Emergency responders need the ability to quickly identify all potential hazards, then predict the outcome at a hazardous material or weapon of mass destruction (WMD) incident to determine incident objectives, operational modes (defensive, offensive, non-intervention), and strategies. Additionally, the incident action plan (IAP) needs to be within the capabilities and competencies of available personnel and their personal protective equipment. Consider the following questions:
- What level of chemical protective clothing should be worn for a chlorine leak?
- Should a rescue be initiated at a sarin release?
- Which is the greater threat: biological agents or radioactive material?
There are no correct responses to these questions, that is until all the components of the incident have been addressed, then and only then can an IAP be developed. Otherwise, the IAP would be based upon incomplete, possibly faulty information.
The expanding mission for emergency responders drives the need for examining both current and proposed concepts of operations. As well, the development of various tactical and operational procedures to meet the anticipated demands created by a WMD event has distorted the established division between defensive and offensive response operations. The evolving mission for emergency response agencies drives the need for a review of operating guidelines to respond safely and effectively.
Analyze, Plan, Implement & Evaluate Process
The risk-based approach (RBA) is a systematic process. Although not always linear, RBA is a continuous process until termination or transfer of command. The RBA incorporates the NFPA 470 APIE (analyze, plan, implement, and evaluate) process. The APIE process can be integrated with any response model for an all-encompassing assessment to reduce the risk and ensure an effective response.
This action starts with the receipt of the alarm and continues throughout the incident. Although this information is often not complete or accurate, there are usually indicators as to the type of incident (e.g., fire, medical, hazmat, WMD, etc.) and the reliability of the information (e.g., dispatcher reports, smoke, numerous victims complaining difficulty breathing, etc.) While responding, if the officer determines they need additional information, they should request it (e.g., any reports of life safety issues, product or container information, occupancy and location, or other incident-specific information). Upon arrival, the officer is required to establish the Incident Command System and provide a preliminary scene report on the conditions, actions, and needs (CAN report) based on their initial scene assessment.
What will emergency responders do when faced with a low-frequency, high-consequence event? A risk-based approach can help answer this question.
Planning a response involves understanding the nature of an incident and selecting a course of action that will have a positive impact on the outcome, enhancing the likelihood of a safe and effective response. Incident objectives are defined, and the operational mode is selected. Upon arrival, responders should initially take a defensive position until the hazards can be identified, outcomes determined, and a risk-benefit analysis has proven that an offensive mode is appropriate. While there is always a risk when operating in an offensive mode, the 2020 edition of the Department of Transportation’s 2020 Emergency Response Guidebook states:
[T]his type of operation can place the responder at risk of exposure, injury, or death. The incident commander makes the decision to do this only if there is an overriding benefit (for example, to perform an immediate rescue, turn off a valve to control a leak, etc. (P. 360)
Plans should be based on the analysis results of the hazards identified and outcome predicted. Plans should be within the training, resources, and capabilities of personnel on-scene. Planning is not a scripted process that tries to dictate tactics; rather, it should provide a starting point for operations, adjusted as the situation changes and as facts are gathered. The incident commander needs to do the following:
- Determine if the personal protective equipment is appropriate,
- Identify the need for and type of decontamination (e.g., emergency vs. technical, mass casualty, ambulatory, non-ambulatory),
- Establish hazard control zones (e.g., hot, cold, warm, safe refuge area, casualty collection point),
- Identify required resources (e.g., hazmat group, safety officer, rapid intervention team, rehabilitation, EMS, technical rescue; law enforcement for security, perimeter control, crime scene, force protection; city, state, and federal agencies; public and private sectors).
Based on these factors, the incident commander shall develop and communicate the IAP. Ideally, the IAP should be written, even if just with a marker and a whiteboard. This allows for arriving responders to read the plan to catch up, which frees the incident commander’s time of repetitive briefings. It also establishes a timeline.
The third phase in the APIE process is putting the IAP with its specific action plans into effect. At this point, the responder has analyzed the incident to identify the hazards, predict the behavior of the product(s) and container(s), and planned the response. The goal of the implementation phase is to conduct and observe operations and outcomes.
The APIE process is a continuous process that may require adjusting the IAP as conditions change or as new facts and circumstances are identified. The goal of the evaluation phase is to assess operational effectiveness. The evaluation process is always critical. If the objectives and tactics are effective, then continue until termination of the incident or transfer of command. If the incident is escalating, the incident’s objectives and tactics may have to be altered to prevent additional harm to life, property, and the environment. The incident commander will need to provide a status report periodically as per local SOPs.
Termination or Transfer of Command
Termination is the final phase of the APIE process at which operations are concluded or the command is transferred to a responsible party, qualified contractors, or a local, state, or federal agency having jurisdiction. Upon termination, the incident commander must complete the following tasks:
- Assist in the incident debriefing and critique,
- Develop required reports and documentation, and
- Conduct incident debriefing and multi-agency critique if necessary.
