Chemical Defense Project ICR

Today the DHS Office of Health Affairs published a 60-day information collection request (ICR) notice in the Federal Register (78 FR 9405) for a new ICR to support a program mentioned in the 2012 spending bill (HR 2055, PL 112-74) Conference Report, the Chemical Defense Program.

Chemical Defense Program

According to congressional testimony by Testimony of Alexander G. Garza, MD, MPH, Assistant Secretary for Health Affairs and Chief Medical Officer 

“OHA’s Chemical Defense Program (CDP) provides health and medical expertise related to chemical preparedness, detection, response, and resilience—all critical to a comprehensive approach to protect against a chemical attack. Technologies and operations already employed at the federal, state and local level are being leveraged to create a comprehensive chemical defense framework. The chemical defense framework will create synergies and efficiencies among the many ongoing, but currently separate, chemical defense efforts. This framework will integrate DHS’s current capabilities as well as strengthen relationships both horizontally and vertically amongst all federal, state, local and tribal chemical defense stakeholders.”

The ICR

The ICR would allow the Office of Health Affairs (OHA) to collect data from “respondents interested in hosting a demonstration project aimed at developing a comprehensive chemical defense framework”. The information collected would include:

• Name of state, local, tribal, or territorial government agency;

• Address; submitter's name, position and contact information;

• Identified venue for demonstration project;

• Interest in developing a chemical defense capability;

• Specific reasons for the communities interest and needs for a chemical defense capability;

• Community chemical threat assessed risks if applicable; and

• Any additional information respondent requests for consideration

An example of the types of projects that would be considered for this program would be the recent Baltimore, MD study of chemical agent dispersion in subways.

Public Comments

The OHA is soliciting public comments on this ICR. Comments may be submitted to CAPT Joselito Ignacio (joselito.ignacio@hq.dhs.gov, or 202-254-5738). Comments should be submitted by April 9^th, 2013.

It is a shame to see that OHA is not utilizing the Federal eRulemaking Portal for the collection of these comments. The current procedure does not allow for full public viewing of comments submitted. This adds an appearance of secrecy that is unnecessary in this process.

Suggested Project

There is one project in particular that I would be very interested in seeing a local emergency planning committee undertake under this program. It would be to establish a communications protocol between chemical facilities in an area that have significant amounts of toxic inhalation chemicals on hand and local medical treatment facilities so that those facilities would be able to prepare in advance for mass casualty events related to the release, accidental or otherwise, of such chemicals. An evaluation of the lessons learned from such a program would be very instructional for other similarly affected communities and the regulatory community. Houston, TX, Charleston, WV or Louisville, KY would be excellent communities in which this project could be done.