alternative risk management practices (e.g., administrative, engineering, personal protective clothing and/or equipment) are
68
3 The Emergency Response Plan
TABLE 3.2 Important Principles for the Guidance of Hazard Identification and Assessment (Adapted from Organization for Economic Cooperation and Development, 1992: Guiding Principles for Chemical Accident Prevention, Preparedness and Response, Environmental Monograph No. 5 I)
Hazard Identification And Assessment When planning, designing and modifying installations and processes, management should ensure that critical examination techniques such as hazard analysis, hazard and operability studies, and fault tree and event tree analysis are utilized in order that hazards are identified and ranked as early as possible at the various stages of the project and the most suitable means of eliminating or reducing the hazards are instituted. The nature and extent of the consequences which could result from each significant hazard and their likelihood should also be assessed, using techniques such as consequence analysis to ascertain the potential for harm. Reducing either the hazard or its probability of occurrence reduces the risk and increases the inherent safety of the design. For existing installations which have not been subject to critical safety examinations, the appropriate hazard studies should be carried out in retrospect. The management of hazardous installations should collate all safety-related information on the process and associated equipment concerning, for example, design, operation, maintenance and foreseeable emergencies. Safety measures should be incorporated at the earliest conceptual and engineering design stages of an installation, to enhance the intrinsic safety of the installation wherever practicable. In designing new installations and significant modifications to existing installations, industry should use the relevant, most up-to-date international standards, codes or practice and guidance established by public authorities, enterprises, industry and professional associations, and other bodies in order to achieve a high level of safety. Existing installations should be assessed to determine whether they meet these standards, codes and guidance. Appropriate improvements should be carried out as soon as practical. The design of a hazardous installation should integrate the appropriate equipment, facilities and engineering procedures that would reduce the risk from hazards as far as is reasonable the practicable (i.e., all measures to reduce the risk should be taken until the additional expense would be considered far to exceed the resulting increase in safety). Processes should be designed to contain, control and minimize the quantity of hazardous intermediate substances to the extent that this would increase safety. Where this is not possible, the quantity of hazardous intermediates produced should be reduced to that required for use in the next stage of production so that quantities held in storage are kept to a minimum. 10. Systems should be designed so that individual component failures will not create unsafe process conditions and/or will be capable of accommodating possible human errors. continues
69
Contents of Emergency Response Plan TABLE 3.2--continued
Hazard Identification and Assessment (continued...) 11. Although emphasis should be on inherent safety in design, consideration should be given to the need for "add-on" protective systems, thereby assuring safety through mitigation measures. 12. In the design phase, management should ensure there is adequate consideration of the site layout as guided by overall safety goals. Particular regard should be given to: the establishing of safe separation distances to minimize any "domino effects"; the location of hazardous processes and substances relative t the location of critical safety-related equipment and instruments; and the local community and environment. 13. Relevant personnel who will be involved in the operation of a hazardous installation should also be involved in the planning, design and construction phases of the installation. Employees, and their representatives, should participate in decisions concerning the design of their workplace, and should be given the opportunity to provide input in the design, application and improvement of equipment in order to utilize employee "knowhow" and experience. 14. The management of a hazardous installation should pay particular attention to quality assurance during the construction phase of the project. 15. Safety checks should also be carried out at the commissioning and startup phases of a project to ensure that the design intent has been completely fulfilled. Functional tests should be carried out for all components, controls and safety devices critical to the safety of the installation. 16. An enterprise should purchase equipment only from reputable suppliers, and should formally inspect equipment to ensure that it conforms to design specifications and safety requirements before being put into use. 17. In the construction of a hazardous installation, an enterprise should do business with only those contractors who are able to satisfy the enterprise that their services will be carried out in compliance with all applicable laws and regulations, as well as in compliance with relevant safety standards and policies of the enterprise, so as not to increase the risk of an accident involving hazardous substances. Contractors should work to the standards set by the management of the installation and, to the extent appropriate, under the direct surveillance of management.
considered and evaluated with respect to controlling what sources of hazards ? Are hazards prioritized with respect to type of potential emergency incident (e.g., fire, explosion, flood, terrorism, earthquake) In any well-managed facility, hazard assessment is an integral component of a facility-wide vulnerability analysis, which is a methodical attempt to integrate information on (a) types of potential emergency, (b) likely
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Type Of Emergency
High Low
High
s4
Low
Weak
s4
* Plan to minimize Total FIGURE 3.5 Vulnerability analysis chart (adapted from Federal Emergency Management Agency (FEMA). Emergency Management Guide for Business & Industry [FEMA electronic reference library]).
impacts and probability of occurrence of each type, and (c) resources available for use in an actual emergency response (Fig. 3.5).
General Procedures
Because prevention must be the first objective of any emergency response planning, particular attention must be given to specific managerial methods and techniques as well as early warning procedures and devices that can decrease the probability of the occurrence of or minimize the magnitude of an incident. Both on- and off-site audits of facility operations can be an effective means of identifying and correcting situations that, if left untended, will result in or exacerbate an actual emergency. Consideration should be given to implementing a variety of audits, each having its own focus, including: 9 Compliance with specific regulations (e.g., hazardous waste, laboratory chemicals; hot work permits) 9 General housekeeping 9 Plant access and egress 9 Receiving, handling, storage, and disposal of chemicals 9 Tank and reactor maintenance 9 Flood prevention procedures 9 Plant and property security measures
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71
9 In-plant signing and labeling of hazardous areas and materials 9 Employee on-the-job behavior
Audits should be carried out by persons having full corporate authority to implement appropriate corrections immediately. The results of all audits, including findings and corrections, should be fully documented and specifically used to review and, as necessary, amend company policy statements, written protocols and procedures, and employee job descriptions, as well as implement personnel actions. General facility procedures (e.g., chain of command, employee information and training programs, purchase and on-site monitoring of contractor services, response to system alarms, operations monitoring) should all be reviewed on a regular basis and, as appropriate, revised to ensure consistency with emergency response objectives and plans. N o t i f i c a t i o n Procedures
Notification procedures are inclusive of all procedures designed to inform all responsible persons of the event of a potential or actual incident, and to provide those persons with information required for their proper performance of emergency-related functions. In the event of an actual emergency, notification also implies the activation of the facility evacuation signal. Even where specific notification procedures are successfully implemented, all too often too little consideration is given to the precise information to be conveyed to the person or organization notified. After all, in an emergency, fear, panic and confusion may result in people giving garbled messages. It is therefore strongly recommended that the emergency planning team compose specific formats (and, as appropriate, prewritten texts) to be used by notifying parties. Another major problem typically encountered in actual emergencies is that the devices (alarms, telephones, automatic electronic alarm and notification devices) relied upon to effect communication become inoperative (e.g., due to power outage, overload, and/or interference). Alternative backup means are therefore necessary. Finally, because many communication devices and systems devoted entirely to notification of responsible persons and organizations during an emergency typically are infrequently used, regularly scheduled testing and maintenance of these devices and systems is an absolute requirement. Evacuation Procedures
While many people tend to view evacuation as a rather elementary procedure, it is one that, if not planned and accomplished correctly, can lead
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3 The Emergency Response Plan
to even more deaths and injury than those resulting from the primary source of an emergency. This is because, during an evacuation, evacuating personnel are subject not only to risk due to the emergency itself(e.g., fire and smoke), but also to risks due to panic and hysteria (e.g., stampeding) and to personal stress (e.g., heart attack) and to risks that arise from the physical features and encumbrances associated with plant design and normal operations (e.g., narrow, steep stairways; barriers to or temporary blocking of egress by work in progress or work-related supplies). It is typically not sufficient to rely upon a single mode (e.g., sound, flashing light) of evacuation alarm. For example, an audible alarm may not be heard in more isolated areas of the facility (e.g., toilets, storage areas); certainly, no audible alarm, regardless of volume or placement, can give warning to a deaf employee. Primary and secondary routes of evacuation, which are clearly marked and identifiable at all times and in all potential circumstances (e.g., heavy smoke), are absolute minimum requirements; depending upon facility layout, as well as specific disabilities of personnel, additional routes (e.g., incorporating ramps, guiding handrails) may be necessary. While it may not be possible to monitor evacuating personnel for signs and symptoms of exposure (e.g., chemical exposure, burns) or of personal stress (hyperventilation, heart attack, broken limb, cuts), concentrated effort must be made to identify personnel who may require immediate medical attention. Alternative assembly points must be managed by personnel specifically designated to ensure (a) on-going communication with incident command (e.g., regarding movement of personnel to avoid interference with emergency vehicles; to minimize further risk due to the emergency), (b) proper accounting of assembled personnel, (c) identifying need of evacuees for decontamination, first aid, and/or other medical treatment, and (d) assignment of evacuees to other protected on- and off-site facilities for temporary shelter and housing, food and water, sanitary facilities. Finally, evacuated personnel must be managed effectively to ensure proper compliance with corporate postevacuation procedures, including procedures regarding the control of personal vehicles, medical consultation and follow-up, notification of employee families, and return to normalcy. Containment Procedures
Emergency containment is a key mitigative measure that may, in fact, prevent a minor spill (e.g., of a flammable material) from becoming a major incident (e.g., facility fire); containment may also be necessary during a fullfledged emergency response, as when contaminated firefighting runoff water
Contents of Emergency Response Plan
73
must be contained on-site to protect downstream environmental resources (surface and groundwater resources, soil) from subsequent contamination. All facility personnel should be trained in the proper use of containment materials. However, it is vital that facility personnel understand that they must use these materials only if they can do so without undue risk to themselves. Facility and community responders must be provided with appropriate training and protective clothing and equipment to implement containment measures with appropriate control of attendant risks. In addition to the use of containment materials, emergency planning must take into account the proper disposal of contaminated containment materials, as well of the hazardous chemicals contained by those materials.
Special Procedures Special procedures are those procedures implemented in response to specifically designated hazards and risks (e.g., fire/explosion, flood, storm, toxic gas release). Such procedures may be developed for implementation by different levels of personnel (e.g., general employees, facility first responders, facility and community-based specialized teams), with due regard for different levels of skill, personal protective clothing, and equipment. While the text of a written emergency response plan contains all information relevant to special procedures, it is recommended that basic procedures also be reduced to simple, stepwise directives that can easily be reduced to small placards, signs, or poster-boards, or even to wallet-size cards. This approach will help to ensure that these procedures are readily available to personnel as needed~being either in their personal possession (as with wallet-size cards) or easily observable as appropriately located signs or posters.
Equipment Shutdown The designation of specific equipment and production processes to be shut down during emergency response and procedures and protocols for effecting shutdown should be done only in close liaison with potential responding authorities and facility engineers. As a preventive action, shutdown should be implemented only by designated employees who are fully trained as to the precise circumstances that require shutdown. This will prevent actions that may inadvertently turn a minor, manageable accident (e.g., a minor spill of flammable liquid) into a major incident, as when the electric arc produced by nonexplosion proof light switch serves as a source of ignition to an explosive room atmosphere.
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3 The Emergency Response Plan
In no circumstance should any facility officer or employee actually undertake to shut down equipment or processes during an actual emergency except by the express order to do so from the incident commander. This approach will ensure that shutdown does not interfere with the proper functioning of protective devices or systems or of emergency response equipment.
Return to Normal Operations
Once the emergency is terminated, all responsibilities assumed by community emergency response services cease. It is therefore solely the responsibility of facility owners and managers to determine that the facility is fit to return to normal operations. There is often such a single-minded determination of facility owners and managers to resume operations as quickly as possible that they overlook potential consequences of both the emergency and the response effort that could result in not only additional risk to employees, but also long-term financial and legal risk to themselves. Before returning the facility to normal operations, owners and managers, in coordination with facility engineers and external consultants, should therefore evaluate the following potential conditions: 1. The facility is structurally unsound as a direct consequence of the emergency. 2. The facility is contaminated with hazardous stock chemicals and/ or by-products, which were released and/or produced during the emergency. 3. Essential operational alarms and monitoring systems are nonfunctional or are in need of testing and adjustment. 4. Emergency containment and other incident response materials and supplies are depleted as a result of previous response activities. 5. On-site emergency equipment is in need of repair and/or decontamination as a result of previous response activities. 6. There are hazardous materials derived from the previous emergency which remain on-site and which must be properly disposed. 7. Personnel are traumatized by the previous emergency. The basic rule governing return to normalcy is that it can be attempted only after full assurance is gained that (a) the facility presents no unmanaged risks to employees, and (b) all warning, alarm systems, and emergency resources (including equipment and supplies) are fully replenished or replaced and functionally on-line.
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75
Training All provisions and procedures included in an emergency response plan must be considered as defining specific needs for personnel training. In no circumstance may the simple presentation of training programs and information to employees be construed as sufficient. The object of emergency response training is the actual behavior of personnel. Because an emergency response plan assigns different responsibilities to different personnel and presumes the availability of diverse skills, emergency response training should be designed to meet the different skill performance levels and informational needs of employees~and training, retraining, and practice must be stubbornly pursued to achieve and maintain specified job performance standards. Joint-training exercises involving both on-site personnel and community emergency services, including simulated emergencies (e.g., table-top exercises, field exercises) should be implemented following a regular schedule. Particular attention should be given to using external experts and professional response services to assess and evaluate the practical effectiveness of all on-site training.
Documentation The importance of documenting all aspects of emergency planning and response cannot be overemphasized because documentation is the primary (and often the only) means of adequately addressing the following issues and needs: 1. Potential regulatory and other legal proceedings related to regulatory compliance or other legal standards (e.g., Common Law doctrine of negligence) 2. On-going evaluation and revision of emergency response plans on the basis of actual experience with emergencies 3. Medical assessment of long-term employee exposures to hazardous chemicals and materials 4. On-going improvement of in-plant safety provisions and procedures on the basis of regularly conducted audits 5. On-going assessment evaluation of the effectiveness of emergencyrelated personnel training All documentation (whether printed or electronic) should be maintained in an on-site "fail-safe" storage area, with duplicates regularly updated and safely warehoused in at least one off-site facility.
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3 The
EmergencyResponsePlan
J Locationof Buildings ! ElectricalSubstations ] HazardousMaterials
JUtilityShutoffs
1 WaterHydrantsI [WaterMainValves~ I GasMainValves~ ! GasLines J i ElectricalCutoffs~ StormDrains J SewerLines /
FloorPlans [ Exits ] Stairways 1 EscapeRoutes ] [ RestrictedArea,, I 1 High-ValueItems I l Alarms 1 StorageTanks,, ,J
FIGURE 3.6 Examplesof types of maps and other graphics showing location of key facility components which should be included in an emergencyresponse plan.
Appendices Appendices typically contain information required for special purposes. As shown in Fig. 3.6, much of this information pertains to the location of specific hazards and other items of particular importance to emergency response teams (e.g., chemical inventories, floor plans). However, appendices are also often used to compile specific procedures, determinations (e.g., plant vulnerability analysis), and lists of equipment and supplies (e.g., spill containment supplies, first aid supplies). The information contained in appendices should be in a format that facilitates rapid access to the information as well as immediate use. In close liaison with community emergency response services, facility management should determine which of this information should be regularly disseminated among the various services and/or included in lockout boxes and other structures that guarantee responder access as needed.
IMPLEMENTATION Given the great amount of careful effort necessary to develop a comprehensive emergency response plan, it is not surprising that, once compiled,
77
Implementation
TABLE 3.3 Important Principles Regarding the Development and Implementation of Safety Policy in Industry (Adapted from Organization for Economic Cooperation and Development, 1992: Guiding Principles for Chemical Accident Prevention, Preparedness and Response, Environmental Monograph No. 51)
Establishment of Safety Policy by Industry 1. Management of hazardous installation has the primary responsibility for preventing accidents involving hazardous substances, and for developing the means to do so. 2.
Effective overall management of hazardous installations necessarily includes effective management of safety; there is a clear correlation been safely run installations and wellmanaged operations. Therefore, safety should be an integral part of the business activities of the enterprise, and adequate resources should be made available for taking the necessary measures to prevent accidents and to pay for the consequences of any accidents which do occur.
3. All installations in an enterprise should aim to reach the ultimate goal of "zero incident," and resources must be targeted towards this goal. 4.
Management should not become complacent if there have not been any accidents at an installation over a period of time; continuous efforts are needed to maintain safety.
5.
Each enterprise should establish a corporate safety culture. Each enterprise should have a clear and meaningful statement of its Safety Policy, agreed, promulgated and applied at the highest levels of the enterprise, reflecting the corporate safety culture and incorporating the "zero incident" goal as well as the safety objectives established by public authorities. The development and implementation by an enterprise of policies and practices relating to accident prevention and preparedness should be coordinated and integrated with its activities relating to occupational safety, health and environmental protection as part of the enterprise's total risk management program.
8. The responsibility for day-to-day management of safety should be in the hands of line management at individual installations. All employees have a continuing role and responsibility in the prevention of accidents by carrying out their jobs in a safe manner, and by contributing actively to the development and implementation of safety policies and practices. Employees at all levels, including manager, should be motivated and educated to recognize safety as a top priority and its continuing improvement as a main corporate aim. 10. Producers of hazardous substances have a responsibility to promote the safe management of substances they produce throughout the total life cycle of the substances, from their design through production and use to their final disposal or elimination, consistent with the principle of "product stewardship." Such producers should make special efforts to help prevent accidents during the handling and use of a hazardous substance by downstream users. continues
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] The Emergency Response Plan
TABLE 3.3--continued
Establishment of Safety Policy by Industry (continued...) 11. Enterprises selling hazardous substances should actively try to determine whether their customers have adequate facilities and know-how to handle the substances (including, as appropriate, processing, use and disposal of the substances). If such determination cannot be achieved, judgment has to be exercised to decide whether to accept such customers. If customers are found to be incapable of safely handling the hazardous substances, the seller of the substances should assist the customer in obtaining this capability or else not accept such customers. 12. Smaller enterprises with limited resources should examine the need for assistance on safety matters from external consultants, professional trade associations and public authorities as well as from suppliers. Suppliers of hazardous substances should be supportive by ensuring that people are available to provide advice in order to achieve an appropriate level of safety. 13. Larger enterprises and/or trade associations should offer assistance to small and medium-sized companies in meeting safety objectives. 14. Enterprises and trade associations should take action strongly to encourage enterprises which act less responsibly to meet the appropriate safety objectives.
the plan tends to become a "shrine" to that effortma suitably jacketed (usually, in a three-ringed binder), thick compendium of multicolored flowcharts, diagrams, and closely printed text. The problem, of course, is that such a tome is hardly a practical tool. It often ends up, as with so many other bulky manuscripts, entombed on a dusty bookshelf--supposedly to be retrieved and consulted in the event of an actual emergency. Certainly it is necessary to maintain a complete and detailed master copy of the emergency response plan, but the implementation of that plan requires that it serve primarily as the source of practical training materials, policies, and directives that, properly formatted, are better suited than a massive book to transforming a plan of action into real behavior. In an emergency, whether potential or real, one must a c t . . , not read! Upon completion of working plan (which must always be subject to revision), the tasks that remain are therefore even more demanding than those performed during the development of the plan precisely because the goal of implementation is to change human behaviormat best, a thoroughly difficult undertaking that demands persistent training and practice, followed by yet more training and more practice. Whether by an industrial facility or a public agency, the implementation of any emergency plan ultimately depends upon the absolute commitment of the highest executive authorities to institutional health and safety objectives and policies (Tables 3.3 and 3.4). Without such executive and
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Implementation
TABLE 3.4 Important Principles Regarding the Development and Implementation of Safety Policy in Public Agencies (Adapted from Organization for Economic Cooperation and Development, 1992: Guiding Principles for Chemical Accident Prevention, Preparedness and Response, Environmental Monograph No. 5 I)
Establishment of Safety Objectives & a Control Framework by Public Authorities Public authorities should ensure that appropriate safety objectives are established as part of a long-term strategy. Public authorities should develop a clear and coherent control framework covering all aspects of accident prevention. Public authorities should have available appropriate staff to carry out their role and responsibilities in the prevention of accidents, and should ensure that the staff is adequately educated and trained. A coordinating mechanism should be established where more than one competent public authority exist, in order to minimize overlapping and conflicting requirements from various public authorities. In establishing safety objectives, as well as the control framework, public authorities should consult with representatives of the other stakeholders, including: relevant public authorities, industry, professional and trade associations, independent experts, trade unions, interest groups, and the public. Public authorities should establish the criteria for identifying those hazardous installations considered to have the potential to cause major accidents. The requirements established by public authorities should be applied fairly and uniformly to ensure that enterprises of all sizes and types, whether national or foreign, are required to meet the same overall safety objectives. The control framework should allow flexibility in the methods used to meet the safety objectives and requirements. The requirements and guidance established by public authorities should stimulate innovation and promote the use of improved safety technology and safety practices. The control requirements should be considered minimum; industry should be encouraged to achieve a higher level of safety than would be achieved by adherence to established standards and guidance alone. 10. The requirements and guidance should be reviewed periodically and, where necessary, amended within a reasonable time to take into account technical progress, additional knowledge and international developments. 11. The control framework should include provisions for the enforcement of requirements, and adequate resources should be available to the public authorities for monitoring and enforcement activities. continues
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3 The Emergency Response Plan
TABLE 3.4--continued
Establishment of Safety Objectives & a Control Framework by Public Authorities
(Continued...)
12. Public authorities should establish procedures for the notification and reporting to them of certain specified categories of hazardous installations. 13. Public authorities should also establish a system for the submission of detailed information for certain categories of hazardous installations. 14. Public authorities should consider which installations, or modifications to installations, are so potentially hazardous that the installations should not be allowed to operate without the prior and continuing approval of identified public authorities. In these cases, a form of licensing control could be utilized which would require management to submit full details of all relevant aspects of its projected activity to the authority in advance of siting and startup, and periodically thereafter. There should be an opportunity for public input into these licensing decisions. 15. Public authorities should establish a requirement for the reporting of certain incidents by the management of hazardous installations. 16. In order to assist industry in importing safety at hazardous installations, public authorities should consider whether to undertake such additional activities as: provision of technical assistance, promotion of training programs, encouragement of research, and fostering of public awareness. 17. Public authorities in neighboring countries should exchange information and establish a dialogue concerning installations which, in the event of an accident, have the potential of causing transfrontier damage. 18. National and, where appropriate, regional public authorities should cooperate internationally to improve prevention of accidents involving hazardous substances as well as to improve emergency preparedness and response. 19. Cooperation should be promoted in the preparation of guidance documents across countries, industry groups and international organizations. 20. A worldwide network should be established to promote the sharing among enterprises and countries of information related to the prevention of, preparedness for, and response to accidents involving hazardous substances. This is particularly important as a means of providing access to information for those with less capability with respect to the safe handling of chemicals. 21. Trade associations, local chambers of commerce and other organizations can be a useful means of disseminating chemical accident prevention information to smaller enterprises which might be unaware of the existence of such information.
Implementation
81
administrative commitment, there is little likelihood that adequate resources (including time, money, and personnel) will be made available to ensure effective implementation by such means as: 1. Using the overall emergency response plan, 9 Define specific responder tasks (taking into account primary, secondary, and backup responsibilities of all members of response team), and 9 Identify specific needs for information, types of skills, and necessary skill levels for individuals having responsibility for each responder task. 2. Develop appropriate training materials, informational packages, and summary action directives/protocols for each responder task. 3. Conduct training of personnel on the basis of task responsibilities, using combinations of various techniques, including (but not limited to): 9 Lectures 9 Demonstrations 9 Group discussions 9 Problem-solving workshops 9 Table-top exercises 9 Field exercises 9 Critique of simulations 9 Role-playing sessions 9 Multiagency/multifacility exercises 4. Evaluate training on the basis of informational and behavioral objectives as defined by required skill levels (using external as well as internal evaluators). 5. On the basis of training, revise (as necessary) the emergency response plan and/or training methods and techniques. 6. Institute facility/agency-wide practice drills (announced and unannounced), and schedule drills to occur over a range of weather conditions and work-shift schedules. 7. Practice, train, drill again!
COMMAND
INTRODUCTION
Despite the ideal availability of tested and ready resources, the highest skill proficiencies of personnel, and the most favorable circumstances of time and weather, an emergency response effort can only be as effective as its command structure is sound. The authoritative control of actions performed to minimize the multifaceted threat of any emergency depends not only upon "the person-incharge" but also upon a practiced and disciplined chain-of-command and a support system that guarantees the timely flow and integration of information and resources into a coordinated effort. Leadership is not to be measured in terms of some vaporous, innate capacity of the individual but, rather, in the objective evidence of smoothly coordinated, flexible, self-correcting, purposeful, and effective actions. Whether there is advance notice or not, and regardless of its initial nature, any emergency may rapidly expand in extent and complexity, with high risk not only for responding personnel but also for the surrounding community. Moreover, given the social and political complexity of contemporary society, any emergency is highly likely to involve the response services and diverse jurisdictional authorities and responsibilities of a multitude of local, state, and/or national governmental agencies. The command structure of effective emergency response, therefore, must (a) be flexible enough to control emergencies of any type or size, including routine and major emergencies, and (b) provide for the efficient and effective integration of diverse response services and responsible authorities. I N C I D E N T C O M M A N D SYSTEM
The Incident Command System (ICS) is a single standard incident management system, originally developed (1980) in California in response 82
Incident Command System
83
to the threat of wildland fires, that has rapidly become the command system used not only by all U.S. Federal agencies having wildland fire management responsibilities, but also by a large number of U.S. Federal and state agencies as well as operational agencies of other nations that have jurisdictional authority over various types of emergencies, including: fires; oil and hazardous chemical releases; earthquakes, storms and other natural disasters; and terrorism. The basic organization if ICS (Fig. 4.1)includes five key functional groups referred to as Sections:
I. Command In incidents involving responders from a single jurisdictional authority (i.e., a single-jurisdiction incident), the Incident Commander (IC) is the individual who has final responsibility for the management of response
Incident
Command lnformation
]
Safety
~_,~
I ._ O p e r a t i o n s
~- StagingArea(s)
Branches
!
I L
Planning
Resources Unit
---
!
. . ogmtms Service Branch
Situation Unit
tT;;;:~
Demobilization
/ t
Documentation Unit
L_ FoodUnit
Strike Teams
[
Finance& ] ~~ministration I--"
/
Time Unit
L Communications!"" ProcurementUnit
I
Divisions & Groups
LiaisOn I
Unit
--
~176 I__ co.,..,,o.. 'ca'On" V ~ On. I . . , CostUnit
Support Branch
t SupplyUnit FacilitiesUnit GroundSupportUnit FIGURE 4.1 Overview of structure of incident command system (adapted from National Interagency Fire Center, 1994: Incident Command SystemNational Training Curriculum, Module 3 [NFES No. 2443]).
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4 Command
More senior or experienced person on-scene elects or is designated by higher authority to assume command of escalating incident
Possible changes in personnel required ~ over different ~ operational periods of on-going incident ~
I
!
Circumstances determine that less senior but more qualified person should assume command
t4 Less senior or qualified person given command of incident that is under < control or moving toward demobilization
FIGURE 4.2
Circumstancestypically involvingtransfer of incident command.
activity. Depending upon various circumstances (Fig. 4.2), Incident Command may be transferred from one individual to another. In incidents involving more than one agency (i.e., a muhijurisdiction or multiagency incident), the command function is assumed by the Unified Command (UC), which may consist of a number of different Federal and state officials as well as other authorities (e.g., emergency coordinator(s) from the industrial facility(ies) primarily involved in the incident). However, whether the command function is assumed by the IC or the UC, there is always one person who has final responsibility for the overall response effort.
2. Operations Operations is responsible for directing and coordinating all tactical operations required by the response effort. At the time of an initial response, operations consists essentially of the first responders, who report directly to the IC; however, depending upon the developing incident, operations may expand or contract, becoming a separate Operations Section under an Operations Section Chief if the incident significantly expands in geographic extent and/or complexity.
Incident Command System
85
3. Planning Depending on need, the IC may establish a Planning Section under a Planning Section Chief, having responsibility for preparing and maintaining specific plans (e.g., Incident Action Plan; Demobilization Plan) and status reports (resources committed to the response; available backup resources) required by command and operations. Of special importance is the need to anticipate problems and situations that may occur as the incident expands. 4. Logistics Logistics is inclusive of all services performed to support personnel and other resources (e.g., vehicles) assigned to response activities. As established by the IC, the Logistics Section (under the Logistics Section Chief) provides for communications, medical support to responders, food for responders, supply (personnel, equipment, and other needed supplies), facilities, and ground support (i.e., transportation vehicles, fuel for vehicles). 5. Finance/Administration Until such a time as a Finance/Administration Section may be activated by the IC, the IC is responsible for all finance-related activities. Upon activation, this section is responsible for (a) monitoring all costs related to the incident, and (b) procuring and administering any contracts required to implement the response effort. Perhaps the most useful way to appreciate the overall structure oflCS is to compare the basic functions of ICS to the basic needs of any objectiveoriented team effort, whether related to incident response or not. For example, any effort that depends upon coordination among team members to achieve specific objectives requires the following: 9 Someone with clear authority and responsibility for making key decisions and who gives specific direction to the overall effort. This is the ICS Command function. 9 Personnel with the clear responsibility for carrying out the decisions made by responsible authority. This is the ICS Operations function. 9 Personnel who can provide on-going information on actual and potential changes in circumstances and provide alternative plans for consideration by responsible decision-makers. This is the ICS Planning function. 9 Personnel who can provide the basic tools (e.g., personnel, materials, equipment, supplies) needed to accomplish specific tasks. This is the ICS Logistics function.
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4 Command
Incident Commander The Incident Commander is the overall manager of the incident. In single-jurisdiction incidents, the command is carried out by a single Incident Commander. In multijurisdiction incidents, command may involve a number of individuals having specific jurisdictional authority and responsibility; however, even in multi-jurisdiction incidents, there is always one person who is ultimately in charge. Major Responsibilities:
......
Assess the situation and/or obtain a briefing from the prior Incident Commander Determine incident objectives and strategy Establish immediate priorities Establish an Incident Command Post Establish an appropriate organization Ensure planning meetings are scheduled as required Approve and authorize the implementation of an Incident Action Plan Ensure that adequate safety measures are in place Coordinate activity for all Command and General Staff Coordinate with key people and officials Approve requests for additional resources or for the release of resources Keep agency administrator informed of incident status Approve the use of trainees, volunteers, and auxiliary personnel Authorize release of information to the news media Order the demobilization of the incident when appropriate
Operations Section Chief The Operations Section Chief is responsible for managing all tactical operations at an incident. The Incident Action Plan provides the necessary guidance. The need to expand the Operations Sections is generally dictated by the number of tactical resources involved and is influenced by span of control considerations. Major Responsibilities: 9 Manage tactical operations 9 Ensure interaction is taking place with other agencies 9 Assist in the development of the operations portion of the Incident Action Plan 9 Supervise the execution of the operations portion of the Incident Action Plan 9 Maintain close contact with subordinate positions 9 Ensure safe Tactical operations 9 Request additional resources to support tactical operations 9 Approve release of resources from active assignments (not from the incident Itself) 9 Make or approve expedient changes to the operations portion of the Incident Action Plan 9 Maintain close communication with the Incident Commander
FIGURE 4.3 Major responsibilities of incident commander and section chiefs in ICS (adapted from National Interagency Fire Center, 1994- Incident Command System National Training Curriculum, Module 12).
9 Personnel who can provide the financial and administrative tools needed to undertake and complete the effort. This is the ICS Finance Administration function.
87
Incident Command System
Planning Section Chief The Planning Section Chief is responsible for providing planning and status services for the incident. Under the direction of the Planning Section Chief, the Planning Section collects situation and resources status information, evaluates it, and processes the information for use in developing action plans. Dissemination of information can be in the form of the Incident Action Plan, formal briefings, or through map and status board displays. Major Responsibilities: Collect and manage all incident-relevant operational data Provide input to the Incident Commander and Operations Sections Chief for use in preparing the Incident Action Plan Supervise preparation of the Incident Action Plan Conduct and facilitate planning meetings Reassign personnel already on site to ICS organizational positions as needed and appropriate Establish information requirements and reporting schedules for Planning Section units Determine the need for specialized resources to support the incident response Assemble and disassemble task forces and strike teams not assigned to Operations Establish specialized data collection systems as necessary (e.g., weather) Assemble information on alternative strategies and contingency plans Provide periodic predictions on incident potential Report any significant changes in Incident status Compile and display incident status information Oversee preparation of the Demobilization Plan ,
Logistics Section Chief The Logistics Section Chief determines the need to activate or deactivate a subsidiary logistics unit (i.e., supply, facilities, ground support, communications, food, and medical units), ff a subsidiary unit is not activated, responsibility for that unit's duties remains with the Logistics Section Chief. Major Responsibilities: 9 9 9 9 9 9
Manage all incident logistics Provide logistical input to the IC in preparing the Incident Action Plan Brief subsidiaries as needed Identify anticipated and known incident service and support requirements Request additional resources as needed Review and provide input to the Communications Plan, Medical Plan and Traffic Plan 9 Supervise requests for additional resources 9 Oversee demobilization of Logistics Section FIGURE 4.3--continued
Among the various characteristics of the ICS, of special importance is its insistence on a clear delineation of key responsibilities among individuals, including not only those in charge of the major functional Sections (Fig. 4.3), but also those who manage the various subsidiary components activated, as needed, by Incident Command (Fig. 4.4).
88
4 Command
Finance/Administration
Section Chief
The Finance~Administration Section Chief is responsible for managing all financial aspects of an incident. Depending upon the incident, the Section Chief may activate any of four subsidiary units (i.e., time, procurement, compensation/claims, and cost units). Major Responsibilities: 9 Manage all financial aspects of an incident 9 Provide financial and cost analysis information as requested 9 Gather pertinent information from briefings with responsible agencies 9 Develop an operating plan for the Finance/Administration Section; fill supply and support needs 9 Determine need to set up and operate an incident commissary 9 Meet with assisting and cooperating agency representative as needed 9 Maintain daily contact with agency(s) administrative headquarters on financial/administrative matters 9 Ensure that all personnel time records are accurately completed and transmitted to home agencies, according to policy 9 Provide financial input to demobilization planning 9 Ensure that all obligation documents Initiated at the Incident are properly prepared and completed 9 Brief agency administrative personnel on all incident-related financial Issues needing attention or follow-up F I G U R E 4.3~continued
Another key characteristic of the ICS is, of course, its flexibility, much of which derives from its sub-Sectional organization.
Sub-Sectional Organization of Command A number of the responsibilities of the Incident Commander pertain to (a) the dissemination of information to news media and relevant governmental agencies, (b) the safety of response personnel, and (c) liaison between command and other agencies and organizations, including those that directly participate in the response effort (assisting agencies) and those (e.g., Red Cross) that may otherwise become involved in the incident (cooperating agencies). Depending on the nature and extent of the emergency, the IC may establish separate Command Staff officers to take over these duties, including: 9 Information Officer: While the Information Officer may designate assistants as necessary, there can be only one Information Officer per incident, even if the incident is a multijurisdictional or multiagency incident 9 Safety Officer: Only one Safety Officer can be designated per incident; as needed, the Safety Officer may appoint one or more assistants, who may represent different agencies or jurisdictions in a multijurisdiction or
89
Incident Command System
Incident Commander
Sector & Company Officers
~ Firefighters/ EMS Personnel
lncident Safety Officer
9 Is expected to make strategic decisions based on risk acceptance or avoidance 9 Decisions are incorporated in the selection of offensive or defensive operations, a major component of the strategic plan for the incident 9 Are expected to supervise tactical operations based on risk acceptance/avoidance in the situations they encounter within the areas they supervise 9 Determinations must be consistent with the direction provided by the incident commander 9 They must keep the incident commander informed of any situations they encounter that may have an impact on the strategic plan 9 Might be called on to make personal decisions about risk acceptance/avoidance when no officer is present, which must also be consistent with the strategic plan and with departmental policies 9 They also need to keep their officers informed of any significant information 9 Is the risk management consultant for emergency operations 9 The incident safety officer is an advisor to the incident commander and should provide an overview of the situation specifically directed toward identifying and evaluating safety concems
FIGURE 4.4 Roles and responsibilities in operational risk management (adapted from U.S. Fire Administration, 1995" Risk Management Practices in the Fire Service [FA-166]).
multiagency incident. Having the primary responsibility for the safety of response personnel, the Safety Officer must develop measures for assuring the safety of personnel during the implementation of tactical response operations; the Safety Officer may also assume emergency authority to stop unsafe actions or procedures if those actions or procedures are likely to result in imminent, life-threatening risk to response personnel. 9 Liaison Officer: Only one Liaison Officer may be designated per incident; as needed, the Liaison Officer may appoint one or more assistants, who may represent different agencies or jurisdictions in a multijurisdiction or multiagency incident. Agency representatives designated by assisting and cooperating agencies to work with the incident management team must report to the Liaison Officer.
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4 Command
Level
Primary Position
Support Position
Incident Command
Incident Commander
Deputy
Command Staff
Officer
Assistant
Section
Chief
Deputy
Branch
Director
Deputy
Division/Group
Supervisor
NA
Strike Team/ Task Force
Leader
NA
Unit
Leader
Manager
Single Resource
Use Unit Designation
NA
FIGURE 4.5 Primary support positions in the various components of an ICS organization (adapted from U.S. Fire Administration, 1995: Risk Management Practices in the Fire Service [FA-166]).
As shown in Fig. 4.5, ICS provides specific nomenclature for designating primary and support personnel having managerial responsibility and authority not only at the command levels, but at all levels of any ICS organization.
Sub-Sectional O r g a n i z a t i o n of O p e r a t i o n s
The IC may designate one or more Staging Areas where in-service resources (i.e., personnel and equipment that are available for service on 3-minute notice) can be safely located until they are assigned to a specific task.
Incident Command System
91
Each Staging Area is under the direct control of a Staging Area Manager, who reports to the IC or, if the Operations Section has been activated, to the Operations Section Chief. The Operations Section may be administratively subdivided on the basis of geographic or functional considerations. The Division is a specific geographic area defined relative to the incident and response effort. The IC may designate a number of Divisions simply to define the extent of the incident without activating individual Divisions. However, separate Division Supervisors should be designated whenever (a) resources (including personnel and equipment) assigned to any Division exceed the span of control (i.e., one-to-five), or (b) Divisions are not under the direct control of either the IC or Operations Section Chief. In some instances, the IC may opt to organize response operations not on the basis of geographically specific Divisions, but on the basis of functional groups, such as Search & Rescue Groups and Medical Groups. Such groups may be under the direct supervision of the IC or, as designated by the IC, of Group Supervisors. The IC may also opt to activate both Divisions and Groups, especially when one or more functional Groups (usually a specialized Group) must operate indifferent operational areas. In such cases, Division Supervisors and Group Supervisors are equal in rank; neither is subordinate to the other. While Branches are the largest operational units, they are typically not activated unless more than 5 Divisions or Groups are in place (i.e., on the basis of span of control considerations). However, depending on the nature and extent of the incident, the IC may activate an Air Operations Branch and designate an Air Operations Branch Director to coordinate the use of aircraft. In smaller incidents that nonetheless require the use of aircraft, aviation personnel report directly to the IC or, if activated, to the Operations Section Chief. As in the case of Divisions and Groups, Branches may be defined geographically, functionally, or on the basis of both geographical location and function. If activated, Branches are under the control of Branch Directors. The basic types of tactical resources of Operations are the Single Resource, Task Force, and Strike Team (Fig. 4.6). As combinations of two or more Single Resources, Task Forces and Strike Teams provide important advantages, including (a) more effective planning for the use of resources, (b) effective means for obtaining precisely what is needed for effective response, (c) reduction in radio traffic as compared to that necessary when using only Single Resources, (d) increased capacity to expand operations for large incidents without sacrificing span-of-control guidelines, and (e) enhanced control and accountability of individual resources.
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4 Command
Single Resources Single Resources are Individual pieces of equipment, or a crew of individuals, with an Identified work supervisor that can be used in a tactical application; usually the most common way of initially using resources at an Incident. Examples: .~ Police motorcycle unit
~ Firs engine company
,~ Medical team
Task Force A Task Force is any combination and number of single resources (within span of control limits) assembled for a particular tactical need. Task forces may be a mix of all different kinds of resources, be of the same kind but different types, or be several resources of one kind mixed with other resources. M u s t have: a leader; communication between resources and the leader, and from the leader to the next level supervisor; transportation (as required). Examples: Oil Spill Task Force (e.g., 5 berthing/food ships; 10 work boats; 1 tank barge) 9~ Search & Rescue Task Force (e.g., 1 helicopter; 1 alpine team; 1 medical tachniclan) 9~ Firs Task Force (e.g., 2 engines; 1 bulldozer; 2 hand crews)
Strike Team A Strike Team is a combination of any number of single resources (within span of control limits) of the same kind and same type. Must have: a leader; communication between resources and the leader; transportation (as required). Example:
.~ Fire Task Force (e.g., 5 Type I Engines, or 3 Type 2 Bulldozers)
FIGURE 4.6 General characteristics of ICS tactical resources (adapted from National Interagency Fire Center, 1994: Incident Command System National Training Curriculum, Module 4 [NFES No. 2445]).
Sub-Sectional Organization of Planning The management of all information relevant to an incident, including the collection, evaluation, processing, and dissemination of that information, often requires a wide range of technical specialists (e.g., flood control specialist, structural engineer, environmental impact specialist) who may be assigned to any one of the four Units of the Planning Section. Each Unit, under the direction of a Unit Leader, may be activated or deactivated by the Planning Section Chief on the basis of need. Unit Leaders, regardless of location in ICS organizations (i.e., whether in Planning, Logistics, or Finance/Administration) have the following common responsibilities:
Incident Command System
9 9 9 9 9 9 9 9 9
93
Obtain briefing from respective Section Chief Participate in incident planning meetings, as required Determine current status of unit activities Confirm dispatch and estimated time of arrival of staff and supplies Assign specific duties to and supervise staff Develop and implement accountability, safety, and security measures for personnel and resources Supervise demobilization of unit, including storage of supplies Provide Supply Unit Leader (in Logistics Sections) with a list of supplies to be replenished Maintain Unit records, including the Unit Log
The Resources Unit maintains the status of all assigned resources (both primary and support). This requires (a) controlling the on-site checkin of all resources (Fig. 4.7), (b) maintaining a system for continually monitoring the location and status of all response resources, and (c) maintaining a master list of all resources (including primary and support) assigned to the incident. The Situation Unit is responsible for collecting, processing, and organizing all information relevant to the on-going incident, including: 9 Deploying Field Observers to collect information on the field situation 9 Collecting weather information from weather services or through the efforts of an assigned meteorologist 9 Posting information (obtained from field observers) on maps and status boards The Documentation Unit is responsible for the maintenance of accurate, up-to-date files related to the incident. After the incident, such files are to be stored for legal, analytical, and historical purposes. The Demobilization Unit is responsible for developing the Incident Demobilization Plan, and for distributing the approved plan to appropriate on- and off-site elements of the incident response team.
Sub-Sectional Organization of Logistics With the exception of aviation support (which is handled by the Air Operations Branch of Operations), all incident support needs are provided by the Logistics Section, under the control of the Logistics Section Chief. The Logistic Section Chief may activate up to six units.
94
4 Command
Actions Prior to Departure Personnel to be notified of an incident assignment by established agency procedures 9 9 9 9
Know incident type and name(or designation), check-in location, reporting time, and means of travel Receive instructions regarding communications Know Resource Order Number or (if applicable) Request Number Know your unit's radio designation
C h e c k - i n at t h e I n c i d e n t Check-in officially logs you in at the incident and provides important basic information that will be used for status keeping and for release and demobilization. The check-in process and information supports the following activities:
Check-in only once. Check-in Recorders may be found at Incident Command Post, Base or Camp(s), Staging Areas, Helibase. You may also report direct to Division~Group Supervisors. If instructed to report directly to a tactical assignment, you should report in to the designated Division or Group Supervisor or to the Operations Section Chief or Incident Commander, depending upon the level of ICS activation. After release from tactical assignment, check-in at one of the above locations. R e s p o n s i b i l i t i e s at t h e I n c i d e n t After check-in, locate your incident point of contact and obtain your initial briefing. The information you receive in your briefing will be important for your own planning and for passing on accurate and up-to-date information to your subordinates.
After receiving your briefing and activating your assignment, give a similar briefing to any personnel assigned to you. Communications Discipline 9 All incident personnel must observe strict radio/telephone procedures. 9 Use clear text or plain English. Codes should be used in radio communications. 9 Limit radio and telephone traffic to essential information. Pre-plan what you are going to say. Incident Demobilization 9 Complete all work assignments. 9 Brief subordinates regarding demobilization. 9 Complete and file required forms and reports. 9 Follow incident and agency check-out procedures. ~; 9 Evaluate performance of subordinates prior to release from the incident. 9 Return any incident-issued communications equipment or other non-expendable supplies. 9 Report to assigned departure points on time or slightly ahead of schedule. 9 As appropriate, stay with your group until you arrive at your final designation. FIGURE 4.7 Guidelines for responders reporting to an incident (adapted from National Interagency Fire Center, 1994: Incident Command System National Training Curriculum, Module 6 [NFES No. 2450]).
Incident C o m m a n d System
95
Incident Command Post 9 Only one ICP per incident, even if incident is multi-jurisdictional 9 Incident communication center is often located with or adjacent to ICP 9 Incident Command function is carried out at the ICP 9 ICP may be located with other incident facilities, such as Incident Base 9 The planning function is normally done at the ICP 9 ICP should contain situation and resource status displays necessary for the incident, and other information necessary for planning 9 Agency representatives are normally located at the ICP
Staging Area(s) 9 Close to the location of tactical assignments (within 5 minutes) 9 Located out of any possible line of direct hazards due to the incident 9 To be relocated as necessary 9 Must have different access routes for incoming and outgoing resources 9 Large enough to accommodate available resources and also have room for growth 9 Must be clearly marked and have security controls 9 To be located to minimize environmental damage
Base 9 9 9 9 9 9
May or may not be established for a particular incident All primary services and support activity for the incident are usually located and performed at the Base Normally the location where all uncommitted resources are located Only one Base per incident In areas where major incidents occur frequently, Base locations usually predetermined and layouts are pre-planned Management control under Base Manager (Logistics Section)
Characteristics of ICS facilities (adapted from National Interagency Fire Center, 1994: Incident Command System National Training Curriculum, Module 4 [NFES No. 2445]).
F I G U R E 4.8
continues
1. The Supply Unit is responsible for ordering, receiving, processing, and storing all on- and off-site resources related to incident response, including tactical and support resources (e.g., personnel, equipment) and all expendable and nonexpendable support supplies. Supply also is responsible for the storage, disbursement, and servicing of all tools and portable nonexpendable equipment used in incident response. 2. The Facilities Unit is responsible for the set-up, maintenance, and demobilization of all incident support facilities (Fig. 4.8) except Staging Areas, Helibases, and Helispots, which are under the management control of Operations. As needed, the Facilities Unit also provides security services. 3. The Ground Support Unit has responsibility for (a) the maintenance, service, and fueling of all mobile equipment and vehicles (except aviation equipment, which falls under the management control of Operations), (b) the ground transportation of personnel, supplies, and equipment, and (c) the development of the Incident Traffic Plan. 4. The Communications Unit has responsibility for (a) developing plans for the use of communications equipment and facilities, (b) installing
96
4 Command
Camp(s) 9 9 9 9 9
Temporary locations within general incident area equipped to provide sleeping, food, water and sanitary services to incident personnel Not to be located at the Incident Base Very large incidents may require two or more camps located in strategic areas All functional unit activities performed at Base may also be performed at Camp(s) Management under designated Camp Manager
Helibase 9
9 9 9 9
Main location within general incident area for parking, fueling, maintenance, and loading of helicopters with personnel, equipment and supplies necessary for incident operations Often located at or near the incident Base; may also be located at nearby airport, or an another off-incident location Helibase designated by the name of the incident Large incident may have more that one Helibase Management under designated Helibase Manager
Helispot(s) 9
9 9 9
Temporary location(s) within the incident area where helicopters can safely land and take off Can be used to load or off-load personnel, equipment and supplies Management under designated on-the-ground Helispot Manager who reports to the Helibase Manager If an incident has no established air operations organization but does have one or more Helispots designated, the Helispot Managers report to the Operations Section Chief FIGURE
4.8~continued
and testing communications equipment, (c) supervision of the Incident Communications Center, and (d) the distribution and maintenance of communications equipment. Where an Incident Communications Center is established, the Incident Dispatcher is responsible for receiving and transmitting radio, telephone, fax, and computer messages, and for providing incident dispatch services. 5. The Food Unit is responsible for supplying food to all response personnel, whether on- or off-site. This responsibility requires careful coordination between Food, Supply, Ground, and Air Support Units. 6. The Medical Unit is responsible for medical services required only by response personnel; medical services for incident victims or the public are provided by the Operations Section. Sub-Sectional Organization of Finance/Administration Given the nature and extent of the emergency, it may not be necessary to activate the Finance/Administration Section. In such a case, a specific
Adaptation of ICS to Other Command Structures
97
function usually assigned to Finance/Administration may be assigned, instead, to the Planning Section. If activated, the Finance/Administration Section Chief may establish up to four units: 1. The Time Unit is responsible for (a) ensuring the accurate recording of daily personnel time, (b) compliance with specific policies of responding agencies regarding the recording of personnel time, and (c) managing commissary operations that might be activated at the incident site. 2. The Procurement Unit is responsible for (a) managing all financial matters related to vendor contracts, leases, and other fiscal agreements pertaining to incident response, and (b) maintaining all time records for the use of equipment during the incident. The Procurement Unit must coordinate closely with the Supply Unit (in Logistics Section) because procurement procedures of different agencies sometimes have different requirements. 3. The Compensation/Claims Unit is responsible for all matters related to compensation for injury and other legal claims involving property associated with or involved in the incident. 4. The Cost Unit (a) provides all incident cost analysis, (b)ensures the proper identification of all equipment and personnel requiring payment, (c) maintains written records of all cost-related data, (d) analyzes and prepares estimates of incident costs, and (e) maintains accurate records of incident costs.
A D A P T A T I O N OF ICS T O O T H E R COMMAND STRUCTURES
As discussed above, much of the flexibility of ICS derives from the various options available to the Incident Commander (and, subsequently, to appropriate incident response managers) regarding the activation of subsidiary components of the ICS management organization. These options are based on the assessment of the on-going developing nature and extent of the incident. Another aspect of the flexibility of ICS derives from the different modes of coordinating and directing incidence response on the basis of (a) multijurisdictional responsibilities, (b) the occurrence of two or more incidents in close proximity, and (c) multiagency and multijurisdictional responsibilities within an extended geographic region. Because of the importance that must be given in the United States to jurisdictional responsibilities of different agencies at federal, regional, state, and local levels, the ICS must be flexible enough to accommodate these differences without, at the same time, sacrificing efficiency and effectiveness. This is accomplished by extending and adapting ICS to meets the needs of
98
4 Command
Incident Command System
(ICS)
Unified Command
(UC)
The management system used to direct all operations at the incident scene. The Incident Commander (IC) is located at an Incident Command Post (ICP) at the incident scene.
An application of ICS used when there is more than one agency with incident jurisdiction. Agencies work together through their designated Incident Commanders at a single ICP to establish a common set of objectives and strategies and a single Incident Action Plan.
Area Command/ Unified Area Command AC/UAC
Established as necessary to provide command authority and coordination for two or more incidents in close proximity. Area Command works directly with Incident Commanders. Area Command becomes Unified Area Command when incidents are multi-jurisdictional. Area Command may be established at an EOC facility or at some location other than an ICP.
Multi-Agency Coordination Systems (MACS)
An activity or formal system used to coordinate resources and support between agencies or jurisdictions. A MAC Group functions with the MACS. MACS interact with agencies or jurisdictions, not with incidents. MACS are useful for regional situation. A MACS can be established at a jurisdiction EOC or at a separate facility.
Emergency Operations Center (EOC)
Also called Expanded Dispatch or Emergency Command and Control Centers. EOCs are used in varying ways at all levels of government and within private industry to provide coordination, direction, and control during emergencies. EOC facilities can be used to house Area Command and MACS activities as determined by agency or jurisdictional policy.
FIGURE 4.9 Comparison of alternative emergency management systems under ICS (adapted from National Interagency Fire Center, 1994: Incident Command System National Training Curriculum, Module 1 [NFES No. 2468]; Module 16 [NFES No. 2470]).
Adaptation of ICS to Other Command Structures
99
Guidelines: Unified Command and the Incident Command System 1. For the ICS/UC(Incident Command System/Unified Command) to be effective, the following elements should be in place well before an incident occurs: 9 The structure must be formalized in the planning stages and must be accepted by all parties concerned, 9 Specific functions and responsibilities must be well defined, 9 Individuals must be designated for each function and the reporting mechanisms defined and accepted, 9 The participating organizations must make a committed effort to respond as a team, 9 Area Contingency Plans (including facility/vessel response plans) must address training and ensure familiarity with ICS utilizing a Unified Command, and 9 Relationships to entities outside the ICS but relevant to the response structure (e.g., Regional Response Team, Natural Resource Trustees) must be defined. The NCP does not attempt to prescribe specifically how a particular organization or individual fits within a given response structure. The FOSC (Federal On-Scene Coordinator) and the Area Committee are responsible for developing, adopting, and implementing a response management system, through the ACP (Area Contingency Plan). A NIIMS-based (National Interagency Incident Management System), ICS/UC can be used as the model for response management in the ACP to ensure an effective response. Because key players differ from area to area, however, Area Committees must have flexibility to adapt the ICS/UC in order to be effective in each specific area. In addition, when developing an ICS/UC, it is important to recognize that the key players in the response management system maintain a separate internal management infrastructure during a response; they do not relinquish authority, responsibility, or accountability. 4. The following items should be considered when developing the Area Contingency Plans: 9 Jurisdictional responsibilities, 9 Roles of all levels of government in the Unified command, 9 Relationship between the OSC (On-Scene Commander) and other officials who also have decision-making authority but are not part of the UC (Unified Command), 9 Financial agreements, 9 Information dissemination, 9 Communications, 9 Training and exercises, 9 Logistics, and 9 Lessons learned. 5. When plans and procedures are understood, agencies can support each other effectively. However, each response results in new lessons learned, which necessitates a continuing need to refine the procedures and processes, develop better methods, and mesh agency needs and actions. Planners and responders at all levels need to understand the authorities and resources each response organization brings to a specific incident. ICS/UC is an important concept to practice as part of response exercises and to include in local and area contingency plans. Such exercising and planning will facilitate coordination and cooperation between federal, state, local and private party responders when the ICS/UC is implemented for a specific incident. F I G U R E 4.10 General guidelines pertaining to unified command and the ICS system (adapted from U.S. National Response Team [NRT]. Managing Response to Oil Discharges and Hazardous Substance Releases under the NCP: Technical Assistance Document, NRT Electronic Reference Library).
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4 Command
(a) Unified Command, (b)Area Command, (c)Multiagency Coordination Systems, and (d) Emergency Operations Centers (Fig. 4.9). The full range of these adaptations of ICS not only ensure proper involvement of diverse responsible authorities in incident response, but also ensure that the response to a particular incident will not unduly detract from local and regional resources that may be needed in response to other incidents. It must be understood that there is no (nor should there necessarily be any one) compelling consensus regarding all possible relationships (or even terminology) regarding muhiagency coordination and management of incident response. The appropriate relationships among response components (as well as precise definitions) ultimately depend upon the specific procedures in place in particular agencies and organizations at the time and place of the incident. The ICS therefore provides a flexible framework of management, rather than a definitive algorithm. For example, The U.S. National Response Team has promulgated guidelines for adapting the Incident Command System to meet the needs of a Unified Command (Fig. 4.10). As noted in these guidelines, no attempt is made "to prescribe specifically how a particular organization or individual fits within a given response structure." Despite the lack of prescriptions regarding specific assignments, however, these guidelines to give explicit directions for ensuring that the accommodation of diverse jurisdictional interests of various public agencies and private organizations do not detract from those clear lines of authority, responsibility, and accountability (Fig. 4.11) that are firmly established by ICS. ADDITIONAL CONSIDERATIONS
It is very likely that, upon a first introduction, the apparent intricacies of ICS management seem overly complex. That is one way to look at it. Another way is to step back and consider, for a moment, just what is involved in mounting any effortmany effort composed of variously trained and available personnel, a huge potential arsenal of different equipment and services that may or may not be available, and a collage of diverse public and private authoritiesntoward the time-constrained objective of minimizing the loss of life and property suddenly at risk in the midst of total confusion and manifest anguish. The fact of the matter is that it is CRISIS which is complex! The ICS is a practical and comprehensive framework that provides for flexible, efficient, authoritative, and accountable response to the extraordinary challenge of life-threatening crisis. But even in the best of circumstances, it can accomplish absolutely nothing in the absence of serious, preincident planning and training.
Additional Considerations
I 01
Local Responsible \ Authorities Party Public Information
Safety
I
Govemment Liaison
!
!
I
I ~176176176 II ~'ann'no II Loo,.t,~. I! ~'n'nce The Unified Command can be described by a triangle, wherein the member placed at the top of the triangle has the final authority for the response. Under the National Contingency Plan, the Unified Command typically consists of the Federal On-Scene Coordinator (FOSC), the State On-Scene Coordinator (and other local authorities), and the incident Commander of the Responsible Party (RP). FIGURE 4.11 Relationship between unified command and ICS (adapted from U.S. National Response Team [NRT]. Managing Response to Oil Discharges and Hazardous Substance Releases under the NCP: Technical Assistance Document, NRT Electronic Reference Library).
102
4 Command
Administration
JJ
Logistics ,,,,,,
!!
[' B e f o r e t h e E m e r g e n c y 9 Establish a written emergency management plan 9 Maintain training records 9 Maintain all written communications 9 Document drills and exercises and their critiques 9 Involve community emergency response organizations in planning activities
I
9 Acquire equipment 9 Stockpile supplies 9 Designate on and off-site emergency facilities 9 Establish training facilities 9 Establish mutual aid agreements with other Industrial facilities or with other organizations 9 Prepare a resource inventory
J During & After the Emergency 9 Maintain telephone logs 9 Keep a detailed record of events 9 Maintain record of injuries and follow-up actions 9 Account for personnel 9 Coordinate notification of family members 9 Issue press releases 9 Maintain sampling records 9 Manage finances 9 Coordinate personnel services 9 Document incident investigations and recovery operations
i
I
9 Provide utility maps to emergency responders 9 Provide Material Safety Data Sheets to emergency responders 9 Move backup equipment into place 9 Repair parts 9 Arrange for medical support, food and transportation 9 Arrange for shelter facilities 9 Provide for backup power 9 Provide for backup communications
FIGURE 4.12 Basic administrative and logistical functions (adapted from Federal Emergency Management Guide for Business and Industry, FEMA Electronic Reference Library).
Whether implemented by public or private organizations, ICS is based upon the premise that what is done during an emergency is no more important than what is done before and after the emergencymbefore the crisis, because any adequate response must be conditioned by previous planning (Fig. 4.12), and after the crisis, because we must both learn from our mistakes and, even in the process of learning, prepare for the next crisis.
Physical and Chemical Hazards
INTRODUCTION
Hazard assessment (or analysis) includes the identification, evaluation, and mitigation (or control) of hazards. The process of hazard identification involves the identification of (a) potential sources of hazards and (b) types (categories, classes)of hazards. Sources of hazards are inclusive of a wide range of structures, materials, operations, activities, circumstances, and phenomena, including (but not limited to) such sources as those included in Table 5.1 and Fig. 5.1. Types of hazards include specific physical, chemical, and biological agents (Fig. 5.2) that, regardless of their source or the circumstance in which they are encountered, present specific categories of safety and health risk. Throughout the world, industrial facilities are under increasing regulatory control regarding the types of hazards that are typically associated with particular types of industrial activities, such as the hazards associated with the industrial use of chemicals. Agencies and organizations having responsibility for responding to emergencies also give particular attention to the types of hazards they are likely to encounter in their role as responders. In some instances, the range of hazards likely to be encountered is extremely comprehensive, as in the case of a fire fighting company; in others, the range may be considerably more narrow, as in the case of a specialized water rescue team. The range of hazards to be associated with either a particular industrial facility or the typical activities of an emergency response organizations does not, in itself, determine the actual risk presented to employees, response personnel, or the general public. Rather, the wider the range of potential hazards, the more comprehensive must be the planning effort devoted to maximizing both the day-to-day control of those hazards and, in the event of an incident, an efficient and effective emergency response. This is particularly the case at the municipal level which, after all, is typically the level that 103
104
s Physical and Chemical Hazards
TABLE 5. I Typical Examples of Community Hazards (Adapted from U.S. Fire Administration, 1995: Technical Rescue Program Development Manual [FA-159])
Source of Risk
Potential Hazards
Sewers
Confined spaces; toxic gases; oxygen deficiency Swift water rescue; calm water rescue; toxic water environments; surface and underwater rescue; ice rescue Hazardous materials; toxic gas emissions; confined spaces; machinery entrapment Above grade and below grade rescue Dust explosions; confined spaces, hazardous materials; fertilizers; machinery entrapment Toxic gases; oxygen deficiency; confined spaces Structural collapse; trench rescue" machinery entrapment Structural collapse Confined spaces; hazardous environments High angle rescue; elevator rescue Collapse rescue; extrication; disaster response Hazardous materials; toxic gas emissions; confined spaces, machinery entrapment Hazardous materials; toxic gas emissions; confined spaces; machinery entrapment; derailment
Rivers/flood ducts, flood-prone areas Industrial facilities Cliffs/gorges/ravines/mountains Agricultural facilities Cesspools/tanks New construction Old buildings Wells/caves High-rises Earthquakes/hurricanes/tornadoes Transfer facilities Transportation centers
is inclusive of all the diverse hazards associated with different industries, the diverse needs of local response services that must meet all contingencies, and, in addition, all nonindustrial hazards that put the public as well as response personnel at risk. Given the diversity of hazard sources as well as types of physical, chemical, and biological hazards, there can be no question that the comprehensive identification of hazards, which is the first step toward the effective control of those hazards, must be achieved through a partnership of facility owners and operators, emergency response authorities, and municipal authorities. In the United States, such a partnership (Chapter 1) is the basic objective of the Federal Emergency and Community Right-to-Know Act of 1986 (EPCRA; SARA Tile III).
STRUCTURAL, MATERIAL, AND OPERATIONAL SOURCES OF HAZARDS Whether at a facility or municipal level, it is useful to approach hazard identification by focusing first on particular structures, materials, and operations that may present specific types of risks in a variety of different circumstances.
Structural, Material, and Operational Sources of Hazards
J
L_
E] Confined Space r J
E
]
E
1 I
El !
I
_J I -']
Wa,er
HighAng le
Trench/Cave-in
/ F-
/ F
][~
L__ F
!{~
Industry
L__ ][~
Building Collapse
J--
105
9 Hypo-/hyperthermia 9 Oxygen deficient and/or toxic atmosphere 9 Exposed Utilities 9 Entrapment
9 9 9 9 9 9 9 9
Hypothermia Electrocution Floating hazards (e.g., logs) Low-head dams (drowning machines) Entrapment in submerged hazards Drowning Swift currents Boats
9 9 9 9 9
Hypo-hyperthermia Falling debris Rope system or equipment failure Falls Improper rigging
9 9 9 9
Exposed utilities Secondary collapse Hypothermia Oxygen deficient atmospheres
9 9 9 9 9 9 9
High noise environments Heavy machinery Exposed utilities Hazardous material releases Falls Confined spaces Stored energy release
9 Entrapment by falling debris/shoring Failure 9 Secondarycollapse
9Hypo-hyperthermia
9 Oxygen deficient atmospheres 9 Exposed utilities 9 High noise environments
FIGURE $.1 Sources of rescue hazards (adapted from U.S. Fire Administration, 1996: Technical Rescue Program Development Manual [FA-159, 2/96]).
Structural elements of any facility (e.g., general layout, floor plans, HVAC and sprinkler systems, construction materials, and engineering specifications) should be examined from the perspective of their becoming not only a source of hazard to persons who work or live inside the facility (employees, tenants), but also to emergency response personnel who may have to respond to an emergency in that facility. Just how structural elements may
106
s Physical and Chemical Hazards
Physical Agents Sonic and ultrasonic sound, including continuous and intermittent (impact) noise
A c o u s t i c Radiation Temperature
Magnetic Radiation
Heat and cold stress
[
Magnetic flux densities, including those having influence on implanted medical devices and ferromagnetic tools
E l e c t r o m a g n e t i c Radiation I
Visible light, lasers, radiofrequency/microwaveradiation, ultraviolet radiation, and x-rays
Radioactivity I
Radionuclides and radiation (alpha, beta and gamma) associated with unstable atomic nuclei/nuclear reactions
Ergonomic Stress I Physical I m p a c t [
Stress associated with mechanical tensions in musculo-skeletal system Mechanical impact that exerts physical force on the body
Chemical Agents Physical Risk Asphyxiant I
Vapors displace air and thereby cause suffocation
I
C o m b u s t i b l e I Bumswhen subjected to a temperature greater than 100~ and below 200~ Corrosive I
Chemically bums living tissue on contact
Explosive I
Suddenly releases pressure, gas and heat when ignited
Flammable !
Bums when subjected to a temperature less than IO0~
Irritant I Pyrophoric I Organic Peroxide
[
I
I
] I
A non-corrosive material that causes itching, soreness or I inflammation of exposed skin, eyes or mucous membranes I Ignites spontaneously in air at temperatures of 130~ or lower Spontaneously explodes due to the formation of unstable peroxides
]
I
!
O x i d i z e r I Promotes or initiates the burning of combustible or flammable I materials I Water Reactive Unstable/Reactive FIGURE 5.2
[
Reacts with water to form a flammable or toxic gas
I Spontaneously explodes with production of pressure, gas, heat I and possibly toxic fumes I
Physical,chemical,and biologicalagentspresentinghumanrisk.
107
Structural, Material, and Operational Sources of Hazards
Chemical Agents -I~
Health Risk Carcinogen !
causes cancer
J
Mutagen [ causes changes in J genetic g e inf~176 nto egeneration. r a that t iis inherited o n ~rf Poison [ Causeslife-threateningdamageto tissuesor intemalorgansin I very small amounts (e.g., severalteaspoonsor less) Sensitizer [
causesallergicreactionsafter repeatedexposures,with possiblysevereor even life-threateningconsequences
Teratogen I
Causes malformationof the developingfetus
I
Toxic I causes life-threateningdamageto tissuesor intemalorgans, but in amountsgreaterthan a poison I I
Biological Agents Bloodborne Pathogens
+
Other Pathogens
J Diseasecausingorganismsthat may be transmittedthrough J blood & other relatedbody fluids of infectedpersons 1 Infectiousdiseasesthatmaybe transmittedby meansother ] ...... thanthe body fluids of infected persons (e.g., air;, food)
F I G U R E 5.2~continued
contribute to an actual emergency depends, of course, on a variety of circumstances, including not only normal circumstances, but also floods, fire, earthquake, and terrorist attack. For example, if a building is constructed downslope of unconsolidated (or unprotected) soils, design specifications may or may not be sufficient to prevent building collapse as a result of mud flow. If significant mud flow is not a possibility, may not heavy rainfall and subsequent flooding result in an explosion due to the location of non-flood-protected groundlevel or subterranean storage areas used for storing water-reactive chemicals? If glass is a substantial component of structural design, does this not present clear categorical risks to employees during an explosion, as well as to fire fighters during fire fighting operations? Are stairwells kept at positive atmospheric pressure to ensure their effectiveness as smoke-free evacuation routes during fire? What state-of-the-art design and engineering features are employed to minimize catastrophic releases of hazardous fuels (e.g., natural gas, oil) during earthquake, or of other hazardous chemicals in even normal circumstances? How do design features make maximum use of fire- and toxicrated materials to minimize the spread of fire and toxic fumes? In congested
[08
5 Physical and Chemical Hazards
industrial areas (e.g., seaports; industrial parks; mixed industrial, commercial, and residential areas), how do facility layout and transportation corridors (ground, water, and air) facilitate or prevent rapid access by community response authorities? Several guidelines are well worth considering in the process of identifying potential hazards related to structures and their design features: 1. It is clearly not sufficient to disregard any potential hazard simply because a particular structural or design element meets the requirements of a particular legal building or construction code. After all, an appropriate code may be lacking or, if legally pertinent, not necessarily as effective as state-ofthe-art practice and technology. The basic rule must be: regulatory compliance is always a de minimus requirement when it comes to health and safety. 2. Structural and design elements should be planned and implemented only after consideration of appropriately defined worst-case circumstances that, at a minimum, include fire, flood, storm, power-outage, earthquake, and terrorist attack. 3. Owners, operators, and other parties having legal responsibility for a facility should understand that, regardless of any regulatory rule, there can be no excuse for failing to coordinate with and seek the advice of local emergency response authorities regarding the structural design of that facility, including both original plans and any subsequent modifications. Materials to be considered in any comprehensive identification of potential hazards typically include (beyond structural materials considered above) materials serving as feedstock to industrial and commercial processes, by-products of operational processes, and final process wastes. Increasingly, global attention has begun to focus on what is commonly called the product-cycle, which is the totality of material and energy transformations that take place over the production, use, and final disposal of manufactured goods. It should therefore be no surprise that the comprehensive identification of hazards is increasingly presumed to be inclusive of those hazards associated not only with process feedstock, process by-products, and process wastes, but also with so-called "finished goods" as well as any material resultant from the use and environmental degradation of those goods. The assessment of new pharmaceutical products in the United States under the National Environmental Policy Act (NEPA), for example, specifically requires such a comprehensive evaluation of potential hazards. Given the fact that a technologically developed society depends upon the daily industrial and commercial use of roughly 60,000 chemicals, the identification of hazards related to these individual chemicals and to the multitude of their combinations is certainly a daunting and demanding task-but it is a task that is nonetheless required under a constantly expanding number of laws, regulations, and standards implemented not only by national and local governments, but also by international organizations.
Structural, Material, and Operational Sources of Hazards
109
It is a mistake for municipal managers and community response services to assume that manufacturing industries are the only potential source of hazardous chemicals. For example, hazardous chemicals may be released into the community during various phases of new development or urban renewal projects, including property management phases prior to construction (e.g., demolition of existing structures that may contain hazardous chemicals as structural components), construction (e.g., on-site storage and preparation of materials and supplies, placement of contaminated fill, fugitive dusts that contain chemical contaminants), and operational and maintenance phases (e.g., runoff from operational site, application of pesticides). Given the variety of potential sources of hazardous chemicals and materials, it is necessary to collate data and information from a variety of sources, including: 9 Chemical inventories of industrial and commercial facilities (including feedstock, process, and waste chemicals) 9 Records of previous land use that might be used to indicate chemical contaminants in soils or downstream wetland and lentic muds 9 Records of previous incidents involving chemical releases in specific areas (including records maintained by regulatory agencies and/or community response services) 9 Data and information that may be available through scientific surveys of local or regional resources (including surveys conducted by corporations and other land buyers to identify potential contamination of on-the-market parcels) Operations that must be considered in any assessment of potential hazards include all on- and off-site operations (whether industrial or commercial) that involve the transportation, delivery, storage, handling, processing, or disposal of hazardous chemicals and materials. While chemicals and materials are typically described as being hazardous by different regulatory agencies using diverse criteria and standards (and having different jurisdictional objectives), it is important to understand that all chemicals are intrinsically hazardous, and that the actual degree of risk presented by any hazard depends on a number of factors, including (but not limited to) the magnitude of exposure (i.e., dose), the route by which the chemical enters the body (i.e., route of entry), and the sensitivity of the person who becomes exposed (e.g., hypersensitive, hyposensitive). For purposes of identifying hazards that might trigger an emergency response, it is therefore inexcusable to dismiss as unimportant any chemical or material simply because it does not have a regulation-based designation (e.g., a hazardous material [under U.S. Department of Transportation regulations pursuant to the Hazardous Material Transportation Act]; a hazardous waste [under U.S. Environmental Protection Agency regulations pursuant to the Resource Conservation and Recovery Act]).
I l0
5 Physical and Chemical Hazards
Structural, Material & Operational Hazards
0
o o
]
~
~
Immediate Environs
On-Site J
FIGURE 5.3 Holisticperspectiveof facilityhazards is inclusiveof all on- and off-site facilities, materials, and operations.
In light of these considerations, the assessment of structural, material, and operational hazards for the purpose of identifying potential hazards that may result in an emergency must be holisticminclusive of not only industrial and commercial facilities, but also any activity (e.g., land clearing, delivery of feedstock chemicals) or circumstance (e.g., flood) that can trigger or otherwise exacerbate any emergency involving either or all; inclusive also of not only on-site features of any particular facility or activity, but also all off-site subsidiary or complementary activities and services related (directly or indirectly) to that facility, whether in the immediate environs or distantly located (Fig. 5.3).
HAZARD EVALUATION AND MITIGATION As discussed in Chapter 2, standard procedures for conducting the appropriate analysis of hazards include Preliminary Hazard Analysis (PHA), What-if Analysis, Hazard and Operability Analysis (HAZOP), Failure Modes and Effects Analysis, Fault- and Event-Tree Analysis, and Human Reliability Analysis. These and additional techniques are included in Figs. 5.4 and 5.5, which summarize some of their basic attributes. It must be
Hazard Evaluation and Mitigation
Procedure
III
Analysis
Hazards
Mitigation
Safety Review Checklist Analysis Relative Ranking
Preliminary Hazard Analysis What-if Analysis What-if/Checklist Analysis
Hazard and Operability Study Failure Modes and Effects Analysis Fault-Tree Analysis Event-Tree Analysis Cause-Consequence Analysis Human Reliability Analysis
FIGURE 5.4 Comparison of common process safety assessment techniques: basic type of analysis and usefulness for prioritizing and mitigating hazards.
emphasized that the indicated procedures are only representative of many techniques in common use in both private and public sectors; new procedures are continually under development. Moreover, because some are more demanding than others (in terms of time, skills of personnel, required data and information bases, and the complexity of protocols), there continues to be very active development of commercially available software (especially for Failure Modes and Effects Analysis, and Fault- and Event-Tree Analysis) to facilitate their use. The early development of most (if not all) of these procedures was greatly influenced in the United States by the Chemical Process Regulations (29 CFR 1910.119). Such hazard analysis procedures are therefore sometimes referred to as process hazard analysis procedures. As this name implies, the primary focus of these procedures is to assess and minimize the potential for a catastrophic release of known hazardous chemicals, such as occurred at the Union Carbide pesticide plant in Bhopal, India. While the achievement of this objective is vital to the proactive phase of emergency response planning, it must be made clear that analytical
112
$ Physical and Chemical Hazards
Procedure
Little Direction
Moderate Direction
Detailed Protocol
Safety Review Checklist Analysis Relative Ranking
Preliminary Hazard Analysis What-if Analysis What-if/Checklist Analysis Hazard and Operability Study Failure Modes and Effects Analysis Fault-Tree Analysis Event-Tree Analysis Cause-Consequence Analysis
Human Reliability Analysis FIGURE 5.5 Comparison of common process safety assessment techniques: relative degree of direction provided by assessment protocols.
techniques used to assess the potential for catastrophic releases in the chemical industry are not sufficient to provide all the types of hazard assessment required by emergency response planning. For example, process hazard analysis typically does not define just what the health and safety hazards of a released chemical are but, rather, the sequence of events in the processing of chemicals that may lead to release. They do not define the actual health and safety probabilities attendant to chemical exposures (i.e., human risk) but, rather, the process-related probabilities of equipment or human failure (i.e., process risk) that will result in human exposure. Another common approach to hazard assessment, and one which is to be clearly distinguished from a "process hazard analysis," is generally referred to as Job-Task Analysis. This type of analysis (Fig. 5.6), which was originally given major impetus in the United States by hazardous waste regulations under the RCRA and, more recently, by workplace health and safety regulations under OSHA, involves the resolution of each workplace job into specifically defined task requirements. Each task requirement is then assessed with respect to health and safety risks likely to be encountered, with subsequent identification and evaluation of alternative means of reducing risks.
I 13
Hazard Evaluation and Mitigation
I
Job Title
1
Shift Maintenance
Job Tasks
Potential Respiratory Exposures
~o Examine requirements of needed work and make work assignments
9 Inspect work while in progress and upon completion 9Assist in actual performance of work as necessary
9 Lead Rescue Team (under Confined Space Program)
Chemical vapors and dusts from plant operations m~
Welding fumes; Grinding dusts
Welding fumes; Grinding dusts; Vehicular exhausts; Operational vapors and dusts Toxic and asphyxiating atmospheres in chemical reactors and material feed silos
FIGURE 5.6 Example of a job-task (or job hazard) analysis.
The focus of Job-Task Analysis is clearly on (a) the manner in which the worker is exposed to hazard, (b) the risk to that specific worker as a consequence of exposure to the hazard, and (c) means for mitigating that risk. This approach to hazard assessment is a basic tool in any modern industrial program of occupational safety and health; it is also particularly relevant to corporate and municipal authorities having primary responsibility for emergency response planning because it requires that careful attention be given to each phase of hazard assessment (i.e., hazard identification, hazard evaluation, and mitigation) at the level of "human risk" rather than, as with process hazard assessment techniques, at the level of "process risk." This is not to say, of course, that process risk assessment is less important to emergency response planning that human risk assessment. Both are necessary. Neither alone is sufficient.
Scientific Basis of Chemical Hazard and Risk Assessment
As a potential harm or injury, any hazard associated with a chemical is intrinsic to that chemical and cannot be altered. Any chemical may be associated with several or more hazards.
114
s Physical and Chemical Hazards
Each of the roughly 60,000 chemicals in daily commercial use in technologically developed nations may be considered hazardous because, depending on the degree and nature of human exposure to it, each may result in harm or injury to an exposed person. Certainly some chemicals are more hazardous than others; the more hazardous are most often listed by regulatory agencies as requiring special attention regarding their handling, shipping, and storage. As shown in Fig. 5.2, chemical hazards are often categorized as physical or health hazards. Physical hazards are those that result in physical injury to exposed persons; health hazards are those that result in physiological injury. Specific types of physical or health hazards are indicated by a chemical's hazard class. Risk results from exposure to hazard. More specifically, risk is the statistical probability (or odds) that an organism will experience the specific harm or injury defined by hazard class. Generally, risk increases with exposure: the greater the exposure, the greater the risk. However, it is important to distinguish between physical and health risks. Essentially a statistical concept, the risk of experiencing injury or harm to health reflects the fact that individuals within a population demonstrate a range of tolerance with respect to chemical exposure. Some individuals are very sensitive (hypersensitive) to certain chemicals, whereas others are relatively insensitive (hyposensitive). Contrarily, the risk of experiencing physical harm or injury as a result of exposure, for example, to a very strong acid or alkali, does not reflect a range of biological tolerance to chemical burns among humans but, rather, to the statistics of accidents. Figure 5.7 depicts an example of a dose-effect (or dose-response) relationship between the dose of a toxic chemical (expressed as weight of the chemical per unit of body weight; e.g., mg/kg) and the probability of a particular effect (e.g., lethality). Dose-effect relationships may be established on the basis of laboratory experiments with animals and may also be inferred on the basis of epidemiological studies of humans. In laboratory studies, the experimenter controls the exposure of the test organisms to the toxic chemical. In epidemiological studies, exposures are inferred from information about workplace and other exposures of humans to the chemical of interest; that is, exposures are not controlled by the experimenter but by the life experience of the persons included in the study. As shown in Fig. 5.7, the LDs0 (lethal dose) represents the dose at which 50% of the test organisms (of the same species) exposed to that dose are expected to die. This statistic essentially states that any one organism exposed to that dose has a 50/50 chance (or 0.5 probability) of dying. If some health effect of exposure other than lethality is of interest (e.g., loss of hair, rapid heart beat), an EDs0 (effective dose) can be similarly determined. LD50 and EDs0 data are based on studies in which the chemical is actually introduced into the organism (e.g., through inhalation, infection);
Hazard Evaluation and Mitigation
I 15
104)Chemi
Effect (% of total population tested showing effect)
_i_..............
50-
!
/'
/
/ 0-I
[
i, ' I
i
i
i
o
, i , Threshold I t Value for B ' LDso(A)
LDso(B)
Dose (mg of chemical per kg of body weight)
FIGURE 5.7 Dose-effect (response) relationships for two chemicals. Note that some effect (i.e., lethality) is seen for every incremental increase in dose of chemical A, whereas increase in dose of chemical B results in effect only after some threshold value of dose. Chemical A does not have a threshold value. The percentage of population showing lethal effects may also be read as the probability of death for an individual (e.g., 50% of the population is equivalent to a 0.5 probability for any individual).
the dose therefore defines that introduced amount. In many instances, the concentration of the toxic chemical in the atmosphere or water in which the test organism lives or functions (i.e., ambient concentration) is known, but the amount actually taken into the organism is unknown. In such cases, LCs0 and ECs0 are used to denote, respectively, the lethal concentration for a 0.5 probability of lethality and the effective concentration for a 0.5 probability of some other effect. LDso, LCso, EDso, and ECs0 values are very useful for defining the relative toxicities of different chemicals. For example, Table 5.2 includes LDs0 values and commonly used categories of relative toxicity. Although these terms are in general use, LDs0 values do have important limitations when comparing the toxicity of two or more chemicals. For example, Fig. 5.8 shows the straight line portions of the dose-effect curves for two
116
5 Physical and Chemical Hazards TABLE 5.2
Commonly Used Terms and Criteria That Describe Relative Toxicity
Relative Toxicity
LDs0 (mg/kg) 1
Lethal
Amount =
Examples of Chemicals 3
Extremely Toxic (Poison)
< 1
Highly Toxic (Poison)
1 - 50
7 drops - 1 teaspoon
Hydrogen cyanide Nickel oxide Arsenic trioxide
Very Toxic
5 0 - 500
1 teaspoon- 1 ounce
Methylene chloride Phenol DDT
Moderately Toxic
500- 5000
1 ounce- 1 pint
Benzene Chloroform Chromium chloride
Slightly Toxic
> 5000
< 7 drops
> 1 pint
Dioxin Botulinus toxin Tetrodotoxin
Acetone Ethyl alcohol
Ferrous sulfate
1. As tested by the oral route in rats 2. Lethal amount for average adult human, based on liquid with density of water 3. As tested by various routes in several animal species
different chemicals. Note that although both chemicals have equal LDs0s, increasing the dose of one chemical results in a smaller incremental increase in risk than does increasing the dose of the other. The dose of a chemical received as a result of exposure is of paramount importance with respect to the health hazard of a chemical. However, it can be irrelevant in certain circumstances. For example, once allergic to a particular chemical, a person can experience a life-threatening episode upon even the most minuscule exposure to that chemical (i.e., an allergen). Also, no well-defined relationship exists between the dose of carcinogens, mutagens, and teratogens and the risk of experiencing their respective hazards.
A c u t e a n d C h r o n i c Effects
The various effects of chemical exposure may be described as acute or chronic effects. Acute effects are those that occur very quickly (e.g., minutes, hours, days) after exposure to the causative chemical agent. As-
I 17
Hazard Evaluation and Mitigation 100-
Effect (% of total population tested showing effect)
Chemical A I
/
IB
50-
O-
I I I I I I I
I I
LD~
i
Dose (mg of chemical per kg of body weight)
FIGURE 5.8 Dose-effect curves for two chemicals with the same LD50.Note that incremental increases in dose result in greater increases in the percentage of population affected for chemical A than for chemical B. At doses less than the LD~0,chemical B is more potent than chemical A; at doses greater than the LDs0,chemical A is more potent than chemical B.
phyxiants, explosives, pyrophorics, organic peroxides, water reactive and unstable/reactive chemicals, corrosives, and poisons typically produce acute effects. Chronic effects are those that occur only after long periods of time postexposure (e.g., years, decades), including effects of sensitizers and carcinogens. Many lung cancers related to exposure to asbestos and cigarette smoke, for example, develop only after as long as 40 years. Because chronic effects become apparent only over extended periods of time, they are particularly difficult to relate to a specific exposure to a particular chemical. As a result, our current state of knowledge regarding the potential effects of the more than 60,000 chemicals in daily commerce tends to be much more extensive with respect to their acute effects than their chronic effects. This state of affairs, however, reflects only the methodological difficulties involved in the scientific investigation of chronic effects, and does not imply that chronic effects should be of less concern. In fact, the paucity of scientific data regarding the chronic effects of exposure to
I 18
5 Physical and Chemical Hazards
hazardous chemicals is sufficient reason to be particularly wary regarding the potential for chronic effects, especially with regard to periodic exposures experienced by community emergency response service personnel. The phrase "target organ effects" is often used to specify the particular organs, tissues, cells, and physiologically important systems that are particularly affected by a specific hazardous chemical, regardless of whether the effects are acute or chronic. Target organs typically affected by a wide range of common commercial chemicals include the skin, eye, mucous membranes, respiratory tract, lungs, liver, kidney, reproductive system, and central nervous system.
Dimensions of Exposure The term "exposure" denotes some measure of the amount of chemical to which a person may be subjected, either as a dose that enters the body or, as is often the case in emergency response, as a concentration in the ambient atmosphere. However, the risk of experiencing a health effect is not simply a function of dose or concentration. Other factors that influence risk include age, gender, general state of health, lifestyle, and any medications (or drugs) a person may use. In some instances, one or more of these exposure-related factors may dramatically increase the risk of exposure to a hazardous chemical. For example, smoking cigarettes imparts a certain risk to a person of developing lung cancer; so does exposure to asbestos. However, the combination of these two factors results in a substantially greater risk than is imparted by either factor alone. The interaction of two or more chemicals to multiply the risks associated with any one chemical is an example of the phenomenon of synergy. Synergistic effects should be of particular concern to emergency response service personnel who, given the nature of their work, are likely to experience periodic exposures to a wide range of chemicals over a long period of time. Another important factor that can directly influence risk is the particular means (route of entry) by which a chemical comes into contact with a person, including: 9 Inhalation 9 Ingestion (contamination of food and/or hands used to prepare or consume food, nasal drippings that have become contaminated through inhalation) 9 Skin or eye contact (where the chemical action is at the surface) 9 Absorption (through intact skin, eye, or mucous membranes; no physical lesions necessary) 9 Puncture (or injection)
Consolidation of Information and Database
] ]9
Not all chemicals can enter the body through all possible routes of entry. Most chemicals do, however, enter the body through two or more routes. The toxicity of many chemicals is greater or lesser (i.e., in terms of the dose required to produce certain health effects) depending on the specific chemical and its specific route of entry. For example, a toxic chemical that is ingested will often have a higher LD50 (i.e., be less toxic on a per dose basis) than the same chemical injected directly into the bloodstream. Knowing the various routes of entry for different hazardous chemicals is important because by blocking those routes of entry through the appropriate use of personal protective clothing and equipment (e.g., impervious gloves, respirators), we can effectively prevent exposure and thereby minimize risk. Environmental Transport and Transformation
Once a chemical enters the environment it is subject to a variety of mechanisms that transport it from place to place and from one environmental medium to another (e.g., soil to air, air to water). During transport, a chemical may also undergo transformation because of dynamic physical, chemical, and biological processes (e.g., combustion). Some environmentally mediated transformations of chemicals can result in the production of a chemical (or chemical by-product) that is more toxic than the original chemical. The environmental transport and transformation of a chemical is often referred to as the environmental fate of that chemical. Computerized multimedia environmental models describe the environmental fate of chemicals and are increasingly available commercially. These models are important for calculating the probable concentrations of different chemical species in different environmental media, as may be expected as a result of chemical release to the environment. Computerized models are also particularly useful to emergency response personnel insofar as they have the capacity to predict atmospheric flows of chemical plumes under a variety of ambient conditions. Such models are most often called air (or water) dispersion models. C O N S O L I D A T I O N OF I N F O R M A T I O N A N D DATABASE
There is no question that there are vast amounts of information and data regarding hazard assessment that are readily available through governmental agencies (e.g., Nuclear Regulatory Commission, National Institute of Occupational Safety and Health, the U.S. Fire Administration), private organizations (e.g., CHEMTREC) and electronic network services (e.g., National Pesticide Telecommunications Network), corporate regulatory c o m -
s Physical and Chemical Hazards
120
6Pical esta 9 9 9 9 9 9 9 9 9 9 9 9 9
Common synonyms Hazards R o u t e s of entry T a r g e t organs A c u t e effects C h r o n i c effects Health & safety s t a n d a r d s S y m p t o m s of e x p o s u r e Protective clothing Protective e q u i p m e n t Disposal r e q u i r e m e n t s C h e m i c a l compatibility Persistence in environment 9 Storage r e q u i r e m e n t s 9 P r o p e r labeling
9 Environmental transport 9 Environmental transformations 9 Emergency response actions 9 Ambient monitoring 9 Personal monitoring 9 Medical surveillance 9 Medical treatment 9 Environmental remediation measures 9 Combustion products 9 Personal R i s k factors 9 Health and e n v i r o n m e n t a l synergisms
FIGURE 5.9 Example of contents of a computerized industrial chemical database used to inform and direct all decision making regarding personnel health and safetyprograms, including the emergencyresponse program.
pliance plans (e.g., Hazard Communication Plan), chemical manufacturers (e.g., Material Safety Data Sheets), and, of course, commercial publications. However, the ready availability of printed or electronic information and data does not in any way guarantee the practical application of that information and data to the manifold needs of effective emergency response planning. Whether at the national, regional, municipal, or corporate level, relevant data and information must not only be collected but, most importantly, organized into useful formats and translated into protocols that can be directly used to meet the urgent needs of site-specific emergency response. It is not, after all, the amount of information and data on hand that is important for preventing, planning for, or responding to an emergency; rather, what is important is precisely how specific information and data are consolidated into actual proactive and reactive practice. For example, Fig. 5.9 is a summary of information related to the inplant inventory of chemicals in a small manufacturing company. This infor-
121
Consolidationof Informationand Database Use this Table When the Material is NOT on Fire
Small Spills 4~ml~Be,.Large Spills - - - - - - - 7 19 " ~ [ Then,
First,
Protect thos~e I [
First,
/ Protectthose
Isolatein personsin-the II! Isola!ein I/personsin the all downwind III .. A~! I/ downwind directly_ ~ 1 ~ L~ection
ID No. Nameof Material
Feet
Feet
Miles
2
~
600
2
2
~
6oo
2
300
i
~
900
3
300
i
~
900
3
1500
5
~ 1 5 0 0
1051 Hydrocyanic Acid 600 1051 Hydrogen Cyanide (anhydrous, stabilized) 6o0 1052 Hydrofluoric Acid (anhydrous) 1052 Hydrofluoric Acid (anhydrous) 1053 Hydrogen Sulfide
Miles ~
5
FIGURE 5.10 Example of page entries on standard guide regarding the proper response to small and large spills of specific chemicals (adapted from U.S. Department Transportation [DOT], Guidebook for First Response to Hazardous Materials Incidents).
mation is consolidated into a computerized database (of roughly 1500 chemicals, including feedstock, by-products, and wastes ) that serves as the basis of corporate policy, operational procedures, and all personnel training related to occupational health and safety, including both in-house and community emergency response services. While there are many readily available, excellent guides that are very useful as generic tools (Fig. 5.10) for implementing effective emergency prevention, planning, and response programs, there can be no substitute for those tools specifically fashioned to meet facility-specific, place-specific, and circumstance-specific emergency response needs.
BIOHAZARDS
INTRODUCTION
Over the last three decades of the 20th Century, it became increasingly evident that, in addition to those hazards and risks typically faced by emergency response personnel, much more concentrated attention had to be given to the hazards and risks posed by the continually expanding profusion of industrial and commercial chemicals. While this concern will likely remain unabated well into the next century, it also became evident by the mid 1980s that biological agents of disease had also become of cardinal importance~ not only with respect to the health of the general public, but, more specifically, to those who, by the nature of their occupation, experience routine exposure to blood and other body fluids. Of immediate concern at that time, of course, was the abruptly devastating emergence onto the world scene of HIV (Human Immunodeficiency Virus), the viral agent that may lead to fully developed AIDS (Acquired Immune Deficiency Syndrome) in HIV-infected persons. In the United States, the growing recognition of AIDS as being communicable through exposure to the blood and certain body fluids of infected persons prompted federal enactment of the Health Omnibus Programs extension Act of 1988, Title II ("Aids Amendments of 1988") as a means of giving specific guidance to health workers, public safety workers, and emergency responders. Even in the absence of precise understanding of the etiology of HIV, the U.S. Department of Health and Human Services (Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health) moved quickly (February, 1989) to issue specific guidelines to reduce workplace risk with regard to not only HIV, but also hepatitis B virus (HBV). The insightful inclusion of HBV along with HIV in these guidelines (U.S. Department of Health and Human Services, 1989: Guidelines for Prevention of Transmission of Human Immunodeficiency Virus and Hepatitis B Virus 122
Introduction
123
to Health-Care and Public-Safety Workers) was based on the following assumptions: 1. Modes of transmission for HBV are similar to those of HIV, 2. Potential for HBV transmission in the workplace is greater than for HIV, 3. There is much greater experience with controlling workplace transmission of HBV, and 4. Practices to prevent the transmission of HBV will also minimize the risk of transmission of HIV. In keeping with this approach to providing practical guidance for minimizing the risk of infection by a number of diverse pathogens that nonetheless demonstrate similarities in modes of transmission, the U.S. Occupational Safety and Health Administration (OSHA) implemented its own "Bloodborne Pathogen Standard" (29 CFR 1910.1030) for American industry in 1992. While the recognition of bloodborne pathogens as an occupational risk to any personnel having contact with blood and body fluids of infected persons is now firmly established, bloodborne pathogens do not exhaust the range of biohazards that may present health risks to emergency responders. With the rapidly growing mobility and population density of persons in an increasingly cosmopolitan global village, with the-ever developing industrial and commercial use of biotechnology and, as a consequence of the misuse of previous pharmaceutical technology, the general public continues to be at highly significant risk due to a host of pathogenic and parasitic organisms, with yearly deaths from infectious and parasitic organisms exceeding, worldwide, the deaths due to all other causes (Fig. 6.1) and accounting for one-third of all deaths. Of growing world-wide concern are the following.
I. Pathogenic Organisms That (a) Have Been Long Existent but Equally Long Isolated in Remote Areas of World, or (b) Are Newly Evolved through Genetic Mutations of Existing Pathogens Diseases caused by these pathogens, including at least 30 new disease agents identified over the past 20 years, are referred to as emerging diseases (Table 6.1). As even the most remote areas of the world become more accessible to world travelers, so does the world itself become more accessible to these pathogens. While it might be assumed that emergency response personnel are at no greater risk than the general public, it must be emphasized that it is becoming increasingly likely that a major catastrophe (e.g., earthquake,
124
6 Biohazards
Infectious & Parasitic Diseases Cardiovascular Diseases Cancer Injuries Perinatal & Neonatal Causes Chronic Pulmonary Diseases Maternal Causes Other & Unknown Causes 0
I
5
10 Number (Millions)
15
20
Worldwide deaths by cause, 1993 (adapted from Centers for Disease Control [CDC], Electronic Reference Library).
FIGURE 6.1
high-rise building collapse), wherever it occurs, will elicit the response of specialized emergency teams from throughout the world.
2. Pathogenic Organisms Cultured in Medical Research and Other Facilities, Including Facilities in Which Genetically Engineered Organisms Are Produced
There have long been laboratories and specialized storage depots housing pathogenic organisms used for research purposes. Emergency responders must therefore be prepared to deal with biohazard risks associated with such facilities. In addition, a growing number of laboratories and commercial industries involve genetic engineering of potential pathogens--a situation that greatly increases the probability of such facilities becoming involved in catastrophic emergencies. Thus, the following considerations become of paramount concern to emergency response planning: 9 Given the rapid growth and development of contemporary societies, many facilities in which pathogens are cultured and stored (and/or genetically manipulated) are located in very dense population areas,
125
Introduction
TABLE 6. I Examplesof Emergent Infectious Diseases Recognized Since 1973 (Adapted from CISET, 1997: Global Microbial Threats in the 1990s [National Center for Infectious Diseases Electronic Reference Library])
Year
M icrobe
Type
Disease
1973 1975 1976 1977 1977 1977 1977
Rotavirus Parvovirus B19 Cryptosporidium parvum Ebola virus Legionella pneumophila Hantaan virus Campylobacterjejuni
Virus Virus Parasite Virus Bacterium Virus Bacterium
Major cause of infantile diarrhea Aplastic crisis in chronic hemolytic anemia Acute and chronic diarrhea Ebola hemorrhagic fever Legionnaires' disease Hemorrhagic fever with renal syndrome Enterric pathogen
1980 1981 1982 1982 1982 1983 1983 1985 1986 1988 1988 1989 1989
HTLV-1 Toxic Staphylococcus aureus Escherichia coil (0157:H7) HTLV-II Borrelia burgdorferi HIV Helicobacter pylori Enterocytozoon bieneusi Cyclospora cayatanensis Human herpesvirus-6 Hepatitis E Ehrlichia chafeensis Hepatitis C
Virus Bacterium Bacterium Virus Bacterium Virus Bacterium Parasite Parasite Virus Virus Bacterium Virus
T-cell lymphoma-leukemla Toxic shock syndrome Homorrhagic colitis; hemolytic uremic syndrome Hairy cell leukemia Lyme disease AIDS Peptic ulcer disease Persistent diarrhea Persistent diarrhea Roseola subitum Enterically transmitted non-A, non-B hepatitis Human ehdlichiosis Parenterally transmitted non-A, non-B hepatitis
1991 1991 1991 1992 1992 1993 1993 1994 1995
Guanarito virus Encephafitozoon hellem New species of Babesia Vibrio cholerae 0139 Bartonella henselae Sin nombre virus Encephalitozoon cuniculi Sabia virus HHV-8
Virus Parasite Parasite Bacterium Bacterium Virus Parasite Virus Virus
Venezuelan hemorrhagic fever Conjunctivitis, disseminated disease Atypical babesiosis New strain associated with epidemic cholera Cat-scratch disease; bacillary angiomatosis Adult respiratory distress syndrome Disseminated disease Brazilian hemorrhagic fever Associated with Kaposi sarcoma In AIDS patients
9 Given recent advances in biotechnology as well as the ready availability of that technology, it is highly unlikely that any legal authority knows precisely what is actually being done anywhere regarding the production or genetic manipulation of pathogens~except in those specific cases where legal sanction or financial support is sought by those doing the work, and 9 Given recent experience with both current technology and external (so-called "foreign") and internal (so-called "domestic") terrorism, it is not unimaginable that a pathogen may well become the weapon of choice for any knowledgeable sociopath. In light of these considerations, it is suggested to be only prudent for emergency response planning to take careful account of the real possibility that the occupational risks associated with bloodborne pathogens do not define the full range of risks attendant to biohazards.
126
6 Biohazards
3. Well-Known Pathogens That, Due to Society's Overuse of Antibiotics, Have Evolved into Strains Now Resistant to Those Antibiotics
Diseases caused by well-known pathogens that were once controlled but which have become either resistant to antibiotics or are, for other reasons (e.g., changes in human behavior, development of natural resources, changes in public policy), ascendant are referred to as reemerging diseases (Table 6.2). Again, microbial resistance to antibiotics is a risk presented to the general public, with seemingly no special relevance to the emergency responder. However, during emergency response activities involving close personal contact with victims, it is only prudent (as in the case of HIV) that emergency response personnel take appropriate measures to protect themselves from any infection.
BLOODBORNE PATHOGENS
Bloodborne pathogens are those pathogenic organisms that may be found in certain body fluids of infected persons. They may be transmitted to noninfected persons through their contact with contaminated body fluids, including: 9 human blood, blood components, and products made from human blood 9 semen (male reproductive secretion) 9 vaginal secretions (female reproductive secretions) 9 cerebrospinal fluid (associated with brain and spinal cord) 9 synovial fluid (associated with membranes in bone joints) 9 pleural fluid (associated with lung) 9 pericardial fluid (associated with chest cavity) 9 peritoneal fluid (associated with abdominal cavity) 9 amniotic fluid (associated with membranous sack covering fetus) 9 saliva (only in dental procedures where there is a high probability of blood becoming mixed with saliva) 9 any other body fluid that is visibly contaminated with blood 9 all body fluids in situations where it is difficult to differentiate between body fluids The two bloodborne pathogens of primary concern are the hepatitis virus (HV), specifically types B and C (HBV and HCV, respectively), and the so-called AIDS virus (HIV), which is really a number of distinctly different genetic strains of the same virus.
127
Bloodborne Pathogens T A B L E 6.2
Some Factors Leading to the Ongoing Reemergence of Infectious Diseases
Disease
or A g e n t
Factors
in R e - e m e r g e n c e
Viral Infections Rabies
Breakdown in public health measures; changes in land use; travel
Dengue/dengue hemorrhagic fever
Transportation, travel and migration, urbanization
Yellow Fever
Favorable conditions for mosquito vector
Parasitic Infections Malaria
Drug and insecticide resistance; civil strife; lack of economic resources
Shistosomiasis
Dam construction, improved irrigation, and ecological changes favoring the snail host
Neurocysticercosis
Immigration
Acanthamebiasis
Introduction of soft contact lenses
Visceral leishmaniasis
War, population displacement, immigration, habitat changes favorable to the insect vector and increase in immunocompromised human hosts
Toxoplasmosis
Increase in immunocompromised human hosts
Giardlasis
Increased use of child-care facilities
Echinococcosis
Ecological changes that affect the habitats of the intermediate (animal) hosts
Bacterial Infections Group A Streptococcus
Uncertain
Trench fever
Breakdown in public health measures
Plague
Economicdevelopment; land use
Diphtheria
Interruption of immunization program due to political changes
Tuberculosis
Human demographics and behavior;, industry and technology;, international commerce and travel; breakdown of public health measures; microbial adaptation
Pertussis
Refusal to vaccinate in some parts of the wodd because of the belief that injections or vaccines are not safe
Salmonella
Industry and technology; human demographics and behavior;, microbial adaptation; food changes
Pneumococcus
Human demographics; microbial adaptation; intematJonal travel and commerce; misuse and overuse of antibiotics
Cholera
Travel; new strain; reduced water chlorination
128
6 Biohazards
Fact Sheet
Hepatitis B
Clinical Feature., Jaundice, fatigue, abdominal pain, loss of appetite, intermittent nausea, vomiting
Etiologic Agent
Hepatitis B virus
Incidence
140,000 - 320,000 infections/year in United States
Sequellae
Of symptomatic infections, 8,400- 19,000 hospitalizations/year and 140 - 320 deaths/year Of all infections, 8,000 - 32,000 chronic infections/year, and 5,000 - 6,000 deaths/year from chronic liver disease including primary liver cancer
Prevalence
Estimated 1 - 1.25 million chronically infected Americans
Costs
Estimated $ 700 million (1991 dollars)/years (medical and work loss)
Transmission Risk Groups
Trends
Prevention
Bloodborne; sexual; perinatal Ik 9 4. 4. 4.
Injection drug user Sexually active heterosexuals Homosexual men Infants/children of immigrants from disease-endemic areas 4. Low socioeconomic level
.1. Sexual/household contacts of infected persons .1. Infants bom of infected mothers .Ik Health care workers 4. Hemodialysis patients
Incident increased though 1985 and then declined 55% through 1993 because of wider use of vaccine among adults, modification of high-risk behaviors, and possibly a decrease in the number of susceptible persons. Since 1993, increases observed among the three major risk groups: sexually active heterosexual, homosexual men, and injection drug users. 4. Hepatitis B vaccine available since 1982 .1. Screening pregnant women and treatment of infants born to infected women 41. Routine vaccination of infants and 11o12 year olds .Ik Catch-up vaccination of high-risk groups of all ages 4. Screening of blood or tissue donors
FIGURE 6.2 Basic facts about Hepatitis B (adapted from information from National Center for Infectious Disease [NCID], Electronic Reference Library).
HBV (Fig. 6.2) is of particular concern as an occupational hazard not only because it causes a long-term disabling liver disease possibly leading to cirrhosis and even liver cancer, but also because of its efficient transmission from one person to anther following contact with infected blood and body
129
Bloodborne Pathogens
Infection
(1-6 month incubation) No SymptomsF u ~ " - J
"~ Iminant Hepatitis
Acute Hepatitis
9Rapidly progressive Liver destruction (85% mortality) 9 Jaundice; dark urine; extreme fatigue; anorexia; nausea; abdominal pain; joint pain; rash; fever
p
.
9 Severe liver damage 9 Headache; fever; abdominal pain; jaundice; generalized weakness
After Infection
Antibody Production No Antibody Production (several years' immunity) (chroniccarrier) Healthy ~r
Chronic Persistent Hepatitis (Asymptomaticor Fatigue
Chronic Active Hepatitis Cirrhosis of Liver (5- 10 Years)
Liver Cancer
(30 + years)
FIGURE 6.3
Alternativepathways of infection and postinfection development of HBV.
fluids. HBV has caused (and continues to cause) more cases of occupationally linked infectious disease than any other bloodborne pathogen. In fact, the probability of infection by HBV is on the order of 100,000 times greater than the probability of infection by HIV. HBV infection may require an extended period of incubation and become manifest in highly diverse symptoms (Fig. 6.3), with many infected
130
6 Biohazards
persons becoming long-term carriers and therefore potential sources of new infection. In the United States, it has been estimated that on the order of 300,000 persons, including 9,000 health care workers, become infected with HBV every year. Worldwide, about 300 million persons are chronic carriers of HBV. In southeast Asia and tropical Africa, chronic carriers represent at least 10% of the population; in North America and most of western Europe, this group is less than 1%. Historically, primary attention was given to HBV as the primary occupationally linked hepatitis virus, while HCV (a non-A, non-B strain), which is also transmitted through blood and other body fluids, was considered to present relatively little risk in the workplace. However, HCB has now been demonstrated to present potentially significant workplace risk, with upward of 40% of hepatitis infections previously attributed to HBV now possibly attributable to HCV. HW contravenes the body's capacity to resist a variety of life-threatening infections. HIV infection may also lead to severe weight loss, fatigue, neurological disorders, and certain cancers, including cancer of the skin or other connective tissue (sarcoma) and cancer of the lymph nodes or lymph tissues (lymphoma). First discovered in 1979, AIDS (Fig. 6.4) quickly attained the status of a global epidemic, with estimates of actual cases worldwide approaching 600,000 in less than a decade. However, a distinction must be made between "HW infection" and the development of AIDS. HW infection is indicated by the presence of (a) the HIV agent in the body (e.g., by means of a positive HIV-antigen test) and/or (b) HIV antibodies produced by the infected body (e.g., by means of a positive HIV-antibody test). AIDS is a complex of symptoms indicating significant destruction of the HIV-infected body's immune response capability. While it is assumed that HW infection can result in the development of AIDS, the disease can progress quite differently in different persons, in both symptomatology and chronology. While most HIV-infected persons do appear to develop antibodies to HIV within 6 to 12 weeks of exposure to HIV, some may show neither outward symptoms nor an analytically detectable antibody response (e.g., by means of an HIV screening test) for even longer periods. Finally, even before the full-blown development of AIDS, which is indicated by essentially the collapse of the immune system and the subsequent development of opportunistic diseases (e.g., pneumonia, fungal diseases of the throat and lung, Kaposi's sarcoma, and tuberculosis), an HIV-infected person may develop other symptoms, including severe, involuntary weight loss, chronic diarrhea, constant or intermittent weakness, and extended periods of fever~conditions that may themselves result in death.
