Emergency Response Training

An emergency response plan that has not been supported by training and exercises is a complete waste of paper. People and organizations need to be trained to accomplish the tasks required in an ERP and the ERP must be practiced to ensure that it is practical, effective and achievable. There is an excellent article at FireEngineering.com about what goes into planning a full-scale hazmat exercise. The author, Steven De Lisi, also touches on some of the important training that supports the exercise and the ERP.

Performance Oriented Training

De Lisi notes in his article that the “components of a well-developed performance objective must include reference to the equipment used in accordance with an established standard that defines the conditions under which a task is performed and the level of performance that is considered acceptable”.

The military recognized the importance of these performance objectives almost forty years ago when they developed their performance oriented training (POT) programs. The Army realized that knowledge oriented training, the ability to answer questions on a written test in a classroom, did not translate well into being able to respond to a real world situation on a battle field.

The Army’s POT program was based on a three component definition of each training requirement. Those components were

TASK: A short, concise action-oriented description of the job that had to be accomplished.

CONDITION: A description of the real world situation in which that job would have to be accomplished, including a listing of the equipment required to complete the task..

STANDARD: A clear statement of the measureable objective requirements that would signify acceptable performance of the task in that particular environment.

De Lisi uses the example of victim decontamination in his article to describe how a performance objective would be written for an exercise; “Can first responders assigned to an engine company use equipment normally found on a standard engine in the department to decontaminate 10 ambulatory victims within 15 minutes?” Translating that into the POT definition requirements we would have

TASK: Decontaminate Ambulatory Victims

CONDITION: Given the equipment normally found on a standard fire engine;

STANDARD: Decontaminate 10 ambulatory victims within 15 minutes.

This is a nice generic training description. If the emergency response plan were designed for a generic chemical spill, for example a highway spill from a truck in transit through the community, this could be an adequate definition of the training objective. If, however, the ERP were for specific chemical release from a specific facility the task would include the name of the chemical, the condition might describe the type of release (catastrophic tank failure vs small spill for example), and the standard might include how adequate decontamination was measured (utilizing a specific paper test strip, no color change indicating contamination).

Identify Training Requirements

An effective emergency response plan will have to identify the tasks that each supporting agency would be expected to successfully complete to adequately support that plan. In the Army we identified thess organizational tasks as ‘Missions’ but the same performance oriented description would apply, simply substituting the word ‘mission’ for the word ‘task’. In any case, a clearly defined and mutually accepted description of what the organization is expected to be able to accomplish to support the ERP is essential.

The words, ‘mutually accepted’ are a very important part of the last sentence that cannot be ignored. An emergency response planner might determine that a local fire department needs to be able to measure the concentration in the air of a chemical of interest as part of their portion of the emergency response plan. If the fire department does not have the necessary equipment, or the funds to obtain the equipment, to measure that chemical concentration, then the inclusion of that requirement in the plan is useless.

If the supporting organization cannot agree to a particular mission requirement, the emergency response planner has just three options, delete the requirement, transfer the requirement to another organization, or work with the organization to overcome the obstacles to their acceptance of the requirement. Even when there is a command relationship between the planner and the organization, these are the only real options.

Supporting Emergency Response Plans

Every agency or organization identified in an emergency response plan as having a supporting mission or task to accomplish must be required to develop their own, supporting emergency response plan that includes the necessary training tasks that support that mission/task accomplishment. For example, let’s look at the decontamination task above.

If a fire department is given the responsibility (mission) to decontaminate victims prior to their evacuation to medical treatment, the emergency response planner at that department is going to have to devise a plan to support that requirement. First they will have to decide if every engine company in the department will be required to be able to support the decontamination task, or if only selected companies or even perhaps just one engine company will be so required. A lot will depend on the amount of specialized equipment that will be necessary for the decontamination task. There might be a general decontamination requirement for every company, but just one company might be required to have the specialized equipment for one specific chemical. If that is the case, the other companies have to know that they are not to attempt the decontamination of that particular chemical.

As one goes down the organizational tree, it is quite common for task/mission definition to expand into multiple tasks. Again, using the decontamination task identified above, at the engine company level that might be expanded to include a task for identifying the chemical of concern (if the chemical is not present, decontamination might not be necessary), isolation of contaminated victims from non-contaminated victims (to avoid increasing the number of people requiring decontamination), and marking of decontaminated victims (so they can receive appropriate medical treatment).

At some point in the emergency planning process, the planner will not have sub-organizations to task with requirements; they will be dealing with individuals. The training identification process will be very similar though. Individual supporting tasks will be identified, conditions under which those tasks will be performed will be described, and measurable standards that must be accomplished to successfully complete the task, must be established.

De Lisi makes an important point in his article about establishing training standards; there may already be standards developed. He notes that “national performance standards such as those published by the National Fire Protection Association can provide additional guidance when developing performance objectives”. Utilizing established standards, where applicable, makes the job of the emergency response planner, and the subordinate agencies much easier. Even modifying those standards to fit specific circumstances may make it easier to develop appropriate training plans.

