RESOLVE

Chemical Emergencies

The Chemical Emergencies work group is focused on preventing, preparing for, responding to, and recovering from acute chemical incidents. To review the group’s membership, charge, and past meeting summaries, visit the National Conversationwork group page.

Next Steps
The National Conversation Council will consider public input received through web dialogues and public comment in revising the Action Agenda in the early spring 2011. Work group reports will be appended to the action agenda.

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30 Comments

  1. David Klein

    Texas Department of State Health Services

    Dear National Conversation,

    I have read the draft report on Chemical Emergencies. Following the Deep Horizons Oil Release, it seems this group did nothing to address chemical exposure. The same environmental measures were addressed but one basic problem is measuring acute chemical exposure.

    This can be done by analyzing blood samples for the chemical or urine samples for the metabolite. The Deep Horizons explosion saw not one person who was screened for chemicals in their blood or urine.

    The technology is there and we have methods from the CDC to do so. An imperative national priority is to develop acute exposure monitoring in conjunction with the Poison Control Centers and the American College of Emergency Physicians.

    Respectfully,

    David M. Klein, Ph.D.

    Chemical Threat Laboratory Leader, Laboratory Response Network-Chemical

    Texas Department of State Health Services

  2. Mark Fountain

    Scientist

    You do not use the words blood, urine, or samples anywhere in the report. Unless samples are taken how can any monitoring be performed? A company having a chemical spill incident may not be collecting samples to detect exposure, for which they may be prosecuted. How, procedurally are you going to obtain actual data describing background levels and detailing human exposure? Detecting environmental presence (requiring samples?) may be legally and factually different from determining presence within a human, different from causally linking the two, for describing as chemical exposure.

    Recommend setting up a baseline background chemical level database and detailing how to collect additional smples.

  3. Frederic Pfaender

    UNC Chapel Hill SRP

    This report is a comprehensive look at the problems and strong recommendations for action. With the exception of Recommendations 10 and 11 most require federal government legislation and funding. While well founded and reasoned in the document most of this is unlikely in the current political climate. This is especially true in a time of fiscal instability. It would be useful to have some recommendations that can be addressed with current resources, both fiscal and human. Training is one possibility as is coordination, at least at some levels. It would strengthen the document to have some steps that can begin at once and without additional funding.

  4. Eileen Senn

    Independent Industrial Hygiene Consultant

    In your view, what are the most important recommendations put forward by the work group?
    Recommendations 1, 5, 6, and 8

    Do you have suggestions for strengthening the report or any of the recommendations?
    Cleanup worker protection from chemical hazards during emergencies should be better addressed in the report and recommendations.

    I disagree with recommendation #10 because PELs perpetuate a deeply flawed approach to controlling chemical exposures whereby OSHA cannot require administrative or engineering controls, respirators, or medical surveillance unless the agency collects air samples that prove that employee exposures exceed a PEL. Invariably, exposures are in compliance with current standards, in spite of significant symptoms and concerns experienced by workers. Air sampling then becomes an extra obstacle in the struggle to reduce exposures and health problems. This occurred in the Gulf cleanup. Opportunities to prevent cleanup worker exposures were missed because of reliance on and misinterpretation of air sampling data as a Clean Bill of Health. In addition, many resources are used to conduct sampling that might have been better used to visually assess worker’s exposures and recommend control measures.

    Instead, respirators and other personal protective equipment are at the bottom of the Hierarchy of Controls* in fixed workplaces but must move up to the top during chemical emergencies when most exposures are uncharacterized, variable, and short-term. Manufacturers should be encouraged to produce Innovative types of respirators for chemical emergency cleanup. These respirators should be lightweight, disposable, and provide protection from a wide variety of chemicals, including organic vapors, acid gases, and particulates.

    Substance by substance air sampling is not an adequate approach to assessing airborne exposures to complex mixtures of chemicals during chemical emergencies. Instead, a team of experts should describe typical and worst exposures for typical cleanup tasks being performed. Exposure assessments should be narratives informed by numbers, not just numbers.

    The narratives would include the chemicals and their hazards; typical activities performed by workers and the typical machinery, equipment, and tools used; activities that may cause chemicals to become airborne near employees; activities that may cause chemicals to contact employees’ eyes, skin, hair, gloves, shoes, or clothing; and measures being taken to reduce exposures, including personal protective equipment.

    OSHA has created an OSHA Personal Protective Equipment Sampling Matrix
    http://www.osha.gov/oilspills/oil_ppematrix.html with recommended personal protective equipment (PPE) for sixteen job tasks in the Gulf cleanup. This sensible approach should be extended to a wider variety of tasks and to worker protection with respiratory protective equipment.