Bloodborne Pathogens
13 [
As of May 1985 Cumulative AIDS Cases app. 10,000
".~
9
.;a. q
8
,"
,~ ,, ,%-
?
.
9
'41,'
,
o
,: -'"
"" ;'~; ~, #
"."~t-]
As of December 1995 Cumulative AIDS Cases app. 500,000
Each point ( . ) = 30 cases
Cumulative AIDS cases (1985, 1995) in United States (adapted from U.S. Centers for Disease Control [CDC], CDC Electronic Reference Library). F I G U R E 6.4
Regardless of the progress of specific symptoms, and regardless of the length of time over which infected persons may remain asymptomatic, all HIV-infected persons must be considered capable of transmitting HIV to others. However, it is important to emphasize that H I V transmission requires intimate contact with contaminated blood and other body fluids.
132
6 Biohazards
There is no documented evidence of HIV transmission simply through casual and even close physical contact with infected persons. In addition to HBV, HCV, and HIV, bloodborne pathogens include a variety of highly infectious agents that pose significant risks to workers in various parts of the world. These pathogens (Fig. 6.5) include bacterial, protozoan, and viral species that, through a variety of disease vectors (e.g., mosquitoes, ticks, lice), ultimately contaminate human blood and other body fluids. Any effort to minimize the risk of infection by bloodborne diseases must be predicated by the following three considerations: 1. Exposure to the blood and body fluids of infected persons always presents a real risk of contracting the disease. 2. Analytical tests devised to detect the presence of infection have inherent limits. In some instances, such limits become manifest in false negatives, which are analytical results that indicate a disease is not present when it actually is present. For example, a person who is infected with HIV may nonetheless be completely asymptomatic, with blood showing no detectable levels of HIV antibody for weeks and even months after infection. Negative analytical results are therefore false; they do not prove that infection is absent--nor do they demonstrate that a person is incapable of transmitting the disease to others. 3. Given the range in variation of human response to infection (from grossly symptomatic to completely asymptomatic response), given different periods of latency typically associated with the signs and symptoms of bloodborne diseases, and given the inherent limits of analytical procedures performed to detect disease (e.g., false negative, outright laboratory error), no person can safely assume that any human blood or related body fluid is safely free of contamination with infectious agents. It is particularly important that these considerations be specifically integrated with job-task analyses (Chapter 5) so that individual job-tasks that might involve exposure of emergency response personnel to blood or body fluids can be identified and proper protective equipment (Table 6.3) issued to responsible personnel. UNIVERSAL P R E C A U T I O N S
Universal precautions are procedures specifically designed to control the risk of infection by bloodborne pathogens in a wide range of different work-related circumstances. These precautions involve (a) vaccination, (b) engineering controls, (c) work practice controls, and (d) the use of personal protective equipment.
133
Universal Precautions
Sexually transmitted disease caused by the bacterial spirochete Treponema pal/Mum; most commonly transmitted by sexual contact; transmission can Syphilis
occur through infected blood or an open wound, or from mother to fetus; characterized by a chancre at the site of infection and by generalized B-~ eruption of the skin and mucous membranes and inflammation of eyes, bones, and central nervous system; ultimately results in chronic skin lesions, damage to the heart and aorta, and central nervous system degeneration. Infectious parasitic disease caused by several parasitic species of the amoeba Plasmodiumwhich is transmitted through the Anopheles mosquito which picks up the parasite from the blood of an infected person and transfers it to that of a healthy person; characterized by high fever, severe chills, enlargement of the spleen, and sometimes anemia and jaundice.
Malaria
Babesiosis
I~
An infectious bacterial disease of human beings caused by several species of Bruce#a; transmitted by contact with infected livestock or unpasteurized dairy products; characterized by fever, malaise, and headache; also called Gibraltar fever, Malta fever, Mediterranean fever, Rock fever, undulant fever
Brucellosis
Leptospirosis
Arborviral
Infections
Relapsing Fever
Human protozoan disease of red blood cells caused by the protozoan Babesia microti that is transmitted by the deer tick; characterized by fever, malaise, and hemolytic anemia; prevalent on the coastal islands of the northeast United States; also called piroplasmosis.
B-~
An infectious disease of domesticated animals, including cattle, swine, and dogs; human infection due to contact with urine of infected animals; caused by bacterial spirochete Leptospira interrogans; characterized by jaundice and fever; also called swamp fever.
Infections such as encephalitis, yellow fever, Colorado tick fever, and dengue fever, which are caused by a variety of viruses; transmitted by B-~ arthropods such as mosquitoes and ticks.
BI•
Rare disease cause by bacterial spirochete Borrelia recurrentis; transmitted to humans by lice and ticks; characterized by chills and fever;, also called recurrent fever.
A rare, usually fatal disease of the brain; characterized by progressive C r e u t z f e l d t - B-~ dementia and gradual loss of muscle control; also called Jakob-Creutzfeldt Jakob Disease disease. Viral Hemorrhagic Fever
A variety of infectious diseases caused by viruses; characterized by fever, B-~ chills, prostration, muscle pain, jaundice, internal hemorrhage, coma, and death.
F I G U R E 6.5 Additional infectious diseases that may be transmitted among humans through contaminated body fluids.
134
6 Biohazards
TABLE 6.3 Guidelines for Use of Protective Clothing and Equipment to Manage Risk of Infection Due to Contaminated Body Fluids (Adapted from U.S. Fire Administration, 1992: Guide to Developing and Managing an Emergency Service Infection Control Program [FA-I 12]) Task or Activity
Disposable Gloves
Gown
Mask
Protective Eyewear
Bleeding Control (with spurting blood)
Yes
Yes
Yes
Yes
Bleeding Control (with minimal bleeding)
Yes
No
No
No
Emergency Childbirth
Yes
Yes
Yes
Yes
Blood Drawing
Yes
No
No
No
Starting an Intravenous (IV) Line
Yes
Yes
Yes
Yes
Endotracheal Intubation, Esophageal Obturator Use
Yes
No
No
No
Oral/Nasal Suctioning (manual cleaning airway)
Yes
No
No
No
Handling & Cleaning Contaminated Instruments
Yes
No
No
No
Measuring Blood Pressure
No
No
No
No
Measuring Temperature
No
No
No
No
No
No
No
No
Giving an Injection ,.
Vaccination
The only bloodborne disease for which there is a proven vaccine is HBV. In the United States, personnel who might become exposed to HBV in the performance of their work must be offered immunization against HBV. According to 29 CFR 1910.1030, vaccination must be offered to at-risk personnel within 10 working days of initial job assignment and at no cost to the employee. Other provisions of the OSHA regulations include: 9 The vaccination is to be offered at a reasonable time and place and under the supervision of a licensed physician or a health care professional licensed to give HBV vaccinations 9 An employee is not required to have a vaccination if (a) the employee has previously received the complete HBV vaccination series, or (b) tests show the employee is immune to HBV, or (c) the vaccine is contraindicated for medical reasons
Universal Precautions
135
9 An employee is not required to participate in a prescreening program as a prerequisite to receiving the HBV vaccination 9 An employee may refuse to receive the HBV vaccination or, having initially refused, may subsequently decide to receive it. W o r k Practice Controls
Work practice controls are those policies and procedures designed to minimize the risk of infection during the performance of routine tasks. Four basic types of work practices are relevant in any situation (including emergency response) where exposure to bloodborne pathogens is possible. I. General Work Practices (Apply across the range of work-related tasks; See "Job-Task analysis" [Chapter 5])
9 Eating, drinking, smoking, applying cosmetics or lip balm, and wearing contact lenses should be prohibited. 9 Food and beverages should not be stored in cabinets, refrigerators, freezers, or on counters except where such facilities are specifically designated and restricted to the storing or handling of food and beverages. 9 Any procedure involving blood, body fluids, body parts, or potentially infectious materials should be performed to minimize splashing, spraying, or the formation of droplets. 9 Any specimen containing blood, body fluids, or potentially infectious materials should be kept in clearly labeled, leakproof, closed containers during collection, storage, handling, processing, shipping, and transport. 9 No blood , body fluid, or body part should ever be touched or cleaned up without the use of proper protective clothing and equipment. 2. The Use of "Sharps" (Practices regarding the use and disposal of needles, blades, and other items that may cut or puncture the skin)
9 Needles or other sharps contaminated with human blood or other body fluids should not be bent, broken, sheared, recapped, or removed from their holders. 9 Disposable sharps should be deposited in containers that are punctureresistant, leakproof, and color-coded or labeled "Biohazard." 9 Nondisposable sharps should be decontaminated according to written directions.
136
6 Biohazards
3. Accidental Contact (Procedures to be followed after accidental contact with human blood, tissue, or body fluids)
9 Immediately flush eyes with water or wash skin with soap and water. 9 Remove any contaminated clothing immediately and wash any areas of skin that may have been contaminated by fluids soaking through. 9 Obtain medical consultation after contact to determine necessity of follow-up medical treatment or prophylaxis.
4. Housekeeping (Procedures governing the clean-up of spills of blood, body fluids, and body parts, as well as general housekeeping tasks) 9 All blood-soaked rags, papers, and other materials should be placed in biohazard bags, sealed, and disposed of through a biohazard-certified (medical waste) facility. ~ Trash receptacles in areas where contamination is likely should be cleaned and decontaminated as soon as possible after contamination. ~ All areas contaminated by blood, body fluids, or body parts should be decontaminated.
5. Personal Protective Clothing and Equipment 9 Disposable vinyl or latex gloves should be used wherever hand contact with bloodborne pathogens may occur. 9 An emergency packet should be immediately available to emergency responder and other personnel who may become exposed to bloodborne pathogens and should contain (a) disposable vinyl or latex gloves, (b) appropriate disinfectant solution, (c) a supply of absorbent containment material and scoop, (d) biohazard bags, and (e) disposable towels (for stanching copious flows of blood without exposing responders to blood splash). 9 Disposable gloves must not be cleaned or washed for reuse. However, they should be cleaned prior to removal and disinfected following removal or discarded into biohazard bags. 9 No petroleum products (e.g., hand creams) should be used in conjunction with latex gloves because such materials may degrade latex. 9 In no circumstances should mouth-to-mouth resuscitation be performed without the use of protective mouthpieces or ambu gags to prevent contact with potentially blood-contaminated saliva.
Exposure Control Plan
137
9 Additional protective clothing should be provided as circumstances may require, including fluid-proof aprons, goggles, shoe covers, and face shields.
EXPOSURE CONTROL PLAN
Under the provision of 29 CFR 1910.1030, an employer must develop a written exposure control plan. The specific objectives of this plan are (a) to designate job-related tasks that present the risk of exposure to bloodborne pathogens, (b) to define the schedule and means for implementing exposure controls, and (c) to establish procedures for the evaluation of exposure incidents, personnel training, and record-keeping. The regulations provide specific guidance regarding those world-related activities that may result in exposure to bloodborne pathogens. Emergency response operations potentially include all of these activities. 1. Activities that result in direct exposure of all personnel to bloodborne pathogens (e.g., emergency medical service personnel) 2. Activities that result in direct exposure of some personnel to bloodborne pathogens (e.g., rescue personnel) 3. Individual tasks and procedures or groups of closely related tasks and procedures in which some or all employees may experience exposure to bloodborne pathogens (note: fire brigade) Among the various procedures to be implemented regarding the control of exposure to bloodborne pathogens, particular attention must be given to oversight and enforcement. It cannot be overemphasized that the protection of emergency responders who might become exposed to bloodborne pathogens and other body fluids means protection from infections that can easily spread to responders' families and the community at large. This broad social responsibility for the control of disease means that compliance with workplace policies and procedures designed to control severely disabling and even life-threatening disease must be rigorously enforced without exception throughout the emergency response team. Special attention must also be given to those procedures regarding the evaluation of any incident of exposure, especially the methodical and detailed assessment of any related failures with regard to the identification of specific tasks and personnel at risk (e.g., responders involved in the extrication victims), the adequacy of work practice controls (e.g., personal protective clothing, disinfection of clothing and equipment), and the adequacy of personnel training. Each postexposure incident evaluation should include specific recommendations for revising the exposure control plan as well as
138
6 Biohazards
TABLE 6.4 SummaryInformation Regarding Nonbloodborne Infectious Diseases (Adapted from U.S. Fire Administration, 1992: Guide to Developing and Managingan Emergency Service Infection Control Program [FA-I 12])
Disease Chickenpox
Diarrhea German Measles
(Rubella)
Mode of Transmission Respiratory secretions and contact with moist blisters FecaVOral contamination Respiratory droplets
Availability of Vaccine
Signs and Symptoms
No
Fever; rash; skin blisters
No
Loose, watery stools
I
Yes
'
Fever; rash
and contact with respiratory secretions
Hepatitis A
Fecal/Oral contamination
No
Fever; loss of appetite; jaundice; fatigue
Herpes Simplex
Contact of mucous membranes with moist lesions; fingers are at particular risk for becoming infected
No
Skin lesions located around the mount area
Other non-A, non-B Hepatitis
Several viruses with different modes of transmission
No
Fever; headache; fatigue; jaundice
Herpes Zoster
(Shingles)
Contact with moist lesions
No
Skin lesions
Influenza
Airborne
Yes
Lice
Close head-to-heacl contact; both body and pubic lice require intimate contact (usually sexual) or sharing of intimate clothing
No
Fever; fatigue; loss of appetite; nausea; headache Severe itching and scratching, often with secondary infection; scalp and hairy portions of body may be affected; eggs of head lice attach to hairs as small, round, gray lumps
(Infectious Hepatitis)
(Cold Sores)
continues
139
Nonbloodborne Pathogens TABLE 6.4--continued
Mode of Transmission
Availability of Vaccine
Signs and Symptoms
Respiratory droplets and contact with nasal or throat secretions; highly communicable
Yes
Fever; rash; bronchitis
9Meningococcal
Contact with respiratory secretions
No
Fever; severe headache; stiff neck; sore throat
9Haemophilus influenza (usually in very young children)
Contact with respiratory secretions
No
Same
9 ViralMeningitis
Fecal/Oral contamination
No
Same
Mononucleosis
Contact with respiratory secretions or saliva, such as with mouth-to-mouth resuscitation
No
Fever; sore throat; fatigue
Mumps
Respiratory droplets and contact with saliva
Yes
Fever; rash
Disease Measles
Meningitis
(Infectious Parotitis)
continues
precise schedules for implementing those revisions and monitoring their effectiveness.
NONBLOODBORNE PATHOGENS A large number of diseases may be transmitted to emergency response personnel through means other than contact with the blood or blood-related fluids of infected persons (Table 6.4). In addition to direct contact with the body and clothing of infected victims, such non-bloodborne diseases may be transmitted via contact with feces, nasal secretions, sputum, sweat, tears, urine, and vomitus. However, emergency responders
140
6 Biohazards
TABLE 6.4--continued
Disease
Mode of Transmission
Availability of Vaccine
Signs and Symptoms
Salmonellosis
Foodborne
No
Sudden onset of fever, abdominal pain, diarrhea, nausea, and frequent vomiting
Scabies
Close body contact
No
Itching; tiny linear burrows or "tracks"; blisters, particularly around finger, wrists, elbows, and skin folds
Tuberculosis
Airbome
No
Fever; night sweats; weight loss; cough
Whooping Cough
Airborne; direct contact with oral secretions
Yes
Violent cough at night; whooping sound when cough subsides
(Pulmonary)
(Pertussis)
....
need not have direct contact with a victim's body, secretions, or clothing to experience the risk of infection. For example, an underwater or swift water rescue effort may require submersion into lakes, ponds, and rivers that contain viable pathogenic organisms deposited there by sewage. Also, the debris of collapsed structures may become contaminated in the immediate area of victim entrapment. Rain and wind can also transfer contaminated body substances to response personnel who are otherwise removed from infected victims. A basic strategy for minimizing the risk of disease transmission by contact with infected body substances is most commonly referred to as body substance isolation (BSI). While universal precautions are based on the assumption that all blood and certain body fluids should be considered potentially infectious for bloodborne pathogens, BSI is based on the assumption that all body fluids and substances are potentially infectious (Fig. 6.6). BSI therefore requires careful attention to proactive infection-preventive measures, including: 9 Proper personal hygiene 9 Immunization programs (where appropriate vaccines are available)
141
Nonbloodborne Pathogens
If it's WET, it's INFECTIOUS ...
If it's AIRBORNE ...
ong If it could SPLASH on your HEAD or FEET ...
FIGURE 6.6 Basic rules for managing risks related to infectious diseases (adapted from U.S. Fire Administration, 1992: Guide to Developing and Managing an Emergency Service Infection Control Program [FA-112]).
9 Decontamination procedures 9 Proper procedures for the handling and disposal of w a s t e Written SOPs should be prepared (Fig. 6.7) for all procedures that implement these infection-preventive measures. In many instances, emergency responders are volunteer personnel who respond to incidents by driving to the emergency site in their own vehicles. This is particularly common in community fire brigades in the United States, which respond not only to fires but also to vehicular accidents and other types of local emergencies. In such a situation, and despite the use of protective gloves and other clothing, special attention must be given to onsite procedures for personal cleaning and disinfection to minimize the possibility of individual volunteer responders carrying home (either on their own bodies or in their personal vehicles) infectious materials that can subsequently be transmitted to friends and families.
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Infection Control Standard Operating Procedures
SOP # IC 5 Scene Operations
1. The blood, body fluids, and tissues of all patients are considered potentially infectious, and Universal Precautions/Body Substance Isolation procedures will be used for all patient contact. 2. The choice of personal protective equipment is specified in SOP # IC 4. Personnel will be encouraged to use maximal rather than minimal PPE for each situation. 3. While complete control of the emergency scene is not possible, scene operations as much as possible will attempt to limit splashing, spraying, or aerosolization of body fluids. 4. The minimum number of personnel required to complete the task safely will be used for all on-scene operations. Members not immediately needed will remain a safe distance from operations where communicable disease exposure is possible or anticipated. 5. Handwashing is the most important infection control procedure. Personnel WILL wash hands 9 9 9 9 9 9
After each patient contact After handling potentially infectious materials After cleaning or decontaminating equipment After using the bathroom Before eating Before and after handling or preparing food
6. Handwashing with soap and water will be performed for 10 to 15 seconds. If soap and water are not available at the scene, a waterless handwash may be used, provided that a soap and water wash is performed immediately upon return to quarters or hospital. 7. Eating, drinking, smoking, handling contact lenses, or applying cosmetics or lip balm is prohibited at the scene of operations.
FIGURE 6.7 Example of standard operating procedure for performing tasks under universal and body substance precautions (adapted from U.S. Fire Administration, 1992: Guide to Developing and Managing an Emergency Service Infection Control Program [FA-112]).
143
Nonbloodborne Pathogens
SOP # IC 5 ......
Continued
8. Used needles and other sharps shall be disposed of in approved sharps containers. Needles will not be recapped, resheathed, bent, broken, or separated from disposable syringes. The most c o m m o n occupational blood exposure occurs when needles are recapped.
9. Sharps containers will be easily accessible on-scene. 10. Disposable resuscitation equipment will be used whenever possible. For CPR, the order of preference is: 9 9 9 9
Disposable bag-valve mask Demand valve resuscitator with disposable mask Disposable pocket mask with one-way valve Mouth-to-mouth resuscitation
11. Mouth-to-mouth resuscitation will be performed only as last resort if no other equipment is available. All members will be issued pocket masks with one-way valves to minimize the need for mouth-to-mouth resuscitation. Disposable resuscitation equipment will be kept readily available during onscene operations. 12. Patients with suspected airborne communicable diseases will be transported wearing a face mask or particulate respirator whenever possible. Ambulance windows will be open and the ventilation system turned on full whenever possible. 13. Personal protective equipment will be removed after leaving the work area, and as soon as possible if contaminated. After use, all PPE will be placed in leakproof bags, color coded and marked as a biohazard, and transported back to the station for proper disposal. 14. On-scene public relations will be handled by the Department Public Information Officer, if available; if not, the senior line office will assume this function. The public should be reassured that infection control PPE is used as matter of routine for the protection of all members and the victims that they treat. The use of PPE does not imply that a given victim may have a communicable disease. 15. No medical information will be released on-scene. 16. At conclusion of on-scene operations, all potentially contaminated patient care equipment will be removed for appropriate disposal or decontamination and reuse. FIGURE 6.7~continued
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6 Biohazards
Another aspect of emergency response that is often overlooked for its potential to spread infectious disease (including both bloodborne and other infectious agents) into the community is the use of private wreckers/recycling companies to transport and dispose of crash-vehicles and/or other types of structural debris (e.g., building materials) that may contain large amounts of infectious body substances. Because this task typically takes place at the termination of an incident response when site control reverts to nonemergency response personnel, there is real potential for (a) direct contamination of personnel involved in subsequent salvage and disposal operations involving contaminated vehicles and debris, and (b) contamination of ambient air, water, and soil during those operations, with subsequent risk to the public.
MEDICAL SURVEILLANCE
INTRODUCTION
Medical surveillance of personnel has become an intrinsic activity in any modern workplace. Various interrelated factors are responsible, including (a) extensive public awareness of health and safety risks, which is engendered by the explosion of telecommunication technology, (b) the increased exposure of corporations, corporate executives, and stockholders to potential liability regarding the exposure of both employees and the general public to workplace chemicals, (c) continually expansive regulatory requirements regarding employee health at all levels of government, (d) the rapid development of a global economy in which the protection of human health is rapidly becoming a basic precept of highly competitive marketing ploys, (e) trade union concerns for the health and well-being of members, and (f) corporate insurance underwriters. While the nature and extent of medical surveillance in the workplace are variable with legal jurisdiction and type of industry, the broad dimensions of contemporary workplace medical surveillance are clearly established and pertain directly to any medical surveillance program established for emergency responders.
SURVEILLANCE OBJECTIVES A N D CONCERNS
Typically, medical surveillance may be subdivided into four basic categories or types of surveillance: preemployment screening, periodic operational monitoring, episodic monitoring, and employment-termination examination. 145
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Preemployment Screening
Preemployment screening generally encompasses three objectives: 9 To determine the fitness of an employee to perform assigned work 9 To identify any health conditions that might exacerbate the effects of work-related hazards 9 To establish a baseline health profile that can be used to measure the effects of both short- and long-term exposure to work-related hazards While each of these objectives is essential to the protection of workers, each is increasingly the subject of concern regarding a potential abasement of workers' rights--especially in light of the possible use of sophisticated clinical and genetic analyses to deny or otherwise restrict employment on the basis of potential health care costs likely to be borne by the employer. It has also become clear that the increasingly widespread use over the last decade of the "temporary employee" (who is typically ineligible for health care and other work-related benefits) may reflect corporate intent to disclaim any long-term financial responsibility for worker health rather than simply to improve cost efficiency by reducing in-house staffs devoted to employee recruitment and training. There can be little doubt that the use of preemployment screening as a means of disenfranchising the employee-atrisk rather than as a means of protecting that employee will long continue to be the focus of legal, political, and social scrutiny and debate--especially with regard to emergency response personnel, a category that includes (a) firstresponders, who may often be temporary employees or, if full-time employees, personnel whose primary exposure to hazards is defined by normal (i.e., nonemergency) workplace conditions, as well as (b) full-time emergency response personnel. In the latter case, the stringency of preemployment health standards (applied to "new hires") as compared to the stringency of postemployment health standards (applied to currently employed personnel) could well become of legal relevance in any legal proceeding based on purported bias in hiring practices. Medical surveillance undertaken to determine fitness for work must be predicated on a precise understanding of the total range of health and safety hazards associated with individual work assignments (including both emergency-related and non-emergency-related tasks) as well as pertinent regulatory requirements (e.g., medical examination for use of respirator). While primarily defined by job requirements, fitness for work must also be determined on the basis of preexisting health conditions or limitations of the worker--a determination that may often be at odds with the desires of the worker and/or the employer. The employer is well advised that the willingness of a worker to undertake risks contrary to professional medical advice
Surveillance Objectives and Concerns
147
generally does not necessarily abrogate the employer's responsibility for the health and safety of that worker. This fact underscores the importance of implementing a medical surveillance program that complies not only with the requirements of pertinent health and safety regulations but also with the constraints imposed by competent legal counsel. In some instances, specific guidance is provided by regulatory authority or by professional organizations. For example, the standard promulgated by the National Fire Prevention Association (NFPA No. 1582: Standard on Medical Requirements for Fire Fighters) establishes medical requirements for both candidate as well as operational firefighters (including age-dependent medical evaluations) regarding: 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9
Vital signs Dermatological system Ears, eyes, nose, mouth, and throat Cardiovascular system Respiratory system Gastrointestinal system Genitourinary system Endocrine and metabolic systems Musculoskeletal system Neurological system Audiometric capacity Visual acuity and peripheral vision Pulmonary function Laboratory analyses Diagnostic imaging Electrocardiography
In addition to these requirements, various fire departments also use a range of tests to evaluate the physical fitness of candidate and engaged personnel, including (a) determination of body fat, (b) assessment of flexibility, (c) evaluation of aerobic power, and (d) assessment of physical strength. O( critical importance in any medical surveillance program is the establishment of baseline health profiles of at-risk personnel. The comparison of these profiles with the results of subsequent surveillance is the basic means for detecting changes in health that may be related to routine and nonroutine exposures and stress. It is therefore essential that the medical examination performed in preemployment screening include those measurements of vital signs, vision and hearing measurements, lung function tests, and other clinical biochemical analyses that are directly relevant to workrelated exposure and stress. The selection of specific tests and analyses and the type of data and information required must be made only with the professional advice of a competent medical authority who is provided with all
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details regarding potential routine and emergency exposures. The medical surveillance program must, therefore, be understood to be specific to the emergency response service; no guideline can be provided for identifying specific tests and analyses to be included in a surveillance program that is universally appropriate throughout the emergency response community.
Periodic Operational Monitoring The sole objective of periodic operational monitoring is the early detection of adverse health effects of routine exposure to hazardous agents and situations. As discussed above, periodic operational monitoring must be integrally linked with the baseline profiles established during preemployment screening. In the design of an operational monitoring program, particular attention should be given to the following issues: 1. Because of the wide diversity in types of hazardous agents and situations, the variable progression of different kinds of health impairments and conditions, and the range of work-related exposures, it is highly unlikely that a monitoring schedule appropriate for the early detection of one kind of health condition will be appropriate for the early detection of another kind. For example, depending upon specific work-related exposure, an annual schedule for blood testing to detect liver disease may not be appropriate for chest X-rays, which may in fact cause lung injury if used too frequently. 2. Differences noted between baseline profiles and subsequent operational monitoring do not necessarily indicate an actual disease or debilitation; even if a disease or debilitation is detected, it is not necessarily due to work-related exposure. All medical monitoring data and information are subject to normal variation; abnormal results that may indicate disease or debilitation may reflect home and recreational exposures as well as workplace exposures to hazardous agents; abnormal results may, in fact, not indicate any specific exposure but, rather, simply reflect overall systemic changes in body function. For example, the alkaline phosphatase test is a very sensitive test that, simply because of its sensitivity, can give widely fluctuating results; it is therefore most often a rather nonspecific indicator of liver impairment. The less sensitive gamma glutamyl transpeptidase test is less influenced by extraneous factors, but elevations in this enzyme typically must be on the order of twice the normal amount to trigger clinical concern for liver damage. The design of an operational monitoring program must therefore be undertaken with a clear understanding of statistical and other criteria of significance that medical professionals must use when interpreting monitoring results. It is strongly recommended that personnel included in a medical surveillance program be provided documentation regarding such criteria.
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149
3. A properly designed medical surveillance program should include a detailed action plan that precisely describes steps to be taken whenever operational monitoring results in the detection of a medically significant condition, including follow-up medical examinations, tests, and treatments. The action plan should also provide for the implementation of a comprehensive review of response operations and procedures that may have contributed to the detected health impairment and which may be corrected.
Episodic Monitoring Episodic medical monitoring includes any nonroutine medical monitoring or surveillance activity undertaken in response to a specific incident, condition, or circumstance, such as exposure to a specific chemical (e.g., styrene monomer), or responder complaints of unusual health symptoms (e.g., persistent headaches or nausea). While episodic monitoring is specifically addressed in particular U.S. regulations (e.g., 29 CFR 1910.1450 [Laboratory Standard], 29 CFR 1910.120 [Hazardous Waste Operations and Emergency Response]), it is appropriately included in any comprehensive medical surveillance program, regardless of regulatory jurisdiction. Provisions for episodic medical monitoring must be predicated on several considerations: 1. While the episode that triggers nonroutine medical surveillance may often be described in terms of objective criteria, such as an uncontrolled exposure to a specific chemical, subjective criteria may alone be sufficient and even critical. Even in the absence of any objectively manifest evidence of exposure, the fact that personnel think they may have suffered a nonroutine exposure is sufficient cause for medical surveillance and consultation over and above that provided through regularly scheduled operational monitoring. While a safety officer may be aptmsometimes, with good reasonmto consider an individual complaint the product of an overactive imagination or the purposeful contrivance of a "problem employee," safety officers are reminded that individual personnel may be particularly sensitive to a hazardous agent. Should a complaint be ignored simply because it is a singular complaint, it is possible that a real health threat will be ignored, with not only dire consequence to the individual, but also serious legal and financial ramifications for both the safety officer and the response service organization. 2. Whatever the cause or circumstance of the episode, medical authority must be provided with relevant data and information. In many instances, standard forms are used to provide medical professionals the appropriate information (Fig. 7.1). In all instances, it is necessary that
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7 Medical Surveillance
Personnel Exposure Determination
Global Emergency Response Services Employee Identification Name
Department
Reason for Implementing Determination of Exposure [ 1 ! I [
] J I I
Monitoring Data ObservedSpill or Release of Chemical Odor,Taste or Other Sensory Perception of Chemical Procedural/OperationalPotential (e.g., open vessel; failure of ventilation) J Signs or Symptoms of Chemical Exposure
Name(s) of C h e m i c a l s or Chemical C o n s t i t u e n t s and Relevant OSHA TLV Chemical Name OSHA TLV
Available M o n i t o r i n g Data Chemical Name
Date
Value/Unit
D e s c r i p t i o n of Incident or C i r c u m s t a n c e
Date
Signature of Safety Officer
FIGURE 7. I Example of a form that provides an attending physician or other medical professional with critical information regarding personnel exposure to a hazardous agent.
preliminary liaison be established between the safety officer and medical personnel so that the latter have direct access to baseline information that may become relevant to any subsequent episode. Such baseline information should at a minimum include an inventory of relevant chemical agents that, for each listed chemical, identifies hazards, target organs, and routes of entry. It is
Surveillance Objectives and Concerns
15 1
also recommended that combustion, water-reactive, and other by-products be identified for each chemical included in the inventory, along with the hazards and target organs associated with those by-products. 3. Episodic events that trigger medical surveillance include those predicated by the recognition of health symptoms. It is therefore essential that all personnel receive thorough training in the range of symptoms that may be associated with response-exposure to hazardous agents and understand the importance of reporting such symptoms to the safety officer. Symptoms (Table 7.1) associated with work-related exposure to hazardous agents typically cannot be differentiated from symptoms associated with non-workrelated exposure or from various health conditions or infections totally unrelated to the work environment. However, the safety officer must understand that the only competent authority for determining the significance of any health symptom is the physician. It is the responsibility of the physician to evaluate symptoms and to determine the relevance of those symptoms to operational exposures; it is the responsibility of the safety officer (and the emergency service organization) to ensure that personnel who display health symptoms have immediate access to the physician. 4. As important as symptoms are for triggering medical consultation and surveillance, the limitations of symptoms must be recognized. For example, the health effects of exposure to many hazardous chemicals often require years and decades to develop. In such cases, there may be no readily recognized symptoms for extended periods of time, whereas in others, clear symptoms develop rapidly after exposure to the hazardous agent (Fig. 7.2). In compiling a list of symptoms requiring medical notification, the safety officer must therefore ensure consideration of the range of symptoms associated with both chronic and acute health effects. It is also necessary to identify which particular symptoms require immediate medical response. The inherent limitations of symptomatology as a trigger to medical consultations mean that the safety officer must establish additional criteria for activating episodic medical monitoring. Examples of such criteria include (but are not limited to): 9 Any failure or aberrant function in exposure control devices or procedures during an emergency response incident (e.g., respirator, decontamination procedure) 9 An area-wide release of toxic fumes or particles, with the result of potential exposure of nonprotected emergency response personnel 9 First-time operational experience with a specific chemical or other hazardous agent 9 Notification through postincident review that personnel might have been exposed to hazardous agents not previously identified or recognized
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~ Medical Surveillance TABLE 7.1 Common Symptoms That May Indicate Exposure to Hazardous Chemicals (Adapted from Materials Provided by Dr. Donald G. Erickson)
9 9 9 9 9 9 9 9 9 9 9 9 9 9 = 9 9 9 9 9 9 9 9 9 9 9 9 9 9
9 9
Chest pain or discomfort Bluish lips or face; extreme paleness Persistent coughing or sneezing Breathing discomfort; rapid or strained breathing Palpitations or fluttering in chest Lightheadedness or dizziness; giddiness; fainting Headaches (especially persistent, recurrent or progressive) Itching or irritation of eye; watering of eye; sensitivity to light Visual impairment, including reduced vision, double vision and changes in perception of color Loss of physical coordination or dexterity; slurring of speech Unusual hair loss Bleeding of gums or nose Increased sensitivity to noise; changes in hearing acuity; ringing in ears Abnormal odor of breath Hoarseness Fever Abnormal sweating or dryness of skin Generalized aches and pains; muscle cramping; weakness of a particular muscle Prickly sensation in legs, arms, or face Prickly or numb sensation in tongue Nausea, vomiting, abdominal pain; burning sensation in throat or stomach Unusual thirst Problems in swallowing; change in taste sensation Loss of appetite Changes in color of urine Unusual skin rashes or swelling; acne-like skin lesions; blisters Changes in skin color Personality changes Abrupt or progressive behavioral changes, including changes in personal grooming; impairment of judgment; aggressiveness; irritability Nervousness or restlessness; tremors or shakes Lethargy or unusual sleepiness
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153
Non-Apparent Symptoms Moderate Symptoms Severe Symptoms Fatality
Mild Symptoms
Non-APparent Symptoms ,,,
Mild Symptoms Severe Symptoms Moderate Symptoms Fatality
Severe Symptoms
Fatality
FIGURE 7.2 Distributionof clinical severity for three distinct types of infection. Other distributional patterns are possible, depending upon the specificinfectiousagent.
9 Special conditions or circumstances encountered during emergency response operations that might have resulted in unforeseen exposures (e.g., temperature inversions, rain, discovery of purposely hidden hazardous wastes)
Termination Examination The objective of the termination examination is to complete the total health profile of terminated personnel over the full period of employment. While specific requirements may be defined by pertinent regulations (e.g., in the United States, 29 CFR 1910.120) or, more commonly, by insurance
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underwriters, the termination examination must be based on preemployment screening, operation, and episodic monitoring data and information available to date as well as on incident-related exposures or health symptoms experienced between the last medical examination and the termination examination. In addition to taking specimens for the purpose of conducting final clinical or biochemical analyses (e.g., urinalysis, blood count, enzymes), it is possible that response organizations will increasingly request specimens to be warehoused for potential future analysis by as yet undeveloped or currently experimental methodologies. Such an approach, which is now rarely practiced, will most likely receive increased attention due to mutually reinforcing trends in rapidly expanding analytical technology and in workrelated health and safety litigation.
LIAISON WITH
MEDICAL AUTHORITY
The various types of information and data generated in the progress of medical consultation and examination may be described in somewhat different terms by different medical practitioners and measured by different methodologies. For example, a "physical examination" given by any physician typically varies greatly from one physician to another, especially with regard to the physician's focus on a person's overall health as opposed to a focus on heath in terms of work-related activity and risk. Whereas measurements of height and weight have some useful meaning with regard to a person's general health, there is generally little if any significant meaning to these parameters with regard to response-related activities. As to actual methodologies or procedures, preferred methods are not necessarily those that are most precise but, in some circumstances, may be those that can be performed most rapidly. Which tests to perform and which method to employ can only be decided by licensed medical authoritymand these decisions must be made on a case-by-case basis. The fact that decisions about the type of data and information required and the best means for obtaining that data and information are within the sole province of the physician does not mean that the safety officer has little or even no responsibility for the design of an effective and comprehensive medical surveillance program. On the contrary, no other responsibility of the safety officer is more demanding or requires more liaison and coordination with external medical authority. Of particular importance are the following considerations: 1. Most safety officers tend to assume that any licensed medical authority is suitable for the design and implementation of a medical surveillance program. This is definitely not the casemnot for the industrial
Liaison with Medical Authority
155
workplace, and certainly not for emergency response personnel. Where possible, the selection of medical professionals should be based on (a) professional experience in occupational medicine, (b) direct professional access to medical and analytical specialists and services regarding laboratory analyses and the timely processing of medically relevant data, and (c) demonstrated experience in quality control management of all professional medical services. 2. Even when contracting with medical professionals who have extensive experience in occupational medical specialties, the safety officer must understand the importance of providing these professionals with comprehensive baseline data and information on work-related hazards. Such data and information include not only specific information (for example, about ambient concentrations of hazardous chemicals), but also all information regarding the potential health significance of those chemicals, such as the target organs of the chemicals themselves and of combustion or water-reactive byproducts. While the safety officer might assume that medical professionals have this information, they often do not~which, given the tens of thousands of different chemicals in daily commerce, is understandable. It is also useful for medical service personnel to become aware of specific correlations and/ or recommendations regarding types of hazardous exposures, target organs, and standard medical monitoring practices (Table 7.2) which are increasingly available through such authorities as professional fire fighting services and organizations, HAZMAT specialists, and regulatory agencies. Redundancy of information cannot harm; oversight of information that is readily available can be disastrous! 3. Despite the fact that the selection of appropriate medical testing of personnel is the responsibility of the medical professional, it is necessary that the emergency service safety officer thoroughly understand the basis of selection, including (a) the range of different medical tests and procedures that can be performed, (b) alternative methods for performing the various tests and procedures, (c) interpretive criteria to be used in evaluating the significance of medical data and information, and (d) limits associated with the use of any medical data or information for the purpose of diagnosing potential health conditions. In this regard, the safety officer is well advised that, as with any contracted service affecting the health and safety of personnel, any potential liability that might result from incompetence or oversight is not necessarily restricted to the contractor, but might also accrue to the emergency response service itself. In short, it is always best to assume that the emergency service is ultimately responsible for accepting and implementing the professional recommendations of its medical service contractors, including the recommendations made by licensed medical practitioners. 4. Prior to committing to any professional medical surveillance service, the safety officer must ensure that medical surveillance reports will be presented in a format that provides for (a) ready comprehension of the sig-
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TABLE 7.2 Target Organs and Medical Monitoring Associated with Selected Substances (Adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities)
Substance
Target Organs
Medical Monitoring
Aromatic Hydrocarbons
Blood; Bone marrow; Central nervous system; Eyes; Liver; Respiratory System; Skin; Kidney
Occupational/general medical history emphasizing prior exposure to these or other toxic agents; Medical examination with focus on liver, kidney, nervous system, and skin; Complete blood count; Platelet count; Measurement of kidney and liver function
Asbestos
Lungs; Gastrointestinal system
History and physical examination focused on lungs and gastrointestinal system; Stool test for occult blood evaluation; High quality chest X-ray and pulmonary function test
Halogenated Aliphatic Hydrocarbons
Central nervous system; Kidney; Liver; Skin
Occupational/general medical history emphasizing prior exposure to these or other toxic agents; Medical examination with focus on liver, kidney, nervous system, and skin; Laboratory testing for liver and kidney function; carboxyhemoglobin where relevant
Heavy Metals
Blood; Skin Cardiopulmonary system; Kidney; Liver; Lung; Central nervous system; Gastrointestinal system
Occupational/general medical history emphasizing prior exposure to these or other toxic agents; Medical examination with focus on liver, kidney, nervous system, and skin; Complete blood count; Platelet count; Measurement of kidney and liver function
Herbicides
Kidney; Liver; Central nervous system; Skin
History and physical exam focused on the skin and nervous system; Measurement of liver and kidney function; Urinalysis
Organochlorine Insecticides
Kidney; Liver; Central nervous system
History and physical exam focused on the nervous system; Measurement of kidney and liver function; Complete blood count for exposure to chlorocyclohexanes
Organophosphate & Carbamate Insecticides
Central nervous system; Liver; Kidney
Physical exam focused on the nervous system; Red blood cell cholinesterase levels for recent exposure (plasma cholinesterase for acute exposures); Measurement of delayed neurotoxicity and other effects
Polychlorinated Biphenyls (PCBs)
Liver; Skin; Central nervous system (possibly); Respiratory system (possible)
Physical exam focused on the skin and liver; Serum PCB levels; Triglycerides and cholesterol; Measurement of liver function
157
Liaison with Medical Authority
Blood
Lead
Levels
Inorganic lead is absorbed into the body through the lung and the intestinal tract. Organic lead can be absorbed through the lung, but the skin is the more common route. In the studied population of personnel, no overt signs of lead intoxication were identified in health history data or by means of the physical
examination. The following histogram displays the distribution of the blood lead levels obtained in the 1997 survey of personnel. No level met or exceeded the OSHA standard.
13__5 130 u
110
Number of Employees per Range of Blood Lead Level
-
Histogram
90 70 -
50--
30--
26
10-~P
0-5
I
ln,,
11-15
21-25
31-35
42-45
Blood Lead Levels ~ g / 1 0 0 ml)
FIGURE 7.3 Example of a summary presentation of medical monitoring data regarding blood lead levels among personnel. Such a concise verbal and graphic presentation of medical surveillance data is necessary in order to ensure that nonmedically trained persons can understand the significance of detailed medical surveillance findings and the recommendations of physicians (adapted from materials provided by Environmental Medicine Resources, Inc.).
nificance of medical data and information by responsible emergency response service personnel, and (b) professional documentation regarding any potential need for follow-up action. Summaries of each type of health monitoring data should clearly highlight the significance of findings and present the basis for the interpretation of that significance (Fig. 7.3).
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5. The processing and handling of any health-related information must be monitored assiduously to ensure confidentiality. The safety officer is strongly advised to examine in detail those control measures implemented by all relevant medical service personnel (including external examining physicians and medical-testing laboratory personnel) and, where necessary to demand additional safeguards. Of particular importance is the need to ensure that physicians do not report any health information about personnel to emergency service personnel that does not directly relate to work-related conditions or fitness for assigned work. The reporting of medical monitoring results and the maintenance of medical records must be conducted in strict conformity with established rules governing confidentiality and should be closely coordinated with emergency service legal counsel, human resource personnel, and the legal counsel of medical contractors.
TYPES OF M E D I C A L ANALYSIS Overview of Standard Medical Tests
Medical service contractors that provide essential medical surveillance services to emergency response organizations (and, increasingly, emergency response services themselves) employ different categorical terms for describing analytical or diagnostic tests. Some of these categories are based on long-used terms that reflect medical specialties and/or health service management, such as hematology, clinical chemistry, and urinalysis (Table 7.3). Other categories are specific to the types of analyses available for diagnosing structural or functional aberrations of specific organs and tissues, such as the liver, kidneys, and blood-forming functions (Table 7.4). However categorically described, individual analyses must be selected on the basis of a comprehensive assessment of the types of hazards actually encountered by emergency response personnel. A detailed job (and task) analysis has long been recognized as the absolutely necessary first step in providing for the proper medical surveillance of emergency response personnel exposed to the smoke, toxic fumes and gases, and airborne particulates associated with fire fighting and the management of hazardous chemical wastes. Since the advent of AIDS and, certainly continuing with our on-going experience with emerging and reemerging infectious diseases (Chapter 6), job analysis has also increasingly focused on how specific emergency response tasks can result in the exposure of response personnel to bloodborne pathogens and other biohazards. In the
159
Types of Medical Analysis TABLE
7.3
T y p e s o f I n f o r m a t i o n T y p i c a l l y G e n e r a t e d in a M e d i c a l S u r v e i l l a n c e P r o g r a m f o r
Emergency Response Personnel
Category
Analyses
Medical History
- Medical/surgical history - Family history - Work-exposure
Vital Signs
- Blood Pressure
Respiration
- Specific gravity - Blood - pH
Electrocardiogram
value
- Albumin - Microscopic
- Resting cardiogram
Radiology
function
- Depth perception - Peripheral vision
- Threshold
Urinalysis
Physical Fitness
- Pulmonary
- visual acuity - Color vision
Hearing
Clinical Chemistries
- Pulse
- Respiratory rate
Vision
Hematology
- Allergy history - Body systems history
- Sugar examination
- Stress Test
- Chest X-Ray
- White blood cell count - White cell differential count - Red blood cell count - Platelet count - Hemoglobin - Corpuscular volume - Corpuscular hemoglobin - Reticulocyte count
serum glutamic pyruvate transaminase - Total bilirubin - Alkaline phosphatase - Lactic dehydrogenase - Serum glutamic oxaloacetic transaminase - Gamma glutamyl transpeptidase - Blood urea nitrogen - Creatinine - Serum glucose - High density lipoprotein - Low density lipoprotein - Triglyceride - Sodium - Potassium - Chloride
.
- Body fat - Flexibility - Aerobic power - Muscular endurance - Muscular power - Muscular strength - Grip strength
same period, more and more attention has been given to the careful analysis of just how response personnel become subject to the extremely debilitating effects of both physical and psychological stress--two types of risk that have always been attendant to emergency response, but which demand closer scrutiny as ergonornic and critical incident stress.
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T A B L E 7.4 Relevance of Monitoring Tests and Analyses to Functional Health of Selected Organ and Tissue Systems(Adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Activities)
Function
Liver:
General Obstruction Cell Injury
Kidney: General
Test
Examples of Analyses
Blood Tests
Total protein; Albumin; Globulin; Total/direct bilirubin Enzyme test Alkaline phosphatase Enzyme tests Gamma glutamyl transpeptidase; Lactic dehydrogenase; Serum glutamic-oxaloacetic transaminase; Serum glutamic-pyruvic llxansaminase
Blood Tests
Bloodurea nitrogen; Creatine; Uric acid
Multiple Systems & Organs: General
Urinalysis
Blood-Forming Function: General
Blood Tests
Color; Appearance; Specific gravity;, pH; Qualitative glucose; Protein; Bile; Acetone; Occult blood; Microscopic examination of centrifuged sediment
Complete blood count with differential and platelet evaluation, including white cell count, red blood count, hemoglobin, hematocdt or packed cell volume, and desired erythrocyte indeces; Reticulocyte count may be appropriate if there is a likelihood of exposure to hemolytic chemicals
Ergonomic Stress
Clearly a still developing discipline, ergonomics deals with the causes and consequences of mechanical tensions in the musculoskeletal system, including those related to vibration, forceful exertion, awkward posture, repetitive and/or prolonged activity, localized bodily impact, and certain environmental conditions (e.g., heat, cold, noise). While ergonomics tends to focus on mechanical forces operating on muscles, nerves, bones, and tendons, ergonomics also extends into the emotional and other psychological correlates of musculoskeletal dysfunction. Mechanical stress on muscles, nerves, tendons, and bones can lead to physical injury to joints (e.g., in hand, wrist, neck, back, elbow, shoulder, leg) and surrounding tissue. Most injuries experienced by fire fighters and EMTs are due to physical stress on the musculoskeletal system. Typically referred to as cumulative trauma disorder (CTD), such an injury may be relatively minor and last for a relatively brief period of time, with primary symptoms expressed as mild discomfort or ache. However, CTD may also become severe, resulting in acute pain, and may progress even to the point of complete disability.
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Types of Medical Analysis
High-Rise Fires
Ventilation & Overhaul Procedures
Hose Laying Operations
9 Moving equipment and high-rise packs to the fire floor while wearing full turnout gear 9 Moving additional equipment (tools, extra air tanks, etc.) to staging area immediately below the fire floor
9 Breaking through a roof while on a ladder or pitched roof 9 Using a pike pole to pull down a ceiling
9 Dragging a charged hose through a fire site 9 Directing a hose for an extended period of time 9 Laying a hose to a fire site from a distant hydrant
Rescuing a victim from a roof or window using a ladder Raising ladders while under-manned Using an axe while on a ladder
Ladder Work
Entry through steel security doors using hand tools
Forcible Entry ~ _ ~
.9 Using hand tools and power equipment to open a wall
Extrications
Using tools in confined areas to extricate victims Using heavy hydraulic equipment in auto extrications Moving victims from damaged car or collapsed building Moving and salvaging fumiture
Extended Procedures
Fighting fires for extended time period and conducting lengthy extrication procedures (automobile crashes, industrial fires, train derailment, etc.)
Emergency Medical
Operations
Carrying first response kits to accident scene Moving victims from multi-story buildings using stairways Moving patients onto and off stretchers & loading stretchers/gumeys into ambulances
FIGURE 7.4 Typical fire fighting and emergency medical service activities involving ergonomic hazards (adapted from U.S. Fire Administration, 1996: Fire and Emergency Medical Services Ergonomics).
In formulating a comprehensive medical surveillance program for emergency responders, careful assessment of ergonomic risk factors must be undertaken in stepwise fashion: 1. Identification of specific actions and activities that may result in ergonomic stress, including not only those activities associated with on-site incident operations (Fig. 7.4), but also all activities related to (a) responding
162
7 Medical Surveillance
to/and returning from the incident site, (b) postemergency clean-up, replacement and refurbishing, and (c) all other nonemergency operations 2. Identification of specific symptoms and syndromes to be associated with different types of ergonomic stress (Table 7.5), with particular emphasis on (a) target organs and (b) personnel risk factors (e.g., level or degree of response activity associated with ergonomic stress, age, physical condition) 3. Establishment of appropriate reporting procedures and personnel training program that promote timely notification of medical authority regarding personnel complaints and symptoms
Critical Incident Stress
All persons may be presumed to operate within a range of individual capacity to cope with events and circumstances that may vary from quite normal to extraordinary. Of course, just what is normal and what is extraordinary depends upon the individualmnot necessarily as a conscious decision or perception, but simply as an experiential fact. When the individual experiences an incident that essentially overwhelms his or her capacity to cope, that incident may be described as being a critical incident; the consequence of a critical incident to the mental and physical well-being of the person who experiences it is known as critical incident stress. Critical incident stress is a common phenomenon in extreme circumstances, such as circumstances involving mass death, co-worker suicide, injury, and death of children. While such circumstances are frequently encountered by emergency response personnel, the frequency of encounter certainly does not immunize response personnel against subsequent critical incident stress, nor does it alleviate the potential severity of critical incident stress due to many other circumstances of emergency response, including (and perhaps, especially) a prolonged and extremely hazardous rescue effort conducted without success. Critical incident stress is not only a common but also a quite natural phenomenon that does not in itself indicate any pathological state. People react extraordinarily to extraordinary events, and that immediate distress experienced by any person involved in a horrifying incident typically does lessen with the passage of time. However, the actual rate of psychological recovery from "the extraordinary" to "the ordinary" is highly variable from person to person (Fig. 7.5), ranging from weeks to months. Unfortunately, there is always a small probability that an individual will not return to a state of fully functional n o r m a l c y ~ t h a t the critical incident stress evolves into a persistent and profound state of post-traumatic stress disorder wherein the individual suffers substantial disability.
163
Types of Medical Analysis T A B L E 7.5 Types of Cumulative Trauma Disorders (Adapted from U.S. Fire Administration, 1996: Fire and Emergency Medical Services Ergonomics)
Hand & Wrist
Neck & Back
9 Tendinitis: Inflammation of a tendon
9 Tension neck syndrome: Neck soreness, mostly related to static loading or tenseness of neck muscles
9 Synovitis: Inflammation of a tendon sheath 9 Trigger finger: Tendinitis of the finger, typically locking the tendon in its sheath causing a snapping, jerking movement 9 DeQuervain's disease: Tendinitis of the thumb, typically affecting the base of the thumb
9 Posture strain: Chronic stretching or overuse of neck muscles or related soft tissue 9 Degenerative disc disease: Chronic degeneration, narrowing, and hardening of a spinal disc, typically with cracking of the disc surface 9
9
9
Ganglion cyst: Synovitis of tendons of the back of the hand causing a bump under the skin Digital neuritis: Inflammation of the nerves in the fingers caused by repeated contact or continuous pressure
9 C a r p a l t u n n e l syndrome: Compression of the median nerve as it passes through the carpal tunnel
Herniated disc: Rupturing or bulging out of a spinal disc
9 Mechanical back syndrome: Degeneration of the spinal facet jointa (parts of the vertebrae) 9 Ligament sprain: Tearing or straining of a ligament (the fibrous connective tissue that helps support bones) 9
Muscle strain: Overstretching or overuse of a muscle continues
By the nature of their work, emergency response personnel are at special risk with respect to critical incident stress and posttraumatic stress disorder. After all, each incident presents a wide range of both environmental and psychological sources of stress (Fig. 7.6), any one or combination of which may prove sufficient to overwhelm the individual's capacity to cope. Signs and symptoms of both critical incident stress and impending posttraumatic stress disorder are recognized as being of the following types: 9 Cognitive (pertaining to individual's state of awareness or capacity to make judgments) 9 Emotional (pertaining to the nature of an individual's feelings) 9 Behavioral (pertaining to objectively observed interactions of an individual with others and the environment) 9 Physical (physical and physiological aspects of the body)
164
7 Medical Surveillance
T A B L E 7.$~continued
Elbow & Shoulder 9 Epicondylitis ("tennis elbow"): Tendinitis of the elbow
9 Bursitis: Inflammation of the bursa (small pockets of fluid in the shoulder and elbow that help tendons glide)
9 Radial tunnel syndrome: Compression of the radial nerve In the forearm 9 Thoracic outlet syndrome: Compression of nerves and blood vessels under the collar bone
9 Rotator cuff tendinitis: Tendinitis in the shoulder
Legs 9 Subpatellar bursitis ("housemaid's knee"): Inflammation of patellar bursa
9 Shin splints: Microtearsand infammation of muscle away from the shin bone
9 Patellar synovitis ("water on the knee": Inflammation of the synovial tissues deep in the knee joint
9 Plantar fascitis: Inflammation of fascia (thick connective tissue) in the arch of the foot
9 Phlebitis: Varicose veins and related blood vessel disorders (from constant standing)
9 Trochanteric bursitis: Inflammation of the bursa at the hip (from constant standing or bearing heaving weight)
Signs and symptoms of critical incident stress in emergency response personnel (Fig. 7.7) should not be viewed as sufficient in and of themselves to initiate immediate intervention by medical authority. However, the emergency service safety officer should take due caution to observe the progress of such signs and symptoms over time. However, signs and symptoms typically associated with the impending development of posttraumatic stress syndrome (Fig. 7.8) must trigger immediate intervention by appropriate medical authority. Of course, in any comprehensive medical surveillance program, proactive approaches to health maintenance must be given priority. With respect to the dangers of critical incident stress, careful attention must be given to the implementation of programs, procedures, and techniques that help personnel to reduce stress before that stress becomes a significant problem. Many programs have been developed and are readily available through private consultants, governmental agencies (e.g., U.S. Fire Administration), professional organizations, and community services. Such programs typically include several of the following types of stress reduction techniques:
165
Types of Medical Analysis ~ 90-95
Immediate distress
P e
r c e
Highlyvariableratesof individualrecovery
n t
A f f
~
20-40%
e
Profound post traumatic stress disorder
- 5-20%
c
t e
d W'dhin
After3 weeks
After 1year
After6 months
24
hours
Time after Critical Incident
Incident FIGURE 7.5 Typical pattern of development of critical incident stress over time (based on data and information provided by J. Mitchell and G. Bray, 1990: Emergency Services Stress. Englewood Cliffs: Prentice-Hall, Inc.).
Explosions] r___[ Poor Leadership
Exposure to Radiation HighNoise ] ] Building I Level Collapse Extreme ]] Hostile ] Temperature / ] People ]
C.rc,oo,en,c H Agents
~
]
Fearof Making ]
I
Environmental Stressors
Psychological Stressors
FIGURE 7.6 Environmental and psychological stressors that may result in the development of critical incident stress (based on information provided by U.S. Fire Administration, 1991: Stress Management: Model Program for Maintaining Firefighter Well-Being [FA-100]).
166
7 Medical Surveillance
Cauti0
Behavioral
Increased smoking and/or alcohol intake Increased or decreasedfood intake Change in interactions with others
a u t l o n
~11~
vii
Caut
. 9
Excessivehumor and/or silence Suspiciousness
O g n i
Confusio~~.~ 9
Withdrawal
t
Calculationd i f f i c u l t i e s ~ Lowerodattention span ~ Seeingan eventover and over Disruptionin logical thinking4c111~/~4r
i V
P~176 c~176 Bad m ~
/
J
~
/ "
Grief
~1~
~
Wishingto hide 0 Feeling overwhelmed t Feeling Identification with victim lost \~,.., Uncertainty~ feelings 0
/Na
Cauti
Caution
JL
~ "~,,.,.Antici patory anxiety usea \ ~ Feeling abandoned. Tremors ~ o n Fatigue
Discoordination~
Cauti0
Upset stomach Rapid heart rate Shakes ry mouth Sleep (n Muscleaches Profusesweating ~ ' - ~ j 9 Vision problems \ I Q 1 1 T1 Chills Diarrhea \ ~ ~ 4 ~ , ~ J on
0.,ur0.n.,..
Physical
FIGURE 7.7 Behavioral, physical, cognitive, and emotional symptoms of critical incident stress that require cautionary monitoring (based on information provided by: (a) J. Mitchell and G. Bray, 1990: Emergency Services Stress. Englewood Cliffs: Prentice-Hall, Inc.; and (b) U.S. Fire Administration, 1991: Stress Management: Model Program for Maintaining Firefighter Well-Being [FA-100]).
9 Centralized Relaxation (meditation, selective awareness, brainwave biofeedback) 9 Peripheral Relaxation (progressive muscle relaxation, yoga, breath control, biofeedback) 9 Time management 9 Cognitive reappraisal 9 Aerobic physical exercise 9 Diversionary techniques (e.g., vacation planning, hobbies, group activities)
Types of Medical Analysis
167
Behavioral
Dang
er
Significantchangesin speech patterns
Excessively angry outbursts
/ Dang Antisocialacts(e.g.,violence, anger anger ,
Extreme hyperactivity
Cryingspells o
g n i
V
Panic reactions
Severedisorientation Serious disruption
t ! II
-'-"
General mental confusion
Inappropriate emotions
in thinking
General loss of control
Problems recognizing familiar people
Shock-like state
Hyperalertness
~"
m
Phobic reactions
r Excessive
D
g ~ Dizziness v~ an
Danger
el"
D
Signsof severe shock
~ /
0
t i
n
0
a
an
Excessive dehydration Cardiac arrhythmias Collapse from exhaustion Blood in stool
Difficultyin breathing
Physical
a n g e l
~
FIGURE 7.8 Behavioral, physical, cognitive, and emotional symptoms of critical incident stress that require immediate intervention (based on information provided by: (a) J. Mitchell and G. Bray, 1990: Emergency Services Stress. Englewood Cliffs: Prentice-Hall, Inc.; and (b) U.S. Fire Administration, 1991: Stress Management: Model Program for Maintaining Firefighter Well-Being [FA-100]).
A particularly important approach to stress management, which typically includes both proactive and reactive elements, is the development of a critical incident stress debriefing (CISD) team. CISD teams are typically composed of at least one mental health professional and two or more members who may be drawn from emergency response personnel, other emergency support services (e.g., hospital administrator), local clergy, and other community services. Some CISD teams serve police, firefighters, and emergency response medical personnel in a multiagency and multijurisdictional setting; some operate within the context of a single organization. The basic functions of a CISD team generally are:
168
7 Medical Surveillance
9 To acquaint personnel with methods for recognizing and reducing both on- and off-the-job stress 9 To train personnel in the use of specific techniques to reduce stress in emergency response situations 9 To provide assistance to personnel who are experiencing stress 9 To serve as a referral service for personnel who need additional support services Another approach to stress management in emergency response services is the member assistance program (MAP), which is also sometimes referred to as the employee assistance program (EAP). An EAP or MAP is essentially a referral program (as opposed to a treatment program) designed to assist personnel with respect to personal problems (including drug and alcohol abuse) that can affect job performance. Fire service MAPs (addressed by NFPA 1500-1987) are sometimes used to promote the general health of personnel, including such activities as family orientation and education programs on weight control, stress reduction, and hypertension. While the recent emergence of such programs as CISD teams and MAPs (EAPs) offers many alternative approaches to stress management, it must be emphasized that such programs typically require significant time and effort to design and implement. Given the very sensitive nature of the issues involved and the potential effect of such programs on mental and emotional health, no organization should undertake to develop either of these programs except with the professional advice of community medical authorities and/or professional organizations having direct experience in both their design and implementation.
Audiometric Testing While audiometric testing is most often included in standard medical monitoring programs, there are many instances where this is not done; therefore, special attention must be given to this issue because it is particularly important in emergency response not simply as a matter of the responder's health, but also of his or her safety during incident operations. In the United States, regulations include specific requirements regarding the certification of (a) persons performing audiometric testing, (b) testing devices and methodology, and (c) types and frequency of audiograms (29 CFR 1910.95(g)). While such requirements may vary from nation to nation, certain aspects of audiometric testing should be emphasized as being of universal concern: 1. The baseline audiogram is a hearing test conducted on an employee shortly following exposure to noise above the action level. As
Types of Medical Analysis
169
TABLE 7.6 Noise Exposure Limits Promulgated by OSHA and Recommended by American Conference of Governmental Industrial Hygienists
-- ACGIH Standards---
If these levels are exceeded, engineering controls will be used to reduce sound to acceptable levels or hearing protectors will be used
Duration (hours/day)
Sound Level (dB)
16 8 4 2 1 1/2 1/4 1/8
80 85 90 95 100 105 110 115
--- O S H A Standard - Whenever noise exposures equal or exceed an 8-hour time-weighted average (TWA) of 85 dBA, a continuing and effective hearing conservation program shall be instituted
implied by the term "baseline," the objective of this audiogram is to define the normal hearing capacity of the employee in the absence of any workrelated impairment. Subsequent audiograms can thereafter be compared with the baseline audiogram to detect work-related hearing impairment and, therefore, the need for appropriate revisions to response service policies and practices regarding hearing protection. Given the importance of the baseline audiogram, it is imperative that it be completed before work-related noise above action levels (Table 7.6) results in actual hearing impairment. Also because noise can cause short- as well as long-term hearing impairment (known, respectively, as temporary threshold shifts [TTS] and permanent threshold shifts [PTS]), it is necessary that the affected individual avoid or otherwise be protected from noise prior to examination for a baseline audiogram. In the United States, the standard requires that the baseline audiogram of an employee be established within 6 months (or, where mobile testing vans are utilized for the purpose, within 1 year) of the employee's first exposure at or above the action level and that the employee not be exposed to work-related noise for least 14 hours immediately preceding the test. 2. Subsequent audiograms should be obtained for affected employees over short enough time intervals to ensure the early detection of hearing impairment. In the United States, the standard rule is that audiograms for
170
7 Medical Surveillance
employees be obtained at least annually. Longer intervals not only lead to an increased risk of permanent threshold shifts in specific individuals, but may also result in progressively expanding hearing risks to the emergency response team. 3. In comparing baseline and subsequent (at least annual) audiograms, the focus is on detecting an impairment of hearing. The action level for such a determination is what is called a standard threshold shift which, in the United States, is a change in hearing (relative to the baseline audiogram) of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. American OSHA regulations also provide for (but do not mandate) the standardized adjustment of annual audiograms for the aging process in making the determination of a standard threshold shift. The safety officer is advised that the decision as to whether or not to adjust annual audiograms for age should not be left to medical judgment alone because this decision has broad implications that go well beyond the professional purview of any attending physician, including: A. Correcting an annual audiogram for aging is basically equivalent to lessening any observed difference between baseline and annual audiograms, and this, in turn, results in the removal of a possibly desirable safety margin. Of course, by not correcting for age, the safety officer may cause an age-related hearing loss to be falsely attributed to workplace exposure. B. Even where there may be good reason to exercise this option, serious consideration should be given to the relevance of the database used to perform the age adjustment. For example, are the data (even if provided by regulatory authority) biased to particular national, cultural, or other social (including gender) groups? Is the database current? What is the extent of professional consensus regarding both the utility and the limitations of the database? 4. Where the comparison of an employee's baseline and annual audiogram reveals a standard threshold shift, it is the obligation of the employer to take immediate responsive action. The first action is, of course, informing (in writing) the affected person. The second action is implementing "appropriate" correction. Determining what constitutes appropriate corrective action is certainly highly problematic because it encompasses not only regulatory mandates, but other considerations well. Whether corrective action can be taken without continuing to place other responding team members at risk due to potential failure in communication with hearing-impaired personnel is certainly of major concern in any emergency response service. If a standard threshold shift is attributed to or aggravated by the noise attendant to work-related noise, American OSHA regulations are clear about several required corrective actions, including:
Programmatic Review
171
9 Other personnel who work under similar work-related conditions as those persons affected by a standard threshold shift and who do not use hearing protectors will be fitted with hearing protectors, trained in their use and care, and required to use them 9 Other personnel who work in similar work-related conditions as those persons affected by a standard threshold shift and who do use hearing protectors will be refitted and retrained in the use of hearing protectors and, if necessary, provided with protectors offering greater noise attenuation 9 The person affected by the work-related standard threshold shift will be referred to a clinical audiological evaluation or otological examination PROGRAMMATIC REVIEW
Once implemented, a medical surveillance program must be viewed as an essential lifeline for emergency response personnel and should therefore be carefully monitored for effectiveness and efficiency. It is especially important that there be at least an annual review of the entire program, with particular care given to the following items: 1. A case-by-case review of any incident involving any aspect of the surveillance program, including episodic exposure to hazardous agents, medical monitoring data that required specific follow-up actions, and discernible trends in the frequency of episodic events or in monitoring data that may signify the need to review operational response procedures, the use of personal protective clothing and equipment, and personnel training requirements, 2. The need to include newly developed medical monitoring tests or to delete or modify other tests (e.g., frequency, methodology) in light of stateof-the-art developments in medical surveillance, changes in response service responsibilities and capabilities, or changes in regulatory requirements or applicable health and safety standards, and 3. Performance evaluation of medical service contractors, including attending physicians and analytical laboratories, with particular emphasis on (a) the timeliness, comprehensiveness, and clarity of written reports and recommendations, (b) adequacy of technical and scientific documentation, and (c) satisfaction of response personnel. It is recommended that, during this annual programmatic review, contracted medical service personnel be requested to (a) present an oral review of findings to date regarding their own quality-control management studies, and (b) discuss their own recommendations regarding any potential changes in the surveillance program.
PERSONAL PROTECTIVE CLOTHING AND EQUIPMENT
INTRODUCTION
Personal protective clothing (PPC) and equipment (PPE) are selected only after all managerial (sometimes called "administrative") efforts and potential engineering controls have been scrutinized toward the objective of minimizing risk. Managerial efforts include alternative procedures and protocols used in incident response as well as those used to conduct normal offsite activities, such as cleaning and maintenance. Engineering controls include alternative uses of barriers, space and area-ventilation (e.g., vehicular ventilation systems for ambulances; spatial isolation of hazards (e.g., biohazard disposal area, on-site decontamination area, hazardous runoff collection system) to confine hazardous materials and/or conditions within areas under management control. PPC and PPE must be viewed as the last available means of controlling responder risk and, therefore, the most sensitive to the consequence of failure. In short, any failure of PPC and/or PPE exposes the responder to immediate life-threatening risk. While protective clothing and equipment are specifically intended to protect the responder against risks otherwise uncontrolled by managerial procedures and engineering controls, PPC and PPE also present additional risks of their own, including impaired vision, mobility, and communication, as well as physical and psychological stress of the user. The objective must therefore be to achieve an effective and assured balance between the risks attendant to the incident and the risks inherent in the use of PPC and PPE, while avoiding both over- and under-protection.
172
Selection of PPC and PPE
173
S E L E C T I O N OF PPC A N D PPE
A wide range of factors must be considered in the selection of PPC and PPE, ranging from general criteria of durability and comfort to highly specific criteria for assessing the capacity of materials to withstand chemical and physical agents and conditions. Examples of basic categories of factors to be considered include: 9 Design features (e.g., sizes and other options, easing of donning, accommodation to use of diverse garment add-ons as well as ancillary equipment, restriction of mobility, visibility in dark, color, weight, comfort for wearer, ease of cleaning and decontamination, ease of field evaluation of functional integrity) 9 Chemical resistance (e.g., permeation of chemical through material; discoloration, loss of physical strength, and other degradation due to chemical interaction; penetration of liquids, gases, vapors and mists through zippers, seams, closures, seals or material imperfections) 9 Physical quality (e.g., resistance to wear, tear, puncture, and abrasion; pliability and flexibility under variable environmental conditions; susceptibility to shrinkage; integrity under extremes of temperature; flame resistance; breathability; resistance to decontamination procedures and solutions; resistance to physical shock and vibration; resistance to static electrical charge and electric current) 9 Vendor-related factors (e.g., ready availability of replacement parts, cost, special servicing requirements, available customization) 9 Other factors (e.g., proven effectiveness, use by other similar emergency services, user complaints, professional certification of meeting appropriate engineering standards, documented failures, state-of-the-art technology, maintenance requirements, service life) No selection of PPC or PPE should be made without full documentation of (a) design and engineering specifications provided by manufacturers, (b) relevant standards, specifications and guidelines, including those promulgated by governmental agencies (e.g., OSHA; NIOSH; EPA; U.S. Fire Administration) and professional organizations (e.g., National Fire Prevention Association [NFPA], American Conference of Governmental Industrial Hygienists [ACGIH], American Society for Testing and Materials [ASTM], and (c) available methods and procedures for conducting visual inspections and field assessments (Table 8.1) of critical parameters of PPC and PPE performance. Much of this information is today readily available via the internet, especially through internet links and networks accessible through governmental agencies, including:
174
s Personal Protective Clothing and Equipment
TABLE 8. I RecommendedChemicals for Field Evaluation of the Performance of Protective Clothing (Adapted from U.S. Department of Labor, OSHA. OSHA Technical Manual. OSHA Electronic Reference Library)
-Note
U.S. EPA has developed a portable test kit that allows field qualification of protective clothing materials within one hour using these chemicals.
Use of this kit may overcome the absence of specific data and provide additional criteria for selection of appropriate clothing.
Chemical
--
Acetone Acetonitrile Ammonia 1,3-Butadiene Carbon disulfide Chlorine Dichloromethane Dietheylamine Dimethyl formamide Ethyl acetate Ethylene oxide Hexane Hydrogen chloride Methanol Methyl chloride Nitrobenzene Sodium hydroxide Sulfuric acid Tetrachloroethylene Tetrahydrofuran Toluene
--
Class
---
Ketone Nitrile Strong base gas Olefin gas Sulfur-containing organic Inorganic gas Chlorinated hydrocarbon Amine Amide Ester Oxygen heterocyclic gas Aliphatic hydrocarbon Acid gas Alcohol Chlorinated hydrocarbon gas Nitrogen-containing organic Inorganic base Inorganic acid Chlorinated hydrocarbon Oxygen heterocyclic Aromatic hydrocarbon
9 CDC (Centers for Disease Control) http://www.cdc.gov/cdc.html 9 EPA (Environmental Protection Agency) http://www.epa.gov/ncepihom/index.html 9 U.S.FA (U.S. Fire Administration) http://ww.usfa.fema.gov/pubs 9 FEMA (Federal Emergency Management Administration) http://www.nrt.org/nrt~ome.nsf 9 NCID (National Center for Infectious Diseases) http://www.cdc.gov/ncidod/ncid.htm 9 NIOSH (National Institute of Occupational Safety and Health) http://ftp.cdc.gov/niosh~omepage.html 9 NRT (National Response Team) http://www.nrt.org/nrt~ome.nsf 9 OSHA (Occupational Safety and Health Administration) http://www.osha.gov/
Protective Clothing and Ensembles
175
PROTECTIVE C L O T H I N G A N D ENSEMBLES
Protective clothing for emergency responders is inclusive of individual items (e.g., bib overalls, helmet, bunker coat) as well as ensembles, which are collections of items that are integrated to meet the needs of a specific condition (e.g., approach suit, fragmentation suit) or constellation of risks (e.g., hazardous chemicals). Each item or ensemble should be considered to offer certain types of protection as well as to impose specific limitations. Some ensembles are recommended on the basis of generic types of protection required, such as splashes of hazardous chemicals, chemical vapors, and hazardous dusts (Table 8.2). Other ensembles are recommended on the basis of level of protection required under certain emergency conditions, such as degree of protection required for skin, eyes, and respiratory system when working with hazardous chemicals (Table 8.3). Still other ensembles are defined essentially by the type of emergency-related mission undertaken, such as search and rescue missions under a wide range of environmental factors. For example, urban search and rescue missions are classified as involving three distinct sets of conditions: (a) technical rescue, (b) swift water rescue, and (c) contaminated water diving. Technical rescues are typically land-based rescues where the principal hazards are physical, such as encountered in the collapse of structures; the protective turnout clothing usually worn for firefighting is too bulky or heavy for responders who must extricate victims from collapsed debris. Protective clothing and ensembles used in such circumstances (Table 8.4) must be flame resistant, but also lighter and permissive of greater physical flexibility than that accorded by typical fire fighting gear. Principal criteria used for selecting PPC and PPE for technical rescue include: 9 Protection from physical hazards (abrasion, tears, cuts, and punctures) 9 High degree of visibility (including light and dark conditions) 9 Thermal and physical comfort, fit, and mobility 9 Protection from airborne particulates 9 Limited flame and heat protection 9 Limited chemical flash fire protection 9 Limited electrical exposure protection 9 Minimal chemical protection 9 Minimal protection from biological fluids Swift water rescue primarily involves the risk of drowning not only through the press of water but also through entanglement, as well as hypothermia. Appropriate criteria for selecting PPC and PPE for swift water rescue (Table 8.5)include:
176
8 Personal Protective Clothing and Equipment
T A B L E 8.2 Types of Protective Clothing for Full-Body Protection(Adapted from U.S. Department of Labor, OSHA. OSHA Technical Manual. OSHA Electronic Reference Library)
Description
T y p e of Protection
User Considerations
,,
II
IOne-piece garment; boots and gloves may be integral, attached and replaceable, or separate
IJacket, hood, pants or bib overalls, and one-piece coveralls
I Fully sleeved and gloved apron; separate coverings for arms and legs; commonly wom over nonencapsulating suit
IGloves, helmet, running or bunker coat, running or bunker pants
I
Fully Encapsulating Suit Protects against splashes, dust, gases and vapors
I
Does not allow body heat to escape; may contribute to heat stress in wearer, particulady if worn in conjunction with a closed-circuit SCBA; a cooling garment may be needed; impairs worker mobility, vision, and communication .,,
Nonencapsulating Suit Protects against splashes, dust, and other materials, but not against gases and vapors; does not protect parts of head or neck
Aprons, Leggings, and Sleeve Protectors Provides additional splash protection of chest, forearms, and legs
]
Do not use where gas-tight or pervasive splashing protection is required; may contribute to heat stress in wearer;, tape-seal connections between pant cuffs and boots and between gloves and sleeves i
, J
Whenever possible, should be used over a nonencapsulating suit to minimize potential heat stress; useful for sampling, labeling, and analysis operations; should be used only when there is a low probability of total body contact with contaminants ....
Firefighters' Protective Clothing Protects against heat, hot water, and some particles; does not protect against gases and vapors, or chemical permeation or degradation. NFPA Standard No. 1971 specifies that a garment consists of an outer shell, an inner liner and a vapor barrier with a minimum water penetration of 25 Ibs/in2 to prevent passage of hot water
I
Decontamination is difficult; should not be worn in areas where protection against gases, vapors, chemical splashes or permeation is required
continues
9 Flotation (buoyancy) 9 Insulation from cold water exposure 9 Protection from physical hazard (abrasion, tears, cuts, and punctures) 9 High degree of visibility (in light and dark) 9 Physical and thermal comfort, fit, and mobility 9 Limited chemical protection 9 Limited protection from biological fluids
177
Protective Clothing and Ensembles T A B L E 8.2--continued
Description
T y p e of Protection
User C o n s i d e r a t i o n s I I
Proximity Garment (Approach Suit)
I
One- or two-piece overgarment with boot covers, gloves and hood of aluminized nylon or cotton fabric; normally worn over other protective clothing, firefighters' bunker gear, or flame-retardent coveralls
I Blast and fragmentation
vests and clothing, bomb blankets, and bomb carriers
IVarious types of protective clothing designed to prevent contamination of the body by radioactive particles
I
Protects against splashes, dust, gases, and vapors
Does not allow body heat to escape; may contribute to heat stress in wearer, particularly if worn in conjunction with a closed-circuit SCBA; a cooling garmet may be needed; impairs worker mobility, vision, and communication
I
Blast and Fragmentation Suit Provides some protection against very small detonations; bomb blankets and baskets can help redirect a blast
Radiation-Contamination Protective Suit Protects against alpha and beta particles; does not protect against gamma radiation
I
Does not provide for hearing protection
.... J
Designed to prevent skin contamination; if radiation is detected on site, consult an experienced radiation expert and evacuate personnel until the radiation hazard has been evaluated ,
,,
Flame/Fire Retardant Coveralls Normally worn as an undergarment
Provides protection from flash fires
I
] m
Adds bulk and may exacerbate heat stress problems and impair mobility
While diving in contaminated water involves some of the same hazards as those encountered in swift water rescue, primary attention must be given to protecting personnel from exposure to biological and chemical contaminants. Criteria used for selecting PPC and PPE for contaminated water rescue (Table 8.6) include: 9 9 9 9
Integrity of breathing air supply Integrity of overall system to water penetration Insulation from cold water exposure Protection from physical hazards (abrasion, tears, cuts, and punctures) 9 Physical and thermal comfort, fit, and mobility 9 Protection from chemicals and biological fluids
Having made a preliminary selection of PPC and PPE on the basis of expected hazards, level of protection required, and/or type of response mission, it becomes absolutely vital to ensure that vendor specifications conform to appropriate technical standards(Table 8.7 ), including governmentally enforceable standards and professionally recommended standards. These
TABLE 11.3 Typesof Protective Ensembles (Adapted from NIOSH, USCG, and EPA, 1985.
Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities)
Level of Protection and Equipment
Overview of
A
The highest available level of respiratory, skin, and eye protection
Recommended: 9 Pressure-demand, full-facepiece SCBA or pressuredemand supplied air respirator with escape SCBA 9 Fully encapsulating, chemical resistant suit 9 Inner chemicalresistant gloves 9 Chemical resistant safety boots/shoes 9 Two-way radio
B
The chemical substance has been identified and requires the highest level of protection for skin, eyes, and the respiratory system based on either: 1.
2.
9
9
Optional: 9 Cooling unit 9 Coveralls 9 Long cotton underwear 9 Hard hat 9 Disposable gloves and boot covers
Recommended: 9 Pressure-demand, full facepiece SCBA or pressuredemand supplied air respirator with escape SCBA 9 Chemical-resistant clothing 9 Inner and outer chemical-resistant gloves 9 Chemical resistant safety boots/shoes 9 Hard Hat 9 Two-way Radio
Conditions for Use and Limitations
Protection
9
Substances with a high degree of hazard to the skin are known or suspected to be present, and skin contact is possible. Operations must be conducted in confined, poorly ventilated areas until the absence of conditions requiring Level A protection is determined. Fully encapsulating suit materials must be compatible with the substances involved.
The same level of respiratory protection but less skin protection than Level A.
The type and atmospheric concentration of substances have been identified and require a high level of respiratory protection, but less skin protection. This involves atmospheres
This is the minimum level recommended for initial site entries until the hazards have been further identified.
-- that do not meet the criteria for use of air-purifying respirators.
-- with IDLH concentrations of specific substances that do not represent a severe skin hazard, or
9 9
9 Optional: 9 Coveralls 9 Disposable boot covers 9 Face shield 9 Long cotton underwear
Measured (or potential for) high concentration of atmospheric vapors, gases, or particulates, or Site operations and work functions involving a high potential for splash, immersion, or exposure to unexpected vapors, gases, or particulates of materials that are harmful to skin or capable of being absorbed through the intact skin.
Atmosphere contains less than 19.5 % oxygen. Presence of incompletely identified vapors or gases is indicated by direct-reading organic vapor detection instrument, but vapors and gases are not suspected of containing high levels of chemicals harmful to skin or capable of being absorbed through intact skin. Use only when highly unlikely that the work will generate either high concentrations of vapors, gases, or particulates or splashes of material will affect exposed skin.
continues
179
Protective Clothing and Ensembles TABLE
8.3--continued
Level of Protection and Equipment
Overview of Protection
C
The same level of skin protection as Level B, but a lower level of respiratory protection
Recommended: 9 Full-facepiece, air purifying, canister equipped respirator 9 Chemical resistant clothing 9 Inner and outer chemical resistant gloves 9 Chemical resistant safety boots/shoes 9 Hard hat 9 Two-way radio
Conditions for Use and Limitations 9
9
9 9 9
Atmospheric contaminants, liquid splashes, or other direct contact will not adversely affect any exposed skin. The types of air contaminants have been identified, concentrations measured, and a canister is available that can remove the contaminant. All criteria for the use of air-purifying respirators are met. Atmospheric concentration of chemicals must not exceed IDLH levels. The atmosphere must contain at least 19.5 % oxygen.
Optional: 9 Coveralls 9 Disposable boot covers
9 9 9
Face shield Escape mask Long cotton underwear
D Recommended: 9 Coveralls 9 Safety boots/shoes 9 Safety glasses or chemical splash goggles 9 Hard hat Optional: 9 Gloves 9 Escal~. mask 9 Face shield
No respiratory protection; minimal skin protection
9 9
9 9
The atmosphere contains no known hazard. Work functions preclude splashes, immersion, or the potential for unexpected inhalation of or contact with hazardous levels of any chemicals. This level should not be worn in the Exclusion Zone. The atmosphere must contain at least 19.5 % oxygen.
180
8 Personal Protective Clothing and Equipment
TABLE 8.4 Technical Rescue Ensemble (Adapted from U.S. Fire Administration, 1993: Protective Clothing and Equipment Needs of Emergency Responders for Urban Search and Rescue Missions [FA-136])
Protective Garment Should cover the wearer's upper and lower torso, legs, and arms; may be one piece coveralls or two piece coat and trousers; two piece garments should have suffident overlap for mid-torso protection Materials should resist tearing, snagging, and abrasion due to physical environment Should be reinforced at elbows and knees; seam and closure strength should be equal to strength of material Should provide high visibility in the dark Material should be breathable and comfortable to wear for extended periods of time Materials should resist ignition when contacted by flame When exposed to convective and radiant heat, materials should prevent transmission of heat that could burn the wearer's skin. In hot environments, materials should not shrink Should maintain measured size when repeatedly cleaned Materials should resist static charge accumulation Supplemental liners should be provided which prevent chemical penetration of common fire scene chemicals and biologically contaminated liquids
Protective Hood Should cover the wearer's head and neck with the exception of those areas of the face which may be covered by a SCBA or air purifying respirator Material should be breathable and comfortable to wear for extended periods of time Material should resist ignition when contacted by flame. When exposed to convective and radiant heat, materials should prevent transmission of heat that could burn the wearer's skin. In hot environments, material should not shrink Should maintain measured size when repeatedly cleaned Material should resist static charge accumulation
Protective Gloves Should cover the wearer's hands to one inch above the wrist and include a wristlet which prevents entry of foreign objects into the glove Materials should resist tearing, cutting, punctures, or abrasion due to the physical environment Materials should be breathable and comfortable to wear for extended periods of time Should offer adequate dexterity and grip to handle tools and machinery Materials should resist ignition when contacted by flame. When exposed to convective and radiant heat, should prevent transmission of heat that could burn the wearer's skin. In hot environments, materials should not shrink Materials should insulate wearer from electrical currents Supplemental gloves should be provided which prevent chemical penetration of conunon fire scene chemicals and biologically contaminated fluids
continues
181
Protective Clothing and Ensembles TABLE
8.4~continued Protective Boots
Should cover wearer's foot from the bottom of the foot to a point eight inches above the foot bottom Should not have any exposed metal parts. Should include a ladder shank and non-metallic toe protective cap Upper materials should resist abrasion, cutting, or puncture due to the physical environment. Soles should resist abrasion and puncture Materials should resist ignition when contacted by flame. When exposed to convective and radiant heat, materials should prevent transmission of heat that could burn the wearer's skin. In hot environments, materials should not shrink Should maintain water-tight integrity following repeated flexing Should insulate the wearer from electrical currents Materials should prevent chemical penetration of common fire scene chemicals and biologically contaminated fluids
Protective Helmet Should cover the top of the wearer's head. Should resist impact on top and sides from falling objects Straps should keep helmet in place when impacted When exposed to convective and radiant heat, materials should prevent transmission of heat that could burn the wearer's skin. In hot environments, materials should not shrink
Goggles Should prevent impact of foreign objects to the eyes. Should keep particulates from reaching eyes Materials should resist ignition when contacted by flame. When exposed to convective and radiant heat, materials should prevent transmission of heat that could burn the wearer's eyes. In hot environments, materials should not shrink
Air Purifying Respirator Should be NIOSH certified. Should keep fine particulates from entering wearer's respiratory system
Ear Protectors Should meet ANSI requirements for ear and hearing protection
182
8 Personal Protective Clothing and Equipment
TABLE 8.S Swift water Rescue Ensemble (Adapted from U.S. Fire Administration, 1993: Protective Clothing and Equipment Needs of Emergency Responders for Urban Search and Rescue Missions [FA-136])
Personal Floatation Device Should meet U.S. Coast Guard requirement for Type III or Type V Should include hardware for attaching lifeline Should be corrosion resistant and have sufficient strength to withstand swift water forces
Protective Dry Suit Should cover wearer's upper and lower torso, arms and legs. Should be easily and quickly donned Should prevent water penetration to parts of body covered (should include wrist, foot, and neck seals) Materials should provide insulation from cold water exposure for at least one hour Materials should resist tearing, snagging, and abrasion due to physical environment Should be reinforced at elbows and knees. Seam and closure strength should be equal to strength of material Should not shrink after cleaning or contact with warm water Should provide high visibility in the dark Materials should be breathable and comfortable to wear for extended periods of time Materials should prevent penetration of diluted chemicals and biological contaminants Materials should not retain contaminants following clean water rinsing
Protective Gloves Should be 5-fingered design and cover wearer's hands to one inch above the wrist Should be available in at least 3-sizes Should limit water penetration to hands and provide insulation from cold water exposure for at least one hour Materials should resist tearing, cutting, and punctures due to physical environment Materials should be breathable and comfortable to wear for extended periods of time Should offer adequate dexterity and grip to tie knots and operate a knife Should not slip off wearer's hand if inner glove is worn Retention straps should not become loosened by use. Metal parts should not corrode or rust Materials should prevent penetration of diluted chemical and biological contaminants. Should not retain contaminants following dean water rinsing
continues
183
Protective Clothing and Ensembles TABLE 8.5mcontinued
Personal Booties Should cover wearer's feet to one inch above the ankle Should limit water penetration to feet and provide insulation from cold water exposure for at least one hour Materials should resist tearing, cutting, puncture, and abrasion due to physical environment Soles should be slip-resistant and provide good traction under wet condition Should accommodate swimming fins Retention straps should not become loosened in use. Metal parts should not corrode or rust Materials should prevent penetration of diluted chemicals and biological contaminants Should not retain contaminants following clean water rinsing
Swimming Fins Should allow wearer to walk normally
Helmet Should cover top of wearer's head. Should resist impact on top and sides from floating or stationary objects Should be ventilated to allow passage of water. Should not have brim or other surfaces suceptable to swift water forces Metal parts should not corode or rust
Knife Should be single edged. Should remain in sheath when inverted and shaken
Whistle Should be non-metallic. Should not include a pall
standards are highly changeable due to changes in technology as well as actual field experience; it is therefore necessary to ensure the use of up-to-date standards, with full awareness of potential trends in both (a) materialsresearch and development, and (b) schedules of standard-setting processes (Table 8.8). Heat Stress
A key consideration regarding all PPC is its contribution to the wearer's beat stress. Heat stress may be manifest in several distinct symptomatologies, including:
184
8 Personal Protective Clothing and Equipment
TABLE 8.6 Contaminated Water Diving Ensemble (Adapted from U.S. Fire Administration, 1993: Protective Clothing and Equipment Needs of Emergency Responclers for Urban Search and Rescue Missions [FA-136])
Protective Dry Suit Should cover wearer's upper and lower torso, arms, legs, and feet. Should be hooded or have attachable hood Should prevent water penetration to parts of body covered (should include wrist, foot, and neck seals) Materials should provide insulation from cold water exposure for at least one hour Materials should be rugged and strong and resist tearing, snagging, and abrasion due to physical environment Wrist, ankle, or neck seal materials should be adjustable for sizing Wrist, ankle, or neck seal materials should resist cuts and punctures Should be reinforced at elbows and knees. Seam and closure strength should be equal to material strength Should provide high visibility in dark Materials should prevent penetration of diluted chemicals and biological contaminants. Materials should not retain contaminants following clean water rinsing
Protective Gloves Should mate directly to the dry suit Materials should prevent penetration of diluted chemicals and biological contaminants Materials should provide insulation from cold water exposure for at least one hour Materials should resist cuts, punctures, and abrasion due to physical environment Should offer adequate dexterity and grip to tie knots and operate a knife Should not retain contaminants following clean water rinsing
Protective Booties Should be a part of the drysuit (directly attached) Materials should prevent penetration of diluted chemicals and biological contaminants Materials should provide insulation from cold water exposure for at least one hour Materials should resist tearing, cutting, punctures, and abrasion due to physical environment Sole materials should resist puncture and wear due to abrasion. Soles should be slip resistant Should not retain contaminants following clean water rinsing
Swimming Fins Should be resistant to diluted chemicals
continues
185
Protective Clothing and Ensembles TABLE 8.6ucontinued
Helmet Should cover entire head and neck. Should mate directly to the dry suit with safety mechanism to avoid accidental removal Should be neutrally buoyant in water Should include non-return valve in breathing system. Should include emergency valve for connecting ball-out system Should have double exhaust (for demand diving helmets) Should have defogging mechanism. Should have shatter resistant face piece Should have equalizing device (to equalize air pressure in ears) Should include integrated communication system Should not retain contaminants following clean water rinsing
Full Face Mask Should enclose eyes, nose, and mouth. Should include integral second stage regulator In surface-supplied mode, should be used with bail-out block Should have equalizing device, automatic defogging mechanism, and earphone pockets Should have low volume, large buckles and wide straps, and modular communications components Should not retain contaminants following clean water rinsing
Dry Suit Underwear Should provide insulating performance even when wet. Must not produce lint
Communication System May be hard-wire or wireless system. Should be constructed of rugged materials Should have mechanism to attach electronics housing to tank harness or buoyancy compensator Exposed parts should be able to be decontaminated Should include back-up systems (line pull signals)
Compressed Air Supply Should be a low pressure (175 - 250 psi) compressor or series of high-pressure bottles Should include emergency air supply for diver (bail-out system)
continues
186
8 Personal Protective Clothing and Equipment
TABLE 8.6~continued
Air Manifold Box Should monitor air-pressure to diver. Should regulate high-pressure air to proper pressure for diver Should provide connection for top-side emergency air supply
Pneumofathom eter Should usually be contained in the air manifold box. Should be accurate to 0.25 % of the gauge's full scale
Umbilical Should be at least 250 ft long. Air supply hose should have minimal length change when pressurized Air supply hose should be at least 3/8 in. diameter Air supply hose should have rated pressure at least 50% higher than maximum pressure required by regulator or maximum diving depth Should resist kinking. Should include air-tight fittings and strong diving tether Should have individual umbilical components (hose, communications wire) connected with plastic cable ties Should include stainless steel ring to attach air supply hose to diver's harness
Weight Belt/Harness Materials should be compatible with diluted chemicals. Materials should not retain contaminants following clean water rinsing Should be plastic or rubber for easier decontamination. Should include minimum amount of weight possible Should be able to be quickly ditched in emergency. Should not include ankle weights
Diving Tether Should be attached to harness. Should include synthetic line compatible with diluted chemicals and strong enough to bear weight of diver Should not retain contaminants following clean water rinsing
SCUBA System Materials should be compatible with diluted chemicals. Should include bail-out block mounted on diver's harness Should include bail-out air bottle with first stage regulations. Should not retain contaminants following dean water rinsing
Bail-Out System Should include 5-minute air supply. Should include bail-out bottle, diver's harness, first-stage regulator, relief valve, submersible pressure gauge, quick disconnect whip/low pressure whip
Knife and Wire Cutter Should be single edged and sheathed. Should not fail out of sheath when inverted
Protective Clothing and Ensembles
187
T A B L E 8.7 Examples of Standards Related to Clothing Ensembles and Respirators (Based on Information Provided by U.S. Department of Labor, OSHA. OSHA Technical Manual. OSHA Electronic Reference Library)
Vapor-Protective Suit (NFPA Standard 1991) 9 Provides "gas tight" integrity Intended for response situations where no chemical contact is permissible 9 Equivalent to the clothing required for EPA Level A
Liquid Splash-Protective Suit (NFPA Standard 1992) Protection against liquid chemicals in the form of splashes, but not against continuous liquid contact or chemical vapors or gases 9 Equivalent to the clothing required for EPA Level B It is important to note that, by wearing liquid splash-protective clothing, the wearer accepts exposure to chemical vapors or gases becausa this clothing does not offer gas-tight performance The use of duct tape to seal clothing interfaces does not provide the type of encapsulation necessary for protection against vapors or gases
Support Function Protective Garment (NFPA Standard 1993) 9 Provide liquid splash protection but offer limited physical protection 9 May comprise several separate protective clothing components (i.e., coveralls, hoods, gloves, and boots) Intended for use in non-emergency, nonflammable situations where chemical hazards have been completely characterized Examples of support functions include proximity to chemical processes, decontamination, hazardous waste clean-up, and training. Should not be used in chemical emergency response or in situations where chemical hazards remain uncharacterized --- C a u t i o n a r y Note R e g a r d i n g R e s p i r a t o r s m Protective clothing should completely cover both the wearer and his or her breathing apparatus. In general, respiratory protective equipment is not designed to resist chemical contamination. Level A protection (vapor-protective suits) require this configuration. Level B ensembles may be configured either with the SCBA on the outside or inside. However, it is strongly recommended that the wearer's respiratory equipment be worn inside the ensemble to prevent its failure and to reduce decontamination problems. Level C ensemble uses cartridge or canister type respirators that are generally worn outside the clothing.
TABLE 8.8
NFPAStandardsRelatedto ProtectiveClothing and Equipment
,,
--
Standard--
---
Title---
NFPA 1971"
Protective Clothing for Structural Fire Fighting (includes hoods)
NFPA 1972
Helmets for Structural Fire Fighting
NFPA 1973
Gloves for Structural Fire Fighting
NFPA 1974
Protective Footwear for Structural Fire Fighting
NFPA 1975
Station/Work Uniforms for Fire Fighting
NFPA 1976
Protective Clothing for Proximity Fire Fighting
NFPA 1977
Protective Clothing and Equipment for Wildlands Fire Fighting
NFPA 1981
Open -Circuit Self-Contained Breathing Apparatus for the Fire Service
NFPA 1982
Personal Alert Safety Systems (PASS) for Fire Fighters
NFPA 1983
Fire Service Life Safety Rope, Harnesses and Hardware
NFPA 1991
Vapor-Protective Suits for Hazardous Chemical Emergencies
NFPA 1992
Liquid Splash-Protective Suits for Hazardous Chemical Emergencies
NFPA 1993
Support Function Protective Clothing for Hazardous Chemical Operations
NFPA 1999
Protective Clothing for Emergency Medical Operations
* NFPA 1971 incorporates NFPA 1972, 1973 & 1974
NFPA reviews and, as necessary in light of new developments in clothing and material technology and testing protocols, revises its standards on a 5-year cycle.
189
Protective Clothing and Ensembles
Relative Humidity 10% 20% T e m P e r a t u r e
CF)
104 102 i00 98 96 94 92 90 88
86
84 82 80 78 76 '74
98 97 95 93 91 89 87 85 82 80 78 77 75 72 70 68
,
104 i01 99 97 95 93 90 88 86 84 81 79 77 75 72 70
30%
40%
50%
60%
70%
80% 90%
110 108 105 i01 98 95 92 90 87 85 83 80 78 77 75 73
120 117 II0 106 104 i00 96 92 89 87 85 81 79 78 76 74
132 125 120 Ii0 108 105 I00 96 93 90 86 84 81 79 77 75
132 125 120 Iii 106 I00 95 92 89 86 83 80 77 75
128 122 115 106 i00 96 91 89 85 81 77 75
122 114 106 i00 95 91 86 83 78 76
122 115 109 99 95 89 85
79
77
Note: Add 10~ when protective clothing worn; add 10~ when in direct sunlight 80-90: Fatigue possible if exposure is prolonged and there is physical activity 90-105: Heat cramps and heat exhaustion if exposure is prolonged and there is physical activity 105-130: Heat cramps or exhaustion likely; heat stroke possible if exposure prolonged and there is physical activity
Above 130: Heat Stroke Imminent FIGURE 8. I
Determination of heat stress based on ambient temperature and relative humidity.
9 Heat cramps (caused by profuse sweating with inadequate replacement of electrolytes): muscle spasms and pain in hands, feet, and abdomen 9 Heat exhaustion (severe effects of dehydration and stress on body organs due to cardiovascular insufficiency): pale, cool, moist skin; heavy sweating; dizziness; nausea and fainting spells 9 Heat stroke (temperature regulation of body fails, with body temperature rising to critical levels, with increasing risk of death; immediate medical attention required): red, hot, dry skin; lack of or reduced perspiration; nausea; dizziness or confusion; strong, rapid pulse; coma As shown in Fig. 8.1, an increase in relative humidity results in increased risk of heat stress at any ambient temperature. While heat stress can
190
8 Personal Protective Clothing and Equipment
be a significant risk when working in encapsulating suits or other protective clothing, it is always a risk when undertaking any type of work in direct sunlight or under conditions of high temperature and relative humidity. There are several strategies that can prove useful for lowering the risk of heat stress. The worker who is acclimatized to working under hot conditions has a lower heart rate and body temperature than a worker who is not acclimatized. Acclimatization can most often be accomplished over a 6-day period. During the first day, only 50% of the normal workload and exposure-time is allowed, with 10% more added each day. For a particularly fit individual, acclimatization can be accomplished in 2 or 3 days. In an encapsulating suite, acclimated persons sweat more profusely than nonacclimated persons and are therefore more subject to the risk of dehydration. It is therefore necessary to provide for a drinking water program to ensure the proper replacement of water lost through sweating. Additional approaches for reducing heat stress include the use of the lightest and coolest PPC and PPE possible, along with the use of light-colored clothing that absorbs less heat than dark-colored clothing. Artificially produced shade (e.g., tarp canopy, beach umbrella) can significantly contribute to reducing heat exposure. Finally, cooling vests (often called "ice vests") may be worn, though many workers dislike cold so close to the skin. Cold Stress
In cold environments, a critical factor in the selection of PPC is cold stress, which includes hypothermia and the freezing of flesh. Hypothermia, a potentially catastrophic drop in body temperature with significantly reduced blood flow and rate of metabolism, is of particular concern during cold water diving operations. The freezing of flesh, with potential subsequent development of gangrene, is always a risk attendant to land operations in cold climates, especially when wind velocity acts to increase risk significantly (Fig. 8.2). Decontamination
Wherever possible and subject to the important constraints of effectiveness and cost, PPC and PPE should be selected to maximize the use of non-reusable clothing and equipment in order to minimize the need for decontaminating reusable clothing and equipment~an activity that presents its own risk to personnel and to environmental resources. However, most PPC and PPE items are, in fact, reusable (as well as costly} and must therefore be selected with careful consideration given to means and methods for re-
Protective Clothing and Ensembles
4s
191
40
3s
30
2s
9
Temperature (~ 20 zs zo
s
0
-s
-zo
-zs
-5
-I0
-15
-21
,|
W
5
i
43
37
32
27
22
10
34
28
22
16
I0
3
-3
-9
-15
-22
-27
-34
-40
15
29
23
16
9
2
-5
-Ii
-18
-25
-31
-38
-45
-51
20
26
19
12
4
-3
-I0
-17
-24
-31
-39
-46
-53
-60
25
23
16
8
1
-7
-15
-22
-29
-36
-44
-51
-59
-66
21
13
6
-2
-I0
-18
-25
-33
-41
-49
-56
-64
-71
20
12
4
-4
-12
-20
-27
-35
-43
-52
-58
-67
-75
19
II
3
-5
-13
-21
-29
-37
-45
-53
-60
-69
-76
18
i0
2
-6
-14
-22
-30
-38
-46
-54
-62
-70
-78
n
d S e e
d
40
(MPH) 45
16
II
6
0
43 to-22: Li~le danger for propedy clothed pe~on -24 to-71" Increasing danger; flesh may freeze -75 ~ - 7 8 : Great danger; flesh may freeze in 30 seconds FIGURE 8.2
Determination of cold stress based on ambient temperature and wind velocity.
moving and/or deactivating incident-related contaminants, including dirt and debris as well as chemical and biological agents (Table 8.9) so as to prevent any loss of integrity or functionality of the PPC and PPE. Available decontamination methods should be assessed for their compatibility with PPC and PPE materials in a rigorous manner (Fig. 8.3). Appropriate decontamination procedures, cleaning and disinfecting solutions, and associated equipment and materials should then be incorporated into SOPs for both incident-related and normal operations (Fig. 8.4).
Inspection
of PPC
In any response organization, written SOPs that give detailed instructions for periodic examination of protective clothing should be readily available and rigidly enforced. Different types and levels of inspections, as well as schedules, are most appropriately developed to cover the life-cycle of the clothing, including (a) receipt of the clothing from the manufacturer, (b) issuance of clothing to personnel, (c) preventive maintenance, prior to and following use (including use during training sessions), (d) receipt of personnel complaints or concerns, governmental or other alerts (e.g., manufacturers other response agencies) regarding field experience with similar clothing, and (e) upon replacement either in-kind or by substitution with other types, styles, or models.
192
8 Personal Protective Clothing and Equipment TABLE 8.9 Decontamination Methods (Adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Activities)
Removal 9 contaminant Removal 9 Water rinse, using pressurized or gravity flow 9 Chemical leaching and extraction 9 Evaporation/vaporization 9 Pressurized air jets 9 Scrubbing/scraping (commonly done using brushes, scrapers, or sponges and watercompatible solvent cleaning solutions) 9 Steam jets
Removal of Contaminated surfaces 9 Disposal of deeply permeated materials (e.g., clothing, floor mats, and seats) 9 Disposal of protective coverings, coatings
Inactivation 9 Chemical D e t o x i f i c a t i o n 9 Halogen stripping 9 Neutralization 9 Oxidation/reduction 9 Thermal degradation 9
Disinfection/Sterilization 9 Chemical disinfection 9 Dry heat sterilization 9 Gas/vapor sterilization 9 Irradiation 9 Steam sterilization
Regardless of the type and schedule of formal inspections, all personnel must understand that it is their responsibility to perform visual checks of PPC prior to, during, and immediately following use, with particular attention given to the following:
Protective Clothing and Ensembles NO
Is the method effective for removing contaminants? YES.
NO
I
193
Are the decontamination materials compatible with the hazardous substances present? . . . . . . ~ir YES
NO
Are the decontamination materials compatible with the materials to be decontaminated?
~
YES i
Do the decontamination materials ] or process pose health or safety | ~ hazards? Take additional measures to prevent contamination or find another decontamination method. Consult specialists if necessary
J
Ir YES Can appropriate protective measures be instituted? .
.
.
.
.
.
.
JF YES Method OK 1.~ to Use
FIGURE 8.3 Assessment of decontamination methods (adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Activities).
9 Check coding device (e.g., color, alpha-numeric, name) to ensure that the clothing is properly identified for use in the intended task 9 Visually inspect for imperfect seams, nonuniform coatings, tears, malfunctioning closures, improper seals 9 Check for pinholes 9 Check inside and out for any indications of chemical degradation, including discoloration, swelling, or stiffness 9 Flex material and look for cracks, wear, abrasion, or any other sign of deterioration 9 Pressurize gloves and hold under water to check for pinholes
194
8 Personal Protective Clothing and Equipment
Infection Control S t a n d a r d Operating Procedures
SOP # IC6: Post.Response
9
Upon retum to quarters, contaminated equipment will be revived and replaced with clean equipment. Supplie s of PPE on response vehicles will be replenished.