Exercises and Training

The only thing more dangerous than an emergency response plan that has not been exercised is the complete lack of an ERP. Until an ERP is put through an evaluated full-scale exercise, no one really knows if it will work. But there is nothing more embarrassing than conducting an exercise for which one or more supporting agencies is not prepared for. That’s why emergency response plans are evaluated from the lowest level up.

Individuals that make up the various emergency response teams are evaluated by their immediate supervisors on the task they have to be able to complete. Each team or organization is evaluated, in turn, by their tasking organization. Once each element demonstrates proficiency the next level of evaluation or exercise can proceed.

At each level it is important to understand that the evaluation must be designed to accomplish two tasks. First (and most obvious) is to ensure that the standards set for the in emergency response plan can be met. But, just as important (and frequently missed), the adequacy of the defined task/mission to support the next level of the ERP must be evaluated.

If the evaluated task does not fully support the requirements for mission accomplishment at the next level, no amount of proficiency at the task will be adequate. The earlier, and lower in the training process, these discrepancies are noted, the easier it will be to correct the problem.

There is one last point that has to be made about the training process. At each level of evaluation, every subordinate level must also be evaluated. This increases the proficiency of each element being evaluated and also makes it easier to identify why an organization was not able to accomplish a given task to the required standard.

To give a military example, when an infantry company was evaluated on their ability to perform a mission, there was an evaluation team in each of the platoons that made up the company. When possible, there was a team evaluating each squad within each of those platoons. If evaluation manpower was short, at least one of the squads would be evaluated within each platoon. In each evaluated squad, one or two individual soldiers would be specifically evaluated on specific mission supporting tasks. This way there was a complete, vertically integrated evaluation of the ability of the company to perform its mission.

After Action Review

Every time an emergency response plan is used, either for an exercise or an actual emergency situation, it is absolutely imperative that a detailed after action review is undertaken. This review must clearly identify what happened, what portions of the ERP worked and which didn’t. Suggestions for improvement of the ERP, at all levels, must be developed (and every plan can be improved) and a specific plan for implementing those improvements must be established utilizing the same principles outlined above.

Finally, the improvements must be evaluated, again, working from the lowest affected level upwards. This must be a process of continuous improvements. The health and safety of the community and the emergency responders demands it.

All Hazards CFATS and Emergency Response

While DHS-ISCD is understandably reticent about detailing just how they make the decision to include, or not include, a facility in the list of High-Risk Chemical Facilities covered under the CFATS regulations, it does not take any regulatory genius to realize that the off-site consequences of a successful terrorist attack must be an important part of the consideration process. With than in mind, it is quite surprising to the novice observer of Federal Government operations, that the CFATS program pays practically no attention what so ever to the actual off-site consequences of a successful attack in the security planning process.

No CFATS ERP Requirement

The reason is not that DHS-ISCD believes that the security plans developed will absolutely prevent all successful terrorist attacks; no one with any background in security would think for a second that any security program would be capable of stopping all determined terror attacks. No, I’m sure that everyone connected with ISCD is well aware that there will likely be a successful terrorist attack on a high-risk chemical facility (and ISCD will be unfairly blamed by Congress and the media for the failure to stop the attack).

No the reason that effective emergency response planning is ignored in the CFATS (and the OSHA/EPA chemical safety) regulations is two-fold. The first is that the facilities that will be attacked will have no authority to plan and/or direct the emergency response efforts beyond the boundaries of their facility. The second is that no one in Congress or the Executive Branch wants to be responsible for placing a dreaded ‘unfunded mandate’ on a State or local government body.

Inadequate EPA ERP Requirement

Actually, there are provisions in EPA regulations for emergency response planning under the Emergency Planning & Community Right-to-Know Act (EPCRA, 40 CFR 355). For the covered facility the requirements are quite simple; notify the Local Emergency Planning Committee (LEPC) that the facility is covered, appoint an Emergency Coordinator to work with the LEPC, and provide the LEPC with information they request. Finally, facilities must report significant releases of covered chemicals to local emergency response agencies..

Unfortunately, the LEPCs have little funding beyond some FEMA grant monies, their members have little or no training in emergency response planning, and no one is responsible for ensuring that they are doing the job for which they were intended. While there are a few activist LEPCs that are well known within their communities, most people wouldn’t know if their community even had an LEPC (many communities with high-risk chemical facilities do not), much less what evacuation plans had been put into place for their protection.

Actually, it is quite surprising that DHS did not take the easy way out when they were developing the CFATS program and simply piggy-back an emergency response planning requirement for a terrorist attack on top of the LEPC program requirements for an accidental release. The EPA has been getting away with it for years.