The RBA considers all aspects of the incident to identify the hazards and develop the IAP based on the level of training of the responders, the required resources, and their mission. This article provides a guide through the RBA concept, which is rooted in the decades of experience gained from training for and responding to a hazardous material or WMD incident.
The RBA allows responders to break down a complex and potentially overwhelming response into sections to aid decision-making. The six components of the RBA that must be addressed to develop a comprehensive IAP are:
- Product, container, and environment
- Training, resources, and mission
Initially, the responder needs to identify each harm(s) that the product, container, and environment each presents. If responders can identify the hazard(s) or threat(s) and their associated harm, they can then start to take protective actions. There are always several on-scene indicators to use to determine the type of incident (e.g., container shapes and sizes, placards and labels, signs and symptoms, occupancy or location, and intelligence information). The identification of harm is critical to protective action decisions throughout the incident. The value of the RBA is that it is a systematic approach to all phases of an emergency. Every incident is dynamic and a function of all on-scene indicators (product, container, environment) requires the responder to be able to adapt during the ongoing and often unpredictable event.
There are many ways to classify products, but the reality is there are only four types of products we respond to; chemicals, biological agents, radioactive material, and explosive (energetic) materials. In order for the responder to predict the likely behavior of a product related to its container and the environment, they need to first understand the importance of the chemical & physical properties, along with the toxic effect of the product. Fundamentally, products are solids, liquids, and gases. The physical state gives us a place to start the analysis. Understanding chemical, physical, and toxicological properties, the terms used to identify them, and their significance in making decisions, all play a critical role to every level of emergency responder at a hazardous materials or WMD release. At the technician level, this knowledge and ability are necessary for the safety of the emergency responders and the public.
Initially, identifying the basic classification of the container may be all that is required, such as Bulk, Non-Bulk, Pressure, Non-Pressure, or Special. The responder must survey the incident to identify the type(s) of containers involved and determine the potential harm such as, has the product been released or the potential for a catastrophic failure of the container.
Imagine the environment in the broadest sense (e.g., occupancy, location, topography, weather, infrastructure, exposures, and life). A WMD incident should be considered as a type of environment. While the response options at a WMD remain the same, the incident commander will have additional considerations (e.g., active shooter, hostile event [ASHE], InterAgency Board July 2016), and the need for law enforcement, for crime scene, evidence preservation, force protection, etc. In the event the incident has the potential to be a WMD event, the responder must make immediate notifications (e.g., dispatcher, units on scene, and in route).
At this point in the RBA process, the responder needs to identify the hazards and the associated harm(s) that each of the following presents (e.g., thermal, radiation, toxic, corrosive, mechanical). However, for an emergency responder to determine the safest and most effective operational mode, they first need to consider the three main components of the incident: product, container, and environment. The exact order in which they need to be analyzed is based on the component with the most information initially.
The components may present with small parts of information from all three or just one. For example, at some emergencies, responders may see a container prior to identifying the product. By understanding the type of container, the state of matter (in the container and when released) can be recognized. While at another incident, they may have information on the environment prior to the container. As such, and the scene dynamics may progress down the environment path until more information on the container or the product is known. Then and only then can the responder determine the types of harm.
Once the types of harm are identified, the following three factors need to be addressed before developing the IAP: training, resources, and mission. In other words, act within the current training, resources, and mission.
“Do what you can, with what you have, where you are.”
Responders should only operate based upon their level of training. If a responder is a technician but is functioning at the operations level, they need to continue to operate at the operations level because they may not have the necessary resources to operate at the technician level. It is a common understanding in the industry that more lives are saved by firefighters at the operations level because they have the training, and resources (e.g., SFPC, SCBA, medical, water supply for decontamination) to provide protection from most hazards.
Responders should only operate within their level of training and with available resources. It is vital that the incident commander identify and request resources required to meet the needs of the incident. Resources might include hazmat group, safety officer, rapid intervention team, rehabilitation, EMS (BLS and ALS), technical rescue, law enforcement (security, perimeter control, crime scene, forced protection), city, state, and federal agencies, utilities, and public and private sector.
The final factor the responder must address prior to developing the IAP is what is their mission (e.g., life safety operations, public safety sampling, mitigation, etc.). The RBA is a process by which one can establish the appropriate level of response. Managing the incident related to the operational task requires judgment to determine the incident objectives, operational modes, and strategies.
The RBA emphasizes the importance of empowering the responder with the knowledge, skills, and judgment that permits them to adjust as the conditions change or as facts are gathered. Using the APIE process, the responder starts by analyzing an event, using on-scene indicators to identify any potential types of harm, then determining the potential consequences, an “if this, then that” decision-making strategy, helping the decision-maker to pick the best option. At each decision point, the responder determines the appropriate course of action based on the facts, science, and the specific circumstances of the incident.