9
Contaminated equipment will be stored only in the decontamination area. Cleaning and decontamination will be performed as soon as practical.
9
Disposable equipment and other biohazard waste generated during on-scene operations will be stored in the biohazard disposal area in appropriate leakproof containers. Sharps containers, when full, will be closed and placed in the biohazard disposal area.
9 Gloves will be worn for all contact with contaminated equipment or materials. Other PPE will be used depending on splash or spill potential. Heavy-duty utility gloves will be used for cleaning, disinfection, or decontamination of equipment. 9
Eating, drinking, smoking, handling contact lenses, or applying cosmetics or lip balm is prohibited during cleaning or decontamination procedures.
9
Disinfection will be performed with a department-approved disinfectant or with a 1:100 solution of bleach in water. All disinfectants will be tuberculocidal and EPA approved and registered.
9 Any damaged equipment will be cleaned and disinfected before being sent out for repair. 9 The manufacturer's guidelines will be used for the cleaning and decontamination of all equipment. Unless otherwise specified: ;~ Durable equipment (backboards, splints, MAST pants) will be washed with hot soapy water, rinsed with clean water, and disinfected with an approved disinfectant or 1:100 bleach solution. Equipment will be allowed to air dry. > Delicate equipment (radios, cardiac monitors, etc.) will be wiped clean of any debris using hot soapy water, wiped with clean water, then wiped with disinfectant or 1:100 bleach solution. Equipment will be allowed to air dry. 9 Work surfaces will be decontaminated with an appropriate disinfectant after completion of procedures, and after spillage or contamination with blood or potentially infectious materials. Seats on response vehicles contaminated with body fluids from soiled PPE also will be disinfected upon return to station. Contaminated structural firefighting gear (turnout coats/bunker pants) will be cleaned according to manufacturer's recommendations found on attached labels. Normally, this will consist of a wash with hot soapy water followed by a rinse with clean water. Tumout gear will be air-dried. Chlorine bleach may impair the fire-retardant properties of structural firefighting gear and will not be used.
9
Contaminated boots will be brush-scrubbed with a hot solution of soapy water, rinsed with clean water, and allowed to air dry.
9 Contaminated work clothes (jump suits, T-shirts, uniform pants) will be removed and exchanged for clean clothes. Personnel will shower if body fluids were in contact with skin under work clothes. Contaminated work clothes will be laundered at the station using hot water. Under no circumstances will contaminated work clothes be laundered at home. Infectious wastes generated during cleaning and decontamination operations will be properly bagged and placed in the biohazard disposal area. F I G U R E 8.4 Example of SOP included in infection control program (adapted from U.S. Fire Administration, 1992: Guide to Developing and Managing an Emergency Service Infection Control Program [FA-112]).
For fully encapsulating suits, check operation of pressure relief valves; inspect fitting of wrist, ankle, and neck seals; check faceshield for cracks and other anomalies
Respiratory Protection
195
RESPIRATORY P R O T E C T I O N Air Contaminants
Air contaminants include a variety of solid and liquid particles that range greatly in size, from relatively large-size liquid chemical mists (>100~m) to progressively smaller particles, like dusts (e.g., foundry dust and fly ash [1-10001~m]), fumes and vapors (e.g., metallurgical fumes and oil smoke [0.001-1.0 ~m]; bacteria and fungal spores [0.1-1.0 ~m]), and, finally, gases. The size of an inhaled particle is a key determinant of the depth to which that particle can penetrate into the respiratory tract. While the depth of penetration is also influenced by the shape of the particle and whether inhalation is primarily through the nose or the mouth, the majority of larger dusts and mists can become deposited along the nasopharyngeal portion of the respiratory tract (above the larynx and including nasal passages), with progressively smaller particles progressing to the upper esophagus, to the tracheobronchial branch of the respiratory tract, and, finally, even to the alveoli of the lung. Particles deposited in nasal passages and within the throat can also ultimately enter the stomach via passage along the esophagus~demonstrating that inhalation, as a route of entry, can be equivalent to that other route of entry, ingestion. Given the range of potential deposition of inhaled particles within both the respiratory and gastrointestinal tract, various organs and tissues become exposed to the diverse health hazards associated with those particles, including such relatively mild acute afflictions as nasal irritation (e.g., certain chromium dusts), persistent sneezing (e.g., o-chlorobenzylidene malononitrile), and cough (e.g., chlorine), as well as life-threatening acute and chronic afflictions, such as pneumonia (e.g., manganese dusts in lower airways and alveoli), hemorrhage (e.g., boron vapors in alveoli), emphysema (e.g., aluminum abrasives in alveoli), and cancer (e.g., nickel dusts in nasal cavities and the lungs). Upon being inhaled, various gases, vapors, and mists (e.g., halogenated hydrocarbons, methyl ethyl ketone, methyl methacrylate) can pass directly from the alveoli (or the gastrointestinal tract) into the blood and, depending upon their differential solubilities in body fluids and tissue (e.g., fat), affect other tissues (e.g., bone), organs (e.g., liver), and systems (e.g., central nervous system). Of course, many air contaminants begin to exert their effect immediately upon entry into the blood by triggering an immunological response. For example, many organic dusts, such as cork, malt, and cheese dust and even those (e.g., pollen) that collect in air conditioners, as well as inorganic dusts (e.g., tungsten carbide, platinum salts, toluene 2,4-diisocyanate, nickel metal), can cause allergenic reactions in hypersensitive persons that can quickly become life threatening. Differential solubilities
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8 Personal Protective Clothing and Equipment
of air contaminants in body fluids and tissues, as well as their potential as immunological antigens, clearly illustrate that many inhaled contaminants are not simply respiratory hazards, but are in fact hazards to many different organs and tissues.
Action Levels
An action level is typically a numerical limit (but it may also be a qualitative situation) that triggers a protective response. In some few cases, action levels may be established by regulation pertaining to specific chemicals, such as benzene or formaldehyde. In most instances, action levels are established by common practice. For example, evacuation from an area containing flammable vapors is most often required whenever ambient concentrations attain 10% of the lower explosive limit (LEL). The rationale for any action limit is that protection must begin well in advance of an actual life- or health-threatening situation. In the absence of either an action level or even so much as a standard or guideline established by legal authority (which is by far the most common situation), a criterion for deciding whether or not the measured quality of an atmosphere requires the use of respiratory protection must be established. Sometimes, given the dearth of action levels and standards as compared with the seemingly limitless number of health and safety standards, the safety officer opts to require respiratory protection regardless of ambient concentrations. In normal operational situations (i.e., nonemergency), this practice should be strongly discouraged because the use of any protective clothing or devices always produces its own risk. Ideally, the objective should be to balance the risks that derive from the lack of specific protection with the risks that derive from wearing protective equipment. However, during an emergency, it is most often prudent to assume the worst case and prepare accordingly. This is usually done for any or all of several reasons: 9 Immediate response action is required even in the absence of specific data and information on ambient air concentrations of chemical or biological contaminants, and/or 9 Even in situations where ambient air concentrations of chemical contaminants are known, it is always possible that actual concentrations can vary significantly over the spaces to be penetrated by emergency response personnel, and/or 9 In some situations (e.g., fire, explosion, release of biological pathogens, any other situation resulting in chemical by-products of combustion or chemical reactions), there is no practical alternative but to implement the highest level of respiratory protection.
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197
Types of Respirators Any reputable manufacturer or supplier of respirators today offers potential clients detailed documentation regarding the broad range of available respirators and the specific uses and limits of each type. In no circumstance should the safety officer purchase any respirator without carefully examining this documentation or consulting with manufacturers' or suppliers' technical staffs. The basic types of respiratory protection devices (Fig. 8.5) may be briefly described as follows:
Air-Purifying Respirators These respirators use filter and/or sorbent materials to remove contaminants from inhaled air. They must not be used in atmospheres that may have either a deficiency (<19.5%) or an excess (>22.5%) of oxygen. 1. Mechanical filter respirator: Removes particles from the air; consists of a simple mesh material that fits over the nose and mouth and is tied with straps of strings behind the neck; some styles include a flexible metal strip that can be easily bent across nose bridge to enforce a more secure seal between face and mask; a comfortable, low-profile, lightweight respirator (often called simply a "paper" or "dust mask") for limited use; low-cost protection against dust, mist, and fumes, but not effective for gases, vapors, or nonabsorbable contaminants; modification of the standard dust mask is the "toxic dust mask," having smaller mesh size; no cleaning, disinfection, or spare parts required; the usual limit for use is set at 10 times the permissible exposure limit (PEL). 2. Chemical cartridge respirator: Either a disposable half-face respirator in which the cartridge is integral to the facepiece or a nondisposable half- or full-face respirator with one or two screw-on chemical cartridges that are specific for particular contaminants; use limited by ambient concentration of contaminants; expended cartridges may be replaced; easy to use; needs little cleaning and few if any spare parts; protection against gas, vapor, dust, and mists; limit is usually set at 10 times the PEL (but may be different) and is indicated on the cartridge. 3. Gas mask: A full-face mask to which is attached a relatively longlived canister containing sorbent materials that can remove toxic gases and particles; expended canisters may be replaced; offers a greater capacity for removing high ambient concentrations of contaminants than cartridge respirators; limits for ambient concentrations are specified on the canister. 4. Powered air-purifying respirator: A helmeted, hooded, or full-face mask containing one or more cartridges through which air is forced by an
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8 Personal Protective Clothing and Equipment
DisposableParticulateMask
--~ MechanicalFilter
DisposableHalf-Mask(IntegralCartridge& Filter) Air-Purifying t Must not be used when there is
-~ ChemicalCartridge
Half-Mask(ReplaceableCartridge& Filter) Full-Face(ReplaceableCartridge& Filter)
oxygen deficiency
-~
Gas Mask
~-~
_~ ~ _ ~Powered P u r Respirator i f yAir. n g
Continuous
Must be used when there is oxygen deficiency
t
PressureDemand AirFlow
~-~ ~
Self-Contained Breathing Apparatus
I
Full-Face(ReplaceableCartridge;Air Blower)
]
I Keeps face underpositivepressure;leaksflowoutward I
Flow
Demand Air Flow
Air-Supplying
Full-Face(Replac~bleCannister)
Keeps faceunderpositivepressure;leaksflow outward;suppliesair only whenuser inhales
I
Keeps maskunderpositivepressureduringboth inhalationand exhalation
I I
I
Closed-circuitrebreathingunit; exhaledair is recycled; carbon dioxideis removedand oxygenis added I Open-circuit,pressuredemandrespirator;exhaledair I directly ventedto outsideatmosphere I
FIGURE 8.5 Typology of respirators (adapted from information provided by Jean Letendre). Each respirator has specific limitations and requirements that must be assessed in light of sitespecific circumstances.
air blower; less exhausting for user than chemical cartridge or gas mask respirators; face- or belt-mounted blower that is battery powered; limits are usually set at 100 times the PEL (or as specified on the cartridge.
Air-Supplying Respirators These respirators consist of a helmet, hood, and full- or half-face mask that is provided air though a compressor compressed air cylinder. They
are used in atmospheres that may have a deficiency or an excess o f oxygen,
Respiratory Protection
199
or if the concentration of the contaminant vapors, gases, or particles may be immediately dangerous to life or beyond the capacity of an air-purifying cartridge or canister. 1. Continuous flow respirator: The facepiece is kept at positive pressure; air flow is outward from the mask, preventing contaminants from entering the facepiece; supplies clean, breathable air from a source independent of the contaminated air; the flow of air remains constant. 2. Demand air flow respirator: Supplies air only when the user inhales; exhalations are ejected directly to the atmosphere; flow of air is regulated by pressure valve. 3. Pressure demand air flow respirator: Supplies air when the user inhales or exhales; exhalations are ejected directly to the atmosphere; flow of air is regulated by pressure valve. 4. Self-contained breather apparatus (SCBA): Provides an independent air supply that is not mixed with the outside atmosphere and which may be either recycled or exhaled directly into the outside atmosphere; offers greatest respiratory protection available. SCBA may be of several types, including open- and closed-circuit units (for multipurpose response operations) and so called "escape-only" SCBA, which can only be used for a period of 5 to 15 minutes for the purpose of escaping a hazardous atmosphere (Fig. 8.6). In the United States, respirator types are subject to 42 CFR 84 regulations, which became effective in July 1995 (Fig. 8.7). These regulations provide for nine classes of filters (three levels of filter efficiency, each with three categories of resistance to degradation of filter efficiency) for nonpowered particulate respirators. The three levels of filter efficiency are 95, 99, and 99.97%; the three categories of resistance to degradation of filter efficiency are labeled N (Not resistant to oil), R (Resistant to oil), and P (oil Proof). Notice of NIOSH certification of nonpowered particulate respirators (Fig. 8.8) is available through the electronic reference library of NIOSH (http://ftp.cdc.gov/niosh~omepage.html).
General Procedures
A written respiratory protection program is mandatory and must include specific procedures that govern the proper use, maintenance, and replacement of respirators. The following examples of general procedures that apply throughout American industry illustrate the range of issues that must be addressed and adapted to the specific needs and managerial practices of any emergency response organization.
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8 Personal Protective Clothing and Equipment
Open-Circuit SCBA supplies clean air to the wearer from a cylinder; wearer exhales directly to the atmosphere Advantages Operated in a positive-pressure mode, open circuit SCBAs provide the highest respiratory protection currently available. A warning alarm signals when only 20-25% of the air supply remains
Disadvantages Shorter operating time (30 to 60 minutes) and heavier weight (up to 35 Ibs) than a closedcircuit SCBA. The 30 to 60-minute operating time may vary depending on the size of the air tank and the work rate of the individual
Closed-Circuit SCBA Recycles exhaled gases by removing CO2 with an alkaline scrubber and replenishing the consumed oxygen with oxygen from a liquid or gaseous source Advantages Longer operating time (up to 4 hours), and lighter weight (21 to 30 Ibs) than open-circuit apparatus. A waming alarm signals when only 20 to 25% of the oxygen supply remains. Oxygen supply is depleted before the COa sorbent scrubber supply, thereby protecting the wearer from CO2 breakthrough
Disadvantages At very cold temperature, scrubber efficiency may be reduced and CO2 breakthrough may occur. Units retain heat normally exchanged in exhalation and generate heat in the CO2 scrubbing operations, adding to danger of heat stress. Auxiliary cooling devices may be required. When worn outside an encapsulating suit, breathing bag may be permeated by chemicals, contaminating breathing apparatus and respirable air. Decontamination of breathing bag may be difficult
Note: Positive-pressure closed-circuit SCBAs offer substantially more protection than negative.pressure units, which are not recommended on hazardous waste sites.
Escape-Only SCBA supplies clean air from either an air cylinder or from an oxygen-generating chemical Advantages Jl Disadvantages Lightweight (10 pounds or less), low bulk, easy Cannot be used for entry. Provides only 5 to 15 to carry. Available in pressure-demand and minutes of respiratory protection, depending on continuous-flow modes the model and wearer breathing rate
F I G U R E 8.6 Advantages and disadvantages of different types of SCBA (adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Activities).
1. Respirators will be selected on the basis of the specific hazards to which individual personnel may be exposed in normal, nonroutine, and emergency response situations. While the selection of respirators is finally the responsibility of the safety officer, the safety officer will coordinate with all supervisors having responsibility for personnel identified as in need of respiratory protection. 2. Only personnel authorized by the safety officer will utilize respiratory protection. Authorization consists of (a) selection by the safety officer or supervisor on the basis of potential exposure to dangerous atmosphere, (b) appropriate training of personnel in the proper use, maintenance, and
201
Respiratory Protection
42 CFR 84 Particulate Filters
Choose filter efficiency ~ (,.e., 95%, 99%, or 99.97%)
No
I ' I Use P-series filter t !
~v ~r
Use R-series, tt Or P-series t filter
Use N-series, tt R-series, t or P-series t filter
* The higher the filter efficiency, the lower the filter leakage. t Limited by considerations of hygiene, damage, and breathing resistance. :1: High (200 mg) filter loading in the certification test is intended to address the potential for filter efficiency degradation by solid or water-based aerosols in the workplace. Accordingly, there is no recommended service time in most workplace settings. However, in dirty workplaces (high aerosol concentrations), service time should only be extended beyond 8 hours of use (continuous or intermittent) by performing an evaluation in specific workplace settings that demonstrates (a) that extended use will not degrade the filter efficiency below the certified efficiency level, or (b) that the total mass loading of the filter is less than 200 mg (100 mg per filter for dual filter respirators). w No specific service time limit when oil aerosols are not present. In the presence of oil aerosols, service time may be extended beyond 8 hours of use (continuous or intermittent) by demonstrating (a) that extended use will not degrade the filter efficiency below the certified efficiency level, or (b) that the total mass loading of he filter is less than 200 mg (100 mg per filter for dual-filter. respirators). 8.7 Flow chart for selecting 42 CFR 84 particulate filters (adapted from NIOSH, 1997: Particulate Respirator Selection and Use: Detailed Guidelines [NIOSH Electronic Library]). FIGURE
limitations of the respirator(s) specified for their use, and (c) completion of medical evaluation and fit testing requirements. 3. All authorized personnel will be trained in the proper fitting of respirators and taught how to conduct fit testing. All supervisors of authorized personnel will be fully trained in all aspects regarding the proper use, maintenance, and fitting of respirators. 4. The safety officer will ensure that, whenever possible, training of personnel and supervisors will be conducted by the vendors of respiratory protection devices and will maintain all training records, including the date
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8 Personal Protective Clothing and Equipment
Particulate Respirators Certified Under 42 CFR Part 84 O n l y I ~ o n - p 0 w e r e d P a r t i c u l a t e R e s p i r a t o r s are l i s t e d here! C a l l , 1 - 8 0 0 - 3 5 - N ! 0 S H f o r listin~lS o f o t h e r C e r t i f i e d R e s p i r a t o r s
ll,
N~)TICE:
,
On July 10, 1995, a new NIOSH certification program for respirators went into effect. This regulation, 42 CFR Part 84, replaced the long standing regulation 30 CFR Part 11. (Commonly referred to as Part 84 and Part 11, respectively.) The new Part 84 covers all respirator types (serf-contained breathing apparatus, air-line respirators, gas and vapor respirators, powered air-purifying respirators, etc.) but only the standards for non-powered, particulate respirators have changed from the provisions of the old Part 11. The following is a list of ONLY non-powered (negative pressure) particulate respirators that have been tested and certified by NIOSH under provisions of the new Part 84. Many other respirator types, such as particulate filters in combination with gas and vapor cartridges, have been certified under provisions of Part 84 but are not included in this listing. Inquiries about other respirators may be made to 1-800-35-NIOSH. This list is updated periodically as additional non-powered, particulate respirators are certified. The current reference date is provided at the top of the listing. Note: Multiple listings under the same certification number will be present when that same respirator is marketed by different suppliers under private labels.
Particulate Respirators Certified Under 42 CFR Part 84 Effective Date: July 31, 1997
Approval Number
Supplier/ Phone Number
Respirator Type/ Trade Name
84A-0001
Better Breathing, Inc.
Filtering Facepiece
84A-0002
1-800-638-6275
APR-3-N95-1
Racal Health and Safety, Inc.
Filtering Facepiece
1-800-682-9500 . .
Delta N95
. 84A-0003
.
1-800-682-9500 ............... j,., 84A-0004
I
Racal Health and Safety, Inc.
Filtering Facepiece .
.
.
.
Exhalation Valve
N95
Yes
N95
Yes
N95
No
NIO0
Yes
Delta N95
Racal Health and Safety, Inc.
Filtering Facepiece
1-800-682-9500
Delta NI00
http'd/ftp.cdc.govlniosh
Protection Level/ Series
Continued ...........
Example of listing (partial) of particulate respirators certified under 42 CFR 84 (adapted from NIOSH, 1997: NIOSH Electronic Library). F I G U R E 8.8
Respiratory Protection
203
of training, the names of persons attending the training, the specific subject matter addressed, and the name and affiliation of the trainer. 5. Wherever possible, respirators will be assigned to individual workers for their exclusive use; in such cases, the employee's name will be clearly marked o the respirator. 6. All nondisposable respirators must be cleaned and disinfected after each use and will be stored in a convenient, clean, sanitary, and clearly identified location. Written instruction for the proper cleaning, disinfection, storage, and maintenance of respirators will be included in standard operating procedures posted at each storage location. 7. Respirators will be inspected during cleaning or at least monthly. Worn or deteriorated parts will be replaced. Inspection will include a check of the tightness of connections and the condition of the facepiece, headbands, valves, connecting tubes, and canisters. Rubber or elastomer parts will be inspected for pliability and signs of deterioration. Inspection records will be maintained by supervisors at the respirator storage location. 8. Respirators must be stored to protect against dust, sunlight, heat, extreme cold, excessive moisture, or damaging chemicals. Respirators placed at ready stations will be immediately accessible at all times and should be stored in dedicated and clearly marked compartments. Routinely used respirators, such as dusts masks, may be placed in plastic bags for storage. Respirators should not be stored in such places as lockers or tools boxes unless they are in carrying cases or cartons. 9. Respirators should be packed or stored so that the facepiece and exhalation valve will rest in a normal position and function will not be impaired by the elastomer setting in an abnormal position. 10. All personnel who issue or use canister-type respirators will ensure that canisters purchased or used by them are properly labeled and color coded (in accordance with 29 CFR 1910.134, Table I-1) before they are placed in service and that labels and colors are properly maintained at all times thereafter. 11. The safety officer will ensure that normal (nonemergency)work areas and operations (e.g., postincident cleaning and disinfection of contaminated equipment and vehicles) requiring the use of respirators are monitored at least twice a year to ensure proper respiratory protection. The safety officer will maintain written records that document the date of monitoring, chemical monitored, measurement devices, concentrations, conversion factors, and mathematical transformations of data, as well as any actions undertaken as a result of the monitoring effort. 12. In the case of SCBA, air may be supplied to respirator from cylinders or air compressors only if in compliance with 29 CFR 1910.134(d). 13. In areas where the wearer of a respiratory protection device could, upon failure of that device, be overcome by a toxic chemical or
204
8 Personal Protective Clothing and Equipment
oxygen deficiency or superabundance, at least one additional person will be present. Communication will be maintained between both or all individuals present. Planning will be such that one individual will be unaffected by any likely incident and have the proper rescue equipment to effect rescue. 14. Personnel using air line respirators in atmospheres immediately hazardous to life or health will be equipped with safety harnesses and safety lines for lifting or removing persons from hazardous atmospheres. 15. In no circumstances will any personnel using a respiratory protective device wear eye contact lenses in any atmosphere that may be chemically contaminated.
Cleaning and Disinfecting Respirators Respirators should be cleaned and disinfected after each use. Cleaning should be accomplished by washing nonfilter components with detergent in warm water using a soft brush, followed by a thorough rinsing in clean water. If possible, detergents containing a biocide should used. In no circumstance should any organic solvent (e.g., acetone, benzene) be used, as such solvents will typically damage the rubber facepiece. Alternatively, following detergent washing, a disinfecting rinse can be used, such as : 9 Hypochlorite disinfecting solution (2 tablespoons of chlorine bleach per gallon of water) 9 Iodine disinfecting solution (1 teaspoon of tincture of iodine per gallon of water) It should be understood that the efficacy of any chemical disinfectant depends upon the time of actual contact between the disinfecting chemical and the target microbe (bacterium, virus, fungus). To ensure contact between disinfectant and microbe, dirt and other substances that can physically interpose between disinfectant and microbe must be completely removed. Once dirt and other interfering substances are removed, allow at least a 2-minute immersion of respirator components in the disinfecting solution.
Inspection of Respirators All respirators should be visually inspected (a) before and after each use, (b) during cleaning and disinfection, and (c) at least monthly (and preferably weekly). Written SOPs should identify signs and symptoms of needed maintenance and replacement, including the following (based on NIOSH recommendations)-
Respiratory Protection
205
1. Disposable Respirator 9 holes in filter (replace respirator) 9 poor elasticity or deterioration of straps (replace straps or respirator) 9 deterioration or excessive deformation of metal nose clip (replace respirator) 2. Air-Purifying Respirator 9 Rubber facepiece: excessive dirt (clean thoroughly); cracks, tear, or holes (replace facepiece); permanent distortion (replace facepiece); cracked, stretched, or loose fitting lenses (replace lenses or facepiece) 9 Headstraps: breaks or tears (replace headstrap); loss of elasticity (replace headstrap); broken or malfunctioning buckles or attachments (replace items); excessive wearing of head harness (replace headstrap) 9 Inhalation valve, exhalation valve: detergent residue, dust particles, or dirt on valve or valve seat (clean); cracks, tears, or distortion of valve material or valve seat (replace); missing or defective valve cover (replace valve cover) 9 Filter element(s): improper filter and approval designation (replace); missing or worn gaskets (replace gaskets); worn threads (replace filter and/or facepiece); cracks or dents in filter housing (replace filter); deterioration of gas mask canister harness (replace harness); service life indicator (determine proper indicator from manufacturer) 9 Corrugated breathing tube (gas mask): cracks or holes (replace tube); missing or loose hose clamps (replace clamps); broken or missing end connectors (replace connectors) 3. Air-Supplying Respirator 9 Facepiece, headstraps, valves, and breathing tube (as for air-purifying respirators, above) 9 Hood, helmet, blouse, or full suit (as applicable): rips and worn seams (repair or replace); headgear suspension (adjust properly for wearer); cracks or breaks in faceshield (replace faceshield); damaged or improper fit of protective screen (replace screen) 4. Air Supply System 9 breathing air quality 9 breaks or kinks in air supply hose and end fitting attachments (replace)
206
8 Personal Protective Clothing and Equipment
9 tightness of connections (adjust; replace as necessary) 9 proper setting of regulators and valves (see manufacturer's recommendations) 9 correct operation of air-purifying elements and carbon monoxide or high-temperature alarms (see manufacturer's recommendations) 5. Self-Contained Breathing Apparatus (SCBA) 9 See manufacturer's recommendations
Key Issues in Respirator Maintenance Program On the basis of its analysis of the cause of deaths of firefighters, NIOSH has strongly emphasized (NIOSH Alert: September 1994; Publication No. 94-125) the critical importance of the various standards to be used
to establish a policy of providing and operating with the highest possible levels of safety and health for all firefighters, including standards directly
pertinent to respiratory protection: 1. NFPA 1404 specifies the minimum requirements for a fire service respiratory protection program, 2. NFPA 100 specifies (1) the minimum requirements for a fire department's occupational safety and health program, and (2) the safety procedures for members involved in rescue, fire suppression, and related activities, 3. NFPA 1561 defines the essential elements of an incident management system, and other relevant NFPA standards include NFPA 1971 (clothing), NFPA 1972 (helmets), NFPA 1973 (gloves), NFPA 1974 (footwear), NFPA 1981 (SCBA), and NFPA 1982 (PASS).
HEARING PROTECTORS Work-related noise is inclusive of two basic categories of sound: (a) impulsive sound, which is sound that varies more than 40 dB per 0.5 sec, and (b) nonimpulsive sound, which includes so-called continuous and intermittent (i.e., varies less than 40 dB per 0.5 sec) sound. The standard action level for the general workplace is an 8-hour TWA of 85 dB. There are four basic types of ear protectors, each having certain advantages and limitations, especially with regard to personal comfort level: 1. Enclosure: helmet type protection, typically providing attenuation of 35 dB at f < 1000 Hz and 50 dB at f > 1000 Hz; while highly effective
Hearing Protectors
207
for attenuating sound conducted through air, not very effective for attenuating sound conducted through one or body; relatively bulky and uncomfortable for most work situations; generally used where both hearing and head protection are required 2. Aural insert (earplug): most commonly used type of protector in general industry; inserted into the ear to plug the ear canal; provides attenuation of up to 25 dB at f < 1000 Hz and 35 dB at f > 1000 Hz, with common attenuations of 5 - 1 5 dB and 15-25 dB, respectively; three different types commonly available: A. Formable earplug: designed to be discarded after one-time use; made of expandable foams, glass fiber, wax-impregnated cotton, Swedish wool, or mineral-down; available in single size only; degree of attenuation depends on snugness of fit B. Custom molded earplug: designed to fit an individual's ear; changes in ear canal and drying of the mold material can detract from effectiveness C. Premolded earplug: made of soft silicone, rubber, or plastic; fits generic shapes of ear canals; various modifications for particular situations, including modifications for differential attenuations at different frequencies and for various combinations of continuous or impact noise; some models developed for specific occupational groups 3. Canal cap (semi- and supraaural): used to seal external opening of the ear canal (as opposed to plugging the ear canal); held in place by band or other head suspension device; range of attenuation comparable to that by earplug; ideal for intermittent use 4. Earmuff (circumaural device): domed cup covering the entire external ear; can provide up to 35 dB attenuation at [ <1000 Hz and 45 dB at f 1000 Hz, but often reaching only 10-12 dB; may be uncomfortable due to slight pressure applied to side of head Any hearing protector presents special risk to the wearer during incident operations because of its interference with (a) vital communication among team members (e.g., voice command to evacuate or other sound signal), and (b) the wearer's awareness of developing ambient hazard (e.g., noise associated with impending structural collapse). No hearing protector should be worn by any emergency response personnel except when specific provision is made (e.g., integrated earmuff and radio receiver) to ensure that the wearer will not thereby be subject to undue risk.
PERSONNEL TRAINING
INTRODUCTION
Over the past two decades, personnel training requirements have become the key requirements in regulations related to workplace health and safety and environmental quality. Their importance derives from several distinct although interrelated factors that influence not only the American but also the global workplace: (a) the need for employees to develop the skills and behavioral patterns required to achieve and maintain safe work conditions, (b) the right of employees to participate in decision-making that affects their well being, and (c) the recognition by the public at large that whole communities are increasingly at risk of their continually expanding and increasingly complex industrial base. Given the diversity of health and safety regulations and the growing awareness of health and safety risks as well as of alternative methods for controlling those risks, personnel training has become a complex undertaking for even small business and, in large corporations, typically demands a significant investment of time and money. In both large and small corporations, effective personnel training is directly relevant not only to broad health and safety objectives, but also to the converging economic and marketing interests that underlie any modern business. Whatever the objectives of any specific type of corporate training in health and safety, all such personnel training is today best viewed in the context of corporate risk management, which is inclusive of all corporate effort to control losses in productivity, capital resources, human resources, and market performance. However, an effective corporate risk management program is today the necessary first step not only toward achieving business objectives, but also to achieving proactive management control of hazards that could result in community-wide emergencies. In short, good business management practices are today based upon good hazard management practices. 208
Proactive Management of Hazards: Corporate Perspective
209
PROACTIVE M A N A G E M E N T OF H A Z A R D S : C O R P O R A T E PERSPECTIVE
The proactive management of hazards in the corporate setting is the essential first objective in any program of emergency response planning. Specifically, proactive management of workplace hazards directly impacts emergency response in two ways: 1. lessens the likelihood that an in-plant incident will require full-fledged emergency response by both on-site first responders and community response services to protect and/or rescue personnel, and 2. lessens the likelihood that an in-plant incident will escalate into a community-wide emergency that endangers not only in-plant personnel but also the public at large. It is for these reasons that any in-plant health and safety program must be considered an essential part of both corporate and community emergency response planning. Deficiencies in personnel training related to human health and safety, including the health and safety not only of employees but also of the general public, clearly contribute both directly and indirectly to significant business losses, including such losses as: 9 Direct health care costs for affected employees and the public 9 Regulatory fines and other legal costs associated with civil and criminal proceedings related to environmental and workplace incidents 9 Insurance premiums that reflect the degree of health and safety risk containment and management 9 Facility audit costs associated with enforcement efforts of regulatory agencies 9 Remediation costs associated with the clean-up of contaminated sites and environmental resources 9 Loss of accreditation by national and international business and marketing associations, with consequent adverse impact on competitive standing within a global market 9 Loss of market share due to adverse publicity generated by health and safety incidents or conditions 9 Increased administrative costs due to incident reporting and followup, as well as recruitment and training of appropriate personnel In light of these considerations, it is clear that an in-plant health and safety training program must first be integrated with an overall business ethos that gives the highest priority to effective health, safety, and environmental management practices--an ethos that, today, is rapidly becoming the
210
9 Personnel Training
essential managerial hallmark of any globally competitive enterprise and, consequently, a touchstone in modern graduate education programs in business management. The fact that, more than 100 years after the advent of the industrial revolution, "the marketplace" has finally discovered the importance of human health and safety should not diminish the key relevance of legally enforceable and technically complex regulations. Notwithstanding the persistent debate regarding the pros and cons of governmental intrusion into boardroom deliberation, the elevation of "good health and safety" practices to "good business" practices has occurred, in fact, only after regulatory agencies caught the serious attention of business. The number of these regulations and the range of workplace standards they establish clearly define a range of potential health and safety hazards to both employees and the public that few if any would dare refute before any objective audience. With regard to diverse workplace health and safety standards, OSHA has clearly circumscribed certain issues that must be addressed by personnel training: I. Responsibility and Accountability in the Design and Day-to-Day Management of the Corporate Health and Safety Program
Personnel training that does not clearly identify functional responsibilities and specific means for establishing and maintaining accountability for all policies, practices, and procedures regarding the safety of the workplace environment (as well as of environmental resources that link the workplace to the community) cannot be condoned in any circumstance and must be viewed as prima facie evidence that the corporation is primarily concerned with "paper compliance" with health and safety standards as opposed to the actual health and safety of its employees and the public at large. 2. Behavioral Measurements of the Efficacy and Adequacy of Health and Safety Policies and Procedures
The objective of any training must be objective-oriented communication, which is always a two-way flow of information between the trainer and the persons being trained. The one-wa y flow of information from an instructor or, as is more commonly the case, from video tapes, from canned, computerized programs, or from pamphlets to a silent student is neither communication nor training. The only meaningful health and safety training is that which actually affects workplace behavior, and this can occur only
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when the training actively involves employees in discussion of information related to their specific work-related activities and responsibilities.
3. Active Employee Participation in All Decision-Making Regarding Health and Safety Effective personnel training must be based on the premise that health and safety are a joint objective and responsibility of both management and labor. Where health and safety practices and procedures (or the lack thereof) are perceived as emanating solely at the discretion of corporate management, it is unlikely that any personnel training program can have any measurable influence on workplace-related health or safety.
4. The Importance of Personnel Training as a Prerequisite to Undertaking Job Assignment Personnel training in health and safety practices and requirements is today an essential component of the initial in-plant processing of new employees. While it is neither possible nor desirable to attempt to complete all health and safety training prior to undertaking actual job assignments, the company must ensure that initial training is sufficient to ensure (a) that workers are not at special health or safety risk simply because of their status as newly assigned personnel, and (b) that the public at large as well as community emergency response personnel are not at risk simply because workplace personnel are incompetent in managing in-plant operational hazards. This requires that the corporate health and safety training program be appropriately "tiered" or "staggered" to meet the needs of personnel at various stages of their employment, including the categories of newly hired, newly assigned, and temporary personnel, as well as personnel in need of refresher or advanced training, or additional training due to the implementation of new production processes or procedures.
Corporate Training and Regulatory Compliance Health and safety training objectives too often become confused with regulatory compliance objectives--a confusion that typically reflects a misguided corporate preoccupation with doing as little as possible to comply with specific regulations, which in turn, is an attitude that reflects an hierarchical isolation of upper level management from the realities of the modern workplace.
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In the United States, for example, many executives would be surprised to learn that the Williams Steiger Occupational Safety and Health Act of 1970, which is the congressional authority for OSHA, requires "that every employer covered under the Act furnish to his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees (29 CFR 1903.1)." Thus, even in the absence of specific regulatory workplace standards (e.g., lockout/tagout, confined spaces, hazard communication), OSHA has the statutory authority to act to protect the health and safety of workers. In some jurisdictions, broad authority to ensure the health and safety of the citizen-worker is accomplished not only by legislative but also by constitutional means, as in India, where the Supreme Court in 1983 interpreted the constitutionally guaranteed right to life as requiring a healthy and safe environment, and in South Africa, where the newly elected democratic government included in its constitution the right of every citizen to an environment that is not detrimental to health and well-being. To these examples of the increasingly broad national and international mandate on behalf of human health and safety (which also presumes environmental quality) must be added the directives of the European Union, which are legally binding on its member states and which, since 1973, have specifically focused on the rights of citizens to a healthful and safe environment. Where corporate executives understand that human health and safety and environmental quality are essential corporate objectives in an interactive and interdependent global economy, it is well established that health and safety training of personnel must ensure regulatory compliance, but must not be solely defined or constrained by (or otherwise limited to) specific regulatory requirements. In short, regulatory requirements are best viewed as de minimus requirements that apply in all circumstances. However, to ensure both employee and public health and safety, it is typically necessary to go well beyond published regulatory standards. To effectively integrate what may be required by written law and what is required by actual workplace (and environmental) circumstance to protect human health and safety is, accordingly, the fundamental objective of any health and safety training program.
Training Policy Document Historically, companies have devised separate training programs to meet the legal requirements of individual regulations regarding workplace health and safety, including specific requirements for personnel training. Given the number of such regulations as well as the need for health and
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safety training beyond de minimus regulatory requirements, corporations are well advised to develop a comprehensive policy document as a basic management tool for the design, implementation, and quality control of all corporate health and safety training. Key elements of such a policy document include: 9 9 9 9 9 9 9 9
Programs and responsibilities Training methods Scheduling constraints Presenters Training records General policies Specific programmatic requirements Training documentation
Programs and Responsibilities The objectives of this section are (a) to identify precisely the individual training programs that fall within the purview of this policy document, and (b) to assign specific responsibilities for the design, content, conduct, and quality control of each program. Programs to be included are (a) those required by specific regulations (e.g., respiratory protection, confined spaces, hot work, bloodborne pathogens), and (b) those deemed by corporate officials and employees as appropriate to workplace and environmental circumstances or otherwise desirable but not specifically addressed by existing workplace regulations (e.g., personal hygiene and carry-home contamination, waterborne diseases). Assigned responsibilities should include specific requirements regarding the development, review and substantive revision, and quality control of each program. Provision should also be made for the timely addition of new programs, including new topics and additional levels of training within the various programs.
Training Methods For each training program, specific training methods should be identified on the basis of which method or combination of methods is most likely to achieve behavioral and informational objectives. Regardless of personal preferences, a comprehensive range of methods should be evaluated for efficacy, including (but not limited to): 9 Classroom style lectures 9 Demonstrations 9 Roundtable workshops or problem solving sessions
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9 9 9 9 9 9
Seminars Audio-visual programs Topical discussions On-the-job practicums Table-top or field exercises Site visits to other facilities
While on-the-job training is a valuable approach, it must be emphasized that this approach must be carefully evaluated with regard to (a) relevant regulatory requirements, (b) the risk to which the person being trained will be exposed, and (c) the risk to which the surrounding community will be exposed because of the incompetence of employees who are yet in the process of being trained.
Scheduling Constraints
Training schedules that are determined solely by routine work schedules are typically irrelevant to training objectives. The time required for a particular training session is precisely the time required to achieve specifically stated and monitored behavioral and informational objectives and should not be determined by any other factor. For example, while it may be convenient to train employees at the end of an 8-hour shift, it is hardly surprising that such training is most frequently a waste of time and effort. The schedule for training in each program should be established to ensure the most meaningful involvement of employees with the training exercise~an objective that can be met only by considering the type of information to be discussed, the nature of the exercise, and the mental and physical condition of the workers to be trained.
Presenters
While many companies have tended to use consultants as trainers, the range of health and safety training is today sufficiently broad that both inhouse personnel and external consultants should be considered for the presentation of training programs. The actual selection, of course, depends upon the type of information to be discussed and the relevance of the presenter's credential to that type of information. In some instances, priority must be given to academic or professional credentials, and in some, to practical experience. The types and balance of the presenter's academic, professional, and experiential credentials should be specified for each training program, as well as those personal skills and attributes that are considered essential for the achievement of specific training objectives.
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All presenters of personnel training programs should provide the company with a detailed resume of relevant experience as well as a syllabus for the training program and a copy of any training materials used during the presentation. It is recommended that the corporation always reserve the right to make an audio-visual recording of any health and safety training program presented by either in-house personnel or consultants, as well as the right to use any recording for purposes of documentation, quality control, and/or subsequent training purposes.
Training Records In addition to the documents provided by each presenter (i.e., resume, syllabus, and course materials), the safety officer should maintain (at least) the following documents for each training session: 9 Training attendance form~Including the name of the program, the name of the presenter, the date of presentation, and the printed name and signature of training participants 9 Employee's training evaluation f o r m ~ T o be submitted by each program participant upon completion of the training and to include a detailed assessment of the content of the training, the quality of the presentation, and the usefulness of the training 9 Monitor's training evaluation f o r m ~ T o be completed by a designated company employee who attends the training session for the express purpose of evaluating the content and presentation of the training; usually a person with administrative or upper managerial authority The increasing use of training evaluation forms, whether completed by training participants or by specially designated monitors, requires appropriate documentation regarding actions subsequently taken in response to those evaluations, including any revision of training session contents and the replacement of presenters. At least an annual review of all training evaluations should be conducted with appropriate documentation of findings and consequent actions. Additional documents may also be required, such as the results of written examinations or exercises that many companies use to measure and document the efficacy of in-house training. In some instances, companies also include posttraining evaluation forms that document the assessment of workplace behavior of individuals who have completed various stages of training. Documentation of personnel actions undertaken by the human resource department due to inappropriate employee behavior or activity specifically addressed in previous health and safety training is also often included as part of the documentation associated with that training.
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General Policies This section is devoted to those policies that must guide and inform the overall training effort, such as: 9 9 9 9
Assessment of efficacy of training Programmatic review and revision Availability of resource information on health and safety issues Relationship between workplace health and safety and general lifestyle 9 State-of-the-art standards and procedures
In developing these policies, the company must understand that it is increasingly subject to external legal scrutiny, especially with regard to the correspondence between written policies and the manner in which they are actually executed (or ignored) in the workplace. The basic rule to follow is that adage: "Say what you mean; mean what you say?"
Specific Programmatic Requirements In this section, all requirements for each health and safety program (Table 9.1) are collated, with particular emphasis give to the following: 9 Regulatory reference (if any) for program 9 Behavioral and informational objectives 9 Personnel to be trained (by job categories and work status, as in "new employees, .... office personnel, .... temporary laboratory personnel") 9 Frequency of presentation 9 Method of evaluation of effectiveness 9 Responsibility for design, implementation, review, and revision
Corporate Training: Special Issues Regardless of the size of a company, the management of personnel training related to health and safety demands an important investment of time and effort which, though arguably a necessary insurance against regulatory, criminal, and civil law proceedings, is subject to numerous factors that can easily overcome the best of intent. Some of these stubbornly difficult facts are directly related to the simple fact that the act of training is inextricably connected to the act of learning. While the failure to train is very often the failure to learn, in matters related to workplace health and safety it is the corporation's responsibility to train that receives primary attention~with the consequence that an employee who refuses to learn or to change workplace behavior in accordance
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T A B L E 9. I Recommended Training Topics and Emphasis (Adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Activities)
Training Topic
Emphasis of Training
Biology, Chemistry, and Physics of Hazardous Materials
Chemical and physical properties; chemical reactions;chemical compatibilties
Toxicology
Dosage; routes of exposure; toxic effects; immediately dangerous to life or health (IDLH) values; permissible exposure limits (PELs); recommended exposure limits (RELs); threshold limit values (TLVs)
Industrial Hygiene
Selection and monitoring of personal protective clothing and equipment; calculation of doses and exposure levels; evaluation of hazards; selection of worker health and safety protective measures
Rights and Responsibilities of Workers under OSHA
Applicable provisions of Title 29 of the Code of Federal Regulations
Monitoring Equipment
Functions; capabilities; selection; use; limitations; maintenance
Hazard Evaluation
Techniques of sampling assessment; evaluation of field and lab results; risk assessment
Site Safety Plan
Safe practices; safety briefings and meetings; standard operating procedures; site safety map
Standard Operating Procedures
(soPs)
Hands-on practice; development and compliance
Engineering Controls
The use of barriers, isolation, and distance to minimize hazards
Personal Protective Clothing and Equipment (PPC & PPE)
Assignment; sizing; fit-testing; maintenance; use; limitations; hands-on training; selection of PPC and PPE; ergonomics
Medical Program
Medical monitoring; first aid; stress recognition; advanced first aid; cardiopulmonary resuscitation (CPR); emergency drills; design, planning and implementation
Decontamination
Hands-on training using simulated field conditions; design and maintenance
Legal and Reulatory Aspects
Applicable safety and health regulations (OSHA, EPA, etc.)
Emergencies
Emergency help and self-rescue; emergency drills; response to emergencies; follow-up investigation and documentation
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with good health and safety practices and who thereby suffers an injury is likely to benefit economically at the expense of the company. It is therefore clearly incumbent upon a company not only to devise competent training programs, but also to implement stringent personnel actions whenever employees who have completed that training nonetheless fail to translate training lessons into workplace behavior. Yet, even then the company is typically constrained by a wide range of legal and societal standards that may often serve to protect a worker from the consequences of his own intransigence or incompetencemintransigence or incompetence, it must be emphasized, that place at risk not only that employee but also his fellow workers and, possibly, the public at large. Certainly one can empathize with a business manager who, unlike a teacher in a college or university, is typically to be blamed for the failure of someone else to learn. However, that same manager should understand that empathy is not necessarily the guarantor of sympathy. The fact remains that, in the modern world, a business does have the responsibility to make every reasonable effort to inform and instruct its employees as to the proper means for working safelymand, by proper monitoring of personnel, to ensure that they translate training into appropriate workplace behavior. Regardless of the attendant difficulties and frustrations, health and safety training and all that it implies is a basic cost of doing business. In light of the clearly dismal history of worker health and safety throughout most of the industrial revolution, one might reasonably add, "Finally!" In undertaking its admittedly burdensome and difficult task of translating training into safe work-related behavior, any business must come to grips with two key issues that, regardless of a company's size or geographic location or industrial code, typically demand particular attention: managerial skills, and the process of the communication. Professional Managerial Skills
The overall responsibility for personnel training in health and safety matters is most often given to a safety or training officer or other persons who, regardless of the extent of their technical, scientific, or other skills, are not professionally trained managers. What managerial skills they do possess have typically been obtained through limited on-the-job experience, with little if any guide or instruction by professional managers. Perceived as essentially technicians, they occupy relatively low-level and low-status positions in a corporate hierarchy that, minimizing their authority even while expanding their responsibility, effectively defines their contribution as a white-collar service function that, at best, is seen as subservient to both mainline corporate managerial and production tasks.
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While more sophisticated corporations have in recent years begun to elevate the status of personnel training by assigning this function to higher level departments, such as a human resource or loss control department, or even, in very few case, to executive level officers, the vast majority of companies persist in marginalizing personnel training. The consequence is that the typical safety or training officer is essentially ignorant of basic managerial skills, especially those related to the management of information, quality control, and objective-oriented systems analysis. Consider the fact, for example, that even a small manufacturing company having on the order of 40 employees may be legally required to comply with a dozen or more relatively complex health and safety regulations that serve not only to protect the workplace employee but also to protect the public surrounding that workplace. In addition to these regulations, the same company may have a variety of additional health and safety training requirements imposed by the concerns of corporate executives, insurance carriers, corporate owners, and unions. In this rather common situation, which specific employees must be trained in what, to what degree or level of competence, how often, and with what measure of success or failure are fundamental questions~and yet, few safety officers who have mainline training responsibility can immediately provide the answers or even know how to organize a relevant database or computerize a database to generate the answers. The prevailing ignorance of safety officers with respect to basic managerial skills, and the consequent ineffectiveness of much of the health and training programs conducted within corporations cannot be blamed on the safety officer but, rather, should be attributed to that corporate executive who considers the management of finances, productivity, raw materials, and product distribution to be inestimably more important than the management of human health and safety~that corporate executive who, despite a long reign in the history of corporations, is well poised to become an endangered species throughout the world. The Realities of Communication
That there can be no effective training without effective communication is a bromide so logically soporific it is usually ignored in practice, especially in the United States where the Americanized English language is considered the lingua franca that not only overcomes all linguistic and cultural barriers but also obviates any and all distinctions imposed by diverse personal experience and values. The perception is, of course, quite w r o n g ~ as evidenced in the United States by the rapidly expanding influx of nonEnglish speaking persons into the work force as well as by the tardy and painful recognition that many of our English-speaking fellow citizens (including some with college degrees) are in fact functionally illiterate.
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The political rhetoric that bemoans this real situation as well as regulations requiring the use of English in warning signs and labels are, however, absolutely irrelevant to the fact that, for now and for the foreseeable future, corporate health and safety training must effectively confront the linguistic pluralism of the American work force, whether that pluralism derives from differences in primary language, from difference in language skills, or, for that matter, from differences in linguistic expression and cognition imposed by personal experience. To do otherwise is essentially equivalent to defining worker health and safety as a reward for social conformity rather than as a right regardless of human diversity. The enormous difficulty inherent in the act of communication within an actual linguistic, cultural, and experiential pluralism cannot be made any the less, of course, simply by extolling the importance of the common objective of human health and safety--nor is the American experiment in linguistic diversity yet so far progressed as to give universally relevant clues as to the most effective strategies for dealing with that difficulty. However, we do know that one does not overcome it simply by speaking English more loudly and more slowly! We also know that the American business community, which is increasingly dependent for its very livelihood upon communication across cultural and linguistic barriers, has had to begin to divest itself of its traditional linguistic and cultural isolationism and to experiment with practical means of fostering cross-cultural and linguistic fluency. Finally, we know that computer technology has only begun to be tapped for its contribution to human communication, whether in the university, at home, or in the business. With a realistic understanding of the limitations of any language, with an experimental ethos directed toward achieving business objectives despite those limitations, and with a sophisticated electronic technology simply waiting to be used, we already perceive that perhaps our long trusted approach to education and training is already grossly outdated and in need of drastic revision. I N C I D E N T RESPONSE PERSONNEL
Except in special circumstances, it cannot be expected that in-plant first responders will be trained to the same level of expertise and competence as professional community and governmental response services. However, because of the critical role that first responders play, it is necessary that industry become more knowledgeable of the guidance and training materials available through professional response services and take specific steps to integrate that guidance and training experience into the corporate training of, at least, in-plant initial responders and, preferably, all in-plant managers and other personnel who have mainline responsibility for materials and op-
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erations that present risk to facility personnel, environmental resources, and the surrounding community. Of particular importance is the experience of professionals with regard to: 9 Designing a comprehensive emergency response training program, 9 Identifying those types of training that have been proven to be highly effective for ensuring the development of emergency response skills, and 9 Utilizing professional emergency response services, resources, and information to meet specific training objectives.
Design of Comprehensive Training Program The comprehensiveness of an adequate training program in emergency planning and response must not be defined solely in terms of corporate experience with so-called "personnel training" which, after all, being inclusive of all aspects of business operations, is far more focused on normal procedures and SOPs than life-threatening incidents. The comprehensiveness of training that focuses on emergency planning and response must be based on what the professionals in emergency response deem important. For example, Fig. 9.1 is a partial listing of diverse resources provided by the U.S. National Response Team, including handbooks, reports, bulletins, courses, videos, model exercise plans, and other documents specifically designed by professionals as effective tools for training related to emergency response. In some instances, guidance for emergency response training is provided across a broad spectrum of types of emergencies (as in Fig. 9.1); in others, detailed guidance is provided with respect to particular types of emergencies. An example of the latter type of resource that can prove invaluable to industries using, storing, or producing petrochemicals is the National Preparedness for Response Exercise Program (PREP), developed by the U.S. Coast Guard, EPA, the Research and Special Programs Administration in the U.S. Department of Transportation, and the Minerals Management Service. This program (Fig. 9.2) provides specific guidelines for conducting response training exercises in compliance with the Oil Pollution Act of 1990. Of course, the comprehensiveness of emergency response training is not to be simply determined by the substantive content of training related to response procedures and techniques, but also by the substantive content related to the overall design and quality control of the training effort itself. A valuable resource to industry at large is a handbook prepared by the U.S. Department of Energy (Fig. 9.3), which emphasizes alternative approaches
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National Response Team http'J/www.nrt.org/nrt/home
RESOURCES The following resources can help you to design, conduct, and evaluate exercises that test your emergency response procedures. If you are aware of additional materials that could be Included in future issues, please send a complete description, including contact information, to the NRT Preparedness Committee, Mail Code 5101, U.S. Environmental Protection Agency, Washington, DC 20460.
Developing a Hazardous Materials Exercise Program: A Handbook for State and Local Officials (NRT2). The NRT developed NRT-2 to provide guidance for the initial development of (or refinement of an existing) exercise program. It also identifies federal-level resources available to state and local officials to assist in the implementation of comprehensive exercise programs to assess their hazardous materials plans and annexes. Contact EPA's EPCRA Hotline at (800) 535-0202 / FAX: (703) 412-3333 to obtain a free copy. The Exxon Valdez Oil Spill: A Report to the President (NRT). This report addresses the preparedness for, response to, and early lessons learned from the Exxon Valdez oil spill in Prince William Sound, Alaska. Exercise planners should review the document when developing exercises that test response procedures for major incidents. Contact EPA's EPCRA Hotline at (800) 535-0202/FAX: (703) 412-3333 to obtain a free copy of this report. Guide to Exercises in Chemical Emergency Preparedness Programs (EPA) - This series of three bulletins provides an overview of the major types of exercises and describes some resources currently available for conducting exercises. You can obtain free copies of Introduction to Exercises in Chemical Emergency Preparedness Programs, A Guide to Planning and Conducting Table-Top Exercises, and A Guide to Planning and Conducting Field Simulation Exercises by contacting EPA s EPCRA Hotline at (800) 535-0202 / FAX: (703) 412-3333. Exercise Design Course (FEMA) - This course develops skills that will enable participants to train staff and to conduct an exercise that will test a community's plan and its operational response capability. Contact the Emergency Management Institute at (301) 447-1286. EPA Region 2 Exercise Video and Manual (EPA) - A video and manual demonstrating field exercises held in the state of New Jersey features comments from Federal On-Scene Coordinators (FOSCs). Contact John Ulshoefer, EPA Region 2 at (908) 321-6620 for more information. GSA Exercise Diskettes (GSA) - Government employees can review GSA's model exercise plan that i includes handbooks for both exercise players and controllers, an exercise evaluation plan, a master iscenario events list, and sample standard operating procedures for an emergency operations center. Contact Gordon Tassi, GSA Emergency Management Department at (202) 501-0900 for more information.
Hazardous Materials Exercise Evaluation Methodology (HM-EEM) and Manual (FEMA) - This document was designed to assist state and local governments in the comprehensive evaluation of hazardous materials exercises. It contains a series of modules prepared to evaluate major exercise objectives, so that emergency plans can be amended to reflect the lessons learned. Contact FEMA s Publications Management Office, 500 C Street, SW, Washington, DC 20472 to obtain a copy.
FIGURE 9.1 Example of training resources available through U.S. National Response Team (National Response Team, internet home page).
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U.S. EPA Emergency Response Program
Preparedness for Response Exercise Program Overview
The U.S. Coast Guard, EPA, the Research and Special Programs Administration in the U.S. Department of Transportation, and the Minerals Management Service developed the National Preparedness for Response Exercise Program (PREP) to provide guidelines for compliance with the Oil Pollution Act of 1990 (OPA) pollution response exercise requirements. These guidelines are voluntary in nature. While plan holders are not required to follow the PREP guidelines, they are still bound by the regulatory exercise requirements of the OPA and may develop their own exercise program in order to comply. Consisting of periodic unannounced drills as required by OPA, the PREP guidelines also recommend announced driUs. The guiding principles for PREP establish both intemal exercises, which are conducted within the plan holder's organization, and external exercises, which extend beyond the plan holder's organization to involve other members of the response community. External exercises are separated into two categories: industry-led Area Exercises and government-initiated unannounced exercises. These exercises are designed to evaluate the entire response mechanism in a given Area to ensure adequate pollution response preparedness. The goal of PREP is to conduct approximately 20 Area exercises per year, with the intent of exercising most Areas of the country over a three-year period.
FIGURE 9.2 Overview of national preparedness for response exercise program for conducting response training exercises in compliance with the oil pollution act of 1990 (U.S. EPA, Electronic Reference Library). continues
to training and techniques for evaluating both their selection and success~ precisely those elements of training that are so crucial to developing an effective in-plant emergency response capability.
Proven Training Methods The general literature is replete with learned discussions and assessments of a plethora of alternative training methods, and there can be no doubt that new methods will continue to be developed, especially with regard to the use of rapidly evolving computer and communication technologies. Given the seemingly limitless plenitude of training methods, it is understandable that trainers tend to have their favorite f e w ~ n o r is it surprising that, in industry at large, such favorites are generally those (e.g., brief lectures and video presentations) that minimize the absence of attending personnel from their main productive work. While professional emergency response personnel also utilize lectures and video presentations in the process of their training, the emphasis of
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U.S. EPA Emergency Response Program Oil Spill Prevention, Preparedness & Response
Oil Spill Training Oil spill training is an important element in EPA's oil spill prevention and preparedness efforts. Studies indicate that a significant number of oil spills at fixed facilities are caused by operator error, such as failing to close valves or overfilling tanks during transfer operations. Because operator error is more likely to be a factor in causing spills, training and briefings are critical for the safe and proper functioning of a facility. Training provides a number of benefits in the area of oil spill preparedness. Proper training of facility personnel can reduce the occurrence of operator-related spills and reduce the severity of impacts when a spill does occur. Training encourages up-to-date planning for the control of, and response to, an oil spill, and also helps to sharpen operating and response skills, introduces the latest ideas and techniques, and promotes interaction with the emergency response organization and familiarity with the facility's SPCC Plan. EPA offers training courses for conducting proper response measures in cases of inland oil spills as well as a drill/exercise proqram for oil-storage facilities.
EPA Training Requirements EPA requires owners and operators of facilities subject to the Oil Pollution Prevention regulations to conduct training on facility-specific oil spill prevention and response m e a s u r e s . Under the Oil Pollution Prevention requlation, EPA requires owner/operators to instruct their personnel on the operation and maintenance of equipment to prevent discharges of oil. In addition, regulated facilities should have a designated person who is accountable for oil spill prevention and who reports to line management. The current regulations also compel facility owners or operators to conduct spill prevention briefings for their operating personnel as often as needed to ensure an adequate understanding of the SPCC Plan for that facility. In 1994, EPA added requirements for oil spill response training for facilities that are required to prepare a facility response plan. Specifically, facility owner or operators are required to develop and implement a facility response training program if their facility is determined to pose substantial harm to the environment. According to the rule, training must be specific in nature and scope to the responsibilities of facility personnel identified in the facility response plan. In addition, facilities are required to develop and implement an oil spill drill/exercise program. The drill/exercise program is comprised of tabletop and deployment exercises that are both announced and unannounced, as well as participation in larger area drills and exercises. To satisfy the drill/exercise program, facilities may participate in the federal government's Preparedness for Response Exercise Proqram. In 1991, EPA proposed revisions to the SPCC regulations to clarify the mandatory nature of the oil spill prevention training requirements and proposed several additional requirements. Specifically, EPA proposed the following spill prevention training requirements: 9 All employees who are involved in oil-handling activities would be required to receive 8 hours of facility-specific training within one year of the final regulations. 9 In subsequent years, employees would be required to undergo 4 hours of refresher training. 9 Employees hired after the training program has been initiated would be required to receive 8 hours of facility-specific training within one week of starting work and 4 hours each subsequent year. EPA currently is reviewing and evaluating comments received from the public on these proposed revisions.
F I G U R E 9.2~continued
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Preparedness for Response Exercise Program Exercise Components
Internal Exercises Intemal exercises are those that are conducted wholly within the plan holder's organizations. The internal exercises are designed to examine the various components of the response plan to ensure the plan is adequate to meet the need of the organization for spill response. The internal exercises include: 9 Qualified individual notification exercises; 9 Emergency procedures exercises for vessels and barges; 9 Emergency procedures exercises for facilities (optional); 9 Spill management team tabletop exercises; 9 and Equipment deployment exercises.
External Exercises Extemal exercises are exercises that extend beyond the internal focus of the plan holder's organization, and involve other members of the response community. The external exercises are designed to examine the response plan and the plan holder's ability to coordinate with the response community in order to conduct an effective response to a pollution incident. The external exercises include area exercises and government-initiated unannounced exercises.
Credit for Spill Response All internal exercises are self-evaluated and self-certified, meaning that the plan holder is responsible for confirming and documenting that the completed exercise was conducted in accordance with PREP guidelines and an examination of the effectiveness of the plan during the exercise was performed. Responses to actual spills may also be taken as credit for unannounced internal exercises. The plan holder must determine which exercises were completed in the spill response and document the findings. This determination should be based on whether the response effort would meet the objectives of the exercise as listed in the PREP guidelines. To receive credit from the NSCC for area exercises conducted as part of an actual spill response, the plan holder must meet the following criteria: (1) the response involved the entire response community; (2) the objectives of the area exercise were met as outlined in the PREP guidelines; (3) the response was evaluated: and (4) the spill response was properly documented and certified. Proper documentation for self-certification should include, as a minimum, the following information: 9 9 9 9 9 9
The type of exercise; Date and time of the exercise; A description of the exercise; The objectives met in the exercise; The components of the response plan exercised; and Lessons learned.
This documentation must be in writing and signed by an individual empowered by the plan holder organization. FIGURE
9.2~continued
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DOE HANDBOOK
Alternative Systematic Approaches to Training U.S. Department of Energy, Washington, D.C. 20585 FSC 6910 http-.//www.osti.gov/html/techstds/standard/hdbk1074Jhdb1074.html
Disclaimer This document is an electronic representation of the official, printed standard. The printed document takes precedence and is available as follows: DOE and DOE contractors: Contact Office of Scientific and Technical Information, P.O. Box 62, Oak Ridge, TN 37831; prices available from (423) 576-8401. Public Contact: U.S. Department of Commerce, Technology Administration, National Technical Information Service, Springfield, VA 22161; (703) 487-4650. Order No. DE95006851
Table of Contents 1. GENERAL GUIDANCE
2.4 Selecting Tasks for Training
1.1 Discussion
2.5 Elements of Analysis
1.2 The Need for Training
2.6 Products of Analysis
1.3 Effective Training
2.7 Application
1.4 Alternative Techniques
2.7.1 Facility Involvement
1.4.1 Table-Top
2.7.2 Periodic Needs and Job Analysis Updating
1.4.2 Verification
2.7.3 Transition to Design Activities
1.4.3 Document Analysis
2.8 Documentation
1.4.4 Templating
3. TRAINING DESIGN
1.5 Application of the Systematic Approach to Training
3.1 Purpose
2. ANALYSIS
3.2 Techniques of Design 3.3 Elements of Design
2.1 Purpose 3.3.1 Fundamental Elements of Training Design 2.2 Selecting an Analysis Technique 3.4 Products of Design 2.3 Types of Analyses 3.5 Application 2.3.1 Needs Analysis 3.5.1 Establishing a Curriculum Outline 2.3.2 Functional Analysis 3.5.2 Writing Leaming Objectives 2.3.3 Job Analysis 3.5.3 Establishing Testing Requirements 2.3.4 Task Analysis F I G U R E 9.3 U.S. Department of Energy handbook on alternative approaches to training and techniques for evaluating training programs (U.S. Department of Energy, Electronic Reference Library). continues
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Incident Response Personnel
3.5.4 Training Program Description
6.6.1 In-Training Evaluations
3.5.5 Facility Involvement
6.6.2 Training Delivery Evaluations
3.6 Documentation
6.6.3 Post-Training Evaluations
4. T R A I N I N G D E V E L O P M E N T
6.6.4 Change Actions
4.1 Purpose
6.6.5 Evaluating Facility and Industry Operating Experience
4.2 Techniques for Development 6.6.6 Comprehensive Training Program Evaluation
4.3 Elements of Development 4.4 Products of Development
6.7 Documentation
4.5 Application
6.7.1 Approval and Tracking of Changes/Improvements
4.6 Documentation
6.7.2 Updating Analysis Data
5. T R A I N I N G I M P L E M E N T A T I O N
5.1 PURPOSE
APPENDIX A, FACTORS AFFECTING TECHNIQUE SELECTION
5.2 Techniques for Implementation
General Guidance- GradingBasedon Hazard
5.2.1 On-the-Job Training
Nuclear HazardCategory 1 (High-Hazard)and 2 (Moderate-Hazard)Facilities
5.2.2 Classroom Training
Nuclear HazardCategory3 (Low-Hazard)Facilities
5.2.3 Individualized Instruction
General Guidance - TechniqueSelectionConsiderations
5.2.4 Laboratory Training
Key Factors
5.2.5 Simulator Training
APPENDIX B, SAMPLE TEMPLATE FOR DETERMINING SYSTEM KNOWLEDGE AND SKILLS
5.3 Elements of Implementation
APPENDIX C, ON-THE-JOB TRAINING GUIDANCE
5.4 Products of Implementation
OJT INSTRUCTOR
5.5 Application
GENERALGUIDANCE Preparation
5.6 Documentation
Conduct
6. T R A I N I N G E V A L U A T I O N
CONDUCTOF OPERATIONSGUIDELINES 6.1 Purpose OJT INSTRUCTIONSTO THE TRAINEE 6.2 Methods of Evaluation
EVALUATORINSTRUCTIONS
6.3 Elements of Evaluation
PERFORMANCEEVALUATION
6.4 Products of Training Evaluation
INSTRUCTIONSTO THE TRAINEE
6.5 Application 6.6 Conducting Training Evaluations
FIGURE
9.3~continued
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9 Personnel Training
the professional is on exercises and drills (Table 9.2 ) w o n the actual practice of specific skills; on the personal doing rather than on a safely removed viewing; on being where the real action is rather than on seeing someone else perform; on playing an actual role rather than on simply sitting in an audience. While there are standard distinctions made among the various types of drills and exercises by professional response services, it should be noted that different organizations (including industrial companies) often experiment with and mix elements of different techniques. For example, while a table-top exercise is usually considered to be more of a conference than an actual drill, many organizations have developed table-top exercises into simulations that others would describe as walk-through or functional drills. The categorical name is not important--the objective is! And the objective is to practice what has been l e a r n e d . . , and, then, to practice again and again. Various types of training are, of course, mandated by specific regulations (Table 9.3). However, even when not mandated, training may in fact be necessary to achieve the objective of effective emergency response. In such instances, it is necessary to define individual training topics precisely and then to determine the most appropriate training technique (or combination of techniques) for each topic. In undertaking these tasks, corporate training personnel should be guided by the examples of professional organizations and agencies that have had to meet the same need (Tables 9.4 and 9.5).
Professional Emergency Response Training Services, Resources, and Information One of the most important advantages of using the training services, resources, and information of professional response services is that such services, which must devote significant effort to evaluating the effectiveness of their own efforts, typically make these evaluations available so that others can learn from their experience. For example, the U.S. National Response Team (NRT) Preparedness Committee has developed an information exchange, which is intended to share NRT experience (via the internet) with both training exercises and actual incidents with the broad emergency response community (Fig. 9.4). Another example of an excellent training resource for general industry as well as governmental agencies is the Learning Resource Center (LRC) maintained by the U.S. Fire Administration (Fig. 9.5).
229
Incident Response Personnel TABLE 9.2 BasicForms of Training (Adapted from FEMA, 1996: Emergency Management Guide for Business. FEMA Electronic Library)
Orientation & Education Session
Regularly scheduled discussion session to provide information, answer questions, and identify needs and concerns.
Table-top Exercise
Members of the emergency management group meet in a conference room setting to discuss their responsibilities and how they would react to emergency scenarios. This is a cost-effective and efficient way to identify areas of overlap and confusion before conducting more demanding training activities.
Walk-through Drill
The emergency management group and response teams actually perform their emergency response functions. This activity generally Involves more people and is more thorough than a table-top exercise.
Functional Drill
This drill tests specific functions, such as medical response, emergency notification, warning and communications procedures and equipment, though not necessarily at the same time. Personnel are asked to evaluate the systems and identify problem areas.
Evacuation Drill
Personnel walk the evacuation route to a designated area where procedures for accounting for all personnel are tested. Participants are asked to make notes as they go along of what might become a hazard during an emergency (e.g., stairways cluttered with debris; smoke in the hallways). Plans are modified accordingly.
Full-scale Exercise
A real-life emergency situation is simulated as closely as possible. This exercise involves company emergency response personnel, employees, and management and community response organizations.
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9 Personnel Training
T A B L E 9.3 Selected Standards That Affect Technical Rescue Training (Adapted from U.S. Fire Administration, 1995: Technical Rescue Program Development Manual [FA-159])
Rescue Discipline
OSHA Standard
NFPA Standard
Confined Space
29 CFR 1910.146
None
Training requirements mandate annual entry training at a representative permit space and basic first aid training, but do not specify levels of training or minimum training proficiencies. A separate OSHA standard on hazmat operations training (29 CFR 1910.120) affects training for operations in confined space with IDLH (toxic or oxygen deficient) environments.
Water/ Diving
None
None
Professional Association of Diving Instructors (PADI) and other dive organizations have standards for dive training. The American Red Cross also has water rescue training standards.
Trench
29 CFR 1926.650.652
None
Mandates training on hazards of trench activities, including proper use of shoring, but does not establish operational training levels.
Rope
None
None
NFPA 1983 is the standard for rope to be used for rescue but does not discuss training.
i
Comment
These and other similar services that are easily available through governmental agencies are invaluable resources and should be regularly consulted by emergency response trainers and managers throughout industry. Other governmental training services are available that meet more narrowly defined needs and/or focus primarily on the training needs of governmental agencies. For example, the U.S. National Institute for Occupational Safety and health (Pittsburgh Research Laboratory) is currently developing a computer
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Incident Response Personnel
T A B L E 9.4 Examples of Appropriate Training Topics for Various Types of Rescue (Adapted from U.S. Fire Administration, 1995: Technical Rescue Program Development Manual [FA-159])
Rope Rescue 9 9 Types of rope 9 Types of equipment 9 Types of hardware and technical gear 9 Communications 9 Knots, hitches, and anchors
Equipment:
Lashing and picketing techniques 9 Simple and complex mechanical advantage systems 9 Belay techniques 9 Litter rigging and evacuation techniques
9 9 9 9 9 9 9 9
Low angle rescue High angle rescue Urban rescue operations Traverse techniques Incident command Self rescue techniques EMS considerations Helicopter operations
Helmet; Boots; Leather gloves; Harness; Clothing Confined Space Rescue
9 Types of confined spaces 9 OSHArules 9 Hazard recognition 9 Securing the scene 9 Resources
Equipment:
9 9 9
Atmospheric monitoring Incident Command Rescuer entry techniques 9 Retrieval systems 9 Rope and hardware and technical equipment
9
Lockout/ragout procedures 9 Breathing apparatus equipment 9 EMS and patient care considerations 9 Safety and survival
Helmet; Gloves; Boots; Clothing; Harness; Knee pads/elbow pads; Eye protection; SCBA Trench Rescue
9 Trench hazards 9 Securing the scene 9 Safety
Equipment:
9 9 9 9
Incident command Equipment and Resources Department SOPs Shoring techniques
9 9 9
Rigging EMS care Entry and patient removal techniques
Helmet; Gloves; Boots; Clothing; Harness Knee pads/elbow pads; Eye protection; SCBA; Folding shovel
continues
program that simulates a major mine emergency. Known as the Mine Emergency Response Interactive Training Simulations (MERITS), this program will serve as an important training device for command center personnel, including personnel from mining companies, labor organizations, and governmental agencies. Once operational (Fall, 1998), MERITS will be a highly interactive program that will provide simulated emergency-related data and information to users via personal computers and the internet and require command input regarding both underground and surface operations.
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9 Personnel Training
T A B L E 9.4~continued
Structural Collapse
9 9 9 9 9 9 9
Size up and command considerations Construction types Types of collapses Initial actions Dangers to rescuers Basic search techniques Advanced search techniques
Equipment:
9
Shoring and stabilizing techniques 9 Equipment and technologies for collapse rescue 9 EMS and patient considerations 9 Safety and psychological impact
9 9 9 9 9
Critical incident stress debriefing Breaching concrete and steel and other barriers Tunneling and excavation techniques Hazards to rescuers Heavy construction equipment operations
Helmet; Gloves; Boots; Clothing; Harness; Knee pads/elbow pads; Eye protection" SCBA; Folding shovel Water Rescue
9 9 9
9 9 9 9 9 9
Water hazards Ice characteristics and dangers Swift water hazards and hydraulic characteristics Reach techniques Throw techniques Row techniques Go techniques Helicopter uses Cold water drowning and Hypothermia
Equipment:
9
Self rescue and survival techniques 9 Rescue vs. recovery 9 Diver support 9 Search patterns and techniques 9 Safety 9 Incident command 9 Boat operations 9 Flash flood and rising water
9
Contaminated bodies of water 9 Ice rescue equipment and techniques 9 Swift water rescue equipment and techniques 9 Surf rescue equipment and techniques 9 Basic water safety 9 Swimming test
Personal floatation device/life vest; Whistle; Knife or shears; Flashlight; Rope throwbag; Helmet; Gloves; Goggles/eye protection; Wet or dry suit; Suitable footwear; SCUBA gear (dive team only)
Another such program is the Comprehensive Exercise Program (CEP), developed by the Federal Emergency Management Agency (FEMA), which is intended to be inclusive of comprehensive, all-hazard, risk-based, muhiscenario training exercises that test and evaluate the effectiveness of plans, policies, procedures, systems, and facilities used to respond to diverse emergency situations. The CEP, which is primarily intended to contribute to the development of compatible Federal, state, and local Emergency Operation Plans (EOPs), is based on the concept of an emergency response partnership among federal, state, and local government authorities, as well as volunteer and private sector organizations. One of the major objectives of this partnership is to provide a means for sharing response-related information throughout the emergency management community.
Incident Response Personnel
233
TABLE 9.5 Major Categories of Training for Dispatchers (Adapted from U.S. Fire Administration, 1995: Fire Department Communications Manual: A Basic Guide to System Concepts and Equipment)
Elements
of Dispatcher
Training
Communication Skills: Includes the ability to listen intently, speak clearly and accurately, not jump to conclusions, and obtain the correct information. Departmental Procedures: Includes basic types of fire incidents, emergency medical incidents, responses to other emergencies, administrative notifications, and interagency communications. Equipment Use: Covers the gamut from telephones to sophisticated computer systems; today's dispatcher must be skilled in the use of the latest communications equipment available to department. Interpersonal Communications and Understanding: Addresses the need to be aware of the community; differences in verbal mannerisms can prevent accurate information from being communicated.
The U.S. Fire Administration (U.S. FA) provides a wide range of training materials and information on fire response, including: 9 Training courses released though U.S. FA's National Fire Academy and available from the National Technical Information Service (NTIS; http://www.ntis.gov/). Industrial trainers may be able to review course materials at state fire training schools and metropolitan fire departments. 9 Other training materials and packages developed by the U.S. FA and available through NTIS 9 Documents and reports that are easily integrated into a corporate training program on emergency response and which are available in hard copy and download format from U.S. FA(http://www.usfa.fema.gov/pubs) Finally, it must be emphasized that many training resources are available not only through national, regional, and local emergency response
9 Personnel Training
234
September 1995 Volume 3, Issue I
Prepared by the National Response Teem Preparedness Committee
Lessons Learned From Exercises and Incidents A WORD F R O M THE NRT This edition of the NRT/RRT Information Exchange, Lessons Learned from Exercises and Incidents, was developed by the NRT Preparedness Committee as a vehicle for sharing the lessons learned from recent exercises and from actual incidents. The insight gained from one exercise can help other planners and responders further develop their own emergency response plans, and ultimately improve preparedness and response capabilities. Agency representatives serving on the NRT Preparedness Committee collected and submitted the lessons leamed described in this issue - each agency is identified in the text. In order to publish this document annually and to keep the information timely, we have developed a SURVEY FORM to collect lessons learned from recent exercises and incidents. Please take a few moments after you have been involved in an exercise to fill out this form and provide us with the lessons you have learned so that others may benefit from your experience. Use the summary of exercise objectives and explanatory notes listed on the back of the form to help us categorize the information. The exercise objectives, adapted from those found in Developing a Hazardous Materials Exercise Program: A Handbook for State and Local Officials (NRT 2), correspond to the sections of this document. You will notice that there are more objectives on the form than appear in this issue. While this effort is certainly voluntary, your input is needed for effective information exchange between and among all levels of government. The NRT Preparedness Committee encourages you to copy this document and distribute it to those likely to plan and conduct exercises in your jurisdiction. Should you have any questions or if you would like to provide feedback on this project, please contact NRT by fax at: (202) 260-0154.. http.J/www.nrt.org/nrt/home
FIGURE 9.4 Information exchange program for sharing national response team experience with training exercises (U.S. National Response Team, Electronic Reference Library).
Incident Response Personnel
235
Learning Resource Center
United States Fire Administration
The Learning Resource Center (LRC) provides current information and resources on fire and emergency management subjects. With its collection of more than 50,000 books, reports, periodicals, and audiovisual materials, the LRC facilitates and supports student and faculty research and supplements classroom lectures and course materials. The LRC routinely answers simple requests; e.g., an organization's telephone number and address. In response to more complex inquiries on specific subjects, the LRC will do literature searches, compile bibliographies, and, depending on length and copyright restrictions, provide documentation in the form of reports and articles. Users of this website may access the LRC's Online Card Catalog to perform their own literature searches. Only FEMA personnel and National Emergency Training Center (NETC) students may borrow materials from the LRC. However, via interlibrary loan through local libraries, the general public can access the LRC's collection of books and research reports. Audiovisuals, magazines, and general reference materials are noncirculating. Call (800) 638-1821 outside of Maryland or (301) 447-1030 for information on how to borrow materials from the LRC. Our email address is
[email protected]. Please include your mailing address and phone number in all email messages. Or, write to us at:
National Emergency Training Center Learning Resource Center 16825 South Seton Avenue Emmitsburg, MD 21727
Updated September 8, 1~7
F I G U R E 9.5 Learning resource center resources available for training purposes (U.S. Fire Administration, Electronic Reference Library).
9 Personnel Training
236
Mission Your team's mission is to manage an emergency in a high-rise shopping complex cum office and hotel which could lead to a major incident Our team is advised to select an Incident Commander to be assisted by Incident Officers and supported by Response Team Members (see enclosure 1). Your crisis team may assume any other functions as may be necessary Situation The 20-story shopping complex consists of 2 basement car-parks, a vehicle washing area, 4 levels of shopping, and 16 above-ground floors used as offices and hotel rooms (see enclosure 2). It is Saturday morning and the shopping complex is crowded with shoppers and their families. Some offices are still operating; the hotel has an 80% occupancy rate. 1100 hrs
]
An explosion/fire was detected at the electrical sub-station. Number of people injured not known. State Line of Action/
Ill
]
Fire reporting spreading to adjoining store, which contains various clothing items and combustible racks. Sprinkler not activated State Line of Action/ 1105 hrs
I
1106 hrs
~_
Fire spreading unchecked in the store, involving the combustible materials. Store attendant reports he has 20 LPG tanks in the same store. State Line of Action/ i
1107hrs
~_
Runnlng Report: Thlck smoke spreadlng horizontally and vertlcally Into shopplng area. Smoke spllls system not activated. State Line of Action!
] 1108hrs
]
Running Report: Six persons seriously injured due to explosion at the transformer in the sub-station. Explosion has affected the filter room station of the swimming pool and several people are having breathing difficulty. Gas unknown but has pungent odor
Smoke detected by automatic smoke detection system at the electrical shaft of the 7= floor. It is suspected that the electrical shaft has not been "fire stopped." Smoke is spreading into the office corridors and some employees are reported trapped
State Line of Action/
State Line of Action/
FIGURE 9.6 Portion of table-top exercise materials showing timed units of information sequentially provided to crisis team members (adapted from scenario designed and provided by Dato' Soh Chai Hock, Director General of Fire and Rescue Services, Malaysia).
237
Incident Response Personnel
1120 hrs
1109 hrs President of company on 11ta floor reports 5 persons (including 3 children) entered lift of hotel.
]
Fire Commander requests Crisis team to assist in phased evacuation by accounting for persons evacuated and waiting for evacuation.
State Line of Action/
State Line of Action/
1110hrs
L [
Smoke continues to spread into shopping mall. Shoppers rushing out of building.
]
Fire on 7a~floor under control; serious smoke and fire damage. Crisis team to carry out salvage & recovery
State Line of Action/
1111 hrs
1145hrs
State Line of Action/
]
Community Fire Brigade Commander arrives on scene and takes over command control center. Your Crisis Team has been asked to give a briefing and then to stand by to provide assistance to the Commander as needed.
[
1150hrs
1
Forward Fire Rescue Commander on shopping floor reports fire under control. Serious damage to several shops due to smoke and water. Crtsis team to mobilize In-house fire squads for salvage operation. State Line of Action/
State Line of Action/
1112 hrs
]_
Fire Commander orders phased evacuation of higher affected floors, and total evacuation of shopping areas. State Line of Action/
1116hrs
]__
1152 hrs
]_
CEO of complex arrlvea and expresses dlsmay over the extent of damage. He requests Crisis team to work on Immedlate recovery. Also the unaffected shopplng areas, hotel and offices should be Immedlately reopened. Your Crisis team Is to develop an action plan to avold repetltlon of thls Incldent
First response fire personnel reach affected floors. Request crisis team to provide detailed information on 6th, 7~ & 8~ floors. State Line of Action/
F I G U R E 9.6~continued
State Line of Action/
238
9 Personnel Training
organizations, but also through the international network of practicing professionals dedicated to comprehensive and effective emergency response. For example, Fig. 9.6 includes a summary of a table-top exercise developed by the Director General of the Malaysian Fire and Rescue Services (Dato' Soh Chai Hock) for use in a 3-day training program presented to industrial managers throughout Malaysia, but also made freely available by him to anyone who could use it in their own emergency response training program. The broad sharing of such information and resource training materials, as exemplified by individuals, governmental agencies, and professional associations throughout the world, underscores the fact that no corporate trainer having responsibility for training in-plant emergency response personnel lacks direct, readily available (and, in most cases, free) access to extensive professional guidance and training materials.
HAZARD AND RISK REDUCTION STRATEGIES
INTRODUCTION
In both proactive and reactive phases of emergency response planning, hazard and risk reduction are central objectives. Hazard reduction strategies include any attempt to minimize the potential harm or injury associated with any substance, situation, or condition; risk reduction strategies focus not on the source of potential hazards but, rather, on the exposure of persons to those hazards. As coequal efforts to minimize the impact of emergencies, hazard and risk reduction are today most often described as two aspects of the process of mitigation. The concept of mitigation is, in fact, very broad, inclusive of both proactive and reactive actions taken by both response and nonresponse personnel and by governmental as well as private organizations. With specific regard to emergency response personnel and organizations, the practical application of mitigation is directed toward the following objectives: I. Minimize the Number of Incidents Requiring the Implementation of Emergency Response
While this objective is very much the bottom-line goal of all emergency response planning, emergency responders themselves can actually do little to advance this objective, except by the advice and training they make available to private corporations and the public at large regarding the control of hazards and protection against exposure. Historically, this type of service (i.e., consulting and training) has most often been viewed as essentially ancillary to the main function of a response organization; however, given the 239
240
10 Hazard and Risk Reduction Strategies
paramount importance of a proactive ethos, there is good reason to argue that consulting and training services are at least as important as actual response services. The primary effort in regard to this mitigation objective (beyond consuiting and training) must be made by persons who have primary managerial responsibility for potential sources of hazards (e.g., plant manager). Regulatory authorities also play a vital role, of course, by forcing compliance with standards that are recognized as effective means of hazard and risk managementma role, it should be noted, which gives important support to the consulting and training services of response organizations.
2. Minimize the Magnitude of Incidents
The magnitude of an incident may be described in terms of various considerations, including (but not limited to) (a) geographic extent of hazardous conditions, (b) numbers of persons harmed or killed, (c) loss of property and other resources, (d) duration of the incident, and (e) resources used in response (e.g., personnel, equipment, money). Certainly these dimensions of an actual incident are influenced by both the proactive and reactive efforts of both response and nonresponse organizationsuefforts that, in the midst of an actual incident, become intertwined and hardly distinguishable. For example, the capacity of response personnel to contain a developing emergency in a particular facility is influenced not only by their response preparedness and readiness, but also by the policies of that facility regarding the control of hazardous material inventory and in-plant safeguards, including notification alarms and first-response protocols. Beyond maintaining their professional response readiness, response organizations are primarily responsible (with regard to this mitigation objective) for minimizing risk to response personnel.
3. Prevent Natural Disasters from Becoming Human-Made Disasters
The historic distinction between natural and human-made disasters is today less distinct. While humans do not cause earthquakes, humans do choose to build upon earthquake-prone faults; while humans do not cause torrential storms and floods, humans do choose to build within floodplains. This is not to say that humans can avoid any and all perils of nature by a mere act of volition, but the fact remains that many ordinary natural phenomena essentially become human disasters simply because of specific
241
Introduction
FEMA- Mitigation
Reducing Risk through Mitigation Protecting Your Property from Earthquakes Are You at Risk? If you aren't sure whether your house is at risk from earthquakes, check with your local building official, city engineer, or planning and zoning administrator. They can tell you whether you are in an earthquake hazard area. Also, they usually can tell you how to protect yourself and your house and property from earthquakes. What You Can Do Earthquake protection can involve a variety of changes to your house and property -changes that can vary in complexity and cost. You may be able to make some types of changes yourself. But complicated or large-scale changes and those that affect the structure of your house or its electrical wiring and plumbing should be carried out only by a professional contractor licensed to work in your state, county, or city. Examples of earthquake protection are anchoring and bracing propane tanks and compressed gas cylinders. These are things that skilled homeowners can probably do on their own. Anchor and Brace Propane Tanks and Gas Cylinders During earthquakes, propane tanks can break free of their supporting legs. When a tank falls, there is always a danger of a fire or an explosion. Even when a tank remains on its legs, its supply line can be ruptured. Escaping gas can then cause a fire. Similar problems can occur with smaller, compressed gas cylinders, which are often stored inside a house or garage. One way to prevent damage to propane tanks and compressed gas cylinders is to anchor and brace them securely. The figure shows how the legs of a propane tank can be braced and anchored. Using a flexible connection on the supply line will help reduce the likelihood of a leak. Compressed gas cylinders, because they have to be periodically replaced, cannot be permanently anchored. But you can use chains to attach them to a wall so that they will remain upright.
FIGURE I0.1
Example of FEMA mitigation tip (FEMA Electronic Reference Library). continues
choices that humans do or do not make--choices that, regrettably, put the lives of emergency responders at risk. While the basic responsibility for this type of mitigation must lie with political and municipal planning processes, emergency response organizations can and do play an important role with respect to: Advising corporations and the general public as to proper location of hazardous facilities and operations Providing guidelines for proper design and construction (Fig. 10.1 ) in areas subject to natural hazards (e.g., storm, flood, wildfire, tornado, earthquake)
242
10 Hazard and Risk Reduction Strategies
Tips Keep these points in mind when you anchor and brace propane tanks or compressed gas cylinders: 9 Before you alter your propane tank in any way, make sure that the tank is your property and not rented from the propane supplier. Before welding new bracing to the tank legs, you must remove the gas from the tank. You should also check with your propane supplier to find out whether additional precautions are necessary. 9 Clear the area around the propane tank to ensure that there are no tall or heavy objects that could fall on the tank or rupture the supply line. 9 Keep a wrench near the shutoff valve and make sure the members of your family know how to turn off the supply line if they smell a gas leak. On larger tanks, such as farm tanks, consider installing a seismic shutoff valve that will automatically turn off the gas during an earthquake. 9 Provide a flexible connection between the propane tank and the supply line and where the supply line enters the house. But keep in mind that adding a flexible connection to a propane tank line should be done by a licensed contractor, who will ensure that the work is done correctly and according to all applicable codes. This is important for your safety. 9 To attach a compressed gas cylinder to a wall, use two lengths of chain around the cylinder -- one just below the top of the cylinder and one just above the bottom. The chains should be attached to eye hooks that are screwed into the wall. In wood-frame walls, the eye hooks must be long enough to penetrate not just the wall but the studs behind it as well. In concrete or masonry block walls, the eye hooks should be installed with expansion anchors or molly bolts.
Estimated Cost Bracing and anchoring a propane tank will cost about $250. Having flexible connections installed on the tank and at the house will cost about $75. Attaching one gas cylinder to the wall will cost about $50.
Other Sources of Information
Seismic Retrofit Training for Building Contractors and Building Inspectors: Participant Handbook, FEMA, 1995 Reducing the Risks of Nonstructural Earthquake Damage: A Practical Guide, FEMA-74, 1994
Protecting Your Home and Business from Nonstructural Earthquake Damage, FEMA, 1994 To obtain copies of these and other FEMA documents, call FEMA Publications at 1-800480-2520. Information is also available on the World Wide Web at http//:www.fema.gov. FIGURE I O. I ~continued
Mitigation
Measures
243
9 Ensuring that the risks attendant to the various types of natural hazards are appropriately integrated into response procedures, the selection of personal protective clothing and equipment, and personnel training
4. Integrate Lessons Learned from Actual Incidents and Response Actions into both Proactive and Reactive Protocols and Methods
A basic tenant of mitigation is that, however high either the level of sophistication of emergency planning and prevention or the level of response preparedness, every emergency incident is a unique opportunity for learning how to plan and how to respond better (Fig. 10.2). This principle applies directly to response and nonresponse organizations with equal relevance.
M I T I G A T I O N MEASURES
Being essentially an interactive, community-wide partnership among all organizations having direct or indirect responsibility for managing human risk, mitigation is inclusive of a wide range of measures that contribute in diverse ways to the (a) prevention, (b) control and containment, and (c) minimization of risk. Many of these measures have long been used in both public and private sectors and are variously encapsulated in such phrases as "good engineering practices, .... regulatory standards, .... pollution control measures, .... quality control measures," and (more recently), "green productivity" and "environmental management." As can be inferred from these phrases, the need to mitigate hazardous incidents has resulted not so much in the invention of whole new technologies as it has the marshaling of both existent and developing technologies toward the achievement of a specific common purpose.
Mitigation of Chemical Hazards
Because of the on-going proliferation of industrial chemicals in densely populated urban areas, renewed attention is being given to specific methods whereby industry can demonstrably reduce both the workplace and community risks associated with hazardous chemicals. It is important to emphasize that whatever an industrial plant does to protect workers and the surrounding community may also provide essential protection to emergency response personnel involved in a facility incident.
244
10 Hazard and Risk Reduction Strategies ~'
Personnel working on or around water must wear appropriate personal flotation devices.
~,
Rotate crews and pace activities to avoid premature exhaustion. Don't let them get burned out in the initial stages of an incident m especially if it is likely to be an extended incident.
>.
Relieve the initial response personnel and remove them from the immediate operating area as soon as feasible. Critical Incident Stress Management (CISM) is an absolute must! Personnel who were involved in the incident report that their participation in CISM was of significant benefit to them. Rehabilitation, although difficult to establish in the tight operational environment of the scene, was an absolute necessity. Given the high temperatures, constant exposure to the sun, and dangerous working conditions, it was critical to ensure that personnel were rehabilitated on a regular, formal basis. Use a large tarp or parachute cloth to set up a shaded area for rehabilitation.
>
Personnel should be rotated through various jobs on an extended incident to prevent them from being unduly subjected to too much of any particular sight, sound, smell, etc. Ensure that this rotation occurs even if they are being adequately rehabilitated with rest periods, fluids, and nourishment.
~,
Personnel must receive ample food and liquids. This will prevent dehydration (which is the most likely source of fatigue) and loss of energy. Care must be taken to ensure that responders do eat and drink as they may have a tendency to ignore sustenance in favor of continuing to work. Personnel must not eat on scene or prior to thoroughly washing their hands.
>.
In swampy areas, have ample supplies of mosquito repellent on hand. When working in the sun, make sure that sunblock is available to all personnel.
FIGURE 10.2 Lessonslearned from train derailment (adapted from FEMA. Technical Rescue Incident Report: The Derailment of the Sunset Limited; September 11, 1993; Big Bayou Canot, Alabama).
Of particular importance are the following techniques, which presume both the redirected use of a current base of knowledge and developing technologies: 9 Product reformulation 9 Chemical substitution 9 Alternative process engineering In many instances, it is possible to reduce or effectively remove a hazard associated with a particular material or process. One of the hazards of a coolant oil, for example, may be toxicity due to a heavy metal constituent (e.g., cadmium). Such an oil may be reformulated to remove the heavy metal constituent and thus remove the hazard of heavy metal toxicity with-
Mitigation Measures
245
out impairing the usefulness of the coolant. This is an example of product reformulation, which is an increasingly important growth industry today precisely because of the concern for human health and safety and the integration of that concern into global marketing strategies. Another hazard reduction strategy is chemical substitution which, though possibly involving a chemical reformulation of an existing product, primarily focuses on the substitution of a less hazardous chemical for a more hazardous substance. Examples include water-based paint substitutes for oilbased paints, non-chlorine bleaching agents for chlorine-containing bleaching agents, and certain botanical pesticides for synthetic pesticides. In many situations, neither chemical reformulation nor a simple chemical substitution can be effectively employed. It may therefore become reasonable to consider alternative process engineering, as in reengineering a water treatment plant to accomplish disinfection by an ozonation process rather than a chlorination process~an engineering alternative that could significantly reduce both facility and community risk due to catastrophic releases of chlorine caused either by natural phenomena (e.g., earthquake, flood) or by human error. Such an alternative would also, of course, significantly reduce the probability of an incident requiring emergency response services as well as the risk presented to emergency response personnel should they be needed. In order to minimize the risk associated with a chemical hazard that cannot itself be reduced, it is necessary to minimize exposure. This is accomplished by implementing exposure-control approaches in the following order: 9 Management (or executive, or administrative) control, which includes the management of schedules, assignments, and procedures to minimize the frequency and duration of exposure to specific hazards 9 Engineering control, which involves the use of space, barriers, and ventilation to limit and isolate exposure 9 Personal protective clothing and equipment Both management control and engineering control approaches are of particular importance to reducing risk not only at the workplace, but also off-site in the surrounding community. Specific examples of management and/or engineering control approaches include:
1. efficiency improvement, which is the redesign of production processes to improve the efficiency by which hazardous materials are processed; increased efficiency can result in decreased amounts of on-hand hazardous chemicals as well as hazardous waste
246
10 Hazard and Risk Reduction Strategies
2. in-process recycling, which involves the re-routing of hazardous materials directly back into a production process, and which can therefore result in reduced inventories of feedstock and hazardous waste 3. fugitive release control, which includes the prevention, entrapment, and/or containment of spills, leaks, and air emissions of hazardous substances 4. chemical inventory control, which includes any policy or procedure affecting the purchase and storage of hazardous feedstock chemicals The reduction in feedstock chemicals and hazardous waste through efficiency improvement and in-process recycling are particularly relevant to emergency response planning not only because they can reduce the probability of large releases of hazardous chemicals (and, therefore, of incidents requiring response) but also, should an incident occur, the risk of exposure presented to the public and to emergency response personnel. Fugitive release control, especially those measures taken by industry to implement immediate containment of leaks and spills, can mean the difference between a minor incident that can be easily handled by in-plant operational personnel or first responders and a major incident that requires extensive community response services. With respect to incident response services themselves, fugitive release control must be given special attention in the progress of several operationally related activities, including: a. The control of runoff of water and foams used for fighting fires, which may be contaminated with on-site hazardous chemicals and which could contaminate both subsurface and downstream surface water supplies, b. The control of wind-borne hazardous particles and other contaminated materials released on-site during and after the incident, c. The control and containment of incident-related releases (e.g., through tank rupture and other structural failures) of on-site feedstock chemicals, fuels, and hazardous wastes), and d. The control, containment, and subsequent disposal of waste water and other contaminated materials generated during the decontamination of equipment and clothing used during response operations. Of all the types of management control approaches to the mitigation of risks associated with industrial chemicals, inventory control is probably the most crucial. However, it is also the approach that most often conflicts with standard operating procedures within industrial bureaucracies. This is because the purchasing function in companies, which is intimately connected to finance and production functions, is typically independent of any corporate authority regarding health and safety.
Mitigation Measures
247
The objective of the purchasing department is to obtain process-feedstock, analytical, special purpose, and/or general-housekeeping chemicals on schedule with regard to plant operations and at or under cost guidelines. It is typically not the objective of purchasing to assess the potential for substitute chemicals having less severe hazards than ordered chemicals, nor to minimize the day-to-day on-site volume of hazardous chemicals. In fact, because the costs of chemicals can be reduced by bulk buying, usual purchasing guidelines generally result in the purchase of volumes in excess of specific operational needs. The bulk buying of hazardous chemicals results, of course, in the onsite storage of larger volumes of hazardous chemicals than are necessary, with consequent increase in the potential for: 9 Major spills, leaks that can result in explosion, fire, uncontrolled reactions, and toxic releases 9 The development of an actual emergency due to unstable or reactive chemicals being stored beyond their safe shelf-life (e.g., chemicals that produce organic peroxides) 9 The development of a hazardous chemical emergency due to environmental factors (e.g., heat) and/or natural disasters (e.g., flood, earthquake) 9 Increased exposure of response and other personnel as well as the general public to hazardous chemicals The only practical approach toward ensuring that the purchasing function does not lead or contribute to hazardous chemical incidents is to integrate that function into a facility-wide health and safety program. This is most effectively accomplished by inserting the health and safety officer into the chemical procurement decision-making loop, which extends from the determination of operational needs and specifications to the actual purchase of chemicals. The impact of inventory control on emergency planning and response extends, of course, well beyond the purchase of chemicals. Inventory control also includes protocols that govern the manner in which chemicals are actually stored and handled. Too often, the storage and handling of chemicals is based solely on grounds of production needs and convenience rather than on an understanding of those physical and chemical characteristics of chemical feedstocks that determine their potential for initiating or exacerbating an emergency. For example, the vapor density of many commonly used flammable industrial solvents (e.g., ethanol, acetone, benzene) is greater than the density of air (Table 10.1). The direct consequence of this physical characteristic is that such vapors fall to the bottom of the air column (rather than rising to the top), with potential subsequent risk of an incident clue to:
10 Hazard and Risk Reduction Strategies
248
T A B L E I 0. I Vapor Density (vd) Relative to Air for Common Industrial Solvents (vd~r = 1.0)
Vapor Density for Common Solvents (relative to air) Methanol Ethanol
1.1 1.6
Acetone Isopropanol Butanol Tetrahydrofuran Petroleum ether Benzene
2.0 2.1 2.5 2.5 2.5 2.8
Furfural
3.3 3.5
Isopropyl ether Heptane n-Butyl ether
3.5
4.5
9Collection of explosive fumes in subfloor conduits used for electrical wiring and junctions: explosion could occur in these room conduits; also, because subfloor conduits often extend beneath walls, an explosion could occur at fume collection points far removed from the source of fumes and/or extend (through flashback) throughout plant conduit system
9Collection at lower floor levels of explosive fumes released on upper floor levels: this is a particularly dangerous situation because fumes could flow from upper level production areas to lower level areas where cafeterias, smoking-break areas, or other locations where open sparks or flame could ignite the fumes and cause flashback to source areas 9Misplacement of intake to exhaust ventilation: in storage areas having exhaust ventilation, the intake to the ventilation system must be at floor level in order to exhaust high-density fumes; misplacement of intake at higher levels, which does not guarantee exhaust of high-density fumes, will lead to a sense of false security. Also, external exhaust of such fumes should be high enough to ensure that there is no contact with sparks or flames (e.g., an outside smoking area or location where there is open-arc machinery).
Regulation-Based Mitigation Methods While regulations are typically viewed by industry simply as constraints imposed by government on business operations, they are also key
Mitigation Measures
249
sources of information regarding the mitigation of hazards that, if not appropriately addressed, may result in incidents requiring emergency response or otherwise result in conditions that present unnecessary risk to emergency response personnel. Regardless of the type of hazard or risk addressed by any particular regulation, regulations generally define a wide range of alternative mitigation strategies that may be used to minimize the probability of occurrence and the magnitude of potential incidents, including (a) general policies, (b) analytical and assessment methods for determining the need for mitigation, (c) criteria for selecting appropriate measures from among alternative administrative and engineering mitigation techniques, (d)criteria for selecting, testing, and maintaining personal protective clothing and equipment, (e) ambient monitoring and medical surveillance techniques, and (f) personnel training objectives and methods. Of particular importance as sources of information regarding effective mitigation measures for American industry are the following OSHA regulations: 9 29 CFR 1910.95 (Hearing Conservation)mRequires the development of a written program that is inclusive of the ambient monitoring of workplace noise, noise reduction strategies, the selection and proper use of appropriate hearing protectors, and the medical surveillance of personnel 9 29 CFR 1910.109 (Process Safety Management of Explosive and Blasting Agents)--Requires the development of written SOPs regarding all aspects of the use of explosive and blasting agents, including marking and labeling, personnel training, and personal protective equipment and clothing 9 29 CFR 1910.119 (Process Safety Management of Highly Hazardous Chemicals)--For companies that handle any of more than 135 listed chemicals at or above threshold quantities, requires the development of written SOPs regarding the analysis of potential hazards and appropriate use of alarms and other fail-safe systems for preventing and containing chemical releases; includes requirements for a written management-ofchange program 9 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response)--Requires the development of a written emergency response plan that will minimize risks to employees engaged in cleanups at uncontrolled hazardous waste sites, in routine operations and corrective actions at RCRA regulated facilities, and in other emergency response activities without regard to location 9 29 CFR 1910.134 (Respiratory Protection)--Requires the development of a written respiratory protection program that is inclusive of the selection, use, and maintenance of respirators as well as personnel training, fit testing, and medical surveillance
250
10 Hazard and Risk Reduction Strategies
9 29 CFR 1910.146 (ConfinedSpace Entry)--Requires the development of written SOPs and facility permits for working within areas having limited openings for human entry and egress and which may present physical and/or chemical hazards; includes specific requirements for response personnel who enter confined spaces for the purpose of rescue 9 29 CFR 1910.147 (Energy Control; Lockout/Tagout)--Requires the development of written SOPs that direct the servicing of machines and equipment in which unexpected energization or the release of stored energy could cause physical injury to employees performing maintenance tasks 9 29 CFR 1910.252 (Hotwork)uRequires the development of written SOPs and facility permits for performing work that results in the generation of an open flame, spark, or (by any other means) sufficient heat to cause fire or explosion, including such commonly performed work as welding, grinding, drilling, and cutting 9 29 CFR 1910.331-.335 (ElectricaISafety-RelatedWorkPractices)-Requires the development of written procedures and training for personnel who, by the nature of their work, can be expected to work with or near an electrical hazard, as well as personnel who may accidentally become exposed to an electrical hazard 9 29 CFR 1910.1030 (Bloodborne Pathogens)--Requires the development of a written exposure control plan to prevent the exposure of personnel to bloodborne pathogens; includes specific requirements regarding the development of SOPs, the use of personal protective clothing and equipment, and personnel training 9 29 CFR 1910.1200 (Hazard Communication Standard; Right-toKnow)--Requires the development of a written program that provides employees specific information about workplace chemical hazards and the various means used to protect employees from those hazards 9 29 CFR 1910.1450 (Laboratory Standard)uRequires the development of written SOPs regarding the determination of chemical hazards, the use of MSDSs, and personnel training designed to protect laboratory personnel from chemical exposure; essentially a more stringent application of the Hazard Communication Standard to laboratories The above list of regulations does not exhaust the OSHA regulations that are relevant to emergency response services and operations, but does give a good representation of more recent OSHA regulations that underscore the comprehensive scope of contemporary hazard management in industry. As well, other regulations promulgated by other agencies (e.g., EPA hazardous waste regulations; DOT hazardous materials regulations; NIOSH respiratory standards; EPA SARA Title III regulations) are equally relevant and should be carefully reviewed by response services not only with respect to potential compliance requirements but, even more importantly, with respect
Mitigation Measures
251
to types of mitigation strategies and methods. It should be noted that many regulations include nonmandatory (as well as mandatory) appendices that typically contain very useful information and guidelines for designing and managing mitigation programs. Another vitally important reason that community response services should become thoroughly familiar with industrial regulations related to hazard and risk mitigation is that they are thereby better prepared to advise local industrial facilities of minimal acceptable standards and, as appropriate, to work with individual corporations to ensure the implementation of adequate policies and programs that can reduce the probability of in-plant incidents and/or of unnecessary risks to emergency response personnel and to the public at-large during any incident that may nonetheless occur.
Mitigation Methods Employed by Professional Response Services As important as it is for any response service to keep abreast of technological developments (e.g., chemical substitution, alternative process engineering) and regulatory standards, perhaps the most practical information on effective in-service mitigation methods is available through peer professional organizations, including other response service organizations (community fire services, local search and rescue services), professional associations (e.g., NFPA), and governmental emergency service agencies (e.g., FEMA, state emergency response agencies). With the advent of Internet and ready accessibility to personal computers, instantaneous linkage with such organizations gives good assurance that in-service mitigation protocols, procedures, and equipment are continually improved by actual field experience as well as by new developments in technology. Information readily available includes criteria, procedures, methods, equipment, and technical assessments having both broad and specialized relevance to any comprehensive in-service mitigation program. For example, ergonomic criteria developed for the selection of tools by one type of response service (Fig. 10.3) can be readily adapted to the needs of other services, regardless of any dissimilarity of incident-related roles and responsibilities. In the same manner, protocols found to be effective by fire services for selecting personal protective clothing and equipment (Fig. 10.4) can be readily adapted to meet comparable needs in swift-water search and rescue and many other specialized services. Specialization and compartmentalization are thoroughly pervasive attributes in any type of human endeavor and, unfortunately, typically result in the proliferation of distinct jargon, informational sources, and, perhaps more importantly, attitudes that isolate groups that otherwise have a common purpose. With respect to community response services (which certainly
252
I0 Hazard and Risk Reduction Strategies it is important to find out how the equipment feels when being used before instructing a fire fighter or EMT to use new equipment. Tools should be tried out and the potential users should understand how they are used and how they feel before being specified.