All Chemical Hazards ERP

Actually, consolidating all emergency response planning for chemical release incidents does make a certain amount of sense. It doesn’t make much difference if the release is due to an industrial accident or a terrorist attack, most of the emergency response actions will be the same. Since FEMA is the all hazards emergency response agency for the Federal Government it would make sense that they would be the agency that should be responsible for overseeing the ERP efforts supporting both EPCRA and CFATS programs.

In fact, we could expand the ERP requirements to include high-risk chemical transportation releases due to potential terror attacks or accidents. We would probably want to limit that to those rail shipments of security-sensitive materials covered under rail route security and safety assessment requirements since there are no current efforts to regulate other hazmat routes at the Federal level.

Under such a program, there would be a Federal requirement for the establishment of an LEPC in every county potentially affected by a chemical release from an EPCRA or CFATS covered facility or a rail-line identified as a primary or alternative route for security-sensitive materials. This would require the establishment of a Chemical Emergency Response Office (CERO) in FEMA to which EPCRA and CFATS covered facilities and railroads would report the physical area affected by a potential release of a covered chemical.

To ensure that LEPC’s were actually established, the chair of each LEPC would be a CERO employee. Additional federal staffing would depend on the number of covered facilities that were potentially affecting the LEPC county and the number of residents of that county. The assistant chair would be from the appropriate State emergency response agency and the deputy chair would be a member of the local county government. Additional LEPC members would represent each emergency response agency within the county and each covered facility and/or railroad affecting that county.

CERO would also be responsible for providing routine funding for and the oversight of the chemical emergency response planning efforts of the affected LEPCs. The ERPs would be required to be submitted to CERO for review and approval. CERO would also ensure that ERPs are routinely exercised through periodic table top exercises and drills. The CERO would also be responsible for establishing and enforcing the regulatory aspects of the ERP program, including establishing the minimum standards for ERPs.

S 3856 and Emergency Response Planning

In a blog posting yesterday about gas pipeline emergency response planning (ERP) I briefly mentioned S 3856, the Pipeline Transportation Safety Improvement Act of 2010, noting that an actual copy of the bill was not available on the GPO web site. Just coincidentally, I’m sure, the bill showed up today on that site. Now that I have had a chance to review the bill, I’m afraid that I am going to have to revise my disparaging comments.

ERP Communication

Sen. Lautenberg’s (D, NJ) bill would require that the PHMSA web site would include “a comprehensive list and individual copy of each gas and hazardous liquid pipeline operator’s facility response plan, excluding any proprietary or security-sensitive information that may be contained in an operator’s plan” {60138(a)(2)}. This would certainly be a step forward as this would make the plan available for public inspection. There is, however, nothing in the proposed legislation that would require the pipeline operator to coordinate the ERP with State or local emergency planning or response agencies.

While I certainly understand the ‘security-sensitive information’ exclusion, this wording would allow pipeline operators to avoid listing actual locations of the pipelines covered under the ERP. So it could be very difficult for a local emergency planning or response organization to determine if they would be affected by the ERP, especially given the really poor search capabilities on Federal web sites.

The one good point about this requirement is that post-incident investigations by the press and public interest groups should be able to find out how well the ERP was executed. I think that is covered under the phrase ‘closing the barn door….’.

Off-Site Mitigation

Facilities that have large quantities of toxic release chemicals on site have a special security problem. It is not possible to completely prevent a successful terrorist attack on any facility. At best you can make it operationally unattractive, but you cannot provide 100% assurance that you can stop a determined, well equipped and trained attacker from executing a successful attack. And, of course, there is always the potential for an accidental release. So what can you do to protect the nearby community form deadly toxic chemical cloud? Well, there is a very good article over on GovTech.com that describes the techniques that the Umatilla Chemical Depot has used to answer that question for the 80,000 nearby residents with regards to potential releases of the chemical warfare agents stored at that facility. The article describes the complex network of sensor and communications links that allows the facility to detect a CW leak and predict the off-site consequence, and then execute a detailed response to ensure the protection of the nearby community. The article makes it clear that it was not the Umatilla Chemical Depot that was the driving force behind the development and implementation of the system described in the article. It was local emergency response personnel that realized that it was ultimately their job to protect the local citizens. The facility provided technical assistance and would provide initial notification of the release, but it is a variety of local governments and agencies that will be responsible for executing the off-site emergency response plan. There was nothing in the article that described who paid for the system development and maintenance. Since this is a Federal installation the assumption can certainly be made that there were a number of FEMA grants that were used to finance this system. Who would be responsible if Umatilla were a privately owned manufacturing company instead of an arm of the federal government is more complicated. Some FEMA grants would still be available, but most would come from local government coffers, and one would hope, ‘donations’ from the facility. Facilities need to remember that their authority to establish emergency response plans stops at their fence line. Outside that perimeter it is only the government (at a variety of levels) that can close roads, open shelters, direct evacuations, and a myriad of other response activities. The facility still needs to provide technical advicee about the hazards associated with the chemicals, the initial alert information and what ever appropriate updates as they become available.