CBRNE & NIMS: Complementary, Not Contradictory

Some critics of the U.S. National Incident Management System (NIMS) have cited a wide variety of examples to justify their claims that the NIMS policy guidelines will not fully and/or effectively serve the nation’s needs in managing future emergency-response situations. In 2010, for example, when the Deepwater Horizon drilling rig in the Gulf of Mexico exploded and began the uncontrolled release of millions of barrels of oil into the local waters, some of those same critics used the incident to validate their claims that the management of such major incidents is beyond the scope of the NIMS guidelines. It seemed obvious at that time, however, that state and local governments were unable, even with help from the private business sector, to cooperate and collaborate effectively enough to stop the release through a unified-command organizational structure.

The critics further argued, though, that the Deepwater Horizon incident was simply another example – similar to the failures of the 2005 post-Katrina response efforts – of the NIMS being flawed both in concept and in application. Some critics even predicted that if the United States were to experience a significant CBRNE (Chemical, Biological, Radiological, Nuclear, or High-Yield Explosive) incident, the NIMS policies would not be capable of meeting the formidable operational challenges that would immediately follow.

Fortunately, although there have been a number of other potential CBRNE incidents since Hurricane Katrina – including several attempted or at least planned terrorist attacks – and other mass-casualty situations, the core NIMS concepts and precepts still seem both sound and productive.

The Implementation of Presidential Directives

The NIMS policy guidelines were established by the issuance in February 2003, by then President George W. Bush, of Homeland Security Presidential Directive-5 (HSPD-5), “Management of Domestic Incidents.” In December 2003, it was incorporated with a National Preparedness Goal that was also issued by President Bush under Homeland Security Presidential Directive-8 (HSPD-8), “National Preparedness.”

In March 2011, President Barack Obama issued Presidential Policy Directive-8 (PPD-8) to further describe “the nation’s approach to preparing for the threats and hazards that pose the greatest risk to the security of the United States.” When used conjunctively, these directives provide the current framework of the policies now in place to guide the nation’s efforts to prevent, protect against, mitigate the effects of, respond to, and recover from virtually any major threat against the United States, including CBRNE incidents.

In May 2010, when Faisal Shahzad, a Pakistani American, attempted to bomb the Times Square area of New York City with a sport utility vehicle loaded with propane cylinders, gasoline containers, and an improvised explosive device (IED), the first emergency call came from a street vendor who had noticed that the vehicle was smoking and emitting sparks. The initial presumption was that there might be a vehicle fire in the making.

The New York City Fire Department (FDNY) was the first agency on the scene. Upon arrival, the FDNY incident commander – who was trained to identify potential dangers not immediately visible to a civilian – immediately implemented a number of actions to protect not only the FDNY personnel but also the public at large. Among the most important of those actions was a decision to isolate and secure the area, while also calling for the New York City Police Department (NYPD) bomb squad to investigate the situation and take whatever additional steps might be needed to secure the area.

The actions taken by the responders are excellent examples of how the core NIMS precepts are intended to work. The FDNY officials not only communicated their observations appropriately but also mobilized the additional resources needed to manage the situation. As this example demonstrates, the management of such incidents or events, rather than the tactical operations that follow, is the primary intent of the NIMS policy.

The core components of NIMS include the following: (a) Preparedness (the training needed both to recognize potential threats and to initiate appropriate actions); (b) Resource Management (identifying, inventorying, and mobilizing the appropriate personnel and material resources needed); (c) Communications and Information Management (the effective communication and management of the information needed not only by responders and incident commanders but also by the media and general public); (d) Command and Management (coordination of the unified command and multi-agency operations required under ICS (Incident Command System) guidelines; and (e) On-Going Management and Maintenance. These five major goals are the fundamental elements essential for effectively managing any challenge, from any cause, anywhere.

A Key Resource: The U.S. National Guard

In assessing whether the NIMS is applicable to CBRNE scenarios, it is important to first determine what resources are likely to be readily available for use in confronting and managing CBRNE emergencies. Fortunately, a primary resource that is immediately available within each state is the National Guard, which provides operational support in the form of a Civil Support Team (CST) and/or a CBRNE Enhanced Response Force Package (CERFP) – either or both of which can be mobilized within hours following an official request through the appropriate state channels.

The composition of the nearest/most immediately available CST and/or CERFP may differ slightly from one state to another. However, the core composition of a CST is typically about 20 full-time National Guard and other personnel who have been highly trained to the HazMat Technician level, at a minimum. The CST is equipped for rapid mobility and carries state-of-the-art systems and other equipment needed to assist in the detection and threat assessment aspects of CBRNE situations.

