By Mr. Joselito Ignacio, Acting Director and Public Health Advisor Chemical, Biological, Radiological/Nuclear Office, Federal Emergency Management Agency (FEMA), USA
Large-scale chemical incidents present unique challenges. An incident may occur without notice. The size and complexity characterizing the incident may not be immediately evident which may overwhelm local and State resources over a short time. Large-scale chemical incidents crossing jurisdictional boundaries may lead to confusion regarding the specific authorities relevant to the incident, Incident Command System (ICS) leadership roles and responsibilities, processes for public warning and communication, etc. Additionally, law enforcement, forensic, and other attribution activities related to terrorist or criminal acts may impact consequence management activities and decision-making processes. Decisions will often have to be agreed upon by multiple agencies operating within a unified command structure. Further, although numerous standards and regulatory guidelines exist to shape consequence management strategies, there is no absolute remediation or site clearance/reoccupation approach or level that is universally applicable to every chemical incident.
Need for Whole of Community Decision-Making Process
Consequence management decision-making should involve a flexible process that includes situation-specific considerations and the most current understanding of science and engineering available to fully inform senior leadership decisions.
According to FEMA, the decision-making process should incorporate the following characteristics:
- Transparency – The basis for consequence management decisions should be well understood by all key stakeholders and the public at large to the extent legally possible.
- Inclusiveness – Representative stakeholders should be involved in decision-making activities, including communities of color, low-income communities, and other underserved and historically marginalized communities.
- Effectiveness – Technical subject matter experts should analyze site remediation and clearance for re-use/re-occupation options, assess various technologies and methodologies, and inform goal/strategy development and specific courses of action developed to implement the strategies selected.
- Joint Accountability – Final decisions regarding the selection of appropriate consequence management goals, strategies, and implementing activities should be made jointly by FSLTT officials participating in the Unified Command, in concert with SLTT elected/appointed leadership, as appropriate.
FEMA’s planning process for large-scale chemical incident remediation
There are four primary steps described in this section that community response and recovery leadership can use to achieve the desired end-states for chemical incident consequence management as defined in this document.
- Step 1: Form Required Planning Teams
- Step 2: Understand the Situation
- Step 3: Determine the Goals and Objectives
- Step 4: Plan Development (This step applies to the various consequence management-related plans described above)
Forming a planning team involves active engagement among appropriate partners and stakeholders will ensure (a) their concerns are addressed sufficiently in the remediation planning process and (b) acceptability of consensus end states (as described in this document, but specific to the given incident) for safe reoccupancy and reuse (to include accepting loss of such facilities, equipment, and materials for proper waste disposal if successful decontamination is not achievable). The planning team is comprised of core and collaborative teams. A core planning team includes a planning team leader and planners actively engaged daily in addressing the daily operational response on-site. The collaborative planning team is composed of individuals who have been identified as being responsible for representing their program area or organization. The collaborative planning team may include SMEs from Federal, State or tribal agencies; nongovernmental organizations (NGOs); other Federal agencies; and private-sector partners who have a significant stake or responsibility in the execution of the operational plan being developed.
Understanding the situation involves a comprehensive information analysis of the impacted areas. Information analysis is the process planners use to inform operational decisions. Based on the scope of the plan, the entire planning team is engaged to identify, research, collect, and assess the information that will drive decision making and provide a factual basis for the plan. Research specific to remediation of facilities, materials and equipment to chemical(s) contamination should include the following: (FEMA, 2014)
- Specific facilities, materials and equipment determined contaminated.
- Extent of contamination (e.g., all rooms, just floors, concentrations)
- Building components of contaminated facilities, materials and equipment (e.g., concrete, linoleum, wood, metal, porous or nonporous)
- Weather conditions (may impact contamination spread or possibly degradation)
- Topographical characteristics of suspected or confirmed contaminated areas
- Political, cultural, or ethnic considerations involving suspected or confirmed contaminated areas.
- Transportation corridors for personnel and equipment (both manual, light, heavy or medium mobile vehicles)
- Access to water, and power
- Known methods & required and effective decontaminants and materials.
Determine the goals and objectives of the large-scale chemical incident response and recovery plan will guide the daily operational priorities. This step, based on the information analysis process described, will develop a mission statement that describes what must be accomplished to achieve success clearly articulating the elements or essential tasks related to “who, what, when where and why” of the plan. The planning team should also describe an end state describes the desired situation that will exist when the operation is successful. Typically, the Federal and/or SLTT senior leadership with “buy-in” from community stakeholders determine the end state. (FEMA, 2014)
Examples of end states for chemical incident remediation may include the following:
· “Contaminated facilities are effectively decontaminated to verified safe levels for reoccupancy, and uncontaminated items not able to be decontaminated are removed as hazardous waste in accordance with Federal and SLTT environmental regulations.”
· “Contaminated materials and equipment, due to unavailability to provide effective decontamination for safe reuse, will be removed and disposed of as hazardous waste in accordance with Federal and SLTT environmental regulations.”
Developing the plan entails a scheme that explains how an operation can be accomplished, and what resources may be required. The purpose of COAs is to provide the Senior Leaders with options, and it is the responsibility of the planning team to develop, evaluate, and recommend viable options. A fully developed COA explains who does what, and when, to achieve the desired outcome. It identifies the resources, capabilities, and information requirements to carry out the strategy. (FEMA, 2014)
Through a comprehensive planning and decision-making process when responding and recovering from a large-scale chemical incident, government, and non-governmental organizations (e.g., civic organizations, private sector) can work collaboratively together with the impacted communities to achieve key tasks that will result in a successful and acceptable remediation. Recovery involving remediation and restoration of affected homes and businesses may still take several months to a few years to fully reach pre-incident conditions, but the challenges likely to be encountered may be efficiently resolved saving time and funds over time. Establishing and sustaining a sound planning and decision-making process described, through planning teams involving key stakeholders at Federal and SLTT levels to include NGO and private sector partners, will increase acceptability levels among citizens willing to reoccupy affected homes and businesses remediated from chemical hazards.
Author: Bio
Mr. Joselito Ignacio is a retired Captain of the U.S. Public Health Service currently serving at the Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA) as the Public Health Advisor within the Chemical, Biological, Radiological and Nuclear Office. He previously served as the Deputy Program Director for Chemical Defense at DHS/Office of Health Affairs (OHA) from June 2010 to December 2014. From November 2000 to June 2010, CAPT (Retired) Ignacio was detailed to the U.S. Coast Guard in an Environmental Health and Industrial Hygiene officer capacity at the former Coast Guard Maintenance and Logistics Command Pacific (MLCPAC) and at Coast Guard Headquarters (CG-1133). He also served in the U.S. Army from 1992 to 2000 as an Environmental Science Officer.
CAPT (Ret.) Ignacio has a Master of Arts in Security Studies at the Naval Postgraduate School in 2011, a Master in Public Health from UCLA in 1991, and a Bachelor of Science in Microbiology with a Chemistry Minor from California State Polytechnic University Pomona (Cal Poly Pomona) in 1989.
CAPT (Ret.) Ignacio is a Certified Industrial Hygienist (CIH), Certified Safety Professional (CSP) and a Registered Environmental Health Specialist (REHS).