Hand tools should be selected which are designed so that the wrist can maintain a straight and neutral position. Whenever possible, tools should be chosen that have been designed to reduce vibration and which do not transmit torque to the hand and arm. Power tools are preferred because they reduce the force and exertion required to perform the task. All devices must be designed for safe operation. Tool balancers should be used where possible. The center of gravity must be aligned with the center of the grasping hand; this provides the leverage necessary to keep the tool in alignment. Tools that are continuously held should weigh approximately one to two pounds. Any heavier tools should be counterbalanced. Handles should contact as much of the hand and fingers as possible. Handles should be approximately 1.25- 1.75 inches in diameter. The minimum handle length should be 5 inches. Tools requiring both hands should provide two handles. Handles should be positioned to reduce awkward positions, and have a maximum distance of 2.7 inches. Tools should be equipped with a comfortable grip span between the thumb and forefinger. Vibration dampening materials should be incorporated in or on tool handles. These materials can also be incorporated into gloves. Where possible, use slip-resistance material for tool handles. Narrow tool handles which concentrate large forces onto small areas of the hand or grips with finger grooves, ridges, or recesses should be avoided. Short tool handles that press into the palm of the hand and tools that exert force onto the sides or back of the hand should be avoided. Power tools that must be grasped by the motor housing should be avoided. Evaluate pinch points, sharp edges, vibration transmitted to the user, tool exhaust air directed toward the wrist or other parts of the body, and excessive noise. Safety features should be maintained as originally designed. Knives and other tools with a cutting edge must be kept sharp. A regularly scheduled tool maintenance program should be established. FIGURE 10.3 Ergonomic criteria for selecting tools (adapted from U.S. Fire Administration,
1996: Fire and Medical Services Ergonomics).
do have a common purpose) and, more specifically, to mitigation (which must become a community-wide objective), it is therefore of paramount importance to recognize that all response services, regardless of the special risks engendered by their specific roles, must deal with certain categories of risk that are common to all, including those risks related to the performance levels of personnel, inappropriate protective clothing and equipment, administrative failures, and problems with communication equipment and procedures (Table 10.2). Risk management techniques designed by one type of service to minimize such risks should therefore be carefully reviewed by other services and, as appropriate, adapted to meet needs that, though similar, may differ to some degree in the operational context of an actual incident.
Mitigation Measures
25)
1. Identify the specific needs of your department 9
Examine current problems or injuries in using protective clothing and equipment. Determine what performance is needed to overcome these limitations.
9 Consider current protective clothing and equipment and its compatibility with the items to be purchased. 9 Determine if there are specific areas of protection that are required but are not covered in available specifications. 9 Decide on clothing sizing and design issues. For example, your department may have a preference for clothing color and trim style. Also, special pockets maybe required to hold radios or other equipment.
2. Write specification that will meet these needs 9
9
Solicit help from other organizations (such as NAFER or SAFER) or departments who may have already developed specifications that you can use or modify. Use NFPA standards as the basis for purchase specifications. If deviations from a NFPA standard are made, thoroughly document the reasons for the deviations. This limits department liability.
9 If trying to purchase specific manufacturer products, determine those product characteristics that are unique which can be specified. 9 Establish rating criteria ahead of time that will allow you to evaluate products to your specification. 9 Include provision for returning unsatisfactory products and assessing penalties if bid specifications are not met. F I G U R E 10.4 Guidelines for selecting and procuring fire-fighting protective clothing and equipment (adapted from U.S. Fire Administration, 1993: Minimum Standards on Structural Fire Fighting Protective Clothing and Equipment: A Guide for Fire Service Education and Procurement [FA-137]). continues
There are, of course, certain mitigative techniques that must be assiduously employed in precisely the same manner by any response service that may have jurisdictional control of incident response. For example, in a prolonged response effort in an isolated area where potable water for responding personnel is problematic, disinfection of drinking water must be implemented in standard fashion, regardless of type of incident or jurisdictional control. The fact that recommended procedures for disinfecting water may vary from state to state (Fig. 10.5) may therefore require that preincident interagency planning and coordination efforts produce a consensual disinfection procedure. Similarly, other mitigative actions must be addressed and resolved by preincident consensus, including (a) proper health maintenance of responders regarding the control of insects and other potential disease-vectors and operational nuisances, (b) location and design of temporary morgues, sanitary facilities, and personnel shelter and rehabilitation areas, and (c) local disposal of incident-related debris and other potentially contaminated materials. Internet linkages to governmental and professional organizations having specific response expertise are invaluable resources not only for re-
254
IO Hazard and Risk Reduction Strategies
3. Solicit bids for the clothing or equipment needed 9
Increase purchasing power by forming collective buys with other departments to obtain larger quantities at volume discounts.
9
Require manufacturers to provide one or more samples that can be evaluated. Develop a test plan to evaluate the sample and compare its performance to competing products.
9
Specify that manufacturers show evidence of compliance with the appropriate NFPA standard. Have manufacturers supply all data showing compliance of their product in a format that will allow your department to compare all competing products easily.
9
Require manufacturers provide complete user instructions and copies of warranties and technical data for examination.
4. Thoroughly evaluate bids 9 Carefully check sample clothing against the developed specification. 9
Examine information supplied with the products such as instructions, warranties, and technical data. Look for completion of the information and ease of its use.
9
Employ an evaluation system to rate products.
9
Physically wear or use equipment to ensure that it meets original specifications.
5. Evaluate the performance of clothing or equipment to determine if it does meet the original needs 9 Once clothing or equipment has been received, establish SOPs for its use, care, and maintenance. 9
Periodically review how clothing or equipment meets fire department needs.
9
Revise specifications as needed for new or replacement clothing and equipment. Use the standard as the basis for your specifications. FIGURE
I 0.4mcontinued
sponse services, but also for industry as well as the general public. Some of these links (Fig. 10.6) provide immediate access to chemical hazard databases, hazmat-related information, and specific alerts regarding both sources and potential mitigation of various types of hazards. Most links also provide access to international (Fig. 10.7) as well as national sources of information regarding mitigation.
ALL-HAZARD MITIGATION
Environmental and workplace health and safety regulations in the United States have emphasized the importance of (a) assessing the potential impacts of various types of industrial hazardous incidents (e.g., fire, chemical release) and natural disasters (e.g., flood, earthquake) on workplace and community health and safety, and (b) taking effective actions to mitigate the probability and magnitude of such impacts. While governmental agencies
255
All-Hazard Mitigation
T A B L E 10.2 Source of Risk and Corrective Actions (Adapted from U.S. Fire Administration, 1996: Risk Management Practices in the Fire Service [FA-166])
Risk Management Technique
Potential Source of Risk Personnel 9
Failureto meet minimum performance requirements ................................
~.
Establish minimum performance
9
Failure to properly train ...................
~,
Establish and conduct performance-based training for all personnel
~.
Training should conform to relevant OSHA, NFPA, and other standards
;~
Provide protective equipment that meets NFPA standards
Failure to notify owners of hazards .......................................
~,
Require complete records of every inspection
Failureto pursue compliance ...........
~,
Consistently issue citations and seek judicial intervention when hazards are imminent
9
Failureto adequately equip personnel ....................................
Fire Inspection Practices 9
9
Administration 9
Level of service not defined .............
>
Define level of service for all service deliverables
9
Incomplete records ........................
~,
Document and address all complaints promptly
~,
Ensure that specific dispatch policies are in place and that performance is monitored
>
Establish policy and procedure to address these issues
Communication 9
Failureto dispatch promptly .............
9
Failure to properly advise callers of potential delay ..............................
have demonstrably moved to integrate response to human-caused and natural disasters into an all-hazard approach to hazard and risk mitigation, much of American industry has failed to do so, persisting in looking at disaster through a regulatory-induced myopia. The all-hazard approach is based on the recognition that any distinction between human-made and nature-made disaster is essentially irrelevant to the risk to human life and health presented by an actual emergency. Just as the risks imposed by a natural disaster such as flood or earthquake can be
256
10 Hazard and Risk Reduction Strategies
Disinfection of Drilled Wells 1. Determine the amount of water in the well by multiplying the gallons per foot (Table 1) by the depth of the well in feet. For example, a well with a 6-inch diameter contains 1.5 gallons of water per foot. If the well is 120 feet deep, multiply 1.5 by 120 (1.5 gal/ft x 120 ft = 180 gallons). 2.
For each 100 gallons of water in the well, use the amount of chlorine (liquid or granules) indicated in Table 2. Mix the total amount of liquid or granules with about 10 gallons of water.
3.
Pour the solution into the top of the well before the seal is installed.
4.
Connect a hose from a faucet on the discharge side of the pressure tank to the well casing top. Start the pump. Spray the water back into the well and wash the side of the casing for at least 15 minutes.
5.
Open every faucet in the system and let the water run until the smell of chlorine can be detected. Then close all the faucets and seal the top of the well.
6.
Let stand for several hours, preferably overnight.
7.
After you have let the water stand, operate the pump by tuming on all faucets, continuing until all odor of chlorine disappears. Adjust the flow of water from faucets or fixtures that discharge into septic tank systems to a low flow to avoid overloading the disposal system. Table I
DIAMETEROF
WELL (IN INCHES)
3 4 5 6 8
10 12
Table 2
GALLONS
PER FOOTOF WATER
0.37 0.65 1.0 1.5 2.6 4.1 6.0
Laundry Bleach (5.25 % Chlorine)
~ 3 cups*
Hypochlorite Granules ( 70% Chlorine) --I~ 2 ounces**
* 1 Cup = 8-ounce measuring cup ** 1 Ounce = 2 heaping tablespoons of granules
Source: Illinois Department of Public Health
Note: Recommendations may vary from state to state
F I G U R E 10.5 Directions for disinfecting drilled wells (adapted from Centers for Disease Control and Prevention, National Center for Environmental Health. Flood: A Prevention Guide to Promote Your Personal Health and Safety, NCEH Electronic Reference Library).
magnified by subsequent releases of hazardous chemicals or uncontrolled chemical reactions, so the risks imposed by chemical or biological contamination can be magnified by a natural disaster. This recognition of the actual concomitancy of human-made and nature-made risks reflects, perhaps, our growing appreciation of some of the more dire consequences of the simultaneous urbanization of world society and the rapidly expanding dependency of that society on industrial technology. There can be no question that industry must continue to improve its mitigation measures with respect to specific types of hazards, such as fire and the release of hazardous materials and wastes (Table 10.3). However, industry must also significantly increase its effort to evaluate the consequences of facility-related operations and chemical inventories in light of disasters
257
All-Hazard Mitigation
Preparedness and Response Links to the Internet Responders' Toolbox: Chemical, Safety, Health, and Risks 4- Agency for Toxic Substances and Disease Register (ATSDR) - HazDat Databases This Hazardous Substance Release/Health Effects Database provides access to information on the release of hazardous substances from Superfund sites or from emergency events and on the effects of hazardous substances on the health of human populations. (Source: ATSDR/HHS) 4- Agency for Toxic Substances and Disease Registry ToxFAQs Menu - Searches on information of toxic hazardous substances. (Source: ATSDR/HHS) 4- Center for Disease Control Sites Query - Specific facility information for particular sites, such as counties, facility type, etc. (Source: ASTDR) 4- Emergency Response & Research Institute - EmergencyNet News Service - Provides direct links to hazmat-related information such as Hazardous Materials Operations Page, Disaster/Rescue Operations Page, etc. (Source: EmergencyNet) 4- Chemical Safety Alert - "Rupture Hazard of Pressure Vessels" (May 1997) - An EPNCEPPO Alert document containing information to protect human health and the environment by preventing chemical accidents. This document provides information on the hazards of improperly operated or maintained pressure vessels that could rupture. Currently only available in Adobe PDF format. (Source: CEPPO) + Chemical Safety Alert - "Fire Hazard from Carbon Absorption Deodorizing Systems" (May 1997) - An EPNCEPPO Alert document containing information to protect human health and the environment by preventing chemical accidents. This document provides information on activated carbon systems used to adsorb vapors for control of offensive odors. Currently only available in Adobe PDF format. (Source: CEPPO) + Chemical Safety Alert - "Catastrophic Failure of Storage Tanks" (May 1997) - An EPAJCEPPO Alert document containing information to protect human health and the environment by preventing chemical accidents. This document provides information on the catastrophic failure of aboveground, atmospheric storage tanks. Currently only available in Adobe PDF format. (Source: CEPPO) 4- Chemical Safety Alert - "Lightning Hazard to Facilities Handling Flammable Substances" (May 1997) - An EPNCEPPO Alert document containing information to protect human health and the environment by preventing chemical accidents. This document provides precaution information for industry in case lightning strikes hit equipment and storage or process vessels containing flammable materials. Currently only available in Adobe PDF format. (Source: CEPPO) F I G U R E 10.6 Key internet links and information available through U.S. National Response Team homepage (NRT Electronic Library).
beyond its control, such as hurricane, tornado, flood, winter storm, earthquake, and power outage (Table 10.4). Of course, another increasingly important source of risk that is typically beyond the operational control of industrial facilities is terrorism. Specifically, industry must consider: 1. how such natural disasters as well as terrorism can cause facilityrelated operations, chemical feedstock, and hazardous wastes to become additional sources of risk to community health and safety,
258 _
I0 Hazard and Risk Reduction Strategies
Intemational Trade Center Bookstore
Environmental Technologies Export Handbook Performing Org.: Intemational Trade Administration, Washington, DC. Price: $28. Outside the U.S., Canada, and Mexico $56. Microfiche price: $14. Outside the U.S., Canada, and Mexico $28. A $4 handling fee is added to each total order, $8 for customers outside of the U.S., Canada, and Mexico.
[
Order
I
Or call the NTIS sales desk at 1-800-553-6847 NTIS Order Number: PB96-1376331NO. 144p* Publication Date: Sep 95. Document Type: Technical Report
Summary:. Table of Contents: Defining Environmental Technology; The Global Environmental Market; Environmental Market Country Summaries (Countries Are Listed Alphabetically); Assistance Programs; Sources of Sales Leads; Sources of Finance; Major Environmental Trade Associations and Programs; Publications on Environmental Technology Issues; and Bibliography. Keywords: * Environmental protection; * International trade; * Market analysis; * Pollution control equipment; Economic development; Exports; Financing; Foreign countries; Investments; Market research; Mitigation; Pollution abatement; Remediation; Sales; Technology innovation; Technology transfer; Waste management Primary Subject Category: Environmental Pollution and Control - General (Codes: 68*; 96C* ) To order, call the NTIS sales desk at 1-800-553-6847 This product may also be ordered by fax at (703) 321-8547, or by e-mail at
[email protected]. NTIS is located at 5285 Port Royal Road, Springfield, VA 22161.
Visit the Intemational Trade Center Bookstore Search page to locate other related products. I International Trade Center Bookstore I National Technical Information Service (NTIS) I
FIGURE 10.7 Example of U.S. International Trade Administration alert on handbook relevant to hazard and risk mitigation (International Trade Administration, Electronic Reference Library).
2. what managerial and/or engineering means of mitigation can be implemented to reduce those risks, and 3. what quality control measures must be implemented to ensure the effective implementation of selected mitigation measures.
SHIFT IN P A R A D I G M
Throughout the world, the phrase shift- in paradigm is used to denote a significant change in perspective if not methodology in the conduct of any
259
Shift in Paradigm T A B L E 10.3 Basic Steps in Fire and Hazardous Material Incident Mitigation (Adapted from FEMA Emergency Management Guide for Business, FEMA Electronic Library)
Fire Mitigation 9
Meet with fire department to talk about community fire response capabilities; discuss your operations; identify processes and materials that could cause or fuel a fire, or contaminate the environment in a fire
9
Have facility inspected for fire hazards; ask about fire codes and regulations
9
Request insurance carrier to recommend fire prevention and protection measures; carrier may also offer training
9
Distribute fire safety information to employees regarding: how to prevent workplace fire; how to contain a fire; how to evacuate the facility; where to report a fire
9
Instruct personnel to use the stairs - - not elevators - - in a fire; instruct them to crawl on their hands and knees when escaping a hot or smoke-filled area
9
Conduct evacuation drills; post maps of evacuation routes in prominent places; keep evacuation routes, including stairways and doorways, clear of debris
9
Assign fire wardens for each area to monitor shutdown and evacuation procedures
9
Establish procedures for the safe handling and storage of flammable liquids and gases
9
Establish procedures to prevent the accumulation of combustible materials
9
Provide for the safe disposal of smoking materials
9
Establish preventive maintenance schedule to keep equipment operating safely
9
Place fire extinguishers in appropriate locations
9
Train employees in use of fire extinguishers
9
Install smoke detectors; check smoke detectors once a month; change batteries at least once a year
9
Establish system for warning personnel of a fire; consider installing a fire alarm with automatic notification to the fire department
9
Consider installing a sprinkler system, fire hoses and fire-resistant walls and doors
9
Ensure that key personnel are familiar with all fire safety systems
9
Identify and mark all utility shutoffs so that electrical power, gas or water can be shut off quickly by fire wardens or responding personnel
9
Determine the level of response facility will take if a fire occurs, considering the following options: (a) immediate evacuation of all personnel on alarm, (b) all personnel are trained in fire extinguisher use; personnel in immediate are of a fire attempt to control it; if they cannot, the fire alarm is sounded and all personnel evacuate, (c) only designated personnel are trained in fire extinguisher use, (d) a fire team is trained to fight incipient-stage fires that can be controlled without protective equipment or breathing apparatus; beyond this level of fire, the team evacuates, (e) a fire team is trained and equipped to fight structural fires using protective equipment and breathing apparatus
continues
enterprise, whether in science, business, government, or any other sphere of professional or technical endeavor. Such a change in perspective or methodology begins with a clear recognition that the former way of doing things does not w o r k ~ t h a t current objectives have outstripped long-established techniques and that, if current objectives are not to be abruptly abandoned,
260
10 Hazard and Risk Reduction Strategies
T A B L E I 0.3~continued
Hazardous Material Incident Mitigation 9
Identify and label all hazardous materials stored, handled, produced and disposed of by facility; follow government regulations that apply to facility and operations; obtain matedal safety data sheets for all hazardous materials at facility
9 Ask local fire department for assistance in developing appropriate response procedures 9 Train employees to recognize and report hazardous material spills and releases; train employees in proper handling and storage 9 Establish a hazardous material response place, including: 1. procedures to notify management and emergency response organizations of an incident, 2.
procedures to warn employees of an incident, and
3.
procedures for evacuating facility
9
Depending on operations, organize and train an emergency response team to confine and control hazardous materials spills in accordance with applicable regulations
9
Identify other facilities in area that use hazardous materials; determine when an incident could affect your facility
9
Identify highways, railroads and waterways near facility used for the transportation of hazardous materials; determine how a transportation accident near your facility could affect your operations
new methodologies, technologies, and/or new approaches must be constructed and implemented. The all-hazard approach to mitigation constitutes such a shift in paradigm. At both federal and state levels of government, it cuts across longestablished boundaries of jurisdictional authority, forcing not only a significant increase in interagency cooperation, but also a growing partnership among federal and state authorities as well as private sector organizations and corporations. But the shift in paradigm required for effective all-hazard mitigation does exact specific costs, whether paid by governmental agencies or corporations. For governmental agencies, the cost is certainly a blurring of jurisdictional authority that too often results in confusion in the midst of incident response. It can be expected that innovative procedures, such as recent formulations of unified command and unified contingency plans, will continue to be explored to reduce this confusion. For industry, the cost is not measured in jurisdictional authority but, rather, in changing social expectations of moral and legal responsibility. For example, in Southeast Asia, various governments have made substantial effort to establish as a working principle the dictum: those who are responsible
261
Shift in Paradigm TABLE
10.4 Basic Steps in Mitigation with Respect to Natural Disasters (Adapted from FEMA Emergency Management Guide for Business, FEMA Electronic Library)
Hurricane & Tornado Mitigation Hurricane 9
Review communication evacuation plans
9
Establish facility shutdown procedures; establish warning and evacuation procedures; make plans for assisting employees who may need transportation Make plans for communicating with employees' families before and after a hurricane Purchase a NOAA Weather Radio with a warning alarm tone and battery backup; listen for hurricane watches and warnings
9
Survey facility and take steps to protect outside equipment and structures
9
Protect windows; permanent storm shutters offer the best protection; covering windows with 518 inch marine plywood is another option
9
Consider the need for back-up systems: portable pumps; alternative power sources; batterypowered emergency lighting
9
Prepare to relocate records, computers and other items within facility or to another location
Tornado 9 9
Review community tornado warning system Purchase a NOAh, Weather Radio with a warning alarm tone and battery backup; listen for tomado watches and warnings
9
Establish procedures to inform personnel when tornado warnings are posted; consider the need for spotters to be responsible for looking out for approaching storms
9 Work with structural engineer or architect to designate shelter areas in facility; ask local emergency management office or National Weather Service office for guidance 9 9
Consider the amount of space needed; adults require about six square feet of space; nursing home and hospital patients require more space If an underground protective area is not available, consider: small interior rooms on lowest
floor and without windows; hallways on lowest floor away from doors and windows; rooms
constructed with reinforced concrete, brick or block with no windows and heavy concrete floor or roof system; protected areas away from doors and windows. Note: auditoriums, cafeterias and gymnasiums that are covered with a flat, wide-span roof are not considered safe. 9
Make plans for evacuating personnel away from lightweight modular offices or mobile homesize buildings; these structures offer no protection from tornadoes.
9
Conduct tornado drills
9
Once in a shelter, personnel should protect their heads with their arms and crouch down.
continues
for causing hazards and risks are precisely the persons who have primary responsibility for controlling those hazards and risks. That industry, wherever it might be, now has the primary responsibility for mitigating those hazards and risks posed to the community in which it conducts its operations is, perhaps, an arguable question under locally relevant lawmbut, that there is a significant world-wide trend toward holding not only corporations but also their owners and officers to such a stan-
262
10 Hazard and Risk Reduction Strategies
T A B L E I O.4--continued
Flood Mitigation
Planning Measures 9
Determine location of facility in relation to flood plain and elevation in relation to streams, rivers and dams
9
Review community emergency plan and community evacuation routes; know where to find higher ground in case of flood
9
Establish warning and evacuation procedures for facility; make plans for assisting employees who may need transportation
9
Inspect areas in facility subject to flooding; identify records and equipment that can be moved to a higher location; make plans to move records and equipment in case of flood Purchase a NOAA Weather Radio with a warning alarm tone and battery backup; listen for flood watches and warnings
9
Consider feasibility of flood-proofing facility
Permanent Flood-proofing Measures 9
Fill windows, doors or other openings with water-resistant materials such as concrete blocks or bricks
9
Install check valves to prevent water from entering where utility and sewer lines enter facility
9
Reinforce walls to resist water pressure; seal walls to prevent or reduce seepage
9
Build watertight walls around equipment or work areas within facility that are susceptible to flood damage
9
Construct floodwalls or levees outside facility to keep flood waters away
9
Elevate facility on walls, columns or compacted fill
Contingent Flood-proofing Measures 9
Install watertight barriers called flood shields to prevent passage of water through doors, windows, ventilation shafts or other openings
9
Install permanent watertight doors
9
Construct movable floodwal~s
9
Install permanent pumps to remove flood waters
Emergency Flood-proofing Measures 9
Build walls with sandbags
9
Construct double row of walls with boards and posts to create a crib and fill crib with soil
9
Construct a single wall by stacking small beams or planks on top of each other
9
Consider need for back-up systems: portable pumps; alternative power sources; batterypowered emergency lighting
9
Participate in community flood control projects
continues
263
Shift in Paradigm T A B L E I 0.4~continued
Severe Winter Storm & Earthquake Mitigation Severe Winter Storm 9 Listen to NOAA Weather Radio and local radio and television stations for weather information 9 Establish procedures for facility shutdown and early release of employees 9 Store food, water, blankets, battery-powered radios with extra batteries and other emergency supplies for employees who become stranded at the facility 9 Provide a backup power source for critical operations 9 Arrange for snow and ice removal from parking lots, walkways, loading docks, etc.
Earthquake 9 Assess facility vulnerability to earthquake; ask local governmental agencies for seismic information for area 9 Have facility inspected by structural engineer; develop and pdoritize strengthening measures, including: adding steel bracing to frames; adding sheer walls to frames; strengthening columns and building foundations; replacing un-reinforced brick filler walls 9
Inspect non-structural systems such as air conditioning, communications and pollution control systems; assess potential for damage and prioritize preventive measures
9
Inspect facility for any item that could fall, spill, break or move during an earthquake, and take steps to reduce these hazards
9 Move large and heavy objects to lower shelves or the floor; hang heavy items away from where people work 9 Secure shelves, filing cabinets, tall furniture, desktop equipment, computers, printers, copiers and light fixtures 9 Secure fixed equipment and heavy machinery to the floor; larger equipment can be placed on casters and attached to tethers which attach to wall 9 Add bracing to suspended ceilings; install safety glass; secure large utility and process piping 9 Keep copies of design drawings to be used in assessing facility safety after an earthquake 9
Review processes for handling and storing hazardous materials" store incompatible chemicals separately
9 Establish post-earthquake evacuation procedures 9
Designate areas away from exterior walls and windows where occupants should gather after an earthquake if an evacuation is not necessary
9 Conduct earthquake drills; provide personnel with following information: (a) during earthquake, if indoors, stay there; take cover under sturdy furniture or counter; brace against inside wall; protect head and neck, (b) if outdoors, move into the open, away from buildings, street lights and utility wires, (c) after earthquake, stay away from windows, skylights and items that could fall; do not use elevators, (d) use stairways to leave building if it is determined that a building evacuation is necessary
continues
264
10 Hazard and Risk Reduction Strategies
T A B L E I 0.4~continued
Technological Mitigation (Technological emergency is any interruption or loss of a utility service, power source, life support systems, information system or equipment needed to keep business in operation) 9
Identify all critical operations, including: a.
utilities, including electric power, gas, water, hydraulics, compressed air, municipal and internal sewer systems, wastewater treatment services b. security and alarm systems, elevators, lighting, life support systems, heating, ventilation and air condition systems, electrical distribution system
c. manufacturing equipment, pollution control equipment d. communication systems, both data and voice computer networks e. transportation systems, including air, highway, railroad and waterway 9 Determine the impact of service disruption to each system 9 Ensure that key safety and maintenance personnel are thoroughly familiar with all building systems 9 Establish procedures for restoring systems 9 Determine need for backup systems 9 Establish preventive maintenance schedule for all systems and equipment
dard cannot be questioned. In the United States, this trend is well established (if not boldly enunciated) in the plethora of health and safety regulations implemented over the past 15 years; it is also becoming increasingly documented in the case law used in both civil and criminal proceedings. What, therefore, does an all-hazard approach to hazard and risk mitigation actually portend if not yet signify to industry? Simply, that whatever the specific circumstance, whatever the sequence of specific causes and specific effects, and whatever the level of compliance to specific regulations, corporate owners, officers, and operators (and, perhaps even corporate boards of directors; even investors) are increasingly at personal financial and criminal risk if they do not take effective measures to mitigate the hazards and risks they present to the community by way of both their on- and offsite operations.
D EC O N TAM I NATI O N
INTRODUCTION
Decontamination is the safe removal or inactivation of any hazardous contaminant that adheres to or is otherwise in contact with personnel, protective clothing, protective equipment, and any other incident-related equipment, vehicles, materials, or debris. Potential contaminants include physical (e.g., asbestos, radioactive substance), chemical (e.g., pesticide), or biological agents (e.g., bacteria, viruses, other parasites). There are several basic objectives to decontamination procedures:
1. To protect on-site response personnel from direct bodily exposure to contaminants adhering to or absorbed into protective clothing or equipment--The presumption is that personal protective clothing (PPC) and equipment (PPE) are appropriately selected to prevent bodily exposure to contaminants. However, unnoticed tears, rips, punctures, and other malfunctions may in fact result in actual exposure (especially during particularly rigorous response activity), in which case timely decontamination can effective minimize the duration of exposure. Of course, in the absence of malfunction of properly selected PPC and PPE, decontamination prevents personal exposure during donning and doffing procedures. 2. To prevent the mixing of incompatible or synergistic chemical contaminants derived from different response activities involving exposure of the same personnel and~or equipment to different chemical hazards--During a particular incident, it may be necessary to use the same PPC, PPE, and other equipment (e.g., hand tools, vehicles, extrication equipment) for a variety of different tasks and also in different locations, with subsequent contamination by different chemical materials that may be incompatible. Chemical incompatibilities or synergies may in turn exacerbate existing hazards as well as result in completely different hazards, such as when a 265
266
I I Decontamination
relatively innocuous powder becomes highly skin-absorbable and toxic when mixed with water.
3. To protect off-site personnel (e.g., hospital personnel) from exposure in the process of treating victims, servicing equipment, or handling and transporting incident-related debris or other materials--While much of the concern regarding decontamination typically focuses on on-site incidentrelated activities, decontamination procedures play a vital role in the attempt to confine hazardous contaminants to the incident site where they can be better controlled. Transported off-site via victims, response personnel, and response-related equipment and debris, such contaminants readily place offsite response personnel as well as the unsuspecting and unprepared public-atlarge in danger.
4. To protect the families of response personnel from "carry-home contamination" (i.e., contamination carried off site on the body, in clothing, and~or in personal vehicles)--A particularly vulnerable subset of the off-site public at risk due to improper decontamination procedures is composed of the families of response personnel. Even if not personally involved in tasks requiring direct exposure to physical, chemical, or biological contaminants, on-site response personnel can become contaminated indirectly simply by being present at the incident site. Also, in many situations involving volunteer responders, personnel arrive on-site in personal vehicles and wearing personal clothes. Personal vehicles can become contaminated either by onsite conditions (e.g., wind, rain, runoff) or by the owners themselves, with subsequent risk to family members and friends; contaminated personal clothes can also transport dangerous chemicals directly into the home.
5. To protect environmental resources (e.g., water, soil, air) and, subsequently, the general public from the incident-related release of contaminants--Another major risk to the public-at-large is the environmental release of contaminants into water, soil, and air not solely as a result of the incident, but also from emergency response operations themselves. Runoff water from fire fighting operations, for example, must not only be contained but collected and finally decontaminated prior to final disposal. Similarly, construction debris from the incident as well as runoff and debris from postincident decontamination operations (e.g., dirt from vehicle tires, equipment wash water) must be decontaminated prior to release to environmental resources that can serve as hazard transport vectors into the general community. SCOPE OF D E C O N T A M I N A T I O N
PLAN
The meet the objective of decontamination, the decontamination plan must include SOPs pertaining to each of the following:
Scope of Decontamination Plan
267
9 9 9 9 9 9
minimization of personnel contact with hazardous substances maximization of responder protection determination of number and layout of decontamination stations determination of decontamination methods and equipment prevention of contamination of clean areas minimization of contact with contaminants during removal of PPC and PPE 9 disposal of materials and equipment that cannot be completely decontaminated and/or that become contaminated as a result of decontamination operations
While there is typically no time to develop SOPs for a specific incident, generic guidelines and checklists should be developed that can be modified and applied as appropriate on a site-specific basis. However, it should also be understood that the appropriateness of any decontamination method is ultimately determined by the specific nature of the hazardous substance of concern and the on-site conditions encountered during the incident. Therefore, all decontamination plans, guidelines, and checklists must be carefully reviewed and tested against the actual field situation before implementation. Minimization of Personnel Contact
Typically viewed as the first step in any comprehensive decontamination program, the minimization of personnel contact with hazardous substances (Fig. 11.1) depends upon not only proper clothing, equipment, policies, and procedures, but also (and perhaps most importantly) attitudes. Personnel must understand that there is nothing heroic about exposing themselves (and, thereby, co-workers and family) to hazardous substances; that potentially lethal agents are typically not visible, nor do they necessarily advertise their presence with strong odors; and that, depending upon the nature of the contaminant and its concentration, a contaminant may cause irreversible acute and chronic affects. The only acceptable professional attitude is, therefore, that attitude of seasoned caution which must inform all response behavior and which is encapsulated in the dictum: The first respon-
sibility of every emergency response provider is to protect himself.
Certain behavioral constraints necessarily follow from this dictum and must be stringently enforced, including : 9 limited access to operational areas, based on functional need, and strict adherence to precautionary measures 9 except as required by job function or assigned task and directed by operational SOPs and operational orders, prohibition of any
268
I I Decontamination
~useStressworkpracticesthat minimizecontactwith - _ _ _ hazardous s u b s t a n c e s ~ _ ~ _
~
1
{
L__l
Remotesampling, handling, and containeropeningtechniques. . . .
I
.
.
.
Minimize
t
F, rst
st.e Decont:mination Is to ... FIGURE I I.I Examples of standard operating procedures that minimize contact with chemicals (adapted from OSHA, OSHA Technical Manual, Section 7. OSHA Electronic Library).
casual investigation of structures, containers, or substances that may result in release of or contact with hazardous agents 9 strict adherence to site control constraints regarding both prescribed and proscribed behavior, activities and clothing, such as eating, drinking, smoking, washing, sleeping, use of sanitary facilities, use of designated footwear, and other clothing as well as personal protective equipment In no circumstances shall any response personnel ignore or otherwise acquiesce to any infringement by any person of any rule or practice implemented to control exposure. This is particularly important with regard to site visits by governmental and other VIPsma stricture that, unfortunately, is too often ignored for the sake of political grandstanding before the TV audience.
Scope of Decontamination Plan
269
Incompatible and Synergistic Chemical Contaminants
Incompatible chemicals (Table 11.1) are those that react with one another with the release of dangerous energy and other products, such as heat, explosion, fire, and toxic gases. Synergistic chemicals are those that, when introduced into the human body simultaneously (e.g., inhalation of certain pesticide particulates as well as petrochemical vapors), result in an unpredictable enhancement of the toxic or other harmful effects of one or more of the components of the mixture. In any incident involving chemicals, there is always the possibility that response personnel will be exposed to both incompatible and synergistic chemicals. It is this possibility that informs the on-site implementation of risk management practices and the selection of appropriate PPC and PPE. However, the use of any PPC, PPE, and other incident-related equipment itself defines the need for subsequent decontamination so as to (a) avoid hazards other than those immediately presented by the incident, and/or (b) avoid additional hazards derived from response operations, and/or (c) manage chemical risks to personnel regardless of the source of risk. The importance of decontamination as the means of avoiding incompatible and synergistic reactions beyond those immediately presented by the incident is twofold: 1. decontamination minimizes the probability that incompatible chemicals will be mixed as a direct result of response operations and, therefore, the likelihood that the risks associated with the incident will not be compounded by additional risks (either in kind or degree), and 2. decontamination minimizes the probability that response personnel will be unknowingly exposed to chemicals that could result in health and safety risks beyond those routinely expected by virtue of task assignment. Decontamination Stations and Facilities
The location and layout of on-site decontamination stations must be based on site-specific conditions of the actual incident, including: 1. precise nature of physical, chemical, and/or biological contaminants 2. specific resources that must undergo decontamination, including victims, response personnel, equipment and supplies, response vehicles, and any other site-related or incident-related materials (e.g., construction debris) 3. number and type of activities and associated equipment necessary to implement proper decontamination procedures (Fig. 11.2) 4. isolation from clean areas
270
II Decontamination TABLE I I.I Examplesof Chemical Incompatibilities (Adapted from the Dangerous Chemical Code, Bureau of Fire Prevention, City of Los Angeles Fire Department) Chemical
Avoid Contact with ...
Acetic acid
Chromic acid, nitric acid, hydroxyl compounds, ethylene glycol, perchloric acid, peroxides, permanganates
Acetylene
Chlorine, bromine, copper, fluorine, silver, mercury
Alkaline metals
Water, chlorinated hydrocarbons, carbon dioxide, halogens
Ammonia (anhydrous)
Mercury, chlorine, calcium hypochlorite, iodine, bromine, hydrofluoric acid (anhydrous)
Ammonium nitrate
Acids, metallic powders, flammable liquids, chlorates, nitrites, sulfur, finely divided organic or combustible materials
Aniline
Nitric acid, hydrogen peroxide
Bromine
Ammonia, acetylene, butadiene, butane, methane, propane, hydrogen, sodium carbide, turpentine, benzene, finely divided metals
Carbon (activated)
Calcium hypochlorite, all oxidizing agents
Chlorates
Ammonium salts, acids, metallic powders, sulfur, finely divided organic or combustible materials
Chromic acid
Acetic acid, naphthalene, camphor, glycerin, turpentine, alcohol, flammable liquids
Chlorine
Ammonia, acetylene, butadiene, butane, methane, propane, hydrogen, sodium carbide, turpentine, benzene, finely divided metals
Chlorine dioxide
Ammonia, methane, phosphine, hydrogen sulfide continues
Scope of Decontamination Plan
271
TABLE I I. I --continued
Chemical Cumene hydroperoxide
Avoid Contact with ... Acids (organic and inorganic)
Flammable liquids
Ammonium nitrate, chromic acid, hydrogen peroxide, nitric acid, sodium peroxide, halogens
Fluorine
Isolate from all other chemicals
Hydrocarbons
Fluorine, chlorine, bromine, chromic acid, sodium peroxide
Hydrocyanic acid
Nitric acid, alkaline chemicals
Hydrofluoric acid (anhydrous)
Ammonia (aqueous or anhydrous)
Hydrogen peroxide
Copper, chromium, Iron, alcohols, acetone, aniline, nitromethane, flammable liquids, combustible materials, most other organic materials
Hydrogen sulfide
Fuming nitric acid, oxidizing gases
Iodine
Acetylene, ammonia, hydrogen
Mercury
Acetylene, fulminic acid, ammonia
Nitric acid (concentrated)
Acetic acid, aniline, chromic acid, hydrocyanic acid, hydrogen sulfide, flammable liquids, flammable gases and liquids
Oxalic acid
Silver, mercury
Perchloric acid
Acetic anhydride, bismuth and its alloys, alcohol, paper, wood
Potassium
Carbon tetrachloride, carbon dioxide, water
Note.
The list of chemicals is not complete, nor are all incompatible substances for each chemical shown. 5. required protection of decontamination processes from the ongoing incident, response-operations, and weather conditions 6. ease of containing and otherwise managing decontamination wastes (e.g., runoff from washing contaminated vehicles) prior to their final treatment and disposal
Depending upon constraints of time, personnel, and/or the availability of proper equipment, decontamination cannot be completed on the site
272
I I Decontamination
9
Drop cloths of plastic or other suitable materials on which heavily contaminated equipment and outer protective clothing may be deposited
9
Collection containers, such as drums or suitably lined trash cans, for storing disposable clothing and heavily contaminated personal protective clothing or equipment that must be discarded
9
Line box with absorbents for wiping or rinsing off gross contaminants and liquid contaminants
9
Large galvanized tubs, stock tanks, or children's wading pools to hold wash and rinse solutions. These should be at least large enough for a worker to place a booted foot in and should have either no drain or a drain connected to a collection tank or appropriate treatment system
9 Wash solutions selected to wash off and reduce the hazards associated with the contaminants 9
Rinse solutions selected to remove contaminants and contaminated wash solutions
9
Long-handled, softbristled brushes to help wash and rinse off contaminants
9
Paper or cloth towels for drying protective clothing and equipment
9
Lockers and cabinets for storage of decontaminated clothing and equipment
9
Metal or plastic cans or drums for contaminated wash and rinse solutions
9
Plastic sheeting, sealed pads with drains, or other appropriate methods for containing
9
Shower facilities for full body wash or, at a minimum, personal wash sinks (with drains connected to a collection tank or appropriate treatment system)
9
Soap or wash solution, wash cloths, and towels for personnel
9
Lockers or closets for clean clothing and personal item storage
and collecting contaminated wash and rinse solutions spilled during decontamination
FIGURE 11.2 Equipment used for decontamination of personnel and personal protective clothing (adapted from NIOSH, USCG, and EPA, 1985" Occupational Safety and Health Guidance Manual for Hazardous Waste Activities).
of the incident. In fact, it is generally most advisable that on-site field decontamination be restricted (wherever possible) to: 9 persons (including victims and response personnel) who will not realize increased risk to life or health due to any delay of access to off-site professional medical services 9 personal protective clothing and equipment that must be readily available for subsequent use in response operations 9 any other materials or items that cannot be moved off-site without endangerment of the general public or environmental resources Where materials are removed to off-site locations and facilities for subsequent decontamination, it is necessary, of course, that suitable precautionary measures be taken at those locations and facilities to assure the effec-
Scope of Decontamination Plan
273
Design disinfecting facilities in stations with proper lighting, separate ventilation to the outside environment, fitted with floor drains connected to a sanitary sewer system, and to prevent contamination of other station areas. Within disinfecting facilities, install a minimum of 2 sinks with hot and cold water faucets and a sprayer attachment, and with drains connected to a sanitary sewer system. Sink faucets should not require the user to grasp, with hands, to turn on or off. All surfaces should be nonporous material with continuous molded counter top and splash panel surfaces Equip disinfecting facilities with rack shelving of nonporous materials. Shelving should be provided above sinks for drip-drying of cleaned equipment. All drainage from shelving should either go into a sink or drain directly into a sanitary sewer system. If possible, select front loading industrial laundry machines designed for the type of cleaning required for protective clothing. When exposure occurs, clean the equipment and store the waste water from this process in a double wall tank where it can then be pumped to waste transfer vehicles for appropriate disposal Provide a designated cleaning area in each station for the cleaning and disinfection of protective clothing, protective equipment, portable equipment, and other clothing. This cleaning area should have proper ventilation, lighting, and drainage connected to a sanitary sewer system. Physically separate the designated cleaning area from areas used for food preparation, cleaning of food and cooking utensils, personal hygiene, sleeping, and living areas; also physically separate the designated cleaning area from the emergency medical disinfecting facility. Store station emergency medical supplies/equipment, other than that stored on vehicles, in a dedicated, enclosed room protected from the outside environment. Store protective clothing and protective equipment in a dedicated, well-ventilated area or room Do not store reusable emergency medical supplies and equipment, protective clothing, and protective equipment in a kitchen, living, sleeping, or personal hygiene areas, nor shall it be stored in personal clothing lockers FIGURE 11.3 Precautionary measures for disinfecting facilities in fire and EMS facilities
(adapted from U.S. Fire Administration, 1997: Safety and Health Considerations for the Design of Fire and Emergency Medical Services Stations [FA 168]).
tive containment and management of contaminants prior to ultimate disposal (Fig. 11.3). Decontamination Methods and Equipment
Basic decontamination methods involve physical and/or chemical removal, detoxification, and disinfection/sterilization of contaminants.
274
II Decontamination
Low molecular hydrocarbons Inorganic compounds Salts Some organic acids Other polar (i.e., charged) compounds r
Water Basic (caustic) compounds Amines
Dilute Acids
Hydrazines
Acld compounds Phenols Thiols Some nitro & sulfonlc compounds
I"
Dilute Bases Non-polar (i.e., non-charged) compounds
Organic Solvents
Many organic compounds
"l
FIGURE 11.4 Examples of contaminants solubilized by each of four solvent types (adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Activities).
i. Physical/Chemical Removal
Gross dirt and caked muds (e.g., lodged in tire treads)containing nonadhesive contaminants can be physically dislodged by brushing, scraping, and pounding, followed by either simple flushing or pressurized air or rinse water. Adhesive contaminants may require more stringent physical treatment prior to physical dislodgment, including freezing {e.g., by dry ice or ice water), melting, adsorption onto other surfaces(e.g., sand), and ab-
Scope of Decontamination Plan
275
sorption into inert materials such as kitty litter or powdered lime. Various ultrasound devices may be useful for dislodging small amounts of either adhesive and nonadhesive materials. Steam jets are useful for cleaning many types of adhesive contaminants. Dusts and vapors of contaminants that collect in small openings in clothing and equipment may simply be washed free with water or blown free with an air jet. Contaminants that cling more tenaciously to materials by virtue of electrostatic forces may be more easily removed by water or air from materials that have been treated with commercially available antistatic solutions and sprays. Liquid contaminants may be wiped off, absorbed into inert substances, and/or, in the case of volatile liquids, air dried, followed by water rinse. Warm air or steam jets may be used to facilitate evaporation. The physical removal of liquefied contaminants may also be facilitated by solidification, which may involve the use of absorbents (e.g., clay, powdered lime) to remove moisture, dry ice, or water to cause freezing, or the addition of chemical catalysts that effect polymerization (i.e., chemical joining together of similar molecules into long chains). Regardless of the type of the type of process employed, the physical removal of gross contaminants should be followed by appropriate wash and rinse of contaminated materials. Primary wash solutions typically contain cleaners that depend upon the action of a variety of solvents (which dissolve contaminants) and surfactants (which, like household detergents, reduce the forces of adhesion between the contaminant and the material contaminated). Cleaners should therefore be selected on the basis of the compatibility of solvent types (Fig. 11.4) with the structural materials of items to be decontaminated. Manufacturers of PPC, PPE, and other types of response equipment typically supply information on solvent compatibility with the engineering specifications of manufactured items. Types of equipment needed for each type of physical/chemical removal (Fig. 11.5) are essentially containers (including storage tanks for wash and rinse solutions), sprayers, brooms, and brushes, as well as items used for containment of contaminants (e.g., curtains, booths) during the decontamination process. All equipment used for decontamination must be dedicated equipment (i.e., not to be used for any other purpose) that is also compatible with cleaning and solvent solutions. Physical decontamination also includes removal of contaminated surfaces as opposed to the removal of contaminants from surfaces. This process involves the disposal of materials and items (clothing, protective coverings, floor mats). However, before their final disposal, such items typically must undergo either chemical deactivation or disinfection to ensure that they do not contaminate environmental resources. No materials can be finally disposed
276
I I Decontamination
9
Storage tanks of appropriate treatment systems for temporary storage and/or treatment of contaminated wash and rinse solutions
9
Drain or pumps for collection of contaminated wash and rinse solutions
9
Long-handled brushes for general exterior cleaning
9
Wash solutions selected to remove and reduce the hazards associated with the contamination
9
Rinse solutions selected to remove contaminants and contaminated wash solutions
9
Pressurized sprayers for washing and rinsing, particularly hard-to-reach areas
9
Curtains, enclosures, or spray booths to contain splashes from pressurized sprays
9
Long-handled brushes, rods, and shovels for dislodging contaminants and contaminated soil caught in tires and the undersides of vehicles and equipment
9
Containers to hold contaminants and contaminated soil removed from tires and the undersides of vehicles and equipment
9
Wash and rinse buckets for use in the decontamination of operation areas inside vehicles and equipment
9
Brooms and brushes for cleaning operator areas inside vehicles and equipment
9
Containers for storage and disposal of contaminated wash and rinse solutions, damaged or heavily contaminated parts, and equipment to be discarded
FIGURE I 1.5 Equipment used for decontamination of heavy equipment and vehicles (adapted from NIOSH, USCG, and EPA, 1985" Occupational Safety and Health Guidance Manual for Hazardous Waste Activities).
except in conformance with applicable hazardous waste regulations. It is therefore necessary to coordinate directly with hazardous waste authorities and RCRA permitted transporters and treatment, storage, and disposal (TSD) facilities to determine appropriate disposal requirements and constraints. Any means of physical/chemical removal (especially those involving heat or pressurized steam) may result in vapors, particles, and liquids that may present risk to the person employing them through inhalation or through eye or skin contact. Physical removal methods typically do not alter the chemical attributes of contaminants, nor affect the viability of pathogenic organisms. Caution must therefore be used with all methods, with appropriate attention paid to (a) personal protective clothing and equipment (e.g., gloves, goggles, respiratory protection) to be used by the person performing the decontamination procedure, (b) containment of all dislodged contaminants to prevent entry into environmental resources or contact with other persons, and (c) additional treatment (as may be required) to deactivate or disinfect dislodge materials prior to final disposal. 2. Detoxification
Detoxification is essentially a chemically, physically, or biologically mediated change in (a) the molecular structure of a contaminant molecule,
Scope of Decontamination Plan
277
or (b) the chemical dynamics of a contaminant mixture or solution to achieve a less hazardous substance or material. Commonly used chemical detoxification procedures involve the removal of halogen atoms (e.g., chlorine, bromine, fluorine, iodine) from a contaminant molecule (e.g., carbon tetrachloride, trichloroethane), which is known as halogen stripping; the addition or removal of electrons (or hydrogen) from the contaminant molecule (e.g., transformation of an alcohol to organic acid), which is known as oxidation (when electrons are added) or reduction (when electrons or hydrogen atoms are removed); and the addition of acids or bases to a contaminant solution to adjust either the acidic or the alkaline nature of the solution toward a less corrosive state, which is called neutralization. The most commonly used physical detoxification procedure is thermal degradation, in which heat is used to transform a contaminant molecule into a less hazardous molecule. Other chemical and physical processes may be used (or are under ongoing investigation and development) to effect changes in the structure and/ or chemical dynamics of contaminant molecules, such as chelation, which involves the addition of chemicals that tightly bind to contaminant molecules, thereby facilitating their removal or otherwise reducing their chemical reactivity. Biological agents may also be used to degrade contaminants to less hazardous substances, as in the use of selected species of bacteria and yeasts to degrade certain types of petrochemicals and pesticidesma rapidly expanding technology known as bioremediation. Emergency response services are well advised to be extremely cautious with regard to the use of any detoxification method. There are several reasons for this caution: 9 Even standard detoxification methods (e.g., neutralization, halogen stripping) are typically employed only when there is detailed chemical knowledge and understanding of the chemical dynamics involved 9 The effectiveness and safety of detoxification methods is dependent on a large number of factors, including the concentration of target contaminants, the concentrations of potentially interfering chemical species in a contaminant mixture, and the ambient conditions under which the procedure is performed 9 The treatment of any hazardous or potentially hazardous waste can be legally undertaken only by U.S.EPA permitted facilities that conform to strict procedural and technical requirements In light of these considerations, response services should rely on the advice of regulatory authority and, as necessary, seek out the professional services of properly licensed contractors who are legally, scientifically, and technically competent to undertake detoxification.
278
I I Decontamination
T A B L E I 1.2 Decontamination Methods for Equipment Used in the pre-Hospital Health-Care Setting (Adapted from the U.S. Fire Administration, 1992: Guide to Developing and Managing an Emergency Service Infection Control Program [FA-112])
Process Sterilization
High-Level Disinfection
Application
Details
Target
All forms of microbial life, including high numbers of bacterial spores
Method(s)
Steam under pressure (autoclave), gas (ethylene oxide), dry heat, or immersion in EPAapproved chemical sterilant for prolonged period of time (e.g., 6-10 hours or according to manufacturers' instructions). Liquid chemical sterilants should be used only on those instruments that are impossible to sterilize or disinfect with heat.
Use
For those instruments or devices that penetrate skin or contact normally sterile areas of the body (e.g., scalpels, needles). Disposable invasive equipment eliminates the need to reprocess these types of items. When indicated, however, arrangements should be made with a healthcare facility for reprocessing of reusable invasive instruments
Target
All forms of microbial life except high numbers of bacterial spores.
Method(s)
Hot water pasteurization (80-100~ for 30 minutes) or exposure to an EPA-registered sterilant chemical (as above), except for a short exposure time (10-45 minutes, or as directed by the manufacturer).
Use
For reusable instruments or devices that come into contact with mucous membranes (e.g., laryngoscope blades~ endotracheal tubes).
continues
3. Disinfection/Sterilization
Both disinfection and sterilization involve the killing of microorganisms, but differ with respect to the range of microbes actually killed. As shown in Table 11.2, disinfection may be carried out at various levels of efficacy as defined by the types of microbes (e.g., bacteria, viruses, fungi) affected and whether or not the disinfecting agent (e.g., heat, germicide) destroys bacterial spores (i.e., reproductive structures of bacteria). Only sterilization, which involves the use of an autoclave, a sterilant gas, a liquid sterilant, or dry heat, can destroy all forms of microbial life as well as a large proportion of bacterial spores. It should be noted, however, that even sterilization techniques do not necessarily kill all bacterial spores.
279
Scope of Decontamination Plan T A B L E I I .2~continued
Process Intermediate-Level Disinfection
Low-Level Disinfection
Application Target
Mycobacterium tuberculosis, vegetative bacteria, most viruses, and most fungi; does not kill bacterial spores.
Method(s)
EPA-registered "hospital disinfectant" chemical germicides that have a label claim for tuberculocidal activity; commercially available hard-surface germicides or solutions containing at least 500 ppm free available chlorine (a 1:100 dilution of common household bleach; approximately 88cup bleach per gallon of tap water).
Use
For those surfaces that come into contact only with intact skin (e.g., stethoscopes, blood pressure cuffs; splints), and which have been visibly contaminated with blood or bloody body fluids. Surfaces must be pre-cleaned of visible material before the germicidal chemical is applied for disinfection.
Target
Most bacteria, some viruses, some fungi, but not Mycobacterium tuberculosis or bacterial spores.
Method(s) Use
Environmental Disinfection
Details
EPA-registered "hospital disinfectant" (no label claim for tuberculocidal activity). These agents are excellent cleaners and can be used for routine housekeeping or removal of soiling in the absence of visible blood contamination. Environmental surfaces that have become soiled should be cleaned and disinfected using any cleaner or disinfectant agent which is intended for environmental use. Such surfaces include floors, woodwork, ambulance seats, countertops, etc.
Important: To assure the effectiveness of any sterilization or disinfection process, equipment and instruments must first be thoroughly cleaned of all visible soil.
With the exception of certain emergency medical service organizations, very few emergency response services possess the equipment to carry out effective sterilization. Even where appropriate sterilization equipment is available, it is impractical (if not impossible) to sterilize large equipment or PPC and PPE. Wherever possible, therefore, disposable clothing and equipment should be used, with appropriate planning for safe disposal through incineration. No infected clothing or equipment should be deposited in a landfill unless it has been sterilized.
280
I I Decontamination
If hot water is used, linen should be washed with detergent in water at least 71 ~ (160 ~ for 25 minutes. If low temperature (<= 70 ~ or 158 ~ laundry cycles are used, chemicals suitable for low-temperature washing at proper use concentration should be used.
Disinfectant-detergent formulations registered by EPA can be used for cleaning environmental surfaces, but the actual physical removal of microorganisms by scrubbing is probably at least as important as any anti-microbial effect of the cleaning agent used.
Infective waste, in general, should either be incinerated or should be autoclaved before disposal in a sanitary landfill. Bulk blood, suctioned fluids, excretions, and secretions may be carefully poured down a drain connected to a sanitary sewer. Sanitary sewers may also be used to dispose of other infectious wastes capable of being ground and flushed into the sewer.
Information on specific label claims of commercial germicides can be obtained by writing to the Disinfectants Branch, Office of Pesticides, EPA, 401 M Street, SW,
In addition to commercially available chemical germicides, a solution of sodium hypochlorite (household bleach) prepared daily is an inexpensive and effective germicide. Concentrations ranging from approximately 500 ppm (1:100 dilution of household bleach) sodium hypochlorite to 5000 ppm (1:10 dilution of household bleach) are effective depending on the amount of organic material (e.g., blood; mucus) present on the surface to be cleaned and disinfected.
11.6 Selected guidelines regarding proper cleaning, disinfection, and/or disposal of infected materials (based on information provided by U.S. Department of Health and Human Services, 1989: A Curriculum Guide for Public-Safety and Emergency-Response Workers: Prevention of Transmission of Human Immunodeficiency Virus and Hepatitis B Virus [89-108]). FIGURE
Disinfection by means of commercially available and U.S. EPA registered germicides, household bleach, and cleaning agents (Fig. 11.6) is effective only when proper attention is given to the prior removal of gross dirt and grime. This is because a disinfectant must come into direct contact with a microbe in order to kill it, and dirt, grime, and other materials prevent direct contact between the disinfectant and the target organism. The duration of contact between the disinfectant and the target organism is also important--the longer the contact, the greater the probability the microbe will be killed. Detailed information concerning the precleaning of infected items required for the effective use of germicides, as well as recommended contact times, is printed on germicide labels. Additional information concerning germicide labels can also be obtained directly from the U.S. EPA.
Scope of Decontamination Plan
281
Prevention of Contamination of Clean Areas
During an actual incident, the most important means of preventing the contamination of clean areas is the establishment of work zones. Depending upon the nature of the incident, any number of clearly demarcated work zones may be designated. In most incidents involving hazardous waste sites, three zones are typically used:
I. Exclusion Zone
This is the contaminated area or an area that is likely to become contaminated in the process of the incident. The outer boundary of this zone is the hotline, which must be clearly marked. The precise location of the hotline is determined on the basis of various considerations, including: (a) known or possible routes of dispersion of contaminants (including surface runoff and wind dispersion), (b) the amount of contaminants, (c) the relationship of site topography to the actual and potential area of contamination, (d) distances necessary to prevent any possible explosion or fire within the exclusion zone from affecting personnel outside of the exclusion area, (e) area necessary to conduct response operations, including the use of response vehicles and heavy equipment, (f) on-site meteorological conditions, including both current and projected conditions, and (as time may permit), (g) field monitoring data (including data derived from air, water, soil, and contaminant sampling). As the incident develops and more information becomes available about the nature of contaminants and other potential risks (e.g., underground tanks, subsurface transformer stations, underground electrical cables), it may become necessary or advisable to adjust the delimitation of the hotline to better protect personnel. Access control points must be established on the hotline to manage the movement of response personnel and equipment into and out of the exclusion zone. The exclusion zone itself may be subdivided on the basis of different types of hazards and/or degree of risk encountered or expected. The type of personal protective clothing and equipment required within the exclusion zone must be clearly indicated at access points and, as appropriate, within each subdivision.
2. Contaminant Reduction Zone
This is the zone where decontamination occurs; it is essentially a buffer area between the highly contaminated exclusion zone and the contaminant-free area of the site (Fig. 11.7).
282
I I Decontamination
Contaminant /
t/
'
Exclusion Zone
Hotline
Contaminant Reduction Zone
Contamination Control
Contamination Reduction
Corridor
Heavy EquipmentUne Personnel Une
Line
_~~-~
Support Z o n e i
Incident Command Post
] Helibase
Helispot
i t
Note:DisplayofActual LayoutofICSStructures isnotintended Area
Cam
Base
p ~ i
11.7 Schematic example of layout of various work zones and ICS-related facilities (note standard ICS symbols used for these facilities).
FIGURE
All access to and through the contaminant reduction zone is through the contamination reduction corridor, which extends from the contaminantfree area of the site through the hotline. Access points must be established on the "clean side" of this corridor to control entry and exit. Within the contamination reduction corridor, at least two lines of decontamination should be established~one for personnel, and one for equipment. As personnel and equipment move from work assignments in the exclusion line toward the clean area, decontamination takes place and, therefore, the risk of contaminating the clear area diminishes. While the essential layout of the contamination reduction zone is based on the need to decontaminate personnel and equipment (in the con-
Scope of Decontamination Plan
283
tamination reduction corridor), it must also accommodate other important functions, including: 9 Emergency response, including the transport of injured response personnel and emergency first aid 9 Emergency containment equipment and operations 9 Resupply of operational equipment, including PPC and PPE, sampiing equipment, and tools 9 Packaging and preparation of samples (e.g., soil, debris, hazardous wastes) for subsequent analysis 9 Rest and recovery areas for response personnel, including toilet facilities, potable water, washing facilities 9 Safe containment of all liquids and other materials used in the decontamination process
3. Support Zone This is the clean area in which all response-related administrative duties and all other operations that need not be performed in either the exclusion or contaminant reduction zones are performed. While the support zone is operationally protected by the contamination control line, it should be noted that, as the emergency develops, necessary adjustments to the location of the contamination control line could result in adjustments to the location of support zone facilities, with consequent interference in overall incident management. The location of support zone facilities must therefore be based as much as possible on a worst-case analysis of the developing incident, while still maintaining practical administrative control of all onsite activities. Other factors in locating specific support zone facilities (e.g., incident command post, staging area, incident base, camps, helibase, and helispot) include: 9 Accessibility for emergency vehicles and equipment 9 Availability of electrical power, telephones, shelter, potable water, and roads 9 Line-of-site visibility of incident-site operations (while still locating facilities as far away from the exclusion zone as possible) 9 Wind direction and topography (which could influence intrusion of wind-blown or runoff-entrained contaminants into the support zone) Removal of PPC and PPE
Depending on the nature of an actual incident and types and degrees of risk, the incident safety officer will establish (a) requirements for protec-
284
I I Decontamination
tive ensembles and equipment to be used by response personnel in the exposure zone, and (b) specific steps for removing and disinfecting each article in the process of moving from work areas within the exposure zone to the support zone. As depicted in the example in Fig. 11.8, decontamination procedures extend (via the contamination reduction corridor) into both exclusion and support zones, even though they are most vigorous in the contamination reduction zone. Decontamination procedures designated for the exclusion zone are intended to prevent gross contamination of the contamination reduction zone; those designated for the contamination reduction corridor, to remove all remaining contamination prior to entry to the support zone. The number and sequence of steps along the decontamination line depend upon actual site conditions, becoming more numerous and stringent with increasing hazards and risks associated with the exclusion zone. In some instances, it may be necessary to establish resting/cooling stations along the decontamination l i n e n a s when response operations must be undertaken under ambient conditions of high heat and humidity. While typical layouts of decontamination stations (such as those included in Fig. 11.8) have long been established for incidents that involve hazardous waste, similar configurations (adaptations thereof) may be employed for incidents involving nonhazardous waste sites but which nonetheless present the hazard of contamination with physical, chemical, or biological agents. Of course, depending upon the nature of the contaminant hazard, different types of decontamination activities at the various stations of the decontamination line may have to be implemented.
Disposal of Contaminated Materials A key consideration with regard to any decontamination line is the waste that is generated as a consequence of performing the various decontamination procedures, including: 9 9 9 9 9 9
neutralization spray solution detergent wash solution disinfectant rinse solution rag and paper wipes clumps and scrapings of contaminated mud disposable PPC and PPE
The decontamination program must specify how these various wastes are to be packaged and disposed in compliance with applicable federal, state, and local regulations. It is important to distinguish between contaminated
285
Scope of Decontamination Plan
From Work Area
OuterGlove
Boot Cover& a Glove 111. mm
Tape
Exclusion Zone Boot Cover Removal
Boot Cover & Glove Rinse
Segregated Equipment Drop
Hotline
TankChange and Redress (Boot Cover/Outer Gloves)
~
Suit/SafetyBootWash
~
Sui',/SafetyBoot Rinse
~
SafetyBootRemoval Fully Encapsulating Suit
and HardHat Removal
SCBA Backpack Removal
Contamination Reduction Zone
Inner GloveWash
~
Inner Glove Rinse
FacePieceRemoval Inner Glove Removal
InnerClothing Removal
Contamination Control Line Field Wash ~
Redress
Support Zone
FIGURE I 1.8 Maximum decontamination layout: level A protection (adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Activities).
286
I I Decontamination
waste generated by the incident and that generated by on-site decontamination procedures designed for response personnel and equipment. In many instances, for example, contaminated construction debris (e.g., from a collapsed building or other structure) presents a major obstacle to the primary response effort (e.g., search and rescue) and must be moved out of the way as quickly as possible. In such a situation, it is very unlikely that there will be time or resources to decontaminate debris; on-site storage, with provision for containment, must then be implemented. Once the primary response effort has been concluded by the lead responding agency, the management of bulk contaminated debris (including decontamination and disposal) typically becomes the responsibility of another agency having appropriate jurisdictional authority. In some instances, contaminated PPC, PPE, and other response equipment are wrapped or placed in secure bulk containers for subsequent decontamination at the home-base of the response service. EMERGENCY D E C O N T A M I N A T I O N
Emergency decontamination may have to be undertaken as a result of any on-site accident involving response personnel, whether that accident results in relatively minor or major injury to personnel. Figure 11.9 includes a standard decision guide for determining the steps to take in such a situation. While the various steps included in this guide are designed to maximize the administration of appropriate on- and/or off-site medical response to such an emergency, it is also important that the medical response not result in the contamination of on-site "clean areas" or of off-site medical personnel, facilities, or ambulance services. Of course, in a life-threatening situation, it is the health of the injured worker that must be given priority, which sometimes requires a highly abbreviated on-site decontamination effort, consisting primarily of wrapping the victim in a protective covering (e.g., blanket, plastic) that can contain gross contamination and which can be later decontaminated and disposed. However, before wrapping the contaminated victim in a blanket or plastic sheet, it is vitally important to remove or cut off as much grossly contaminated clothing as possible in order to minimize contact of contaminants with the victim's body. Any clothing gives some degree of protection against contamination and, of course, the protective clothing worn by response personnel is specifically selected to maximize protection. However, all clothing is subject to permeation by contaminants, the degree of permeation being subject to various factors (Fig. 11.10), including (a) the time interval in which contaminants are in contact with the clothing, (b) the physical state and chemical
287
Emergency Decontamination Accident/Injury Event
NO
YES
Perform Life-Saving
Procedures
NO
YES Grossly
Decontaminate
and/or Cover or Wrap Contaminated Areas
Decontaminate as Much as Possible
1 ~'
NO--.~
., r '
Emergency _ Care .^
/
YES NO
Report to Superiors for Instructions
YES
.,~ Transport to Medical Facility
L
r
FIGURE I 1.9 Decisionguide for emergency decontamination (adapted from NIOSH, USCG, and EPA, 1985: Occupational Safety and Health Guidance Manual for Hazardous Waste Activities).
nature of the contaminant, (c) the concentration of the contaminant, and (d) the ambient temperature. In an emergency situation, it is therefore most advisable to strip the victim of any obvious contaminated clothing or equipment as quickly as possible. No attempt should be made to wash or rinse gross contamination off of the victim's clothing because this would most
288
I I Decontamination
P E Temperature The higherthe temperature, the greater the permeation "~
Contact Time The longerthe contactwith a contaminant,the greaterthe permeation
P E RM E A T I O N
A T ~ Physical State of I Contaminant P E R M E A T I O N The greaterthe proportionof M N gases, vaporsand lowE viscosityliquids in Concentration of A contaminant materials,the Contaminant T greater the permeation The greaterthe I concentration of O contaminant, the greater N the permeation ~
F I G U R E I I. I0 Four key factors that influence the permeation of contaminant chemicals into protective clothing and equipment (adapted from information provided by OSHA, OSHA Technical Manual, Section 7, OSHA Electronic Library).
likely increase the rate of permeation of the contaminant through that clothing. Depending on the nature of the contaminant, a wash or rinse solution could also result in enhanced risk due to unsuspected chemical or physical reactions of the contaminant with rinse solutions--a situation that usually cannot be reliably assessed in the press of an emergency. In all situations involving the spillage of blood or the release of body fluids, appropriate decontamination (Fig. 11.11) should be implemented to minimize the potential for the spread of bloodborne diseases. This procedure, including the universal precautions always to be associated with handling blood and body fluids, is as applicable (and necessary) in an emergency situation as in any nonemergency situation and need not in any way interfere with the timely emergency treatment of the victim. Where it is impossible to decontaminate the victim properly prior to off-site transport, it is important that the victim be accompanied to the offsite medical facility by a person who is fully knowledgeable of (a) the type of contaminant to which the victim has been exposed, (b) the nature of emergency decontamination that was performed on the victim while on-site, and (c) the appropriate types of decontamination and other precautions that medical, rescue, and other emergency personnel should employ during and subsequent to transporting, handling, and treating the victim.
289
Emergency Decontamination
Cleaning and Decontamination of Spills of Blood I [
\
.
/
Put on disposable gloves and remove visible material by cleaning with disposable towels or another means that ensures against direct skin contact with blood. Place soiled towels in plastic bag to prevent contamination with other surfaces.
\
,,,
/
Wear appropriate face and eye protection if splashing | of blood is possible. 1
\
/
If the amount of the blood in the area is great, wear | shoe coverings that will not allow blood and fluids to seep through.
\
/
1_
After removal of visible material, decontaminate with appropriate germicide or a 1"100 solution of household bleach. Use clean towels with germicide to wipe area. Let the area air dry.
\
/
After decontamination of the area, remove contaminated items, shoe coverings, and gloves and place in plastic bag for disposal or decontamination. Remove gloves last.
\
/ V
FIGURE I1.11 Directions for cleaning and decontaminating spills of blood (adapted from U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, 1989: A Curriculum Guide for Public-Safety and Emergency-Response Workers [89-108]).
290
I I Decontamination
Because the potential for injury of response personnel is always high, emergency decontamination and all associated activities (e.g., rescue), procedures (e.g., emergency first aid), and equipment (e.g., ventilation equipment in ambulances) must be viewed as an integral component of the site safety plan. The site safety officer must therefore ensure that all possible needs for decontamination as a result of response operations and contingencies be thoroughly examined and appropriate proactive policies and SOPs established. Moreover, because the need for emergency decontamination may (depending upon the nature of the incident) instantaneously escalate due to uncontrollable exposure of the general public, extensive planning is required to deal effectively with the decontamination of not only individual response personnel but also large community populations. Given the potential scope of emergency decontamination in any incident (and, especially, in terrorist incidents), effective proactive planning depends heavily upon effective coordination with local, state, and Federal rescue, response, and support resources (Table 11.3) that are available to provide a wide range of services, including on-site emergency treatment of victims, the control and stabilization of hazardous conditions that could result in increased instances of exposure to contaminants, and the provision of technical assistance and equipment. While it is typically the responsibility of the safety officer of the lead response organization to provide for the basic on-site equipment needed to control potential contaminants and to implement emergency decontamination (Table 11.4), no local response agency or organization can be expected to maintain sufficient equipment to meet the potential decontamination needs of large off-site populations. This situation underscores the importance of interagency and interorganizational liaison to ensure the regional stockpiling (e.g., in civil defense and state repositories) or other timely availability (e.g., Federal Emergency Management Agency, regional response team stockpiles) of equipment, materials, and supplies that can be used both to control the spread of contaminants into the general population and to effect, as needed, decontamination of large numbers of persons and vital community resources. With regard to the local availability of equipment and supplies required proactively and reactively for the control of contaminants and incident-related decontamination, municipal managers should consider the use of municipal-wide inventories of potential industrial contaminants to identify potential equipment and supply needs, including not only the types and amounts of equipment and supplies that should be stockpiled or made available via requisition, but also needs regarding (a) the maintenance, upkeep, and replacement of identified equipment and supplies, (b) the timely transport of supplies under worst-case conditions, and (c) back-up supplies that may be needed in the event of simultaneous incidents.
291
Emergency Decontamination T A B L E I 1.3 Types of Support Services Typically Available through Federal, State, and Local Support Services
I
Agency or Organization
Rescue Response Supportii
Federal Army Corps of Engineers Coast Guard Department of Defense (DOD) Department of Transportation Environmental Protection Agency (EPA) Federal Aviation Administration (FAA) Federal Emergency Management Agency (FEMA) National Institute for Occupational Safety and Health (NIOSH) Occupational Safety and Health Administration (OSHA)
t !
"]
1
r----]
State Civil defense Department of Health Department of Labor Environmental Agency Office of the Attorney General State Police I
Local Ambulance and rescue services Cleanup contractor Disposal companies Fire department Hospital Police Red Cross Salvation Army Transporters Utility companies
I I l [ I
!
1
I
.......
I
i
!
I
I
i
t
I
i
i
I
i
!
i
I
i
I
i
292
I I Decontamination
T A B L E I 1.4 Basic On-Site Equipment Used to Control Exposure to Contaminants and to Implement Emergency Decontamination Procedures
Personal Protection 9
Escape SCBA or SCBA, which can be brought to the victim to replace or supplement his or her SCBA
9
Personal protective equipment and clothing specialized for known site hazards
Medical Air splints Decontamination solutions appropriate to onsite hazards Reference books containing basic firstaid procedures and Information on treatment of specific injuries
9 Antiseptics 9 Emergency eye wash 9 Resuscitator 9 Safety Harness 9 Stretchers 9 Water, in potable containers
9 9
Blankets Emergency showers or wash stations 9 Wire basket litter (Stokes litter) which can be used to carry victim in bad weather and on difficult terrain, and is itself easy to decontaminate
Hazard Mitigation 9 9 9 9
Fire-fighting equipment and supplies Spill-containment equipment, such as absorbents and oil booms Special hazardous-use tools, such as remote pneumatic impact wrenches, nonsparking wrenches and picks Containers to hold contaminated materials
Toward the same objective, industrial managers should explore the potential for mutual assistance programs among industrial partners, with particular emphasis given to mock-incidents as a means of training multifacility personnel to ensure the rapid delivery of fully operational contamination control equipment, supplies, and, as appropriate, personnel to the incident scene.
DATA AN D INFORMATION MANAGEMENT
INTRODUCTION
Though often used synonymously to refer to "things that are known," the terms data and information may be variously distinguished. For example, some prefer to reserve the use of data (plural of datum) for reference to quantitative knowledge and information for qualitative knowledge. Others prefer to distinguish between them not on the basis of type of knowledge but, rather, on whether or not individual pieces of knowledge have been integrated into a larger understanding~an approach that reserves the use of data (or datum) for singular pieces of knowledge and information for data that have been connected to other knowledge bases or otherwise purposely processed for use. By either definition, emergency response is always a data- and information-intensive effort, not only in terms of the level of detail, but also in terms of the diversity of data and information that must be collected, evaluated, and acted upon. The management of data and information is therefore absolutely critical to the success of emergency response. Moreover, because the focus of both proactive and reactive emergency response is always action~in particular, the act of making decisions, it is perhaps best to view data as either qualitative or quantitative knowledge that must be processed into precisely that information which is most useful for decisionmaking. Given the widespread accessibility to global information networks and databases and the ready availability of an ever-expanding computer 293
294
I1 Data and Information Management
technology, it might appear that the management of emergency-related health and safety data and information should be a relatively simple task. However, it is well worth considering that access to global data banks and information networks enhances not only the potential for improvement in the efficiency and comprehensiveness of decision-making, but also the potential for utter confusion. Even the most sophisticated technology for retrieving and processing information is no guarantor of competence, nor can it correct the consequences of incompetence. As happens with the application of any new technology, the application of computer technology to emergency response needs is subject to a variety of misconceptions that can actually contravene the objectives of the response service. Some of the most common misconceptions involve the following considerations: 1. Despite the continuing development of expert programs, computers are essentially ignorant tools. While an extremely powerful tool in terms of flexibility, efficiency, and range of applications, a computer cannot as yet even begin to substitute for human intelligence. The practical consequence of this simple fact must be the realization that any aspect of computerized response applications must be fully conceived and developed before appropriate computerization should even be attemptedmand, even then, only when the specific objectives of computerization can be clearly defined in terms of the actual needs of emergency response. 2. The rapidity with which we can now access worldwide databases means that we can retrieve bad information as quickly as we can good information. In fact, one may reasonably suppose that the likelihood of retrieving bad information, pure nonsense, or at least misleading data is far greater than retrieving information that is subject to strict quality criteria and review. The practical consequence of this situation is that data and information to be used for emergency response purposes must be evaluated for its veracity and pertinence regardless of source. 3. Software marketing hoopla to the contrary, there is no single computer program that can meet all the needs of managing emergency response databases. Each program has its capacities and its limitations--and both its capacities and its limitations are inherently obstinate. The practical consequence of this must be the realization that the capacities and limitations of each program must be carefully evaluated with regard to specific objectives of the hazardous response service. There is, in short, no such thing as "an excellent program" except that it meets precisely defined needs and objectives. Given the importance that a computer program serve specific response needs and objectives and not vice versa, emergency response planners and safety officers should seriously consider developing, where possible,
Expert Software
295
custom-made computer programs rather than simply relying upon commercially available "canned" or "off-the-shelf" programs. While this alternative is too often given little serious attention, it should be noted that few companies or other organizations entrust their financial, inventory, or billing procedures to over-the-counter computer programs but, rather, utilize the consulting services of professional programmers. Moreover, the ready availability of powerful yet simple programming languages and tools (e.g., Visual Basic) makes it increasingly possible for in-house response personnel who are not professional programmers to develop highly useful programs. 4. In many companies and organizations having extensively computerized operations, and especially where such operations entail the use of mainframe computers, computer programs and procedures are typically centralized in a computer operations or data processing department. Even where PC networking (as opposed to mainframe systems) is employed, such a centralized department usually exerts full authority over all computer hardware and software. Certainly there are very good reasons for this, including the need for data and information security and the handshaking requirements of computer networks. However, it is reasonable to suggest that there are practical levels of flexibility required in order to ensure that the needs of corporate financial management, inventory control, and office management do not unnecessarily constrain the operational needs of health and safety programs and, in particular, those health and safety programs directly relevant to emergency response. In proposing appropriate computerization of the various elements of health, safety, and emergency-response programs, particular attention must be given to defining capabilities that provide timely and practical information to emergency response personnel without conflicting the needs of other computer-assisted corporate functions and operations. EXPERT S O F T W A R E
Over the past decade there has been an explosive development of professionally designed software of particular importance to emergency planning and response. Some of this software has been designed by governmental agencies having broad jurisdictional responsibility and/or special expertise regarding certain types of emergencies; some has been designed by independent experts who, often in close coordination with emergency response services, focus on practical response needs that are particularly dataintensive. For example, CAMEO (Computer-Aided Management of Emergency Operations) is a software suite developed by the U.S. Environmental Protection Agency (EPA) and the National Oceanic and Atmospheric Administra-
296
12 Data and I n f o r m a t i o n M a n a g e m e n t Heavy gas and neutrally buoyant gas modeling; calculates indoor air infiltration; estimates gas cloud area and concentration over time, under varying environmental conditions; uses weather data that can be inputted by user or directly from a meteorological station; plots toxic cloud "footprint" onto area maps A database of more than 4,700 chemicals, 70,000 synonyms, trade names, and other labeling conventions; each chemical is linked to a Response Information Data Sheet (RIDS) that details the chemical-specific information on fire and explosive hazards, health hazards, fire fighting techniques, cleanup procedures, and protective clothing
Employs area maps using either digitized data generated by the U.S. Bureau of the Census, or scanned or drawn images; allows users to search and display roadways, street addresses, waterways, railroads and census blocks and other political boundaries; users may design custom map overlays to display facilities an chemical information, evacuation zones, special populations, and hazards analysis vulnerability zones.
FIGURE
12. I Basiccomponents of the computer-aided management of emergency operations (CAMEO) interactive program.
tion (NOAA) to assist both governmental and private sector managers in (a) planning for and mitigation of chemical accidents, and (b) meeting regulatory compliance objectives of the Emergency Planning and Community Right to Now Act of 1986 (EPCRA; SARA Title III). Designed for use by EPCRA-defined entities, such as Local Emergency Planning Committees (LEPCs) and State Emergency Planning Commissions (SERCs) as well as by fire departments, emergency planners, and chemical facilities, CAMEO meets four key objectives: 9 Provides instant access to safety and emergency response information on more that 4700 chemicals 9 Tracks chemical inventories in the community and in transit 9 Provides for the electronic submission of reports submitted by regulated facilities in compliance with EPCRA 9 Performs an analysis of hazards and off-site consequences of airdispersed chemical plumes CAMEO is composed of three interactive programs (Fig. 12.1): ALOHA, which is a sophisticated air-dispersion model; MARPLOT, which is a mapping application for planning and managing field response operations at chemical incidents; and the CAMEO chemical database, which includes chemical-specific information on fire and explosive hazards, health
Elements of In-Service Data and Information Base
297
hazards, fire fighting techniques, cleanup procedures, and protective clothing. The U.S. National Safety Council (NSC) provides extensive professional training on the use of CAMEO and can be directly accessed via the internet for additional information and training purposes (http://www.nsc.org/ehc/ CAM/trn_main.html). Other commercially available expert programs are also easily accessed via the internet, including programs that meet both general and highly specific emergency response operational and management needs, such as: 9 3-D modeling of groundwater flow and contaminant plumes 9 hydrodynamic simulation of hydraulic flow in open channels 9 simulation of contaminant flow in lakes, estuaries, and coastal waters 9 modeling of soil-vapor interactions 9 modeling of contaminant flow, transport, and environmental fate in saturated and unsaturated soils 9 simulation of environmental transformations of hazardous chemicals These and many other such expert programs can be accessed most easily through the use of such search-phrases as "computer models, .... dispersion models," or "transport simulations," or through the home pages of individual providers (e.g., Scientific Software Group: http://www.gwsoftware.com/). Of course, the most important sources of information regarding highly useful expert programs for emergency response are practicing emergency response professionals. For example, one of the most important software tools under current development for firefighters and other rescue personnel utilizes virtual reality technology to provide response services an operational management tool as well as a highly effective training technique by integrating sitespecific structural, locational, and hazard information with simulated optical feedback. Information about this developing technology is available through Firemaster James Jameson, Strathclyde Fire Brigade (U.K.).
E L E M E N T S OF IN-SERVICE D A T A A N D I N F O R M A T I O N BASE
While the data and information base for emergency planning and response must serve the site-specific needs of an actual incident, certain types of data and information have universal relevance and can easily be implemented without the aid of expert programs and techniques derived from external sources. Examples of minimal types of data and information bases and the necessary cross-referencing among individual databases may be briefly summarized as follows:
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12 Data and Information Management
1. Persons and Personnel at Potential Risk 9 response personnel by name and operational task category, with cross-reference to potential sources of risk or hazard, pertinent regulations, training needs, required protective equipment, communication needs, decontamination and waste disposal requirements, emergency medical treatment, required medical surveillance, personal susceptibilities, or other factors of special relevance to health and safety 9 other on-site persons, including facilities employees, contractors, consultants, and other support personnel, with cross-reference to specific health and safety precautions, evacuation and temporary shelter needs, taskrelated restrictions and constraints, and documentation requirements 9 off-site persons who may be exposed to hazards associated with incident and response operations, including property abutters, downwind or downstream residents and communities, with cross-reference to environmental mechanisms of dispersal of hazardous materials and substances, automatic and manual alarm devices and systems, and evacuation procedures 2. Inventory and Assessment of Hazards 9 Types of physical, chemical, and biological hazards, with crossreference to source, modes of exposure, chronic and acute effects, signs and symptoms of exposure, rehabilitation requirements, emergency and followup medical treatment and surveillance 9 Sources of routine and emergency hazards, with cross-reference to required engineering and managerial controls, required use of personal protective clothing and equipment, routine and emergency ambient monitoring requirements, inspection schedules, and evaluation criteria 3. Incident Response Operations 9 Description of individual health and safety incidents (including routine and emergency incidents), with detailed assessment of cause and crossreference to pertinent regulatory requirements, organizational policies, and specific requirements of the health and safety plan 9 Assessment of frequency and magnitude of incidents, with crossreference to review and modification of health and safety program, notification of regulatory authorities, and personnel training requirements 4. Support Resources 9 Consultant, contractor, regulatory, and other available personnel having special knowledge and experience relevant to health and safety and response operations, with cross-reference to specific data, information, material, equipment, and other needs of support resources
Elements of In-Service Data and Information Base
299
9 Hard copy and electronic sources of regulatory, technical, and scientific data and information, with cross-reference to routine and emergency need for importation, including up-to-date information on health and safety standards, chemical toxicity and compatibility, personal protective equipment, monitoring devices, and medical treatment and surveillance 9 In-place maps, schematics, and diagrams for all facility structures and properties that locate all primary sources of hazards, routes of ingress and egress, potential pathways and receiving systems for spills or releases of hazardous materials, with cross reference to specific regulatory requirements (e.g., underground storage tanks, hazardous waste storage areas, electrical transformers) It must be stressed that the above types of data and information should be immediately available to the incident commander or other responsible person whether or not the data and information are computerized. However, the cross-referencing required to meet the pressing needs of an actual incident, a facility inspection by regulatory or response personnel, or even routine operational decision-making clearly emphasizes the importance of well designed and highly integrated computerized files. What is meant by "highly integrated" is that the data contained in one file allow the user to identify (i.e., through appropriate cross reference) other data that may be contained in other files. For example, a file that contains information on the general technologies available to technical rescue personnel (Fig. 12.2) can be cross-referenced to files that contain data (e.g., design specifications) on specific equipment that is available within a type of technology as well as vendors who can provide that equipment. Such cross-referencing of files (or integration)can be done, of course, without the use of computers, although computers do provide for a much more efficient management (e.g., updating, correction, correlation) of the relevant databases.
External Databases
Electronic publishing is a rapidly expanding phenomenon that commercial companies, professional organizations, and governmental agencies increasingly use to make technical and scientific information and data more easily available at little or no cost. Powerful search-and-retrieve programs, CD ROMs, and worldwide networking provide essentially instantaneous access to data and information pertinent to all aspects of emergency planning and response, including state, national, and international regulations, health and safety standards, epidemiological and laboratory studies, personal protective clothing and equipment, ambient and personal monitoring systems, and medical surveillance protocols.
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12 Data and Information Management
Technologies File Locating Equipment Communications Equipment Power Sources .....................
ISe
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.........................
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Hand tools Amkus, Inc. 708 -515-1800 Percussive tools Holmatro, Inc. 410-987-6633 Rams Code 3 ResQ Tools 800-959-6395 Devices spreaders Curtiss-Wright Flight Systems 800-797-4295 ...o...................................................... = Alligator Air knife Phoenix, inc. 800-87%1629 Vacuum excavator Lifting and Pulling Porter-Ferguson, Inc. 800-877-1629 Saws Equipment Edge Industries, Inc. 800-742-3343 Drills Pacific Stihl 916-343-1657 Chisels L.C. Miller Co. 213-268-3611 Shoring Devices Jackhammers bamler Industrial Produtts 800-323-3553 Rotohammers ........................................................................... i Cutting torches i Rope, Rigging, and i Feather and wedge ! l Hauling ;..................................... _: Equipment
i ~
and Impacting
i i " [ i i i i ." .~
Water and Ice Rescue Equipment Monitoring Devices Victim Extrication Devices Structural Movement Sensing Devices Miscellaneous Equipment
FIGURE 12.2
E x a m p l e of c r o s s - r e f e r e n c e d fields in a d a t a b a s e of g e n e r a l t e c h n o l o g i e s avail-
a b l e to t e c h n i c a l r e s c u e p e r s o n n e l .
While it is important to explore the full range of available databases, it is equally important to consider the following: 1. Even a brief perusal of health and safety standards is sufficient to determine that standards are highly variable from one legal jurisdiction to another. While it goes without saying that the safety officer must ensure compliance with the specific legal authority having jurisdictional precedence, it may very well be appropriate to adopt a more stringent standard proposed by some other authority. Such an approach is consistent with not only the
Elements of In-Service Data and Information Base
301
principle of minimizing health and safety risk, but also the recognition that there is often a significant lag between scientific findings and regulatory reform. Of course, there are instances in which standards become less stringent precisely because of advances in scientific understanding of hazards and risksma consideration that should nonetheless be weighed against state-ofthe-art practice. 2. There are many CD ROM databases on chemical hazards and risks, some of which are available through chemical manufacturers and some through commercial sources, including companies that specialize in the production of material safety data sheets (MSDSs). A comparison of MSDSs prepared by different companies for the same chemical substance or product will often reveal differences regarding not only specific hazards, but also routes of entry, target organs, and recommended protective clothing and equipment. The adoption of the findings, determinations, and recommendations made by any purveyor of information does not absolve the buyer or user of such information from potential liabilities that might accrue to errors of fact or judgment on which that information is based. It is therefore necessary that comparisons of alternative databases be examined and, where differences do occur, to resolve discrepancies. In many instances, discrepancies in hazard determinations and the toxicology of chemicals are not due to oversight or error but to differences in the interpretation of highly technical data. Where this is the case, guidance must be sought from regulatory and competent scientific authority. 3. While many commercial electronic databases are offered as part of a subscription service, which ensures periodic updating of information, updating does not ensure veracity. Confidence in a database is warranted only when efforts are made to review that database in light of recognized legal, professional, and scientific standards as promulgated through a wide range of governmental agencies and professional organizations, including the National Fire Protection Association (NFPA), Federal Emergency Management Agency (FEMA), National Institute of Occupational Safety and Health (NIOSH), Occupational Safety and Health Administration (OSHA), Agency for Toxic Substances and Disease Registry (ATSDR), and the U.S. Environmental Protection Agency (EPA). Internal Databases
As important as external databases are, they cannot substitute for those databases that must be compiled on a facility- or incident-specific basis and which represent the operational details of emergency response operations. Encompassing information on all service-related health and safety
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12 Data and Information Management
policies and procedures, personal protective clothing and equipment, engineering and managerial controls, personal risk factors, ambient monitoring, medical surveillance, operations auditing and inspection, and personnel training, internal databases must not only accommodate the documentation needs of the response service but also meet the day-to-day operational and planning needs of that service, including: 9 Scheduling of key activities (e.g., personnel assignments, ambient monitoring, personnel training, medical surveillance, internal audits of operations) 9 Assessment of incident response 9 Revisions of pertinent programs and policies in light of incidents, changes in health and safety standards, changes in operational capacity, changes in regulatory requirements, development of new materials and technologies) 9 Personnel actions required to enforce health and safety policies and procedures 9 Assessment of effectiveness of response strategies and tactics 9 Evaluation of in-place policies, procedures, and equipment with regard to the current and developing state-of-the-art In constructing internal databases, which include selected data and information obtained from external sources, it is vital that emphasis be given to the specific information that is most likely to be immediately needed during response operations (e.g., nature of biological hazards in facility, likelihood of release of a toxic vapor or mist into the atmosphere). Only by defining the particular informational needs engendered by actual situations can specific cross-reference and retrieval capabilities be incorporated into diverse databases--capabilities that ultimately determine the actual usefulness of those databases and which, unfortunately, are too often overlooked by personnel so mesmerized by the sheer volume of information at their command that they forget that no data or information are of any value whatsoever unless they can be readily integrated with specific planning or response objectives.
Integrating Data with Objectives Data processing is the means by which individual pieces of information become integrated with planning and response objectives. It consists of both the analysis and presentation of data so as to facilitate purposeful decision-making. While data processing long precedes the advent of computer technology, computers not only greatly reduce the time and effort required
303
Elements of In-Service Data and Information Base T A B L E 12.1 Number of Fires (Boston, 1988) on Basis of Time of Day (Adapted from U.S. Fire Administration, Fire Data Analysis Handbook) Time ,,
Period
Midnight1 AM 2AM3AM-
Number
Time
Period
Number
1 AM 2 AM 3AM 4AM
478 420 360 273
Noon- 1 PM 1 P M - 2 PM 2 PM - 3 PM 3 PM - 4 PM
307 316 363 381
4AM- 5AM 5AM- 6AM 6 AM - 7 AM 7 AM - 8 AM
192 127 122 139
4 5 6 7
PM PM PM PM
417 433 492 514
9PM 10 PM 11 PM Midnight
540 622 510 547
8AM9 AM10 A M 11 AM -
9AM 10 AM 11 AM Noon
156 168 206 242
PMPM PM PM -
8PM9 PM 10 PM 11 PM -
5 6 7 8
to produce a competent analysis and presentation of data, but also significantly increase the sophistication of data processing. For example, the U.S. Fire Administration developed an comprehensive text (Fire Data Analysis Handbook) on statistical and graphic methods of data processing for use by fire services based on the following premise: Turning data into information is neither simple nor easy. It requires some knowledge of the tools and techniques used for this purpose. Historically,the fire service has had few of these tools at its disposal and none of them has been designed with the fire service in mind. (from Forward to Fire Data Analysis Handbook, U.S. Fire Administration) Today, all of the methods and techniques discussed in this excellent text are readily available through low- to moderate-priced commercial software. In fact, a good number of these techniques are standard components of popular word processing programs that can automatically convert tabulated data (Table 12.1) typically compiled by fire service personnel into alternative graphic representations (Fig. 12.3) having direct relevance to specific operational objectives (e.g., most efficient scheduling of fire response personnel over a 24-hour period). Essentially one step up in technical sophistication from the simple data processing afforded by word processing programs are those spreadsheet and database management programs that are typically included in home and office program suites. Yet another step up from these are simple programming languages (e.g., Visual Basic) that can nonetheless perform rigor-
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12 Data and Information Management
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FIGURE
12.3
Elements of In-Service Data and Information Base Amount stored in local industrial facilities
Protective Clothing/Equipment
Type of Hazard
~
l
/
Chemical Data Base
Compatibility with water "
.,-,,
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305
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FIGURE 12.4 Somecommonlycross-referenceddata in a chemicaldatabase(additionaltypes of data may also be includedin the database).
ous data analysis and informational packaging with relatively little investment in time, training, or money. More complex and sophisticated programming tools are, of course, available. Figure 12.4 is a representation of a chemical database that may be established by any readily available and simple data management program. Such a base may include from several hundred (e.g., for a small manufacturing facility) to several thousand or more individual chemicals (e.g., for a community response facility), each being correlated with appropriate information, such as waste disposal requirements, toxic by-products, type of hazard, and other types of information important for planning or responding to a chemical incident. Thus, relevant information about a particular chemical may be retrieved on the basis of any of the types of information associated with that chemical. Of course, in an actual incident, the precise chemical involved in a spill or release may not be known, or mixtures of chemicals may be involved. Because of this, it is important to include not only the names of pure chemicals in the database, but also categorical descriptors (e.g., "flammable solvents, .... toxic gases") that correspond to chemical mixtures likely to be encountered in a site-specific incident. Whatever the tool used (i.e., whether provided by word processors, spreadsheets, database programs, or programming languages), the most important element in any data processing is the clear understanding of (a) how individual pieces of data can be linked to one another, and (b) how those linked data can be used to provide essential input into decision-making. In short, the difficulty, today, is not the analytical techniques of data processing~these are already prepackaged for almost instantaneous use in
12 Data and InformationManagement
306
Pre- and post-use inspection requirements
Maintenanceand Replacement schedule
Altemative Vendors T f
Protective Clothing Database
Proceduresfor decontamination
Required personal protective equipment
/ Personnel rehabiliation requirements
~ Donning and Specifications on Doffing basis of type of Protocols hazard FIGURE 12.5 Somecommonlycross-referenced data in a protective clothing database (additional types of data may also be included in the database).
user-friendly format; rather, the difficulty is matching informational needs with planning and response objectives. Thus, the data to be included in the database depicted in Fig. 12.4 must be selected from among voluminous available data--selected precisely because only certain types of information can be acted upon, whether for planning, operational, or training purposes. During an actual incident, of course, informational needs will vary with a wide range of factors, including type of incident, weather conditions, and timing of the incident with respect to work schedules and community activities. Informational needs may also vary during any particular incident as additional details of the incident become evident. The substantive design of a database is therefore essentially a function of managerial strategy rather than of technical or scientific necessity.
M O D U L A R A P P R O A C H TO DATABASE DESIGN The practical approach to building databases having high relevance to the practical needs of emergency planning and response is to focus on the construction of individual modules--databases that correlate information of a particular type, such as the chemical database depicted in Fig. 12.4, or a database for protective clothing (Fig. 12.5), or for decontamination (Fig. 12.6), or for any other major category of operational concern. This compartmentalization of databases, especially if undertaken by in-service personnel, typically results in less time required for not only the design of databases, but also for upkeep due to the development of new materials,
Modular Approachto DatabaseDesign
307 Alternative
T
wash and rinse
Emergency decontamination procedures
solutions
~"~ Off-site support services
r
Required i"/ procedures on basis of type of hazard
i]
/ / Decontamination t
Disposal of decontamination wastes
,
Database
Protocols for temporary on-site storage of contaminated materials
Altemative layout
of decontamination lines
Protocols for individual steps in decontamination process
FIGURE 12.6 Some commonly cross-referenced data in a decontamination database (additional types of data may also be included in the database).
equipment, standards, and regulations. It also allows for the use of the overall format used in one module as a design template for other modules. Finally, it allows individual personnel (either singly or in small groups) to focus on topical areas in which they have particular expertise, experience, and interest. Another key attribute of the modular approach is that it allows for more concentrated and efficiently performed debugging and testing to ensure that it contains precisely the information required and correctly performs retrieval, updating, and corrective functions. A key disadvantage of this approach is that the final product could be nothing more than a series of disconnected databases that must be individually accessed to retrieve information sets that are operationally interdependent. It is therefore vital that the design of individual modules allow for multidimensional access into related modules. For example, in a given incident, the type of chemical may be known and can be used (either by name or category) to access response-relevant information (e.g., reactivity with water, type of health or safety hazard) from a chemical database. However, hazard type can also be used as a means of entry into the database module designed for protective clothing. If this second module (i.e., protective clothing module) contains information on procedures for decontamination, then such procedures may also serve as a means of access to a third module, which is a database for decontamination. In short, the design of individual modules can be accomplished easily so that
308
12 Data and Information Management
Emergency decontamination procedures 3K,~
............".......
Pre-and post-use inspection requirements Maintenanceand replacement ~ schedule Personnel rehabiliation reauirements
Altemative vendors
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Donningand doffingprotocols
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of hazard i
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FIGURE 12.7 Example of linkage of different databases. The arrow indicates that primary linkage is through chemically specific hazard; other linkages are also possible.
one piece of information (e.g., hazard type) triggers the retrieval of relevant hazard-specific information from a range of different types of databases (Fig. 12.7)~information that singularly and collectively provides essential direction to decision-making. Of course, in the example presented in Fig. 12.7, this approach would appear to result in an unnecessary duplication of files (e.g., decontamination procedures in both protective clothing and decontamination databases). However, this is not the case. After all, any database ultimately consists of interrelated files; the arrows in Fig. 12.7 do not point to actual duplicate files but, rather, to the same file. In this context, it is important to emphasize that the construction of interconnected modules depicted in Fig. 12.7 is not at all dependent upon computer technology~such a system can be constructed just as solidly out of traditional file folders and paper labels as out of elec-
Modular Approach to Database Design
309
trons. What is depicted is simply a logic, not a technologyma way of organizing data to meet decision-making needs for information, not an exercise in arcane engineering. The computer is simply a highly efficient means for consistently exercising a defined logic on organized data to produce information in a selected format. Yes, the technology is new. But the manner of thinking is not. Team Approach to Database Design
Ideally, the construction of any database and associated retrieval systems should be undertaken by a team composed of experienced response personnel who, because of the depth and diversity of their experience, are best able to (a) identify the types of information that are operationally critical to both emergency and normal operations, (b)identify and collect the types of data that must be organized to provide that information, and (c) define and implement design criteria for data and information management that are fully consistent with the practical constraints of time and resources imposed by emergency incidents. The importance of using experienced response personnel to design data processing systems cannot be overstressed. Systems designed primarily by computer and other information-processing specialists are very likely to meet technical criteria of excellence and coding elegance, but they are also very likely to be impractical in terms of the actual needs and constraints of response services. In the early development of PC technology, there was an obvious need to rely upon computer specialistsJafter all, such specialists were the only people who had the necessary knowledge of the software and hardware intricacies of electronic data management. However, this is not longer true. Today, not only is that knowledge more widely dispersed, but it has also itself become encapsulated in user-friendly technology as readily available to grade-school students as it is to practicing professionals. In addition to the use of an experienced and diverse response team, it is critical that the design of a data and information management system proceed in close coordination with other key members of the community partnership for emergency planning and response. Whether it is called coordination, communication, liaison, or networking, the on-going functional interaction and interdependence of all team members must be structured into the vital decision-making processes of each m e m b e r J a n d nothing is more critical to coordinated decision-making than data and information processing, a fact that is most obvious in the midst of an actual incident where immediate, coordinated, and complementary response action must be taken by a wide range of response services and support resources. Precisely the same teamwork required to manage an actual incident should be manifest in
3 l0
12 Data and Information Management
i
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Response Service
Support
1
Resources
Incident
Site
FIGURE 12.8 Data and information processing systems underlie the dynamic linkage among different response services, their support resources, and on-site incident response. Support resources include a wide range of both public and private organizations, including industrial and other community resources.
the day-to-day management of critical data and information processing systems that influence the decision-making of separate response services and support resources (Fig. 12.8). Toward the achievement of this objective, it is necessary that concerted effort be made to ensure:
Modular Approach to Database Design
31 I
1. that local industries invite community response services (e.g., fire, medical, municipal) to review, comment upon, and suggest modifications of in-house response-related data and information processing systems, 2. that community response services as well as municipal and other jurisdictional authorities similarly involve local industry as well as private support contractors and vendors in the design and implementation of relevant service and municipal databases and retrieval systems, and 3. that all members of the community response partnership actively maintain information sharing programs with their global colleagues, with particular emphasis on the sharing of ideas and approaches to the design of practical and effective data processing strategies and techniques.
Testing Database Design Both modular and integrated databases should be tested using evaluation criteria germane to their operational uses under normal and emergency conditions. Clearly, criteria for assessing a database designed to facilitate decision-making regarding the nonemergency purchase of clothing, equipment, and supplies would not be appropriate criteria for assessing a database designed to facilitate decision-making regarding on-site deployment of PPC decontamination stations. Some criteria, however, may be consistently applied to all databases and processing software, including (but not limited to): 9 Consistency of output with different users and different makes/ models of auxiliary equipment (e.g., printers, monitors, fax modems, e-mail programs) 9 Flexibility of output formats (e.g., monitor and printed page formats, text, graphics) 9 Memory requirements 9 Search time 9 Ease ofcorrecting/upgrading/deleting/archiving 9 Susceptibility to crashing and user misuse 9 Security 9 Automatic documentation of use Once appropriate evaluation criteria are established, serious consideration should be given to the use of table-top or other simulation exercises (Chapter 9) as means of assessing the data and information management system. A very practical approach to such an assessment is to define a variety of scenarios (e.g., accidental spill of bulk hazardous liquid, emergency exposure of response personnel to a biological agent, on-site entrapment of
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12 Data and Information Management
technical rescue personnel, release of toxic vapor in residential area, fire in pharmaceutical R & D laboratory) that would require immediate access to particular types of information. In such an exercise, the objective is not simply to retrieve the appropriate information, but also to test the range of factors that may influence the successful retrieval and subsequent processing or use of the retrieved information. Of particular concerns should be such considerations as: 1. How does the on-site person faced with a particular problem determine which information in the database is required or, at least, most relevant? 2. Can the information be retrieved by persons most likely to be available at the time, or must it be retrieved by a limited number of personnel who may not be available in a timely fashion? 3. How can the data required for a critical situation be retrieved or processed in the case of a power failure? For example, are printed records containing the needed information readily available under any emergency condition? 4. Does the retrieved information direct the person who retrieves it how to act upon i t ~ o r is it simply assumed that available personnel will know what to do with the information? As implied by such questions, the overriding concern that must guide the construction of any response-related database and information management system is that no single datum or bit of information can "speak for itself." What information do I need? How do I get it? Is it good information? What do I do with it? These are the necessary questions that must be posed to any data and information management system and, as yet, they cannot be obviated by even our most sophisticated electronic tools. Unasked or unanswered, or posed imprecisely or unclearly, they transform even the most extensive database and most elegantly conceived information processing system into simply so many gigabits of pure nonsense.
MONITORING STRATEGIES AND DEVICES
INTRODUCTION
Today, chemical surveillance of the workplace is standard practice, with specific requirements defined not only by regulatory authority (e.g., emergency response, laboratory standard, confined space entry, respiratory protection, hazard communication, chemical process safety) but also by corporate insurance carriers, corporate legal counsel, health and safety professional organizations, and employees themselves. Chemical surveillance is, in fact, as intrinsic to modern business practice as loss control, total quality management, and human resource development. Given the broad legal, political, economic, and ethical ramifications of exposure to workplace chemicals, it is useful to distinguish between chemical monitoring and chemical surveillance. Chemical monitoring connotes the technical and methodological aspects of any qualitative or quantitative analysis of process or fugitive chemicals. It may be undertaken for a variety of reasons, including not only the management of potential human exposure, but also to control production processes or the quality of intermediate and finished products. Chemical surveillance is a much broader, programmatic approach to the management of human exposure to chemicals. Surveillance includes monitoring, but also includes a variety of other efforts, such as the control of chemical inventories, waste minimization, chemical substitution, and process management. In the United States, chemical monitoring for the purpose of managing human risk is historically linked to industrial compliance with chemicalspecific health and safety standards (e.g., 29 CFR 1900 Subpart Z), with generic hazard and risk management regulations (e.g., laboratory standard, hazard communication), and, most recently, with standards established for 313
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hazardous waste sites (RCRA, CERCLA) and operations involving especially hazardous chemicals and chemical processing (e.g., SARA Title 3). The rapid development of a wide range of workplace standards in the 1980s and 1990s coincided with two other significant developments: the explosive progress in materials sciences and electronic engineering (which provide the physical means for monitoring technology), and the growing recognition of the potential chemical risks associated with modern industry, including not only normal design and operational risks, but also those engendered by natural catastrophe, human error, and acts of terrorism. All three factors (i.e., regulatory standards, monitoring technology, and catastrophic chemical release) continue to underscore the vital importance of monitoring capability in modern emergency planning and response~ a capability which, while necessarily responsive to potential chemical risk, is not limited to chemical monitoring but includes a wide range of sensor systems necessary to achieve proactive and reactive response objectives. CHEMICAL MONITORING TECHNOLOGIES
Common techniques for monitoring hazardous chemicals maybe conveniently divided into three basic types: 1. Ambient air monitoring: techniques that provide rapid on-site detection or measurement of chemicals that are present in the air as dusts, vapors, gases, or mists, 2. Ambient materials testing: techniques that typically require off-site laboratory analysis of samples, including solids (e.g., soil samples) and liquids (e.g., groundwater, hazardous waste mixtures), and 3. Personal monitoring: techniques that involve the detection or measurement of chemicals (a) within body tissues such as blood or urine, or (b) in the immediate vicinity of a worker equipped with a personal monitor to measure cumulative exposure over a specific period of time. Ambient Air Monitoring Devices
By far the most commonly used chemical monitoring devices, ambient air monitoring devices provide a rapid, direct reading of chemical concentrations in air. However, there are usually significant limitations associated with any particular device, including: 9 Most detect or measure only specific chemicals or chemical classes; none detect all possible chemicals
Chemical M o n i t o r i n g Technologies TABLE
13. I
3 15
Data and Information Typically Provided by Manufacturers of C o l o r i m e t r i c Devices
Used for the M o n i t o r i n g of C o m m o n Industrial Chemicals Gas or Vapor Catalog R a n g e DetectionLimit To Be Monitored Number (ppm/hours) (ppm; 8-hour) Ammonia Carbon Dioxide Carbon Monoxide Chlorine Formaldehyde Hydrogen Cyanide Hydrogen Sulfide Nitrogen Dioxide Sulfur Dioxide
3D 2D 1D 8D 91 D 12D 4D 9D 5D
25 - 500 ppm 0.2 - 8.0% hr. 50 - 1000ppm 2 - 50 ppm 1 -20 ppm 10 - 200 ppm 10 - 200 ppm 1 - 30 ppm 5 - 100 ppm
1.0 0.015% 2.5 0.13 0.06 0.5 0.25 0.06 0.13
Color Change Purple to Yellow Blue to White Yellow to Dark Brown White to Yellow Yellow to Red Brown Orange to Red White to Dark Brown White to Yellow Green to Yellow
Storage Temp.