The typical CERFP, on the other hand, which can provide more than just CBRNE operational assistance, is composed of a larger number of personnel trained and prepared to provide what is officially described as “Defense Support to Civil Authorities” (DSCA). The CERFP resources are primarily intended, in accordance with federal National Guard Bureau policies, to provide direct support to local and state emergency-responder agencies and organizations.

In order to meet these responsibilities and acknowledge the commitment of state and local emergency response resources to conform to the NIMS policy and operational tenets, the National Guard Bureau issued a policy in 2004 that all state National Guard units will be “NIMS Compliant.” To meet that goal, these units have been aggressively training to facilitate the effective integration of National Guard resources with those available to state and local emergency response units. For example, by working in close cooperation with the Virginia Department of Fire Programs and Department of Emergency Management, Virginia’s Guard personnel have received, at the minimum, the Introduction to NIMS (IS-700) training required and the core ICS training (ICS-100 and ICS-200). In addition, the Virginia Guard’s officers and supervisors have also received Intermediate ICS (ICS-300) training, and commanding officers have received Advanced ICS (ICS-400) training as well.

In most operational situations, local emergency management services, fire, law enforcement, and/or other emergency responders will have been at the incident scene – and conducting some type of operations – prior to the arrival of the first CST or CERFP units. For that reason, it should be emphasized that an important principle of the National Guard philosophy is that the Guard will provide support to civil authorities within the ICS framework rather than simply assuming command of operations involving CBRNE threats. According to Lieutenant Colonel William Patton, Commander of the Virginia Guard’s 34th Civil Support Team, “CBRNE incidents are well within the All-Hazards approach [as defined in the NIMS].” It is in that context, he added, that “We work for the police, fire, or other incident commander when we [the Guard units] are tasked to respond to a local incident.”

Operational, Supervisory & Technical “Backup”

Whether in a weapons context, a terrorist scenario, or simply an accident involving a hazardous commodity or product, CBRNE materials remain, first and foremost, hazardous materials. As Major Shawn Talmadge, Chief of Current Operations at the Virginia National Guard’s Joint Operations Center, described it: “Our approach to the management of incidents involving weaponized agents is similar to … [the approaches typically] used in traditional hazardous materials responses.”

Moreover, although a CBRNE response is almost automatically considered to be a unique security threat, management of the tactics, personnel, and resources is fundamentally the same as dealing with “routine” incidents. What this means, essentially, is that incident command will involve: (a) the designation of the same command and general staff (as necessary under the circumstances); and (b) the assignment of appropriate supervision for the tactical resources required.

The bottom line is that today’s National Guard personnel are trained, equipped, and philosophically prepared to support the incident commander as needed in either an operational or supervisory capacity. Typically, CST or CERFP resources arrive on-scene fully prepared to function in an operational capacity. However, they also can be assigned as technical specialists for planning activities, or even for intelligence gathering and investigations.

Moreover, because National Guard personnel also bring with them their individual “day-job” capabilities, they may have expertise in such fields as logistics, finance and administration, and/or planning, and therefore can augment local personnel in these functions when needed. In Talmadge’s words, National Guard personnel can be considered “another asset on call.” In that context, National Guard personnel can serve as a unique value-added resource pool that is ready and able to augment the local resource inventory. By functioning within the framework provided by NIMS, the National Guard units, and individual members, can integrate themselves more readily into the overall response effort.

Incidents involving CBRNE materials generally cannot be considered “ordinary” events or everyday risks. Although local emergency response resources may be prepared to confront and resolve many incidents using local resources, CBRNE incidents of any type or magnitude present unusual challenges that may require integration and coordination with other more highly specialized resources such as a CST or CERFP. The NIMS guidelines provide an operational template by which additional and sometimes uniquely specialized resources can be made available to support the response effort.

As proponents and practitioners of the NIMS and the ICS philosophies, National Guard members are another valuable asset already available and well prepared to integrate its capabilities to support the nation’s overall efforts to prevent, protect against, mitigate, respond to, and recover from a CBRNE threat. Despite criticisms leveled at the NIMS, the doctrine’s core concepts still provide a comprehensive and well-articulated “roadmap” to available resources, which can be used effectively to meet the unique challenges facing “National Preparedness” and “Management of Domestic Incidents.”

Stephen Grainer

Stephen Grainer is the chief of IMS programs for the Virginia Department of Fire Programs (VDFP). He has served in Virginia fire and emergency services and emergency management coordination programs since 1972 – in assignments ranging from firefighter to chief officer. He also has been a curriculum developer, content evaluator, and instructor, and currently is developing and managing the VDFP programs needed to enable emergency responders and others to meet the National Incident Management System compliance requirements established by the federal government. From 2010 to 2012, he served as president of the All-Hazards Incident Management Teams Association.



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