This morning Stu Fischbeck left a comment on my blog post from Friday about the introduction of S 242. This was the bill that reauthorized some public health and medical emergency response programs. I suggested that the bill ought to include language requiring facilities with significant amounts of toxic inhalation hazard (TIH) chemicals to provide MSDS to local medical facilities so that they could make appropriate plans for mass casualty operations in the event of a catastrophic leak. Stu asked:
“Do you have any data on how many in industry already coordinate with hospitals, FDs, local EMAs, etc.?”
Notifications are required to be made to local fire departments and local emergency planning committees (LEPC) for certain facilities under CERCLA. This should certainly cover the significant holders of TIH chemicals. Unfortunately LEPCs don’t exist everywhere and the ones that do vary widely in their efficacy.
As best I can tell there is no requirement for anyone to talk to the medical community about the potential treatment requirements for a mass casualty event due to a catastrophic event at a chemical facility.
Different toxic chemicals are going to require different treatment regimes. It seems to me that knowledge of the potential toxic agent in advance would allow the local medical community to do some advance preparation for the required treatment. At the very least the triage personnel are going to have to know what symptoms to look for to separate the chemical casualties from the other related injuries.
Stu makes a valid point. There are almost certainly folks that are already doing this, but from the limited number of conversations that I have had and the news reports that I have seen related to actual incidents there seems to be little to indicate that this is anything but a minority. This isn’t out of any evil intent; too many people think that doctors can recognize the source of all ailments and treat them appropriately with the material on hand. If they can’t we simply sue them for malpractice.
Most doctors have little or no experience dealing with gross exposures to toxic chemicals. Even if they do have some specific experience it is not likely to be on the chemical in question for a particular release; those releases come too far and in between for much of an experience base to have been acquired. That combined with the special equipment and drugs that may be necessary to treat the casualties means that prior planning is an absolute requirement for an effective response to this type of situation.
While this probably should have been included in the CERCLA regulations, it is certainly time to correct the oversight. I think this legislation is a good point to go back and add it to the EPA regulations as it directly effects public health measures and planning that should be done prior to a terrorist attack or a terrible accident that results in a large release of toxic chemicals.