Shelf-Life
Room Temp. Room Temp. Room Temp. Room Temp. Refrigerate Room Temp. Room Temp. Refrigerate Room Temp.
(years) 3 2 2 2 1 2 3 1 2
9 While the sensitivity of such devices is always subject to the development of new technology, they are generally incapable of detecting airborne concentrations of chemicals below i mg/m3 9 Many can give false readings because, although designed to detect one particular substance, they are subject to interference (i.e., poisoned) by the presence of other chemicals
I. Colorimetric Indicator Tube
This relatively low-priced and easily used device consists of (a) a tubular glass ampoule containing an indicator chemical that reacts with a specific ambient contaminant of interest, and (b) a manual or motorized pump to draw a calibrated amount of ambient air through the ampoule. The reaction of the indicator chemical and the air contaminant changes the color of the indicator chemical. The linear length of the color change in the ampoule is proportional to the concentration of the air contaminant. Calculating the air concentration of the contaminant requires a simple mathematical operation involving the calibrated length of the color reaction in the ampoule and the volume of air pumped through the device. Depending upon the specific chemical being measured, the calculation may also require correction for barometric pressure. The measurement of certain air contaminants may also require the simultaneous use of a second ampoule, which is affixed to the indicator tube. Manufacturers of colorimetric indicator tubes provide detailed information on the limits of each indicator tube that is specific to the ambient gas or vapor of interest (Table 13.1). In addition to such chemical-specific limitations, all colorimetric tubes share certain general limitations:
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9 While each indicator tube is specific to a particular ambient chemical, other ambient contaminants can interfere with the indicator chemical 9 Most tubes can be affected by high humidity, thereby giving false readings 9 Tubes available from different manufacturers may have different sensitivities, thereby providing different measurements of ambient concentrations 9 Because of the variability of color perception among persons, different personnel may make different judgments as to the length of the color stain within the indicator ampoule. Another common problem associated with colorimetric indicator devices is the problem of false negatives. If, after use, an ampoule shows no color reaction, the negative result may be due to (a) the concentration of the ambient contaminant being lower that the sensitivity of the tube, or (b) the indicator tube being defective. In such a case, the user is well advised to test the negative ampoule with a known high concentration of the contaminate vapor. Finally, it must be stressed that the volume of air perfused through the indicator tube is typically very small and therefore represents a tiny portion of the ambient atmosphere. The location of the air intake to the detection device is therefore critical with regard to estimating air quality in the total volume of breathable air. It is, therefore, always advisable to conduct colorimetric monitoring within the immediate breathing space of personnel at risk. High-flow personal samplers are increasingly available and should be considered as an important adjunct to any monitoring program. Single pumps are typically housed in a lightweight plastic case that clips to the user's belt. Multiple pumps are also available and can be used for simultaneous monitoring of atmospheric samples taken at different locations within the same general area. Battery packs for both single and multiple samplers allow continuous sampling over an 8- to 10 hour period.
2. Electronic Devices
A wide range of electronic devices are available for the detection of specific chemicals and broad categories of chemicals, and typically include such additional capabilities as data retrieval and storage, database searching, automatic calculations, and the formatting and printing (or modem transmission) of written reports and display graphics. Some, such as the combustible gas indicator, flame ionization detector, portable infrared spectrophotometer, and ultraviolet photoionization detector (Table 13.2), have broad application for compliance with numerous health and safety stan-
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TABLE 13.2 BasicTypes of Electronic Monitoring Devices (Adapted from NIOSH, USCG, and EPA, 1985: Occupational Safetyand Health Guidance Manual for Hazardous Waste Activities)
Combustible Gas Indicator {CGI) 9 9
Measures the concentration of a combustible gas or vapor A filament, usually made of platinum, is heated by burning the combustible gas or vapor; the increase in heat is measured 9 Accuracy depends, in part, on the difference between the calibration and sampling temperatures 9 Sensitivity is a function of the differences in the chemical and physical properties between the calibration gas and the gas being sampled 9 The filament can be damaged by certain compounds, such as silicones, halides, tetraethyl lead and oxygen-enriched atmospheres Flame Ionization D e t e c t o r (FID) w i t h Gas Chromatography O p t i o n 9 9 9 9 9 9 9 9
In survey mode, detects the total concentrations of many organic gases and vapors; all organic compounds are ionized and detected at the same time In GC mode, identifies and measures specific compounds; volatile species are separated Gases and vapors are ionized in a flame; a current is produced in proportion to the number of carbon atoms present Does not detect inorganic gases and vapors, or some synthetics; sensitivity depends on the compound Should not be used at temperatures < 40 deg. F (4 deg. C) Difficult to identify compounds absolutely; specific identification requires calibration with the specific compound of interest High concentrations of contaminants or oxygen-deficient atmospheres require system modification In survey mode, readings can be only reported relative to the calibration standard used
Portable Infrared (IR) Spectrophotometer 9 9 9 9 9 9
Measures concentration of many gases and vapors in air Passes different frequencies of IR through the sample; the frequencies absorbed are specific for each compound In the field, must make repeated passes to achieve reliable results Not approved for use in a potentially flammable or explosive atmosphere Water vapor and carbon dioxide interfere with detection Certain vapors and high moisture may attach to the instrument's optics, which must then be replaced
Ultraviolet (UV) Photoionization Detector (PID)
9 9 9 9
Detects total concentrations of many organic and some inorganic gases and vapors; some identification of compounds is possible if more than one probe is used Ionizes molecules using UV radiation; produces a current that is proportional to the number of ions Does not detect a compound if the probe used has a lower energy level than the compound's ionization potential Response may change when gases are mixed Other voltage sources may interfere with measurements; response is affected by high humidity
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dards. Others, such as an oxygen meter or sound meter, obviously have much more narrow application. Increasingly available today are electronic instruments that combine monitoring capabilities for different chemicals. Examples of such combined capabilities include: 9 A combustible gas meter that also measures oxygen, hydrogen sulfide, and carbon monoxide 9 A toxic gas meter that can detect oxygen and combustible gases and which can also be equipped to monitor hydrogen cyanide, hydrogen chloride, nitrogen dioxide, nitrous oxide, and sulfur dioxide 9 A hazardous gas detector that provides continuous measurements of many gases or vapors, including acetone, ammonia, arsine, benzene, carbon monoxide, ethylene oxide, and formaldehyde Of critical importance in emergency response is the combustible gas indicator. As shown in Fig. 13.1, the combustion of a substance depends upon an adequate supply of both burnable fuel and oxygen. The relative amounts of oxygen and fuel that will support combustion are described in terms of both the lower explosive limit (LEL) and the upper explosive limit (UEL). Below the LEL, there is insufficient fuel to support combustion; above the UEL, there is insufficient oxygen. The readout of the combustion meter is usually given in terms of percentage of LEL, with 100% indicating that the mixture of fuel and oxygen meets the minimal requirement for explosion. On such a scale, a reading of 10%, which is increasingly used to trigger the evacuation of an area, means that the concentration of flammable vapor is one-tenth of that required for a state of imminent explosion. Portable detectors (Table 13.2) can, with proper calibration, detect hundreds of individual toxic vapors and gases. FID (flame ionization detector) and PlD (photoionization detector) units can also be operated to measure total concentrations of ambient chemicals without regard to individual chemical species. This mode of operation (i.e., survey mode) is useful because its lack of chemical specificity provides an inherent safety factor. For example, in the survey mode, a reading of, say, 250 ppm, which could represent a total concentration of potentially hundreds of organic compounds, could also be interpreted to represent the concentration of a particularly toxic compound of concern. Such a worst-case interpretation of the reading might or might not be realistic in a particular circumstance, but such an interpretation always has very real value as a criterion for further investigatory (if not corrective) action or even the initiation of area evacuation. An oxygen meter (and, in some circumstances, a toxic gas and/or combustible gas meter), is a basic requirement in any situation in which
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Chemical Monitoring Technologies
o oc
~o o
~o O0
o~
2
o
At Time = O, only air (containing oxygen)
t I
UEL
Oxygen
<
IHo
Progressive displacement of air by flammable vapor
present; no fuel
Concentration
OH
At Time = n, only fuel present; no
oxygen
Fu
"k.......... ,,... SufficientFuelandOxygen f ''...
for Explosive C o m b u s t i o n /
LEL .AI
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FIGURE 13.1 Lower and upper explosive limits. As the air in a container is progressively displaced by a flammable vapor (upper portion of figure), the concentration of oxygen in the container decreases while the concentration of potential fuel increases. At concentrations of fuel (expressed as percentage of atmosphere) below the LEL (lower explosive limit), there is too little fuel to support burning; at concentrations of fuel above the UEL (upper explosive limit), there is too little oxygen to support burning. Explosion may occur only when the relative concentrations of fuel and oxygen are at or between the LEL and UEL. On a scale where 100% represents the LEL, 10% is typically used as the trigger for implementing personnel evacuation.
confined space entry is required. While there are many different designs of oxygen meters, it is imperative that the meter be provided with a long probe that can be lowered or otherwise extended into a confined space without the operator becoming exposed to an atmosphere that is potentially oxygen deficient and/or toxic. It is also important that the operator understand that an oxygen meter is typically sensitive to a range of environmental factors, including barometric pressure and ambient concentrations of carbon dioxide and other oxidizing agents (e.g., ozone). A wide variety of radiation survey meters are available for the detection of alpha, beta, and gamma radiation and X rays. It should be noted
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that, while alpha particles (energetic helium nuclei) are relatively large and slow-moving particles that are easily stopped by the outer layer of skin, they are also very hazardous if inhaled (e.g., via contaminated dust). Gamma and X rays (electromagnetic radiation) and beta particles (high-speed electrons) may have high penetration capabilities. It must be stressed that, despite their apparent simplicity of design and operation, all electronic detectors are sophisticated instruments and require a precise understanding of their inherent limitations and requirements regarding calibration, care, and maintenance. Users are well advised to ensure that the manufacturer of any electronic detector provide proper instruction in all aspects of operation and maintenance, with particular emphasis given to the routine documentation of calibration, precision, and accuracy. Ambient Materials Testing In many situations a safety officer may require analyses of site materials and resources that cannot be performed on site, such as the analysis of: 9 Potable water supplies, including wells, public water supply mains and lines, and other sources that might be contaminated with biological or chemical agents 9 Surface or groundwater supplies that might become contaminated as a result of an incident and/or incident response activities 9 On-site soils and dusts possibly contaminated with heavy metals and hazardous contaminants 9 Structural and other on-site materials containing toxic substances (e.g., asbestos, pesticide residues, lead-based paint) Such analyses typically require the use of specialized laboratories, including commercial water testing laboratories and materials testing laboratories. Where such professional analytical services are required, only those vendors who are certified by legal authority should be selectedwand, more precisely, those who are specifically certified for the particular analysis to be performed. For example, in the United States, a water testing laboratory may be certified through a state agency under the aegis of the U.S. Environmental Protection Agency; however, the certification is typically highly specific on the basis of the different types of analyses required by the Federal Safe Drinking Water Act, with certification for the analysis of heavy metals, for example, being separate and distinct from certification for the analysis of microorganisms. Having procured the professional services of an appropriately certified laboratory, the safety officer must ensure that all samples are collected,
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Chemical Monitoring Technologies TABLE 13.3 Examplesof Gases and Vapors That Can Be Monitored by Means of Open Diffusion Detector Tubes
Gas or Vapor
8 Hr. Measuring Range (ppm)
Acetic acid Ammonia Butadiene Carbon dioxide Carbon monoxide Ethanol Ethyl acetate Hydrochloric acid Hydrocyanic acid Hydrogen sulfide Nitrogen dioxide Olefin Perchloroethylene Sulfur dioxide Trichloroethylene
1.25- 25 2.5 - 187.5 1.25- 37.5 62.5- 2500 6.25- 75 125 - 3000 62.5 - 1250 1.25- 25 2.5- 25 1.25- 37.5 1.25- 25 12.5 - 250 25 - 187.5 .63 - 18.8 25 - 125
stored, and delivered in full compliance with relevant regulations. While it is usually desirable that the contracted certified laboratory itself collect and handle samples, this is typically impossible during an emergency. The site safety officer should therefore obtain written directions from the certified laboratory for the proper procedure for collecting, handling, packaging, preserving, transporting, and documenting samples.
Personal Monitoring Personal monitoring devices include such devices as badges, monitors, dosimeters, and open diffusion detector tubes, all of which can easily be clipped or otherwise attached to personal clothing. Monitors may be dedicated to a particular chemical species (e.g., mercury vapor, trichlorethylene) or provide detection of a broad class of chemicals (e.g., organic vapors). In some designs, monitors that detect classes of chemicals may be processed to yield specific exposure data regarding a limited number of specific chemicals out of several dozen possibilities. Some devices give direct readouts of timed exposure (Table 13.3) or require simple comparison of color changes with standard color charts or data sheets; others require off-site laboratory processing, which introduces delays of several or more days in obtaining results.
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Because of the necessary delays in obtaining data from badges that require off-site processing, it is imperative that such devices not be used in emergency response where exposure can exceed health or safety standards. The basic rule is that personal monitoring devices be used only after a comprehensive survey of an area has established, by means of ambient monitoring devices, potential worst-case exposures--and even then, only when there is assurance that worst-case exposures cannot exceed health and safety standards within the estimated time frame of on-site personnel work schedules.
OTHER MONITORING TECHNOLOGIES
In addition to the technologies discussed above, which are standard technologies employed by industrial hygienists, regulatory compliance officers, and hazardous waste emergency response personnel, other monitoring capabilities should be assessed for their relevance to the health and safety of response personnel. Some of the more common monitoring devices that should be considered have long been used by industrial hygienists in the routine surveillance of workplace conditions and, depending upon incident site conditions, may be important tools for managing site-specific risks, including: 9 Temperature and relative humidity monitors (especially important when incident conditions and operations enhance the risk of heat stress and dehydration; also available are heat stress monitoring systems that, while essentially hand-held units, can be connected to fixed or remote sensors) 9 Sound meters (for continuous and intermittent noise that may not only result in significant damage to hearing, but also interfere with communication as well as concentration among site personnel) 9 Particle analyzers (concentration and size distribution; an important adjunct to respirator use) 9 Hand-held gas tracers and leak (gas and liquid) detectors (including colorimetric developers that can detect specific liquids, such as oil and chlorine) Depending upon the nature of the incident and site operations, other more specialized but long developed technologies may be appropriate, such as: 9 Vibration and dynamic strain sensor, as well as a variety of structural motion and/or level sensors (e.g., during technical rescue operations inside unstable structures) 9 Piezoelectric films, cables, and other devices (which, by converting mechanical stress or strain into proportionate electrical energy, may also be adapted to monitor stability of on-site structural features)
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9 Personal alert safety system (PASS; to monitor motion of isolated personnel working under hazardous conditions and, as necessary, sound rescue alarm) 9 Hand-held thermal sensor (to detect hot spots in overhaul and other response-related operations) 9 Fixed and portable traffic monitors (which, in situations of public panic and/or in situations involving multiple incidents in dense population centers, can prove to be of inestimable value for achieving both strategic and tactical response objectives) 9 Meteorological monitors (that can supplement regionally available data with site-specific details or, in case of communication failure and/or multiple incidents, provide basic data [e.g., wind speed and direction, barometric pressure] and forecast capability needed for operational management) In addition to existing technologies, critical assessment of developing monitoring and alert technologies must be maintained as an on-going emergency management planning effort. This is especially important with regard to the monitoring of chemical and biological warfare agents that may be purposely used by terrorists or inadvertently released during a nonterrorist incident. Both manual and electronic techniques are employed (and are under constant development) for detecting warfare agents, including: 9 Detection paper, which is impregnated with dyes and pH indicators and yield characteristic colors when in contact with specific chemical warfare agents 9 Detection tubes, which (as discussed above) involve chemically specific colorimetrically defined reactions between a known substrate and target agents 9 Detection tickets, which consist of enzyme- and substrate-impregnated papers that mediate detectable reactions with various nerve gases 9 Ion mobility spectroscopy (IMS) system, such as the Chemical Agent Monitor (CAM), which is currently in worldwide use for the detection of nerve gas, blister and choking agents 9 Flame photometric detector (FPD), which can detect certain chemical warfare agents through the photometric analysis of air-hydrogen combustion residues 9 Biosensors, which utilize enzymes and/or bioreceptors to detect chemical agents DESIGN A N D I M P L E M E N T A T I O N OF M O N I T O R I N G PROGRAM
Different response services have different monitoring needs that may or may not overlap in the progress of a particular incident. The design and
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implementation of an effective monitoring program is therefore essentially a two-tiered effort: the first, focusing on specific in-service (or, in the case of the industry, in-plant) informational needs; the second, on mutual assistance among community services and support resources to provide a comprehensive monitoring capability.
In-Service Monitoring Capability The design of an in-service monitoring capability should be viewed as basically an on-going process of matching operational decision-making needs with available technologiesnand, of course, an assessment of potential applications within the constraints of costs and available personnel. Costs must include not only capital costs, but also direct and indirect costs associated with maintenance and replacement, quality control testing and calibration, and personnel training requirements. Basic steps in the design and assessment process should, at a minimum, include the following: I. Conduct a Needs Analysis
This is a methodical examination of all decision-making needs during the conduct of response operations. Decision-making needs must be clearly and specifically defined with respect to (a) which monitoring data are actually used to choose from among which alternative courses of action, and (b) alternative sources and/or types of data and information that may serve the same decision-making objective. A proper needs analysis includes not only a detailed examination of the linkage of certain types of data to certain types of operational decisions, but also an evaluation of the relative importance or criticality of both the data and the decisions under emergency conditions. For example, it may not at first appear to be necessary to use a field detector to monitor for toxic organic fumes if it is definitely known that toxic organic fumes are present and that search and rescue teams will wear SCBA--and, perhaps most importantly, that there are victims that must be recovered as quickly as possible. However, a properly conducted needs analysis will force additional considerations that can significantly increase the criticality rating of monitoring data--such as, in this example: 9 If a SCBA system fails or there is a physical tearing or ripping in protective clothing, what is the health consequence to the wearer, and what is the time frame in which these consequences may become irreversible? 9 Are the permeability ratings of fully functional protective clothing adequate under actual response conditions?
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The answers to these questions depend, of course, on knowing just what the organic fume is, its concentration and physical and chemical properties, its combustion products, and other ambient conditions that affect its permeation into clothing (e.g., temperature). 2. Document Reliability of Monitoring Device or Procedure
Once it is demonstrated that specific monitoring data are necessary for operational decision-making, it is necessary to demonstrate the field reliability of the monitoring device or procedure selected to provide that data. This is best done by documenting its actual field use by other agencies and organizations, testing laboratories, and regulatory agencies, with particular attention given to observed failures and limitations. Design specifications should also be submitted to prospective vendors to ensure that devices and procedures can be successfully used under typical field conditions. Finally, actual field testing of the device or procedure should be conducted under simulated emergency conditions. 3. Develop Standard Operating Procedures
Once there is demonstrable assurance that the device or procedure meets practical decision-making needs under actual field conditions, comprehensive SOPs should be developed with regard to proper use, storage, maintenance, cleaning and decontamination, calibration, and any other protocol that may be necessary to ensure effective readiness and reliability. SOPs should also give particular attention to action levelsJi.e., specified monitoring data (e.g., concentration, % LEL, radiation level) that require the implementation of predetermined actions by specifically identified personnel. SOPs should also specify personnel training requirements, with appropriate attention given to ensuring the ready availability of properly trained personnel under likely field conditions. Finally, it is vital that SOPs specify backup or fail-safe requirements for each device or procedure. For example, it may be deemed necessary to require the on-site availability of two or more fully functional devices so that the failure of any one device will not result in the loss of key monitoring capability. In some instances, it may be possible to provide manual monitoring capability (e.g., indicator tube technology) as a backup to an electronic monitoring device (e.g., photoionizing device).
Mutual Assistance Monitoring Programs While there is much monitoring technology that is moderately priced, there is also much that is expensive not only in terms of capital costs, but also
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in servicing and maintenance costs. No response service is therefore likely to have the full primary and backup monitoring capability that may be called for in a particular incident. It is therefore necessary that careful attention be given to developing mutual assistance programs among both governmental and private sector organizations at local, regional, and even national levels. Just who should initiate this action and take responsibility for developing such programs is arguable. However, because any incident presents potential risks to the community as a whole, it is reasonable to suggest that municipal authority assume lead responsibility. In the United States, this approach is consistent with the establishment of local emergency response commissions (LERCs) under the U.S. Emergency Planning and Community Right-toKnow Act. However, more regionally or even nationally centralized authority is most appropriate to the political structures of many other countries. Whatever its position in the sociopolitical hierarchy, the lead authority must ensure the on-site ready availability of an appropriate, fully functional monitoring capability that is likely to be composed of different resources supplied by a variety of response and support organizations. In many instances, monitoring devices are only part of the total resources (which may include heavy equipment and/or transport vehicles as well as radiation meters available through a civil defense or state emergency response center) to be mobilized to meet incident response needs. However, there are also many circumstances in which vital monitoring equipment may be most readily available only through a particular source that has no other resource of potential response value (e.g., local pharmaceutical company, industrial chemical manufacturer, research and development facility). The questions to be addressed by the lead organization for mutual assistance are essentially simple, including: Who has what device? Where is it ? How will it be delivered to where it is needed? Who takes responsibility for delivery? How long will it take to obtain it? Will it be functional when it arrives? Who knows how to use it? Obtaining clear, reliable answers, of course, is very difficult and requires significant, long-term commitment to preincident planning, coordination, and (especially) training. PROACTIVE I N D U S T R I A L M O N I T O R I N G
Because the industrial facility must always be considered a potential source of risk to the surrounding community, in-plant monitoring of potentially hazardous substances, which is subject to extensive regulatory scrutiny in the United States, should be considered not simply a means of achieving regulatory compliance but also a key step in proactive emergency planning. While monitoring technologies are equally available to community response services and industrial facilities, the industrial safety officer and incident safety officer have essentially different objectives, even if both must
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be primarily concerned with the health and safety of their respective personnel. In particular, the industrial safety officer must focus on the use of monitoring as a primary means of preventing or correcting a situation that can otherwise evolve into a full-blown emergency. Identification of Monitor Parameters
The essential first step to implementing an effective in-plant monitoring program is to identify potential parameters to be monitored on the basis of (a) regulatory requirements (e.g., 29 CFR 1910 Subpart Z, hazard communication regulations, confined space regulations, OSHA laboratory standard, hazardous waste regulations, chemical process safety regulations), (b) requirements imposed by corporate insurance carriers, (c) state-of-the-art practices within the industry, (d) concerns of personnel, and (e) recommendations of a facility safety committee. This is typically accomplished by means of a comprehensive hazard assessment of the total facility, which usually (and preferably) includes a prioritization of hazards. The prioritization of hazards is important for two basic reasons: 1. prioritization facilitates the implementation of appropriate mitigation techniques, including administrative and engineering control measures and the required use of personal protective clothing and equipment 2. because even a moderate size manufacturing facility may have a chemical inventory of several thousand chemicals, prioritization of hazards requires not only an assessment of the degree of hazard but also detailed assessment of the technological feasibility of monitoring individual chemical species In identifying potential chemical agents and available technologies for monitoring those agents, the safety officer must ensure that chemical byproducts and processing intermediaries are considered along with feedstock product chemicals. Finally, it must be noted that the availability of a monitoring technology does not necessarily imply the existence of a health or safety standard that can be used to interpret generated data. The safety officer must ensure that the final selection of parameters and monitoring technology is based on clear criteria for acting upon monitoring results. Establishing Baseline Conditions
The concentration of ambient substances (e.g., chemical fumes, dusts) in the workplace typically varies greatly over the workday. Before any sched-
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ule of ambient monitoring or sampling is established, it is necessary to conduct a baseline study to identify the range of variation that may be correlated with routine workplace production schedules, seasonal patterns of temperature and humidity (which may directly influence in-plant ventilation), and plant production levels. A baseline study must also establish variations in ambient concentrations with regard to nonroutine situations, as in the case of power outages and staged shutdowns of ventilation for equipment repair or replacement. The importance of establishing a comprehensive baseline cannot be overemphasized simply because it is the deviation of monitored concentrations away from baseline conditions that may indicate an impending or actual emergency situation. In some situations, deviations away from in-plant baselines may even indicate off-site emergencies that have resulted in atmospheric plumes which have subsequently become entrained in the make-up air of downwind facilities. Action Levels Some regulations (e.g., 29 CFR 1910 Subpart Z) specify actions to be taken if monitoring data regarding certain chemicals (e.g., formaldehyde) meet or exceed certain limits (i.e., action levels). While the number of chemicals having action levels defined by safety and health regulations is small, the key requirement for any monitoring program is that corporate action levels be clearly defined for all monitored parameters. In the typical situation, routine monitoring data are collected, recorded, and, over some period of time involving days, weeks, and months, processed and eventually filed. Oftentimes, the employee who conducts the monitoring is not the employee responsible for reviewing the data. This situation is in direct opposition t the objective of using monitoring data to protect human health and safety. Persons who conduct the monitoring and have first access to the resultant data must be equipped with clear criteria for immediately initiating any protective or correction action. Data that meet or exceed established action levels are not to be used to call a meeting to discuss the ramifications of the data; they must trigger immediate response to protect personnel and the general public and to correct a hazardous situation-actions that have already been assessed, fully formulated, and coordinated with external authorities. Carry-Home Contamination Most often overlooked in corporate monitoring programs is the contamination that may be carried home or elsewhere from the workplace
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by hair, clothes, shoes, and other personal clothing. Even where the company attempts to control such carry-home contamination by the use of siterestricted shop uniforms and specially required workplace practices (e.g., workplace showers, hair nets), it is advisable to consider including personal clothing and other items in a comprehensive monitoring program. Even where the potential for such carry-home contamination is negligible, periodic monitoring data can provide documentation that might prove important in a legal proceeding involving any claim of corporate negligence. Such data are also important in setting contractual responsibilities with company out-service contractors, including corporate laundry services.
Quality Control In addition to routinely scheduled monitoring activities, the safety officer is well advised to consider implementing unscheduled or even randomized monitoring efforts. Such unscheduled monitoring, whether conducted by in-plant personnel or external consultants, is a very useful means of ensuring the adequacy and quality of routine monitoring. Where external consultants are used, data sets generated by those consultants should be carefully compared to data sets generated internally. Consideration should also be given to using external consultants (including representatives of local response services) to conduct or to participate in a comprehensive annual review and assessment of the entire monitoring program.
ALARP Principle While regulatory standards must always inform and guide any program of in-plant monitoring and surveillance, the objective of keeping workplace ambient concentrations of hazardous substances as low as reasonably possible (ALARP) is internationally recognized as a universally relevant objective. Elevated to a principle within a globally competitive business community, ALARP properly emphasizes that regulatory standards should be considered maximum allowable limits. However, within those regulatory limits, the company should endeavor to set action levels for monitored data that minimize all workplace and environmental exposure to hazardous substances within the constraints of available technology and economic reasonableness. In formulating a program of workplace monitoring that is consistent with ALARP, companies are well advised to consider that, notwithstanding the necessity of employing legally enforceable health and safety standards, specific technological and economic criteria for setting action levels are also
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to be assessed in terms of the state-of-the-art--i.e., what the "best" companies actually do. Because what happens in the workplace can so easily happen to the community which surrounds that workplace, it can be expected that stateof-the-art practice will increasingly become the measure of competent industrial planning and management rather than, as is too often now the case, economic practicality.
TERRORISM
INTRODUCTION
The U.S. Federal Bureau of Investigation (FBI) defines terrorism as "the use of force or violence against persons or property in violation of the criminal laws of the United States for purposes of intimidation, coercion or ransom," and distinguishes between international terrorism (involving "groups or individuals whose terrorist activities are foreign-based and/or directed by countries or groups outside the United States or whose activities transcend national boundaries") and domestic terrorism (involving "groups or individuals whose terrorist activities are directed at elements of our government or population without foreign direction"). Emergency response services may become involved in terrorist acts in two ways: first (and most obvious), simply because they respond to any community emergency, whatever its cause; second (and too often ignored), because they themselves may become the object of terrorist acts or otherwise unwittingly become pawns in terrorist strategy. To emphasize the difference in these two types of involvement, it is instructive to consider that, while "intimidation, coercion or ransom" may in fact be key motivational dimensions of documented terrorist acts, other emotions, volitions, and psychological states can as well serve to unleash wanton disregard for human life--including "revenge, .... anger and frustration," and even (albeit perversely and pathologically misguided) a "sense of excitement or challenge." From this perspective, response services can become the objects of terrorist violence for several and diverse reasons: 331
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9 because they are high-profile targets of opportunity; or, 9 because their dependable response to an emergency situation makes them predictable and therefore susceptible to the advanced planning of those intent on murder; or 9 because they are so central to community safety and health and yet finite in number they become that first shield of defense to break apart before releasing a more concerted onslaught on the community proper; or 9 because their field operations necessarily entail physical disruptions of normal traffic flows and so occupy the attention of other community services and the public that they can be used both as tactical bottlenecks and feints in a many-layered stratagem for city-wide destruction. As these examples demonstrate, to focus on "intimidation, coercion or ransom" as the sole or even primary (or even necessary) motivations of terrorism is, perhaps, to define the risk presented by terrorism to emergency services (and, thence, to the public at large) too narrowly, essentially ignoring not only the range of human motivations for inventing horror, but also a basic corollary of any humanly contrived and directed violence~that if you play a tactical role against the interests of an adversary, then you yourself become of special interest in that adversary's strategy. It is important to be very clear here~the intent is not to derogate the FBI's definition of terrorism but, rather, to argue as strongly as possible against automatically and uncritically extending that definition into the province of emergency response. Definitions, after all, are precisely whatever we choose them to be, and the FBI and other organizations define things as they do to meet the organizational and legal constraints of their activities. But the objectives, constraints, and activities of the FBI are not those of community response services, which should quickly come to understand that they are subject to the hazards imposed not only by their response to terrorist-caused incidents, but also by themselves becoming targets~that they are at risk not only of the physical, chemical, and biological agents wielded by terrorists, but also of strategies contrived by terrorists. POTENTIAL TERRORIST WEAPONS
Regardless of underlying motivation, a terrorist act is most brutally characterized by the willful use of weapons of mass and indiscriminate murder and destruction. Historically, the typical terrorist weapon has been an explosive device. However, there is a wide range of weaponry that is increasingly available to terrorists. The U.S. Department of Justice and the Federal Emergency Management Agency (FEMA) use the acronym B-NICE to denote this range, the letters standing for: Biological, Nuclear, Incendiary, Chemical, and Explosive incidents.
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Biological Incidents Biological agents include microorganisms (i.e., bacteria, rickettsia, and viruses) and by-products of microbiota (e.g., Botulinum toxin) that can be disseminated within human populations by such means as atmospherically released aerosols and particulates, the contamination of food, water, and other common-use items (e.g., cosmetics, clothing), and the use of living carriers (humans and animals). Biological weaponry is not, as many think, a new development or the product of the "Cold War" rather, such weaponry has been used for hundreds of years with devastating effect. Documented instances of the use of biological weapons in warfare include the use of plague-infested corpses as a means of disseminating the Bubonic plague throughout a besieged city (1346 AD), the use of viruscontaminated blankets to spread smallpox among American Indian loyalists to the French (1759 AD), and the long established use (from Roman times through the American Civil War) of both human and animal corpses to contaminate the water supplies of opposing armies (see Lt. Col. Terry Mayer, USAF, The Biological Weapon: A Poor Nation's Weapon of Mass Destruction; http://www.cdsar.af.mil/battle/chpt8.html). Beginning with World War I and extending through all subsequent wars to the present, the potential for biological warfare resulted in concerted research and development regarding both the use of and the response to biological warfare agents. Despite the unilateral action of the U.S. in the early 1970s to destroy its offensive biological warfare capability, and despite subsequent actions by the world community of nations to remove the threat of biological warfare, the relevant technologies for the production, storage, and delivery of such agents are well developed and, because of their essential simplicity as well as low cost, are readily available. While the World Health Organization (WHO) has estimated that a single incident involving a deadly biological agent could result in approximately 100,000 deaths and an even greater number of incapacitated victims, it is a mistake to assume that a terrorist incident involving biological agents would necessarily be directed against large populations. They can as easily be used against a small population--targeted, perhaps, as part of a more community-wide strategy or, perhaps, simply out of personal revenge. For example, in the mid 1980s, 751 people in Oregon became severely ill after dining at several restaurants. Two years later, a member of a religious cult confessed that these illnesses were the direct result of a plot to contaminate the salad bars in these restaurants with the pathogenic bacterium Salmonella. The objective of the plot was to incapacitate enough of the local population to influence the results of an election in which one of the key issues was land-use disputes between the sect and local officials. Other similar incidents involving the purposeful use of biological agents (e.g., the bac-
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terium Shigella) against relatively small numbers in a selected population have been more recently documented, including hospital and laboratory staff members (Texas) who evidently became targets of personal revenge rather than, as in the Oregon case, of political strategy. Examples of microbial diseases that could be employed by terrorists include: 9 Anthrax: Contagious disease of warm-blooded animals caused by Bacillus anthracis bacterium; characterized by fever, prostration, malignant pustules on exposed skin, and internal hemorrhage 9 Cholera: infectious disease of the small intestine caused by Vibrio cholerae bacterium; characterized by profuse watery diarrhea, vomiting, muscle cramps, severe dehydration, and depletion of electrolytes 9 Bubonic Plague: contagious, often fatal epidemic disease caused by Yersinia pestis bacterium; transmitted from person to person or by the bite of fleas from an infected host, especially a rat; characterized by chills, fever, vomiting, diarrhea, and the formation of buboes (i.e., inflamed, tender swellings of lymph nodes, especially in the area of the armpit or groin) 9 Tularemia: infectious disease caused by Francisella tularensis bacterium; chiefly affects rodents but can also be transmitted to human beings by bite of various insects or contact with infected animals; characterized by intermittent fever and swelling of the lymph nodes 9 Salmonellosis: infection caused by intestinal bacteria of the genus Salmonella; characterized by nausea, abdominal pains, diarrhea, and fever; it can lead to death, especially in people with impaired immune systems 9 Staphylococcus infections: any of a number of infections caused by bacteria of the genus Staphylococcus; characterized by abscesses, boils, and other infections of the skin; can also produce infection in any organ of the body (e.g., staphylococcal pneumonia in the lungs) 9 Q Fever: infectious disease caused by Coxiella burnetii rickettsia; characterized by fever, general malaise, and muscular pains 9 Epidemic Typhus: Any of several infectious diseases caused by rickettsia (e.g., Rickettsia prowasecki); typically transmitted by fleas, lice, or mites; characterized by severe headache, sustained high fever, depression, delirium, and the eruption of red skin rashes 9 Smallpox: highly contagious, sometimes fatal, viral disease; characterized by a high fever and successive stages of severe skin eruptions 9 Lassa Fever: often fatal viral disease endemic to West Africa; characterized by high fever, headache, ulcers of the mucous membranes, and disturbances of the gastrointestinal tract 9 Hemorrhagic Fever: Type of fever characterized by profuse bleeding from internal organs and rapid wasting and death; caused by variety of viruses (e.g., Ebola virus; Marburg virus)
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9 Venezuelan Equine Encephalitis: Viral infection of the central nervous system, with potentially fatal swelling of the brain 9 Hanta Disease: viral infection due to any member of the genus Hantavirus; transmitted by rodents; characterized by flu-like symptoms and, in more severe cases, shock, kidney failure, internal bleeding, fluid accumulation in the lungs, and death. Among the metabolic by-products of microbial growth are potent chemicals collectively known as toxins, which can also be used as biological weapons. Such toxins include bacterial toxins, plant toxins, and other molecules (i.e., bioregulators) which, though not (in a strict sense) toxins, can exert toxic-like effects on the body. Examples of such substances include: 9 Diphtheric toxin: potent toxin produced by the bacterium Corynebacterium diphtheriae, which causes tissue destruction and the formation of a gray membrane in the upper respiratory tract that can detach to cause asphyxiation; toxin may also enter into blood and subsequently damage tissues elsewhere in the body 9 Botulin toxin: extremely potent toxins typically associated with food poisoning; produced by Clostridium botulinum bacterium; characterized by disturbances in vision, speech, and swallowing and, within a few days, paralysis of respiratory muscles and death by suffocation 9 Clostridian toxin: toxin produced by the bacterium Clostridium perfringens, the causative agent of gas gangrene; characterized by slow asphyxiation and subsequent necrosis (cellular death) of living tissue 9 Staphylococcus Enterotoxin Type B (SEB): toxin produced by bacterium Staphylococcus aureus; most commonly associated with food poisoning; characterized by stomach cramps, diarrhea, and vomiting. 9 Saxitoxin: produced by marine blue-green alga (i.e., cyanobacterium), which serves as food supply for various shellfish that are immune to effects of the toxin, but pass it on to higher order consumers (e.g., humans); in humans, toxin acts on central nervous system to produce paralysis; at high doses, death can occur in less than 15 minutes 9 Ricin: mixture of poisonous proteins produced by the castor oil plant; plant gene controlling the production of ricin has been successfully transferred to the bacterium Escherichia coli; ricin interferes with the body's normal synthesis of proteins; symptoms include decreased blood pressure, with death occurring most often through heart failure 9 Substance P: a protein closely related to normally produced proteins in the body; may cause pain, or act as anaesthetic, or affect blood pressure; rapid loss of blood pressure in victim may cause unconsciousness
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With regard to biological weapons, it is necessary to emphasize several facts that underscore the growing concern about their potential use by terrorists: 1. Many of the diseases of primary concern have long been recognized for their potency as human pathogens. Anthrax, for example, reached epidemic proportions in the Roman Empire, resulting in sharp reductions in human populations over a period of 5 years. Similar epidemic outbreaks have occurred throughout history and, even with the invention of effective vaccines for animals (Pasteur; 1861) and humans (Koch; 1883), modern outbreaks have occurred--most notably in the USSR in 1979, when there was an accidental release of dry anthrax spores at the Microbiology and Virology Institute, a Soviet biological warfare facility. This incident resulted in the contamination of an area with a radius of at least 3 kilometers. Despite strict Soviet censorship concerning this incident, it is estimated that from several hundred to several thousand people died after inhaling the spores and contracting pulmonary anthrax. The decision of the U.S. government in 1997 to inoculate troops that could possibly be assigned to duty in the Persian Gulf in opposition to Iraq, which is considered to have developed anthrax as a biological weapon, underscores the potency of this ancient disease. However, as potent as the causative bacterial agent (Bacillus anthracis) of anthrax is, there can be no doubt that modern biotechnologies can be used to develop and mass-produce even more potent bacterial strains. 2. Whether the intent is to mass-produce known lethal microbial byproducts (e.g., ricin), existing pathogens, or newly engineered pathogens, the relevant biotechnologies (e.g., fermentation techniques, DNA amplification, genetic engineering) are universally available and cheap, require little space, can be implemented without the use of highly sophisticated equipment, and are essentially impossible to detect or to distinguish from legitimate uses except through their lethal consequences. 3. As with any means of mass destruction, the delivery of the weapon to the intended target is a primary constraint on its actual use. At one extreme is thermonuclear weapons, which (at least, at a national level) require highly engineered, sophisticated rockets. Far less sophisticated engineering is required, of course, for the delivery of explosive devices, which can be efficiently delivered by means of home-made mortars, cars, and trucks, as well as by a single person harnessed to a bomb. With regard to biological weapons, the primary requisite sophistication for effective delivery is in planning and executionmnot in engineering. Whether the target is a large or small population, many biological agents can be effectively dispersed with minimum dependence on mechanical contrivancemin all probability, dependent more on simple access to a vul-
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nerable population than anything else. Of course, in the case of viable pathogens (as opposed to toxins), access can be quite indirect because, once infected, even a single victim becomes a disease vector within the larger population. 4. Easily engineered to maximize potency, easily manufactured and hidden from detection, and easily dispersed into large and small target populations, biological agents are also highly cost-effective, with killing rates equivalent to those of conventional means at comparatively tiny fractional cost and with a manifold increase in certitude. 5. While modern terrorist incidents have been characterized essentially by a clearly defined instant of horror (e.g., as in an explosion or shooting), biological incidents (especially those involving the use of viable microbes) are much more likely to be discernible only after a period of several days or weeks--a period referred to as the incubation period, which is the time required for a disease to result in clinically defined symptoms. Depending on the length of the incubation period, as well as on the virulence and clinical severity of the disease, a terrorist incident involving biologicals would therefore tend to evolve through various distinct (though also overlapping) phases, most of which could impose profound restraints on normal social interactions. The first phase would extend from the time of the release of the microbial agent to the time at which clinical symptoms become recognized and defined. During this period, the disease would spread surreptitiously and essentially unencumbered through the targeted population. Once clinical symptoms become obvious, a second phase would likely be characterized by a (possibly overwhelming) press on limited and most likely unprepared community hospitals and public health services, accompanied by growing public fear if not panic. Subsequent phases would be characterized by concerted effort to determine preventive and treatment alternatives; to contain the spread of disease and to manage secondary exposure; to secure or, as necessary, develop sufficient stockpiles of antidotes/vaccines; and, finally, to implement population-wide preventive/treatment methods. Nuclear Incidents
Potential nuclear agents are of two basic types: actual thermonuclear devices, and conventional explosive devices that structurally incorporate nuclear materials (radiological dispersal device, or RDD) and which could therefore be used to disperse hazardous nuclear materials over an extended area. It is also possible to achieve the same effects of an RDD by detonating conventional explosives in the immediate vicinity of normal sources of nu-
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clear materials, such as nuclear plants or transport vehicles carrying nuclear cargo. While the access of terrorists to thermonuclear devices cannot be ruled out as a possibility, by far the more likely possibility is the terrorist use of RDDs or, as described above, RDD-equivalent incidents involving normal sources of nuclear materials. The health impact of nuclear materials is due to three types of radiation (or particles) characteristically emitted as a result of the natural radioactive decay of nuclear materials: 9 Alpha particles, which are indistinguishable from the nuclei of helium atoms (2 protons and 2 neutrons): Being very heavy and relatively slow moving, alpha particles travel only small distances (e.g., few inches) before they become absorbed. They cannot penetrate human skin. They are dangerous, therefore, only when they enter the body through the ingestion of contaminated food or water, or the inhalation of dusts or other contaminated materialsmeither of which results in the direct exposure of internal body organs to alpha particles. 9 Beta particles, which are fast moving electrons: Because they are much smaller than alpha particles and travel at very high velocity, beta particles can penetrate into human skin tissue. At high levels, they can cause skin burns. As with alpha particles, the danger of beta particles is through direct exposure of internal organs after ingestion and/or inhalation of contaminated materials. 9 Gamma radiation (or rays), which is a form of high-energy (i.e., high-frequency) electromagnetic radiation that is indistinguishable from energetic X rays: Traveling at the speed of light, gamma radiation can penetrate through the human body as well as through most materials, causing severe and even fatal injury to tissues and organs. Early symptoms of high exposure include skin burns, nausea, vomiting, high fever, and hair loss; later symptoms include the development of various types of cancers, and diminished immunological capacity. In an RDD-incident, first responders are at immediate risk from all three types of radiation. Where the incident involves the generation of large amounts of dust and smoke that can be wind-driven over great distances, large populations become subject to the risks attendant to the inhalation and ingestion of contaminated materials, resulting in significant, long-term interruption of normal daily life and consequent severe (and possibly overwhelming) strain on community resources and services.
Incendiary Incidents An incendiary device is any mechanical, chemical, and/or electrical device specifically designed to start a fire. Whatever the arrangement of me-
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chanical, chemical, and/or electrical components, any incendiary device consists of (a) an igniter or fuse, (b) a container, and (c) a flammable or combustible accelerator that, once ignited, serves as a source of fire for surrounding combustible materials. The igniter or fuse may be as simple as a lighted cigarette or a chemically impregnated fuse, or as complex as a sophisticated electrical circuit that incorporates pressure-, light-, or sounddetectors as well as radio-frequency components. Containers (for the accelerator) may be of any shape and any material and, therefore, easily camouflaged to appear as an ordinary item in any type of surrounding. Accelerators are typically liquid or solid, but may also be gaseous. The range of possible designs of incendiary devices is essentially infinite, limited only by the inventiveness of the designer. Regardless of the sophistication of actual design, essential mechanical, chemical, and electrical components are readily available at low cost, being nondistinguishable from legitimate items in daily commerce. In fact, highly effective and reliable incendiary devices can easily be composed using materials and items typically found in any American home. Moreover, the knowledge needed to contrive such devices is commonplace in the printed and electronic libraries of both general and specialized references that are available to anyone. Chemical Incidents
Chemical agents may be variously classified. For example, they may be classified on the basis of their volatility, with volatile agents being those that can be used to contaminate the atmosphere and, nonvolatile agents being those that can coat surfaces. They may also be classified on the basis of whether they are intended to result in death (i.e., lethal agents) or in incapacitation of victims (e.g., nausea, disorientation, visual problems). Most often, chemical agents are classified on the basis of the types of effects they cause in victims. This is the scheme commonly used by the U.S. Department of Justice and the Federal Emergency Management Agency--a scheme that recognizes five basic classes of chemical agents: 9 Nerve agents (disruption of transmission of nerve impulses) 9 Blister agents (cause severe burns to eyes, skin, and respiratory tract) 9 Blood agents (interfere with capacity of blood to transport oxygen) 9 Choking agents (cause severe stress on respiration) 9 Irritating agents (causing sufficient respiratory distress, tearing, and/or skin pain to temporarily incapacitate victim) The development of modern biotechnologies obscures historical distinctions between biological and chemical warfare agents that have been perpetuated by international law and convention as well as by military prac-
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tice. For example, while certain toxins and bioregulators are several thousand times more potent than even the most lethal nerve gases, they are not classed as chemical warfare agents. Because the terminology related to warfarearmatoria is typically applied to the "weaponry" of terrorism, biologically derived toxins and bioregulators that may be used by terrorists are classified as biological agents despite their being chemicals in precisely the same physical sense as mustard gas. Also, similarly excluded from the above list of agents are pesticides that, whether they are directed against plants (i.e., herbicides) or animals (e.g., piscicides, molluscides), are also potential terrorist weapons. On the basis of these considerations, it is imperative that emergency response personnel clearly understand that the five classes of chemical agents listed above represent selected categories from among a much larger number of types of chemical hazards imposed by terrorist activity--and that they have been selected because they represent, for the emergency responder as well as for military personnel, immediate personal risk.
I. Nerve Agents In their pure form, nerve agents are colorless, odorless, and tasteless chemicals having a wide range of volatility. They enter into the body primarily through inhalation and/or absorption through the skin; however, nerve agents may also be consumed via contaminated food and water. Poisoning is usually most rapid as a result of inhalation, which facilitates the blood's distribution of the nerve agent to target organs throughout the body. Death can occur in a matter of minutes, although (depending on the specific agent and its ambient concentration) distinct symptoms may become evident prior to death, including:
Symptomsof Initial Poisoning 9 9 9 9 9 9 9
Increased salivation Contraction of pupils, dim and blurred vision, pain in the eyes Runny nose and pressure in chest Headache and nausea Slurred speech Hallucinations Unexplained tiredness
Symptomsof Progressive Poisoning 9 9 9 9 9
Uncontrollable salivation, lachrymation, urination, and defecation Involuntary contraction of muscles Excessive sweating Coughing and difficulty in breathing Abdominal pain, nausea, vomiting
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9 Giddiness, anxiety, difficulty in thinking If the primary mechanism of entry into the body is absorption through the skin, the symptoms of poisoning may not become evident for 15-30 minutes after initial exposure. However, at high ambient concentrations, death typically occurs within a few moments after the first symptoms appear. It is therefore crucial that the earliest symptoms be immediately recognized (i.e., salivation, chest pressure, contraction of pupils, blurred vision) so that appropriate antidotes (e.g., atropine, oximes) can be administered. Because of the extreme rapidity of the action of nerve agents, it is sometimes necessary to administer preventive antidotes. Preventive antidotes (pyridostigmine, diazepam) are given in the form of tablets, which require up to 30 minutes to begin having a protective effect, with maximum effect realized about 2 hours following ingestion. Preventive antidotes are therefore most effectively used when it is judged that there is a high likelihood of exposure to nerve agents and there is sufficient time (i.e., 2-3 hours) to take appropriate preventive action. One indication of a situation in which the use of preventive antidotes may be considered would be the on-site presence of many dead insects, birds, and other animals. Another would be the discovery of supplies of nerve gas ingredients during response operations. Nerve agents are known by American alpha denomination (e.g., GA), common name (e.g., Tabun), and scientific name (e.g., o-ethyl dimethylamidophosphorylcyanide). Except for the letter V, the first letter in alpha denominations designates the country that first developed the agent (e.g., G: Germany), and the second letter indicates the relative order in which the agent was developed (e.g., A: first). In V-designated agents, the V stands for venom, while X stands for one of the chemical components in the chemical compound. The most important nerve agents are: 9 9 9 9 9
GA or Tabun [o-ethyl dimethlyamidophosphorylcyanide] GB or Sarin [isopropyl methylphosphonofluoridate] GD or Soman [pinacolyl methylphosphonofluoridate] GF [cyclohexyl methylphosphonofluoridate] VX [o-ethyl s-diisopropylaminomethyl methylphosphonothiolate]
It should be noted that while Sarin was used by Iraq during the IraqIran war (1984-1988), it was also used by Japanese Aum Shinrikyo Cult members against fellow civilians in a Tokyo subway (1995). In this incident, cult members punctured plastic bags containing Sarin in several different subway cars. Despite this primitive mode of release, the incident resulted in a dozen deaths and the serious injury of almost 6000 additional commuters. Nerve agent devices may be manufactured in so called "ready to use" (unitary) form, in which state the agent is fully active and need only be
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released, or in binary form, in which two or more ingredients must be mixed with one another to produce the active agent. Because binary devices essentially contain inactive ingredients up to the moment of mixing, they are safer to manufacture, store, and transport than are fully activated, unitary devices. They are also likely to be less reliable, because the mixing of ingredients must be held within certain constraints of temperature and concentration in order to maximize the production of the active agent--a fact that is of primary concern regarding their military use, which requires a high level of dependability and efficiency for each of large numbers of devices. However, terrorists need not worry about quality control of large stockpiles of identical weapons, whereas the relative ease of storing and transporting could be of primary concern to terrorists in the planning and execution of a specific incident. For example, if the objective is to kill and incapacitate a large number of people in an urban setting, it would make little sense to use an explosive device to release a nerve agent--the noise of the explosion and resultant panic and confusion would serve to disperse the target population away from lethal concentrations. The more insidious and efficient approach would be to activate strategically located devices so as to release the agent silently and otherwise as unobtrusively as possible. In such a scenario, the act of placing devices becomes of critical importance, requiring perhaps an extended period of time (e.g., months)--during which time it becomes necessary to ensure that there is no premature release that would serve as warning. Radio-controlled, nonexplosive binary devices installed and camouflaged into basic infrastructure (HVC components, sewer conduit, electrical conduit, building raceways, street culverts)could serve this purpose.
2. Blister Agents Also known as mustard agents, blister agents are colorless and, while having a characteristic garlic or onion odor, they quickly dull the sense of smell. Readily penetrating clothing and skin, blister agents not only produce burn- and blister-like wounds, but also interfere with a large number of essential cellular processes in living tissue. Examples of blister agents include: 9 9 9 9 9 9
Mustardgas [bis-(2-chloroethyl)sulfide] O-Mustard Ibis (2-chloroethylthioethyl)ether] Nitrogen mustard [bis(2-chloroethyl)ethylamine] Lewisite 1 [2-chlorovinyldichloroarsine] Lewisite 2 Ibis (2-chlorovinyl)chloroarsine] Lewisite 3 [tris (2-chlorovinyl)arsine]
The timing of appearance of symptoms after exposure depends upon the specific agent, varying from immediate to delayed appearance (e.g., 2 to
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24 hours after exposure). Depending upon exposure levels of specific agents, symptoms may include: 9 9 9 9 9 ~ 9 9 9
Aching eyes and lachrymation Inflammation of skin Skin blisters and necrosis Irritation of mucous membranes Hoarseness, coughing, and sneezing Loss of sight Abdominal pain, nausea, blood-stained vomiting, and diarrhea Severe respiratory distress due to lung lesions; pulmonary edema Significant injury to bone marrow, spleen, and lymphatic tissue, with resultant diminution of immune response
Death of exposed persons is typically due to complications from agent-induced injury to lung tissue and, to a lesser extent, to secondary infections as a result of agent-mediated reduction in immunological capacity. Nonlethal effects of low-dose exposures to blister agents are not known; however, at high, long-term doses, mustard gases and lewisites are known to increase the risk of cancer (skin, respiratory tract) as well as other dysfunctions, including chronic respiratory diseases, chronic psychological disorders, and suppression of the immunological system. While mustard gases are classified as mutagens on the basis of animal studies, it is unknown if they present significant mutagenic risk to humans. There is no comprehensive antidote for blister agents. While dimercaptopropanol yields good protection against minor injuries to skin and mucous membranes, the primary form of treatment consists of removal of the victim from sources of addition exposure, decontamination of the body, and the treatment of symptoms, including the use of antibiotics against secondary infections.
3. Blood Agents By interfering with the transfer of oxygen between red blood cells and body tissue, blood agents (e.g., hydrogen cyanide, cyanogen chloride) cause asphyxiation of living tissue (especially heart and brain tissue), resulting in rapid death. While the primary route of entry is primarily through inhalation, hydrogen cyanide as well as cyanide salts in solution can be absorbed through the skin. At high concentrations of hydrogen cyanide (e.g., 300 mg/m3), death occurs within a matter of seconds. At low concentrations, distinct symptoms may progressively develop over a period of several hours and, depending upon exposure time, may include:
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9 9 9 9 9 9 9 9 9
Restlessness Increased rate of respiration Lachrymation Giddiness, headache Heart palpitation Irritation of lungs, respiratory difficulty Vomiting Convulsions Respiratory failure
Blood agents are typically generated by the mixture of cyanide salts (e.g., sodium cyanide, potassium cyanide) and acids (e.g., hydrochloric acid) that are readily available as common industrial chemicals. As with nerve gases, terrorist devices may easily be constructed in binary mode, with the mixing of precursors achieved by simple timing mechanisms or by radiocontrol devices. Because blood agents are liquids while under pressure but become gaseous at normal atmospheric pressure, unitary devices can be easily activated through simple mechanical or electrical means. While low-level cyanide poisoning can be treated medically (e.g., sodium thiosulfate, sodium nitrite, demethylaminophenol), it is necessary-given the rapidity of toxic effectsmthat such treatment be quick. Antidotes that can be used for pretreatment are under active development.
4. Choking Agents These agents (e.g., chlorine, phosgene)cause severe irritation of the lungs, with the consequence that lung tissue secretes large volumes of fluids. Because of the presence of these fluids in lung cavities (the condition known as pulmonary edema), the lung cannot function to exchange oxygen and carbon dioxide, and the victim asphyxiates--literally drowning in his own body fluid. In addition to severe respiratory stress, symptoms include extreme irritation of the eyes. Choking agents are readily available as common industrial gases, and are easily stored and transported in variously sized gas bottles and cylinders.
5. Irritating Agents Also called riot control agents or tear gas, irritating agents such as chloropicrin, MACE, tear gas, pepper spray, and dibenzoxazepine are used to cause respiratory distress and uncontrollable tearing of the eyes. They may also cause severe skin pain, nausea, and vomiting. Although irritating agents are designed to incapacitate rather than to kill, lethality is possible in certain
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circumstances, such as extremely high ambient concentration, or victim hypersensitivity. Most irritating agents are readily available from retail markets. Many may also be easily manufactured from common industrial chemicals or standard laboratory supplies.
INCIDENT SITE AS CRIME SCENE In 1996, the U.S. Fire Administration (USFA) undertook the development of a series of training courses on emergency response to terrorism. The objective of these courses, which are offered through the USFA's National Fire Academy, is to introduce first responders to the consequences of emergency response to terrorist incidents. A self-study training program ("Emergency Response to Terrorism: Self-Study") is also available for download. One of the points given special emphasis in these excellent courses is the fact that any response to an incident other than a natural disaster m a y be a response to a crime scene. There are several necessary precautions that follow from this dictum:
I. Recognition of Warning Signs It must be understood that a terrorist objective may be not simply to cause a particular incident (e.g., an explosion or fire), which will of course result in an emergency response, but also to lure responding community services into an ambush. Whether the target is the immediately involved population at the incident site or the responders to that incident, emergency personnel must be constantly alert to any warning signs of terrorist involvement. The USFA identifies various signs or signals that may warn of the presence of lethal agents included in the five categories of incidents discussed above, including: Biological Incidents
9 Unusual numbers of sick or dying people or animals 9 Dissemination of unscheduled and unusual sprays, especially outdoors and/or at night 9 Abandoned spray devices with no distinct odors Nuclear Incidents
9 Ambient radiological monitoring data 9 Presence of U.S. DOT placards/labels (e.g., in rubble, containers)
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Incendiary Incidents 9 9 9 9
Multiple fires in area Remains of incendiary device components Odors ofaccelerants Unusual heavy burning or fire volume
Chemical Incidents 9 Hazardous materials or lab equipment that is not relevant to the occupancy 9 Exposed individuals reporting unusual odors or tastes 9 Explosions that disperse liquids, mists, or gases 9 Explosions that seem only to destroy a package or bomb device 9 Unscheduled dissemination of an unusual spray 9 Abandoned spray devices 9 Numerous dead animals, fish, and birds 9 Absence of insect life in a warm climate 9 Mass casualties without obvious trauma 9 Distinct pattern of casualties and common symptoms 9 Civilian panic in potential target areas
Explosive Incidents 9 9 9 9
Obvious large-scale structural damage Blown-out windows and widely scattered debris Shrapnel-induced trauma Shock-like symptoms and/or damage to victims' eardrums
Of course, it must be emphasized that any combination of lethal agents may be employed by terrorists--as well as primed for release in sequenced fashion. Thus, for example, the absence of any indicator of a chemical device at the site of a fire does not mean that such a device is not present, or that one could not be activated by an internal or external trigger.
2. Entry Precautions Given the potency of biological, chemical, and nuclear agents, and given the limited resources typically available to first responders, any suspicion of possible terrorist involvement in an incident is sufficient cause to delay entry into the incident area until additional and specialized resources are available. The USFA has emphasized that, in the face of a determined terrorist effort, perhaps the single most important task is the decontamination of equipment, personnel, survivors, and c a s u a l t i e s ~ a task that, depending on
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the geographical extent of the incident and the nature of the hazardous agent, can easily overwhelm community and even state resources. The on-site evaluation of needed resources (e.g., radiological monitoring, biological agent monitoring, decontamination equipment and supplies) cannot be conducted in the absence of extensive, preincident planning between local, state, regional, and federal services and authorities, as well as critical industrial and private sector facilities and organizations. 3. C r i m e Scene Precautions
Just as the possibility of arson requires fire fighters to conduct their operations in a manner consistent with the needs of a criminal investigation, so does terrorism require similar caution for all emergency response operations. While the rescue of victims and community safety are always critical objectives of on-site operations, the preservation of physical evidence of terrorism must be given equal priority. After all, until terrorists are apprehended, they are free to target additional victimsJand they cannot be apprehended and successfully prosecuted if crucial evidence is lost or destroyed as a result of emergency response operations. In order to ensure the preservation of critical criminal evidence, all response operations must be tightly coupled with law enforcement needs, which requires (a) extensive preincident liaison between response services and criminal investigative authorities, (b) the development of relevant SOPs by response services, and (c) intensive training of response personnel. T H R E A T A N D RISK T A R G E T A S S E S S M E N T
While much emphasis has been given to the need for extensive preincident operational planning by response services in close coordination with municipal, state, regional, and Federal authorities (e.g., items 2 and 3, above), equal emphasis must be given to two types of assessment that can provide crucial input not only to the formulation of operational response plans but also of preventive strategies: (a) Threat Assessment, which is the attempt to identify groups and organizations that may pose a terrorist threat to the community, and (b) Risk Target Assessment, which attempts to identify specific facilities, activities, organizations, and groups that might become targets of terrorists. Examples of potential terrorist groups might include (but are not be limited to): ethnic separatist and ~migr(3 groups; left-wing radical organizations; right-wing racist, anti-authority, survivalist groups; foreign terrorist organizations; and issue-oriented groups, such as animal rights groups, extremist
348
14 Terrorism
environmental groups, extremist religious groups, and anti-abortionists. Potential community targets might include (but are not be limited to): military or governmental installations; industries that are part of the "military-industrial complex"; industries that manufacture environmentally sensitive products or operate in politically sensitive countries; major financial institutions; major components of social infrastructure (e.g., transportation, communication, utilities); sports arenas; shopping centers; special events (e.g., parades). While both Threat and Risk Target Assessments should be coordinated through local, state, regional, and federal law enforcement authorities, perhaps the primary responsibility for conducting these assessments should be assumed by a local emergency planning and response authority, which is ideally situated to have detailed knowledge of potentially sensitive local targets and can take meaningful steps toward developing practical partnerships among both public and private resources, services, and organizations.
EMERGENCY OPERATIONS PLAN
Whenever a response service determines that the magnitude of an incident (whether a terrorist incident or a natural disaster) is beyond its routine response responsibility and capability, that response service must implement the community Emergency Operations Plan (EOP). The EOP is a written plan that: 9 Assigns responsibility to organizations and individuals for carrying out specific actions at projected times and places 9 Sets forth lines of authority and organizational relationships, and shows how all actions will be coordinated 9 Describes how people and property will be protected in emergencies and disasters 9 Identifies personnel, equipment, facilities, supplies, and other resources available--within the jurisdiction or by agreement with other jurisdictionsmfor use during response and recovery operations 9 Identifies steps to address mitigation concerns during response and recovery activities As a local plan, the EOP is intended to address specific needs to be provided to local authorities by state and federal authorities in order to ensure the protection of the public. While emergency response in the United States is the primary responsibility of local government, the EOP details precise procedures wherein the state provides essential assistance: 1. providing direct response assistance to local jurisdictions whose capabilities are overwhelmed by an emergency,
EmergencyOperations Plan
349
2. providing state response services as primary response authority in certain types of emergencies, and 3. coordinating with Federal authorities to secure additional assistance Federal emergency response assistance to state and local governments is authorized by the federal Robert T. Stafford Disaster Relief and Emergency Assistance Act (Public Law 93-288, as amended). This assistance is provided according to the provisions of the U.S. Federal Response Plan (FRP), which is activated when the state governor, having determined that emergency response needs exceed state resources, requests Federal assistance. Once activated, the FRP assigns Federal lead agencies to coordinate federal assistance in each of 12 functional areas, as follows: 9 Transportation (U.S. Department of Transportation [DOT]) 9 Communications (National Communication System) 9 Public Works and Engineering (U.S. Department of Defense, Army Corps of Engineers) 9 Fire Fighting (U.S. Department of Agriculture, Forest Service) 9 Information and Planning (Federal Emergency Management Agency [FEMA]) 9 Mass Care (American Red Cross) 9 Resource Support (General Services Administration [GSA]) 9 Health and Medical Services (U.S. Department of Health and Human Services, Public Health Service) 9 Urban Search and Rescue (Federal Emergency Management Agency [FEMA]) 9 Hazardous Materials (Environmental Protection Agency [EPA]) 9 Food (U.S. Department of Agriculture, Food and Nutrition Service) 9 Energy (U.S. Department of Energy [DOE]) The FRP is amended by Presidential Decision Directive 39(PDD-39), "United States Policy on Counterterrorism." Thus, if the FRP is activated in response to a state governor's request (through FEMA) for assistance in a terrorist incident, Federal assistance will be provided in conformance with the provisions of the Terrorism Incident Annex to the FRP (see Appendix I). This annex to the RFP, reflecting the directives of PDD-39, assigns specific responsibility for two key aspects of operational response to any terrorist incident: 9 Crisis management (law-enforcement efforts that focus on the criminal aspects of the incident) 9 Consequence management (response efforts that focus on alleviating damage, loss, hardship, or suffering related to the incident)
350
14 Terrorism
Crisis management activities are the responsibility of the Federal Bureau of Investigation (FBI), which coordinates all relevant local, state, and Federal legal authorities. Consequence management activities are the responsibility of FEMA, which coordinates Federal, state, and local volunteer and private agencies. Upon a state governor's request for assistance and a Presidential Declaration of Disaster, the sequence of events would be as follows: 1. FEMA would use its emergency authorities to notify appropriate Federal agencies, activate the FRP, begin coordinating the delivery of Federal assistance, and establish liaison operations with the FBI, 2. The FEMA Director would consult with the governor of the affected state to determine the scope and extent of the incident, and 3. An emergency response team, made up of representatives from each of the primary Federal agencies, would be assembled and deployed to the field to establish a disaster field office and initiate operations.
GLOSSARY
A Abrasion The wearing away of any part of a material by rubbing against another surface. A C blood agent hydrogen cyanide.
Acclimatization Process whereby worker is conditioned to work under high temperature and relative humidity; usually accomplished over a period of 6 days by gradually increasing work load and time of exposure to heat. A C G I H American Conference of Government Industrial Hygienists; a private organization of occupational safety and health professionals; recommends occupational exposure limits for toxic substances; ACGIH limits are not legally enforceable. A C P see Area contingency plan.
Acquired immune deficiency syndrome A commnicable disease caused by human immunodeficiency virus (HIV).
chemical exposure, developing within a short time period (seconds, minutes, hours) after the exposure. A d m i n i s t r a t i v e control Any administrative procedure, policy, or protocol that results in a reduction of risk to personnel.
Advanced life support Emergency medical treatment at an advanced level, usually provided by paramedics, and including use of drugs, cardiac monitoring/ intervention, and intravenous fluids. Aerial torch An ignition device suspended under a helicopter, capable of dispensing ignited fuel to the ground for assistance in burnout or backfiring. A f t e r f l a m e t i m e The length of time for which a material (fabric) continues to flame after the ignition source has been removed.
Afterglow Glow that persists in the material after the removal of an external ignition source or after the cessation (natural or induced) of flaming of the material.
A c t i o n plan see Incident action plan.
Acute As used regarding a disease, of short duration, usually with an abrupt onset; as used regarding an illness due to
AI'IE Acute hazardous event. AIDS see Acquired immune deficiency syndrome.
351
352 A I D S related complex An outdated term used to describe symptoms of HIV infection in patients who have not developed AIDS. These include fatigue, diarrhea, night sweats, and enlarged lymph nodes. ARC is not included in the current Centers for Disease Control classification of HIV Infection.
Airborne pathogen Pathologic microorganism spread by droplets expelled into the air, typically through a productive cough or sneeze. A i r p e r m e a b i l i t y The rate of air flow through a material under a differential pressure between two fabric surfaces. A i r t a n k e r Any fixed wing aircraft certified by the U.S. Federal Aviation Administration as being capable of transport and delivery of fire retardant solutions.
Alarm signal An identifiable audible warning that indicates that a fire fighter is in need of assistance.
Allocated resources Resources dispatched to an incident. Alpha radiation The least penetrating type of nuclear radiation; not considered dangerous unless alpha-contaminated particles enter the body (e.g., through inhalation); indistinguishable from the nucleus of helium atom (2 protons and 2 neutrons).
Appendix A (e.g., dust, vapor, mist) in a volume of air or water.
Amniotic fluid The watery fluid that surrounds the fetus or unborn child in the uterus.
Annunciator The device of a PASS unit designed to emit the alarm signal. A N S I American National Standards Institute.
Anthrax Contagious disease of warm-
blooded animals caused by Bacillus anthracis bacterium; characterized by fever, prostration, malignant pustules on exposed skin, and internal hemorrhage.
Antibody A component of the immune system that eliminates or counteracts a foreign substance (antigen)in the body.
Antibody positive The result of a test or series of tests to detect antibodies in blood; a positive result means that a particular antibody is present.
Antigen A foreign substance (including pathogens) that stimulates the production of antibodies in the immune system.
Antiviral drug A drug that can interfere with the life cycle of a virus. A P E L L see Awareness and preparedness for emergencies at local level.
Approach clothing Protective clothing
ALS see Advanced life support.
designed to provide protection from radiant heat.
Alternative response technology
ARC see AIDS related complex.
Response method or technique other than mechanical containment or recovery; may include use of chemical dispersants, in-situ burning, bioremediation, or other alternatives.
Area command In ICS, an organiza-
Ambient concentration The concentration of a chemical or material
tion established to: (I) oversee the management of multiple incidents that are each being handled by an Incident Command System organization; or (2) to oversee the management of a very large incident that has multiple Incident
Glossary
353
Management Teams assigned to it_ Area Command has the responsibility to set overall strategy and priorities, allocate critical resources based on priorities, ensure that incidents are properly managed, and ensure that objectives are met and strategies followed.
Assisting agency In ICS, any agency or
Area committee In the U.S., commit-
A S T M American Society for Testing and Materials.
tee appointed by the President for each national area that is designated by the President under the Oil Pollution Act of 1990.
Area contingency plan An incident response plan prepared, under authority of the U.S. Oil Pollution Act of 1990, by a presidentially designated Area Committee, to be implemented in conjunction with the National Contingency Plan to remove a worst case discharge, and to mitigate or prevent a substantial threat of such a discharge, from a vessel, offshore facility, or onshore facility operating in or near the affected area.
Area of probability Limited area where a lost object or person is most likely to be found.
organization that directly participates (i.e., provides tactical or service resources) in the emergency response effort; a wide range of different agencies may provide such assistance in a multijurisdiction or multiagency incident.
Asymptomatic Havinga disease-causing agent in the body but showing no outward signs of disease.
Asymptomatic HIV seropositive The condition of testing positive for HIV antibody without showing any symptoms of the disease; a person who is HIVpositive, even without symptoms, is capable of transmitting the virus to others.
Audiogram Hearing test to determine normal hearing capacity of individual. A u t o i g n i t i o n t e m p e r a t u r e The lowest temperature at which combustion occurs in the bulk gas in a heated gas-air mixture.
Available resources Incident-based resources that are ready for deployment.
ARIP Accidental release information program. ART see Alternative response technology.
Asphyxiant Any vapor that can displace air and thereby cause suffocation.
Aspiration hazard The danger of
Awareness and preparedness for emergencies at local level A process for responding to technological accidents; a component of the United Nations Environmental Program. A Z T The first FDA-approved drug used to treat AIDS.
drawing a fluid into the lungs and causing an inflammatory response to occur.
Assigned resources Resources checked in and assigned work tasks on an incident.
Assignments Tasks given to resources to perform within a given operational period, based upon tactical objectives in the incident action plan.
Bacterium A type of microorganism; some can produce disease in a suitable host. Bacteria can self-reproduce, and some forms may produce toxins harmful to their host.
354 Base In ICS, the location at which primary logistics functions for an incident are coordinated and administered; there is only one Base per incident; the incident command post may be collocated with the base. Baseline audiogram An audiogram performed to determine normal hearing capacity in the absence of any work-related hearing impairment; used to compare with results of subsequent audiograms and thereby determine any development of hearing impairment. Basic life support Emergency medical treatment at a level authorized to be performed by emergency medical technicians as defined by the medical authority having jurisdiction; generally refers to treatment provided at EMT-A level. BATF Bureau of Alcohol, Tobacco, and Firearms (U.S.). Beta radiation A type of nuclear radiation (fast moving electrons) that is more penetrating than alpha radiation and can damage skin tissue and harm internal organs. Binary device Any CW device composed of two or more chemical components (i.e., precursors) that, when mixed, produce a toxic gas or liquid; mixing may be accomplished by a wide range of mechanical or electrical forces. Biological agents Living organisms, or the materials derived from them, that cause disease in (or harm) humans, animals, or plants, or cause deterioration of materials. Biological agents may be found as liquid droplets, aerosols, or dry powders. A biological agent can be adapted and used as a terrorist weapon, such as anthrax, tularemia, cholera, encephalitis, plague, and botulism.
Appendix A
Bioremediation Technology in which living organisms (e.g., bacteria, yeasts) are used to effect chemical changes in hazardous chemicals; can be used in both water and soil. Bleve A boiling liquid expanding vapor explosion, with the sudden release and ignition of a great mass of pressurized liquid into the atmosphere. Blister agent A chemical agent (also called a vesicant) which causes severe blistering and burns to eyes, skin, and tissues of the respiratory tract; exposure is through liquid or vapor contact; also referred to as mustard agents (e.g., mustard, lewisite). Blizzard warning Condition of alert that severe winter weather with sustained winds of at least 35 mph is expected.
Blood agent A chemical agent that interferes with the ability of blood to transport oxygen and causes asphyxiation (e.g., hydrogen cyanide, cyanogen chloride). BLS see Basic life support.
Bloodborne pathogen Pathologic microorganisms that are present in human blood and that can cause disease in humans; the term "blood" includes blood, blood components, and products made from human blood. Boat-directed search Offshore search pattern that is surface-directed by tender in boat with on board safety diver equipped and standing by. Body fluid Fluid that has been recognized by the U.S. Center for Disease Control as directly linked to the transmission of HIV and/or HBV and/or to which universal precautions apply; includes blood, semen, blood products, vaginal secretions, cerebrospinal fluid, snynovial fluid,
Glossary pericardial fluid, amniotic fluid, and concentrated HIV or HBV viruses.
Body substance isolation An infection control strategy that considers all body substances potentially infectious; more stringent than universal precautions, the strategy used to control exposure to bloodborne pathogens. Boiling point The temperature at which a liquid's vapor pressure equals the atmospheric pressure, resulting in rapid vaporization of the liquid. Botulin toxin Extremely potent toxin typically associated with food poisoning; produced by Clostridium botulinum bacterium; infection is characterized by disturbances in vision, speech, and swallowing and, within a few days, paralysis of respiratory muscles and death by suffocation.
Branch The organizational level (in ICS) having functional or geographic responsibility for major parts of incident operations; the Branch level is organizationally between section and division/group in the operations section, and between section and units in the logistics section; branches are identified by the use of roman numerals or by functional name (e.g., medical, security). Breathability The capacity of a material to allow air permeability and water vapor transmission. BSI see Body substance isolation.
Bubonic plague Contagious, often fatal epidemic disease caused by Yersinia pest,s bacterium; transmitted from person to person by the bite of fleas from an infected host, especially a rat; characterized by chills, fever, vomiting, diarrhea, and the formation of buboes (swellings of lymph nodes).
355 Bursting strength The force or pressure required to rupture a textile by expanding it with a force applied perpendicular to the fabric surface. B W Biological warfare.
C
Cache A predetermined complement of tools, equipment, and/or supplies stored in a designated location, available for incident use. CAER Community awareness and emergency response.
CAMEO Computer-aided management of emergency operations; a suite of programs developed by U.S. EPA and NIOSH for management of chemical incidents. Camp In ICS, a geographical site, within the general incident area, separate from the incident base, equipped and staffed to provide sleeping, food, water, and sanitary services to incident personnel. Carcinogen Any material that causes cancer. Carpal tunnel syndrome Entrapment of the median nerve of the hand and wrist in the tunnel through the carpal bones of the wrist; symptoms include finger numbness and pain upon gripping. C a r r i e r A person who apparently is healthy, but who is infected with some disease-causing organism that can be transmitted to another person.
Carries Means of moving a drowning victim, under control of the rescuer, to a place of safety. CAS Chemical abstract service; an organization operated by the American
356
Appendix A
Chemical Society that indexes information about chemicals.
material tears along the burned area is the char length.
Catalyst A substance that promotes or
Charring The formation of carbonaceous
increases the rate of a chemical reaction, but is not a reactant and is not consumed by the reaction.
residue as the result of pyrolysis or incomplete combustion.
Catastrophic release A major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals.
Cause-consequence analysis A hazard analysis method that combines fault tree and event tree analyses, displaying the relationships between the accident's consequences (modeled by event tree analysis) and their basic causes (modeled by fault tree analysis). C B W Chemical/biological warfare. C D C see Centers for Disease Control.
Center punch Device for breaking side and rear windows of a vehicle.
Centers for Disease Control A branch of the U.S. Public Health Service, Department of Health and Human Services, concerned with communicable disease tracking and control. CEPP Chemical emergency preparedness program. C E R C L A Comprehensive Emergency Response, Compensation, and Liability Act
(u.s.). CFR U.S. Code of Federal Regulations.
Chain of command A series of management positions in order of authority.
Char length The distance a material burns after being exposed to a flame as measured using a weight to tear the materials; specifically, the distance the
Check-in In ICS, the process whereby resources first report to an incident; checkin locations include: incident command post (resources unit), incident base, camps, staging areas, helibases, helispots, and division supervisors (for direct line assignments).
Checklist analysis A hazard evaluation method that uses written lists of design or operational features as a guide in assessing the process safety status of a system; can be generic in scope or specific to a type of process.
Chelation Decontamination method involving the addition of chemical reagents that tightly bind with the target contaminant; can effectively reduce the chemical dynamics of the contaminant and/or facilitate its removal.
Chemical agent Any of five classes of chemicals that produce incapacitation, serious injury, or death, including: nerve agents, blister agents, blood agents, choking agents, and irritating agents.
Chemical asphyxiant Known also as blood agents or blood poisons, these chemicals interrupt the flow of oxygen in the blood or the tissues in any of three ways: (a) react more readily than oxygen with the blood (e.g., carbon monoxide), (b) liberate the hemoglobin from red blood cells, resulting in a lack of oxygen transport, (c) cause a malfunction in the oxygen-carrying capacity of red blood cells (e.g., benzene and toluene).
Chemical penetration The bulk flow of a liquid chemical through seams, closures,
357
Glossary and openings or pores and imperfection in a clothing material.
Chemical process quantitative risk analysis A numerical evaluation of overall risk from a chemical process that combines consideration of both incident consequences and incident probabilities. C H E M T R E C Chemical Transportation Emergency Center; a nationwide service established by the Chemical Manufacturers Association to relay emergency information concerning specific chemicals that have been involved in a transportation emergency.
Cholera Infectious disease of the small intestine caused by Vibrio cholerae bacter-
disease, often used to denote persons who can serve as the source of infection for other persons. Circular pattern Circular or semicircular search pattern of area of probability when datum point is known. CISD see Critical incident stress debriefing. Cleaning The physical removal of dirt and debris.
Cleaning shrinkage The change in dimension of a fabric specimen after exposure to a specified cleaning process.
Clear text The use of plain English in
ium; characterized by profuse watery diarrhea, vomiting, muscle cramps, severe dehydration, and depletion of electrolytes.
radio communications transmissions; no ten codes or agency-specific codes are used when utilizing clear text.
Chicken pox A highly communicable disease caused by a herpes virus; no vaccine presently available; commonly occurs in childhood.
Closed-circuit S C B A A recirculationtype SCBA in which the exhaled gas is rebreathed by the wearer after the carbon dioxide has been removed from the exhalation gas and the oxygen content within the system has been restored from sources such as compressed breathing gas, chemical oxygen, liquid oxygen, or compressed gaseous oxygen.
Chief The ICS title for individuals responsible for command of functional sections: operations, planning, logistics, and finance/administration. Choking agent A chemical agent (e.g., chlorine, phosgene) that causes physical injury to the lungs; in extreme cases, membranes swell and lungs become filed with liquid, which can result in asphyxiation.
Chronic As used regarding a disease, of long duration or recurring often; as used regarding an illness due to chemical exposure, developing within a long time period (years, decades) after the exposure.
Chronic carrier A person who is a longterm carrier of a disease, whether or not that person shows any symptoms of that disease; in the case of a communicable
Clostridian toxin Potent toxin produced by the bacterium Clostridium perfringens, the causative agent of gas gangrene; characterized by slow asphyxiation and subsequent necrosis (cellular death) of living tissue. C H V see Cytomegalovirus. CNS Central nervous system (brain and spinal cord).
Colorfastness The ability of a material to retain the same color following exposure to specific physical or environmental conditions.
358 Combustible Any material that burns when subjected to a temperature greater than 100~ and below 200~ Combustion A chemical process of oxidation that occurs at a rate fast enough to produce heat and usually light in the form of either flames or glow. Command post see Incident command post.
Command staff In ICS, the command staff consists of the information officer, safety officer, and liaison officer, who report directly to the incident commander; in minor incidents, the incident commander may choose not to establish a separate command staff, in which case these functions become the responsibility of the incident commar der.
Communicable disease A disease that can be transmitted from one person to another; also known as contagious disease.
Appendix A incident, with focus on the alleviation of damage, loss, hardship, or suffering; the Federal Emergency Management Agency is the lead agency for consequence management.
Contaminant A substance or microbial organism that poses a threat to human health or life or to the environment.
Contamination reduction corridor Designated area of hazardous waste site within the contamination reduction zone (CRZ) where decontamination procedures are performed.
Contamination reduction zone At a hazardous waste site, the transition area between the contaminated area and the clean area.
Contraindicated In reference to any
Compliance audit A documented
medicine or vaccine, determined to be actually counterproductive to health and well being in certain circumstances.
evaluation and assessment of a facility's compliance with regulatory provisions.
Convection For thermal protection,
Composite The layer or combination of
refers to heat transfer through a material by air transmission.
layers for a protective clothing item.
Compressed breathing gas Oxygen or a respirable gas mixture stored in a compressed state and supplied to the user in gaseous form.
Conduction For thermal protection,
Cooperating agency In ICS, any agency or organization that, though not directly participating in the response effort, becomes involved in the incident to provide key services (e.g., Red Cross, Red Crescent)
refers to heat transfer through a material by direct contact with another material or surface.
Corrosive Any material that chemically
Confined space An enclosed space large enough for a person to enter and perform work but which has restricted means of entry and exit (e.g., tanks, vessels, vaults).
C P Q I ~ see Chemical process quantitative risk analysis.
Consequence management As described in (U.S.) Presidential Decision Directive 39, the response to a terrorist
burns living tissue on contact; may be either an acid or a base (alkali).
CPR Cardiopulmonary resuscitation. CRC see Contamination reduction corridor.
359
Glossary Crisis management As described in (U.S.) Presidential Decision Directive 39, the response to a terrorist incident, with focus on the criminal aspects of the incident; the Federal Bureau of Investigation (FBI) is the lead agency in crisis management. Critical e q u i p m e n t Chemical process equipment that is deemed to be critical to process safety. Critical incident Any event, circumstance, or condition that overwhelms an individual's capacity to cope; an extreme situation that causes significant and potentially long-lasting psychological effects. Critical incident stress Stress resulting from the experience of a critical incident and having the potential to cause significant behavioral, cognitive, emotional, and physical changes in the individual who experiences the stress.
Critical incident stress debriefing Stress reduction processes designed to address the special needs of emergency response personnel in dealing with situations that cause strong emotional reactions or interfere with the ability to function.
Critical operating parameter A parameter that indicates imminent approach of a major process hazard when a certain measurable level of that parameter is exceeded.
Cumulative stress disorder The cumulative wear and tear of joints and associated tissue due to mechanical injury to muscle, nerve, tendon, and/or bone tissue; also called cumulative trauma disorder.
Cut resistance The capacity of a material to prevent cut-through by a sharp-edged blade. C W Chemical warfare. C X Choking agent phosgene oxime.
Cyalume Chemical light stick attached to buoyancy compensator by lanyard; to be activated and displayed on all night operations. Cytomegalovirus A viral infection that may occur without any symptoms or result in mild flue-like symptoms; severe CMV infections can result in hepatitis, mononucleosis, or pneumonia; CMV is shed in body fluids (urine, semen, sputum, and saliva); in the presence of immune deficiency, such as AIDS, it can also affect other internal organs and vision, sometimes leading to blindness.
D Datum point Last known position of lost object or person. Debilitating illness (or injury) A condition that temporarily or permanently prevents a person from engaging in normal work or activities.
Decibel The unit of measurement (dB) used to express sound levels. Decontamination The physical and/or chemical process of reducing and preventing the spread of contamination from contaminated persons or equipment. Deflagration A chemical reaction where the reaction or flame front travels at less than sonic velocity. Delta hepatitis see Hepatitis D.
CRZ see Contamination reduction zone.
Demand S C B A see Negative pressure
CSD see Critical stress disorder.
SCBA.
360
Appendix A
Dermal Pertaining to the skin.
Dispersant A chemical agent used to
Detoxification Decontamination
break up concentrations of a hazardous material (e.g., oil spill).
method that involves a chemically, physically, or biologically mediated change in either the molecular structure of a contaminant molecule or the molecular dynamics (e.g., acidity, alkalinity) in which the contaminant plays a role; used to reduce the hazard associated with a contaminant.
Diphtheric toxin Potent toxin pro-
duced by the bacterium Corynebacterium causes tissue destruction and the formation of a gray membrane in the upper respiratory tract that can detach to cause asphyxiation; toxin may also enter into blood and subsequently damage tissues elsewhere in the body.
diphtheriae, which
Direct disease transmission The transmission of a disease from one person to another clue to direct contact with infected blood, body fluids, or other infectious materials. Disease An alteration of health, with a characteristic set of symptoms, which may affect the entire body or specific organs; diseases have a variety of causes and are known as infectious diseases when they are due to pathogenic microorganisms such as bacteria, viruses, or fungi. Disease v e c t o r An organism (e.g., mosquito, tick) that plays an intermediary role in the transmission of a pathogenic organism from an infected person to a noninfected person.
Disinfection A procedure that inactivates virtually all recognized pathogenic microorganisms, but not necessarily all microbial forms (e.g., bacterial endospores) on inanimate objects.
Dispersion model A quantitative model (usually computerized) that is used to make predictions concerning the spatial distance traversed by and the changing concentration of a volume of a chemical or material released into either air or water. Division In ICS, divisions are used to divide an incident into geographical areas of operation; a division is located between the branch and the task force/strike team; divisions are identified by alphabetic characters for horizontal applications and, often, by floor numbers when used in buildings.
Documentation unit In ICS, functional unit within the planning section responsible for collecting, recording, and safeguarding all documents relevant to the incident. Dose The amount of a chemical that enters into the body relative to the weight of that body; usually measured in terms of milligrams (of chemical) per kilogram (of body weight). D o s e - e f f e c t see Dose-response.
Dose-response The direct mathematical relationship between the dose of a chemical administered to an individual or group and the probability that the individual or group will experience a defined response (effect) to the chemical. D O T U.S. Department of Transportation. DVV~N Dangerous when wet.
Dispatch c e n t e r In ICS, a facility from
EAP see Member assistance program.
which resources are directly assigned to an incident.
ECs0 Effective concentration of a chemical (in ambient air or water) for 50% of the
361
Glossary population (or the ambient concentration that presents an individual with a 0.5 probability of experiencing the defined effect). EDs0 Effective dose of a chemical for 50% of the population (or the dose that presents an individual with a 0.5 probability of experiencing the defined effect). ELISA see Enzyme-linked immunosorbent assay.
Emergency management coordinator/director The individual within each political subdivision that has coordination responsibility for jurisdictional emergency management.
Emergency medical care The provision of treatment to patients, including first aid, cardiopulmonary resuscitation, basic life support (EMT level), advanced life support (paramedic level), and other medical procedures that occur prior to arrival at a hospital or other health care facility. Emergency medical operations Delivery of emergency medical care and transportation prior to arrival at a hospital or other health care facility. EMS see Emergency medical service.
Emergency medical services A group, department, or agency that is trained and equipped to respond in an organized manner to any emergency situation where there is the potential need for the delivery of pre-hospital emergency medical care and/or transportation; EMS can be provided by fire department, private, third service, or hospital-based systems or any combination thereof. EMT see Emergency medical technician.
Emergency medical technician A health-care specialist with particular skills
and knowledge in pre-hospital emergency medicine.
Emergency operations center A predesignated facility established by an agency or jurisdiction to coordinate the overall agency or jurisdictional response and support to an emergency.
Emergency operations plan A document that (a) assigns responsibility to organizations and individuals for carrying out specific actions at projected times and places in an emergency that exceeds the capability or routine responsibility of any one agency; (b) sets forth lines of authority and organizational relationships, and shows how all actions will be coordinated; (c) descries how people and property will be protected in emergencies and disasters; (d) identifies personnel, equipment, facilities, supplies, and other resources available for use during response and recovery operations; and (e) identifies steps to address mitigation concerns during response and recovery activities. End-of-service-time indicator A warning device on a SCBA that warns the user that the end of the service time of the SCBA is approaching. Enclothermic A chemical reaction that requires the addition of heat. Engineering control Any method of controlling exposure to a hazard by modifying the physical space in which the hazard is contained (e.g., barrier, ventilation). Enteric precautions A system of precautions to prevent transmission of disease by the oral/fecal route. E n t r y clothing Protective clothing that is designed to provide protection from conductive, convective, and radiant heat, and permit entry into flames.
362 Environmental fate The totality of translocations (movements) and transformations that a chemical undergoes upon release to the environment. Enzyme-linked immunosorbent assay A test used to detect antibodies to the AIDS virus, indicating infection; for accuracy, a positive ELISA test is always repeated; if still positive, a Western blot test is then performed to confirm the diagnosis; the sensitivity and specificity of a properly performed ELISA test 12 weeks after exposure is at least 99%. EOC see Emergency operations center. EOP see Emergency operations plan. EPA U.S. Environmental Protection Agency. EPCRA Emergency Planning and Community Right-to-Know Act (U.S.). Epidemic typhus Any of several infectious diseases caused by rickettsia (e.g., Rickettsia prowasecki); typically transmitted by fleas, lice, or mites; characterized by severe headache, sustained high fever, depression, delirium, and the eruption of red skin rashes.
Appendix A
Evacuation drill A training exercise in which personnel walk the evacuation route to a designated area where procedures for accounting for all personnel are tested; participants are asked to make note of what might become a hazard during an actual emergency (e.g., stairways cluttered with debris, smoke in hallways) so that appropriate modifications of the evacuation plan may be made. Evaporative heat transfer The process by which heat is removed from a surface by the evaporation of liquid; as applied to protective clothing, this measure refers to how easily bodily heat can be released from inside the clothing to the outside environment by the process of sweating, which involves both permeation of air and transmission of water vapor as fluid for transferring heat. Event Any planned, nonemergency activity (e.g., parades, concerts). Event tree analysis One of several methods of hazard analysis, which involves inductive determination of pathways of disturbances having led to a hazardous situation.
Epidemiology The study of the incidence, distribution, and control of a disease in a population.
Exclusion zone Area at hazardous waste site where contamination by hazardous chemicals has either already occurred or might occur.
Ergonomics Discipline concerned with designing plant, equipment, operations, and work environments so that they match human capabilities.
Exothermic A term used to characterize the evolution of heat (e.g., from a chemical process).
Ergonomic stress Any stress associated with mechanical tensions in the musculoskeletal system.
Expanding square search Compassdirected search pattern for offshore use.
toxins) that may cause human disease.
Explosive Any material that suddenly releases pressure, gas, and heat when ignited.
Etiology The cause(s) or origin(s) of a disease.
Explosive (Class A) U.S. Department of Transportation classification for those
Etiologic agent A living organism (or its
Glossary substances that pose maximum explosion hazard through detonation. Explosive (Class B) U.S. Department of Transportation classification for those substances that ignite by rapid combustion rather than by detonation; includes fireworks, flash powders. Explosive (Class C) U.S. Department of Transportation classification for those substances that contain restricted quantities of Class A and/or Class B explosives; minimum explosion hazard.
Explosive Limits see Upper and Lower Explosive Limit. Exposure Eye, mouth, mucous membrane, skin, or parenteral contact with blood, other body fluids, or other potentially infectious material. Extremely hazardous substance Any one of 366 hazardous chemicals on a list compiled by the U.S. Environmental Protection Agency to provide a focus for state and local emergency planning activities.
Facepiece The component(s) of a SCBA that covers, at a minimum, the wearer's nose, mouth, and eyes; also known as a facemask. Faceshield A transparent shield on the protective helmet that provides protection for the face and supplements primary eye protection. Facilities unit In ICS, a functional unit within the support branch of the logistics section that provides fixed facilities for the incident; these facilities may include the incident base, feeding areas, sleeping areas, and sanitary facilities.
363
False negative Incorrect test result indicating that no antibodies or diseases are present when they are in fact present. False positive Incorrect test result indicating that antibodies or diseases are present when they are in fact not present. Fan sweep A semicircular variation of a circular search pattern; shore- or boatbased; surface-directed for down-current search use. Fault tree analysis One of several methods of hazard analysis, which involves deductive description of events leading from the failure of one or more components to a hazardous situation. Federal response plan In the United States, a Federal plan that is activated when the state's resources are not sufficient to cope with a disaster and the governor has requested federal assistance. Finance/administration section In ICS, the section responsible for all incident costs and financial considerations; includes the time unit, procurement unit, compensation/claims unit, and cost unit. Fire point The lowest temperature at which a material can evolve vapors fast enough to support continuous combustion.
First-degree burn A mild burn characterized by pain and reddening of the skin. First responder Person(s) who arrives first on the scene at emergency incidents and has the responsibility to act; includes fire, police, EMS, and other public safety workers. Flame resistance The property of a material to prevent, terminate, or inhibit combustion following application of a flaming or nonflaming source of ignition, with or without subsequent removal of the
364 ignition source; flame resistance can be an inherent property of the material, or it may be imparted by specific treatment.
Flammable Any material that burns when subjected to a temperature less than 100~ Flash fire The combustion of a flammable vapor in which the flame front travels at less than sonic velocity, resulting in a negligible blast wave.
Flash point The lowest temperature at which the vapor of a substance will burn or explode; not to be confused with ignition temperature.
Flood warning Condition of alert that flooding is already occurring or will soon occur; precautions should be taken immediately; preparations should be made to move to higher ground. Flood watch Condition of alert that flooding is possible. Flue gas The air coming out of a chimney after combustion in the burner it is venting. Fluid resistant clothing Clothing designed and constructed to provide a barrier against accidental contact with body fluids. FOSC Federal on-scene commander. FRP see Federal response plan. FSSA Firefighter Safety Study Act (U.S.). Fuel t e n d e r Any vehicle capable of supplying fuel to ground or airborne equipment. Fugitive emission Any emission of dust, vapor, mist, or gas that is not prevented by a capture system. Full-scale exercise A training exercise in which a real-life emergency situation is
Appendix A simulated as closely as possible; involves company emergency response personnel, employees, management, and community response organizations. Function In ICS, function refers to the five major activities, i.e., command, operations, planning, logistics, and finance/ administration; also used when describing the activity involved, e.g., the planning function. Functional drill A training exercise involving an intensive practicum on specific emergency response functions, such as medical response, emergency notification, warning and communications procedures, and equipment; personnel are generally asked to evaluate the protocols and procedures tested during the drill and to identify any problem areas.
Fungus A group of microorganisms that includes molds and yeasts; some fungi are pathogenic.
G G A Nerve agent tabun.
Gamma radiation High-energy ionizing radiation (X ray) that travels at the speed of light and has great penetrating power; can cause skin burns, severely injure internal organs, and have long-term physiological effects. Gastric lavage The washing out or irrigation of the stomach with innocuous fluids by means of a gastric tube. GB Nerve agent Sarin. G D Nerve agent soman. GEDAPER Acronym used to describe steps in the analysis of an incident: gathering information; estimating course and harm; determining strategic goals;
365
Glossary assessing tactical options and resource; planning and implementing actions; evaluating; and reviewing.
H
General exhaust Removal of contami-
method involving the removal of halogen atoms (e.g., chlorine, bromine, iodine) from a contaminant molecule, thus reducing the hazard associated with the contaminant.
nated air from a large area by use of an air circulation or exchange system.
General staff In ICS, the group of incident management personnel reporting to the incident commander, including operations section chief, planning section chief, logistics section chief, and finance/ administration section chief.
Generic ICS The description of a ICS management system that is generally applicable to any kind of incident or event.
Geographic information system Any satellite-mediated information system that provides the user with specific on-theground location data.
German measles see Rubella. GF Fluoride-containing, organophosphate nerve agent. GIS see Geographic information system.
Gonorrhea A sexually transmitted disease cased by the bacterium Nesisseria gonorrhea. Ground support unit In ICS, the functional unit within the support branch of the logistics section responsible for the fueling, maintaining, and repairing of vehicles, and the transportation of personnel and supplies.
Group In ICS, groups are established to divide the incident into functional areas of operation; composed of resources assembled to perform a special function not necessarily within a single geographic divisions; located between branches (when activated) and resources in the operations section.
Halogen stripping A decontamination
Hanta disease Viral infection due to any member of the genus Hantavirus; transmitted by rodents; characterized by flu-like symptoms and, in more severe cases, shock, kidney failure, internal bleeding, fluid accumulation in the lungs, and death. Hazard The potential harm or injury that may be associated with any material or situation; also defined by various governmental agencies (e.g., OSHA, USDOT) in terms of "hazard classes" or "hazard categories" (e.g., flammable, carcinogen). Hazard analysis Identification of individual hazards of a system, determination of the mechanisms by which they could give rise to undesirable events, and evaluation of the consequences of those events.
Hazard and operability study One of several methods of hazard analysis carried out by application of guide words to engineering and instrument drawings to identify all deviations from design intent with undesirable effects for safety or operability, with the aim of identifying potential hazards. Hazard class The category used to describe the type of physical or health hazard of a chemical (e.g., flammable, mutagen); various regulatory agencies have adopted hazard classes of particular usefulness within their jurisdictional authority.
366 H A Z O P see Hazard and operability study. H A Z W O P E R U.S. OSHA safety standard for hazardous waste operations and emergency response (29 CFR 1910.120). HBIG see Hepatitis B Immune Globulin. H B V see Hepatitis B. HCS
Hazard communication standard; U.S. OSHA regulated standard under 29 CFR 1910.1200. H C V see Hepatitis C. H D Blister agent distilled mustard. H D V see Hepatitis D. Health hazard Any property of a material or substance that either directly or indirectly can cause injury or incapacitation, either temporary or permanent, from exposure by contact, inhalation, or ingestion. Health care w o r k e r An employee of a health care facility including, but not limited to, nurses, physicians, dentists, and other dental workers, optometrists, podiatrists, chiropractors, laboratory and blood bank technologists and technicians, research laboratory scientists, phlebotomists, dialysis personnel, paramedics, emergency medical technicians, medical examiners, morticians, housekeepers, laundry workers, and others whose work may involve direct contact with body fluids from living individuals or corpses; this definition includes fire fighters, due to potential for direct contact with body fluids during fire fighting, rescue, extrication, and other emergency response activities. Health database A compilation of records and data relating to the health experience of a group of individuals,
Appendix A maintained in a manner such that it is retrievable for study and analysis over a period of time. Health p r o m o t i o n Preventive health activities that identify real and potential risks in the workplace, and that inform, motivate, and otherwise help people to adopt and maintain healthy practices and lifestyles. Heat cramps Relatively early phase of heat stress caused by profuse sweating with inadequate replacement of electrolytes; characterized by muscle spasms and pain in hands, feet, and abdomen. Heat exhaustion Condition of severe dehydration and stress on body organs due to heat-induced cardiovascular insufficiency; characterized by pale, cool, moist skin, heavy sweating, dizziness, nausea, and fainting spells Heat resistance The capacity of a material to retain useful properties as measured during exposure of the material to a specified temperature and environment for a specified time. Heat stroke Advanced state of heat stress that requires immediate medical attention due to failure of body's system of temperature regulation; characterized by red, hot, dry skin, lack of or reduced perspiration, nausea, dizziness or confusion, strong, rapid pulse, coma. Helibase In ICS, the main location for parking, fueling, maintenance, and loading of helicopters operating in support of an incident; usually located at or near the incident base. Helicopter tender A ground service vehicle capable of supplying fuel and support equipment to helicopters. Helispot Any designated location where a helicopter can safely take off and land.
367
Glossary Some helispots may be used for loading of supplies, equipment, or personnel. Helitack The initial attack phase of fire suppression using helicopters and trained airborne teams to achieve immediate control of wildfires.
Helitanker A helicopter equipped with a fixed tank or a suspended bucket type container that is used for aerial delivery of water or retardants.
Helper/suppressor T-cells White blood cells that are part of the immune system. Hemorrhagic fever Type of fever characterized by profuse bleeding from internal organs and rapid wasting and death; caused by variety of viruses (e.g., Ebola virus, Marburg virus). Hepatitis Inflammation or swelling of the liver; can be caused by certain drugs, toxins, or infectious agents, including viruses; hepatitis caused by viruses includes hepatitis A, B, and D, and non-A non-B. Non-A non-B hepatitis includes hepatitis C, hepatitis E, and other, as yet unclassified types of hepatitis.
Hepatitis A Infectious hepatitis; a viral form of hepatitis normally spread by fecal contamination and generally not a significant risk for emergency care providers. Hepatitis B HBV; Serum hepatitis; a viral form of hepatitis spread through blood contact, and also as a sexually transmitted disease; a significant risk for emergency care workers; infection may result in death, chronic hepatitis, liver cancer, or cirrhosis of the liver; vaccine to prevent spread of hepatitis B is available. Hepatitis B immune globulin A preparation that provides some temporary
protection following exposure to HBV if given within 7 days after exposure.
Hepatitis C HCV; a recently identified viral form of hepatitis spread via blood contact. Hepatitis D HDV; delta hepatitis; a viral infection occurring in people with present or past HBV infection; delta hepatitis is a complication of HBV infection and can increase the severity of HBV infection.
Hepatitis, non-A non-B NANB; viral hepatitis caused by a virus other than hepatitis A or B; there are probably several viruses included under this name. NANB hepatitis is a bloodborne infection; the cause of 90% of posttransfusion hepatitis cases. Herpes A family of similar viruses, which can cause different diseases, including chicken pox, zoster, "cold sores," and genital herpes type II. Herpes zoster A painful skin rash caused by recurrence of a past case of chicken pox; herpes zoster is not typically spread person-to-person; however, persons who have not had chicken pox previously can contract chicken pox after exposure to a patient with zoster. H e r t z Unit of measurement used to express frequency; numerically equal to cycles per second (cps). H I V see Human immunodeficiency virus.
HIV antibody screening test A blood test that reveals the presence of antibodies to HIV. HIV antibody positive A test result indicating that HIV antibodies are present_ H I V antigen positive A result of antigen testing where it has been found that HIV is present; antigen testing can be useful in
368 predicting the progression of HIV infection and monitoring treatment. H M T A Hazardous Materials Transportation Act (U.S.). H M T U S A Hazardous Materials Transportation Uniform Safety Act (U.S.).
Host A person that can harbor or nourish a disease-producing organism; the host is said to be infected; the host is a "carrier." Hot tap A procedure that involves welding on a piece of equipment. Hot w o r k Work involving electric or gas welding cutting, brazing, or similar flame-, spark-, or heat-producing operations. H I ~ , see Human reliability analysis. H T L V Human T-cell lymphotropic virus, the former name for the AIDS virus; now called human immunodeficiency virus or HIV.
Human immunodeficiencyvirus HIV; the causative agent of AIDS; HIV type I (HIV- I) causes most cases of aids; a second virus, HIV-2, is a less common cause of the disease. Human reliability analysis A systematic evaluation of the factors that influence the performance of personnel; uses one of several types of task analyses and produces a systematic listing of the errors likely to be encountered during normal or emergency operations, a list of factors contributing to such errors, and proposed modifications to reduce the likelihood of such errors.
Human tissue burn tolerance In testing thermal protective clothing, the capacity to withstand the amount of thermal energy that causes a second degree burn in human tissue.
Appendix A
Hurricane warning Condition of alert that a hurricane will hit land within 24 hours; immediate precautions should be taken. Hurricane watch Condition of alert that a hurricane is possible within 24 to 36 hours. Hypersensitivity A phenomenon in which an individual demonstrates an abnormally high sensitivity to chemical exposure when compared with the median sensitivity of the population; hypersensitive individuals react to very small doses of the chemical. Hyposensitivity A phenomenon in which an individual demonstrates an abnormally low sensitivity to chemical exposure when compared with the median sensitivity of the population; hyposensitive individuals react only to very large doses of the chemical.
IARC International Agency for Research on Cancer.
latrogenic Caused by the doctor; a complication, injury, or disease state resulting from medical treatment. iC p r o g r a m see Infection control program. ICP see Incident command post; integrated contingency plan. I D L H see Immediately dangerous to life and health. Ignitable Capable of burning.
Ignition temperature The lowest temperature at which a substance will burn.
Glossary
Immediately dangerous to life and health The maximum level at which a healthy individual can be exposed to a chemical for 30 minutes and escape without suffering irreversible health effects or impairing systems.
Imminent hazard An act or condition that is judged to present a danger to persons or property that is so urgent and severe that it requires immediate corrective or preventive action. Immune status The state of the body's immune system; factors affecting immune status include heredity, age, diet, and physical and mental health. Immunization The process of rendering a person immune or highly resistant to a disease. Immunosuppressed A condition or state of the body in which the immune system does not work normally.
Incendiary device Any mechanical, electrical, or chemical device used intentionally to start a fire. Incident An occurrence (caused by either human or natural phenomena) that requires action by emergency service personnel to prevent or minimize loss of life or damage to property and/or natural resou rces. Incident action plan Contains objectives reflecting the overall incident strategy and specific tactical actions and supporting information for the next operational period of emergency response; plan may be oral or written; when written, the plan may have a number of forms as attachments (e.g., traffic plan, safety plan, communications plan). Incident area In ICS, geographical area of the incident, including effect area and
369 traffic route to corresponding storage and disposal sites.