    * The hierarchy of controls is a list of steps that employers must take to prevent or reduce exposure to a hazard, ranked from best to worst in terms of effectiveness. It starts with substituting a safer material, machine, or process; followed by engineering controls like mechanization, enclosure, and ventilation; followed by administrative controls like limiting exposure time and distance, housekeeping, hygiene facilities, medical surveillance and air monitoring; ending with personal protective equipment like hearing protection, respirators, gloves, goggles, and clothing.

  5. Preston Twyman

    Thanks to all who participated in this massive and worthy document. I kept looking for loopholds that weren’t addressed, however I did’nt find any. My single recommendation, is that it be a criminal offense for any employee or appointee of government, to knowingly attempt to undermind the mission of this progam; by understaffing an agency; defunding in order to limit effectiveness; utilizing political appontees or others to gut or otherwise make ineffective the program.

  6. Cheryl Wittman

    Recommendation #1 is great and needs to come to fruition!!

  7. Linda Kilgore

    concerned citizen

    I feel recommendation # 1 is outstanding and is most important..

  8. Stehanie Holland

    I think recommendation #1 is outstanding!!

  9. Nancy Wood

    I totally support Recommendation 1

  10. Lori Wilke

    Recomendation #1 should be implemented.

  11. Lucy Hindman

    Please vote, YES, for Recommendation #1

    We need to expand Poison Control to be able to handle toxic events that happen in our communities all over the Country. I live in the community of “Fife” which is in Fairburn, Georgia. What happened in our community should never have happened. What is so hard to understand, living in the United States of America, is that we had to convience the local agencies that there was indeed a problem and that people were really sick. Even the doctors didn’t know what to say about what we were telling them. This poison pesticide chemical that was released in the air in 2006 by the PSC Plant down the road from our house, was the beginning of a nightmare for all of us. Connie Biemiller Thomas has a voice that speaks volumes of what happened and the changes that need to me made. I watched my sister-in-law, Clare Hindman, lose her battle from symptons of ALS brought on by this pesticide poison. Clare should still be with us enjoying her retirement and her family. All of us that were exposed to this poison are not even sure of health issues in our future that might come up as a result of this incident. The health department is not following any of us. In fact, we had to fight to even get anyone to believe there was a problem. Who is looking out for the people of this Country?

  12. Venetta Thomas

    It is a MUST that Recommendation #1 be adopted. In 2006, toxic waste sickened many people in my community and actually killed several. Government agencies had no idea how to test, what to test for, or how to give medical treatment to our community. This can not be allowed to happen again.

  13. Don Hindman

    I do agree that Recommendation #1 should be adopted. I also was a victim of the 2006 pesticide poisoning in the community of “Fife”, Fairburn, Georgia. Over a 1,000 people were ill from this poisoning and we still had to beg for help. The help really never came. It is time for the government to step up and take care of its citizens instead of siding with big corporations. We personally lost a family member who became ill from exposure to this pesticide poison from the PSC Plant located a half mile from our home.

  14. Greg Fleeger

    The first few recomendations are costly and add even more layers to our federal government. In particular the recomendation to mandate changes in manufacturing processes. This idea has failed in both the US House and Senate, only organized labor supports this notion which would simply hand all economic advantage for US based business to China, Latin America, etc. This recomendation is bad policy and bad politics (not even Congress supports it) and it should be removed. Anytime you mandate a new law you are increasing the cost and size of our government. To include such an unpopular suggestion places a negative light over the entire report and makes one wonder just who took part in coming up with such an idea and the entire report in which it appears.

    The last few recomendations are more on target, increased and standardized training for all those involved is vital and long overdue, kudos to whoever came up with that idea as it is exactly what we need to prepare EMS and others to respond to chemical emergencies. I also highly commend those who recommend updates to WISER, as someone familar with all the various programs available, WISER is by far the best and most widely used. Also this recomendation hit another important point, multiple sources of fragmented information. The recommendation to pull it all together in one working tool is well worth supporting.

  15. Ernest Grolimund

    Coalition Against Wood Burning, Residents Against Wood Smoke Emmissons of Particulates

    Emergency!!! 180 toxic chemicals are being released into the air all over the country from woodburning. 80 mcg/m3 pm2.5 with 180 air toxics and chemicals encapsulated in the pm and in gases released with the pm. Dioxin, acrolein, formeldehyde, 32 Volatile aromatic hydrocarbons, carbon black soot, organic soot. 80 mcg/m3 pm2.5 from an old stove heating a house in design calm wind inversions which are common. Maine DEP-EPA modeling. EPA checked inputs. Conc checked bu monitoring by EPA, others. 30% of population affected. New safe dose for woodsmoke pm at 1/8 the dose for ambiant pm from mixed sources. EPA exposure scientist says the peer reviewed dose for wood smoke pm should be considered in wood smoke health nuisance court cases. 108 mcg/m3,hrs not 840 mcg/m3,hrs from ambiant pm. Ambiant pm std is not apllicable. Wood smoke is 12 times more carcinogenic than tobacco smoke. It is more toxic than ambiant pm. But it is violating even 24 hr ambiant pm stds.