When combining the complexities of incidents with the pressure on responders to act in certain ways based on their organizational culture, training, and experience, an approach with a clear purpose is more efficient and effective than an approach based on a predetermined assumption that incidents are similar enough to warrant a list of responses. The RBA stresses the importance of empowering the responder with knowledge, skills, and judgment permitting the responders to react to the dynamic nature of incidents.
Given the rarity of real-world experiences with low-frequency, high-consequence type events from which an emergency responder can draw upon, many do not have the experience base to rely upon in evaluating these complex problems and determining initial actions. As a result, there is a greater probability of responders being overwhelmed, increasing the risks to both responders and civilians. Scenario-based training using simulations (e.g., gaming, virtual reality, augmented reality) is a solution to the lack of real-world experience. Scenario-based training for an emergency response to a WMD may benefit responders by applying a blend of situational awareness with clear decision points. It is much less costly than drills and exercises conducted in the field and easier to involve more participants.
Given virtual training scenarios that reflect incident experience at low-frequency, high-consequence scenarios, participants virtually walk through these scenarios in real-time, with a real-world perspective. These virtual simulations allow responders to practice decision-making in simulated emergencies (e.g., mass casualty events, WMD, etc.), thereby providing experiences that can then be used to prepare for future situations. The simulation should be appropriate for individual or group training to present unique problem-solving and critical-thinking exercises. It is the next best thing to being in a live scenario. In some cases, it is even better, as there is no danger and risk involved to responders.
Accepting tolerances in emergency management helps reduce friction and factions, creating a more collaborative environment. Identifying risks and hazards more openly rather than just creating an exclusionary mindset of zero tolerance should drive policy. Comparative analysis, data collection, operational orders, and mitigation tasks must be realistic and attainable to determine what is causing the parts not to match up and find out what works together. Without this type of tolerance, issues become bound up and create heated friction. This was seen repeatedly throughout the COVID-19 pandemic.
One cannot solve complex issues with the demand to “make the solution fit the problem,” and punitive actions rarely offer longstanding solutions. Merriam Webster defines zero tolerance as “a policy of giving the most severe punishment possible to every person who commits a crime or breaks a rule.” Although emergency response should never be punitive, one 2022 study found that the global lockdowns and mandates used to reduce COVID-19 mortality rates had a punitive effect. Attempting to maintain societal norms by forcing an ideal that cannot be collaborative, compassionate, or collectively for the good of the whole of society will likely fail and possibly create a never-ending cycle of failures.
Changing the Narrative
Imagine removing zero tolerance from the discussion and coordinating the emergency management phases on the foundation of tolerance to see how close all the players can work together. Considering society has been faced with an emergency that has killed many people, events must be handled better. Take the challenge to use creative and critical thinking skills to progress through a problem and hone professional tolerances:
Do not use demanding, punitive language to define a way through a problem or emergency.
When planning, exercising, responding, or mitigating, reframe incident thinking, communicate, promote unity, and drive toward resilience rather than resistance. The development of community lifelines and their guiding principles to collaborate all the pieces will win hearts and minds.
Decentralize old emergency management programming and create a new positive equilibrium of agencies with relevant partners and stakeholders.
Visualize the exercise and discuss the intended consequences ensuring that the components are not relying on zero tolerances.
Welcome legitimate opinions then discuss, debate, and decide promptly using tolerances that may elicit better decision-making.
Remove dissension, debunking, and discrediting efforts in professional narratives.
Challenge the team to prove an idea through tolerances. What the conversation reveals may be surprising. Try to provide at least three reasons why it will work and support it by citing meaningful research.
Overcommunicate. Recognizing that communication is often a problem during incidents, define objectives succinctly and communicate them repeatedly. The cadence of the incident will be disrupted or derailed by zero-tolerance policies; remove them. With discretion and tolerance, the resolution will be closer than imagined.
Improving the future requires working together and understanding tolerances to build capability and acceptance of core principles.
Tony Mussorfiti was a member of the Fire Department of New York (FDNY) from 1988 to 2010. During his tenure, he served as a firefighter, lieutenant, a hazardous materials technician specialist and a hazardous materials instructor. Along with Battalion Chief Robert Ingram, he established the FDNY Hazardous Materials Technician Training School and emergency response programs specific to terrorist incidents involving hazardous materials and weapons of mass destruction. The school has trained more than 10,000 members of the FDNY. He was assigned to the FDNY Center for Terrorism and Domestic Preparedness, where he was involved with the development of response protocols and drills and exercises for terrorist incidents. Since 2006, he represented the fire department and the city as a member or chairperson on the following working groups: NFPA 475; NFPA 470; and ASTM-E2601. Since 2003, he has been a member of the Inter-Agency Board (IAB) Training and Exercise Sub-Group. Additionally, he has been involved with the Federal Bureau of Investigation’s Hazardous Materials Training and International Counter-proliferation Program in the former Soviet Union since its inception. He has been a technical adviser to Combating Terrorism Technical Support Office/Technical Support Working Group, in the development of training simulation programs for emergency responders to prepare for terrorist incidents.