Incident base In ICS, location at the incident where the primary logistics functions are coordinated and administered; there is only one base per incident.
Incident command post In ICS, the location at which the primary command functions are executed; may be collocated with the incident base or other incident facilities. Incident command system see Incident management system.
Incident commander In ICS, the person responsible for the overall coordination and direction of all activities at the incident scene. Incident communications center In ICS, the location of the communications unit and the message center at the incident site.
Incident management system An organized system of roles, responsibilities, and standard operating procedures used to manage emergency operations; often referred to as incident command system or ICS. Incident management team In ICS, the incident commander and appropriate command and general staff personnel assigned to an incident. Incident objectives Statements of guidance and direction necessary for the selection of appropriate strategy(s) and the tactical direction of resources; incident objectives are based on realistic expectations of what can be accomplished when all allocated resources have been effectively deployed; incident objectives must be achievable and measurable, yet flexible enough to allow for strategic and tactical alternatives.
370 Incubation period The time from exposure to a disease vector until the first appearance of symptoms. Indirect disease transmission
Appendix A
Infrared groundlink A capability through the use of a special mobile ground station to receive air-to-ground infrared imagery at an incident.
Transmission of a communicable disease from one person to another without direct contact.
Initial actions The actions taken by personnel who are the first to arrive at an incident.
Infection control officer A person
Initial attack see Initial actions and Initial response.
assigned specific responsibility for infection control practices, including immunizations and postexposure follow-up protocols.
Infection control practitioner A medical professional with a specialty interest in infection control. Infection control program IC Program; an oral or written policy and implementation of procedures related to the control of infection disease hazards where employees may be exposed to direct contact with body fluids. Infectious Capable of causing infection in a suitable host. Infectious disease An illness or disease resulting from invasion of a host by diseaseproducing organisms such as bacteria, viruses, fungi, or parasites.
Infectious waste Blood and blood products, pathological wastes, microbiological wastes, and contaminated sharps. Information officer In ICS, the member of the command staff responsible for interfacing with the public and media or with other agencies requiring information directly from the incident; there is only one information officer per incident.
Infrared In fire fighting, a heat detection system used for fire detection, mapping, and identification of hot spots.
Initial response Resources (personnel, materials, and equipment) initially committed to an incident.
Integrated contingency plan An emergency response plan designed in conformance with technical guidelines provided by the U.S. National Response Team to consolidate multiple plans developed by facilities in compliance with various U.S. regulations, including those pursuant to the Oil Pollution Act of 1990. Interface area An area of the body not protected by a protective garment, helmet, gloves, footwear, or SCBA facepiece; the area where the protective garment and the helmet, gloves, footwear, or SCBA facepiece meet. Interface component Item(s) designed to provide limited protection to interface area. Intravenous drugs Drugs injected by needle directly into a vein.
Intubation The introduction of a tube into a hollow organ (e.g., trachea). IR see Infrared. I r r i t a n t Any noncorrosive material that causes itching, soreness, or inflammation of exposed skink, eyes, or mucous membranes. I r r i t a t i n g agent A chemical agent (also known as control agent or tear gas) that
371
Glossary causes respiratory distress and tearing designed to incapacitate (e.g., chloropicrin, MACE, tear gas, pepper spray, dibenzoxazepine). ISO International Standards Organization.
Jet fire An ignited pressurized release of gases and/or liquids.
Joint advisory notice A list of recommendations developed to assist employers in implementing Centers for Disease Control (CDC) guidelines.
Jurisdictional agency The agency having jurisdiction and responsibility for a specific geographical area or for a mandated function.
50% of the population (or the ambient concentration that presents an individual with a 0.5 probability of dying). Leader The ICS title for an individual responsible for a task force, strike team, or functional unit.
Leakproof bag A bag designed for disposal of potentially infectious substances, color coded and labeled in accordance with applicable laws. LDs0 Lethal dose of a toxic chemical for 50% of the population (or the dose that presents an individual with a 0.5 probability of dying). LEPC Local emergency planning commission established by the U.S. Emergency Planning and Community Right-to-Know Act. LEPD Local emergency planning district.
L Blister agent lewisite.
Ladder shank Reinforcement to the shank area of protective footwear designed to provide additional support to the instep when the wearer is standing on a ladder rung.
Lassa fever Often fatal viral disease endemic to West Africa; characterized by high fever, headache, ulcers of the mucous membranes, and disturbances of the gastrointestinal tract. Latency A period when a virus is in the body but is inactive. LAV see Lymphadenopathy-associated virus. LCs0 Lethal concentration of a toxic chemical (in ambient air or water) for
Liaison officer In ICS, member of the command staff responsible for coordinating with representatives from cooperating and assisting agencies. Linear pattern Straight line search pattern in area of probability when datum point is not known. Line rescue Water rescue using water rescue line, rescue skin diver, and line tender. Line signal Communication between diver and tender on search line by means of pulls. Line t e n d e r Person who directs search from shore via search line or pulis rescuer and victim to shore in surface rescue by means of water rescue line.
Local exhaust A system for capturing and removing airborne contaminants at the point at which they are produced.
Appendix A
372
Logistics section In ICS, the section responsible for providing facilities, services, and materials for the incident.
specific managerial responsibilities, e.g., staging area manager or camp manager.
Lower explosive limit The
trative control).
concentration of a gas or vapor in air below which a flame will not propagate if the mixture contacts an ignition source.
Lymphadenopathy-associated virus An early name for the virus that causes AIDS; now called human immunodeficiency virus (HIV). L y m p h o m a Cancer of the lymph nodes or lymph tissues.
M MAC see Multiagency coordination. MACS see Multiagency coordination system.
Management-by-objective In ICS, this is a top-down management activity that involves a three-step process to achieve the incident goal: establishing the incident objectives, selection of appropriate strategy(s) to achieve the objective, and the tactical direction associated with the selected strategy. Tactical direction includes: selection of tactics, selection of resources, resource assignments, and performance monitoring.
Management control (see AdminisM A P see Member assistance program.
Material safety data sheet A chemically specific compendium of health and safety information and data. In the United States, OSHA requires industrial users of chemicals to obtain MSDSs from chemical manufacturers or importers; MSDSs also used to fulfill part of the hazardous chemical inventory reporting requirements under the Emergency Planning and Community Right-to-Know Act. M B O see Management-by-objective.
Measles A vaccine-preventable viral communicable disease causing a skin rash; usually occurs in childhood. Mechanical exhaust A powered device for exhausting contaminants from a workplace, vessel, or enclosure (e.g., motor-driven fan, air/steam venturi tube). Medical unit In ICS, functional unit within the service branch of the logistics section responsible for the development of the medical emergency plan, and for providing emergency medical treatment of incident personnel.
identify and review all modifications of process equipment, procedures, raw materials, and processing conditions (other than replacement-in-kind) prior to implementing a change in order to minimize the possibility of a hazardous consequence of that change.
Member assistance program A program designed to provide assistance to employees regarding personal problems (including drug and alcohol abuse) that may interfere with on-the-job performance; may also be used to provide training to employees and their families on healthrelated issues; sometimes known as an "employee assistance program."
Manager Individual within ICS organizational units that are assigned
Meningitis An infection of the meninges, the covering layers of the brain and spinal
Management of change A program to
Glossary cord; may be caused by a bacterium or virus; considered a communicable disease.
Message center In ICS, the message center is part of the incident communications center and is collocated or placed adjacent to it; receives, records, and routes information about resources reporting to the incident, resource status, and administrative and tactical traffic. Mobilization The process and procedures used by all organizations for activating, assembling, and transporting all resources that have been requested to respond to or support an incident. Mobilization center In ICS, an offincident location at which emergency service personnel and equipment are temporarily located pending assignment, release, or reassignment. M M W R see Morbidity and mortality weekly report.
Morbidity and mortality weekly report A weekly publication from the U.S. Centers for Disease Control presenting up-to-date information on communicable diseases.
Motion detector An integral portion of the personal alarm safety system (PASS) that senses movement, or alternatively, lack of movement, and activates the alarm signal under a specified sequence of events. MSDS see Material safety data sheet. M S H A Mine Safety and Health Administration of the U.S. Department of Labor.
Mucous membrane The lining of the nose, mouth, eyes, vagina, and rectum; mucous membranes are not as durable as other skin; contact of infected body fluids with intact mucous membranes may transmit disease.
373
Multiagency coordination A generalized term that describes the functions and activities of representatives of involved agencies and/or jurisdictions who come together to make decisions regarding the prioritizing of incidents and the sharing and use of critical resources. The MAC organization is not a part of the on-scene ICS and is not involved in developing incident strategy or tactics.
Multiagency coordination system The combination of personnel, facilities, equipment, procedures, and communications integrated into a common system. When activated, the MACS has the responsibility for coordination of assisting agency resources and support in a multiagency or multijurisdictional environment. A MAC Group functions within the MACS.
Multiagency incident An incident where one or more agencies assist a jurisdictional agency or agencies; may be single or unified command. Multijurisdiction incident An incident requiring action from multiple agencies that have a statutory responsibility for incident mitigation. In ICS, these incidents will be managed under unified command.
Mutual aid agreement Written agreement between agencies and/or jurisdictions in which they agree to assist one another upon request by furnishing personnel and/or equipment. Mumps A vaccine-preventable communicable disease caused by a virus; usually occurring in children; may cause serious complication in adult cases. Musculoskeletal Pertainingto muscles, bones, and joints.
Mutagen Any material that causes changes in genetic information that is inherited from generation to generation.
374 Myositis Inflammation of a muscle caused by heavy use or repeated use of a muscle with inadequate time for recovery.
Appendix A supporter of ICS development and training. Needlestick A parenteral exposure with a needle contaminated from patient use.
N NAERG Acronym for the North American Emergency Response Guidebook. N A N B Hepatitis see Hepatitis, non-A non-B.
National interagency incident management system An NWCGdeveloped program consisting of five major subsystems that collectively provide a total systems approach to all-risk incident management. The subsystems are: the incident command system, training, qualifications and certification, supporting technologies, and publications management. National response center The central U.S. clearinghouse for information involving emergency spills and other releases of oil and hazardous substances. National response team A consortium of 14 U.S. Federal agencies devoted to preparing for and responding to significant releases of oil and hazardous substances to the environment; maintains and operates the National Response Center for receiving reports of releases of oil and hazardous substances. National wildfire coordinating group A group formed under the direction of the Secretaries of the U.S. Departments of the Interior and Agriculture to improve the coordination and effectiveness of wildland fire activities, and provide a forum to discuss, recommend appropriate action, or resolve issues and problems of substantive nature. The NWCG has been a primary
Nerve agent A substance that interferes with the central nervous system (e.g., Sarin, Soman, tabun, and VX agent); exposure is primarily through contact with the liquid and, secondarily, through inhalation of the vapor; three distinct symptoms associated with nerve agents are pinpoint pupils, extreme headache, and severe tightness in the chest.
Neutralization A decontamination process involving the addition of acids or bases to a contaminant in order to lessen its corrosive nature. NFIRS National fire incident reporting system. NFPA National Fire Protection Association. NIIMS see National interagency incident management system. NIOSH National Institute for Occupational Safety and Health (U.S. government). N I O S H I M S H A Certified Tested and certified jointly by the National Institute for Occupational Safety and health (NIOSH) of the U.S. Department of Health and Human Services and the Mine Safety and Health Administration (MSHA) of the U.S. Department of Labor.
N I T R O X Oxygen-enriched gas mixture as defined by NOAA standards for increased physiological or time advantage in dive operations deeper than 50 fsw. N O A A National Oceanic and Atmospheric Administration (U.S.).
375
Glossary N O A A weather station A mobile weather data collection and forecasting facility (including personnel) provided by the National Oceanic and Atmospheric Administration that can be utilized within the incident area.
incidental exposures that may take place on the job, that are neither reasonably nor routinely expected and that the worker is not required to incur in the normal course of employment.
N.O.S. Not otherwise specified (used extensively in U.S. Department of Transportation regulations pursuant to Hazardous Materials Transportation Act).
disease contracted through or aggravated by the performance of job-related duties.
Nosoacusis Hearing loss caused by medical abnormalities (e.g., hereditary progressive deafness; diseases such as mumps, rubella, Meniere's disease; ototoxic drugs and chemicals; blows to the head).
Nosocornial Originating in the hospital; a disease spread by contact with the healthcare system.
Notification (procedure) Inclusive of
Occupational illness An illness or
Odor threshold The lowest concentration of a substance's vapor that can be smelled; high variable, depending on the individual's sensitivity. O E C D see Organization for Economic Cooperation and Development. Officer The ICS title for the personnel responsible for the command staff positions of safety, liaison, and information.
Olfactory Relating to the sense of smell.
all procedures designed to inform all responsible persons in the event of a potential or actual incident, and to provide those persons with information required for their proper performance of emergency-related functions.
Open-circuit S C B A SCBA in which
NRC see National response center.
Operational period In ICS, the period
NRT see National response team. N W C G see National wildfire coordinating group.
of time scheduled for execution of a given set of operational actions as specified in the incident action plan; operational periods can be of various lengths, although usually not over 24 hours.
O
Operations section In ICS, the section
O C C see Operations coordination center.
responsible for all tactical operations at the incident; includes branches, divisions and/ or groups, task forces, strike teams, single resources, and staging areas.
Occupational exposure Reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties; this definition excludes
exhalation is vented to the atmosphere and not rebreathed. There are two types of open-circuit SCBA: negative pressure (or demand type), and positive pressure (or pressure demand type).
Operations coordination center The primary facility of the multiagency coordination system housing the staff and equipment necessary to perform MACS functions.
376 Opportunistic infection Infection that
Appendix A
usually is warded off by a healthy immune system.
subject to DOT regulations, presents a limited hazard during transportation due to its form, quantity, and packaging.
Oral Relating to the mouth.
Orthophoto map Aerial photograph
Organic peroxide Any material that
corrected to scale such that geographic measurements may be taken directly from the print; may contain graphically emphasized geographic features and may be provided with overlays of such features as water systems and important facility locations.
spontaneously explodes due to the formation of unstable peroxides.
Organization for Economic Cooperation and Development An intergovernmental organization in which 24 industrialized countries from North America, Western Europe, and the Pacific meet to compare, coordinate, and, where appropriate, harmonize national policies, discuss issues of mutual concern, and work together to respond to problems with international dimensions. O R M Otherwise regulated material; acronym used by U.S. DOT in regulations pursuant to the Hazardous Materials Transportation Act. O R M - A U.S. DOT classification applied to a material that has an anesthetic, irritating, noxious, toxic, or other similar property and that can cause extreme annoyance or discomfort to passengers and crew in the even of leakage during transportation. O R M - B U.S. DOT classification applied to a material (including a solid when wet with water) capable of causing significant damage to a transport vehicle or vessel by leaking during transportation. O R M - C U.S. DOT classification applied to a material that has other inherent characteristics not described by ORM-A or ORM-B classes, but that make it unsuitable for shipment unless properly identified and prepared for transportation. O R M - D U.S. DOT classification applied to a material such as a consumer commodity which, though otherwise
O S H A U.S. Occupational Safety and Health Administration (in Department of Labor).
Ototoxins Any chemical agent that may cause damage to or cause a decrease in hearing ability.
Out-of-service resources Resources assigned to an incident but unable to respond for mechanical, rest, or personnel reasons. Overhead personnel In ICS, personnel who are assigned to supervisory positions, which include incident commander, command staff, general staff, directors, supervisors, and unit leaders. Oxidation The removal of electrons (or hydrogen) from a molecule, with consequent transformation of that molecule into another chemical type; a type of chemical process that can be used in certain types of chemical detoxification. O x i d i z e r Any material that promotes or initiates the burning of combustible or flammable materials.
Parenteral Through the skin barrier, as in a parenteral exposure, which is an exposure that occurs through a break in
377
Glossary the skin barrier (e.g., injections, needle sticks, human bites, and cuts contaminated with blood).
PASS Personal alert safety system. Pathogen A microorganism that can cause disease, including bacterial, fungal, parasitic, or viral pathogens. Pathogenic Capable of causing disease. Patrol unit In fire fighting, any light, mobile unit having limited pumping and water capacity. PCP see Pneumocystis pneumonia. PDD-39 see Presidential decision directive 39. PEL see Permissible exposure limit.
Percutaneous Entering the body through the skin (e.g., by needlestick or through broken skin). Pericardial fluid A clear fluid contained in the thin membranous sac that surrounds the heart. Peritoneal fluid Fluid contained in the membrane lining of the abdominal cavity. Permanent threshold shift A permanent hearing impairment as determined by comparing a baseline audiogram with subsequent audiograms.
Permissible exposure l i m i t In the United States, a legally enforceable maximum airborne exposure limit for a specific chemical.
Personal Protective Equipment Specialized clothing or equipment worn by an employee for protection from a hazard; general work clothes not intended to function as protection against a specific hazard are not consider to be personal protective equipment.
PFD Personal floatation device (U.S. Coast Guard approved, Class III).
Phlebotomist Any health-care worker who draws blood samples. PIH Poison inhalation hazard.
Planning meeting In ICS, a meeting held as needed throughout the duration of an incident to select specific strategies and tactics for incident control operations, and for service and support planning. On larger incidents, the planning meeting is a major element in the development of the incident action plan. Planning section In ICS, responsible for the collection, evaluation, and dissemination of tactical information related to the incident, and for the preparation and documentation of incident action plans. The section also maintains information on the current and forecasted situation, and on the status of resources assigned to the incident; includes the situation, resource, documentation, and demobilization units, as well as technical specialists. Plan of action A written document that consolidates all of the operational actions to be taken by various personnel in order to stabilize an incident.
Pleurai fluid Fluid contained in the membrane that covers the lung and lines the chest cavity. Plume A visible or measurable discharge of a contaminant to air, water, and/or soil from a given point of origin.
Polymerization A chemical reaction that forms a compound (polymer) from the bonding together of the molecules of a particular chemical. Pneumocystis pneumonia PCP; a type of pneumonia caused by a parasite; seen in patients with impaired immune systems.
378 Poison Any material that causes lifethreatening damage to tissues or internal organs in very small amounts (e.g., several teaspoons or less). Poison, Class A U.S. DOT classification applied to an extremely dangerous poison. Poison, Class B U.S. DOT classification applied to any non-Class A poison that nonetheless presents a hazard to health during transportation. Polio Poliomyelitis; a vaccine-preventable viral disease not commonly seen in the United States.
Polymerization A chemical process in which many molecules of the same type (called monomers) are joined together in long chains; used in certain types of chemical detoxification. Positive pressure SCBA SCBA in which the pressure inside the facepiece, in relation to the pressure surrounding the outside of the facepiece, is positive during both inhalation and exhalation. Post-traumatic stress syndrome Persistent and profound state of psychological dysfunction attributed to previously experienced traumatic stress.
Appendix A capabilities to prevent and manage the consequences of the terrorist use of nuclear, biological, and chemical weapons; provisions of PDD-39 that affect the FRP are included in the FRP Terrorism Incident Annex.
Pressure demand S C B A see Positive pressure SCBA.
Process safety information A compilation of written information that describes safety-related attributes of chemical substances, the processes in which they are used, and the equipment used for those processes.
Procurement unit In ICS, a functional unit within the finance/administration section responsible for financial matters involving vendor contracts.
Prophylaxis Any substance, material, or steps taken to prevent something from happening (e.g., condoms, vaccines). P r o x i m i t y clothing Reflective protective clothing that is designed to provide protection against conductive, convective, and radiant heat.
PTS see Permanent threshold shift.
PPD see Purified protein derivative.
Purified protein derivative A skin test
PPE see Personal protective equipment.
for exposure to tuberculosis.
ppb Parts per billion.
Pyrolysis The breaking apart of a complex molecule into a simpler molecule by the use of heat.
ppm Parts per million. Presbycusis Natural hearing loss associated with aging. Presidential decision directive
Pyrophoric Any material that ignites spontaneously in air at temperatures of 130~ or lower.
39 Issued in June 1995, this directive (United States Policy on Counterterrorism) directs a number of measures to reduce the nation's vulnerability to terrorism, to deter and respond to terrorist acts, and to strengthen
Pyrotechnics Any combustible or explosive compositions or manufactured articles designed and prepared for the purpose of producing audible or visible effects (i.e., fireworks).
Glossary
Q Q Fever Infectious disease caused by Coxiella burnetJi rickettsia; characterized by fever, general malaise, and muscular pains.
Quayside search A semicircular, surfacedirected search pattern conducted alongside a quay or dock.
379 process that can be used in certain types of chemical detoxification.
Reinforced attack see Reinforced response. Reinforced response Those resources requested in addition to the initial response. Reporting locations Location or facilities where incoming resources can check-in at the incident.
Radiant heat Heat that is emitted by one material and absorbed by another over a distance. Radio cache A supply of radios stored in a predetermined location for assignment to incidents; used to disperse radioactive particles over an extensive area. Radiological dispersal device Any conventional explosive that incorporates nuclear materials. RAM Radioactive materials. Rated service time The period of time that SCBA supplies air to the breathing machine when tested according to the requirements of 30 CFR I I; recorded on the SCBA's certification label. Recombinant vaccine A vaccine produced by genetic manipulation (gene splicing). Recorders Individuals within ICS organizational units who are responsible for recording information; may be found in planning, logistics, and finance/ administration units. RDD see Radiological dispersal device.
Reduction The addition of electrons (or hydrogen) to a molecule, with consequent transformation of that molecule into another chemical type; a type of chemical
Regional response team Any of 13 regional teams designated by the U.S. national response team to provide planning, policy, and coordination assistance to incident response organizations. Reportable quantity An amount of a hazardous chemical that, if released to the environment, must be reported (in the United States) in compliance with the Emergency Planning and Community RightTo-Know Act, the Hazardous Materials Transportation Act (HMTA), and/or the Comprehensive Emergency Response, Compensation and Liability Act (CERCLA).
Rescue incident An emergency incident that primarily involves the rescue of persons subject to physical danger, and may include the provision of emergency medical services. Residual risk The risk still remaining after the implementation of risk management practices. Resources Personnel and equipment available or potentially available for assignment to incidents. Resources are described by kind and type (e.g., ground, water, air) and may be used in tactical support or overhead capacities at an incident. Resources unit In ICS, functional unit within the planning section responsible for
38O
Appendix A
recording the status of resources committed to the incidenr~ also evaluates resources currently committed to the incident, the impact that additional responding resources will have on the incident, and anticipated resource needs.
contact with the body (includes inhalation, ingestion, skin or eye contact, absorption, and puncture).
RESTAT An acronym for "resources status"; in ICS, used in reference to a unit within the Planning Section responsible for tracking resources assigned to an incident.
RRT see Regional response team.
Retroreflective Descriptive of a material that reflects and returns a relatively high proportion of light in a direction close to the direction from which it came. Ricin Mixture of poisonous proteins produced by the castor oil plant; plant gene controlling the production of ricin has been successfully transferred to the bacterium Escherichia coli; ricin interferes with the body's normal synthesis of proteins; symptoms include decreased blood pressure, with death occurring most often through heart failure. Risk The probability that an individual (or group) will actually experience a hazard; usually expressed as a decimal between 0.0 and 1.0, with values approaching !.0 denoting increasing risk. Risk assessment The value judgment of the significance of the risk, identified by a risk analysis taking into account relevant criteria. Risk m a n a g e m e n t Actions taken to achieve or improve the safety of an installation and its operation. Root cause analysis A technique of incident investigation that includes developing a chronology of events, listing deviations from normal conditions or circumstances, and possible causes based on these deviations. Route-of-entry The pathway that a chemical takes to enter or come into
RPR A blood test for syphilis. RQ see Reportable quantity.
RTECS The U.S. Registry of Toxic Effects of Chemical Substances.
Rubella A vaccine-preventable viral disease; rubella infection during pregnancy can cause birth defects.
Safety diver A back-up diver, geared up, on shore, and available to assist. Safety interlock system An automatic system that inhibits the operation of critical equipment until certain process parameters are within acceptable ranges. Safety officer In ICS, a member of the command staff responsible for monitoring and assessing safety hazards or unsafe situations, and for developing measures for ensuring personnel safety.
Salmonellosis Infection caused by intestinal bacteria of the genus Salmonella; characterized by nausea, abdominal pains, diarrhea, and fever; it can lead to death, especially in people with impaired immune systems. S A R A Superfund Amendments and Reauthorization Act (U.S.).
Sarcoma Cancer of the skin or other connective tissue. Saxitoxin Toxin produced by marine blue-green alga (i.e., cyanobacterium), which serves as food supply for various shellfish that are immune to effects of the
381
Glossary toxin, but pass it on to higher order consumers (e.g., humans); in humans, toxin acts on central nervous system to produce paralysis; at high doses, death can occur in less that 15 minutes. S C B A see Self-contained breathing apparatus.
Search line Water rescue line; 100 ft three-strand twisted I/4 -inch polypropylene with a monkey's fist at one end and 30-inch loop with snap at other end. Search pattern Logical means of
Self-contained breathing apparatus A respirator that supplies a respirable atmosphere that is either carried in or generated by the apparatus and is independent of the ambient environment.
Sensitizer A material that causes allergic reactions after repeated exposures, with possibly severe or even life-threatening consequences. SERC State emergency response commission established by the U.S. Emergency Planning and Community Right-To-Know Act.
covering a search area while maintaining diver accountability.
Seroconversion A change in the status of one's serum test.
SEB see Staphylococcus enterotoxin type B.
Serologic test Any number of tests that are performed on blood; usually refers to a test that measures antibodies to a virus.
Second-degree burn A burn that is more severe than a first-degree burn and typically characterized by blistering, reddening of the skin, swelling, and destruction of the superficial tissue.
Section In ICS, that organizational level with responsibility for a major functional area of the incident (e.g., operations, planning, logistics, finance/administration). The section is organizationally between branch and incident commander.
Seropositive A condition in which antibodies to a disease-causing agent are found in the blood; a positive reaction to a blood test; the presence of antibodies indicates that a person has been exposed to the agent.
Service branch In ICS, a branch within the logistics section responsible for service activities at the incident, including communications, medical, and food units.
Sector Term used in some applications to
Sexually transmitted disease A
describe an organizational level similar to an ICS division or group; sector is not a part of ICS terminology.
disease spread through sexual contact; HIV and HBV are both bloodborne and sexually transmitted diseases.
Segment In ICS, a geographical area in which a task force/strike team leader or supervisor of a single resource is assigned authority and responsibility for the coordination of resources and implementation of planned tactics. A segment may be a portion of a division or an area inside or outside the perimeter of an incident. Segments are identified with arabic numbers.
Sharps Any object that can penetrate the skin including, but not limited to, needles, lancets, scalpels, and broken capillary tubes. Shingles Common term for Herpes zoster infection, resulting in painful rash. Single resource In ICS, an individual, a piece of equipment and its personnel complement, or a crew or team of
382 individuals with an identified work supervisor that can be used on an incident. Site work zone A designated work area at a hazard waste site; may include one or more designated exclusion zones, contamination reduction zones, and support zones. SITSTAT An acronym for "situation status"; in ICS, used in reference to unit in the planning section responsible for keeping track of incident events.
Situation unit In ICS, functional unit within the planning section responsible for the collection, organization, and analysis of incident status information, and for analysis of the situation as it progresses; reports to the planning section chief. Smallpox Highly contagious, often fatal, viral disease; characterized y a high fever and successive stages of severe skin eruptions.
Sociocusis Hearing loss associated with everyday noises (e.g., lawn mowers, loud music, traffic).
Sound pressure level The measurement of loudness of sound in decibels.
Span-of-control The supervisory ratio of from three-to-seven individuals, with five-to-one being established (in ICS) as optimum.
Staging areas The locations set up at an incident where resources can be placed while awaiting a tactical assignment. Staging areas (in ICS) are managed by the operations section.
Standard threshold shift A change in hearing capacity (relative to baseline audiogram) of 10 dB or more at 2000, 3000, and 4000 Hz in either ear.
Staphylococcus enterotoxin type B Toxin produced by bacterium
Appendix A
Staphylococcus aureus; most commonly associated with food poisoning; characterized by stomach cramps, diarrhea, and vomiting. State EOP In the United States, State emergency operations plan; framework within which local EOPs are created and through which the federal government becomes involved.
Sterilization The use of a physical or chemical procedure to destroy all microbial life, including highly resistant bacterial endospores. STD see Sexually transmitted disease. STEL see TLV-STEL.
Strategic goals Broad, general statements of intent with respect to incident command. Strategy The general plan or direction selected to accomplish incident objectives. Strike t e a m In ICS, specified combinations of the same kind and type of resources, with common communications and a leader.
Subcutaneous Beneath the skin (e.g., subcutaneous injection).
Substance P A protein closely related to normally produced proteins in the body; may cause pain, act as anaesthetic, or affect blood pressure; rapid loss of blood pressure in victim may cause unconsciousness. Supervisor The ICS title for individuals responsible for command of a division or group.
Supply unit In ICS, functional unit within the support branch of the logistics section responsible for ordering equipment and supplies required for incident operations.
383
Glossary
Support branch In ICS, the branch within the logistics section responsible for providing personnel, equipment, and supplies to support incident operations; includes the supply, facilities, and ground support units. Support zone Uncontaminated area at hazardous waste site where response personnel should not be exposed to hazardous contamination.
Supporting materials In ICS, the several attachments that may be included with an incident action plan, e.g., communications plan, map, safety plan, traffic plan, and medical plan.
Support resources In ICS, nontactical resources under the supervision of the logistics, planning, finance/administration sections, or the command staff.
Surfactant A chemical added to reduce the force of adhesion between a contaminant and the surface to which the contaminant is attached by molecular forces; household detergents are common examples of surfactants. Suspect carcinogen A substance that might cause cancer in humans or animals but which has not been proven to do so.
T Table-top exercise Generally, a conference-based exercise in which members of the emergency management group discuss their responsibilities and how they would react to different emergency scenarios; may often involve the acting out of specific scenarios, with specific information about a hypothetical emergency being parceled out to the group in a scheduled manner; may also involve simulated computer-assisted data/ information processing as well as voice/ telephonic and radio communications.
Tactical direction In ICS, direction given by the operations section chief, which includes the tactics appropriate for the selected strategy, the selection and assignment of resources, tactics implementation, and performance monitoring for each operational period. Task analysis A method of evaluating components and task sequences of jobs to identify potential sources of error, performance inefficiencies, and safety hazards.
symptoms that occur together.
Task force In ICS, a combination of single resources assembled for a particular tactical need, with common communications and a leader.
Synergy A phenomenon in which two
TB see Tuberculosis.
Syndrome A collection of signs and
or more chemicals interact to produce an effect (e.g., toxicity, lethality)in a magnitude that is an unpredictable multiple of the individual magnitude of each chemical's solitary effect; synergistic interactions may involve other than chemicals; a general term denoting a multiplication of consequences as opposed to additive consequences. Syphilis A sexually transmitted infectious disease; commonly transmitted through blood exposure or transfusion.
TB bacteria Bacteria that cause tuberculosis.
Team see Single Resource. Technical specialists Personnel with special skills that can be used anywhere within the ICS organization.
Temporary flight restrictions Temporary airspace restrictions for nonemergency aircraft in the incident area; in the United States, TFRs are established
384 by the Federal Aviation Administration to ensure aircraft safety, and are normally limited to a 5-nautical-mile radius and 2000 feet altitude.
Temporary threshold shift A shortterm hearing impairment as determined by comparing the baseline audiogram with subsequent audiograms. Tendinitis Inflammation of a tendon, often caused by repetitive, forceful exertions involving rotations around a joint. Teratogen A material that causes malformation of the developing fetus. TFR see Temporary flight restrictions. T h e r m a l degradation A decontamination procedure in which heat is used to degrade or destroy the molecular structure of a contaminant.
Thermal shrinkage The change in dimensions of a fabric specimen when exposed to heat.
Third-degree burn The most serious type of burn, characterized by charring (blackening) of the skin and by skin necrosis (tissue death).
Threshold planning quantity The amount of an extremely hazardous substance present at a facility above which the facility must give emergency planning notification to the state emergency response commission and local emergency planning committee as required by the U.S. Emergency Planning and Community Right-To-Know Act. Threshold shift A short-term or permanent hearing impairment as determined by comparing a baseline audiogram with subsequent audiograms. TLV Threshold limit value; concentration limit for prolonged exposure to a particular hazardous chemical.
Appendix A TLV-C Threshold limit value-ceiling; concentration that should not be exceeded by exposure even instantaneously. TLV-STEL Threshold limit value-short term exposure; concentration that should not be exceeded by an exposure of 15 minutes. T L V - T ~ / A Threshold limit value-time weighted average; the time-weighted average concentration to which persons can be exposed for 8 hours per day (of a 40-hour workweek) without adverse effect.
Top event The culminating event of a fault tree from which basic causes are deduced to determine the cause and probability of the top event. Tornado warning Condition of alert that a tornado has been sighted in the area or is indicated by radar; should immediately take shelter. Tornado watch Condition of alert that a tornadoes are likely; prepare to take shelter.
Torpedo buoy Towable surface rescue float.
Torpedo buoy rescue Water rescue using a torpedo buoy and a rescue skin diver.
Toxic Any material that causes lifethreatening damage to tissues or internal organs, but in amounts greater than a poison (e.g., greater than several teaspoons).
Toxic release inventory A national (U.S.) inventory of annual toxic chemical releases from manufacturing facilities. T P Q see Threshold planning quantity. T R A C E M Acronym to identify six types of harm from terrorist incident: thermal,
Glossary
radioactive, asphyxiation, chemical, etiological, and mechanical.
Transfrontier damage Any damage to human health o r the environment. includingproperty, in the event of an accident suffered by a country other than the country where the accident originated. Traveler’s advisory Condition of alert that conditions may make driving difficult o r dangerous. TRI see Toxic release inventory. T T S see Temporary threshold shift. Tuberculocidal Capable of killing tuberculosis (TB) bacteria. Tuberculosis A communicable disease caused by the bacterium Mycobacterium tuberculosis; usually affecting the lungs. Tularemia Infectious disease caused by Francisella tularensis bacterium; chiefly affects rodents but can also be transmitted t o human beings by bite of various insects or contact with infectedanimals; characterized by intermittent fever and swelling of the lymph nodes.
TWA see TLV-TWA. Type In ICS, refers t o resource capability. A type I resource provides a greater overall capability due to power, size, capacity, etc. than would be found in a type 2 resource. Resource typing provides managers with additional information in selectingthe best resource for the task.
385 Unconfined vapor cloud explosion A high-velocityflame front created by the ignition of a released flammable vapor that has mixed with air to form a vapor cloud. Unified area command An incident management system established when incidents under an area command are multijurisdictional. Unified command In ICS, unified command is a unified team effort that allows all agencies with responsibility for the incident (either geographical or functional) to manage an incident by establishing a common set of incident objectives and strategies. This is accomplishedwithout losing or abdicating agency authority, responsibility, or accountability. Unit In ICS, the organizational element havingfunctional responsibilityfor a specific incident planning, logistics, or finance/administrationactivity. Unity of command The concept by which each person within an organization reports to one and only one designated person.
UN United Nations.
Universal precautions A system of infectious disease control which assumes that every direct contact with body fluids is infectious and requires every employee exposed t o direct contact with body fluids t o be protected as though such body fluids were HBV or HIV infected; intended to prevent health-care workers for parented, mucous membrane, and nonintact skin exposures to bloodborne pathogens and should be used by emergency response personnel.
Unassisted rescue Water rescue conducted by a rescue skin diver without assistance of a torpedo buoy or water rescue line.
Unstablelreactive Any material that spontaneously explodes with production of pressure, gas, heat, and possibly toxic fumes.
U
386 Upper explosive l i m i t The concentration of a chemical in air above which a flame will not propagate if the mixture contacts an ignition source. USCG U.S. Coast Guard. USFA U.S. Fire Administration.
V
Vaccine A substance that produces or increases immunity and protection against a particular disease.
Vapor density The weight per unit volume of a vapor; commonly given in comparison to air when the density of air is defined as 1.0.
Vapor pressure The pressure created within a closed container by the gaseous phase of a contained liquid. V D R L A blood test (Venereal Disease Research Laboratory) for syphilis.
Venereal Due to or propagated by sexual contact.
Venezuelan equine encephalitis Viral
Appendix A Volatility A measure of how quickly a substance forms vapor at ordinary temperatures. V u l n e r a b i l i t y analysis Any procedure used to integrate facility-specific information on (a) types of potential emergency, (b) likely impacts and probability of occurrence of each type, and (c) resources available for use in an actual emergency response.
W Walk-through drill A training activity in which the emergency management group and response teams actually perform their emergency response functions in a simulation; generally involves more people and is more thorough than a table-top exercise, although elements of both types of exercises are often integrated.
Water reactive Any material that reacts with water to form a flammable or toxic gas.
Water rescue line see Search line. Water sector That part of a water
infection of the central nervous system, with potentially fatal swelling of the brain.
rescue scene that involves divers and dive rescue activity; in ICS, it is the area of responsibility of the senior rescue diver.
Vesicant A chemical agent (also called
Water tender Any ground vehicle
blister or mustard agent) that causes severe burns to eyes, skin, and tissues of the respiratory tract.
capable of transporting specified quantities of water.
Virulence The disease-provoking power or potency of a microorganism in a given host.
Virus A microorganism usually only visible with the electron microscope; viruses normally reside within other living (host) cells, and cannot reproduce outside of a living cell.
Western blot A test for HIV, used to confirm a positive ELISA test; more expensive and time consuming to perform than ELISA, but more specific; diagnosis of HIV infection requires two positive ELISA tests, confirmed with a positive Western blot test.
What-if analysis A hazard evaluation method that uses a brainstorming
387
Glossary approach to develop a list of questions or concerns addressing hazards or specific accidents that could produce undesirable consequences in a system or a process. W h i t l o w A fingertip infection commonly caused by herpes virus; spread by contact with respiratory secretions. W H O United Nations World Health Organization. W i n d o w phase The time from exposure to a disease until a positive diagnostic test for its presence. W o r s t - c a s e analysis Any analysis of a situation, circumstance, or process in
which it is assumed that all or some of the relevant factors are at their most negative or adverse value. W r i s l e t The circular, close fitting part of the glove, usually made of knitted material, that extends beyond the opening of the glove body to over the wrist area; also used to describe connection of a safety line to the wrists, which can be used to extricate a person out of a narrow confined space.
Z o s t e r see Herpes zoster
FEMA ADDRESSES
FEMA Headquarters Federal Emergency Management Agency 500 C Street, SW Washington, DC 20472 (202)646-2500
FEMA Regional Offices Region I: Boston (617) 223-9540 Region I1: New York (212) 225-7209 Region II1: Philadelphia (215) 931-5500 Region IV: Atlanta (770) 220-5226 Region V: Chicago
(312) 408-5500 Region VI: Denton, TX (817) 898-5104 Region VII: Kansas City, MO (816) 283-7061 Region VIII: Denver (303) 235-1813 Region IX: San Francisco (415) 923-7100
388
Region X: Bothell, WA (206) 487-4604
State & Territorial Emergency Management Agencies
FEMA region numbers are in parentheses.
Alabama (4) Alabama Emergency Management Agency 5898 S. County Rd. Clanton, AL 35045
(205) 280-2200
Alaska (10) Division of Emergency Services New Anchorage Armory Fort Richardson Bldg. 49000, Suite B-210 Fort Richardson, AK 99595-5750 (907) 428-7000
Arizona (9) Arizona Division of Emergency Services National Guard Bldg. 5636 E. McDowell Rd. Phoenix, AZ 85008 (602) 231-6245
Arkansas (6) Office of Emergency Services P.O. Box 758
389
FEMA Addresses Conway, AR 72032 (501)329-5601 California (9) Office of Emergency Services 2800 Meadowview Rd. Sacramento, CA 95823 (916) 427-4990 Colorado (8) Colorado Office of Emergency Management Camp George West Golden, CO 80401 (303) 273-1622 Connecticut (I) Connecticut Office of Emergency Management 360 Broad St. Hartford, CT 06105 (203) 566-3180 Delaware (3) Division of Emergency Planning and Operations Delaware City, DE 19706 (302) 834-4531 District of Columbia (3) Office of Emergency Preparedness 200 14th St., NW, 8th Floor Washington, DC 20009 (202) 727-3150 Florida (4) Division of Emergency Management 2740 Crestview Dr. Tallahassee, FL 32399 (904) 488-1900 Georgia (4) Georgia Emergency Management Agency P.O. Box 18055 Atlanta, GA 30316-0055 (404) 624-7205
Hawaii (9) State Civil Defense 3949 Diamond Head Rd. Honolulu, HI 96816-4495 (808) 734-2161 Idaho (10) Bureau of Disaster Services 650 W. State St. Boise, ID 83720 (208) 334-3460
Illinois (5) Illinois Emergency ManagementAgency 110 E. Adams St. Springfield, IL 62706 (217) 782-2700 Indiana (5) Indiana Emergency ManagementAgency State Office Bldg., Room E-208 302 W. Washington St. Indianapolis, IN 46204
Iowa (7) Iowa Emergency Management Division Hoover State Office Bldg. Level A, Room 29 Des Moines, IA 50319 (515) 281-3231 Kansas (7) Division of Emergency Preparedness P.O. Box C300 Topeka, KS 66601 (913) 266-1400 Kentucky (4) Kentucky Disaster and Emergency Services Boone Center, Parkside Dr. Frankfort, KY 40601 (502) 564-8682 Louisiana (6) Office of Emergency Preparedness Department of Public Safety LA Military Dept. P.O. Box 44217
390 Capitol Station Baton Rouge, LA 70804 (504) 342-5470
Maine (I) Maine Emergency Management Agency State Office Bldg., Station 72 Augusta, ME 04333 (207) 289-4080 Maryland (3) Maryland Emergency Management and Civil Defense Agency Two Sudbrook Ln., East Pikesville, MD 21208 (301) 486-4422
Massachusetts (I) Massachusetts Emergency Management Agency 400 Worcester Rd. Framingham, MA 01701 (508) 820-2000
Michigan (5) Emergency Management Division Michigan State Police 300 S. Washington Sq. Suite 300 Lansing, MI 48913 (517) 334-5130
Minnesota (5)
Appendix B
Missouri (7) State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102 (314) 751-9779
Montana (8) Emergency Management Specialist Disaster and Emergency Services P.O. Box 4789 Helena, MT 59604-4789 (406) 444-6911
Nebraska Nebraska Civil Defense Agency National Guard Center 1300 Military Road Lincoln, NE 68508-1090 (402) 473-1410
Nevada (9) Nevada Division of Emergency Services 2525 S. Carson St. Carson City, NV 89710
(702) 887-7302
New Hampshire (I) Governor's Office of Emergency Management State Office Park South 107 Pleasant St. Concord, NH 03301 (603) 271-2231
New Jersey (2)
Division of Emergency Services Department of Public Safety State Capitol, B-5 St. Paul, MN 55155 (612) 296-2233
Office of Emergency Management P.O. Box 7068 W. Trenton, NJ 08628-0068 (609) 538-6050
Mississippi (4)
Emergency Planning and Coordination Department of Public Safety 4491 Cerrillos Rd. P.O. Box 1628 Santa Fe, NM 87504 (505) 827-9222
Mississippi Emergency Management Agency P.O. Box 4501, Fondren Station Jackson, MS 39296 (601) 352-9100
New Mexico (6)
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FEMA Addresses
New York (2) State Emergency Management Office Public Security Bldg. #22 State Campus Albany, NY 12226-5000 (518) 457-2222
Puerto Rico (2) State Civil Defense Commonwealth of Puerto Rico P.O. Box 5127 San Juan, PR 00906 (809) 724-0124
North Carolina Division of Emergency Management 116 West Jones St. Raleigh, NC 27603-1335 (919) 733-3867
Rhode Island ( I ) Rhode Island Emergency Management Agency State House, Room 27 Providence, RI 02903 (401) 421-7333
North Dakota (8) North Dakota Division of Emergency Management P.O. Box 5511 Bismarck, ND 58502-5511 (701) 224-2113 Ohio (5) Ohio Emergency Management Agency 2825 W. Granville Rd. Columbus, OH 43235-2712 (614) 889-7150 Oklahoma (6) Oklahoma Civil Defense P.O. Box 53365 Oklahoma City, OK 73152 (405) 521-2481 Oregon (10) Emergency Management Division Oregon State Executive Department 595 Cottage St., NE Salem, OR 97310 (503) 378-4124 Pennsylvania (3) Pennsylvania Emergency Management Agency P.O. Box 3321 Harrisburg, PA 17105-332 I (717) 783-8016
South Carolina (4) South Carolina Emergency Management Division 1429 Senate St., Rutledge Bldg. Columbia, SC 29201-3782 (803) 734-8020 South Dakota (8) Division of Emergency and Disaster Services State Capitol, 500 East Capitol Pierre, SD 57501 (605) 773-323 I Tennessee (4) Tennessee Emergency Management Agency 3041 Sidco Dr. Nashville, TN 37204-1502 (615) 741-0001 Texas (6) Division of Emergency Management P.O. Box 4087 Austin, TX 78773-4087 (512) 465-2183
Utah (8) Division of Comprehensive Emergency Management Sate Office Bldg., Room III0 Salt Lake City, UT 84114 (801) 538-3400
392 Vermont (I) Vermont Emergency ManagementAgency Department of Public Safety Waterbury State Complex 103 S. Main St. Waterbury, V'I" 05676 (802) 244-8271
Virgin Islands (2) Office of Civil Defense and Emergency Services 131 Gallows Bay Christiansted, VI 00820 (809) 773-2244
Virginia (3) Department of Emergency Services 310 Turner Rd. Richmond, VA 23225-6491 (804) 674-2497
Washington (I O) Division of Emergency Management Washington Military Department
Appendix B
Camp Murray, WA 98430-5122 (800) 562-6108 West Virginia (3) West Virginia Office of Emergency Services State Capitol Complex Room EB80 Charleston, WV 25305 (304) 558-5380
Wisconsin (5) Division of Emergency Government 4802 SheboyganAve., Room 99A Madison, WI 53707 (608) 266-3232
Wyoming (8) Wyoming Emergency Management Agency P.O. Box 1709 Cheyenne, WY 82003 (307) 777-7566
REG IONAL AN D AREA OSHA OFFICES
REGION I
South Boston Area Office
Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont
639 Granite Street, 4th Floor Braintree, MA 02184 (617) 565-6924
Regional Office
Springfield Area Office
JFK Building, Room E 340 Boston, MA 02203 (617) 565-9860
1145 Main Street, Room 108 Springfield, MA 01103 (413) 785-0123
Bridgeport Area Office
Concord Area Office
I Lafayette Square, Suite 202 Bridgeport, CT 06604 (203) 579-5580
279 Pleasant Street, Suite 201 Concord, NH 03301 (603) 225-1629
Hartford Area Office 450 Main Street, Room 613 Hartford, CT 06103 (860) 240-3152
Providence Area Office 380 Westminster Mall, Room 243 Providence, RI 02903 (401) 528-4669
Augusta Area Office 40 Western Avenue, Room 608 Augusta, ME 04330 (207) 622-8417
REGION II New Jersey, New York, Puerto Rico
Bangor Area Office
Regional Office
202 Harlow Street, Room 211 Bangor, ME 00401 (207) 941-8177
201 Varick Street Room 670 New York, NY 10014 (212) 337-2378
North Boston Area Office 13 Branch Street, I st Floor Methuen, MA 01844 (617) 565-8110
Avenel Area Office Plaza 35, Suite 205 1030 St. Georges Avenue
393
Appendix C
394 Avenel, NJ 07001 (908) 750-3270
Hasbrouck Heights Area Office 500 Route 17 South, 2nd Floor Hasbrouck Heights, NJ 07604 (201) 288-1700
Marlton Area Office Marlton Executive Park, Building 2 Suite 120 701 Route 73, South Marlton, NJ 08053 (609) 757-5181
Parsippany Area Office 299 Cherry Hill Road Suite 304 Parsippany, NJ 07054 (201) 263-1003
Albany Area Office 401 New Karner Road, Suite 300 Albany, NY 12205 (518) 464-4338
Bayside Area Office 42-40 Bell Boulevard Bayside, NY I 1361 (718) 279-9060
Tarrytown Area Office 660 White Plains Road, 4th Floor Tarrytown, NY 1059 I (914) 524-7510
Puerto Rico Area Office BBV Plaza Building 15 I0 FD Roosevelt Avenue Guaynabo, PR 00968 (787) 277-1560
REGION III Delaware, District of Columbia, Maryland, Pennsylvania, Virginia, West Virginia
Regional Office Gateway Building Suite 2 I00 3535 Market Street Philadelphia, PA 19104 (215) 596-1201
Wilmington District Office I Rodney Square, Suite 402 920 King Street Wilmington, DE 19801 (302) 573-6115
5360 Genesee Street Bowmansville, NY 14026 (716) 684-389 I
W a s h i n g t o n D C Area Office 820 First Street NE, Suite 440 Washington, DC 20002 (202) 523-1452
Long Island Area Office
Baltimore Area Office
Buffalo Area Office
990 Westbury Road Westbury, NY II 590 (516) 334-3344
300 West Pratt Street, Suite I I I0 Baltimore, MD 21201 (410) 962-2840
Manhattan Area Office
Allentown Area Office
6 World Trade Center, Room 881 New York, NY 10048 (212) 466-2482
850 North 5th Street Allentown, PA 18102 (610) 776-0592
Syracuse Area Office
Erie Area Office
3300 Vickery Road, North Syracuse Syracuse, NY 13212 (315) 451-0808
3939 West Ridge Road, Suite B 12 Erie, PA 16506 (814) 833-5758
395
Regional and Area OSHA Offices
Harrisburg Area Office
Mobile District Office
Progress Plaza 49 North Progress Avenue Harrisburg, PA 17109 (717) 782-3902
3737 Government Boulevard Suite 100 Mobile, AL 36693 (334) 441-6131
Philadelphia Area Office U.S. Custom House, Room 242 Second & Chestnut Street Philadelphia, PA 19106 (215) 597-4955
Pittsburgh Area Office Federal Building, Room 1428 1000 Liberty Avenue Pittsburgh, PA 15222 (412) 395-4903
Wilkes-Barre Area Office
Fort Lauderdale Area Office Jacaranda Executive Court 8040 Peters Road, Building H-100 Fort Lauderdale, FL 33324 (954) 424-0242
Jacksonville Area Office Ribault Building, Suite 227 1851 Executive Center Drive Jacksonville, FL 32207
(904) 232-2895
Penn Place, Room 2995 20 North PennsylvaniaAvenue Wilkes-Barre, PA 18701 (717) 826-6538
Tampa Area Office
Norfolk Area Office
Atlanta-East Area Office
Federal Office Building 200 Granby Street, Room 835 Norfolk, VA 23510 (757) 441-3820
Charleston Area Office 550 EaganStreet, Room 206 Charleston, WV 25301 (304) 347-5937
REGION IV Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee
Regional Office 61 Forsyth Street, SW Atlanta, GA 30303
5807 Breckenridge Parkway, Suite A Tampa, FL 33610
(813) 626-1177 Building 7, Suite 100 LaVista Perimeter Office Park Tucker, GA 30084 (707) 493-6644
Atlanta-West Area Office 2400 Herodian Way, Suite 250 Smyrna, GA 30080
(770) 984-8700 Savannah District Office 450 Mall Boulevard, Suite J Savannah, GA 31406
(912) 652-4393 Frankfort Area Office John C. Watts Federal Building 330 West Broadway, Room 108 Frankfort, KY 4061
(404) 562-2300
(502) 227-7024
Birmingham Area Office
Jackson Area Office
Todd Mall, 2047 Canyon Road Birmingham, AL 35216
3780 1-55 North, Suite 210 Jackson, MI 39211
(205) 731-1534
(601) 965-4606
Appendix C
396
Raleigh Area Office
North Aurora A r e a Office
Century Station Federal Office Building 300 Fayetteville Street Mall, Room 438 Raleigh, NC 27601 (919) 856-4770
344 Smoke Tree Business Park North Aurora, IL 60542 (630) 896-8700
Columbia Area Office
2918 Willow Knolls Road Peoria, IL 61614 (309) 671-7033
1835 Assembly Street, Room 1468 Columbia, SC 29201 (803) 765-5904
Nashville Area Office 2002 Richard Jones Road Suite C-205 Nashville, TN 37215 (615) 781-5423
REGION V Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin
Regional Office 230 South Dearborn Street Room 3244 Chicago, IL 60604 (312) 353-2220
Aurora Area Office 344 Smoke Tree Business Park North Aurora, IL 60542 (708) 896-8700
Calumet C i t y A r e a Office 1600 167th Street, Suite 12 Calumet City, IL 60409 (708) 891-3800
Chicago Area Office
Peoria Area Office
Indianapolis Area Office 46 East Ohio Street, Room 423 Indianapolis, IN 46204 (317) 226-7290
Lansing Area Office 801 South Waverly Road, Suite 306 Lansing, MI 48917 (5 ! 7) 377-1892
Minneapolis A r e a Office II 0 South 4th Street, Room 116 Minneapolis, MN 55401 (612) 348-1994 C i n c i n n a t i A r e a Office 36 Triangle Park Drive, Building 36 Cincinnati, OH 45246 (513) 841-4132 Cleveland A r e a Office Federal Office Building, Room 899 1240 East 9th Street Cleveland, OH 44199 (216) 522-3818 C o l u m b u s A r e a Office Federal Office Building, Room 620 200 North High Street Columbus, OH 43215 (614) 469-5582
2360 East Devon Avenue, Suite 1010 Des Plaines, IL 60018 (847) 803-4800
T o l e d o A r e a Office 234 North Summit Street, Room 734 Toledo, OH 43604 (419) 259-7542
Fairview Heights Area Office
Appleton Area Office
II Executive Drive, Suite II Fairview Heights, IL 62208 (618) 632-8612
2618 North Ballarcl Road Appleton, WI 54915 (920) 734-4521
397
Regional and Area OSHA Offices
Eau C l a i r e D i s t r i c t Office
Austin Area Office
500 South Barstow Street, Room B-9 Eau Claire, WI 54701 (715) 832-9019
903 San Jacinto Boulevard, Suite 319 Austin, TX 78701 (512) 916-5783
Madison Area Office
Corpus Christi Area Office
4802 East Broadway Madison, WI 53716 (608) 264-5388
Wilson Plaza, Suite 700 606 North Carancahua Corpus Christi, TX 78401 (512) 888-3420
Milwaukee Area Office 310 West Wisconsin Avenue Suite 1180 Milwaukee, WI 53203 (414) 297-3315
Dallas Area Office 834 East R.L. Thornton Freeway Suite 420 Dallas, Texas 75228
(214) 320-2400 R E G I O N VI Arkansas, Louisiana, New Mexico, Oklahoma, Texas
Regional Office 525 Griffin Street, Room 602 Dallas, Texas 75202 (214) 767-473 I L i t t l e Rock Area Office TCBY Building 425 West Capitol Avenue, Suite 450 Little Rock, AK 72201 (501) 324-6291
Baton Rouge Area Office 2156 Wooddale Boulevard Hoover Annex, Suite 200 Baton Rouge, LA 7806 (504) 389-0474 Albuquerque Area Office Western Bank Building 505 Marquette, N.W., Suite 820 Albuquerque, NM 87102 (505) 248-5302
E! Paso Area Office Commons Building C 4171 North Mesa Street~ Room C-119 El Paso,TX 79902 (915) 534-7004 F o r t W o r t h Area Office North Star II, Suite 430 8713 Airport Freeway Fort Worth, TX 76180 (817) 428-2470
Houston-North Area Office 350 North Sam Houston Parkway, East Suite 120 Houston, Texas 77060 (281) 591-2438
Houston-South Area Office 17651 El Camino Real, Suite 400 Houston, TX 77058 (281) 286-0583
Lubbock Area Office 1205 Texas Avenue, Room 804 Lubbock, TX 79401 (806) 472-7681
Oklahoma City Area Office 420 West Main, Suite 300 Oklahoma City, OK 73102 (405) 231-5351
R E G I O N VII Iowa, Kansas, Missouri, Nebraska
398
Appendix C
Regional Office
Denver Area Office
City Center Square II 00 Main Street Kansas City, MO 64120 (816) 426-5861
Colonnade Center, Suite 210 1391 Spear Boulevard Denver, CO 80204 (303) 844-5285
Des Moines Area Office 210 Walnut Street, Room 815 Des Moines, IA 50309 (515) 284-4794
Overland Park Area Office 6600 Farley, Suite 105 Overland Park, KS 66212
(913) 236-3220 Wichita Area Office 301 North Maine 300 Epic Center Wichita, KS 67202
(316) 269-6644 Kansas City Area Office 6200 Connecticut Avenue, Suite 100 Kansas City, MO 64120 (816) 483-9531
Englewood Area Office 7935 East Prentice Avenue, Suite 209 Englewood, CO 80111 (303) 843-4500
Billings Area Office 2900 4th Avenue North, Suite 303 Billings, MT 59101 (406) 247-7494
Bismarck Area Office Federal Building, Room 348 P.O. Box 2439 Bismarck, ND 58501 (701) 250-4521 Salt Lake C i t y Area Office 1781 South 300 West P.O. Box 15200 Salt Lake City, UT 84115 (801) 487-0680
St. Louis Area Office 911 Washington Street, Room 420 St. Louis, MO 63101 (314) 425-4249
Omaha Area Office Overland-Wolf Building, Room 100 6910 Pacific Street Omaha, NE 68106
(402) 221-3182
REGION VIII Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming
REGION IX American Samoa, Arizona, California, Guam, Hawaii, Nevada, Trust Territory of the Pacific Islands
Regional Office 71 Stevenson Street, Suite 420 San Francisco, CA 94105 (415) 975-4310
Phoenix Area Office 3221 North 16th Street, Suite 100 Phoenix, AZ 85016 (602) 640-2007
Regional Office
Sacramento Area Office
1999 Broadway, Suite 1690 Denver, CO 80202 (303) 844-1600
105 El Camino Plaza,Suite 105 Sacramento, CA 95815 (916) 566-7470
399
Regional and Area OSHA Offices
San Diego District Office 5675 Ruffin Road, Suite 330 San Diego, CA 92123 (619) 557-2909
Honolulu Area Office 300 Ala Moana Boulevard, Suite 5-146 Honolulu, HI 96850 (808) 541-2685
Carson C i t y A r e a Office 705 North Plaza, Room 204 Carson City, NV 89701 (702) 885-696
REGION X Alaska, Idaho, Oregon, Washington
Regional Office I II Third Avenue, Suite 715
Seattle, WA 98101 (206) 553-5930
Anchorage A r e a Office 301 West Northern Lights Boulevard Suite 407 Anchorage, AK 99503 (907) 271-5152
Boise Area Office 3050 North Lakeharbor Lane, Suite 134 Boise, ID 83724 (208) 334-1867 P o r t l a n d A r e a Office 1220 SW 3rd Avenue, Room 640 Portland, OR 97204 (503) 326-2251 Bellevue A r e a Office 505 106th Avenue, NE, Suite 302 Bellevue, WA 98004 (206) 553-7520
STATES WITH APPROVED OCCUPATIONAL SAFETY AN D H EALTH PLANS
Alaska Department of Labor I I I I W. 8th Street, Room 306 Juneau, Alaska 99801 Tom Cashen, Commissioner (907) 465-2700 Fax: (907) 465-2784 Alan W. Dwyer, Program Director (907) 465-4855 Fax: (907) 465-3584
Industrial Commission of Arizona 800 W. Washington Phoenix, Arizona 85007 Larry Etchechury, Director (602) 542-5795 Fax: (602) 542-1614 Derek Mullins, Program Director (602) 542-5795 Fax: Same as above
California Department of Industrial Relations 45 Fremont Street San Francisco, California 94105 John Duncan, Acting Director (415) 972-8835 Fax: (415) 972-8848 Dr. John Howard, Chief (415) 972-8500 Fax: (415) 972-8513
Connecticut Department of Labor 200 Folly Brook Boulevard
4OO
Wethersfield, Connecticut 06109 James P. Butler, Commissioner (860) 566-5123 Fax: (860) 566-1520 Program Director's Office (860) 566-4550 Fax: (860) 566-6916
Hawaii Department of Labor and Industrial Relations 830 Punchbowl Street Honolulu, Hawaii 96813 Lorraine H. Akiba, Director (808) 586-8844 Fax: (808) 586-9099 Jennifer Shishido, Administrator (808) 586-9116 Fax: (808) 586-9104
Indiana Department of Labor State Office Building 402 West Washington Street, Room WI95 Indianapolis, Indiana 46204 Timothy Joyce, Commissioner (317) 232-2378 Fax: (317) 233-3790 John Jones, Deputy Commissioner (317) 232-3325 Fax: Same as above
Iowa Division of Labor Services 1000 E. Grand Avenue Des Moines, Iowa 50319
States with Approved Occupational Safetyand Health Plans
401
Byron K. Orton, Commissioner (515) 281-3447 Fax: (515) 242-5144 Mary L. Bryant, Administrator (515) 281-3469 Fax: (515) 281-7995
Ron Swirczek, Administrator (702) 687-3032 Fax: (702) 687-6305 Danny Evans,Assistant Administrator (702) 687-3250 Fax: (702) 687-6150
Kentucky Labor Cabinet
New Mexico Environment Department
1047 U.S. Highway 127 South, Suite 2 Frankfort, Kentucky 40601 Joe Norsworthy, Secretary (502) 564-3070 Fax: (502) 564-5387 Steven A. Forbes, Federal/State Coordinator (502) 564-2300 Fax: (502) 564-1682
Maryland Division of Labor and Industry
II 90 St. Francis Drive P.O. Box 26110 Santa Fe, New Mexico 87502 Mark E. Weidler, Secretary (505) 827-2850 Fax: (505) 827-2836 Sam A. Rogers, Chief (505) 827-4230 Fax: Same as above
New York Department of Labor
Department of Licensing and Regulation 1100 North Eutaw Street, Room 613 Baltimore, Maryland 21201-2206 John P. O'Conner, Commissioner (410) 767-2215 Fax: (410) 767-2003 Ileana O'Brien, Deputy Commissioner (410) 767-2992 Fax: Same as above
W. Averell Harriman State Office Building12, Room 500 Albany, New York 12240 James T. Dillon, Acting Commissioner (518) 457-2741 Fax: (518) 457-6908 Richard Cuculo, Program Director (518) 457-3518 Fax: Same as above
Michigan Department of Consumer and Industry Services
North Carolina Department of Labor
3423 North Martin Luther King Boulevard P.O. Box 30649 Lansing, Michigan 48909 Kathleen M. Wilbur, Director (517) 373-7230 Fax: (517) 373-2129 Douglas R. Earle, Program Director for Safety and Health (517) 322-1814 Fax: (517) 335-8010
319 Chapanoke Road Raleigh, North Carolina 27603 Harry Payne, Commissioner (919) 662-4585 Fax: (919) 662-4582 Charles Jeffress, Deputy Commissioner (919) 662-4585 Fax: Same as above
Minnesota Department of Labor and Industry
Oregon Occupational Safety and H e a l t h Division
443 Lafayette Road St. Paul, Minnesota 55155 Gary Bastian, Commissioner (612) 296-2342 Fax: (612) 282-5405 Gail Blackstone, Assistant Commissioner (612) 296-6529 Fax: Same as above
Department of Consumer & Business Services 350 Winter Street, NE, Room 430 Salem, Oregon 97310 Peter DeLuca, Administrator (503) 378-3272 Fax: (503) 378-4538 David Sparks, Deputy Administrator (503) 378-3272 Fax: Same as above
Nevada Division of Industrial Relations
Puerto Rico Department of Labor and Human Resources
400 West King Street Carson City, Nevada 97502
Prudencio Rivera Martinez Building 505 Munoz Rivera Avenue
Appendix D
402 Hato Rey, Puerto Rico 00918 Cesar J. Almodovar-Marchany, Secretary (787) 754-2119 Fax: (787) 753-9550 Assistant Secretary's Office (787) 754-2119/2171 Fax: (787) 767-6051
South Carolina Department of Labor, Licensing and Regulation Koger Office Park, Kingstree Building 110 Centerview Drive PO Box II 329 Columbia, South Carolina 29210 Lewis Gossett, Director (803) 896-4300 Fax: (803) 896-4393 William Lybrand, Program Director (803) 734-9594 Fax: (803) 734-9772
Tennessee Department of Labor 710 James Robertson Parkway Nashville, Tennessee 37243-0659 Alphonso R. Bodie, Commissioner (615) 741-2582 Fax: (615) 741-5078 Don Witt, Program Director (615) 741-2793 Fax: (615) 741-3325
Labor Commission of Utah 160 East 300 South, 3rd Floor PO Box 146650 Salt Lake City, Utah 84114-6650 R. Lee Eliertson, Commissioner (801) 530-6898 Fax: (801) 530-6880 Jay W. Bagley,Administrator (801) 530-6898 Fax: (801) 530-7606
Vermont Department of Labor and Industry National Life Building-Drawer 20 120 State Street Montpelier, Vermont 05620 Stephen Jamsen, Commissioner (802) 828-2288 Fax: (802) 828-2748
Robert McLeod, Project Manager (802) 828-2765 Fax: Same as above
Virginia Department of Labor and I n d u s t r y Powers-Taylor Building 13 South 13th Street Richmond, Virginia 23219 Theron Bell, Commissioner (804) 786-2377 Fax: (804) 371-6524 Charles Lahey, Deputy Commissioner (804) 786-2383 Fax: Same as above
Virgin Islands Department of Labor 2131 Hospital Street Box 890, Christiansted St. Croix, Virgin Islands 00820-4666 Carmelo Rivera, Commissioner (809) 773-1994 Fax: (809) 773-0094 Raymond Williams, Program Director (809) 772-1315 Fax: (809) 772-4323
Washington D e p a r t m e n t of Labor and Industries General Administration Building PO Box 44001 Olympia, Washington 98504-4001 Gary Moore, Director (360) 902-4200 Fax: (360) 902-4202 Michael Silverstein, Assistant Director (360) 902-5495 Fax: (360) 902-5529
Wyoming Department of Employment Worker's Safety and Compensation Division Herschler Building, 2nd Floor East 122 West 25th Street Cheyenne, Wyoming 82002 Stephan R. Foster, Safety Administrator (307) 777-7786 Fax: (307) 777-5850
OSHA CONSULTATION DI RECTORY
Alabama
Safe State Program University of Alabama 432 Martha Parham West PO Box 870388 Tuscaloosa, Alabama 35487 (205) 348-7138 (205) 348-3049 FAX
[email protected] E-mail
(501) 682-4522 (501) 682-4532 FAX California
CAL/OSHA Consultation Service Department of Industrial Relations PO Box 420603 San Francisco, California 94142 (415) 972-8515
Alaska
Colorado
ADOL/OSHA Division of Consultation 3301 EagleStreet P.O. Box 107022 Anchorage, Alaska 99510 (907) 269-4954 (907) 269-4950 FAX
[email protected] E-mail
Colorado State University Occupational Safety and Health Section II 0 Veterinary Science Building Fort Collins, Colorado 80523 (303) 491-6151 (303) 491-7778 FAX
[email protected] E-mail
Arizona
Connecticut
Consultation and Training Industrial Commission of Arizona Division of Occupational Safety & Health 800 West Washington Phoenix, Arizona 85007 (602) 542-5795 (602) 542-1614 FAX
Connecticut Department of Labor Division of Occupational Safety & Health 200 Folly Brook Boulevard Wethersfield, Connecticut 06109 (203) 566-4550 (203) 566-6916 FAX
Arkansas
Delaware Department of Labor Division of Industrial Affairs Occupational Safety and Health 4425 Market Street Wilmington, Delaware 19802
OSHA Consultation Arkansas Department of Labor 10421 West Markham Little Rock, Arkansas 72205
Delaware
403
404 (302) 761-8219 (302) 761-6601 FAX
[email protected] E-mail Washington DC DC Department of Employment Services Office of Occupational Safety and Health 950 Upshur Street, N.W. Washington, DC 20011 (202) 576-6339 (202) 576-7282 FAX Florida Florida Department of Labor and Employment Security 7(c)(I) Onsite Consultation Prog. Div. of Safety 2002 St. Augustine Road, Building E, Suite 45 Tallahassee, Florida 32399 (904) 488-3044 (904) 922-4538 FAX Georgia 7(c)(I) Onsite Consultation Program Georgia Institute of Technology O'Keefe Building, Room 22 Atlanta, Georgia 30332 (404) 894-2646 (404) 894-8275 FAX
[email protected] E-mail Guam
OSHA Onsite Consultation Department of Labor, Government of Guam PO Box 9970 Tamuning, Guam 96931 (671) 475-0136 (671) 477-2988 FAX Hawaii Consultation & Training Branch Department of Labor and Industrial Relations 830 Punchbowl Street Honolulu, Hawaii 96813
Appendix E (808) 586-9100 (808) 586-9099 FAX Idaho Boise State University Department of Health Studies 1910 University Drive, ET-338A Boise, Idaho 83725 (208) 385-3283 (208) 385-4411 FAX
[email protected] E-mail Illinois Industrial Service Division Department of Commerce & Community Affairs State of Illinois Center, Suite 3-400 100 West Randolph Street Chicago, Illinois 60601 (312) 814-2337 (312) 814-7238 FAX Indiana Bureau of Safety, Education and Training Division of Labor, Room WI95 402 West Washington Indianapolis, Indiana 46204 (317) 232-2688 (317) 232-0748 FAX Iowa
7(c)(I) Consultation Program Iowa Bureau of Labor 1000 East Grand Avenue Des Moines, Iowa 50319 (515) 281-5352 (515) 281-4831 FAX Kansas Department of Human Resources 512 South West 6th Street Topeka, Kansas 66603 (913) 296-7476 (913) 296-1775 FAX Kentucl~ Division of Education and Training Kentucky Labor Cabinet
405
OSHA Consultation Directory 1049 U.S. Highway 127 South Frankfort, Kentucky 40601 (502) 564-6895 (502) 564-4769 FAX
Saint Paul, Minnesota 55155 (612) 297-2393 (612) 297-1953 FAX
Louisiana 7(c)(i) Consultation Program Louisiana Department of Labor Post Office Box 94094 Baton Rouge, Louisiana 70804 (504) 342-9601 (504) 342-5158 FAX
Mississippi Mississippi State University Center for Safety and Health 2906 North State Street, Suite 201 Jackson, Mississippi 39216 (601) 987-3981 (601) 987-3890 FAX
[email protected] E-mail
Maine Division of Industrial Safety Maine Bureau of Labor State House Station No. 82 Augusta, Maine 04333 (207) 624-6460 (207) 624-6449 FAX
[email protected] E-mail
Missouri Division of Labor Standards Department of Labor & Industrial Relations 3315 West Truman Boulevard Jefferson City, Missouri 65109 (573) 751-3403 (573) 751-3721 FAX
Maryland Division of Labor and Industry 501 St. Paul Place, 3rd Floor Baltimore, Maryland 21202 (4J0) 333-42 l0 (410) 333-8308 FAX
Montana Department of Labor and Industry Bureau of Safety PO Box 1728 Helena, Montana 59624 (406) 444-6418 (406) 444-4140 FAX dfolsom.mt.gov E-mail
Massachusetts
The Commonwealth of Massachusetts
Department of Labor & Industries 1001 Watertown Street West Newton, Massachusetts 02165 (617) 969-7177 (617) 969-4581 FAX
[email protected] E-mail Michigan Michigan Department of Public Health Division of Occupational Health 3423 North Martin Luther King Boulevard Lansing, Michigan 48909 (517) 335-8250 (517) 335-8010 FAX Minnesota Department of Labor and Industry 443 LaFayette Road
Nebraska Division of Safety Labor & Safety Standards Nebraska Department of Labor State Office Building, Lower Level 301 Centennial Mall, South Lincoln, Nebraska 68509-5024 (402) 471-4717 (402) 471-5039 FAX Nevada Division of Preventive Safety Department of Industrial Relations, Suite 106 2500 West Washington Las Vegas, Nevada 89106 (702) 486-5016 (702) 486-5331 FAX
Appendix E
406 New Hampshire New Hampshire Dept. of Health Division of Public Health Services 6 Hazen Drive Concord, New Hampshire 03301-6527 (603) 271-2024 (603) 271-2667 FAX
[email protected] E-mail New Jersey Division of Workplace Standards New Jersey Department of Labor STATION PLAZA 4, CN953 22 South Clinton Avenue Trenton, New Jersey 08625-0953 (609) 292-2424 (609) 292-4409 FAX New Mexico New Mexico Environment Department Occupational Health and Safety Bureau 525 Camino de Los Marquez, Suite 3 PO Box 26110 Santa Fe, New Mexico 87502 (505) 827-4230 (505) 827-4422 FAX New York Division of Safety and Health State Office Campus Building 12, Room 130 Albany, New York 12240 (518) 457-2238 (518) 457-3454 FAX North Carolina Bureau of Consultative Services North Carolina Department of Labor 319 Chapanoke Road, Suite 105 Raleigh, North Carolina 27603-3432 (919) 662-4644 (919) 662-4671 FAX
[email protected] E-mail North Dakota Division of Environmental Engineering 1200 Missouri Avenue, Room 304
Bismarck, North Dakota 58506-5520 (701) 328-5188 (701) 328-s200 FAX
[email protected] E-mail Ohio Bureau of Employment Services 145 S. Front Street Columbus, Ohio 43216 (614) 644-2246 (614) 644-3133 FAX Oklahoma Oklahoma Department of Labor OSHA Division 4001 North Lincoln Boulevard Oklahoma City, Oklahoma 73105-5212 (405) 528-1500 (405) 528-5751 FAX Oregon Department of Consumer and Business Services Oregon Occupational Safety and Health Division 350 Winter Street NE, Room 430 Salem, Oregon 97310 (503) 378-3272 (800) 922-2689 TOLL FREE (503) 378-5729 FAX
[email protected] OR
[email protected] E-mail Pennsylvania Indiana University of Pennsylvania Safety Sciences Department 205 Uhler Hall Indiana, Pennsylvania 15705-1087 (412) 357-2561 (412) 357-2385 FAX Puerto Rico Occupational. Safety and Health Office Department of Labor & Human Resources, 2 I st Floor 505 Munoz Rivera Avenue Hato Rey, Puerto Rico 00918
407
OSHA Consultation Directory (809) 754-2188 (809) 767-6051 FAX Rhode Island Rhode Island Department of Health Division of Occupational Health 3 Capital Hill Providence, Rhode Island 02908 (401) 277-2438 (401) 277-6953 FAX
[email protected] E-mail South Carolina South Carolina Department of Labor Licensing and Regulation 3600 Forest Drive PO Box II 329 Columbia, South Carolina 29211 (803) 734-9614 (803) 734- 734-9741 FAX
[email protected] E-mail South Dakota Engineering Extension Onsite Technical Division South Dakota State University Box 510 West Hall 907 Harvey Dunn Street Brookings, South Dakota 57007 (605) 688-4101 (605) 688-6290 FAX E-mail Tennessee OSHA Consultative Services Tennessee Department of Labor 710 James Robertson Parkway, 3rd Floor Nashville, Tennessee 37243-0659 (615) 741-7036 (615) 741-3325 FAX Texas Workers' Health and Safety Division Workers' Compensation Commission Southfield Building 4000 South I H 35
Austin, Texas 78704 (512) 440-3834 (512) 440-3831 FAX Utah Utah Industrial Commission Consultation Services 160 East 300 South Salt Lake City, Utah 84114-6650 (801) 530-6868 (801) 530-6992 FAX
[email protected] E-mail Vermont Division of Occupational Safety & Health Vermont Department of Labor and Industry National Life Building, Drawer 20 Montpelier, Vermont 05602-3401 (802) 828-2765 (802) 828-2748
[email protected] E-mail Virginia Virginia Department of Labor and Industry Occupational Safety and Health Training and Consultation 13 South 13th Street Richmond, Virginia 23219 (804) 786-6359 (804) 786-8418 FAX Virgin Islands Division of Occupational Safety and Health Virgin Islands Department of Labor 3021 Golden Rock Christiansted St. Croix, Virgin Island 00840 (809) 772-1315 (809) 772-4323 FAX Washington Washington Department of Labor and Industries Division of Industrial Safety and Health PO Box 44643 Olympia, Washington 98504
Appendix E
408 (360) 902-5638 (360) 902-5459 FAX
[email protected] E-mail
West Virginia West Virginia Department of Labor Capitol Complex Building No. 3 1800 East Washington Street, Room 319 Charleston, West Virginia 25305 (304) 558-7890 (304) 558- 3797 FAX
Wisconsin (Health) Wisconsin Department of Health and Human Services Section of Occupational Health, Room 112 1414 East Washington Avenue Madison, Wisconsin 53703 (608) 266-8579 (608) 266-9711 FAX
Wisconsin (Safety) Wisconsin Department of Industry Labor and Human Relations Bureau of Safety Inspections 401 Pilot Court, Suite C Waukesha, Wisconsin 53188 (414) 521-5063 (414) 521-8614 FAX
Wyoming Wyoming Department of Employment Workers' Safety and Compensation Division Herschler Building, 2 East 122 West 25th Street Cheyenne, Wyoming 82002 (307) 777-7786 (307) 777-3646 FAX
STATE EMERGENCY RESPONSE COMMITTEES
Alabama
Alaska
Lee Helms, Co-Chair Alabama Emergency Response Commission Alabama Emergency ManagementAgency 5898 Country Road 41 P.O. Drawer 2160 Clanton, AL 35046-2160
Major General Jake Lestenkof, Co-Chair Department of Military and Veteran Affairs P.O. Box 5800 Fort Richardson, AK 99505-5800 (907) 428-6003
(205) 280-2234 James War, Co-Chair Field Operations Office Alabama Emergency Response Commission Alabama Department of Environmental Management 1751 Congressman W.L. Dickinson Drive P.O. Box 301463 Montgomery, AL 36130-1463 (334) 271-7710 Edward Poolos Alabama Emergency Response Commission Alabama Department of Environmental Management 1751 Congressman W.L. Dickinson Drive P.O. Box 301463 Montgomery, AL 36130-1463
Commissioner Michele Brown, Co-Chair Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801-1795 (907) 465-5065 Bob Heavilin, Director Department of Military and Veteran Affairs Division of Emergency Services P.O. Box 5750 Fort Richardson, AK 99505-5750 (907) 428-7000 Camille Stephens Department of Environmental Conservation Spill Prevention and Response 410 Willoughby Avenue, Suite 105 Juneau, AK 99801-1795 (907) 465-5220
409
410 American Samoa
Faamausili Pola Territorial Emergency Management Coordinating Officer American Samoan Government Department of Public Safety P.O. Box 1086 Pago Pago,AS 96799 (684) 633-1111 Pati Faiai American Samoa Environmental Protection Agency Office of the Governor Pago Pago,AS 96799 (684) 633-2304 Arizona
Michael P. Austin, Chairman Arizona Emergency Response Commission 5636 East McDowell Road Phoenix, AZ 85008 (602) 231-6244 Daniel Roe, Executive Director Arizona Emergency Response Commission Division of Emergency Management 5636 East McDowell Road Phoenix, AZ 85008 (602) 231-6346 Bill Quinn Arizona Department of Environmental Quality Pollution Prevention Unit Manager 3033 North Central Avenue Phoenix, AZ 85012 (602) 207-4203 Arkansas
Robert Holyfield Atlantic Research RO. Box 1036 Camden, AR 7171 I-1036 (870) 574-2509 John Ward State Emergency Response Commission
Appendix F c/o Arkansas Department of Pollution Control and Ecology P.O. Box 8913 8001 National Drive Little Rock, AR 72219-8913 (501) 682-0913 California Dr. Richard Andrews, Director Chemical Emergency Planning& Response Comm. Office of Emergency Services Hazardous Materials Division 2800 Meadowview Road Sacramento, CA 95832 (916) 262-1816 Steve DeMello Chemical Emergency Planningand Response Commission Office of Emergency Services Hazardous Materials Division 2800 Meadowview Road Sacramento, CA 95832 (916) 464-3281 Stephen Hanna California Environmental Protection Agency Department of Toxic Substances Control 400 P Street, 4th Floor P.O. Box 806 Sacramento, CA 95812-0806 (916) 324-9924 Colorado
Steve Gunderson Colorado Emergency Planning Commission Colorado Department of Health Mail Code OE-EMU-B2 4300 Cherry Creek Drive South Denver, CO 80222-1530 (303) 692-3022 Tamara Vanhorn Colorado Emergency Planning Commission
411
State EmergencyResponseCommittees Colorado Department of Public Health & Environment 4300 Cherry Creek Drive South Denver CO 80222-1530 (303) 692-3017 Connecticut
Gerard P. Goudreau, Chairman State Emergency Response Commission c/o Ulbrich Stainless Steels I Dudley Ave. P.O. Box 610 Wallingford, CT 06492 (203) 269-2507, ext. 275 Joseph B. Pulaski, SERCAdministrator State Emergency Response Commission Department of Environmental Protection 79 Elm Street, 4th Floor Hartford, CT 06106-5127 (860) 424-3373 Delaware
Karen Johnson, Chair/Secretary Delaware Department of Public Safety P.O. Box 818 Dover, DE 19901 (302) 739-4321 Joe Wessels, SARA Title III Coordinator Delaware Emergency ManagementAgency P.O. Box 527 Delaware City, DE 19706 (302) 834-4531 Andrea Maucher Division of Air and Waste Management Department of Natural Resources & Environmental Control 89 Kings Highway P.O. Box 1401 Dover, DE 19903 (302) 739-4791 David Fees Division of Air and Waste Management Department of Natural Resources & Environmental Control 89 Kings Highway
P.O. Box 1401 Dover, DE 19903 (302) 739-4791 District of Columbia
Samuel Jordan, Acting Director Office of Emergency Preparedness 2000 14th Street, NW Washington, DC 20009 (202) 727-6161 Michele Penick Emergency Response Commission for Title III Office of Emergency Preparedness 2000 14th Street, NW 8th Floor Washington, DC 20009 (202) 673-2101 Ext. 3159 Florida
James F. Murley, Chair Florida Department of Community Affairs Division of Emergency Management State Emergency Response Commission 2555 Shumard Oak Boulevard Tallahassee, FL 32399-2100 (904) 413-9970 Joseph Myers Alternate Chair Division of Emergency Management State Emergency Response Commission 2555 Shumard Oak Boulevard Tallahassee, FL 32399-2100 (904) 413-9970 Eve Rainey Compliance Planning Florida Department of Community Affairs Division of Emergency Management State Emergency Response Commission 2555 Shumard Oak Boulevard Tallahassee, FL 32399-2149 In State: (800) 635-7179 Out of State: (904) 413-9970 Sam Brackett State Emergency Response Commission
412 Florida Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 In State (800) 635-7179 Out of State (904) 413-9970 Georgia Lonice Barrett, Chairman/Commissioner Georgia Emergency Response Commission 205 Butler Street, S.E. Suite 1252 Atlanta, GA 30334-4910 (404) 656-3500
Burt Langley, Chief Georgia Emergency Response Commission 205 Butler Street, S.E. Floyd Tower East, Suite II 66 Atlanta, GA 30334 (404) 656-6905 Guam
Jesus Salas,Administrator Guam EPA 22439 GMF Barrigada, GU 96921 (671) 475-1669 Hawaii Dr. Bruce S. Anderson Hawaii State Emergency Response Commission Hawaii State Department of Health P.O. Box 3378 Honolulu, HI 96801 (808) 586-4424
Marsha Mealey, Coordinator Hawaii State Emergency Response Commission Hawaii State Department of Health P.O. Box 3378 919 Ala Moana Boulevard, Room 206 Honolulu, HI 96814 (808) 586-4694 Idaho Major General John Kane, Chairman Idaho Bureau of Hazardous Material 4040 West Guard Street, Building 600
Appendix F
Boise, ID 83705-5004 (208) 422-5242 Leslie Aller, Director Idaho Emergency Response Commission 4040 West Guard Street, Building 600 Boise, ID 83705-5004 (208) 334-3263 Illinois John Mitchell, Chair State Emergency Response Commission Illinois Emergency Management Agency II 0 East Adams Street Springfield, IL 62701-9963 (217) 232-3986
Oran Robinson, Supervisor Hazardous Materials Compliance and Enforcement State Emergency Response Commission c/o Illinois Emergency Management Agency II 0 East Adams Street Springfield, IL 62706-9963 (217) 782-4694 Joe Goodner, Manager Illinois Environmental Protection Agency Office of Chemical Safety Emergency Planning Unit P.O. Box 19276 2200 Churchill Road Springfield, IL 62794-9276
(217) 785-0830 Indiana Patrick Ralston, Chair State Emergency Response Commission Indiana Government Center South 302 West Washington Street, Room E208 Indianapolis, IN 46204 (317) 232-3986
Cindi Wagner or Tom Madix Indiana Department of Environmental Management 2525 North Shadeland P.O. Box 7024 Indianapolis, IN 46207
(317) 308-3039
413
State EmergencyResponseCommittees Paula Smith or Harry Davis Indiana Department of Environmental Management Indiana Government Center North P.O. Box 6015 Indianapolis, IN 46206-6015 In State (800) 451-0627, ext. 28172 Out of State (317) 232-8172 Iowa
William Zitterich, P.E., Director Iowa Emergency Response Commission IA DOT Office of Maintenance Services 800 Lincoln Way Ames, IA 50010 (515) 239-1396 Walter Johnson, Vice-Chair Iowa Emergency Response Commission Iowa Division of Labor 1000 East Grand Avenue Des Moines, IA 50319 (515) 281-8460 Paul Sadler Program Planner Emergency Management Division Hoover State Office Building, Level A Des Moines, IA 50319 (515) 242-5171 Pete Hamlin, Chief Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road Urbandale, IA 50322 (SIS) 281-8852 Anne Jackson St. Industrial Hygienist Iowa Division of Labor 1000 East Grand Avenue Des Moines, IA 50319 (515) 281-8460 Kansas
Bob Barid General Motors 3201 Fairfax Traffic Way
Kansas City, KS 66115 (913) 573-7303 Jon Flint, Section Chief Kansas Emergency Response Commission Right-To-Know Program J Street and 2 North, Forbes Field Building 283 Topeka, KS 66620 (913) 296-1690 Frank Moussa Kansas Division of Emergency Management State Defense Building 2800 South West Topeka Blvd. Topeka, KS 6661 I-1287 (913) 274-1409 Kentucky Ron Padgett, Executive Director Kentucky Emergency Response Commission Kentucky Disaster and Emergency Services Boone National Guard Center Frankfort, KY 40601-6168 (502) 564-8681 Lucille Orlando, Branch Mgr. for Technological Hazards Kentucky Emergency Response Commission Kentucky Disaster and Emergency Services Boone National Guard Center Frankfort, KY 40601-6168 (502) 564-5223 Alex Barber Kentucky Department for Environmental Protection 14 Reilly Road Frankfort, KY 4060 I-I 132 (502) 564-2150 Louisiana
Captain Mark S. Oxley, Chairman Louisiana Emergency Response Commission Office of State Police, Right-To-Know Unit 7901 Independence Boulevard Building A
414 Baton Rouge, LA 70806 (504) 925-6113 Robert Hayes, Management Analyst Louisiana Emergency Response Commission Office of State Police, Right-To-Know Unit 7901 Independence Boulevard Building A Baton Rouge, LA 70806 (504) 925-6113 Linda Brown, TRI Coordinator Department of Environmental Quality Office of the Secretary P.O. Box 82263 Baton Rouge, LA 70884-2263 (504) 765-0737
Maine John W. Libby, Chairman State Emergency Response Commission 72 State House Station Augusta, ME 04333 In State: (800) 452-8735 Out of State: (207) 287-4080 Rayna Leibowitz State Emergency Response Commission 72 State House Station Augusta, ME 04333 In State (800) 452-8735 Out of State (207) 287-4080
Maryland David McMillian, Chairman Governor's Emergency Management Advisory Council c/o Maryland Emergency Management Agency 2 Sudbrook Lane East Pikesville, MD 21208 (410) 486-4422 Patricia Williams, Environmental Specialist Maryland Department of the Environment Technical and Regulatory Services Administration
Appendix F Community Right-To-Know Section 2500 Broening Highway Baltimore, MD 21224 (410) 631-3800
Massachusetts Kathleen O'Toole, Chair Secretary of Public Safety Massachusetts Emergency Response Commission Executive Office of Public Safety One Asburton Place, Room 2133 Boston, MA 02108 (617) 727-7725 Douglas Forbes Massachusetts Emergency Management Agency P.O. Box 1496 400 Worcester Road Framingham, MA 01701-0317 (508) 820-2040 William Panos Massachusetts Department of Environmental Protection Bureau of Waste Prevention Toxics Use Reduction Program I Winter Street Boston, MA 02108 (617) 292-5870
Michigan Captain Robert Tarrant, Chair Michigan State Police 4000 Collins Road P.O. Box 30636 Lansing, MI 48909-8136 (517) 333-5041 Robert Jackson, Chief, Grants & Information State Emergency Response Commission Michigan Department of Environmental Quality Environmental Assistance Division, Title III Office 300 South Washington
415
State EmergencyResponseCommittees P.O. Box 30457 Lansing, MI 48909 (517) 373-8481 Minnesota Dennis Shershen, Chair State Emergency Response Commission Truth Hardware Corporation 700 West Bridge Street Owatonna, MN 55060 (507) ~,4-~81
Paul Aasen Minnesota Emergency Response Commission Room B-5 State Capitol Building 75 Constitution Avenue St. Paul, MN 55155
(612) 282-5391 Steve Tomlyanovich Minnesota Emergency Response Commission Room B-5 State Capitol Building 75 Constitution Avenue St. Paul, MN 55155 (612) 282-5396 Mississippi J.E. Maher, Chairman Mississippi Emergency Response Commission Mississippi Emergency Management Agency P.O. Box 4501 Jackson, MS 39296-4501
(601) 960-9000 John David Burns or Chuck Carter Plan Operations Manager Mississippi Emergency Response Commission Mississippi Emergency Management Agency P.O. Box 4501 Jackson, MS 39296-4501 (601) 960-9000
Missouri Bob Dopp, Executive Chief Missouri Emergency Response Commission P.O. Box 3133 Jefferson City, MO 65102 (573) 526-9237
Eugene Nickel Missouri Department of Natural Resources Technical Assistance Program P.O. Box 176 Jefferson City, MO 65102 (573) 526-6627 Montana Tom Ellerhoff, Chairman Montana Emergency Response Commission ESD/DHES Metcalf Building 1520 E. 6th Avenue P.O. Box 200901 Helena, MT 59620-0901 (406) 444-5263
Jim Greene Disaster Emergency Services II 00 North Main P.O. Box 4789 Helena, MT 59604-4789 (406) 444-6911 Nebraska Major General Stanley M. Heng, Chairman Nebraska Emergency Response Commission 1300 Military Road Lincoln, NE 68508-1090 (402) 471-7100
Dale Bush, Interim Coordinator Nebraska Department of Environmental Quality P.O. Box 98922 State House Station Lincoln, NE 68509-8922 (402) 471-4237
416 Dave Kudmore Nebraska Emergency Management Agency 1300 Military Road Lincoln, NE 68508-1090 (402) 471-7420 Mike Mallory State of Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 (402) 471-4230
Nevada Marvin Carr State Emergency Response Commission 555 Wright Way Carson City, NV 89711-0925 (702) 687-6973 Division of Emergency Management 2525 South Carson Street Carson City, NV 89710 (702) 687-4240 Larry W. Bennett Co-Chair of SERC Southern Pacific Transportation Co. 50 Washington Street Suite 101 Reno, NV 89530 (702) 323-3688 Karen I_arson Co-Chair of SERC Clark County Manager's Office 500 South Grand Central Parkway Las Vegas, NV 89155-I I I I (702) 455-6186
New Hampshire George L. Iverson, Director New Hampshire Office of Emergency Management Title III Program State Office Park South 107 Pleasant Street
Appendix F Concord, NH 03301 (603) 271-2231 Leland Kimball State Emergency Management Agency Title III Program State Office Park South 107 Pleasant Street Concord, NH 03301-3809 (603) 271-2231
New Jersey Shirlee Schiffman, Chief NJ Department of Environmental Protection Bureau of Chemical Release Information and Prevention Health and Analytical Programs 401 East State Street, CN 405 Trenton, NJ 08625 (609) 984-3219 Stan Delikat Director of Responsible Party Site Remediation Bureau of Emergency Response 401 East State Street CN-028 Trenton, NJ 08625 (609) 633-2168 Alan Bookman NJ Department of Environmental Protection and Energy Bureau of Chemical Release Information and Prevention Health and Analytical Programs 401 East State Street, CN-405 Trenton, NJ 08625 (609) 984-5338 Andrew Opperman Department of Environmental Protection Health and Analytical Programs SARA Title III Section 313 Bureau of Chemical Release Information and Prevention 401 East State Street, CN-405 Trenton, NJ 08625 (609) 984-3219
417
State EmergencyResponseCommittees New Mexico
North Carolina
Ray Denison, Chairman New Mexico Emergency Response Commission New Mexico Department of Public Safety P.O. Box 1628 Santa Fe, NM 87504-1628 (505) 827-3376
Billy Camaron, Chairman North Carolina Emergency Response Commission North Carolina Division of Emergency Management 116 West Jones Street Raleigh, NC 27603-1335 (919) 733-3825
Max Johnson, Coordinator New Mexico Emergency Response Commission Technological Hazards Bureau Emergency Management P.O. Box 1628 Santa Fe, NM 87504-1628 (SOS) 476-9620 New York
Major General John Fenimore, Vice Chairman New York Emergency Response Commission State Emergency Management Office Building 22, Suite 101 1220 Washington Avenue Albany, NY 12226-225 I (518) 457-2222 New York Emergency Response Commission NY State Department of Environmental Conservation Bureau of Spill Prevention and Response 50 Wolf Road Room 340 Albany, NY 12233-3510 Bill Eberle New York Emergency Response Commission NY State Department of Environmental Conservation Bureau of Spill Prevention and Response 50 Wolf Road Room 340 Albany, NY 12233-3510 (518) 457-7267
Esther Castaldo North Carolina Emergency Response Commission North Carolina Division of Emergency Management II 6 West Jones Street Raleigh, NC 27603-1335 (919) 733-3899 North Dakota
Lyle Gallagher, Director of Communications State Radio Communications Department P.O. Box 5511 Bismarck, ND 58506 (701) 328-2121 Douglas C. Friez, Chairman State Division of Emergency Management P.O. Box 5511 Bismarck, ND 58506-5511 (701) 328-3300 Robert Johnston North Dakota Emergency Response Commission Division of Emergency Management P.O. Box 5511 Bismarck, ND 58506-5511 (701) 328-211 I Northern Mariana Islands
Felix Sasamoto, Civil Defense Coordinator Office of the Governor Commonwealth of Northern Mariana Islands Capitol Hill Saipan, MP 96950 (670) 322-9529
418 John Castro Division of Environmental Quality Commonwealth of the Northern Mariana Islands Doctor Torres Hospital P.O. Box 1304 Saipan, MP 96950 (670) 234-6984
Ohio Dale Shipley, Co-Chair State Emergency Response Commission Ohio Emergency Management Agency 2855 West Dublin-Granville Road Columbus, OH 43235-2206 (614) 889-7150 Ken Shultz, Co-Chair Ohio Emergency Response Commission Ohio Environmental Protection Agency P.O. Box 13669 Columbus, OH 43216-3669 (614) 644-2081 Jeff Beattie Ohio Emergency Response Commission Ohio Environmental Protection Agency Office of Emergency Response 1800 Watermark Drive Columbus, OH 43215-1099 (614) 644-2081 Cindy Dewulf Ohio Environmental Protection Agency Division of Air Pollution Control 1800 Watermark Drive Columbus, OH 43216 (614) 644-3606
Oklahoma Monty Elder Department of Environmental Quality Customer Services 1000 North East Tenth Street Oklahoma City, OK 73117-1212 (405) 271-1400 ext. 192
Appendix F Lynne Moss Department of Environmental Quality 1000 N.E. 10th Street Oklahoma City, OK 73117-1212 (405) 271-7363
Oregon Jim Mazza, Liaison c/o Department of State Police Oregon Emergency Management 595 Cottage Street, NE Salem, OR 97310 (503) 378-2911 ext. 239 Bob Albers Oregon Emergency Response Commission c/o State Fire Marshall 4760 Portland Road, NE Salem, OR 97305-1760 (503) 378-3473 Ext. 262
Pennsylvania Lt. Governor Mark S. Schweiker, Chairman Pennsylvania Emergency Management Council P.O. Box 3321 Harrisburg, PA 17105-3321 (717) 651-2001 Robert F. Broyles, Chief Chemical Emergency Preparedness Division Pennsylvania Emergency Management Agency P.O. Box 3321 Harrisburg, PA 17105-332 I (717) 651-2199 Thomas Ward or Lynn Snead Pennsylvania Emergency Management Council Bureau of Worker and Community Right-To-Know Room 1503 Labor and Industry Building 7th and Forster Streets Harrisburg, PA 17120 (717) 783-2071
419
State EmergencyResponseCommittees Puerto Rico
South Carolina
Hector Russe Martinez, Chairman Puerto Rico Emergency Response Commission Environmental Quality Board
Stan M. McKinney, Chairman South Carolina Emergency Response Commission c/o Emergency Preparedness Division 1429 Senate Street Columbia, SC 29201 (803) 734-8020
P.O. Box I 1488
Santurce, PR 00910 (787) 767-8056 Genaro Torres Director of Superfund and Emergency Division Title III - SARA Section 313 Puerto Rico Environmental Quality Board Sernades Junco Station P.O. Box 11488 Santurce, PR 00910 (809) 766-8056 Rhode Island
Raymond LaBelle, Executive Director Rhode Island Emergency Response Commission State House Room 27 Providence, RI 02903 (401) 277-3039 John Aucott Rhode Island Emergency Response Commission State House Room 27 Providence, RI 02903 (401) 946-9996 Patrice Carvaretta Rhode Island Department of Labor Division of Occupational Safety 610 Manton Avenue Providence, RI 02909 (401) 457-1829 Martha Delaney Mulcahey Rhode Island Department of Environmental Management Division of Air Resources 291 Promenade Street Attn: Toxic Release Inventory Providence, RI 02908-5767 (401) 277-2808
John Berzins South Carolina Emergency Response Commission c/o Emergency Preparedness Division 1429 Senate Street Columbia, SC 29201 (803) 734-8020 Michael Juras South Carolina State Emergency Response Comm. EPCRA Reporting Point SC Department of Health & Environmental Control 2600 Bull Street Columbia, SC 29201 (803) 896-4117 Peter Saussy SC State Emergency Response Commission SC Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 (803) 896-4116 South Dakota
Bob McGrath South Dakota Emergency Response Commission South Dakota Department of Environmental & Natural Resources Joe Foss Building 523 East Capitol Pierre, SD 57501-3181 (605) 773-3296
420 Lee Ann Smith, Title III Coordinator South Dakota Emergency Response Commission South Dakota Department of Environmental & Natural Resources Joe Foss Building 523 East Capitol Pierre, SD 57501-3181 (605) 773-3296 Tennessee
John White, Chairman Tennessee Emergency Response Commission Tennessee Emergency Management Agency 3041 Sidco Drive Nashville, TN 37204 (615) 741-0001 Betty Eaves, Director Tennessee Emergency Management Agency 3041 Sidco Drive Nashville, TN 37204 (615) 741-2986 Texas
Russ Lecklider, Co-Chair Texas Emergency Response Commission P.O. Box 4087 Austin, TX 78773-0226 (512) 424-2429 Philip Moore, Co-Chair Texas Emergency Response Commission P.O. Box 4087 Austin, TX 78773-0226 (512) 424-2454 David Barker Emergency Response Team (MC 142) Texas Natural Resource Conservation Commission Room 241 P.O. Box 13087 Austin, TX 78711 (512) 463-7727
Appendix F Annabelle Dillard Texas Department of Health Hazard Communication Branch II 00 West 49th Street Austin, TX 78756 In State: (800) 452-2791 Out of State: (512) 834-6603 302 Becky Kurka, TRI Coordinator Office of Pollution Prevention and Recycling Texas Natural Resources Conservation Commission P.O. Box 13087 (MC II 2) Austin, TX 78711-3087 (512) 239-3100 Utah
Lorayne Frank, Director, Co-Chairperson Department of Public Safety Division of Comprehensive Emergency Management III0 State Office Building Salt Lake City, UT 84114 (801) 538-3400 Jerry Nortin Division of Comprehensive Emergency Management III0 State Office Building Salt Lake City, UT 84114 (801) 538-3774 Neil Taylor State Emergency Response Commission Utah Department of Environmental Quality Division of Environmental Response & Remediation 168 North 1950 West, I st Floor Salt Lake City, UT 84116 (801) 536-4102, or 536-4107 (SteveThiriot) Vermont
George Lowe Vermont Emergency Management Department of Public Safety 103 South Main Street
421
State EmergencyResponseCommittees Waterbury, VT 05676 (802) 244-8721 Randy Bronson Department of Public Safety 103 S. Main Street Waterbury, VT 05676 (802) 244-8721 Paul Van Hollebeke Vermont Department of Environmental Conservation Pollution Prevention Section 103 S. Main Street Waterbury, V-I" 05671-041 I (802) 241-3629
Virgin Islands Austin Moorehead Department of Planning& Natural Resources Division of Environmental Protection Watergut Homes 1118 Christiansteb St. Croix, VI 00820-5065 (809) 773-0565
Virginia Addison Slayton,Jr., Chair Virginia Emergency Response Commission Virginia Department of Emergency Services 310 Turner Road Richmond, VA 23225 (804) 674-2497 Cathy Harris Virginia Emergency Response Council c/o Virginia Department of Environmental Quality P.O. Box 10009 Richmond, VA 23240-0009 (804) 698-4480 or 4489
Washington Chief Robert Johnson Auburn Fire Department 1101 D Street NE Auburn, WA 98002 (206) 931-3060
John Ridgwayor Sadie Whitener CRTK Unit Department of Ecology P.O. Box 47659 Olympia, WA 98504-7659 (360) 407-6713,407-6729; or (800) 633-7585 Idell Hansen, Supervisor CRTK Unit Department of Ecology P.O. Box 47659 Olympia, WA 98504-7659 (360) 407-6727 or (800) 633-7585
West Virginia Carl L. Bradford, Director West Virginia Emergency Response Commission West Virginia Office of Emergency Services Main Capitol Building I Room EB-80 Charleston, WV 25305-0360 (304) 558-5380
Wisconsin Steven D. Sell, Chair State Emergency Response Board Division of Emergency Government P.O. Box 7865 2400 Wright Street Madison, WI 53707-7865 (608) 242-3232 William Clare State Emergency Response Board 2400 Wright Street Madison, WI 53707-7865 (608) 242-3232 Wess Taylor, 313 Coordinator Department of Natural Resources 101 South Webster P.O. Box 7921 Madison, WI 53707 (608) 264-6043
422
Wyoming Pete IIIoway,Chair Wyoming EmergencyResponse Commission Wyoming EmergencyManagementAgency 5500 Bishop Blvd. Cheyenne,VVY 82009-3320 (307) 777-4900
Appendix F Bob Bezek Wyoming EmergencyResponse Commission Wyoming EmergencyManagement Agency 5500 Bishop Blvd. Cheyenne,WY 82009-3320 (307) 777-4900
FEMA EMERGENCY MANAGEMENT GUIDE FOR BUSINESS A N D INDUSTRY
A step-by-stepapproach to emergencyplanning, response, and recovery for companies of all sizes. Sponsored by a Public-Private Partnership with the Federal EmergencyManagement Agency.
INTRODUCTION
A hurricane blasts through South Florida causing more than $25 billion in damages. A fire at a food processing plant results in 25 deaths, a company out of business, and a small town devastated. A bombing in the World Trade Center results in six deaths, hundreds of injuries, and the evacuation of 40,000 people. A blizzard shuts down much of the East Coast for days. More than 150 lives are lost and millions of dollars in damages incurred. Every year emergencies take their toll on business and i n d u s t r y ~ i n lives and dollars. But something can be done. Business and industry can limit injuries and damages and return more quickly to normal operations if they plan ahead.
About This Guide
This guide provides step-by-step advice on how to create and maintain a comprehensive emergency management program. It can be used by 423
424
Appendix G
manufacturers, corporate offices, retailers, utilities, or any organization where a sizable number of people work or gather. Whether you operate from a high-rise building or an industrial complex, whether you own, rent, or lease your property, whether you are a large or small company the concepts in this guide will apply. To begin, you need not have in-depth knowledge of emergency management. What you need is the authority to create a plan and a commitment from the chief executive officer to make emergency management part of your corporate culture. If you already have a plan, use this guide as a resource to assess and update your plan. The guide is organized as follows: 9 Section 1:4 Steps in the Planning P r o c e s s ~ h o w to form a planning team; how to conduct a vulnerability analysis; how to develop a plan; and how to implement the plan. The information can be applied to virtually any type of business or industry. 9 Section 2: Emergency Management C o n s i d e r a t i o n s ~ h o w to build such emergency management capabilities as life safety, property protection, communications, and community outreach. 9 Section 3: Hazard-Specific Information'~technical information about specific hazards your facility may face. ~ Section 4: Information Sources~where to turn for additional information.
W h a t Is an Emergency?
An emergency is any unplanned event that can cause deaths or significant injuries to employees, customers, or the public, or that can shut down your business, disrupt operations, cause physical or environmental damage, or threaten the facility's financial standing or public image. Obviously, numerous events can be "emergencies," including: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.
Fire Hazardous materials incident Flood or flash flood Hurricane Tornado Winter storm Earthquake Communications failure Radiological accident Civil disturbance
Introduction
425
11. Loss of key supplier or customer 12. Explosion The term "disaster" has been left out of this document because it lends itself to a preconceived notion of a large-scale event, usually a "natural disaster." In fact, each event must be addressed within the context of the impact it has on the company and the community. What might constitute a nuisance to a large industrial facility could be a "disaster" to a small business.