    Cities are being photographed engulfed in wood smoke. The EPA says it cannot regulate indoor air or it says the problem is local. The local and state governments say they can’t or won’t handle it. Everyone brushes people off trying to deal with this and the result is cities engulfed in wood smoke, and millions of dangerous hotspots. EPA says it cannot lobby congress but it can inform them of an air pollution disaster or emegency but it is not doing that. They I canot declare such an emergency. Congress or the President has to. But the president cannot be reached. The ATSDR has modeling capabilities but says it is not our jurisdiction. Everyone tries hard not to do anything to save a little, but it winds up costing the public $150billion/year. A disaster is happening and the EPA is powerless to act or won’t and the same thing is happening with the ATSDR and Consumer Product Safety Commission.

    These bureaucratic problems have to solved as a management problem in the ATSDR, CDC, and the entire federal government. hundreds of millions are being exposed to the largest cumalative source of toxic chemicals in the country from wood smoke. Toxic chemicals do not come from just chemical plants.

    This is a national toxic emergency!!!

  16. Christine Grem

    It is a chemical emergency when newborns cord blood is contaminated with more than 200 toxins

    read the Pediatrics journal study 2010.

    Does the government have to be sued to uphold responsibility?

    Ban all pesticides and chemical treatments on farms, lawns, and golf courses now.

  17. Barbara Warren

    Citizens' Environmental Coalition

    Please see attached comments.
    [file]http://resolv.org/site-nationalconversation/files/2011/02/Chemical Emergencies Workgroup Comments.doc[/file]

  18. Katie Weisman

    Coalition for SafeMinds

    The Coalition for SafeMinds was founded to raise awareness, support research, change policy and focus national attention on the growing evidence of a link between mercury and neurological disorders such as autism, attention deficit disorder, language delay and learning difficulties. Our mission is to restore health and protect future generations by eradicating the devastation of autism and associated health disorders induced by mercury and other man made toxicants.

    In reading this draft report, and while recognizing that it is geared to crisis situations, SafeMinds would suggest including a further scenario to improve preparedness. In both of the worst recorded cases of mercury poisoning in specific populations, the exposure was through ingestion of mercury, In Iraq, the population was poisoned by consumption of feed grain that had been treated with a mercury fungicide which had been intended for planting, not direct consumption. In Minimata, Japan, the Chisso chemical factory’s ongoing dumping of mercury into the nearby bay contaminated the fish that the local population consumed. Apropos to the Gulf Oil Spill, oil contains low levels of mercury and there is the possibility that after the immediate effects of the spill are dealt with, there may be ongoing mercury contamination of the local seafood. We would recommend that you include the possibility of food contamination with a chemical in your plan and make allowances for coordination with the FDA and CDC food safety systems, which currently deal primarily with pathogens, in the event that a recall was needed.

    Thank you for the opportunity to comment on the draft report.

    Sincerely,
    Katie Weisman
    Coalition for SafeMinds, Environmental Committee

  19. Michael E. Bailey

    People First, California, Orange County Chapter

    This is a critically important draft report. Of special importance are the issues of barriers to good emergency response and the importance of the 11 recommenations that have been made.

    A major problem is inefficient communication among those agencies that would be called on to respond to a chemical emergency. Not only the technical issues involved concerning different radio frequencies and age and capabilities of communications equipment between responding agencies, but also the fact that too often officials who need to work together in an emergency response like to stay in their individual silos until the time comes when they need to come together and work together which can make organizational communication between agencies alot harder. One agency set up specifically to coordinate communications in a chemical emergency and to promote communications technical and administrative improvements is a great idea and a badly needed one. It is also worth noting that it would be of great importance especially to the disability community and seniors to be able to have automatic notification by phone message of an emergency and have evacuation routes and shelter locations included in the message. This type of emergency notification is provided in a number of urban areas today but is not available in many rural areas.

    Planning for chemical emergency response is another area that needs improving. The idea that local and state emergency planners should strongly be asked to take into account the importance of other organizations in helping deal with emergency planning and response is a great idea, too. Many counties have a disabled community, a senior community, and a community of those who do not have English as their primary language. Emergency planning for chemical response needs to consider the needs of such persons for emergency evacuationplans and sheltering. Members of the disabled community and the senoir community should be active participants in the emergency planning process to make sure that specific health and communications needs are addressed in the emergency planning process.