What Is Emergency Management? Emergency management is the process of preparing for, mitigating, responding to, and recovering from an emergency. Emergency management is a dynamic process. Planning, though critical, is not the only component. Training, conducting drills, testing equipment, and coordinating activities with the community are other important functions.
Making the "Case" for Emergency Management To be successful, emergency management requires upper management support. The chief executive sets the tone by authorizing planning to take place and directing senior management to get involved. When presenting the "case" for emergency management, avoid dwelling on the negative effects of an emergency (e.g., deaths, fines, criminal prosecution) and emphasize the positive aspects of preparedness. For example: 1. It helps companies fulfill their moral responsibility to protect employees, the community, and the environment. 2. It facilitates compliance with regulatory requirements of federal, state, and local agencies. 3. It enhances a company's ability to recover from financial losses, regulatory fines, loss of market share, damages to equipment or products, or business interruption. 4. It reduces exposure to civil or criminal liability in the event of an incident. 5. It enhances a company's image and credibility with employees, customers, suppliers, and the community. 6. It may reduce your insurance premiums.
426
Appendix G
S E C T I O N l - - F O U R STEPS IN T H E P L A N N I N G PROCESS
Step Step Step Step
l~Establish a Planning Team 2~Analyze Capabilities and Hazards 3~Develop the Plan 4~Implement the Plan
Step I---Establish a Planning Team
There must be an individual or group in charge of developing the emergency management plan. The following is guidance for making the appointment. 1. Form the Team: The size of the planning team will depend on the facility's operations, requirements and resources. Involving a group of people is usually best because: a. It encourages participation and gets more people invested in the process. b. It increases the amount of time and energy participants are able to give. c. It enhances the visibility and stature of the planning process. d. It provides for a broad perspective on the issues. Determine who can be an active member and who can serve in an advisory capacity. In most cases, one or two people will be doing the bulk of the work. At the very least, you should obtain input from all functional areas. Remember: a. b. c. d. e. f. g. h. i. j. k. 1.
Upper management Line management Labor Human Resources Engineering and maintenance Safety, health, and environmental affairs Public information officer Security Community relations Sales and marketing Legal Finance and purchasing
Have participants appointed in writing by upper management. Their job descriptions could also reflect this assignment.
Section I-Four Steps in the PlanningProcess
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2. Establish Authority: Demonstrate management's commitment and promote an atmosphere of cooperation by "authorizing" the planning group to take the steps necessary to develop a plan. The group should be led by the chief executive or the plant manager. Establish a clear line of authority between group members and the group leader, though not so rigid as to prevent the free flow of ideas. 3. Issue a Mission Statement: Have the chief executive or plant manager issue a mission statement to demonstrate the company's commitment to emergency management. The statement should: Define the purpose of the plan and indicate that it will involve the entire organization Define the authority and structure of the planning group 4. Establish a Schedule and Budget: Establish a work schedule and planning deadlines. Timelines can be modified as priorities become more clearly defined. Develop an initial budget for such things as research, printing, seminars, consulting services, and other expenses that may be necessary during the development process.
Step 2 - - A n a l y z e Capabilities and Hazards
This step entails gathering information about current capabilities and about possible hazards and emergencies, and then conducting a vulnerability analysis to determine the facility's capabilities for handling emergencies. I. Where Do You Stand Right Now?
Review internal plans and policies. Documents to look for include: a. b. c. d. e. f. g. h. i. j. k. 1.
Evacuation plan Fire protection plan Safety and health program Environmental policies Security procedures Insurance programs Finance and purchasing procedures Plant closing policy Employee manuals Hazardous materials plan Process safety assessment Risk management plan
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m. Capital improvement program n. Mutual aid agreements 2. Meet with Outside Groups
Meet with government agencies, community organizations, and utilities. Ask about potential emergencies and about plans and available resources for responding to them. Sources of information include: a. b. c. d. e. f. g. h. i. j. k. 1. m.
Community emergency management office Mayor or Community Administrator's office Local Emergency Planning Committee (LEPC) Fire Department Police Department Emergency Medical Services organizations American Red Cross National Weather Service PublicWorks Department Planning Commission Telephone companies Electric utilities Neighboring businesses
3. Identify Codes and Regulations Identify applicable federal, state, and local regulations such as: a. b. c. d. e. f. g.
Occupational safety and health regulations Environmental regulations Fire codes Seismic safety codes Transportation regulations Zoning regulations Corporate policies
4. Identify Critical Products, Services, and Operations
You'll need this information to assess the impact of potential emergencies and to determine the need for backup systems. Areas to review include: a. Company products and services and the facilities and equipment needed to produce them
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b. Products and services provided by suppliers, especially sole source vendors c. Lifeline services such as electrical power, water, sewer, gas, telecommunications, and transportation d. Operations, equipment, and personnel vital to the continued functioning of the facility 5. Identify Internal Resources and Capabilities
Resources and capabilities that could be needed in an emergency include: a. Personnel--fire brigade, hazardous materials response team, emergency medical services, security, emergency management group, evacuation team, public information officer b. Equipment--fire protection and suppression equipment, communications equipment, first aid supplies, emergency supplies, warning systems, emergency power equipment, decontamination equipment c. Facilitieswemergency operating center, media briefing area, shelter areas, first-aid stations, sanitation facilities d. Organizational capabilities--training, evacuation plan, employee support system e. Backup systemswarrangements with other facilities to provide for: 1. 2. 3. 4. 5. 6. 7. 8.
Payroll Communications Production Customer services Shipping and receiving Information systems support Emergency power Recovery support
6. Identify External Resources There are many external resources that could be needed in an emergency. In some cases, formal agreements may be necessary to define the facility's relationship with the following: a. b. c. d. e.
Local emergency management office Fire Department Hazardous materials response organization Emergency medical services Hospitals
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f. g. h. i. j. k.
Local and State police Community service organizations Utilities Contractors Suppliers of emergency equipment Insurance carriers
7. Do an Insurance Review
Meet with insurance carriers to review all policies. (See Section 2: Recovery and Restoration.) 8. Conduct a Vulnerability Analysis
The next step is to assess the vulnerability of your facility--the probability and potential impact of each emergency. Use the Vulnerability Analysis Chart on p. 70 of this book to guide the process, which entails assigning probabilities, estimating impact, and assessing resources, using a numerical system. The lower the score the better. 9. List Potential Emergencies
In the first column of the chart, list all emergencies that could affect your facility, including those identified by your local emergency management office. Consider both: a. Emergencies that could occur within your facility, and b. Emergencies that could occur in your community. Below are some other factors to consider: HistoricalmWhat types of emergencies have occurred in the community, at this facility, and at other facilities in the area? a. b. c. d. e. f. g. h. i.
Fires Severe weather Hazardous material spills Transportation accidents Earthquakes Hurricanes Tornadoes Terrorism Utility outages
GeographicmWhat can happen as a result of the facility's location? Keep in mind:
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a. Proximity to flood plains, seismic faults, and dams b. Proximity to companies that produce, store, use, or transport hazardous materials c. Proximity to maior transportation routes and airports d. Proximity to nuclear power plants Technological--What could result from a process or system failure? Possibilities include: a. b. c. e. f. g. h.
Fire, explosion, hazardous materials incident Safety system failure Telecommunications failure Computer system failure Power failure Heating/cooling system failure Emergency notification system failure
Human Error--What emergencies can be caused by employee error? Are employees trained to work safely? Do they know what to do in an emergency? Human error is the single largest cause of workplace emergencies and can result from: a. b. c. d. e. f.
Poor training Poor maintenance Carelessness Misconduct Substance abuse Fatigue
Physical--What types of emergencies could result from the design or construction of the facility? Does the physical facility enhance safety? Consider: a. b. c. d. e. f. g.
The physical construction of the facility Hazardous processes or by-products Facilities for storing combustibles Layout of equipment Lighting Evacuation routes and exits Proximity of shelter areas
Regulatory--What emergencies or hazards are you regulated to deal with? Analyze each potential emergency from beginning to end. Consider what could happen as a result of: a. Prohibited access to the facility b. Loss of electric power
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c. e. f. g. h. i. j. k. 1. m.
Communication lines down Ruptured gas mains Water damage Smoke damage Structural damage Air or water contamination Explosion Building collapse Trapped persons Chemical release
10. Estimate Probability In the Probability column, rate the likelihood of each emergency's occurrence. This is a subjective consideration, but useful nonetheless. Use a simple scale of I to 5 with 1 as the lowest probability and 5 as the highest. I I. Assess the Potential Human Impact
Analyze the potential human impact of each emergency--the possibility of death or injury. Assign a rating in the Human Impact column of the Vulnerability Analysis Chart. Use a 1 to 5 scale with 1 as the lowest impact and 5 as the highest. 12. Assess the Potential Property Impact
Consider the potential property for losses and damages. Again, assign a rating in the Property Impact column, 1 being the lowest impact and 5 being the highest. Consider: a. Cost to replace b. Cost to set up temporary replacement c. Cost to repair
13. Assess the Potential Business Impact Consider the potential loss of market share. Assign a rating in the Business Impact column. Again, 1 is the lowest impact and 5 is the highest. Assess the impact of: a. b. c. d.
Business interruption Employees unable to report to work Customers unable to reach facility Company in violation of contractual agreements
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e. Imposition of fines and penalties or legal costs f. Interruption of critical supplies g. Interruption of product distribution
14. Assess Internal and External Resources Next, assess your resources and ability to respond. Assign a score to your Internal Resources and External Resources. The lower the score the better. To help you do this, consider each potential emergency from beginning to end and each resource that would be needed to respond. For each emergency ask these questions: 9 Do we have the needed resources and capabilities to respond? 9 Will external resources be able to respond to us for this emergency as quickly as we may need them, or will they have other priority areas to serve? If the answers are yes, move on to the next assessment. If the answers are no, identify what can be done to correct the problem. For example, you may need to: a. b. c. d. e.
Develop additional emergency procedures Conduct additional training Acquire additional equipment Establish mutual aid agreements Establish agreements with specialized contractors
15. Add the Columns
Total the scores for each emergency. The lower the score the better. While this is a subjective rating, the comparisons will help determine planning and resource prioritiesmthe subject of the pages to follow.
Step 3---Develop the Plan You are now ready to develop an emergency management plan. This section describes how. Plan Components
Your plan should include the following basic components. 1. Executive Summary The executive summary gives management a brief overview of: the purpose of the plan, the facility's emergency
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management policy, authorities and responsibilities of key personnel, the types of emergencies that could occur, and where response operations will be managed. 2. Emergency Management Elements This section of the plan briefly describes the facility's approach to the core elements of emergency management, which are: a. b. c. d. e. f. g.
Direction and control Communications Life safety Property protection Community outreach Recoveryand restoration Administration and logistics.
These elements, which are described in detail in Section 2, are the foundation for the emergency procedures that your facility will follow to protect personnel and equipment and resume operations. 3. Emergency Response Procedures The procedures spell out how the facility will respond to emergencies. Whenever possible, develop them as a series of checklists that can be quickly accessed by senior management, department heads, response personnel, and employees. Determine what actions would be necessary to: a. Assess the situation b. Protect employees, customers, visitors, equipment, vital records, and other assets, particularly during the first 3 days c. Get the business back up and running Specific procedures might be needed for any number of situations such as bomb threats or tornadoes, and for such functions as: a. Warning employees and customers b. Communicating with personnel and community responders c. Conducting an evacuation and accounting for all persons in the facility d. Managing response activities e. Activating and operating an emergency operations center f. Fighting fires g. Shutting down operations h. Protecting vital records i. Restoring operations
4. Support Documents Documents that could be needed in an emergency include:
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Emergency call lists--lists (wallet size if possible) of all persons on and off site who would be involved in responding to an emergency, their responsibilities, and their 24-hour telephone numbers. Building and site maps that indicate: a. b. c. d. e. f. g. h. i. j. k. 1. m. n. o. p. q. r. s. t. u.
Utility shutoffs Water hydrants Water main valves Water lines Gas main valves Gas lines Electrical cutoffs Electrical substations Storm drains Sewer lines Location of each building (include name of building, street name and number) Floor plans Alarm and enunciators Fire extinguishers Fire suppression systems Exits Stairways Designated escape routes Restricted areas Hazardous materials (including cleaning supplies and chemicals) High-value items
S. Resource Lists These are lists of major resources (equipment, supplies, services) that could be needed in an emergency, and mutual aid agreements with other companies and government agencies. The Development Process The following is guidance for developing the plan. 1. Identify Challenges and Prioritize Activities Determine specific goals and milestones. Make a list of tasks to be performed, by whom and when. Determine how you will address the problem areas and resource shortfalls that were identified in the vulnerability analysis. 2. Write the Plan Assign each member of the planning group a section to write. Determine the most appropriate format for each section. Establish an aggressive timeline with specific goals. Provide enough time for completion of work, but not so much as to allow assignments to linger. Establish a schedule for:
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a. b. c. d. e. f. g.
First draft Review Second draft Table-top exercise Final draft Printing Distribution
3. Establish a Training Schedule Have one person or department responsible for developing a training schedule for your facility. For specific ideas about training, refer to Step 4. 4. Coordinate with Outside Organizations Meet periodically with local government agencies and community organizations. Inform appropriate government agencies that you are creating an emergency management plan. While their official approval may not be required, they will likely have valuable insights and information to offer. Determine state and local requirements for reporting emergencies, and incorporate them into your procedures. Determine protocols for turning control of a response over to outside agencies. Some details that may need to be worked out are: a. b. c. d. e.
Which gate or entrance will responding units use? Where and to whom will they report? How will they be identified? How will facility personnel communicate with outside responders? Who will be in charge of response activities?
Determine what kind of identification authorities will require to allow your key personnel into your facility during an emergency. S. Maintain Contact with Other Corporate Offices Communicate with other offices and divisions in your company to learn: a. b. c. d.
Their emergency notification requirements The conditions where mutual assistance would be necessary How offices will support each other in an emergency Names, telephone numbers, and pager numbers of key personnel
Incorporate this information into your procedures. 6. Review, Conduct Training, and Revise Distribute the first draft to group members for review. Revise as needed. For a second review, conduct a table-top exercise with management and personnel who have a key emergency management responsibility. In a conference room setting, describe an emergency scenario and have participants discuss their responsibilities and how they would react to the situation. Based on this discussion, identify areas of confusion and overlap, and modify the plan accordingly.
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7. Seek Final Approval Arrange a briefing for the chief executive officer and senior management and obtain written approval. 8. Distribute the Plan Place the final plan in three-ring binders and number all copies and pages. Each individual who receives a copy should be required to sign for it and be responsible for posting subsequent changes. Determine which sections of the plan would be appropriate to show to government agencies (some sections may refer to corporate secrets or include private listings of names, telephone numbers, or radio frequencies). Distribute the final plan to:
a. b. c. d.
Chief executive and senior managers Key members of the company's emergency response organization Company headquarters Community emergency response agencies (appropriate sections)
Have key personnel keep a copy of the plan in their homes. Inform employees about the plan and training schedule.
Step 4--Implement the Plan Implementation means more than simply exercising the plan during an emergency. It means acting on recommendations made during the vulnerability analysis, integrating the plan into company operations, training employees, and evaluating the plan.
Integrate the Plan into Company Operations Emergency planning must become part of the corporate culture. Look for opportunities to build awareness; to educate and train personnel; to test procedures; to involve all levels of management, all departments and the community in the planning process; and to make emergency management part of what personnel do on a day-to-day basis. Test how completely the plan has been integrated by asking: a. How well does senior management support the responsibilities outlined in the plan? b. Have emergency planning concepts been fully incorporated into the facility's accounting, personnel, and financial procedures? c. How can the facility's processes for evaluating employees and defining job classifications better address emergency management responsibilities? d. Are there opportunities for distributing emergency preparedness information through corporate newsletters, employee manuals, or employee mailings?
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e. What kinds of safety posters or other visible reminders would be helpful? f. Do personnel know what they should do in an emergency? g. How can all levels of the organization be involved in evaluating and updating the plan? Conduct Training, Drills, and Exercises
Everyone who works at or visits the facility requires some form of training. This could include periodic employee discussion sessions to review procedures, technical training in equipment use for emergency responders, evacuation drills, and full-scale exercises. Below are basic considerations for developing a training plan. 1. Planning Considerations Assign responsibility for developing a training plan. Consider the training and information needs for employees, contractors, visitors, managers, and those with an emergency response role identified in the plan. Determine for a 12-month period: a. b. c. d. e.
Who will be trained? Who will do the training? What training activities will be used? When and where each session will take place? How the session will be evaluated and documented?
Use the Training Drills and Exercises Chart in the appendix section to schedule training activities or create one of your own. Consider how to involve community responders in training activities. Conduct reviews after each training activity. Involve both personnel and community responders in the evaluation process. 2. Training Activities Training can take many forms: a. Orientation and Education Sessions~These are regularly scheduled discussion sessions to provide information, answer questions, and identify needs and concerns. b. Table-Top Exercise~Members of the emergency management group meet in a conference room setting to discuss their responsibilities and how they would react to emergency scenarios. This is a cost-effective and efficient way to identify areas of overlap and confusion before conducting more demanding training activities. c. Walk-through Drill~The emergency management group and response teams actually perform their emergency response functions. This activity generally involves more people and is more thorough than a table-top exercise. d. Functional Drills~These drills test specific functions such as medical response, emergency notifications, and warning and communications
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procedures and equipment, though not necessarily at the same time. Personnel are asked to evaluate the systems and identify problem areas. e. Evacuation Drill--Personnel walk the evacuation route to a designated area where procedures for accounting for all personnel are tested. Participants are asked to make notes as they go along of what might become a hazard during an emergency, e.g., stairways cluttered with debris, smoke in the hallways. Plans are modified accordingly. f. Full-scale Exercise--A real-life emergency situation is simulated as closely as possible. This exercise involves company emergency response personnel, employees, management, and community response organizations. 3. Employee Training General training for all employees should address: a. b. c. d. e. f. g. h.
Individual roles and responsibilities Information about threats, hazards, and protective actions Notification, warning, and communications procedures Means for locating family members in an emergency Emergency response procedures Evacuation, shelter, and accountability procedures Location and use of common emergency equipment Emergency shutdown procedures
The scenarios developed during the vulnerability analysis can serve as the basis for training events. 4. Evaluate and Modify the Plan Conduct a formal audit of the entire plan at least once a year. Among the issues to consider are: a. How can you involve all levels of management in evaluating and updating the plan? b. Are the problem areas and resource shortfalls identified in the vulnerability analysis being sufficiently addressed? c. Does the plan reflect lessons learned from drills and actual events? d. Do members of the emergency management group and emergency response team understand their respective responsibilities? Have new members been trained? e. Does the plan reflect changes in the physical layout of the facility? Does it reflect new facility processes? f. Are photographs and other records of facility assets up to date? g. Is the facility attaining its training objectives? h. Have the hazards in the facility changed? i. Are the names, titles, and telephone numbers in the plan current? j. Are steps being taken to incorporate emergency management into other facility processes? k. Have community agencies and organizations been briefed on the plan? Are they involved in evaluating the plan?
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In addition to a yearly audit, evaluate and modify the plan at these times: a. b. c. d. e. f.
After each training drill or exercise After each emergency When personnel or their responsibilities change When the layout or design of the facility changes When policies or procedures change Remember to brief personnel on changes to the plan.
SECTION 2mEMERGENCY MANAGEMENT CONSIDERATIONS This section describes the core operational considerations of emergency management. They are: Direction and Control Communications Life Safety Property Protection Community Outreach Recovery and Restoration Administration and Logistics
Function: Direction and Control Someone must be in charge in an emergency. The system for managing resources, analyzing information, and making decisions in an emergency is called direction and control. The direction and control system described below assumes a facility of sufficient size. Your facility may require a less sophisticated system, though the principles described here will still apply. The configuration of your system will depend on many factors. Larger industries may have their own fire team, emergency medical technicians, or hazardous materials team, while smaller organizations may need to rely on mutual aid agreements. They may also be able to consolidate positions or combine responsibilities. Tenants of office buildings or industrial parks may be part of an emergency management program for the entire facility. I. EmergencyManagementGroup (EMG)
The EMG is the team responsible for the big picture. It controls all incident-related activities. The Incident Commander (IC) oversees the technical aspects of the response.
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The EMG supports the IC by allocating resources and by interfacing with the community, the media, outside response organizations, and regulatory agencies. The EMG is headed by the Emergency Director (ED), who should be the facility manager. The ED is in command and control of all aspects of the emergency. Other EMG members should be senior managers who have the authority to: a. b. c. d.
Determine the short- and long-term effects of an emergency Order the evacuation or shutdown of the facility Interface with outside organizations and the media Issue press releases
2. Incident Command System (ICS) The ICS was developed specifically for the fire service, but its principles can be applied to all emergencies. The ICS provides for coordinated response and a clear chain of command and safe operations. The Incident Commander (IC) is responsible for front-line management of the incident, for tactical planning and execution, for determining whether outside assistance is needed, and for relaying requests for internal resources or outside assistance through the Emergency Operations Center
(EOC). The IC can be any employee, but a member of management with the authority to make decisions is usually the best choice. The IC must have the capability and authority to: a. b. c. d. e. f. g. h.
Assume command Assess the situation Implement the emergency management plan Determine response strategies Activate resources Order an evacuation Oversee all incident response activities Declare that the incident is "over"
3. EmergencyOperations Center (EOC) The EOC serves as a centralized management center for emergency operations. Here, decisions are made by the EMG based upon information provided by the IC and other personnel. Regardless of size or process, every facility should designate an area where decision makers can gather during an emergency.
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The EOC should be located in an area of the facility not likely to be involved in an incident, perhaps the security department, the manager's ofrice, a conference room, or the training center. An alternate EOC should be designated in the event that the primary location is not usable. Each facility must determine its requirements for an EOC based upon the functions to be performed and the number of people involved. Ideally, the EOC is a dedicated area equipped with communications equipment, reference materials, activity logs, and all the tools necessary to respond quickly and appropriately to an emergency.
4. Planning Considerations To develop a direction and control system: a. Define the duties of personnel with an assigned role. Establish procedures for each position. Prepare checklists for all procedures. b. Define procedures and responsibilities for fire fighting, medical and health, and engineering. c. Determine lines of succession to ensure continuous leadership, authority, and responsibility in key positions. d. Determine equipment and supply needs for each response function. At a minimum, assign all personnel responsibility for: a. b. c. d. e.
Recognizing and reporting an emergency Warning other employees in the area Taking security and safety measures Evacuating safely Provide training
S. Security
Isolation of the incident scene must begin when the emergency is discovered. If possible, the discoverer should attempt to secure the scene and control access, but no one should be placed in physical danger to perform these functions. Basic security measures include: Closing doors or windows Establishing temporary barriers with furniture after people have safely evacuated Dropping containment materials (sorbent pads, etc.) in the path of leaking materials Closing file cabinets or desk drawers
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Only trained personnel should be allowed to perform advanced security measures. Access to the facility, the EOC, and the incident scene should be limited to persons directly involved in the response.
6. Coordination of Outside Response In some cases, laws, codes, prior agreements, or the very nature of the emergency require the IC to turn operations over to an outside response organization. When this happens, the protocols established between the facility and outside response organizations are implemented. The facility's IC provides the community's IC a complete report on the situation. The facility IC keeps track of which organizations are on-site and how the response is being coordinated. This helps increase personnel safety and accountability, and prevents duplication of effort.
Function: Communications
Communications are essential to any business operation. A communications failure can be a disaster in itself, cutting off vital business activities. Communications are needed to report emergencies, to warn personnel of the danger, to keep families and off-duty employees informed about what's happening at the facility to coordinate response actions, and to keep in contact with customers and suppliers.
I. Contingency Planning Plan for all possible contingencies from a temporary or short-term disruption to a total communications failure. Consider the everyday functions performed by your facility and the communications, both voice and data, used to support them. Consider the business impact if your communications were inoperable. How would this impact your emergency operations? Prioritize all facility communications. Determine which should be restored first in an emergency. Establish procedures for restoring communications systems. Talk to your communications vendors about their emergency response capabilities. Establish procedures for restoring services. Determine needs for backup communications for each business function. Options include messengers, telephones, portable microwave, amateur radios, point-to-point private lines, satellite, and high-frequency radio.
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2. Emergency Communications Consider the functions your facility might need to perform in an emergency and the communications systems needed to support them. Consider communications between: a. b. c. d. e. f. g. h. i.
Emergency responders Responders and the Incident Commander (IC) The IC and the Emergency Operations Center (EOC) The IC and employees The EOC and outside response organizations The EOC and neighboring businesses The EOC and employees' families The EOC and customers The EOC and media
Methods of communication include: a. b. c. d. e. f. g. h. i.
Messenger Telephone Two-way radio FAX machine Microwave Satellite Dial-up modems Local area networks Hand signals
3. Family Communications In an emergency, personnel will need to know whether their families are okay. Taking care of one's loved ones is always a first priority. Make plans for communicating with employees' families in an emergency. Also, encourage employees to: Consider how they would communicate with their families in case they are separated from one another or injured in an emergency. Arrange for an out-of-town contact for all family members to call in an emergency. Designate a place to meet family members in case they cannot get home in an emergency.
4. Notification Establish procedures for employees to report an emergency. Inform employees of procedures. Train personnel assigned specific notification tasks.
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Post emergency telephone numbers near each telephone, on employee bulletin boards, and in other prominent locations. Maintain an updated list of addresses and telephone and pager numbers of key emergency response personnel (from within and outside of the facility). Listen for tornado, hurricane, and other severe weather warnings issued by the National Weather Service. Determine government agencies' notification requirements in advance. Notification must be made immediately to local government agencies when an emergency has the potential to affect public health and safety. Prepare announcements that could be made over public address systems. 5. Warning
Establish a system for warning personnel of an emergency. The system should: a. Be audible to or within view of all people in the facility b. Have an auxiliary power supply c. Have a distinct and recognizable signal Make plans for warning persons with disabilities. For instance, a flashing strobe light can be used to warn hearing-impaired people. Familiarize personnel with procedures for responding when the warning system is activated. Establish procedures for warning customers, contractors, visitors, and others who may not be familiar with the facility's warning system. Test your facility's warning system at least monthly.
Function: Life Safety
Protecting the health and safety of everyone in the facility is the first priority during an emergency.
I. Evacuation Planning One common means of protection is evacuation. In the case of fire, an immediate evacuation to a predetermined area away from the facility may be necessary. In a hurricane, evacuation could involve the entire community and take place over a period of days. To develop an evacuation policy and procedure:
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a. Determine the conditions under which an evacuation would be necessary. b. Establish a clear chain of command. Identify personnel with the authority to order an evacuation. Designate "evacuation wardens" to assist others in an evacuation and to account for personnel. c. Establish specific evacuation procedures. Establish a system for accounting for personnel. Consider employees' transportation needs for community-wide evacuations. d. Establish procedures for assisting persons with disabilities and those who do not speak English. e. Post evacuation procedures. f. Designate personnel to continue or shut down critical operations while an evacuation is underway. They must be capable of recognizing when to abandon the operation and evacuate themselves. g. Coordinate plans with the local emergency management office.
2. Evacuation Routes and Exits
Designate primary and secondary evacuation routes and exits. Have them clearly marked and well lit. Post signs. Install emergency lighting in case a power outage occurs during an evacuation. Ensure that evacuation routes and emergency exits are: a. b. c. d.
Wide enough to accommodate the number of evacuating personnel Clear and unobstructed at all times Unlikely to expose evacuating personnel to additional hazards Have evacuation routes evaluated by someone not in your organization.
3. Assembly Areas and Accountability Obtaining an accurate account of personnel after a site evacuation requires planning and practice. Designate assembly areas where personnel should gather after evacuating. Take a head count after the evacuation. The names and last known locations of personnel not accounted for should be determined and given to the EOC. (Confusion in the assembly areas can lead to unnecessary and dangerous search and rescue operations.) Establish a method for accounting for non-employees such as suppliers and customers.
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Establish procedures for further evacuation in case the incident expands. This may consist of sending employees home by normal means or providing them with transportation to an off-site location. 4. Shelter In some emergencies, the best means of protection is to take shelter either within the facility or away from the facility in a public building. Consider the conditions for taking shelter, e.g., tornado warning. Identify shelter space in the facility and in the community. Establish procedures for sending personnel to shelter. Determine needs for emergency supplies such as water, food, and medical supplies. Designate shelter managers, if appropriate. Coordinate plans with local authorities. 5. Training and Information Train employees in evacuation, shelter, and other safety procedures. Conduct sessions at least annually or when: a. Employees are hired b. Evacuation wardens, shelter managers, and others with special assignments are designated c. New equipment, materials, or processes are introduced d. Procedures are updated or revised e. Exercises show that employee performance must be improved Provide emergency information such as checklists and evacuation maps. Post evacuation maps in strategic locations. Consider the information needs of customers and others who visit the facility. 6. Family Preparedness Consider ways to help employees prepare their families for emergencies. This will increase their personal safety and help the facility get back up and running. Those who are prepared at home will be better able to carry out their responsibilities at work.
Function: Property Protection Protecting facilities, equipment, and vital records is essential to restoring operations once an emergency has occurred.
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I. Planning Considerations Establish procedures for: a. b. c. d. e. f.
Fighting fires Containing material spills Closing or barricading doors and windows Shutting down equipment Covering or securing equipment Moving equipment to a safe location
Identify sources of backup equipment, parts, and supplies. Designate personnel to authorize, supervise, and perform a facility shutdown. Train them to recognize when to abandon the effort. Obtain materials to carry out protection procedures and keep them on hand for use only in emergencies.
2. Protection Systems Determine needs for systems to detect abnormal situations, provide warning, and protect property. Consider: a. b. c. d. e. f.
Fire protection systems Lightning protection systems Water-level monitoring systems Overflow detection devices Automatic shutoffs Emergency power generation systems
Consult your property insurer about special protective systems.
3. Mitigation Consider ways to reduce the effects of emergencies, such as moving or constructing facilities away from flood plains and fault zones. Also consider ways to reduce the chances of emergencies from occurring, such as changing processes or materials used to run the business. Consider physical retrofitting measures such as: a. Upgrading facilities to withstand the shaking of an earthquake or high winds b. "Flood-proofing" facilities by constructing flood walls or other flood protection devices (see Section 3 for additional information) c. Installing fire sprinkler systems d. Installing fire-resistant materials and furnishings e. Installing storm shutters for all exterior windows and doors
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There are also nonstructural mitigation measures to consider, including: a. Installing fire-resistant materials and furnishings b. Securing light fixtures and other items that could fall or shake loose in an emergency c. Moving heavy or breakable objects to low shelves d. Attaching cabinets and files to low walls or bolting them together e. Placing Velcro strips under typewriters, table-top computers, and television monitors f. Moving work stations away from large windows g. Installing curtains or blinds that can be drawn over windows to prevent glass from shattering onto employees h. Anchoring water heaters and bolting them to wall studs Consult a structural engineer or architect and your community's building and zoning offices for additional information.
4. Facility Shutdown Facility shutdown is generally a last resort but always a possibility. Improper or disorganized shutdown can result in confusion, injury, and property damage. Some facilities require only simple actions such as turning off equipment, locking doors, and activating alarms. Others require complex shutdown procedures. Work with department heads to establish shutdown procedures. Include information about when and how to shut off utilities. Identify: a. b. c. d. e.
The conditions that could necessitate a shutdown Who can order a shutdown Who will carry out shutdown procedures How a partial shutdown would affect other facility operations The length of time required for shutdown and restarting
Train personnel in shutdown procedures. Post procedures. 5. Records Preservation Vital records may include:
a. b. c. d.
Financial and insurance information Engineering plans and drawings Product lists and specifications Employee, customer, and supplier databases
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e. Formulas and trade secrets f. Personnel files Preserving vital records is essential to the quick restoration of operations. Analyzing vital records involves: a. Classifying operations into functional categories, e.g., finance, production, sales, administration b. Determining essential functions for keeping the business up and running, such as finance, production, and sales c. Identifying the minimum information that must be readily accessible to perform essential functions, e.g., maintaining customer collections may require access to account statements d. Identifying the records that contain the essential information and where they are located e. Identifying the equipment and materials needed to access and use the information. Next, establish procedures for protecting and accessing vital records. Among the many approaches to consider are: a. b. c. d. e. f. g. h. i.
Labeling vital records Backing up computer systems Making copies of records Storing tapes and disks in insulated containers Storing data off-site where they would not likely be damaged by an event affecting your facility Increasing security of computer facilities Arranging for evacuation of records to backup facilities Backing up systems handled by service bureaus Arranging for backup power
Function: Community Outreach Your facility's relationship with the community will influence your ability to protect personnel and property and return to normal operations. This section describes ways to involve outside organizations in the emergency management plan. I. Involvingthe Community Maintain a dialogue with community leaders, first responders, government agencies, community organizations, and utilities, including:
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a. b. c. d. e. f. g. h. i. j.
451
Appointed and elected leaders Fire, police, and emergency medical services personnel Local Emergency Planning Committee (LEPC) members Emergency management director Public Works Department AmericanRed Cross Hospitals Telephone company Electric utility Neighborhood groups
Have regular meetings with community emergency personnel to review emergency plans and procedures. Talk about what you are doing to prepare for and prevent emergencies. Explain your concern for the community's welfare. Identify ways your facility could help the community in a communitywide emergency. Look for common interests and concerns. Identify opportunities for sharing resources and information. Conduct confidence-building activities such as facility tours. Do a facility walk-through with community response groups. Involve community fire, police, and emergency management personnel in drills and exercises. Meet with your neighbors to determine how you could assist each other in an emergency. 2. Mutual Aid Agreements
To avoid confusion and conflict in an emergency, establish mutual aid agreements with local response agencies and businesses. These agreements should: a. Define the type of assistance b. Identify the chain of command for activating the agreement c. Define communications procedures Include these agencies in facility training exercises whenever possible. 3. Community Service
In community-wide emergencies, business and industry are often needed to assist the community with: a. Personnel b. Equipment
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c. d. e. f. g. h. i. j.
Shelter Training Storage Feeding facilities EOC facilities Food, clothing, building materials Funding Transportation
While there is no way to predict what demands will be placed on your company's resources, give some thought to how the community's needs might influence your corporate responsibilities in an emergency. Also, consider the opportunities for community service before an emergency occurs. 4. Public Information
When site emergencies expand beyond the facility, the community will want to know the nature of the incident, whether the public's safety or health is in danger, what is being done to resolve the problem, and what was done to prevent the situation from happening. Determine the audiences that may be affected by an emergency and identify their information needs. Include: a. b. c. d. e. f. g. h. i. j. k. I.
The public The media Employees and retirees Unions Contractors and suppliers Customers Shareholders Emergency response organizations Regulatory agencies Appointed and elected officials Special interest groups Neighbors
5. Media Relations
In an emergency, the media are the most important link to the public. Try to develop and maintain positive relations with media outlets in your area. Determine their particular needs and interests. Explain your plan for protecting personnel and preventing emergencies. Determine how you would communicate important public information through the media in an emergency. Designate a trained spokesperson
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and an alternate spokesperson. Set up a media briefing area. Establish security procedures. Establish procedures for ensuring that information is complete, accurate, and approved for public release. Determine an appropriate and useful way of communicating technical information. Prepare background information about the facility. When providing information to the media during an emergency: Do "s
Give all media equal access to information. When appropriate, conduct press briefings and interviews. Give local and national media equal time. Try to observe media deadlines. Escort media representatives to ensure safety. Keep records of information released. Provide press releases when possible. Don'ts
Do Do Do Do
not not not not
speculate about the incident. permit unauthorized personnel to release information. cover up facts or mislead the media. place blame for the incident.
Function: Recovery and Restoration
Business recovery and restoration, or business resumption, goes right to a facility's bottom line: keeping people employed and the business running.
I. Planning Considerations
Consider making contractual arrangements with vendors for such postemergency services as records preservation, equipment repair, earthmoving, or engineering. Meet with your insurance carriers to discuss your property and business resumption policies (see the next page for guidelines). Determine critical operations and make plans for bringing those systems back on-line. The process may entail: a. Repairing or replacing equipment b. Relocating operations to an alternate location c. Contracting operations on a temporary basis
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Take photographs or videotape the facility to document company assets. Update these records regularly.
2. Continuity of
Management
You can assume that not every key person will be readily available or physically at the facility after an emergency. Ensure that recovery decisions can be made without undue delay. Consult your legal department regarding laws and corporate bylaws governing continuity of management. Establish procedures for: a. Assuring the chain of command b. Maintaining lines of succession for key personnel c. Moving to alternate headquarters Include these considerations in all exercise scenarios.
3. Insurance
Most companies discover that they are not properly insured only after they have suffered a loss. Lack of appropriate insurance can be financially devastating. Discuss the following topics with your insurance advisor to determine your individual needs. a. How will my property be valued? b. Does my policy cover the cost of required upgrades to code? c. How much insurance am I required to carry to avoid becoming a co-insurer? d. What perils or causes of loss does my policy cover? e. What are my deductibles? f. What does my policy require me to do in the event of a loss? g. What types of records and documentation will my insurance company want to see? Are records in a safe place where they can be obtained after an emergency? h. To what extent am I covered for loss due to interruption of power? Is coverage provided for both on- and off-premises power interruption? i. Am I covered for lost income in the event of business interruption because of a loss? Do I have enough coverage? For how long is coverage provided? How long is my coverage for lost income if my business is closed by order of a civil authority? j. To what extent am I covered for reduced income due to customers not all immediately coming back once the business reopens? k. How will my emergency management program affect my rates?
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4. EmployeeSupport Since employees who will rely on you for support after an emergency are your most valuable asset, consider the range of services that you could provide or arrange for, including: a. b. c. d. e. f. g.
Cash advances Salary continuation Flexible work hours Reduced work hours Crisis counseling Care packages Day care
5. Resuming Operations Immediately after an emergency, take steps to resume operations. Establish a recovery team, if necessary. Establish priorities for resuming operations. Continue to ensure the safety of personnel on the property. Assess remaining hazards. Maintain security at the incident scene. Conduct an employee briefing. Keep detailed records. Consider audio recording all decisions. Take photographs of or videotape the damage. Account for all damage-related costs. Establish special job order numbers and charge codes for purchases and repair work. Follow notification procedures. Notify employees' families about the status of personnel on the property. Notify off-duty personnel about work status. Notify insurance carriers and appropriate government agencies. Protect undamaged property. Close up building openings. Remove smoke, water, and debris. Protect equipment against moisture. Restore sprinkler systems. Physically secure the property. Restore power. Conduct an investigation. Coordinate actions with appropriate government agencies. Conduct salvage operations. Segregate damaged from undamaged property. Keep damaged goods on hand until an insurance adjuster has visited the premises, but you can move material outside if it's seriously in the way and exposure to the elements won't make matters worse. Take an inventory of damaged goods. This is usually done with the adjuster, or the adjuster's salvor if there is any appreciable amount
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of goods or value. If you release goods to the salvor, obtain a signed inventory stating the quantity and type of goods being removed. Restore equipment and property. For major repair work, review restoration plans with the insurance adjuster and appropriate government agencies. Assess the value of damaged property. Assess the impact of business interruption. Maintain contact with customers and suppliers. Function: Administration and Logistics Maintain complete and accurate records at all times to ensure a more efficient emergency response and recovery. Certain records may also be required by regulation or by your insurance carriers, or may prove invaluable in the case of legal action after an incident. I. Administrative Actions
Administrative actions prior to an emergency include: a. b. c. d. e.
Establishing a written emergency management plan Maintaining training records Maintaining all written communications Documenting drills and exercises and their critiques Involving community emergency response organizations in planning activities
Administrative actions during and after an emergency include: a. b. c. d. e. f. g. h. i. j.
Maintaining telephone logs Keeping a detailed record of events Maintaining a record of injuries and follow-up actions Accounting for personnel Coordinating notification of family members Issuing press releases Maintaining sampling records Managing finances Coordinating personnel services Documenting incident investigations and recovery operations
2. Logistics
Before an emergency, logistics may entail: a. Acquiring equipment
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Stockpiling supplies Designating emergency facilities Establishing training facilities Establishing mutual aid agreements Preparing a resource inventory
During an emergency, logistics may entail the provision of: a. b. c. d. e. f. g. h.
Providing utility maps to emergency responders Providing material safety data sheets to employees Moving backup equipment in place Repairing parts Arranging for medical support, food, and transportation Arranging for shelter facilities Providing for backup power Providing for backup communications
SECTION 3--HAZARD-SPECIFIC INFORMATION
This section provides information about some of the most common hazards: Fire Hazardous Materials Incidents Floods and Flash Floods Hurricanes Tornadoes Severe Winter Storms Earthquakes Technological Emergencies
I. Hazards: Fire
Fire is the most common of all the hazards. Every year fires cause thousands of deaths and injuries and billions of dollars in property damage.
Planning Considerations Consider the following when developing your plan: a. Meet with the fire department to talk about the community's fire response capabilities. Talk about your operations. Identify processes and
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materials that could cause or fuel a fire, or contaminate the environment in a fire. b. Have your facility inspected for fire hazards. Ask about fire codes and regulations. c. Ask your insurance carrier to recommend fire prevention and protection measures. Your carrier may also offer training. d. Distribute fire safety information to employees: how to prevent fires in the workplace, how to contain a fire, how to evacuate the facility, where to report a fire. e. Instruct personnel to use the stairs~not elevators~in a fire. Instruct them to crawl on their hands and knees when escaping a hot or smokefilled area. f. Conduct evacuation drills. Post maps of evacuation routes in prominent places. Keep evacuation routes including stairways and doorways clear of debris. g. Assign fire wardens for each area to monitor shutdown and evacuation procedures. h. Establish procedures for the safe handling and storage of flammable liquids and gases. i. Establish procedures to prevent the accumulation of combustible materials. j. Provide for the safe disposal of smoking materials. k. Establish a preventive maintenance schedule to keep equipment operating safely. 1. Place fire extinguishers in appropriate locations. m. Train employees in use of fire extinguishers. n. Install smoke detectors. Check smoke detectors once a month; change batteries at least once a year. o. Establish a system for warning personnel of a fire. Consider installing a fire alarm with automatic notification to the fire department. p. Consider installing a sprinkler system, fire hoses, and fire-resistant walls and doors. q. Ensure that key personnel are familiar with all fire safety systems. r. Identify and mark all utility shutoffs so that electrical power, gas, or water can be shut off quickly by fire wardens or responding personnel. Determine the level of response your facility will take if a fire occurs. Among the options are: Option l ~ I m m e d i a t e evacuation of all personnel on alarm. Option 2 ~ A l l personnel are trained in fire extinguisher use. Personnel in the immediate area of a fire attempt to control it. If they cannot, the fire alarm is sounded and all personnel evacuate. Option 3 ~ O n l y designated personnel are trained in fire extinguisher USE.
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Option 4 m A fire team is trained to fight incipient-stage fires that can be controlled without protective equipment or breathing apparatus. Beyond this level fire, the team evacuates. Option 5 m A fire team is trained and equipped to fight structural fires using protective equipment and breathing apparatus.
2. Hazards: Hazardous Materials Incidents
Hazardous materials are substances that are either flammable or combustible, explosive, toxic, noxious, corrosive, oxidizable, an irritant, or radioactive. A hazardous material spill or release can pose a risk to life, health, or property. An incident can result in the evacuation of a few people, a section of a facility, or an entire neighborhood. There are a number of federal laws that regulate hazardous materials, including: the Superfund Amendments and Reauthorization Act of 1986 (SARA), the Resource Conservation and Recovery Act of 1976 (RCRA), the Hazardous Materials Transportation Act (HMTA), the Occupational Safety and Health Act (OSHA), the Toxic Substances Control Act (TSCA), and the Clean Air Act. Title III of SARA regulates the packaging, labeling, handling, storage, and transportation of hazardous materials. The law requires facilities to furnish information about the quantities and health effects of materials used at the facility, and to promptly notify local and state officials whenever a significant release of hazardous materials occurs. In addition to on-site hazards, you should be aware of the potential for an off-site incident affecting your operations. You should also be aware of hazardous materials used in facility processes and in the construction of the physical plant. Detailed definitions as well as lists of hazardous materials can be obtained from the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA). Planning Considerations
Consider the following when developing your plan: a. Identify and label all hazardous materials stored, handled, produced, and disposed of by your facility. Follow government regulations that apply to your facility. Obtain material safety data sheets (MSDS) for all hazardous materials at your location. b. Ask the local fire department for assistance in developing appropriate response procedures.
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c. Train employees to recognize and report hazardous material spills and releases. Train employees in proper handling and storage. d. Establish a hazardous material response plan: 1. Establish procedures to notify management and emergency response organizations of an incident. 2. Establish procedures to warn employees of an incident. 3. Establish evacuation procedures. e. Depending on your operations, organize and train an emergency response team to confine and control hazardous material spills in accordance with applicable regulations. f. Identify other facilities in your area that use hazardous materials. Determine whether an incident could affect your facility. g. Identify highways, railroads, and waterways near your facility used for the transportation of hazardous materials. Determine how a transportation accident near your facility could affect your operations.
3. Hazards: Floods and Flash Floods
Floods are the most common and widespread of all natural disasters. Most communities in the United States can experience some degree of flooding after spring rains, heavy thunderstorms, or winter snow thaws. Most floods develop slowly over a period of days. Flash floods, however, are like walls of water that develop in a matter of minutes. Flash floods can be caused by intense storms or dam failure. Planning Considerations
Consider the following when preparing for floods: a. Ask your local emergency management office whether your facility is located in a flood plain. Learn the history of flooding in your area. Learn the elevation of your facility in relation to steams, rivers, and dams. b. Review the community's emergency plan. Learn the community's evacuation routes. Know where to find higher ground in case of a flood. c. Establish warning and evacuation procedures for the facility. Make plans for assisting employees who may need transportation. d. Inspect areas in your facility subject to flooding. Identify records and equipment that can be moved to a higher location. Make plans to move records and equipment in case of flood. e. Purchase a NOAA Weather Radio with a warning alarm tone and battery backup. Listen for flood watches and warnings.
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f. Flood Watch--Flooding is possible. Stay tuned to NOAA radio. Be prepared to evacuate. Tune to local radio and television stations for additional information. g. Flood Warning--Flooding is already occurring or will occur soon. Take precautions at once. Be prepared to go to higher ground. If advised, evacuate immediately. h. Ask your insurance carrier for information about flood insurance. Regular property and casualty insurance does not cover flooding. i. Consider the feasibility of flood-proofing your facility. There are three basic types of methods. Permanent flood-proofing measures are taken before a flood occurs and require no human intervention when flood waters rise. They include: a. Filling windows, doors, or other openings with water-resistant materials such as concrete blocks or bricks. This approach assumes the structure is strong enough to withstand flood waters. b. Installing check valves to prevent water from entering where utility and sewer lines enter the facility. c. Reinforcing walls to resist water pressure. Sealing walls to prevent or reduce seepage. d. Building watertight walls around equipment or work areas within the facility that are particularly susceptible to flood damage. e. Constructing floodwalls or levees outside the facility to keep flood waters away. f. Elevating the facility on walls, columns, or compacted fill. This approach is most applicable to new construction, though many types of buildings can be elevated. Contingent flood-proofing measures are also taken before a flood but require some additional action when flooding occurs. These measures include: a. Installing watertight barriers called flood shields to prevent the passage of water through doors, windows, ventilation shafts, or other openings b. Installing permanent watertight doors c. Constructing movable floodwalls d. Installing permanent pumps to remove flood waters Emergency flood-proofing measures are generally less expensive than those listed above, though they require substantial advance warning and do not satisfy the minimum requirements for watertight flood-proofing as set forth by the National Flood Insurance Program (NFIP). They include: a. Building walls with sandbags
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b. Constructing a double row of walls with boards and posts to create a "crib," then filling the crib with soil c. Constructing a single wall by stacking small beams or planks on top of each other d. Consider the need for backup systems: 1. Portable pumps to remove flood water 2. Alternate power sources such as generators or gasoline-powered pumps 3. Battery-powered emergency lighting e. Participate in community flood control projects.
4. Hazards: Hurricanes
Hurricanes are severe tropical storms with sustained winds of 74 miles per hour or greater. Hurricane winds can reach 160 miles per hour and extend inland for hundreds of miles. Hurricanes bring torrential rains and a storm surge of ocean water that crashes into land as the storm approaches. Hurricanes also spawn tornadoes. Hurricane advisories are issued by the National Weather Service as soon as a hurricane appears to be a threat. The hurricane season lasts from June through November.
Planning Considerations The following are considerations when preparing for hurricanes: a. Ask your local emergency management office about community evacuation plans. b. Establish facility shutdown procedures. Establish warning and evacuation procedures. Make plans for assisting employees who may need transportation. c. Make plans for communicating with employees' families before and after a hurricane. d. Purchase a NOAA Weather Radio with a warning alarm tone and battery backup. e. Listen for hurricane watches and warnings. f. Hurricane Watch--A hurricane is possible within 24 to 36 hours. Stay tuned for additional advisories. Tune to local radio and television stations for additional information. An evacuation may be necessary.
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g. Hurricane WarningEA hurricane will hit land within 24 hours. Take precautions at once. If advised, evacuate immediately. h. Survey your facility. Make plans to protect outside equipment and structures. i. Make plans to protect windows. Permanent storm shutters offer the best protection. j. Covering windows with 5/8-inch marine plywood is a second option. Consider the need for backup systems: Portable pumps to remove flood water Alternate power sources such as generators or gasoline-powered pumps Battery-powered emergency lighting Prepare to move records, computers, and other items within your facility or to another location. 5. Hazards: Tornadoes Tornadoes are incredibly violent local storms that extend to the ground with whirling winds that can reach 300 mph. Spawned from powerful thunderstorms, tornadoes can uproot trees and buildings and turn harmless objects into deadly missiles in a matter of seconds. Damage paths can be in excess of I mile wide and 50 miles long. Tornadoes can occur in any state but occur more frequently in the Midwest, Southeast, and Southwest. They occur with little or no warning. Planning Considerations The following are considerations when planning for tornadoes: a. Ask your local emergency management office about the community's tornado warning system. b. Purchase a NOAA Weather Radio with a warning alarm tone and battery backup. Listen for tornado watches and warnings. c. Tornado Watch--Tornadoes are likely. Be ready to take shelter. Stay tuned to radio and television stations for additional information. d. Tornado WarningmA tornado has been sighted in the area or is indicated by radar. Take shelter immediately. e. Establish procedures to inform personnel when tornado warnings are posted. Consider the need for spotters to be responsible for looking out for approaching storms.
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f. Work with a structural engineer or architect to designate shelter areas in your facility. Ask your local emergency management office or National Weather Service office for guidance. g. Consider the amount of space you will need. Adults require about 6 square feet of space; nursing home and hospital patients require more. h. The best protection in a tornado is usually an underground area. If an underground area is not available, consider: 1. Small interior rooms on the lowest floor and without windows 2. Hallways on the lowest floor away from doors and windows 3. Rooms constructed with reinforced concrete, brick, or block with no windows and a heavy concrete floor or roof system overhead 4. Protected areas away from doors and windows Note: Auditoriums, cafeterias and gymnasiums that are covered with a flat, wide-span roof are not considered safe.
i. Make plans for evacuating personnel away from lightweight modular offices or mobile home-size buildings. These structures offer no protection from tornadoes. j. Conduct tornado drills. k. Once in the shelter, personnel should protect their heads with their arms and crouch down.
6. Hazards: Severe W i n t e r Storms
Severe winter storms bring heavy snow, ice, strong winds, and freezing rain. Winter storms can prevent employees and customers from reaching the facility, leading to a temporary shutdown until roads are cleared. Heavy snow and ice can also cause structural damage and power outages.
Planning Considerations Following are considerations for preparing for winter storms: a. Listen to NOAA Weather Radio and local radio and television stations for weather information: b. Winter Storm Watch--Severe winter weather is possible. c. Winter Storm WarninguSevere winter weather is expected. d. Blizzard WarninguSevere winter weather with sustained winds of at least 35 mph is expected. e. Traveler's Advisory~Severe winter conditions may make driving difficult or dangerous.
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f. Establish procedures for facility shutdown and early release of employees. g. Store food, water, blankets, battery-powered radios with extra batteries, and other emergency supplies for employees who become stranded at the facility. h. Provide a backup power source for critical operations. i. Arrange for snow and ice removal from parking lots, walkways, loading docks, etc.
7. Hazards: Earthquakes
Earthquakes occur most frequently west of the Rocky Mountains, although historically the most violent earthquakes have occurred in the central United States. Earthquakes occur suddenly and without warning. Earthquakes can seriously damage buildings and their contents; disrupt gas, electric, and telephone services; and trigger landslides, avalanches, flash floods, fires, and huge ocean waves called tsunamis. Aftershocks can occur for weeks following an earthquake. In many buildings, the greatest danger to people in an earthquake is when equipment and nonstructural elements such as ceilings, partitions, windows, and lighting fixtures shake loose.
Planning Considerations Following are guidelines for preparing for earthquakes: a. Assess your facility's vulnerability to earthquakes. Ask local government agencies for seismic information for your area. b. Have your facility inspected by a structural engineer. Develop and prioritize strengthening measures. These may include: 1. 2. 3. 4.
Adding steel bracing to frames Adding sheer walls to frames Strengthening columns and building foundations Replacing unreinforced brick filler walls
c. Follow safety codes when constructing a facility or making major renovations. d. Inspect nonstructural systems such as air conditioning, communications and pollution control systems. Assess the potential for damage. Prioritize measures to prevent damages. e. Inspect your facility for any item that could fall, spill, break, or move during an earthquake. Take steps to reduce these hazards:
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1. Move large and heavy objects to lower shelves or the floor. Hang heavy items away from where people work. 2. Secure shelves, filing cabinets, tall furniture, desktop equipment, computers, printers, copiers, and light fixtures. 3. Secure fixed equipment and heavy machinery to the floor. Larger equipment can be placed on casters and attached to tethers which attach to the wall. 4. Add bracing to suspended ceilings, if necessary. 5. Install safety glass where appropriate. 6. Secure large utility and process piping. f. Keep copies of design drawings of the facility to be used in assessing the facility's safety after an earthquake. g. Review processes for handling and storing hazardous materials. Have incompatible chemicals stored separately. h. Ask your insurance carrier about earthquake insurance and mitigation techniques. i. Establish procedures to determine whether an evacuation is necessary after an earthquake. j. Designate areas in the facility away from exterior walls and windows where occupants should gather after an earthquake if an evacuation is not necessary. k. Conduct earthquake drills. Provide personnel with the following safety information: 1. In an earthquake, if indoors, stay there. Take cover under a sturdy piece of furniture or counter, or brace yourself against an inside wall. Protect your head and neck. 2. If outdoors, move into the open, away from buildings, street lights and utility wires. 3. After an earthquake, stay away from windows, skylights and items that could fall. Do not use the elevators. 4. Use stairways to leave the building if it is determined that a building evacuation is necessary.
8. Hazards: Technological Emergencies Technological emergencies include any interruption or loss of a utility service, power source, life support system, information system, or equipment needed to keep the business in operation.
PlanningConsiderations The following are suggestions for planning for technological emergencies:
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Section 4-Information Sources
Identify all critical operations, including: a. Utilities including electric power, gas, water, hydraulics, compressed air, municipal and internal sewer systems, wastewater treatment services b. Security and alarm systems, elevators, lighting, life support systems, heating, ventilation and air conditioning systems, electrical distribution system. c. Manufacturing equipment, pollution control equipment d. Communication systems, both data and voice computer networks e. Transportation systems including air, highway, railroad, and waterway Determine the impact of service disruption. Ensure that key safety and maintenance personnel are thoroughly familiar with all building systems. Establish procedures for restoring systems. Determine need for backup systems. Establish preventive maintenance schedules for all systems and equipment. SECTION 4--INFORMATION
SOURCES
I. Sources: Additional Readings from FEMA
The following publications can be obtained from FEMA by writing to: FEMA, Publications, P.O. Box 70274, Washington, DC 20024. Disaster Mitigation Guide for Business and Industry (FEMA 1 9 0 ) Technical planning information for building owners and industrial facilities on how to reduce the impact of natural disasters and manmade emergencies. Principal Threats Facing Communities and Local Emergency Management Coordinators (FEMA 191)mStatistics and analyses of natural disasters and man-made threats in the United States. Flood-proofing Non-Residential Structures (FEMA 102)--Technical information for building owners, designers, and contractors on flood-proofing techniques (200 pages). Non-Residential Flood-proofingmRequirements and Certification for Buildings Located in Flood Hazard Areas in Accordance with the National Flood Insurance Program (FIA-TB-3)--Planning and engineering considerations for flood-proofing new commercial buildings. Building Performance: Hurricane Andrew in Florida (FIA 22)~Technical guidance for enhancing the performance of buildings in hurricanes.
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Building Performance: Hurricane Iniki in Hawaii (FIA 23)~Technical guidance for reducing hurricane and flood damage. Answers to Questions About Substantially Damaged Buildings (FEMA 213)~Information about regulations and policies of the National Flood Insurance Program regarding substantially damaged buildings (25 pages). Design Guidelines for Flood Damage Reduction (FEMA 15)~A study on land use, watershed management, design and construction practices in flood- prone areas. Comprehensive Earthquake Preparedness Planning Guidelines: Corporate FEMA 71)~Earthquake planning guidance for corporate safety officers and managers. 2. Sources: Ready-to-Print Brochures
Ready-To-Print Brochure Mechanicals for Your Employee Safety Program. You can provide your employees and customers with life-saving information from FEMA and the American Red Cross. Available at no charge is ready-to-print artwork for a series of brochures on disaster preparedness and family safety. Select any of the brochures below, and you'll receive camera-ready materials, printing instructions, and ideas for adding your own logo or sponsor message. Write to: Camera-ready Requests, FEMA Publications, 500 C Street, SW, Washington, DC 20472. Your Family Disaster PlanmA four-step plan for individuals and families on how to prepare for any type of disaster. Emergency Preparedness Checklist~An action checklist on home safety, evacuation, and disaster preparedness. Your Family Disaster Supplies Kit~A checklist of emergency supplies for the home and car. Helping Children Cope With Disaster~Practical advice on how to help children deal with the stress of disaster.
OSHA TRAINING CURRICULUM GUIDELINES 1910.120 (HAZARDOUS WASTE OPERATIONS &
EMERGENCY RESPONSE) APP E (NON MAN DATORY)
The following nonmandatory general criteria may be used for assistance in developing site-specific training curriculum used to meet the training requirements of 29 CFR 1910.120(e); 29 CFR 1910.120(p)(7), (p)(8)(iii); and 29 CFR 1910.120(q)(6), (q)(7), and (q)(8). These are generic guidelines and they are not presented as a complete training curriculum for any specific employer. Site-specific training programs must be developed on the basis of a needs assessment of the hazardous waste site, RCRA/TSDF, or emergency response operation in accordance with 29 CFR 1910.120. It is noted that the legal requirements are set forth in the regulatory text of Sec. 1910.120. The guidance set forth here presents a highly effective program that in the areas covered would meet or exceed the regulatory requirements. In addition, other approaches could meet the regulatory requirements. 469
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SUGGESTED GENERAL CRITERIA Definitions
"Competent" means possessing the skills, knowledge, experience, and judgment to perform assigned tasks or activities satisfactorily as determined by the employer. "Demonstration" means the showing by actual use of equipment or procedures. "Hands-on training" means training in a simulated work environment that permits each student to have experience performing tasks, making decisions, or using equipment appropriate to the job assignment for which the training is being conducted. "Initial training" means training required prior to beginning work. "Lecture" means an interactive discourse with a class lead by an instructor. "Proficient" means meeting a stated level of achievement. "Site-specific" means individual training directed to the operations of a specific job site. "Training hours" means the number of hours devoted to lecture, learning activities, small group work sessions, demonstration, evaluations, or hands-on experience.
Suggested Core Criteria
1. Training facility. The training facility should have available sufficient resources, equipment, and site locations to perform didactic and handson training when appropriate. Training facilities should have sufficient organization, support staff, and services to conduct training in each of the courses offered. 2. Training Director. Each training program should be under the direction of a training director who is responsible for the program. The Training Director should have a minimum of 2 years of employee education experience. 3. Instructors. Instructors should be deemed competent on the basis of previous documented experience in their area of instruction, successful completion of a "train-the-trainer" program specific to the topics they will teach, and an evaluation of instructional competence by the Training Director. Instructors should be required to maintain professional competency by participating in continuing education or professional development programs or by completing successfully an annual refresher course and having an annual review by the Training Director. The annual review by the Training
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Director should include observation of an instructor's delivery, a review of those observations with the trainer, and an analysis of any instructor or class evaluations completed by the students during the previous year. 4. Course materials. The Training Director should approve all course materials to be used by the training provider. Course materials should be reviewed and updated at least annually. Materials and equipment should be in good working order and maintained properly. All written and audio-visual materials in training curricula should be peer reviewed by technically competent outside reviewers or by a standing advisory committee. Reviews should possess expertise in the following disciplines were applicable: occupational health, industrial hygiene and safety, chemical/environmental engineering, employee education, or emergency response. One or more of the peer reviewers should be a employee experienced in the work activities to which the training is directed. 5. Students. The program for accepting students should include: a. Assurance that the student is or will be involved in work where chemical exposures are likely and that the student possesses the skills necessary to perform the work. b. A policy on the necessary medical clearance. 6. Ratios. Student-instructor ratios should not exceed 30 students per instructor. Hands-on activity requiring the use of personal protective equipment should have the following student-instructor ratios. For Level C or Level D personal protective equipment the ratio should be 10 students per instructor. For Level A or Level B personal protective equipment the ratio should be 5 students per instructor. 7. Proficiency assessment. Proficiency should be evaluated and documented by the use of a written assessment and a skill demonstration selected and developed by the Training Director and training staff. The assessment and demonstration should evaluate the knowledge and individual skills developed in the course of training. The level of minimum achievement necessary for proficiency shall be specified in writing by the Training Director. If a written test is used, there should be a minimum of 50 questions. If a written test is used in combination with a skills demonstration, a minimum of 25 questions should be used. If a skills demonstration is used, the tasks chosen and the means to rate successful completion should be fully documented by the Training Director. The content of the written test or of the skill demonstration shall be relevant to the objectives of the course. The written test and skill demonstration should be updated as necessary to reflect changes in the curriculum and any update should be approved by the Training Director. The proficiency assessment methods, regardless of the approach or combination of approaches used, should be justified, documented, and ap-
472
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proved by the Training Director. The proficiency of those taking the additional courses for supervisors should be evaluated and documented by using proficiency assessment methods acceptable to the Training Director. These proficiency assessment methods must reflect the additional responsibilities borne by supervisory personnel in hazardous waste operations or emergency response. 8. Course certificate. Written documentation should be provided to each student who satisfactorily completes the training course. The documentation should include: a. b. c. d. e. f. g.
Student's name. Course title. Course date. Statement that the student has successfully completed the course. Name and address of the training provider. An individual identification number for the certificate. List of the levels of personal protective equipment used by the student to complete the course.
This documentation may include a certificate and an appropriate wallet-sized laminated card with a photograph of the student and the above information. When such course certificate cards are used, the individual identification number for the training certificate should be shown on the card. 9. Recordkeeping. Training providers should maintain records listing the dates that courses were presented, the names of the individual course attenders, the names of those students successfully completing each course, and the number of training certificates issued to each successful student. These records should be maintained for a minimum of 5 years after the date an individual participated in a training program offered by the training provider. These records should be available and provided upon the student's request or as mandated by law. 10. Program quality control. The Training Director should conduct or direct an annual written audit of the training program. Program modifications to address deficiencies, if any, should be documented, approved, and implemented by the training provider. The audit and the program modification documents should be maintained at the training facility.
SUGGESTED PROGRAM Q U A L I T Y C O N T R O L CRITERIA
Factors listed here are suggested criteria for determining the quality and appropriateness of employee health and safety training for hazardous waste operations and emergency response.
Suggested Program Quality Control Criteria
473
A. Training Plan Adequacy and appropriateness of the training program's curriculum development, instructor training, distribution of course materials, and direct student training should be considered, including: 1. The duration of training, course content, and course schedules/ agendas; 2. The different training requirements of the various target populations, as specified in the appropriate generic training curriculum; 3. The process for the development of curriculum, which includes appropriate technical input, outside review, evaluation, program pretesting. 4. The adequate and appropriate inclusion of hands-on, demonstration, and instruction methods; 5. Adequate monitoring of student safety, progress, and performance during the training.
B. Program Management, Training Director, Staff, and Consultants Adequacy and appropriateness of staff performance and delivering an effective training program should be considered, including: 1. Demonstration of the training director's leadership in assuring quality of health and safety training. 2. Demonstration of the competency of the staff to meet the demands of delivering high-quality hazardous waste employee health and safety training. 3. Organization charts establishing clear lines of authority. 4. Clearly defined staff duties including the relationship of the training staff to the overall program. 5. Evidence that the training organizational structure suits the needs of the training program. 6. Appropriateness and adequacy of the training methods used by the instructors. 7. Sufficiency of the time committed by the training director and staff to the training program. 8. Adequacy of the ratio of training staff to students. 9. Availability and commitment of the training program of adequate human and equipment resources in the areas of: a. Health effects, b. Safety, c. Personal protective equipment (PPE),
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d. Operational procedures, e. Employee protection practices/procedures. 10. Appropriateness of management controls. 11. Adequacy of the organization and appropriate resources assigned to assure appropriate training. 12. In the case of multiple-site training programs, adequacy of satellite centers management.
C. Training Facilities and Resources
Adequacy and appropriateness of the facilities and resources for supporting the training program should be considered, including: 1. Space and equipment to conduct the training. 2. Facilities for representative hands-on training. 3. In the case of multiple-site programs, equipment and facilities at the satellite centers. 4. Adequacy and appropriateness of the quality control and evaluations program to account for instructor performance. 5. Adequacy and appropriateness of the quality control and evaluation program to ensure appropriate course evaluation, feedback, updating, and corrective action. 6. Adequacy and appropriateness of disciplines and expertise being used within the quality control and evaluation program. 7. Adequacy and appropriateness of the role of student evaluations to provide feedback for training program improvement.
D. Quality Control and Evaluation
Adequacy and appropriateness of quality control and evaluation plans for training programs should be considered, including: 1. A balanced advisory committee and/or competent outside reviewers to give overall policy guidance; 2. Clear and adequate definition of the composition and active programmatic role of the advisory committee or outside reviewers. 3. Adequacy of the minutes or reports of the advisory committee or outside reviewers' meetings or written communication. 4. Adequacy and appropriateness of the quality control and evaluations program to account for instructor performance.
Suggested Program Quality Control Criteria
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5. Adequacy and appropriateness of the quality control and evaluation program to ensure appropriate course evaluation, feedback, updating, and corrective action. 6. Adequacy and appropriateness of disciplines and expertise being used within the quality control and evaluation program. 7. Adequacy and appropriateness of the role of student evaluations to provide feedback for training program improvement.
E. Students
Adequacy and appropriateness of the program for accepting students should be considered, including: 1. Assurance that the student already possess the necessary skills for their job, including necessary documentation. 2. Appropriateness of methods the program uses to ensure that recruits are capable of satisfactorily completing training. 3. Review and compliance with any medical clearance policy.
F. Institutional Environment and Administrative Support
The adequacy and appropriateness of the institutional environment and administrative support system for the training program should be considered, including: 1. Adequacy of the institutional commitment to the employee training program. 2. Adequacy and appropriateness of the administrative structure and administrative support.
G. Summary of Evaluation Questions
Key questions for evaluating the quality and appropriateness of an overall training program should include the following: 1. 2. 3. 4.
Are the program objectives clearly stated? Is the program accomplishing its objectives? Are appropriate facilities and staff available? Is there an appropriate mix of classroom, demonstration, and hands-on training?
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5. Is the program providing quality employee health and safety training that fully meets the intent of regulatory requirements? 6. What are the program's main strengths? 7. What are the program's main weaknesses? 8. What is recommended to improve the program? 9. Are instructors instructing according to their training outlines? 10. Is the evaluation tool current and appropriate for the program content? 11. Is the course material current and relevant to the target group?
SUGGESTED T R A I N I N G C U R R I C U L U M GUIDELINES
The following training curriculum guidelines are for those operations specifically identified in 29 CFR 1910.120 as requiring training. Issues such as qualifications of instructors, training certification, and similar criteria appropriate to all categories of operations addressed in 1910.120 have been covered in the preceding section and are not readdressed in each of the generic guidelines. Basic core requirements for training programs that are addressed include: 1. General Hazardous Waste Operations 2. RCRA operations~Treatment, storage, and disposal facilities 3. Emergency Response
A. General Hazardous Waste Operations and Site-Specific Training I. Off-Site Training
Training course content for hazardous waste operations, required by 29 CFR 1910.120(e), should include the following topics or procedures:
a. Regulatory Knowledge
(1) A review of 29 CFR 1910.120 and the core elements of an occupational safety and health program. (2) The content of a medical surveillance program as outlined in 29 CFR 1910.120(f). (3) The content of an effective site safety and health plan consistent with the requirements of 29 CFR 1910.120(b)(4)(ii). (4) Emergency response plan and procedures as outlined in 29 CFR 1910.38 and 29 CFR 1910.120(1). (5) Adequate illumination. (6) Sanitation recommendation and equipment.
Suggested Training Curriculum Guidelines
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(7) Review and explanation of OSHA's hazard-communication standard (29 CFR 1910.1200)and lock-out-tag-out standard (29 CFR 1910.147). (8) Review of other applicable standards including but not limited to those in the construction standards (29 CFR Part 1926). (9) Rights and responsibilities of employers and employees under applicable OSHA and EPA laws. b. Technical Knowledge (1) Type of potential exposures to chemical, biological, and radiological hazards; types of human responses to these hazards and recognition of those responses; principles of toxicology and information about acute and chronic hazards; health and safety considerations of new technology. (2) Fundamentals of chemical hazards including but not limited to vapor pressure, boiling points, flash points, pH, other physical and chemical properties. (3) Fire and explosion hazards of chemicals. (4) General safety hazards such as but not limited to electrical hazards, powered equipment hazards, motor vehicle hazards, walking-working surface hazards, excavation hazards, and hazards associated with working in hot and cold temperature extremes. (5) Review and knowledge of confined space entry procedures in 29 CFR 1910.146. (6) Work practices to minimize employee risk from site hazards. (7) Safe use of engineering controls, equipment, and any new relevant safety technology or safety procedures. (8) Review and demonstration of competency with air sampling and monitoring equipment that may be used in a site monitoring program. (9) Container sampling procedures and safeguarding; general drum and container handling procedures including special requirement for laboratory waste packs, shock-sensitive wastes, and radioactive wastes. (10) The elements of a spill control program. (11) Proper use and limitations of material handling equipment. (12) Procedures for safe and healthful preparation of containers for shipping and transport. (13) Methods of communication including those used while wearing respiratory protection. c. Technical Skills (1) Selection, use, maintenance, and limitations of personal protective equipment including the components and procedures for carrying out a respirator program to comply with 29 CFR 1910.134. (2) Instruction in decontamination programs including personnel, equipment, and hardware; hands-on training including level A, B, and C ensembles and appropriate decontamination lines; field activities including the donning and doffing of protective equipment to a level commensurate
478
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with the employee's anticipated job function and responsibility and to the degree required by potential hazards. (3) Sources for additional hazard information; exercises using relevant manuals and hazard coding systems. d. Additional Suggested Items (1) A laminated, dated card or certificate with photo, denoting limitations and level of protection for which the employee is trained should be issued to those students successfully completing a course. (2) Attendance should be required at all training modules, with successful completion of exercises and a final written or oral examination with at least 50 questions. (3) A minimum of one-third of the program should be devoted to hands-on exercises. (4) A curriculum should be established for the 8-hour refresher training required by 29 CFR 1910.120(e)(8), with delivery of such courses directed toward those areas of previous training that need improvement or reemphasis. (5) A curriculum should be established for the required 8-hour training for supervisors. Demonstrated competency in the skills and knowledge provided in a 40-hour course should be a prerequisite for supervisor training.
2. Refresher Training The 8-hour annual refresher training required in 29 CFR 1910.120(e)(8) should be conducted by qualified training providers. Refresher training should include at a minimum the following topics and procedures: (a) Review of and retraining on relevant topics covered in the 40-hour program, as appropriate, using reports by the students on their work experiences. (b) Update on developments with respect to material covered in the 40-hour course. (c) Review of changes to pertinent provisions of EPA or OSHA standards or laws. (d) Introduction of additional subject areas as appropriate. (e) Hands-on review of new or altered PPE or decontamination equipment or procedures. Review of new developments in personal protective equipment. (f) Review of newly developed air and contaminant monitoring equipment.
Suggested Training Curriculum Guidelines
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3. On-Site Training a. The employer should provide employees engaged in hazardous waste site activities with information and training prior to initial assignment into their work area, as follows: (1) The requirements of the hazard communication program including the location and availability of the written program, required lists of hazardous chemicals, and material safety data sheets. (2) Activities and locations in their work area where hazardous substance may be present. (3) Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearances, or other evidence (sight, sound, or smell) of hazardous chemicals being released, and applicable alarms from monitoring devices that record chemical releases. (4) The physical and health hazards of substances known or potentially present in the work area. (5) The measures employees can take to help protect themselves from work-site hazards, including specific procedures the employer has implemented. (6) An explanation of the labeling system and material safety data sheets and how employees can obtain and use appropriate hazard information. (7) The elements of the confined space program including special PPE, permits, monitoring requirements, communication procedures, emergency response, and applicable lock-out procedures. b. The employer should provide hazardous waste employees information and training and should provide a review and access to the site safety and plan as follows: (1) Names of personnel and alternate responsible for site safety and health. (2) Safety and health hazards present on the site. (3) Selection, use, maintenance, and limitations of personal protective equipment specific to the site. (4) Work practices by which the employee can minimize risks from hazards. (5) Safe use of engineering controls and equipment available on site. (6) Safe decontamination procedures established to minimize employee contact with hazardous substances, including: (A) Employee decontamination,
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(B) Clothing decontamination, and (C) Equipment decontamination. (7) Elements of the site emergency response plan, including: (A) (B) (C) (D) (E) (F) (G)
Preemergency planning. Personnel roles and lines of authority and communication. Emergency recognition and prevention. Safe distances and places of refuge. Site security and control. Evacuation routes and procedures. Decontamination procedures not covered by the site safety and health plan. (H) Emergency medical treatment and first aid. (I) Emergency equipment and procedures for handling emergency incidents.
c. The employer should provide hazardous waste employees information and training on personal protective equipment used at the site, such as the following: (1) PPE to be used based upon known or anticipated site hazards. (2) PPE limitations of materials and construction; limitations during temperature extremes, heat stress, and other appropriate medical considerations; use and limitations of respirator equipment as well as documentation procedures as outlined in 29 CFR 1910.134. (3) PPE inspection procedures prior to, during, and after use. (4) PPE donning and doffing procedures. (5) PPE decontamination and disposal procedures. (6) PPE maintenance and storage. (7) Task duration as related to PPE limitations. d. The employer should instruct the employee about the site medical surveillance program relative to the particular site, including: (1) Specific medical surveillance programs that have been adapted for the site. (2) Specific signs and symptoms related to exposure to hazardous materials on the site. (3) The frequency and extent of periodic medical examinations that will be used on the site. (4) Maintenance and availability of records. (5) Personnel to be contacted and procedures to be followed when signs and symptoms of exposures are recognized. e. The employees will review and discuss the site safety plan as part of the training program. The location of the site safety plan and all written
Suggested Training Curriculum Guidelines
481
programs should be discussed with employees including a discussion of the mechanisms for access, review, and references described.
B. RCRA Operations Training for Treatment, Storage, and Disposal Facilities 1. As a minimum, the training course required in 29 CFR 1910.120 (p) should include the following topics: (a) Review of the applicable paragraphs of 29 CFR 1910.120 and the elements of the employer's occupational safety and health plan. (b) Review of relevant hazards such as, but not limited to, chemical, biological, and radiological exposures; fire and explosion hazards; thermal extremes; and physical hazards. (c) General safety hazards including those associated with electrical hazards, powered equipment hazards, lock-out-tag-out procedures, motor vehicle hazards, and walking-working surface hazards. (d) Confined-space hazards and procedures. (e) Work practices to minimize employee risk from workplace hazards. (f) Emergency response plan and procedures including first aid meeting the requirements of paragraph (p)(8). (g) A review of procedures to minimize exposure to hazardous waste and various type of waste streams, including the materials handling program and spill containment program. (h) A review of hazard communication programs meeting the requirements of 29 CFR 1910.1200. (i) A review of medical surveillance programs meeting the requirements of 29 CFR 1910.120(p)(3) including the recognition of signs and symptoms of overexposure to hazardous substances including known synergistic interactions. (j) A review of decontamination programs and procedures meeting the requirements of 29 CFR 1910.120(p)(4). (k) A review of an employer's requirements to implement a training program and its elements. (1) A review of the criteria and programs for proper selection and use of personal protective equipment, including respirators. (m) A review of the applicable appendices to 29 CFR 1910.120. (n) Principles of toxicology and biological monitoring as they pertain to occupational health. (o) Rights and responsibilities of employees and employers under applicable OSHA and EPA laws.
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(p) Hands-on exercises and demonstrations of competency with equipment to illustrate the basic equipment principles that may be used during the performance of work duties, including the donning and doffing of PPE. (q) Sources of reference, efficient use of relevant manuals, and knowledge of hazard coding systems to include information contained in hazardous waste manifests. (r) At least 8 hours of hands-on training. (s) Training in the job skills required for an employee's job function and responsibility before they are permitted to participate in or supervise field activities. 2. The individual employer should provide hazardous waste employees with information and training prior to an employee's initial assignment into a work area. The training and information should cover the following topics: (a) The Emergency response plan and procedures including first aid. (b) A review of the employer's hazardous waste handling procedures including the materials handling program and elements of the spill containment program, location of spill response kits or equipment, and the names of those trained to respond to releases. (c) The hazardous communication program meeting the requirements of 29 CFR 1910.1200. (d) A review of the employer's medical surveillance program including the recognition of signs and symptoms of exposure to relevant hazardous substance including known synergistic interactions. (e) A review of the employer's decontamination program and procedures. (f) An review of the employer's training program and the parties responsible for that program. (g) A review of the employer's personal protective equipment program including the proper selection and use of PPE based upon specific site hazards. (h) All relevant site-specific procedures addressing potential safety and health hazards. This may include, as appropriate, biological and radiological exposures, fire and explosion hazards, thermal hazards, and physical hazards such as electrical hazards, powered equipment hazards, lock-outtag-out hazards, motor vehicle hazards, and walking-working surface hazards. (i) Safe use engineering controls and equipment on site. (j) Names of personnel and alternates responsible for safety and health.
SuggestedTraining Curriculum Guidelines
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C. Emergency Response Training
Federal OSHA standards in 29 CFR 1910.120(q) are directed toward private sector emergency responders. Therefore, the guidelines provided in this portion of the appendix are directed toward that employee population. However, they also impact indirectly through State OSHA or USEPA regulations some public sector emergency responders. Therefore, the guidelines provided in this portion of the appendix may be applied to both employee populations. States with OSHA state plans must cover their employees with regulations at least as effective as the Federal OSHA standards. Public employees in states without approved state OSHA programs covering hazardous waste operations and emergency response are covered by the U.S. EPA under 40 CFR 311, a regulation virtually identical to Sec. 1910.120. Since this is a nonmandatory appendix and therefore not an enforceable standard, OSHA recommends that those employers, employees, or volunteers in public sector emergency response organizations outside Federal OSHA jurisdiction consider the following criteria in developing their own training programs. A unified approach to training at the community level between emergency response organizations covered by Federal OSHA and those not covered directly by Federal OSHA can help ensure an effective community response to the release or potential release of hazardous substances in the community. a. General Considerations
Emergency response organizations are required to consider the topics listed in Sec. 1910.120(q)(6). Emergency response organizations may use some or all of the following topics to supplement those mandatory topics when developing their response training programs. Many of the topics would require an interaction between the response provider and the individuals responsible for the site where the response would be expected. (1) Hazard recognition, including: (A) Nature of hazardous substances present, (B) Practical applications of hazard recognition, including presentations on biology, chemistry, and physics. (2) (3) (4) (5) (6) (7)
Principles of toxicology, biological monitoring, and risk assessment. Safe work practices and general site safety. Engineering controls and hazardous waste operations. Site safety plans and standard operating procedures. Decontamination procedures and practices. Emergency procedures, first aid, and self-rescue.
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(8) Safe use of field equipment. (9) Storage, handling, use, and transportation of hazardous substances. (10) Use, care, and limitations of personal protective equipment. (11) Safe sampling techniques. (12) Rights and responsibilities of employees under OSHA and other related laws concerning right-to-know, safety and health, compensations, and liability. (13) Medical monitoring requirements. (14) Community relations. b. Suggested Criteria for Specific Courses
(1) First responder awareness level. (A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q). (B) Hands-on experience with the U.S. Department of Transportation's Emergency Response Guidebook (ERG) and familiarization with OSHA standard 29 CFR 1910.1201. (C) Review of the principles and practices for analyzing an incident to determine both the hazardous substances present and the basic hazard and response information for each hazardous substance present. (D) Review of procedures for implementing actions consistent with the local emergency response plan, the organization's standard operating procedures, and the current edition of DOT's ERG including emergency notification procedures and follow-up communications. (E) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards. (F) Awareness and knowledge of the competencies for the First Responder at the Awareness Level covered in the National Fire Protection Association's Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents. (2) First responder operations level. (A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q). (B) Hands-on experience with the U.S. Department of Transportation's Emergency Response Guidebook (ERG), manufacturer material safety data sheets, CHEMTREC/CANUTEC, shipper or manufacturer contacts, and other relevant sources of information addressing hazardous substance releases. Familiarization with OSHA standard 29 CFR 1910.1201. (C) Review of the principles and practices for analyzing an incident to determine the hazardous substances present, the likely behavior of the
Suggested Training Curriculum Guidelines
485
hazardous substance and its container, the types of hazardous substance transportation containers and vehicles, and the types and selection of the appropriate defensive strategy for containing the release. ( D ) Review of procedures for implementing continuing response actions consistent with the local emergency response plan, the organization’s standard operating procedures, and the current edition of DOT’S ERG including extended emergency notification procedures and follow-up communications. (E) Review of the principles and practice for proper selection and use of personal protective equipment. (F) Review of the principles and practice of personnel and equipment decontamination. ( G ) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards. (H) Awareness and knowledge of the competencies for the First Responder at the Operations Level covered in the National Fire Protection Association’s Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents. ( 3 ) Hazardous materials technician. (A) Review of and demonstration of competency in performing the applicable skills of 2 9 CFR 1910.120(q). (B) Hands-on experience with written and electronic information relative to response decision making including but not limited to the 1J.S. Department of Transportation’s Emergency Response Guidebook (ERG), manufacturer material safety data sheets, CHEMTREUCANUTEC, shipper or manufacturer contacts, computer data bases and response models, and other relevant sources of information addressing hazardous substance releases. Familiarization with OSHA standard 29 CFR 1910.1201. (C) Review of the principles and practices for analyzing an incident to determine the hazardous substances present, their physical and chemical properties, the likely behavior of the hazardous substance and its container, the types of hazardous substance transportation containers and vehicles involved in the release, and the appropriate strategy for approaching release sites and containing the release. ( D ) Review of procedures for implementing continuing response actions consistent with the local emergency response plan, the organization’s standard operating procedures, and the current edition of DOT’S ERG including extended emergency notification procedures and follow-up communications. (E) Review of the principles and practice for proper selection and use of personal protective equipment.
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(F) Review of the principles and practices of establishing exposure zones, proper decontamination and medical surveillance stations and procedures. (G) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards. (H) Awareness and knowledge of the competencies for the Hazardous Materials Technician covered in the National Fire Protection Association's Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents. (4) Hazardous materials specialist. (A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q). (B) Hands-on experience with retrieval and use of written and electronic information relative to response decision making including but not limited to the U.S. Department of Transportation's Emergency Response Guidebook (ERG), manufacturer material safety data sheets, CHEMTREC/ CANUTEC, shipper or manufacturer contacts, computer data bases and response models, and other relevant sources of information addressing hazardous substance releases. Familiarization with OSHA standard 29 CFR 1910.1201. (C) Review of the principles and practices for analyzing an incident to determine the hazardous substances present, their physical and chemical properties, and the likely behavior of the hazardous substance and its container, vessel, or vehicle. (D) Review of the principles and practices for identification of the types of hazardous substance transportation containers, vessels, and vehicles involved in the release; selecting and using the various types of equipment available for plugging or patching transportation containers, vessels or vehicles; organizing and directing the use of multiple teams of hazardous material technicians and selecting the appropriate strategy for approaching release sites and containing or stopping the release. (E) Review of procedures for implementing continuing response actions consistent with the local emergency response plan, the organization's standard operating procedures, including knowledge of the available public and private response resources, establishment of an incident command post, direction of hazardous material technician teams, and extended emergency notification procedures and follow-up communications. (F) Review of the principles and practice for proper selection and use of personal protective equipment. (G) Review of the principles and practices of establishing exposure zones and proper decontamination, monitoring and medical surveillance stations and procedures.
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487
(H) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards. (I) Awareness and knowledge of the competencies for the Off-Site Specialist Employee covered in the National Fire Protection Association's Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents. (5) Incident commander. The incident commander is the individual who, at any one time, is responsible for and in control of the response effort. This individual is the person responsible for the direction and coordination of the response effort. An incident commander's position should be occupied by the most senior, appropriately trained individual present at the response site. Yet, as necessary and appropriate by the level of response provided, the position may be occupied by many individuals during a particular response as the need for greater authority, responsibility, or training increases. It is possible for the first responder at the awareness level to assume the duties of incident commander until a more senior and appropriately trained individual arrives at the response site. Therefore, any emergency responder expected to perform as an incident commander should be trained to fulfill the obligations of the position at the level of response they will be providing including the following: (A) Ability to analyze a hazardous substance incident to determine the magnitude of the response problem. (B) Ability to plan and implement an appropriate response plan within the capabilities of available personnel and equipment. (C) Ability to implement a response to favorably change the outcome of the incident in a manner consistent with the local emergency response plan and the organization's standard operating procedures. (D) Ability to evaluate the progress of the emergency response to ensure that the response objectives are being met safely, effectively, and efficiently. (E) Ability to adjust the response plan to the conditions of the response and to notify higher levels of response when required by the changes to the response plan. [54 FR 9317, Mar. 6, 1898, as amended at 55 FR 14073, Apr. 13, 1990; 56 FR 15832, Apr. 18, 1991; 59 FR 43268, Aug.22, 1994; 61 FR 9227, March 7, 1996]
TERRORISM INCIDENT AN N EX TO TH E FEDERAL RESPONSE PLAN
INTRODUCTION
In June 1995, the White House issued Presidential Decision Directive 39 (PDD-39), "'United States Policy on Counterterrorism." PDD-39 directed a number of measures to reduce the Nation's vulnerability to terrorism, to deter and respond to terrorist acts, and to strengthen capabilities to prevent and manage the consequences of terrorist use of nuclear, biological, and chemical (NBC) weapons including weapons of mass destruction (WMD). PDD-39 discusses crisis management and consequence management. Crisis management includes measures to identify, acquire, and plan the use of resources needed to anticipate, prevent, and/or resolve a threat or act of terrorism. The laws of the United States assign primary authority to the federal government to prevent and respond to acts of terrorism; state and local governments provide assistance as required. Crisis management is predominantly a law enforcement response. Based on the situation, a federal crisis management response may be supported by technical operations, and by federal consequence management, which may operate concurrently. Consequence management includes measures to protect public health and safety, restore essential government services, and provide emergency relief to governments, businesses, and individuals affected by the consequences of terrorism. The laws of the United States assign primary authority to the states to respond to the consequences of terrorism; the federal government provides assistance as required. 488
Policies
489
Purpose The purpose of this Terrorism Incident Annex, hereafter referred to as the Annex, is to describe the federal concept of operations to implement PDD-39, when necessary, to respond to terrorist incidents within the United States. The Annex: 1. Describes crisis management. Guidance is provided in other federal plans. 2. Defines the policies and structures to coordinate crisis management with consequence management. 3. Defines consequence management, which uses Federal Response Plan (FRP) structures, supplemented as necessary by structures that are normally activated through other federal plans.
Scope 1. The Annex applies to all threats or acts of terrorism within the United States that the White House determines require a federal response. 2. The Annex applies to all federal departments and agencies that may be directed to respond to a threat or act of terrorism within the United States. 3. The Annex builds upon FRP concepts and procedures by addressing unique policies, assumptions, structures, responsibilities, and actions that will be applied for consequence management as necessary.
POLICIES Lead Agency Responsibilities PDD-39 validates and reaffirms existing Federal Lead Agency responsibilities for counterterrorism, which are assigned to the Department of Justice, as delegated to the Federal Bureau of Investigation (FBI), for threats or acts of terrorism within the United States. It is FBI policy that crisis management will involve only those federal agencies requested by the FBI to provide expert guidance and/or assistance, as described in the PDD-39 Domestic Guidelines (classified) and FBI Incident Contingency Plans (classified).
Consequence Management PDD-39 states that the Federal Emergency Management Agency (FEMA) shall ensure that the FRP is adequate to respond to the consequences
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Appendix I
of terrorism. FEMA, with the support of all agencies in the FRP, shall act in support of the FBI in Washington, DC, and on the scene of the crisis, until such time as the Attorney General shall transfer the Lead Agency role to FEMA. FEMA retains responsibility for consequence management throughout the federal response, and acts in support of the FBI as appropriate, until the Attorney General, in consultation with the FBI Director and the FEMA Director, determines that such support is no longer required. It is FEMA policy to use FRP structures to coordinate all federal assistance to state and local governments for consequence management.
Costs
PDD-39 states that federal agencies directed to participate in the resolution of terrorist incidents or conduct of counterterrorist operations shall bear the costs of their own participation, unless otherwise directed by the President.
SITUATION Conditions
1. A general concern or actual threat of an act of terrorism occurring at or during a special event within the United States may cause the President to direct federal agencies to implement precautionary measures which may include some of the consequence management actions described in this Annex. When directed, FEMA will coordinate with the FBI and the affected state to identify potential consequence management requirements and with federal consequence management agencies to implement increased readiness operations. 2. A significant threat or act of terrorism may cause the FBI to respond and to implement a crisis management response as described in this Annex. FBI requests for assistance from other federal agencies will be coordinated through the Attorney General and the President with coordination of NSC groups as warranted. During the course of a crisis management response, consequences may become imminent or occur that cause the President to direct FEMA to implement a consequence management response as described in this Annex. 3. The occurrence of an incident without warning that produces major consequences involving NBC/WMD may cause the President to direct FEMA to implement a consequence management response as described in this Annex.
Concept of Operations
491
Planning Assumptions 1. No single agency at the local, state, federal, or private level possesses the authority and the expertise to act unilaterally on many difficult issues that may arise in response to threats or acts of terrorism, particularly if NBC/WMD are involved. 1 2. An act of terrorism, particularly an act directed against a large population center within the United States involving NBC/WMD, may produce major consequences that would overwhelm the capabilities of many local and state governments almost immediately. Major consequences involving NBC/WMD may overwhelm existing federal capabilities as well. 3. Local, state, and federal responders may define working perimeters, which may overlap to some degree. Perimeters may be used to control access to the area, target public information messages, assign operational sectors among responding organizations, and assess potential effects on the population and the environment. Control of these perimeters may be enforced by different authorities, which may impede the overall response if adequate coordination is not established. 4. If protective capabilities are not available, responders cannot be required to put their own lives at risk in order to enter a perimeter contaminated with NBC material. It is possible that the perimeter will be closed until the effects of the NBC material have degraded to levels that are safe for first responders. 5. This Annex may be implemented in situations involving major consequences in a single state or multiple states. The FBI will establish coordination relationships among FBI Field Offices and with federal agencies supporting crisis management, including FEMA, based on the locations involved. 2 6. This Annex may be implemented in situations that also involve consequences in neighboring nations.
CONCEPT OF OPERATIONS Crisis Management (FBI, National Security Division, Domestic Terrorism/Counterterrorism Planning Section) PDD-39 reaffirms the FBI's federal lead responsibility for crisis management response to threats or acts of terrorism that take place within United 1FEMA will incorporate language into the FRP Basic Plan concerning the incident command system (ICS) and command structures. 2FEMA will incorporate language into an FRP procedure and FEMA internal procedures for backup operations concerning support to multiple terrorism operations within a single state or in multiple states.
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States territory or in international waters and do not involve the flag vessel of a foreign country. The FBI provides a graduated flexible response to a range of incidents, including: 9 A credible threat, which may be verbal, written, intelligence-based, or in another form. 9 An act of terrorism which exceeds the local FBI field division capability to resolve. 9 The confirmed presence of an explosive device or WMD capable of causing a significant destructive event, prior to actual injury or property loss (e.g., a significant threat). 9 The detonation of an explosive device, utilization of a WMD, or other destructive event, with or without warning, that results in limited injury or death (e.g., limited consequences/state and local consequence management response). 9 The detonation of an explosive device, utilization of a WMD, or other destructive event, with or without warning, that results in substantial injury or death (e.g., major consequences/federal consequence management response). In response to a credible threat involving NBC/WMD, the FBI initiates a threat assessment process that involves close coordination with federal agencies with technical expertise, in order to determine the viability of the threat from a technical, as well as tactical and behavioral, standpoint. The FBI provides the initial notification to law enforcement authorities within the affected state of a threat or occurrence that the FBI confirms as an act of terrorism. If warranted, the FBI implements an FBI response and simultaneously advises the Attorney General, who notifies the President and NSC groups as warranted, that a federal crisis management response is required. If federal crisis management response is authorized, the FBI activates multiagency crisis management structures at FBI Headquarters, at the responsible FBI Field Office, and at the incident site. (The FBI provides guidance on the crisis management response in the FBI Nuclear Incident Contingency Plan (classified) and the FBI Chemical/Biological Incident Contingency Plan (classified.) If the threat involves NBC/WMD, the FBI Director may recommend to the Attorney General, who notifies the President and NSC groups as warranted, to deploy a Domestic Emergency Support Team (DEST). The mission of the DEST is to provide expert advice and assistance to the FBI On-Scene Commander (OSC) related to the capabilities of the DEST agencies and to coordinate follow-on response assets. When deployed, the DEST merges into the existing Joint Operations Center (JOC) structure. (Authorization and coordination procedures and the interagency organizational structure for the DEST are outlined in the PDD-39 Domestic Guidelines (classified)).
Concept of Operations
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During crisis management, the FBI coordinates closely with local law enforcement authorities to provide a successful law enforcement resolution to the incident. The FBI also coordinates with other federal authorities, including FEMA. The FBI Field Office responsible for the incident site modifies its Command Post to function as a JOC. The JOC structure includes the following standard groups: Command, Operations, Support, and Consequence Management. Representation within the JOC includes some federal, state, and local agencies with roles in consequence management. FEMA notitles federal, state, and local consequence management agencies selected by the FBI OSC to request that they deploy representatives to the JOC. Selected federal, state, and local consequence management agencies may be requested to serve in the JOC Command Group, the JOC Support Group/Media component, and the JOC Consequence Management Group. A FEMA representative coordinates the actions of the JOC Consequence Management Group, expedites activation of a federal consequence management response should it become necessary, and works with an FBI representative who serves as the liaison between the Consequence Management Group and the FBI OSC. The JOC Consequence Management Group monitors the crisis management response in order to advise on decisions that may have implications for consequence management, and to provide continuity should a federal consequence management response become necessary.
Consequence Management Preincident The FBI may notify federal agencies, including FEMA, of a significant threat of an act of terrorism. Federal agencies requested by the FBI, including FEMA, will deploy a representative(s) to the FBI Headquarters Strategic Information Operations Center (SIOC). Based on the circumstances, FEMA Headquarters and the responsible FEMA Region(s) may implement a standard procedure to alert involved FEMA officials and federal agencies supporting consequence management. FEMA and other federal agencies requested by the FBI OSC will deploy representatives to the JOC(S) being established by the responsible FBI Field Office(s). 3 Representatives may in-
3FEMA Headquarters will develop planning guidance for the FEMA Regions to incorporate language into the Regional Response Plans to explain that the senior FEMA official at the JOC has the authority to expedite activation of a federal consequence management response. Following a Stafford Act declaration, federal consequence management operations will transition from the JOC Consequence Management Group, supported by the ROC, to a DFO.
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clude a senior official to serve in the JOC Command Group, in order to assist the FBI OSC and to provide continuity in leadership should a federal consequence management response be required. Issues arising from the response that affect multiple agency authorities and areas of expertise will be discussed by the FBI OSC and the other members of the JOC Command Group, who are all working in consultation with other local, state, and federal representatives. While the FBI OSC retains authority to make federal crisis management decisions at all times, operational decisions are made cooperatively to the greatest extent possible. The FBI OSC and the senior FEMA official will provide, or obtain from higher authority, an immediate resolution of conflicts in priorities for allocation of critical federal resources (such as airlift or technical operations assets) between the crisis management and the consequence management response. The JOC Command Group plays an important role in ensuring coordination of Federal crisis management and consequence management actions. Coordination will also be achieved through the exchange of operational reports on the incident. Because reports prepared by the FBI are "law enforcement sensitive," FEMA representatives with access to the reports will review them, according to standard procedure, in order to identify and forward information to Emergency Support Function (ESF) No. 5 that may affect operational priorities and action plans for consequence management. As a situation progresses, consequences may become imminent. FEMA will consult immediately with the White House and the Governor's office in order to determine if FEMA is directed to use authorities of the Robert T. Stafford Disaster Relief and Emergency Assistance (Stafford) Act to mission-assign federal consequence management agencies to predeploy assets, in order to lessen or avert the threat of a catastrophe. These actions will involve appropriate notification and coordination with the FBI, as the overall Federal Lead Agency for counterterrorism. FEMA Headquarters may activate an Emergency Support Team (EST), may convene an executive-level meeting of the Catastrophic Disaster Response Group (CDRG), and may place an Emergency Response Team-National (ERT-N) on alert. 4 When FEMA activates the EST, FEMA will notify FBI Headquarters to request a liaison. The responsible FEMA region(s) may activate a Regional Operations Center (ROC) and deploy a representative(s) to the affected state(s). When the responsible FEMA region(s) activate a ROC, the region(s) will notify the responsible FBI Field Office(s) to request a liaison.
4FEMA will incorporate language into the FRP BasicPlan concerningthe EmergencyResponse Team - National.
Concept of Operations
495
Trans-lncident (Situations Involving a Transition from a Threat to an Act of Terrorism)
If consequences become imminent or occur that cause the President to direct FEMA to implement a federal consequence management response, then FEMA will initiate procedures to activate additional FRP structures(the EST, the CDRG, the ROC, and a Disaster Field Office (DFO)if necessary). Federal, state, and local consequence management agencies will begin to disengage from the JOC. The senior FEMA official and liaisons will remain at the JOC until the FBI and FEMA agree that a liaison presence is no longer required. FEMA will establish Joint Information Centers (JICS) in the field and Washington, DC, to serve as the primary federal information centers on the consequence management response for the media, Members of Congress, and foreign governments. FEMA JICS will establish coordination with the FBI media component in the field and the FBI Headquarters National Press Office, which serve as the primary federal information centers on the crisis management response.
Postincident (Situations without Warning) If an incident occurs without warning that produces major consequences and appears to be caused by an act of terrorism, then FEMA and the FBI will initiate consequence management and crisis management actions concurrently. FEMA will consult immediately with the White House and the Governor's office to determine if a federal consequence management response is required. If the President directs FEMA to implement a federal consequence management response, then FEMA will implement portions of this Annex and other FRP annexes as required. FEMA will support the FBI as required and will lead a concurrent federal consequence management response. During the consequence management response, the FBI provides a liaison to either the ROC Director or the Federal Coordinating Officer (FCO) in the field, and a liaison to the EST Director at FEMA Headquarters. Issues arising from the response that affect multiple agency authorities and areas of expertise will be discussed by the ROC Director or FCO, in consultation with the FBI liaison, the on-scene decision-makers of the federal agencies supporting the technical operation, and the ESF Leaders, who are all working in consultation with local, state, and other federal representatives. While the ROC Director or FCO retains authority to make federal consequence management decisions at all times, operational decisions are made cooperatively to the greatest extent possible. Meetings will continue to be scheduled until the FBI and FEMA agree that coordination is no longer required. Op-
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erational reports will continue to be exchanged, as described in the preincident phase. The FBI liaisons will remain at the EST and the ROC or DFO until FEMA and the FBI agree that a liaison presence is no longer required.
Disengagement If an act of terrorism does not occur, then the consequence management response disengages when the FEMA Director, in consultation with the FBI Director, directs FEMA Headquarters and the responsible region(s) to issue a cancellation notification by standard procedure to appropriate FEMA officials and FRP agencies. FRP agencies disengage according to standard procedure. If an act of terrorism occurs that results in major consequences, then each FRP structure (the EST, the CDRG, the ROC, and the DFO if necessary) disengages at the appropriate time according to standard procedures. Following FRP disengagement, operations by individual federal agencies or by multiple federal agencies under other federal plans may continue, in order to support the affected state and local governments with long-term hazard monitoring, environmental decontamination, and site restoration (clean-up).
RESPONSIBILITIES FBI PDD-39 clarifies and expands upon the responsibilities of the FBI as the Federal Lead Agency for crisis management. The FBI will: 9 Appoint an FBI OSC to provide leadership and direction to the federal crisis management response. The FBI OSC will convene meetings with decision-makers representing FEMA, the federal agencies involved in technical operations, and the state (as appropriate). These meetings will be held in order to formulate incident action plans, define priorities, review status, resolve conflicts, identify issues that require decisions from higher authorities, and evaluate the need for additional resources. 9 Issue and track the status of crisis management actions assigned to federal agencies. A common system should be used by the FBI and FEMA, in order to provide a capability to control, prioritize, and deconflict taskings to federal agencies, several of which support crisis management and consequence management. 9 Establish the primary federal operations centers for crisis management in the field and Washington, DC.
Responsibilities
497
9 Establish the primary federal centers for information on the crisis management response for the media, Members of Congress, and foreign governments in the field and Washington, DC. 9 Designate appropriate liaison and advisory personnel to support FEMA. 9 Determine when a threat of an act of terrorism warrants consultation with the White House. 9 Advise the White House, through the Attorney General, when the FBI requires assistance for a federal crisis management response, in accordance with the PDD-39 Domestic Guidelines. 9 Coordinate the federal crisis management response with the lead state and local crisis management agencies. FEMA
PDD-39 clarifies and expands upon the responsibilities of FEMA as the Federal Lead Agency for consequence management. FEMA will: 9 Appoint a ROC Director or FCO to provide leadership and direction to the federal consequence management response. The ROC Director or FCO will convene meetings with decision-makers representing the FBI, the federal agencies involved in technical operations, and the state (as appropriate). These meetings will be held in order to formulate incident action plans, define priorities, review status, resolve conflicts, identify issues that require decisions from higher authorities, and evaluate the need for additional resources. 9 Issue and track the status of consequence management actions assigned to federal agencies. A common system should be used by the FBI and FEMA, in order to provide a capability to control, prioritize, deconflict, and (as appropriate) audit and reimburse taskings to federal agencies, several of which support crisis management and consequence management. 9 Establish the primary federal operations centers for consequence management in the field and Washington, DC. 9 Establish the primary federal centers for information on the consequence management response for the media, Members of Congress, and foreign governments in the field and Washington, DC. 9 Designate appropriate liaison and advisory personnel to support the FBI. 9 Determine when consequences are imminent that warrant consultation with the White House and the Governor's office. 9 Consult with the White House and the Governor's office to determine if a federal consequence management response is required
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and if FEMA is directed to use Stafford Act authorities. This process will involve appropriate notification and coordination with the FBI. 9 Coordinate the federal consequence management response with the lead state and local consequence management agencies.
Federal Agencies Supporting Technical Operations Department of Defense As directed in PDD-39, the Department of Defense (DOD) will activate technical operations capabilities to support the federal response to threats or acts of NBC/WMD terrorism. As required under the Constitution and laws of the United States, DOD will coordinate military operations within the United States with the appropriate civilian lead agency(ies) for the technical operations.
Department of Energy As directed in PDD-39, the Department of Energy (DOE) will activate nuclear response capabilities to support the federal response to threats or acts of nuclear/WMD terrorism. DOE may coordinate with individual agencies identified in the FRERP to use the structures, relationships, and capabilities described in the FRERP to support response operations. The FRERP does not require formal implementation. Under the FRERP: 9 The federal OSC under the FRERP will coordinate the FRERP response with the FEMA official (either the senior FEMA official at the JOC, the ROC Director, or the FCO), who is responsible under PDD-39 for on-scene coordination of all federal support to state and local governments. 9 The FRERP response may include on-site management, radiological monitoring and assessment, development of federal protective action recommendations, and provision of information on the radiological response to the public, the White House and Members of Congress, and foreign governments. The Lead Federal Agency (LFA) of the FRERP will serve as the primary federal source of information regarding on-site radiological conditions and off-site radiological effects. 9 The LFA/FRERP will issue taskings that draw upon tiding from the responding FRERP agencies.
Responsibilities
499
Department of Health and Human Services
As directed in PDD-39, the Department of Health and Human Services (DHHS) will activate health and medical response capabilities to support the federal response to threats or acts of NBC/WMD terrorism. DHHS may coordinate with individual agencies identified in the DHHS Health and
Medical Services Support Plan for the Federal Response to Acts of Chemical/ Biological Terrorism, to use the structures, relationships, and capabilities described in the DHHS plan to support response operations. If the DHHS plan is formally implemented: 9 The DHHS on-scene representative will coordinate, through the ESF No. 8 Leader, the DHHS plan response with the FEMA official (the senior FEMA official at the JOC, the ROC Director, or the FCO), who is responsible under PDD-39 for on-scene coordination of all federal support to state and local governments. 9 The DHHS plan response may include threat assessment, consultation, agent identification, epidemiological investigation, hazard detection and reduction, decontamination, public health support, medical support, and pharmaceutical support operations. 9 DHHS will issue taskings that draw upon tiding from the responding DHHS plan agencies.
Environmental Protection Agency
As directed in PDD-39, the Environmental Protection Agency (EPA) will activate environmental response capabilities to support the Federal response to acts of NBC/WMD terrorism. EPA may coordinate with individual agencies identified in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to use the structures, relationships, and capabilities of the National Response System as described in the NCP to support response operations. If the NCP is formally implemented: 9 The On-Scene Coordinator under the NCP will coordinate, through the ESF No. 10 Leader, the NCP response with the FEMA official (the senior FEMA official at the JOC, the ROC Director, or the FCO), who is responsible under PDD-39 for on-scene coordination of all federal support to state and local governments. 9 The NCP response may include threat assessment, consultation, agent identification, hazard detection and reduction, environmental monitoring, decontamination, and long-term site restoration (environmental clean-up) operations.
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F U N D I N G GUIDELINES
As stated in PDD-39, federal agencies directed to participate in the resolution of terrorist incidents or conduct of counterterrorist operations bear the costs of their own participation, unless otherwise directed by the President. This does not preclude federal agencies from reallocating funds from current agency operating budgets, accepting reimbursable work orders offered by other federal agencies, and/or submitting requests for supplemental appropriation to the Office of Management and Budget for consideration. If the President directs FEMA to use Stafford Act authorities, FEMA will issue mission assignments through the FRP to support consequence management. FEMA provides the following finding guidance to the FRP agencies:
Special Events and the Stafford Act
Commitments by individual agencies to take precautionary measures in anticipation of special events will not be reimbursed under the Stafford Act, unless mission-assigned by FEMA to support consequence management.
Crisis Management/Law Enforcement and the Stafford Act
Stafford Act authorities do not pertain to law enforcement functions. Law enforcement or crisis management actions will not be mission-assigned for reimbursement under the Stafford Act. s
REFERENCES ( N O T OTHERWISE REFERENCED IN THE FRP)
A. Presidential Decision Directive 39 (classified). An unclassified extract may be obtained from FEMA. B. FBI Chemical/Biological Incident Contingency Plan (classified). An unclassified version may be obtained from the FBI. C. FBI Nuclear Incident Contingency Plan (classified). An unclassified version may be obtained from the FBI. D. PDD-39 Domestic Guidelines (classified).
5FEMA will review and update language concerning Stafford Act declarations and mission assignments in the FRP Basic Plan, as follows:
Primary Point of Contact
501
E. DHHS Health and Medical Services Support Plan for the Federal Response to Acts of ChemicalfBiological Terrorism. PRIMARY P O I N T OF C O N T A C T
Inquiries concerning this Annex should be addressed to the Federal Emergency Management Agency, Response and Recovery Directorate, Operations and Planning Division, Planning and Coordination Branch. 6,v
6FEMA will update FRP Appendix A. The following acronyms and abbreviations used in the Annex will be incorporated: DEST, Domestic Emergency Support Team FBI OSC, On-Scene Commander JOC, Joint Operations Center NBC, Nuclear, Biological, and Chemical NSC, National Security Council PPD-39, Presidential Decision Directive 39 SIOC, Strategic Information Operations Center WMD, Weapons of Mass Destruction 7FEMA will incorporate these terms and definitions into the FRP Appendix B: 1. Biological agents are microorganisms or toxins from living organisms that have infectious or noninfectious properties which produce lethal or serious effects in plants and animals. (FBI) 2. Chemical agents are solids, liquids, or gases that have chemical properties that produce lethal or serious effects in plants and animals. (FBI) 3. Limited consequences are within state and local capabilities. 4. Major consequences exceed state and local capabilities, requiring a federal response. 5. Nuclear weapons release nuclear energy in an explosive manner as the result of nuclear chain reactions involving fission and/or fusion of atomic nuclei. (DOE) 6. Significant threat. The confirmed presence of an explosive device or WMD capable of causing a significant destructive event, prior to actual injury or property loss. (FBI) 7. Technical operations include operations to identify, assess, dismantle, transfer, dispose, and decontaminate personnel and property exposed to explosive ordnance or NBC/ WMD material. 8. Terrorist Incident. A violent act, or an act dangerous to human life, in violation of the criminal laws of the United States or of any state, to intimidate or coerce a government, the civilian population, or any segment thereof, in furtherance of political or social objectives. 9. Weapon of Mass Destruction. (A) Any destructive device as defined in Section 921 of this title, (which reads) any explosive, incendiary, or poison gas, bomb, grenade, rocket having a propellant charge or more than four ounces, missile having an explosive or incendiary charge of more than one quarter ounce, mine or device similar to the above; (B) poison gas; (C) any weapon involving a disease organisms; or (D) any weapon that is designed to release radiation or radioactivity at a level dangerous to human life (18 U.S.C., Section 2332a)
502
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- - F O L L O W - O N PLANNING REQUIREMENTS-FEMA can use limited predeployment authorities in advance of a Stafford Act declaration to "lessen or avert the threat of a catastrophe," only if the President expresses intent to go forward with a declaration (Section 201). This authority is further interpreted by Congressional intent, to the effect that the President must determine that assistance under existing federal programs is inadequate to meet the crisis before FEMA may directly intervene under the Stafford Act. The Stafford Act authorizes the President to issue "emergency" and "major disaster" declarations (Section 501). Emergency declarations may be issued in response to a Governor's request, or in response to those rare emergencies, including some acts of terrorism, for which the federal government is assigned in the laws of the United States the exclusive or preeminent responsibility and authority to respond. Major disaster declarations may be issued in response to a Governor's request for any natural catastrophe or, regardless of cause, any fire, flood, or explosion which has caused damage of sufficient severity and magnitude, as determined by the President, to warrant major disaster assistance under the Act. If a Stafford Act declaration is provided, finding for consequence management may continue to be allocated from responding department and agency operating budgets, the Disaster Relief Fund, and supplemental appropriations. Mission assignments are reimbursable work orders issued by FEMA to federal agencies directing completion of a specific task. While the Stafford Act states that "Federal agencies may (emphasis added) be reimbursed for expenditures under the Act" from the Disaster Relief Fund (Section 304), it is FEMA policy to reimburse Federal agencies for work performed under mission assignments. Mission assignments issued to support consequence management will follow FEMA's "Standard Operating Procedures for the Management of Mission Assignments (May 1994)" or applicable superseding documentation.
PRESIDENTIAL DECISION DIRECTIVE 39 (UNCLASSIFIED)
The following is a copy of an unclassified1 abstract derived from Presidential Decision Directive 39 (PDD-39), United States Policy on Counterterrorism, dated June 21, 1995. This abstract has been reviewed and approved by the National Security Council (NSC) for distribution to federal, state, and local emergency response and consequence management personnel to assist them in responding to terrorist emergencies.
U N I T E D STATES P O L I C Y O N C O U N T E R T E R R O R I S M General Terrorism is both a threat to our national security as well as a criminal act. The Administration has stated that it is the policy of the United States to use all appropriate means to deter, defeat and respond to all terrorist attacks on our territory and resources, both people and facilities, wherever they occur. In support of these efforts, the United States will: 9 Employ efforts to deter, preempt, apprehend and prosecute terrorists. 9 Work closely with other governments to carry out our counterterrorism policy and combat terrorist threats against them. 1The full text of PDD-39 is a classified document. State and local officials, however, should understand that PDD-39 essentially gives the responsibility of response to terrorist attacks to the FBI for "crisis management" and FEMA for "consequence management." State and local agencies and assets will be expected to support the Federal efforts. 503
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Appendix J
9 Identify sponsors of terrorists, isolate them, and ensure they pay for their actions. 9 Make no concessions to terrorists.
Measures to C o m b a t T e r r o r i s m
To ensure that the United States is prepared to combat terrorism in all its forms, a number of measures have been directed. These include reducing vulnerabilities to terrorism, deterring and responding to terrorist acts, and having capabilities to prevent and manage the consequences of terrorist use of nuclear, biological, and chemical (NBC) weapons, including those of mass destruction.
a. Reduce Vulnerabilities
In order to reduce our vulnerabilities to terrorism, both at home and abroad, all department/agency heads have been directed to ensure that their personnel and facilities are fully protected against terrorism. Specific efforts that will be conducted to ensure our security against terrorist acts include the following: 9 Review the vulnerability of government facilities and critical national infrastructure. 9 Expand the program of counterterrorism. 9 Reduce vulnerabilities affecting civilian personnel/facilities abroad and military personnel/facilities. 9 Reduce vulnerabilities affecting U.S. airports, aircraft/passengers and shipping, and provide appropriate security measures for other modes of transportation. 9 Exclude/deport persons who pose a terrorist threat. 9 Prevent unlawful traffic in firearms and explosives, and protect the President and other officials against terrorist attack. 9 Reduce U.S. vulnerabilities to international terrorism through intelligence collection/analysis, counterintelligence and covert action.
b. Deter
To deter terrorism, it is necessary to provide a clear public position that our policies will not be affected by terrorist acts and we will vigorously deal with terrorist/sponsors to reduce terrorist capabilities and support. In this regard, we must make it clear that we will not allow terrorism to succeed
United States Policy on Counterterrorism
505
and that the pursuit, arrest, and prosecution of terrorists is of the highest priority. Our goals include the disruption of terrorist-sponsored activity including termination of financial support, arrest and punishment of terrorists as criminals, application of U.S. laws and new legislation to prevent terrorist groups from operating in the United States, and application of extraterritorial statutes to counter acts of terrorism and apprehend terrorists outside of the United States. Return of terrorists overseas, who are wanted for violation of U.S. law, is of the highest priority and a central issue in bilateral relations with any state that harbors or assists them. c. Respond
To respond to terrorism, we must have a rapid and decisive capability to protect Americans, defeat or arrest terrorists, respond against terrorist sponsors, and provide relief to the victims of terrorists. The goal during the immediate response phase of an incident is to terminate terrorist attacks so that the terrorists do not accomplish their objectives or maintain their freedom, while seeking to minimize damage and loss of life and provide emergency assistance. After an incident has occurred, a rapidly deployable interagency Emergency Support Team (EST) will provide required capabilities on scene: a Foreign Emergency Support Team (FEST) for foreign incidents and a Domestic Emergency Support Team (DEST) for domestic incidents. DEST membership will be limited to those agencies required to respond to the specific incident. Both teams will include elements for specific types of incidents such as nuclear, biological or chemical threats. The Director, FEMA, will ensure that the Federal Response Plan is adequate for consequence management activities in response to terrorist attacks against large U.S. populations, including those where weapons of mass destruction are involved. FEMA will also ensure that State response plans and capabilities are adequate and tested. FEMA, supported by all Federal Response Plan signatories, will assume the Lead Agency role for consequence management in Washington, DC, and on scene. If large scale casualties and infrastructure damage occur, the President may appoint a Personal Representative for consequence management as the on scene Federal authority during recovery. A roster of senior and former government officials willing to perform these functions will be created and the rostered individuals will be provided training and information necessary to allow them to be called upon on short notice. Agencies will bear the costs of their participation in terrorist incidents and counterterrorist operations, unless otherwise directed.
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d. NBC Consequence Management The development of effective capabilities for preventing and managing the consequences of terrorist use of nuclear, biological, or chemical (NBC) materials or weapons is of the highest priority. Terrorist acquisition of weapons of mass destruction is not acceptable and there is no higher priority than preventing the acquisition of such materials/weapons or removing this capability from terrorist groups. FEMA will review the Federal Response Plan on an urgent basis, in coordination with supporting agencies, to determine its adequacy in responding to an NBC-related terrorist incident; identify and remedy any shortfalls in stockpiles, capabilities or training; and report on the status of these efforts in 180 days.
NATIONAL FIRE ACADEMY AND EMERGENCY MANAGEMENT INSTITUTE COURSES REkATED TO CONSEQUENCE MANAGEMENT
The following National Fire Academy (NFA) and Emergency Management Institute (EMI) courses can assist fire and emergency services personnel in preparing for consequence management of terrorism incidents. Readiness for such occurrences is a logical extension of normal major incident preparation. These courses have components or modules that contribute to the development of skills, knowledge, and abilities of those who must be ready to respond to terrorist incidents.
N A T I O N A L FIRE A C A D E M Y (NFA) COURSES Hazardous Materials
0234 Chemistry of Hazardous Materials
A two-week course that focuses on the basic knowledge required to evaluate the potential hazards and behaviors of materials considered to be hazardous.
507
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R243 Hazardous Materials Incident Management
A six-day course that focuses on the duties and responsibilities of the emergency response personnel who will assume the Incident Commander (IC) role in hazardous materials emergencies. R229 Hazardous Materials Operating Site Practices
A two-week course that focuses on the strategies and safe procedures for alleviating the danger at hazardous materials incidents. F809 Initial Response to Hazardous Materials Incidents: Basic Concepts
A two-day course that gives students an understanding of the basic concepts and techniques of first response to hazardous materials incidents. F808 Initial Response to Hazardous Materials Incidents: Concept Implementation
A two-day course that expands upon the above course. New concepts and more detail are provided on procedures, usage, and related considerations following the basic chronology of a hazardous materials incident. Emergency Medical Services R I51 Advanced Leadership Issues in Emergency Medical Service
A two-week course designed for upper-management personnel who have organizational responsibility for emergency medical operations in their agency. Situational, scenario-based instruction is the foundation for this course. R150 Management of Emergency Medical Services A two-week course that focuses on current and emerging management practices as they relate to EMS in the fire service.
Emergency Medical Services/Hazardous Materials R247 Advanced Life Support Response to Hazardous Materials Incidents
A two-week course that focuses on in-depth chemistry, toxicology, and the medical management of victims for paramedic personnel.
National Fire Academy Courses
509
F246 Basic Life Support and Hazardous Materials Response A two-day course that focuses on critical concerns for emergency medical responders at hazardous materials incidents.
Safety F719 Incident Safety Officer
A two-day course that focuses on the Safety Officer's role at emergency responses, specifically on the Safety Officer role within the Incident Command System (ICS). Response to all-hazard types of situations is emphasized. F720 Health and Safety Officer
A two-day course that focuses on the Health and Safety Officer's role in identifying, evaluating, and implementing policy and procedures that affect health and safety aspects for first responders.
Command and Control
R306 Executive Analysis of Fire Service Operations in Emergency Management
A two-week course that is designed to prepare senior staff officers in the administrative functions necessary to manage the operational component of a fire and rescue department. R304 Command and Control of Fire Department Operations at Multialarm Incidents
A two-week course, using intensive simulation, that focuses on the command officer's responsibility while conducting major operations involving multialarm units. R308 Command and Control of Fire Department Operations at Natural and Manmade Disasters
A two-week course that focuses on fire and rescue department operations at natural and manmade disasters that may require interagency or interjurisdictional coordination.
510
Appendix K R314 Command and Control of Fire Department Operations at Target Hazards
A six-day course designed to introduce command officers to the complexities involved in commanding incidents at high-risk areas. R801 Fire Command Operations
A six-day course in which volunteer fire officers are introduced to incident command and study proper fire command techniques for control and extinguishment of fires ranging from small, residential structures to multi-occupancy, commercial complexes.
Managing Company Tactical Operations A series of four two-day courses that focus on fire and rescue practices dealing with confinement, extinguishment, water supply, salvage, and offensive and defensive firefighting operations. Courses are divided into Preparation (F375), Decisionmaking (F450), Tactics (F451), and Simulation (no course number assigned).
Command and Control/Emergency Medical Services F I60 Incident Command System for Emergency Medical Services
A two-day course that focuses on the concepts of EMS-specific incident command using lecture, role play, simulation, case studies, and graphics.
Arson R205 Fire/Arson Investigation A two-week course that addresses the basic skills needed to conduct fire investigations. Students will be equipped to identify the origin and cause of fires, to conduct a technically and legally sound investigation, and to pursue the case through the judicial system. R81 I Fire Cause Determination for Company Officers
A six-day course that addresses the skills needed to conduct initial fire cause determinations.
National Fire Academy Courses
5 J]
R207 Management for Arson Prevention and Control
A two-week course that focuses on innovative concepts and practical skills for managing a synergistic response to arson prevention and control.
R216 Initial Fire Investigation A six-day course that focuses on the needs of personnel whose duties include determining origin and cause, and responsibility for fires and explosions based primarily on examination of the incident scene.
Emergency Response to Terrorism: Self Study (ERT:SS) This home study course is a self-study, self-paced, paper-based document and is designed to provide the basic awareness training that first responders need to increase the chances for successful and safe response to incidents involving terrorism. The target audience for ERT:SS includes fire, emergency medical, hazmat, incident command, and law enforcement responders. At present the intent is to produce 100,000 copies of the ERT:SS document. This would provide, initially, one for every fire department in the U.S. (approximately 35,000). ERT:SS will provide a basic overview of the following: 9 definition and historical background of terrorism; 9 recognizing suspicious circumstances and identifying key indicators (outward warning signs or cues); 9 implementing self-protective measures (time, distance, and shielding); 9 initial scene control; and 9 making appropriate notification (activating response resources based on local/state emergency plans).
Emergency Response to Terrorism: Basic Concepts (ERT:BC) The intent of this two-day course is to prepare first responders for terrorist-related incidents primarily at the operations level. The key learning objectives focus on life safety and self-preservation. The target audience for ERT:BC includes fire, emergency medical, hazmat, incident command, and law enforcement responders. ERT:BC will provide a basic overview of the following: 9 understanding and recognizing terrorism; 9 implementing self-protective measures;
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9 scene control; 9 tacticalconsiderations; and 9 incident management overview. Content will include information on detection and monitoring for various hazards.
Proposed Future Developments Two additional classes are being proposed:
Emergency Responseto Terrorism: Tactical Considerations (ERT:TC) This course will be a six-day NFA resident course dealing with emergency medical, hazardous materials, and incident command issues. This course will be designed primarily for technician- and specialist-level personnel who will be directly involved with advanced tactical operations. Proposed content for this course will be 9 emergency medical issues; 9 tactical operations (detection and monitoring, suit selection); and 9 incident command.
Emergency Responseto Terrorism: Incident Management (ERT:IM) This course will be a six-day NFA resident course designed for Incident Commanders who would be responsible for managing terrorism incidents. Proposed content for this course will be 9 9 9 9
Incident Command (unified command, mass casualty issues); Federal Response Plan (PDD-39); activating federal resources; and planning (all-hazard approach, threat/capability assessment).
In addition, a job aid (reference guide) is proposed for development. The intent of this document would be as a small reference document that could be used on-scene by emergency responders to assist them with mitigating the incident.
Degrees at a Distance Disaster and Fire Defense Planning A course offered through the NFA's Degrees at a Distance Program that focuses on the concepts and principles of community fire risk assessment, as related to group fires and disasters (no course number assigned).
Emergency Management Institute Courses
513
Managerial Issuesin Hazardous Materials A course offered through the NFA's Degrees at a Distance Program that focuses on the issues that confront hazardous materials program managers, from planning to postincident phases (no course number assigned).
EMERGENCY MANAGEMENT INSTITUTE (EMI) COURSES E417 Community Emergency Response Team (CERT) Train-the-Trainer Course A two-and-a-half-day course conducted in residence at EMI prepares participants to institute a CERT program in their communities. Topics include fire suppression, disaster medical operations, light search and rescue, and team organization and management.
G357 Emergency Response to Criminal and Terrorist Incidents A six-hour workshop course that sensitizes responders to the special issues involved in responding to an event that may involve a crime. Topics such as preservation of evidence are covered in detail.
G I20 Exercise Design Course A two-day course designed to enable participants to conduct community emergency management exercises to test the communities' emergency operations plans and to rehearse key response personnel.
G I30 Exercise Evaluation Course A two-day course that enables participants to manage exercise evaluation activities before, during, and following an exercise.
G 191 Incident Command System (ICS)/Emergency Operations Center (EOC) Interface A one-and-a-half-day field course designed for delivery to ICS and EOC personnel in a community. Course provides an opportunity to develop
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a working interface between the IC and the EOC. The course reviews ICS and EOC concepts and uses exercises to demonstrate key points.
G I90 Incident Command System (ICS) for Law Enforcement Personnel A 12-hour field course introduces police and other law enforcement personnel to ICS and provides opportunities for exercising the concepts learned.
GI92 Incident Command System (ICS) for Public Works Officials A one-and-a-half-day field course that introduces public works personnel to ICS and provides opportunities for exercising the concepts learned.
$105 Integrated Emergency Management Course (IEMC): Consequences of Terrorism A five-day exercise-based course that focuses on preparing for, responding to, and recovering from the emergency consequences of a terrorist act. Special attention is placed on the response among agencies when the disaster area is also a crime scene.
Joint Information Center (JIC)/Joint Information System (JIS) Course A 16- to 24-hour course that introduces participants to the JIC/JIS concept and details the functions to be performed in establishing a single location for the dissemination of coordinated emergency information.
G386 Mass Fatalities Incident Course A one-week field course designed to prepare local and State response personnel and other involved personnel to manage incidents involving large numbers of fatalities effectively.
FOR MORE INFORMATION For more information on any of these courses, please contact the National Emergency Training Center at (800) 238-3358, or (301) 447-1000.
EMERGENCY PROCEDURES FOR EMPLOYEES WITH DISABILITIES IN OFFICE OCCUPANCIES (U.S. FIRE
ADMINISTRATION:JUNE 1995)
With funding from the United States Fire Administration, this guide was developed by the National Institute of Standards and Technology with assistance from the National Task Force on Life Safety and People with Disabilities. For additional copies of this publication write to: United States Fire Administration, 16825 South Seton Avenue, Emmitsburg, Maryland 21727.
REVIEW PANEL
The following individuals composed our Review Panel. The author appreciates their willingness to serve through the planning session, resource, draft review. . . . sometimes at a moment's notice and always ready with advice and information for inclusion in this guide. Brian Black, Eastern Paralyzed Veterans Association Marianne Cashatt, Consultant, Disability Awareness/Public Relations Alan Clive, Federal Emergency Management Agency Eunice Fiorita, Rehabilitation Services Administration Victor Galloway, Rehabilitation Services Administration Anne Hirsch, Job Accommodation Network, affiliate of PCEPWD 515
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Marsha Mazz, U.S. Architectural & Transportation Barriers Compliance Board Bill Scott, Abilities Unlimited Certain commercial equipment or products are identified in this guide as representative examples of products which are available for the purposes discussed. Such identification does not imply endorsement by the U.S. Government nor does it imply that the equipment identified is necessarily the best available for the purpose.
INTRODUCTION
People with disabilities are increasingly moving into the mainstream of society, contributing to the diversity which has been this country's strength. It is only right that they be provided with the same level of safety as the rest of society, as referenced in the Americans with Disabilities Act (ADA). Equipment and procedures exist that can provide such safety for any person with a disability that is not so severe that it would preclude the ability to work. The key points regarding finding the best solution for your building are, first, to remember that every person with a disability has unique abilities and limitations, and accommodations should be tailored to their needs. Second, it is crucial that the person be included in the decision on which equipment and procedures will work for them to provide them with the confidence that they will be protected. It is every employer's responsibility to provide a safe place for all employees to work. Employees with disabilities are entitled to THE SAME level of safety as everyone else (no more/no less). The "reasonable accommodation" as mandated in ADA is intended only to provide this same level of safety and utility as is provided to everyone. Further, we cannot predict when any one of us may need assistance, such as in the case of a broken leg or the development of heart disease. The underlying principle in providing safety from fire and smoke in buildings is that of safe egress: the efficient relocation of building occupants to an area of safety usually outside the building. This depends on several steps. First, we must provide for detection of a fire, before it can interfere with the movement of people. Next comes notification of the people that a potential danger exists and that evacuation to a predetermined point of safety should begin. Third is the movement of people through the building spaces to a protected exit-way by which they can leave the building. The techniques for detection, notification, and movement are generally appropriate for anyone in any setting, but there are some exceptions.
Introduction
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For example, special considerations are required with regard to movement in the case of the "limited mobility" of the patients in health care occupancies and the "limitations imposed" on the occupants in correctional occupancies. Both of these occupancies require special considerations with regard to movement, or a higher level of protection (such as "defend in place"), which does not require movement. For other occupancies, the presence of individuals with temporary or permanent disabilities requires some additional planning. This guide is intended to provide information for facilities managers and may be useful for those individuals who might need special assistance as to the notification of an emergency situation and/or in the evacuation of a building. The information includes examples of equipment available as well as suggestions on procedures and comments on some of the advantages and the disadvantages. By starting with the same information, options can be discussed and a decision on the best approach to providing for the individual's needs can be made. This discussion is a crucial step because each person's capabilities and limitations are unique; thus plans must be designed to meet the needs of the individual to be most effective. Detection
The detection of fires is generally accomplished by automatic systems that do not require human intervention. Generally, no special accommodations are needed for people with disabilities. One exception where manual pull stations that are provided in public buildings by which persons can initiate a fire alarm if they discover a fire before it is detected by the automatic system. In recent years, codes have been revised to require that these manual pull stations be mounted at a height to be within the "reach range" of 48" to 54" for a person in a wheelchair. Facility managers should also consider that not all people possess the strength and/or dexterity to operate some of the manual pull station devices (e.g., those with arthritis or quadriplegia). Notification
Notification refers to the process of informing occupants that an emergency exists and that some action is needed. In most cases, this action is simply to evacuate, and the quantity of information to be given is only this fact. Traditionally, notification of an emergency has been accomplished by audible devices, which are effective for all but those with hearing impairments. Recently, visible devices (high-intensity flashing lights) are being used
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along with the audible devices to broaden the range of notification effectiveness. In larger buildings, emergency evacuation may involve relocation to a safe area within the building or sequencing evacuation by floor or area so as not to overload the stairways. In such cases, the amount of information that must be provided to occupants is substantially greater. This is typically done audibly, through emergency paging systems. These are effective for all except those with hearing impairments where textural displays (television monitors or scrolling text signs) are located throughout the building, or portable devices (tactile/vibratory pagers) have been utilized effectively.
Movement
By far, the greatest range of special needs exists in the area of movement of persons to safe areas. People using wheelchairs or with other obvious mobility disabilities come immediately to mind, but there are many who may not appear to have a disability who will also require some special assistance. Permanent conditions such as arthritis or temporary conditions such as a sprained ankle or a broken leg can limit one's ability to evacuate quickly and safely. Heart disease, emphysema, asthma, or pregnancy can reduce stamina to the point of needing assistance when moving down many flights of stairs. One major challenge is the identification of those individuals who may need the special assistance. Consider persons with emphysema, asthma, and other respiratory conditions who may perform well in a drill but then experience problems in an actual emergency situation, as learned in the World Trade Center evacuation as a result of the February 1993 bombing. The people with respiratory conditions who were interviewed described the terror they experienced when faced with the grim reality of extreme exertion required to escape down the many flights of stairs in unfamiliar and smokefilled stair towers. They also explained that prior to that emergency evacuation they had never considered themselves as having a disability that would qualify them as potential candidates for inclusion in the emergency evacuation plans for those requiring special assistance.
How to Proceed
There will always be someone who will need some special assistance in the event of a fire or other emergency requiring evacuation. Thus, identifying these individuals is essential, never losing sight of the fact that some of these people may not recognize their own need for assistance.
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In addition, allowances for visitors present in the building must also be made. Once identified, individuals should be consulted about their specific limitations and how best to provide assistance. Finally, the methods for accommodation and assistive devices should be selected and discussed. This is necessary to assure a safe "emergency" evacuation from the building for the individual with a disability. The remainder of this guide is intended to present the range of possible approaches to the accommodation of special needs along with the advantages and disadvantages. From this, it is expected that the facility management and the affected individuals can make a more informed decision on what approach would work best for the specific conditions present. All concerned should operate with a common understanding of the options so that an optimum solution can be reached.
PLANNING Identifying Special Needs While the Americans with Disabilities Act of 1990 (ADA) does not require formal emergency plans, Titles I and III do require that policies and procedures of public accommodations be modified to include people with disabilities. The facility emergency plan which may already have provisions for individuals with limited mobility must now include all the other classifications of disabilities as covered in the ADA. These include: 9 Individuals with varying degrees of mobility impairments, ranging from slow walkers to wheelchair users. 9 Individuals who are visually impaired and may require special assistance in learning the emergency evacuation routes or assistance in proceeding down exit stairs. 9 Individuals with hearing impairments and who may require modification to the standard audible alarms. 9 Individuals with temporary impairments due to recovery from serious medical conditions such as stroke or traumatic injuries such as a broken leg or a sprained ankle or surgeries such as a knee or hip replacement. 9 Individuals with medical conditions such as respiratory disorders or pregnancy who may tire easily, need special assistance, or more time to evacuate. 9 Individuals with mental impairments who may become confused when challenged with the unusual activity during an emergency, lose their sense of direction, or require having emergency directions that are broken down into simplified steps or basic concepts.
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9 Other populations that need to be considered as being vulnerable, such as visitors or customers with small children who require extra time to evacuate down stairs, or employees who work outside the normal working hours. All of these individuals need to have special provisions or contingencies included in the emergency plan for their protection.
Discussion with the Individual
Keep in mind that someone with a permanent or major impairment generally knows the best way to be assisted. A minute or so spent talking with the individual will give you crucial information. People providing assistance should be trained on how to help without causing injury to themselves or others. This is especially relevant if someone needs to be lifted or carried.
Put It in Writing
Identify and plan for times (of the day and the week) plus locations in the workplace where the basic life safety or emergency contingency plans have not been put in place or, due to some other factor, might not work.
Periodic Review
Innovative educational techniques such as role playing or the use of audiovisual aids might prove more effective than more traditional methods of information dissemination used in the past. Practice using the elements of Sections II and III that you have selected as being appropriate for your workplace. Practice will instill confidence in one's ability to cope in an emergency. It will also do more than anything else to assure that appropriate lifesaving actions will be taken during a real emergency. Practice consists of one of three types of activity--walk through procedures, announced drills- or surprise drills.
Walk through Procedures Practice separate parts of a plan one at a time. In this way you can concentrate your efforts on the particular parts and particular individuals requiring more extensive practice. Members of an emergency response organization (e.g., fire wardens) would be prime candidates for this practice.
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This is also a way of introducing newly hired employees in the workplace to important parts of the plan. Announced Drills
As with the walk through procedures, this is intended more to train than to evaluate. Such drills will help identify crucial coordination activities and communication links.
Surprise Drills Use these drills infrequently. Depending on the situation, this might be done once or twice each year. Surprise drills should involve some realistic elements (e.g., blocked exits). Panic has rarely been reported, either in drills or in actual emergencies. Alarms: Horn and Strobe for the Hearing Impaired are "ADA" and "UL Standard 1971" compliant. (Photo included in pamphlet) Intele-Modem 1 converts a personal computer into a Telecommunications Device for the Deaf (TDD). It also automatically converts PC (ASCII) to TDD (Baudot); directly connects to phone lines; automatically detects both Baudot and ASCII calls; and is FCC approved. (Photo included in pamphlet) Clarity Phone 2 with built-in equalizer automatically tunes, tones, and balances sounds to improve clarity, making words clearer, not just louder. The phone is designed to help those with highfrequency hearing loss, a problem affecting 95 % of the people who are hardof-hearing. The Clarity adjustment controls set the high frequency that is right for each individual. (Photo included in pamphlet) Shake-Up System. 3 9-V battery smoke detector, signal unit, and vibrator alert device. Detector and receiver attach to wall and/or ceiling with a vibrator device placed on the desk. A smoke detector sends a transmitted signal to the receiver and activates the vibrator. (Photo included in pamphlet) Ultratec Superprint ES. 4 This portable, 20-character display TDD provides printed records of conversations and optional auto-answer. lIntele-Modem Ultractec 450 ScienceDrive, Madison, WI 53711, voice/TDD 608-238-5400. 2Clarity Phone: three models for business use: the basic model, 2-line phone, and 2-line feature speakerphone. WalkerEquipment, a Plantronics Company,P.O. Box 829, Ringgold, GA 30736. 3Shake-Up 9-V smoke detector, receiver & vibrator from Weitbrecht Communications Devices for the Deaf, 2656 29th Street, Suite 205, Santa Monica, CA 90405, voice/TDD 1-800233-9130. 4Superprint ES Telecommunication Device for the Deaf, from Weitbrecht Communications Devices for the Deaf. page 10 Office Case-Alerting System (adapted from case for hotel guest room) from Weitbrecht Communications Devices for the Deaf.
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SPECIAL EQUIPMENT/DEVICES Notification Appliances The disability that most affects the process of notification of an emergency condition is hearing impairment. Hearing impairments can range from mild hearing loss to an extreme of profound deafness, the level at which individuals receive no benefit from aural input. Many persons who are hearing impaired can use their residual hearing effectively with assistance from hearing aids or other sound amplification devices, often augmented by lip reading. However, hearing aids also amplify background sounds, and the sound of the emergency alarms may interfere with or even drown out voice announcements of an emergency, voice communication system. Systems used for emergency notification must comply with UL1971, the Underwriters Laboratories Standard for Emergency Signaling Devices for the Hearing Impaired. The signaling devices covered in the UL1971 standard are designed to alert persons with hearing impairments through the use of light, vibrations, and air movement. Many hotels post a sign at the desk to make deaf or hearing impaired guests aware that rooms with strobe lights are available, s In some government buildings, employees who are deaf or hard of hearing have been provided with tactile/vibratory pagers to notify them when a fire alarm has been activated. Building managers who wish to provide wheelchair assist equipment for use by visitors can receive assistance in selecting appropriate devices from one of the groups in the Resources section Tactile Signage-Raised Text and Braille Braille signs have been installed at some locations in buildings to assist individuals with visual impairments. You may have noticed these raised patterns of dots on elevator control panels. The problem with the use of such labels to mark egress doors is that the person must be at the door in order to feel the label. Thus, they provide no directional guidance on how to find the door in the first place.
Audible Directional Signage Audible remote signage is a way of informing individuals who are visually impaired of what they need to know about their environment. Audible directional instructions are transmitted by low-power radiowaves or infrared beams. The signal/instructions are then picked up by a small receiver carried by the individual (e.g., "the exit is 25 steps south of the front desk," 5Multi-Alert SS12/24ADA Series signaling strobes from System Sensor, 3825 Ohio Ave, St. Charles, IL 60174, voice 1-800-SENSOR2.
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or simply "stairway, .... restroom," or "elevator") act as signals when one approaches a stairway, restroom, or elevator.
Audible PedestrianSystems Another example of audible signs is the common pedestrian traffic signal. These signs "cuckoo" and "chirp" to alert pedestrians to changing traffic signals. However, these devices have some inherent limitations for those with learning disabilities. They are not currently in use for emergency egress systems within buildings, although there are exit signs available that flash and sound internal horns when activated by the building fire alarm system.
Movement Aids/Equipment Another area where disabilities impact on emergency egress is with mobility limitations. This is most frequently associated with wheelchair users. Here we should be sensitive to the fact that wheelchairs represent mobility and are frequently fitted to accommodate the specific physical needs of the user. Thus, whether evacuated with or without their wheelchairs, they will need their own chairs when they reach safety for both physical and psychological reasons.
Permanently Installed Systems There are several types of controlled descent devices that can be permanently installed within stairways to accommodate wheelchair users. In some, the individual transfers from the wheelchair to the portable, controlled descent chair. Some models permit a relatively small person to transport a larger person while with other devices, the individuals ideally should be about the same weight. These chairs are designed to travel down stairs on special tracks with friction braking systems, rollers, or other devices to control the speed of descent. Another type of controlled descent device is designed so the wheelchair user rolls onto the transport device and the wheelchair is secured to the device. This has the advantage that the wheelchair user does not have to be separated from the c h a i r ~ a situation that will be more comfortable and reassuring. The wheelchair lift is a motor-driven device designed to be installed in a stairway. Vertical wheelchair lifts are differentiated from elevators in that they are limited in the height of their vertical lift, are not enclosed, and do not go through a floor level. These lifts were originally intended for private resi-
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dences, but are now being used in nursing homes, churches, and public buildings. Always consult the wheelchair user as to the selection of an emergency evacuation chair. The advantages or disadvantages of these devices are dependent on the capabilities, acceptance, and understanding of the end user(s). The effectiveness or failure of evacuation chairs as a rule can be attributed to the fact that the wheelchair user was not consulted as to the equipment selection. Chairs that do not accommodate the physical needs of the user create problems which may lead to a refusal to use them in an emergency.
Elevators
Most people are familiar with the fact that elevators are not to be used for emergency egress and are so marked in most buildings. Elevator codes require that when smoke detectors in elevator lobbies activate, the elevator is recalled to the ground floor (as long as the ground floor smoke detector is not the one that alarmed) and is taken out of service. The fire department can operate the elevator with a special key and may use it to move their people and equipment, or for evacuation of occupants. This means that without the fire department, persons with disabilities are relegated to the stairs or must await rescue. In recent years (especially since the 1993 World Trade Center bombing), there has been a growing interest in providing elevators that can be used for emergency evacuation. In a study conducted for the General Services Administration (GSA), the National Institute of Standards and Technology (NIST) found that the use of both elevators and stairs can improve evacuation times by as much as 50% over stairs alone. However, elevators that are used for emergency evacuation need to be specially designed to assure their reliability and safety during the fire. NIST research has shown that, with enclosed lobbies at each floor which are pressurized through the shaft so that both remain smoke free, dual power systems for reliability, and water resistant components to prevent failure due to flooding of the shaft by firefighting water, it is feasible to design elevators that are sufficiently safe to allow their continued use for emergency evacuation (Feasibility of Fire Evacuation by Elevators at FAA Control Towers, NISTIR 5445, 1994.) Miscellaneous Devices
A number of unique escape devices have been developed over the years. These include controlled descent devices using cables and chutes of various types.
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The cable devices usually use a strap or chair secured to the cable by a device that is squeezed to allow descent. The more you squeeze, the faster you go. Letting go stops your descent. Most people are reluctant to evacuate down the outside of a building. The chutes may be solid or flexible fabric tubes that generally rely on friction to control speed. They have the advantage that they do not let you see out, so they are more acceptable than cable devices. However, their acceptance in practice in this country has been limited. There is little information available as to the performance of these devices in emergency situations. These unique specialized escape devices generally have serious shortcomings. (Egress Procedures & Technologies for People with Disabilities. Final Report of a State of the Art Review with Recommendations for Action, ATBCB 1988.)
Sprinklered Buildings In a study of areas of refuge conducted by NIST for the GSA, it was concluded that the operation of a properly designed and maintained sprinkler system eliminates the life threat to building occupants regardless of their individual abilities and can provide superior protection for people with disabilities. Sprinkler systems will, in most circumstances, provide the protection to permit evacuation that is limited to the area under immediate threat from the fire. In sprinklered buildings it would probably be appropriate to put more emphasis on understanding of the protection afforded or provided with the sprinklers and about limited evacuation through horizontal exits versus total evacuation from the building. Of course, while about 95% reliable, there is a small possibility that the sprinkler system will fail to extinguish the fire. For these possibilities, there need to be contingency plans for providing evacuation assistance for all occupants, including those needing special assistance.
Areas of Refuge/Rescue Assistance Even in buildings equipped with sprinkler systems it is recommended that areas of refuge be provided. There is the small possibility that the sprinkler system will fail to extinguish the fire and there is the problem of smoke propagation. It is quite possible for a person with a disability to be stranded and overcome with smoke before the arrival of the rescue personnel, given the difficulty in locating someone in a smoke-filled building.
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For these possibilities, there need to be contingency plans for providing evacuation assistance for all occupants, as well as those needing special assistance. (Photo Included in Pamphlet) Evacuation Assistance Device. A threeperson, assisted-wheelchair-carry device, called "Evac-u-Straps," was developed by a wheelchair user in Atlanta. It consists of wide padded leather wrist bands with Velcro closures equipped with large metal grasping hooks. The hooks are designed to be attached to both sides of the front of the wheelchair. Persons on either side of the wheelchair grasp the straps and are assisted by a third person behind, keeping the wheelchair slightly tipped backwards. The wheelchair user assists by handbraking the wheels. (Photo Included in Pamphlet) All-in-One Carrying Case. Includes: TDD; telephone signaler; telephone amplifier; door knock signaler; telecaption decoder; notification vibrator; and visual/audio smoke detector. This device was used in the study conducted in 1988 by Underwriters Laboratories to evaluate alternative signaling systems that would alert persons with hearing impairments to fires and other emergency conditions. The study established guidelines for the use and installation of the devices covered in "Standard 1971." Talking Signs 6 provide people who are blind with the directional and usage clues that traditional visual signs provide for sighted persons. By sending information from installed infrared transmitters these signs speak for themselves. Hand held sensors pick up information from the transmitters and give verbal directions to the blind individual (see illustration in pamphlet). These signs are installed in the San Francisco Municipal Railway and Bay Area Rapid Transit District. (Photo included in pamphlet) Wheelchair lifts for use indoors, and for use outdoors: Garaventa Evacu-Trac. 7 Developed in Switzerland. Convenient, top of stair storage. (1) Brake system engages when lever is released; (2) Adjustable safety belts; (3) Rubber tracks grip stairs; (4) Eight auxiliary wheels for smoother ride on flat surfaces, such as stair landings. Designed so a passenger's weight propels it down stairs. Governor limits the maximum descent speed. (Photo included in pamphlet) Evac +Chair '300-H. TM Folds for on-thejob storage. Can be readily available for emergencies. Unfolds/opens quickly 6Talking Signs Inc. 812 North Blvd., Baton Rouge, LA 70802. voice 504-344-2812. Talking Signswere developed by the Smith-KettlewellEye ResearchInstitute, LoveElectronics,Inc. and Talking Signs, Inc. Installation in New York City, "Light House for the Blind," example of workingsystemin the officebuildingsetting. 7EVACU-TRACGaraventa (Canada) Ltd., 7505-134A Street, Surrey, BC, Canada V3W 7B3, voice 1-800-663-6556. 8EVAC+CHAIR Corporation, 17 East 67 Street, New York,NY 10021, voice212-734-6222.
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and Weighs only 15 pounds but has a 300-pound capacity. Cantilevered design places seat inches above stairs. Other features: sliding head rest, quick-release safety belt buckle, and instructions permanently stamped on back. Changes the obstacle of firestairs into usable escape route for all, e.g., pregnant women, the frail or employees with limited stamina, or someone with a temporary disability. (Photo included in pamphlet) Scalamobil. 9 Stairclimbing and power unit, invented in Germany. Three-step process for use. First, attach handles to the Scalamobil. Second, attach Scalamobil to wheelchair. Third, begin operation. 12V/12AH power base. Operator's safety features include automatic mechanical security brakes on every wheel, variable speed control from 6 to 12 steps per minute, and ability to park the wheelchair safely on any step during ascent or descent. Designed to negotiate most all stairs, from the extremely narrow stair to curving circular stairs.
PROVIDING ASSISTANCE Identifying Those with Special Needs Before special accommodations can be made, persons needing them must be identified. One strategy is to maintain a listing of individuals needing assistance and keeping it current as part of the facility's emergency plan. At the beginning of employment during the orientation process is the time to begin to stress the importance of identifying if an individual will need special assistance. Of course, since conditions change and persons can become temporarily disabled, this system needs to be flexible. Such lists must be accessible by the emergency personnel to assist in the emergency evacuation. But, it should be understood that there are many individuals who are protective of their right to independence and privacy and who may be reluctant to have their names put on such a list. Some disability categories are easily recognizable and in these cases the individual can be approached as to what can be done to assist them in emergency evacuation. It is important to treat the individual as one who happens to have a particular disability, and not make the mistake of "lumping" together all persons with disabilities in the development of emergency procedures. 9SCALAMOBIL,alber TMI, Technomarketing, Inc, 307 Bacon Road, Rougemont, NC 27572, voice 919-477-1387. For further information about accessibilityequipment and manufacturers contact: Accessibility Equipment and Manufacturers' Association (AEMA), P.O. Box 51784, New Berlin,WI 53151, voice/fax 414-789-9900.
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There are some emergency plans (and codes on which they are based) in which all persons with disabilities are "directed" to go to the area of rescue assistance to await members of the emergency team to escort them to safety. As a general rule there is no reason that individuals who are blind or deaf cannot use the stairs to make an independent escape as long as they can effectively be notified of the need to evacuate and can find the stairway. One of the lessons learned from interviews of people with disabilities following the February 1993 World Trade Center bombing was that, prior to the incident, some of the people with disabilities said that, in the interest of privacy or because they felt that they did not need special assistance, they had opted not to identify themselves to be among those listed as disabled in the emergency management plan. They realized after the incident that they did need assistance and that they had not realized how vulnerable they were outside of normal working hours when there were few co-workers around to provide such assistance.
"Buddy" Systems and Fire Wardens Buddy systems are widely accepted and used, but have some inherent faults or flaws. When setting up such a system in the workplace, consider the following potential problem areas and potential solutions. To be effective, the person and the buddy must be able to make contact with each other quickly when the need arises. Situations that can prevent this include: 9 The buddy is in the building, but is absent from the customary work area. 9 The buddy cannot locate the person with a disability because the person is absent from the customary work area. 9 The employee with a disability is working late, etc., when the buddy is unavailable. 9 The buddy has left the company and a new one has yet to be identified. 9 The buddy has not been trained in what to do or how to assist. 9 The buddy is inappropriate (e.g., not strong enough). 9 The buddy isn't acceptable to the employee with a disability. 9 The buddy forgets or is frightened and abandons the employee with a disability. Now consider the following potential solutions: 9 Assign at least two buddies who are work associates.
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9 Alert the floor warden about the work location of the person with a disability. If he/she cannot locate the assigned person, the buddy should alert the floor warden. 9 Employees could be given pagers. 9 Employees with disabilities should identify themselves to the officials in the emergency control center when in the building after hours. The officials coordinate immediate emergency response, call the employee, and alert responding fire service. 9 Employees with disabilities can be given the responsibility for selecting their own buddies; bimonthly emergency plan reviews should include checking the status of buddies. 9 The buddy is trained by the employee with a disability as soon as they are recruited. 9 The employee with a disability is encouraged to select only buddies who are capable. 9 Practice sessions are required to ensure that buddies can handle their assigned tasks. 9 Employees with disabilities are encouraged to select only friends/ colleagues as buddies.
Spontaneous Assistance Techniques Vision Impairments When assisting persons with vision impairments there are some basic rules to follow in order to be effective. 9 Announce your presence; speak out when entering the work area. 9 Speak naturally and directly to the individual and N O T through a third party. Do not shout. 9 Don't be afraid to use words like "see, .... look," or "blind." 9 Offer assistance but let the person explain what help is needed. Describe the action to be taken in advance. Let the individual grasp your arm or shoulder lightly for guidance. He/she may choose to walk slightly behind you to gauge your body reactions to obstacles; be sure to mention stairs, doorways, narrow passages, ramps, etc. 9 When guiding to a seat, place the person's hand on the back of the chair. If leading several individuals with visual impairments at the same time, ask them to hold each other's hands. 9 You should ensure that, after exiting the building, individuals with impaired vision are not "abandoned" but are led to a place of safety, where a colleague(s) should remain with them until the emergency is over. Another of the lessons learned from the World
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Appendix L
Trade Center incident involved the complaints of blind tenants who, after being escorted down and out of the building, were unceremoniously left in the unfamiliar environs out-of-doors in the midst of a winter ice storm, where they had to negotiate icecovered sidewalks and falling glass from overhead.
Hearing Impairments When assisting persons with hearing impairments there are also some things to keep in mind. These include: 9 Flick the lights when entering the work area to get the person's attention. 9 Establish eye contact with the individual, even if an interpreter is present. ~ Face the light, do not cover or turn your face away, and never chew gum. 9 Use facial expressions and hand gestures as visual cues. Check to see if you have been understood and repeat if necessary. 9 Offer pencil and paper. Write slowly and let the individual read as you write. Written communication may be especially important if you are unable to understand the individual's speech. 9 Do not allow others to interrupt or joke with you while conveying the emergency information. 9 Be patient, the individual may have difficulty comprehending the urgency of your message. 9 Provide the individual with a flashlight for signaling their location in the event that they are separated from the rescuing team or buddy and to facilitate lip-reading in the dark.
Learning Disabilities Persons with learning disabilities may have difficulty in recognizing or being motivated to act in an emergency by untrained rescuers. They may also have difficulty in responding to instructions which involve more than a small number of simple actions. Some suggestions for assisting such persons include: 9 Their visual perception of written instructions or signs may be confused. 9 Their sense of direction may be limited, requiring someone to accompany them. 9 Directions or information may need to be broken down into simple steps.
Providing Assistance
53 1
patient. 9 Simple signals and/or symbols should be used (e.g., the graphics used throughout this section).
9 Be
A person's ability to understand speech is often more developed than his/her own vocabulary. Do not talk about a person to others in front of him/ her. The individual should be treated as an adult who happens to have a cognitive or learning disability. Do not talk down to them or treat them as children.
Mobility Impairments Someone using a crutch or a cane might be able to negotiate stairs independently. One hand is used to grasp the handrail the other hand is used for the crutch or cane. Here, it is best not to interfere with this person's movement. You might be of assistance by offering to carry the extra crutch. Also, if the stairs are crowded, you can act as a buffer and "run interference." Wheelchair users are trained in special techniques to transfer from one chair to another. Depending on their upper body strength, they may be able to do much of the work themselves. If you assist a wheelchair user, avoid putting pressure on the person's extremities and chest. Such pressure might cause spasms or pain and even restrict breathing. Carrying someone slung over your shoulders (something like the socalled fireman's carry) is like sitting on their chest and poses danger for several individuals who fall within categories of neurologic and orthopedic disabilities.
Carry Techniques One-Person Carry Technique The Cradle Lift is the preferred method when the person to be carried has little or no arm strength. It is safer if the person being carried weighs less than the carrier's weight. Two-Person Carry Technique The Swing or Chair Carry: Carriers stand on opposite sides of the individual. Take the arm on your side and wrap it around your shoulder. Grasp your carry partner's forearm behind the person in the small of the back. Reach under the person's knees to grasp the wrist of your carry partner's other hand. Both carry partners should then lean in, close to the person, and lift on the count of three. Continue pressing into the person being carried for additional support in the carry. The advantage of this carry is that the partners can support (with practice and coordination) a person whose weight is the same as or even greater than their own weight. The disadvantage is increased awkwardness
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Appendix L
in vertical travel (stair descent) due to the increased complexity of the twoperson carry. Three persons abreast may exceed the effective width of the stairway.
Other Impairments Pregnancy is not usually considered a disability, but it can result in reduced stamina or impaired mobility, especially in negotiating stairs. In these cases, offer to walk with the woman and be of support both emotionally and physically. Remain with her until you have reached safety and she has a safe, warm place to sit. With respiratory disorders, such as asthma or emphysema, the onset of symptoms can be triggered by stress, exertion, or exposure to small amounts of dust or smoke. Remind the individual to bring inhalation medication before leaving the work place. Persons with cardiac conditions should be reminded to take their medications. Offer them assistance in walking; they may have reduced stamina and require frequent rest periods.
Fire Department Coordination It is vital to have a clear understanding through effective planning and practice with the local fire and rescue services regarding evacuation procedures for persons with disabilities. Opinions can vary among local fire departments, for example: 9 Whether individuals with disabilities should remain in their workplaces or assemble in an area of refuge to await the arrival of the fire fighters, or whether fellow workers should help with their immediate evacuation. 9 What evacuation techniques are to be used, in particular the carry techniques for getting nonambulatory individuals down the stairs. 9 Whether dog guides should be permitted to evacuate down the stairway with their owners. There are examples of the fire department instructing that the dog be separated from its owner. Whatever the plan, what is most critical is that it be coordinated and practiced with the local fire and rescue service. New York City leads the nation in a number of techniques for addressing fire safety in tall buildings, including the designation of fire wardens. Under Local Law 5, a fire warden is assigned for each floor of a building, and is responsible for the safe evacuation of persons on that floor. The fire warden knows who is and is not at work that day, what visitors are present, and who might need assistance in
Providing Assistance
533
case of emergency. New York fire wardens take required training at regular intervals. The law also requires a building fire safety manager whose full-time job is to keep fire emergency plans up to date and who coordinates the activities of the fire wardens with the fire service during an emergency. Suggestions When Assisting Owners of Dog Guides
Do not pet or offer the dog food without the permission of the owner. When the dog is wearing its harness, he is on duty; if you want the dog not to guide its owner, have the person remove the dog's harness. Plan for the dog to be evacuated with the owner. In the event you are asked to take the dog while assisting the individual, it is recommended that you (the helper) hold the leash and not the dog's harness. To Assist in Moving a Wheelchair Downstairs
When descending stairs, stand behind the chair grasping the pushing grips. Tilt the chair backwards until a balance is achieved. Descend frontward. Stand one step above the chair, keeping your center of gravity low and let the back wheels gradually lower to the next step. Be careful to keep the chair tilted back. If possible, have another person assist by holding the frame of the wheelchair and pushing in from the front. But do not lift the chair as this places more weight on the individual behind. After Working Hours
Most office fire fatalities occur outside of normal working hours. Here, fires can grow unnoticed and persons working alone can be cut off from their normal egress route. In many buildings, only a few people working late and the housekeeping staff are present at night. An employee with a mobility impairment who has relied on the elevator for access may need help to get down the stairs, but trained "buddies" are unavailable. To compensate, the individual should alert building security upon entering the building. Someone will then be ready to search for and assist the individual to safety, if needed. Alternatively, the person could be instructed to telephone the fire department as to their location when an emergency occurs. Managers should ensure that shift workers and others who work on the premises outside normal hours, such as cleaners, are included. If there are employees whose knowledge of English may be limited, training should be given in a manner which they can understand. Non-English speakers and
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staff who have poor reading skills should be considered when written instructions are being prepared.
GLOSSARY
ADA
Americans with Disabilities Act.
ADAAG
Americans with Disabilities Act Accessibility Guidelines
Aphasia Absence or impairment of the ability to communicate through speech, writing, or signs. Area of Refuge/Area of Rescue Assistance An area that has direct access to an exit, where people who are unable to use stairs may remain temporarily in safety to await further instructions or assistance during emergency evacuation.
Asthma A complex disease which causes obstruction of the respiratory system. Back Pain Can be caused by congenital conditions, disease, or injury, but for the millions of people affected by this condition the key element is always the same: pain. Blind~lindness Range of vision impairments from the inability to distinguish light and dark to a loss of part of the visual field or the inability to see detail. (see definition: Visually Impaired)
BraiUer "Perkins Brailler," an all-purpose Braille writer. Buddy System The system of assigning the appropriate individual(s) to assist in the evacuation of persons with disabilities.
Cane As used by the blind individual, the cane is a natural extension of the arm and hand and is used as an information gathering device (to locate familiar landmarks) for the purpose of establishing a clear path of travel. The conventional two-point touch system: The cane is moved from side to side in an arcing motion. The width of the arc is usually two inches to either side of the shoulders. As the cane touches to the left, the right foot should be forward. The cane tip touches in the opposite direction of the leading foot. Chronic Obstructive Pulmonary Disease (COPD)
Includes the diseases of
chronic bronchitis and emphysema.
Cerebrovascular Accident (CVA) Localized brain damage due to a ruptured blood vessel in the brain; commonly called a stroke.
Cerebral Palsy Non-progressive disorder of the brain; results from damage to the nervous system at birth or in the first hours or days of life; not a disease.
535
Glossary
Closed Circuit TV Magnifier (CCTV) Consists of television camera which takes the picture of the printed page and a television monitor which displays image in enlarged form. Critical Language Terminology that is unacceptable and/or insulting to persons with disabilities. Deaf~eafness
Range of auditory impairments, from a total lack of sensitivity to sound to reduced sensitivity to certain sound frequencies. Dog Guide Dog that has been specially trained to assist people who are blind, physically disabled, or hearing-impaired.
Epilepsy Condition characterized by occasional seizures. A small fraction of those with epilepsy are photosensitive. Seizures can be triggered by flashing lights. Exercise Induced Bronchospasm (EIB)
A form of asthma.
Fingerspelling When no sign language exists for a thought or concept, the word can be spelled out using the American Manual Alphabet.
"Guide Dog"
Proprietary name for a dog guide.
Hearing Impaired Scale of hearing impairment ranges from mild hearing loss to profound deafness, the point at which the individual receives no benefit from aural input. Many hard-of-hearing persons are able to use residual hearing effectively with the assistance of hearing aids (HA) or other sound-amplification devices, often augmented by lip reading. Hearing aids amplify background noises as well as voices, so noise caused by emergency conditions (alarm bells, people shouting, sirens, etc.) may rise to an uncomfortable level for the person with the hearing impairment. Head Pointer Stick or rod which is attached to a person's head with a head band so that by moving the head, an individual can perform tasks that would ordinarily be performed by hand or finger movement. Hemiplegia A disability resulting from a CVA which involves some degree of muscle weakness and motor skill loss on one side of the body.
Interpreter Professional who assists a deaf person in communicating with hearing people who cannot sign.
Learning Disability An individual who may have difficulty recognizing or being motivated to act in an emergency. These individuals may also have difficulty in following anything other than a few simple instructions. Little People General term for persons of short stature who are less than 4'10" or whose height is significantly below average.
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Appendix L
Low Level Signage/Floor Proximity Exit Signs Are usually placed between 6" and 8" above the floor. A supplement to the required exit sign. The required exit signs are usually located over the exits or near the ceiling, the first place to become obscured by smoke. Low Vision Can be moderate to serve vision impairment which includes difficulty in reading without magnification and seeing fine detail. Some persons with low vision may be considered legally blind. Means of Egress An accessible means of egress is one that complies with these following guidelines: a continuous and unobstructed way of exit travel from any point in a building or facility to a public way. A means of egress comprises vertical and horizontal travel and may include intervening room spaces, doorways, hallways, corridors, passageways, balconies, ramps, stairs, enclosures, lobbies, horizontal exits, courts, and yards. Areas of refuge or evacuation elevators may be included as part of accessible means of egress. (Contact the authority having jurisdiction or refer to the building codes for the local application or definition.) Mobility Impaired Employees with mobility impairments can vary in the degree of assistance that they require. The degree of impairment can range from walking with a slow gait (thus requiring more time to exit), to walking with a mobility aid such as a cane, crutches, and/or braces, to the wheelchair user. Monitors/Wardens Terms used to identify the different assignments made in the Occupant Emergency Plan. For example, the duties of the Monitor could include assisting with the coordination of the evacuation of their floor or unit, identifying people with disabilities who require special assistance and coordinating assignment of "buddies" or assistants to stay with them (e.g., see excerpt from NYC Fire Drill & Evacuation Rules for Offices). Mouth Wand Rod with a tooth grip that is held in the mouth and used to perform tasks that would normally be performed by hand. Normal Critical language (see list below). Nystagmus Uncontrolled movement of the eye; also noticeable by (characteristic) head tilt which helps the person to better focus on an object, and thereby to see better. Optical Character Reader Device that can be scanned over a printed page, reading the text aloud through a voice synthesis system. These may also have provision for reading directly from a computer disk containing a word processor file.
Opticon Device to enable a blind person to "read," consisting of a camera that converts print into an image of letters which are then produced via vibrations onto the finger.
Glossary
537
Paraplegia Impairment or loss of motor and/or sensory function in the thoracic, lumbar, or sacral segments of the spinal cord, affecting trunk and legs. Postpolio Syndrome This affects individuals who have recovered from polio. The symptoms include an increase in muscle weakness and an increase in respiratory weakness. Usually necessitates use of a wheelchair. Quadriplegia
(see tetraplegia).
"Seeing Eye" Dog Proprietary name for dog guide. Seizure Involuntary muscular contraction, a brief impairment or loss of consciousness, etc., resulting from a neurological condition, such as epilepsy. Service Animal Trained dog or other animal that provides assistance to a person who is blind, deaf, or mobility impaired. The animal can be identified by the presence of a harness or backpack. Sign Language Means of communication used by persons who are deaf. Speech Disorder
Limited or difficult speech patterns or without speech.
Tactile Signage Signs or labels with Braille; raised letters or textured patterns that can be read tactilely by persons with visual impairments. Tetraplegia Impairment or loss of motor and/or sensory function in the cervical segments of the spinal cord, affecting arms, trunk, and legs. Text Telephone Equipment that includes TTYs and employs interactive graphic communications through transmission of coded signals across the standard telephone network. Victim Critical language (see list below). Visually Impaired A person with a vision impairment may be totally or legally blind. Legally blind implies that a person may be able to differentiate between light and dark or see very large objects, but may not be able to see anything clearly enough to depend on their vision in an emergency situation. This can also include persons with low vision who can see well enough to walk but cannot read without magnification. Wardens Persons assigned as coordinators of emergency actions by occupants of a single floor or part of a floor of a building.
Critical Language Persons with disabilities are sensitive to the use of certain terms which are considered to be demeaning. When discussing evacuation plans with employees, the following terms should be avoided.
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Appendix L
9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9
Able-bodied Afflicted Amputee Cerebral Palsied Confined to a wheelchair Courageous Crippled Deaf and Dumb Deaf/mute Disease Dwarf Gimp Handicapped Normal Patient Physically challenged
9
POOF
9 9 9 9 9 9
Retard, retardate or retarded Spastic Suffering Unfortunate Victim Wheelchair bound
RESOURCES ATBCB U.S. Architectural & Transportation Barriers Compliance Board Lawrence W. Roffe, Executive Director, 1331 F Street, N W Washington, DC 20004-1111. Voice: (800) USA-ABLE/872-2253; TTY: (800) 993-2822.
Technical Assistance on Accessibility Issues & the A D A P C E P W D President's Committee on Employment of People with Disabilities Maggie Roffe, Program Manager, 1331 F Street, N W Washington, DC 20004. Voice: (202) 376-6200; TTY: (202) 376-6205.
Resources
539
JAN (Job Accommodation Network)*
Anne E. Hirsh, West Virginia University, EO. Box 6080, 918 Chestnut Ridge Road, Suite 1, Morgantown, West Virginia 26506-6080. Voice/ TTY: (800) 526-7234. *An affiliate of PCEPWD.
NFPA (National Fire Protection Association), Learn Not to Burn Foundation
Sharon Gamache, Executive Director, P.O. Box 9101, Batterymarch Park Quincy, Massachusetts 02269-9101. Voice: (617) 770-3000; TTY: (617) 984-7880.
NEMA (National Electrical Manufacturers Association)
Malcolm E. O'Hagan, President, 2101 L Street, NW, Suite 300 Washington, DC 20037. Voice: (202) 457-8400.
AEMA (Accessibility Equipment Manufacturers Association)
Terry Nevins-Buchho|tz, Administrative Assistant, P.O. Box 51784, 2445 South Calhoun Road, New Berlin, Wisconsin 53151. Voice: (414) 7899890.
EPVA (Eastern Paralyzed Veterans Association), Buffalo Regional Office
Brian Black, Assistant Director of Building Code Standards, Buffalo Regional Office, 111 West Huron Street, Buffalo, New York 14202. Voice: (716) 856-6582.
NAD (National Association of the Deaf)
Nancy J. Bloch, Executive Director, 814 Thayer Avenue, Silver Spring, Maryland 20910. Voice: (301) 587-1788; TFY: (301) 587-1789.
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Appendix L
SHHH (Self Help for Hard of Hearing People, Inc.) Donna L. Sorkin, Executive Director, 7910 Woodmont Avenue, Suite 1200, Bethesda, Maryland 20814. Voice: (301) 657-2248; TTY: (301) 657-2249. TDI (Telecommunications for the Deaf, Inc.) Alfred Sonnenstrahl, Executive Director, 8719 Colesville Road, Suite 300, Silver Spring, Maryland 20910. Voice: (301) 589-3786; TTY: (301) 589-3006. NFB (National Federation of the Blind) Patricia Maurer, Coordinator, Community Relations, 1800 Johnson Street, Baltimore, Maryland 21230-4998. Voice: (410)659-9314. ACB (American Council of the Blind) Oral Miller, National Representative, 1155 15th Street, NW, Suite 720 Washington, DC 20005. Voice: (202) 467-5081 or (800) 424-8666. page 10 LABDATA page 5, issue Vol. 20, No. 1, 1990 a quarterly technical and information publication by Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062. page 10 LABDATA, Vol. 20, No. 1, 1990, pages 12 & 14. A quarterly technical and information publication by Underwriters Laboratories Inc. page 13 in pamphlet TECH SHEET, the diagrams are taken from one of a series of publications on the design requirements of the ADA Accessibility Guidelines (AADAG), written and compiled by the Barrier Free Environment, Inc., design for people of all ages and all abilities, P.O. Box 30634, Raleigh, NC 27622.
HOW TO PREPARE FOR WORKPLACE EMERGENCIES (U.S. DEPARTMENT OF LABOR, OCCUPATIONAL SAFETY AND H EAkTH
ADMINISTRATION, 1995, REVISED)
INTRODUCTION
The importance of an effective workplace safety and health program cannot be overemphasized. There are many benefits from such a program including increased productivity, improved employee morale, reduced absenteeism and illness, and reduced workers' compensation rates; however, incidents still occur in spite of efforts to prevent them. Therefore, proper planning for emergencies is necessary to minimize employee injury and property damage.
PURPOSE
This publication details the basic steps to handle emergencies in the workplace. These emergencies include accidental releases of toxic gases, chemical spills, fires, explosions, and bodily harm and trauma caused by workplace violence. This publication is intended to assist small businesses that do not have safety and health professionals. It is not intended as an all541
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Appendix M
inclusive safety program but rather to provide guidelines for planning for emergencies. It is hoped that businesses without safety and health plans will utilize one of the consultation sources listed below to help develop guidelines for their plants and to obtain training for their personnel. Many companies already have programs in effect. For these companies, this document can assist in updating and revising existing programs. PLANNING
The effectiveness of response during emergencies depends on the amount of planning and training performed. Management must show its support for plant safety programs and the importance of emergency planning. If management is not interested in employee protection and in minimizing property loss, little can be done to promote a safe workplace. It is therefore management's responsibility to see that a program is instituted and that it is frequently reviewed and updated. The input and support of all employees must be obtained to ensure an effective program. The emergency response plan should be developed locally and should be comprehensive enough to deal with all types of emergencies specific to that site. When emergency action plans are required by a particular OSHA standard, the plan must be in writing; except for firms with 10 or fewer employees, the plan may be communicated orally to employees. The plan must include, as a minimum, the following elements: (1) Emergency escape procedures and emergency escape route assignments, (2) Procedures to be followed by employees who remain to perform (or shut down) critical plant operations before the plant is evacuated. (3) Procedures to account for all employees after emergency evacuation has been completed, (4) Rescue and medical duties for those employees who are to perform them, (5) The preferred means for reporting fires and other emergencies, and (6) Names or regular job titles of persons or departments to be contacted for further information or explanation of duties under the plan. The emergency action plan should address all potential emergencies that can be expected in the workplace. Therefore, it will be necessary to perform a hazard audit to determine toxic materials in the workplace, hazards, and potentially dangerous conditions. For information on chemicals, the manufacturer or supplier can be contacted to obtain Material Safety Data Sheets. These forms describe the hazards that a chemical may present, list
Communications
543
precautions to take when handling, storing, or using the substance, and outline emergency and first-aid procedures. The employer must list in detail the procedures to be taken by those employees who must remain behind to care for essential plant operations until their evacuation becomes absolutely necessary. This may include monitoring plant power supplies, water supplies, and other essential services that cannot be shut down for every emergency alarm, and use of fire extinguisher. For emergency evacuation, the use of floor plans or workplace maps that clearly show the emergency escape routes and safe or refuge areas should be included in the plan. All employees must be told what actions they are to take in emergency situations that may occur in the workplace, such as a designated meeting location after evacuation. This plan must be reviewed with employees initially when the plan is developed, whenever the employees' responsibilities under the plan change, and whenever the plan is changed. A copy should be kept where employees can refer to it at convenient times. In fact, to go a step further, the employer could provide the employees with a copy of the plan, particularly all new employees. C H A I N OF C O M M A N D
A chain of command should be established to minimize confusion so that employees will have no doubt about who has authority for making decisions. Responsible individuals should be selected to coordinate the work of the emergency response team. In larger organizations, there may be a plant coordinator in charge of plant-wide operations, public relations, and ensuring that outside aid is called in. Because of the importance of these functions, adequate backup must be arranged so that trained personnel are always available. The duties of the Emergency Response Team Coordinator should include the following: (1) Assessing the situation and determining whether an emergency exists that requires activating the emergency procedures, (2) Directing all efforts in the area including evacuating personnel, (3) Ensuring that outside emergency services such as medical aid and local fire departments are called in when necessary, and (4) Directing the shutdown of plant operations when necessary. COMMUNICATIONS
During a major emergency involving a fire or explosion it may be necessary to evacuate offices in addition to manufacturing areas. Also, nor-
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Appendix M
mal services, such as electricity, water, and telephones, may be nonexistent. Under these conditions, it may be necessary to have an alternate area to which employees can report or that can act as a focal point for incoming and outgoing calls. Since time is an essential element for adequate response, the person designated as being in charge should make this the alternate headquarters so that he/she can be easily reached. Emergency communications equipment such as amateur radio systems, public address systems, or portable radio units should be present for notifying employees of the emergency and for contacting local authorities, such as law enforcement officials, private sector charitable groups, and the fire department. A method of communication also is needed to alert employees to the evacuation or to take other action as required in the plan. Alarms must be audible or seen by all people in the plant and have an auxiliary power supply in the event electricity is affected. The alarm must be distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the emergency action plan. The employer must explain to each employee the means for reporting emergencies, such as manual pull box alarms, public address systems, or telephone. Emergency phone numbers should be posted on or near telephones, on employees' notice boards, or in other conspicuous locations. The warning plan should be in writing and management must be sure each employee knows what it means and what action is to be taken. It may be necessary to notify other key personnel such as the plant manager or physician during off-duty hours. An updated written list of key personnel should be kept listed in order of priority.
ACCOUNTING
FOR P E R S O N N E L
Management will need to know when all personnel have been accounted for. This can be difficult during shift changes or if contractors are on site. A responsible person in the control center must be appointed to account for personnel and to inform police or Emergency Response Team members of those persons believed missing.
E M E R G E N C Y RESPONSE T E A M S
Emergency Response Teams are the first line of defense in emergencies. Before assigning personnel to these teams, the employer must assure that employees are physically capable of performing the duties that may be
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Training
assigned to them. Depending on the size of the plant there may be one or several teams trained in the following areas: (1) (2) (3) (4) (5) (6) (7) (8) (9)
Use of various types of fire extinguishers, First aid, including cardiopulmonary resuscitation (CPR), Shutdown procedures, Evacuation procedures, Chemical spill control procedures, Use of self-contained breathing apparatus (SCBA), Search and emergency rescue procedures, Incipient and advanced stage firefighting, and Trauma counseling.
The type and extent of the emergency will depend on the plant operations and the response will vary according to the type of process, the material handled, the number of employees, and the availability of outside resources. OSHA's Hazard Communication Standard (29 CFR per 19101200) is designed to ensure that the hazards of all chemicals produced or imported are evaluated and that information concerning their hazards is transmitted to employers and employees. This is done by means of comprehensive hazard communication programs including container labeling and other forms of warnings, Material Safety Data Sheets, and employee training. Emergency Response Teams should be trained in the types of possible emergencies and the emergency actions to be performed. They are to be informed about special hazards, such as storage and use of flammable materials, toxic chemicals, radioactive sources, and water reactive substances to which they may be exposed during fire and other emergencies. It is important to determine when not to intervene. For example, team members must be able to determine if the fire is too large for them to handle or whether search and emergency rescue procedures should be performed. If there is the possibility of members of the Emergency Response Team receiving fatal or incapacitating injuries, they should wait for professional firefighters or emergency response groups. TRAINING
Training is important to the effectiveness of an emergency plan. Before implementing an emergency action plan, a sufficient number of persons must be trained to assist in the safe and orderly evacuation of employees. Training for each type of disaster response is necessary so that employees know what actions are required. In addition to the specialized training for Emergency Response Team members, all employees should be trained in the following:
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Appendix M
(1) (2) (3) (4) (5)
Evacuation plans, Alarm systems, Reporting procedures for personnel, Shutdown procedures, and Types of potential emergencies.
These training programs must be provided as follows: (1) (2) (3) (4) (5)
Initially when the plan is developed, For all new employees, When new equipment, materials, or processes are introduced, When procedures have been updated or revised, When exercises show that employee performance must be improved, and (6) At least annually.
The emergency control procedures should be written in concise terms and be made available to all personnel. A drill should be held for all personnel, at random intervals at least annually, and an evaluation of performance made immediately by management and employees. When possible, drills should include groups supplying outside services, such as fire and police departments. In buildings with several places of employment, the emergency plans should be coordinated with other companies and employees in the building. Finally, the emergency plan should be reviewed periodically and updated to maintain adequate response personnel and program efficiency. PERSONAL P R O T E C T I O N
Effective personal protection is essential for any person who may be exposed to potentially hazardous substances. In emergency situations employees may be exposed to a wide variety of hazardous circumstances, including: (1) Chemical splashes or contact with toxic materials, (2) Falling objects and flying particles, (3) Unknown atmospheres that may contain toxic gases, vapors or mists, or inadequate oxygen to sustain life, (4) Fires and electrical hazards, and (5) Violence in the workplace. It is extremely important that employees be adequately protected in these situations. Some of the safety equipment that may be used includes: (1) Safety glasses, goggles, or face shields for eye protection, (2) Hard hats and safety shoes for head and foot protection,
Personal Protection
547
(3) Proper respirators for breathing protection, (4) Whole body coverings~chemical suits, gloves, hoods, and bouts for body protection from chemicals, and (5) Body protection for abnormal environmental conditions, such as extreme temperatures. The equipment selected must meet the criteria contained in the OSHA standards or described by a nationally recognized standards producing organization. The choice of proper equipment is not a simple matter and consultation should be made with health and safety professionals before making any purchases. Manufacturers and distributors of health and safety products may be able to answer questions if they have enough information about the potential hazards involved. Professional consultation will most likely be needed in providing adequate respiratory protection. Respiratory protection is necessary for toxic atmospheres of dust, mists, gases, or vapors and for oxygen-deficient atmospheres. There are four basic categories of respirators: (1) Air-purifying devices (filters, gas masks, and chemical cartridges), which remove contaminants from the air but cannot be used in oxygendeficient atmospheres. (2) Air-supplied respirators (hose masks, airline respirators), which should not be used in atmospheres that are immediately dangerous to life or health. (3) Positive-pressure self-contained breathing apparatus (SCBA), which are required for unknown atmospheres, oxygen-deficient atmospheres, or atmospheres immediately dangerous to life or health, (4) Escape masks. Before assigning or using respiratory equipment, the following conditions must be met: (1) A medical evaluation should be made to determine if the employees are physically able to use the respirator. (2) Written procedures must be prepared covering safe use and proper care of the equipment, and employees must be trained in these procedures and in the use and maintenance of respirators. (3) A fit test must be made to determine a proper match between the facepiece of the respirator and the face of the wearer. This testing must be repeated periodically. Training must provide the employee an opportunity to handle the respirator, have it fitted properly, test its facepiece-to-face seal, wear it in normal air for a familiarity period, and wear it in a test atmosphere. (4) A regular maintenance program must be instituted including cleaning, inspecting, and testing of all respiratory equipment. Respirators used for emergency response must be inspected after each use and at least
548
Appendix M
monthly to assure that they are in satisfactory working condition. A written record of inspection must be maintained. (5) Distribution areas for equipment used in emergencies must be readily accessible to employees. A positive-pressure SCBA offers the best protection to employees involved in controlling emergency situations. It must have a minimum service life rating of at least 30 minutes. Conditions that require a positive-pressure SCRA include the following: (1) Leaking cylinders or containers, smoke from chemical fires, or chemical spills that indicate high potential for exposure to toxic substances. (2) Atmospheres with unknown contaminants or unknown contaminant concentrations, confined spaces that may contain toxic substances, or oxygen-deficient atmospheres. Emergency situations may involve entering confined spaces to rescue employees who are overcome by toxic compounds or who lack oxygen. These permit-required confined spaces include tanks, vaults, pits, sewers, pipelines, and vessels. Entry into permit-required confined spaces can expose the employee to a variety of hazards, including toxic gases, explosive atmospheres, oxygen deficiency, electrical hazards, and hazards created by mixers and impellers that have not been deactivated and locked out. Personnel must never enter a permit-required confined space unless the atmosphere has been tested for adequate oxygen, combustibility, and toxic substances. Conditions in a permit-required confined space must be considered immediately dangerous to life and health unless shown otherwise. If a permit-required confined space must be entered in an emergency, the following precautions must be adhered to: (1) All lines containing inert, toxic, flammable, or corrosive materials must be disconnected or blocked off before entry. (2) All impellers, agitators, or other moving equipment inside the vessel must be locked out. (3) Appropriate personal protective equipment must be worn by employees before entering the vessel. Mandatory use of harnesses must be stressed. (4) Rescue procedures must be specifically designed for each entry. A trained stand-by person must be present. This person should assigned a fully charged, positive-pressure, self-contained breathing apparatus with a full facepiece. The stand-by person must maintain unobstructed lifelines and communications to all workers within the permit-required confined space and be prepared to summon rescue personnel if necessary. The stand-by person should not enter the confined space until adequate assistance is pres-
Medical Assistance
549
ent. While awaiting rescue personnel, the stand-by person may make a rescue attempt utilizing lifelines from outside the permit-required confined space. A more complete description of procedures to follow while working in confined spaces may be found in the OSHA standard for permit-required confined spaces, 29 CFR 1910.145 and the National Institute for Occupational Safety and Health (NIOS14) Publication Number 80-106, Criteria for
a Recommended Standard... Working in Confined Spaces.
M E D I C A L ASSISTANCE
In a major emergency, time is a critical factor in minimizing injuries. Most small businesses do not have a formal medical program, but they are required to have the following medical and first-aid services: (1) In the absence of an infirmary, clinic, or hospital in close proximity to the workplace that can be used for treatment of all injured employees, the employer must ensure that a person or persons are adequately trained to render first aid. The first aid is to begin within 3 to 4 minutes of the incident if the injury is of a serious nature. (2) Where the eyes or body of any employee may be exposed to injurious corrosive materials, eye washes or suitable equipment for quick drenching or flushing must be provided in the work area for immediate emergency use. Employees must be trained to use the equipment. (3) The employer must ensure the ready availability of medical personnel for advice and consultation on matters of employees' health. This does not mean that health care must be provided, but rather that, if health problems develop in the workplace, medical help will be available to resolve them. To fulfill the above requirements, the following actions should he considered: (1) Survey the medical facilities near the place of business and make arrangements to handle routine and emergency cases. A written emergency medical procedure should then be prepared for handling accidents with minimum confusion. (2) If the business is located far from medical facilities, at least one and preferably more employees on each shift must be adequately trained to render first aid. The American Red Cross, some insurance carriers, local safety councils, fire departments, and others may be contacted for this training. (3) First-aid supplies should be provided for emergency use. This equipment should be ordered through consultation with a physician.
550
Appendix M
(4) Emergency phone numbers should be posted in conspicuous places near or on telephones. (5) Sufficient ambulance service should be available to handle any emergency. This requires advance contact with ambulance services to ensure they become familiar with plant location, access routes, and hospital locations.
SECURITY During an emergency, it is often necessary to secure the area to prevent unauthorized access and to protect vital records and equipment. An offlimits area must be established by cordoning off the area with ropes and signs. It may be necessary to notify local law enforcement personnel or to employ private security personnel to secure the area and prevent the entry of unauthorized personnel. Certain records also may need to be protected, such as essential accounting files, legal documents, and lists of employees' relatives to be notified in case of emergency. These records may be stored in duplicate outside the plant or in protected, secure locations within the plant.
SOME OSHA REQUIREMENTS The following is a list of some of the OSHA requirements pertaining to emergency response. These references refer to appropriate sections of the Occupational Safety and Health Standards (Title 29, Code of Federal Regulations, Part 1910, which are the OSHA General Industry Standards). If additional information is required call the nearest OSHA Area Office or State Plan Office listed below..
Subpart E--Means of Egress 1910.37 Means of egress 1910.38 Employee emergency plans and fire prevention plans Appendix to Subpart E - Means of egress
Subpart H--Hazardous Materials 1910.119 Process safety management of highly hazardous chemicals 1910.120 Hazardous waste operations and emergency response.
Some OSHA Requirements
Subpart I---Personal Protective Equipment
1910.132 General requirements~personnel protection 1910.133 Eye and face protection 1910.134 Respiratory protection 1910-155 Occupational head protection 1910.136 Occupational foot protection 1910.138 Hand protection
Subpart J--General Environmental Controls
1910.146 Permit-required confined spaces 1910.147 Control of hazardous energy sources
Subpart K--Medical and First Aid
1910.151 Medical services and first aid
Subpart L--Fire Protection
1910.155-156 Fire protection and fire brigades 1910.157-163 Fire suppression equipment 1910.164 Fire detection systems 1910.165 Employee alarm systems Appendices A-E of Subpart L
Subpart R--Special Industries, Electrical Power Generation, Transmission, and Distribution
Subpart Z--Toxic and Hazardous Substances
1910.1030 Bloodborne pathogens 1910.1200 Hazard communication
551
552
Appendix M
I N F O R M A T I O N A N D C O N S U L T A T I O N SERVICES
Much of the planning and program development for responding to occupational emergencies will require professional assistance. Many public and private agencies provide information and services free or at minimal cost (e.g., federal, state, and local health and labor departments, insurance carriers, and local universities). After having exhausted these sources, consider using a private consultant selected by matching his/her specialty with your specific needs. If there is a carrier for workers' compensation insurance, that company probably has safety and health specialists on staff who are familiar with minimum standards and technical information currently available and may be quite helpful in advising about accident and illness prevention and control. Trade. associations often have technical materials, programs, and industry data available for specific needs. The Department of Labor through the Occupational Safety and Health Administration (OSHA) provides information in interpreting the law and on meeting the applicable standards. This information is available free of charge or obligation. The OSHA Area Office or State Plan Office nearest to the plant may be contacted for this information. The Department of Health and Human Services through the National Institute for Occupational Safety and Health (NIOSH) provides printed material relating to employee safety and health in the workplace. Staff from this agency will perform industrial hygiene surveys of plants upon request of employers or employees. See the listing below. Machine or product manufacturers can be helpful in providing additional information on precautions to take in using their products. Any special problems should be referred to them first. Professional societies in the safety, industrial hygiene, and medical fields issue publications in the form of journals, pamphlets, and books that may be quite useful (e.g., American Society of Safety Engineers or the Occupational Health Institute). They can also recommend individuals from their societies to serve as consultants. FREE ON-SITE C O N S U L T A T I O N
Free on-site safety and health consultation services are available to employers in all states who want help in establishing and maintaining a safe and healthful workplace. This service is largely funded by OSHA. Primarily developed for smaller employers with more hazardous operations, the consultation service is delivered by state governments employing professional
Training and Education
553
safety consultants and health consultants. Comprehensive assistance includes an appraisal of all mechanical systems, physical work practices, and environmental hazards of the workplace and all aspects of the employer's present job safety and health program. This program is completely separate from OSHA's inspection efforts. No penalties are proposed or citations issued for any safety or health problems identified by the consultant. The service is confidential. For more information concerning consultation services, see the list of state consultation projects above.
V O L U N T A R Y P R O T E C T I O N PROGRAM
Voluntary Protection programs (VPPS) and on-site consultation services, when coupled with an effective enforcement program, expand worker protection to help meet the goals of the OSH Act. The three VPPs--Star, Merit, and Demonstrationmare designed to recognize outstanding achievement by companies that have successfully incorporated comprehensive safety and health programs into their total management system. They motivate others to achieve excellent safety and health results in the same outstanding way, and they establish a cooperative relationship among employers, employees, and OSHA. For additional information on VPPs and how to apply, contact the OSHA offices listed at the end of this appendix.
TRAINING AND EDUCATION
OSHA's area offices offer a variety of informational services, such as publications, audiovisual aids, technical advice, and speakers for special events. OSHA's training institute in Des Plaines, Illinois, provides basic and advanced courses in safety and health for federal and state compliance officers, state consultants, federal agency personnel, and private sector employers, employees, and their representatives. OSHA also provides funds to nonprofit organizations, through grants, to conduct workplace training and education in subjects where OSHA believes there is a lack of workplace training. Grants are awarded annually. Grant recipients are expected to contribute 20% of the total grant cost.
For more information on grants, training, and education, contact the OSHA Training Institute, Office of Training and Education, 1555 Times Drive, Des Plaines, IL 60018; (708) 297-4810.
554
Appendix M
For further information on any OSHA program, contact your nearest OSHA area or regional office listed at the end of this appendix Local colleges and universities sometimes have industrial hygiene, public health, medical, or other relevant departments with faculty and libraries to assist. O T H E R SOURCES OF O S H A ASSISTANCE
Effective management of worker safety and health protection is a decisive factor in reducing the extent and severity of work-related injuries and their related costs. To assist employers and employees in developing effective safety and health programs, OSHA publishes recommended Safety and Health Management Guidelines (Federal Register 54(18): 3908-3916, January 26, 1988). These voluntary guidelines apply to all places of employment covered by OSHA. The guidelines identify four general elements that are critical to the development of a successful safety and health management program: (1) (2) (3) (4)
Management commitment and employee involvement; Work-site analysis; Hazard prevention and control, and Safety and health training.
The guidelines recommend specific actions, under each of these general elements, to achieve an effective safety and health program. A single free copy of the guidelines can be obtained from the OSHA Publications Office, U.S. Department of Labor, 200 Constitution Avenue, N.W., Room N3101, Washington DC 20210, by sending a self-addressed mail label with your request. STATE O C C U P A T I O N A L SAFETY A N D H E A L T H PLANS
The Occupational Safety and Health Act of 1970, under Section 18(b), encourages states to develop and operate their own state job safety and health plans under the approval and monitoring of OSHA. Twenty-five states and territories operate such plans. They are required to set standards that are at least as effective as the federal, conduct inspections to enforce those standards (including inspections in response to workplace complaints), cover state and local government employees, and operate occupational safety and health training and education programs. In addition, all states provide on-site consultation to help employers to identify and correct workplace hazards. Such consultation may be provided either under the plan or through
State Occupational Safety and Health Plans
555
a special agreement under section 7(c)(1) of the Act. Federal OSHA does not conduct enforcement activities in the states with State Plans, except in very limited circumstances. A listing of those states that operate approved State Plans can be found on page 14 of the Occupational Safety and Health Standards booklet, or call your local OSHA Area Office. A comprehensive customer service poster listing OSHA services and how to contact agency Regional, Area, and District offices is available from OSHA's Publications Office, 200 Constitution Avenue, N.W., Washington DC 20210, Room N3101. Telephone: (202) 219-4667.
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INDEX A AC/UAC, s e e Area command/unified area command Acquired immune deficiency syndrome, s e e AIDS Action level, 170, 196, 325,328-329 Acute effect, 116-118 Acute hepatitis, 129 AIDS, 122, 130-132 Air contaminants, 195-196 Air purifying respirator, 197-198 Air supplying respirator, 198-199 ALARP principle, 329-330 Alkaline phosphatase test, 148 All hazard mitigation, 254-258,260 ALOHA, 296 Alpha particle, 338 Alternative process engineering, 245 Ambient air monitoring devices, 314-320 Ambient materials testing, 320-321 Anthrax, 334, 336 Area command/unified area command, 98 Area locations of hazardous atmospheres, s e e ALOHA Audiometric testing, 168-171 Aural insert, 207
B Baseline audiogram, 168-170 Baseline health profile, 146 Beta particle, 338 Binary device, 341 Biohazard, 122-144 Biological agent, 107 Bioregulator, 335 Bioremediation, 277 Biosensor, 323 Blister agent, 342-343 Blood agent, 343-344
Bloodborne pathogen, 126-139 exposure control plan, 137-139 protective clothing, 134, 136-137 standard (29 CFR 1910.1030), 123, 126-132, 134, 137, 250 work practices, 135-137 B-NICE, 332 Body fluid, 126, 131 Body substance isolation, 140-144 Botulin toxin, 335 Bubonic plague, 334
C CAM, 323 CAMEO, 295-297 Canal cap, 207 Carry-home contamination, 266,328-329 CERCLA, 1, 12, 314 CGI, see Combustible gas indicator Chelation, 277 Chemical agent monitor, s e e CAM Chemical hazard, 103-121,243-248 Chemical hygiene plan, 47-50 Chemical incompatibility, 265,269-271 Chemical inventory control, 45,246-248 Chemical monitoring, 313-330 ambient air monitoring devices, 314-320 ambient materials testing, 320-321 personal monitoring, 321-322 technologies, 314-322 Chemical substitution, 245 Chest X-ray, 148 Choking agent, 344 Cholera, 334 Chronic effect, 116-118 Circumaural device, s e e Earmuff CISD, s e e Critical incident stress debriefing Clean water act, s e e CWA Clinical chemistries, 159 557
Index
558 Clinical severity (of infection), 153 Closed-circuit SCBA, 200 Clostridium toxin, 335 Cold stress, 190-191 Colorimetric indicator tube, 315-316, 321 Combustible gas indicator (meter), 317-318 Command, 82-102 Communication, 26, 44-46, 219-220 Community hazard, 104 Comprehensive emergency response, compensation and liability act, s e e CERCLA Comprehensive exercise program (FEMA), 232 Computer-aided management of emergency operations, s e e CAMEO Confined space entry standard (29 CFR 1910.146), 212, 250, 327 Containment, 72-73 Contaminant reduction zone, 281-283,285 Contaminated water rescue, 177, 184-186 Contamination control line, 282, 285 Contingency plan, 19-22 Continuous flow respirator, 198-199 Control agent, s e e Irritating agent Cooling vest, s e e Ice vest Corporate risk management, 208 Corporate training, 216-220 Crime scene precautions, 347 Crisis development, 54-55 Critical incident stress, 162-168 Critical incident stress debriefing, 167-168 Cumulative trauma disorder, 160-163 Curriculum guidelines (OSHA), 469-487 CWA, 1
D Data and information management, 293-312 elements of in-service data and information base, 297-306 expert software, 295-297 modular approach to database design, 306-312 Database, 120, 299-302, 305-312 Decontamination, 190-193,265-292 disposal of contaminated material, 284-286 emergency decontamination, 286-292 incompatible and synergistic chemical contaminants, 269
methods and equipment, 272-280, 290, 292 objectives, 265-266 prevention of contamination of clean areas, 273,281-284 scope of decontamination plan, 266-286 standard operating procedures, 266-268 stations and facilities, 269-273 Demand air flow respirator, 198-199 Detection ticket, 323 Detector paper, 323 Detector tube, s e e Colorimetric indicator tube Detoxification, 276-277 Diphtheric toxin, 335 Disinfection, 191,204, 256,278-280 Dispersion model, 119,297 Disposal of contaminated material, 284-286 Domestic terrorism, 125, 331 Dose, 109 Dose-response (effect), 114-118 Dosimeter, 321 Drilled well, 256 Dynamic strain sensor, 322
E Earmuff, 207 Earplug, s e e Aural insert Earth summit (Rio, 1992), 27 Ebola virus, 334 ECs0, 114-118 EDs0, 115-118 Effective concentration, s e e ECs0 Effective dose, s e e ED50 Efficiency improvement, 245 Electrical safety-related work practices standard (29 CFR 1910.331-.335), 250 Electronic communication, 15 Emergency decontamination, 286-292 Emergency management guide (FEMA), 423-468 Emergency operations center, 98 Emergency operations plan, 348-350 Emergency planning, 25-52 Emergency planning and community right to know act, s e e EPCRA Emergency response operations, 38, 41 Emergency response personnel (hazardous waste), 6-10 essential on-site personnel, 6-7 off-site personnel, 9
559
Index
optional on-site personnel, 8 personnel that may be needed, 10 Emergency response plan, 2-5, 22-23, 39, 53-81,423-468,515-555 appendices, 76 assessment of hazards, 67-70 basic issues, 39 containment procedures, 72-73 contents, 58-76 distribution, 64-65 documentation, 75-76 emergency equipment and supplies, 65-66 employees with disabilities, 515-540 equipment shutdown, 73-74 evacuation procedures, 71-72 general procedures, 70-71 location of data/information, 66-67 management guide (FEMA), 423-468 notification procedures, 71 principles, 56-57 responsibility and authority, 63-64 return to normal operations, 74 special procedures, 73 training, 75 workplace emergencies (OSHA), 541-555 Emergent disease, 123-125 Employee assistance program, 168 Employee emergency plan (29 CFR 1910.38), 2 Energy control standard (29 CFR 1910.147), 212,250 Engineering control, 245 Ensembles, 174-194 Entry precautions, 346-347 Environmental disinfection, 279 Environmental fate, 119 Environmental technologies export handbook, 258 Environmental transport/transformation, 119 EPCRA, 5-8, 13, 53,250, 296,314 Equipment shutdown, 73-74 Ergonomic criteria, 251-252 Ergonomic hazard, 160-163 Escape-only SCBA, 200 Evacuation drill, 229 Event tree analysis, 32-33, 110-112 Exclusion zone, 281,285 Expert software, 294-297 Exposure, 118-119, 150, 152 dimensions of, 118-119 exposure incident, 150
symptoms, 152 Exposure control, 137-139,245 control methods, 245 plan, 137-139
F Fail-safe requirement, 325 Failure mode and effect analysis, 31-32, 110-112 False negative, 316 Fault tree analysis, 32-33, 110-112 Federal on-scene coordinator, 101 Federal response plan, s e e FRP Federal water pollution control act, 12 FID, s e e Flame ionization detector Fire data analysis handbook, 303 Fit testing, 201 Flame ionization detector, 317-318 Flame photometric detector, s e e FPD FPD, 323 FRP, 349-350,488-502 Fugitive release control, 246 Full-scale exercise, 229 Fulminant hepatitis, 129 Functional drill, 229
G GA, s e e Tabun Gamma radiation, 338 GB, s e e Sarin GC mode, 317 GD, s e e Soman Global economy, 14-15,145,210
I-I Halogen stripping, 277 Hanta disease, 335 Hazard, agents of, 106-107 biological, 122-144 class, 114 community, 104 evaluation and mitigation of, 110-119 identification, 108-110 job task analysis, 113, 158-159 reduction, 239-243 rescue, 105 sources, 104-110 Hazard and operability analysis, 31-32, 110-112 Hazard assessment, 28-30, 67-70, 103-121
560 Hazard assessment ( c o n t i n u e d ) criteria for evaluation of, 67-70 Hazard communication plan, 47, 120 Hazard communication standard (29 CFR 1910.1200), 44-45, 53,212, 250, 327 Hazard reduction strategies, 239-264 Hazardous chemicals, 12-13, 103-121 Hazardous material, 109 Hazardous material transportation act, s e e HMTA Hazardous waste operations and emergency response (29 CFR 1910.120), 2, 13, 34, 149, 153,249, 327, 469-487 HAZMAT, 34-36, 49 HAZOP, s e e Hazard and operability analysis HBV, 122-123, 126, 128-130, 132, 134-135 HCV, 126, 130, 132 Hearing conservation standard (29 CFR 1910.95), 249 Hearing protection, 206-207 Heat stress, 183, 189-190 Hemorrhagic fever, 133,334 Hepatitis B virus, s e e HBV Hepatitis C virus, s e e HCV High-level disinfection, 279 HIV, 122, 126, 129-132 HMTA, 1, 12, 109 Holistic planning, 25-52, 110 Hotline, 281-282,285 Hotwork standard (29 CFR 1910.252), 250 HSE, 15, 26-28 Human immunodeficiency virus, s e e HIV Human reliability analysis, 32-33, 110 Hypothermia, 190
! Ice vest, 190 ICS, 42-43, 82-102 adaptation to other command structure, 97-102 alternative emergency management systems, 98 command, 83-84, 88-90 facilities, 95-96 finance/administration, 85-88, 96-97 guidelines, 94 logistics, 85, 93-96 operations, 84, 90-91 planning, 85, 92-93 responsibilities, 86-89
Index
subsectional organization, 88-97 support positions, 90 tactical resources, 92 transfer of command, 84 Impulsive sound, 206 Incident action plan, 59 Incident command system, s e e ICS Incident response personnel, 220-238 Incident site as crime scene, 345-347 crime scene precautions, 347 entry precautions, 346-347 recognition of warning signs, 345-346 Incubation period, 337 Indicator chemical, 315 Infection control procedures, 141-143 Infectious (pathogenic) disease, 122-144 Information exchange (National Response Team), 228 Information handling and processing, 44-46, 119-121,293-312 Information sources, 48, 174, 199,222-225, 228-238,249-250, 257-258,297 Infrared spectrophotometer, 317 In-process recycling, 246 Intermediate-level disinfection 279 International standards organization, s e e ISO International terrorism, 331 Ion mobility spectroscopy (IMS) system, s e e CAM IR, s e e Infra red spectrophotometer Irritating agent, 344-345 ISO, 14-15
1
Job-task (hazard)analysis, 113, 135, 158-159 I_ Laboratory standard (29 CFR 1910.1450), 44-46, 149,250, 327 Lassa fever, 334 LCs0, 115-118 LDs0, 114-118 Learning resource center (U.S. Fire Administration), 228,233 LEL, 318-319, 325 LEPC, 5-7 LERC, 326 Lethal concentration, s e e LCs0 Lethal dose, s e e LDs0 Lewisite, 342
Index
Local emergency planning committee, s e e LEPC Local emergency response commission, s e e LERC Lockout/tagout, s e e Energy control standard Lower explosive limit, s e e LEL Low-level disinfection, 279
M MACS, s e e Multiagency coordination systems Malaysia, 54, 236-237 Management control, 245 Management of change, s e e MOC MaP, 47 Mapping applications for response and planning of local operations tasks, s e e MARPLOT Marburg virus, 334 MARPLOT, 296 Medical tests, 158-171 Medical treatment/surveillance, 4, 26, 48-51,145-171 episodic monitoring, 149-153 liaison with medical authority, 154-158 objectives and concerns, 145-154 OSHA standards, 4 periodic operational monitoring, 148-149 programmatic review, 171 target organs, 156 termination examination, 153-154 types of medical analysis, 158-171 types of surveillance, 145 Member assistance program, 168 Mitigation, 239-264 all hazard mitigation, 254-258 chemical hazard, 243-248 fire, 259 flood, 262 hazardous material incident, 260 hurricane and tornado, 261 measures, 243-254 methods employed by professional services, 251-254 objectives, 239-243 regulation-based methods, 248-251 severe winter storm and earthquake, 263 technological, 264 MOC, 16-21 Monitoring strategies and devices, 313-300
561 chemical monitoring technologies, 314-322 design and implementation of monitoring program, 323-326 other monitoring technologies, 322-323 proactive industrial monitoring, 326-330 Multiagency coordination systems, 97-98 Mustard gas, 342 Mutual assistance monitoring program, 325 Mutual assistance program, s e e MAP
N Needs analysis, 324-325 Nerve agent, 340-342 Neutralization, 277 NFPA standards, 147, 188 NIOSH certification, 199 Nitrogen mustard, 342 Nonbloodborne pathogen, 133,138-144 Nonimpulsive sound, 206 Nonpowered particulate respirator, 199,204 Notification procedures, 71
O O-mustard, 342 On- and off-site management, 37-41, 51 Open-circuit SCBA, 200 Open diffusion detector tube, 321 Operational risk management, 89 OSHA standards, 2-4 emergency response, 2 medical surveillance, 4 protection of personnel, 3 Oxidation, 277 Oxygen meter, 318-319
P Particulate filters, 201-202 PASS, s e e Personal alert safety system Pathogen, 107 PDD-39, 349 PEL, s e e Permissible exposure limit Permanent threshold shift, 169 Permeation, 286,288 Permissible exposure limit, 197 Personal alert safety system, 323 Personal monitoring, 321-322 Personal protective clothing and equipment, s e e PPC/PPE Personnel training, 75, 81,208-238 alternative approaches, 226-227
562 Personnel training ( c o n t i n u e d ) comprehensive exercise program (FEMA), 232 curriculum guidelines (OSHA), 469-487 design of comprehensive training program, 221-223 general policies, 216 incident response personnel, 220-238 information exchange (National Response Team), 228 NFA and EMI training courses, 507-514 NSC training in CAMEO, 297 presenters, 214-215 proactive management of hazards, 209-220 professional training services, resources and information, 228-238 programs and responsibilities, 213 proven training methods, 223-228 rescue, 230-232 scheduling constraints, 214 specific programmatic requirements, 216 tabletop exercise, 225, 229, 236-237 training methods, 213-214, 229 training policy document, 212-216 training records, 215 training topics, 217, 223-233 PHA, s e e preliminary hazard analysis Photoionization detector, 317-318 Physical hazards, 103-121 PID, s e e Photoionization detector Piezoelectric film, 322 Portable detector, 318-320 Posttraumatic stress disorder, 162-168 PPC/PPE, 3, 35-36, 136-137, 172-207 bloodborne pathogens, 136-137 cold stress, 190-191 contaminated water, 177, 184-186 decontamination, 190-191,266-268, 272-280,290,292 ensembles, 175-194 evaluation of performance, 174 field evaluation, 174 full body protection, 176-177 guidelines, 253-254 hazardous waste operations, 35-36 hazardous waste sites, 178-179 hearing, 206-207 heat stress, 183, 189-190 inspection, 191-194
Index
NFPA standard, 188 OSHA standard, 3, 187 removal, 283-284 respiratory, 187, 195-206 selection, 173-174 swift water rescue, 175-176, 182-183 technical rescue, 175, 180-181 Preliminary hazard analysis, 31-32, 110-112 PREP, s e e Preparedness for response exercise program Preparedness for response exercise program, 221,223-225 Presidential Decision Directive 39, s e e PDD-39 Pressure demand air flow respirator, 198-199 Preventive antidote, 341 Proactive industrial monitoring, 326-330 action level, 328-329 ALARP principle, 329-330 carry-home contamination, 328-329 establishing baseline conditions, 327-328 identification of monitor parameters, 327 quality control, 329 Proactive management of hazards, 209-220 Process safety assessment, 111-112 Process safety management of explosive and blasting agents (29 CFR 1910.109), 249 Process safety management of highly hazardous chemicals (29 CFR 1910.119), 1, 16-19, 31,111,249, 347 Product cycle, 108 Product reformulation, 244-245 Provisions and support, 46-48 PTS, s e e Permanent threshold shift
Q Q fever, 334
R Radiation survey meter, 319-320 Radiological dispersal device, s e e RDD RCRA, 1-2, 5-10, 12, 53, 64, 109, 314 RDD, 337 Reemergent disease, 126-127 Relative toxicity, 116-117 Remediation, 26, 51-52 Replacement in-kind, 17
Index
Rescue hazard, 105 Resource conservation and recovery act, s e e RCRA Respirators, 197-199 Respiratory protection, 195-206 action level, 196 air contaminants, 195-196 cleaning and disinfection, 204 general procedures, 199-204 inspection, 204-206 types of respirators, 197-199 Respiratory protection standard (29 CFR 1910.134), 13,249 Ricin, 335 Risk assessment, 28-33, 114, 255 Risk management, 37-39 Risk reduction strategies, 239-264 Risk target assessment, 347-348 Route of entry, 109, 118-119
S Safety policy, 76-81 industry, 77-78 public agency, 79-80 Salmonellosis, 334 SARA, 1 SARA Title III, s e e EPCRA Sarin, 341 Saxitoxin, 335 SCBA, 198-200, 323-324 SEB, 335 Self-contained breathing apparatus, s e e SCBA Sharps, 135 Site control, 40-41,281-283 Smallpox, 334 Soman, 341 Standard threshold shift, 170 Staphylococcus enterotoxin type B, s e e SEB Staphylococcus infection, 334 State on-scene coordinator, 101 Sterilization, 278-280 Substance P, 335 Superfund, s e e CERCLA Superfund amendments and reauthorization act, s e e SARA Support services, 49, 290-291,310 Support zone, 283 Survey mode, 317-318 Swift river rescue, 175-176, 182-183 Symptoms,
563 blister agent, 343 blood agent, 344 chemical, 151-153 critical incident stress, 163-168 heat stress, 183,189-190 nerve agent, 340-341 Synergy, 118,265,269
T Tabletop exercise, 81,225,229, 236-237 Tabun, 341 Target organ, 118, 156 Target organ effect, 118 Tear gas, s e e Irritating agent Technical rescue, 175,180-181,230, 300 Temporary threshold shift, 169 Terrorism, 11, 13-14, 314, 331-350, 488-506 biological incident, 333-337 chemical incident, 339-345 emergency operations plan, 348-350 incendiary incident, 338-339 incident site as crime scene, 345-347 NFA and EMI training courses, 507-514 nuclear incidents, 337-338 potential terrorist weapons, 332-345 presidential decision directive 39, 503-506 terrorist incident annex to the Federal Response Plan, 488-502 warning signs, 345-346 Thermal degradation, 277 Threat assessment, 347-348 Threshold value, 115 Time weight average, s e e T W A Traffic monitor, 323 Training, s e e Personnel training Transfer of incident command, 84 Transport simulation, 297 T Y S , s e e Temporary threshold shift Tularemia, 334 TWA, 206 Typhus, 334
U UEL, 318-319 Unified command, 84, 97-101,260 Unitary device, 342 Universal precautions, 132-134, 288 Upper explosive limit, s e e UEL Urban search and rescue, 175
564 U.S. Federal Bureau of Investigation, 331-332,350
V Vaccination, 132, 134-135, 138-140 Vapor density, 247-248 Venezuelan equine encephalitis, 335 Vibration sensor, 322 Virtual reality technology, 297 Vulnerability analysis, 69-70 VX, 341
Index
W
Walk-through drill, 229 Warning signs, biological incident, 345 chemical incident, 346 explosive incident, 346 incendiary incident, 346 nuclear incident, 345 Wash solutions, 274-275 What-if analysis, 31-32