    Prevention of chemical accidents will require stronger regulation, changes to state and federal law, and the participation of Federal DoT Research Centers at colleges and universities. Research Centers like the Volpe Institute are very important to this effort because the research work in designing and testing various materials and technologies to make railroad tank cars and highway tank trailers more sturdy and less combustable. Regulations and laws need to be stronger as well. There are regulations now on natural gas and crude oil pipelinfe safety But we have recently had a major oil leak from an oil pipeline and a Pacific Gas and Electric Company gas supply line blew up only about two weeks ago killing seven people and leveling a whole neighborhood in the town of San Bruno. The utility asked the PUC for funding to make the pipeline safe since it was one of the top 100 unsafe lines in the state and country but after funding was given, the utility decided to use it for what it called “:other purposes” instead.

    And training of fire fighters and other specialists that will respond to chemical emergencies always needs to be kept current and updated; and refresher training needs to be provided on a regular basis. Maybe what is needed is the creation of a special agency to develop and coordinate the training that is needed, do research on the type of training that will work best, and possibly offer 2 or 4 year college degree equivalants to fire fighters and others to ensure they are well trained and schooled in the critical area of emergency chemical response.

    Thank you.

    Michael E. Bailey, People First, California, Orange County Chapter, 25801 Marguerite Parkway, No. 103, Mission Viejo, CA 92692.

  20. Nsedu Witherspoon

    Children's Environmental Health Network

    In general, this work group report needs to make an explicit priority of protecting children and other vulnerable populations. The report does not currently recognize children’s unique vulnerabilities and exposures, including that children cannot identify risks, remove themselves from harm, describe exposures or events, or link symptoms to exposures. Protecting and caring for children is different than protecting and caring for adults.

    Thus, first responders, first receivers and emergency planners need guidance and training to understand how to protect children in emergencies and to explicitly plan on how they will do so. For example, public health advisories should be issued on preventing children’s exposures and providing examples of children’s symptoms from exposure to toxicants.

    In an emergency, children may be in specific locations — child care centers and schools — apart from their families. Planners and responders must prepare for this. When an emergency occurs, chaos can result as parents seek to reunite with their children in schools and child care centers. Just as caregivers and school personnel need policies for handling such emergency events, emergency planners need to consider this aspect in their planning.

    Similarly, steps to protect first responders, first receivers and others responding to emergencies should also consider the health of their families, because children are affected by their parents’ “workplace” exposures (not just take-home, but also fetal and preconception exposures).

    Post-emergency policies and planning must consider children’s unique susceptibilities and vulnerabilities, such as explicitly requiring child-safe remediation of homes, schools, child care settings, and playgrounds.

    An important resource for protecting children is Executive Order 13045 on children’s environmental health and safety and the interagency task force it created.

    Specific comments:

    *Recommendation 2, (p. 18), states that “relevant funding announcements [should] include language strongly encouraging the development of partnerships with non-governmental organizations (NGOs) and community-based organizations, academia, labor unions, and industry.” The Network urges that this phrase be changed to read: “relevant funding announcements [should] include language requiring the development of partnerships with non-governmental organizations (NGOs) and community-based organizations, academia, labor unions, and industry.”

    *The definition used in the report for “a vulnerable population” (p. 6) “includes those with functional or developmental needs, disabilities, and activity limitations (FEMA, 2010). It also includes those who are made vulnerable by their financial circumstances or place of residence, health, age, personal characteristics, ability to communicate effectively, and presence of chronic illness (President’s Advisory Commission, 1998).” It does not explicitly mention children; it should.

    *On p. 7, we urge that this paragraph also call for awareness and training on the protection, diagnosis and treatment of vulnerable subpopulations, such as children, the elderly, and the immune compromised:
    “Hospitals currently plan and train for mass casualty events and need to be included in chemical emergency planning within their communities. Communication between first responders and health care providers needs to be strengthened so they receive adequate warning of chemical emergencies to prepare for the potential decontamination, triage, or treatment of incoming patients. Emergency Department staff as well as clinic and all hospital staff should have a level of chemical hazard awareness, with some key designated personnel receiving training to the operational level to facilitate safe and effective response and treatment.”

    *The Network urges that the discussion of risk assessment on p. 12 provide expanded guidance on the limitations, appropriate use, and alternatives to risk assessment. The paragraph currently reads:

    “Risk Assessment data can inform policy makers and planners regarding prioritization of funds, focus of training, research. Only by assuring a scientifically rigorously risk assessment process and education of policy and decision-makers regarding the use of risk assessments (making decisions with uncertainty) will risk assessments play an important role.”

    This paragraph should be expanded to include:
    “Unfortunately, the limitations of risk assessment are not transparent to the public and, often, to decision makers. The limitations as well as the benefits of risk assessment must be recognized. We must both make improvements to the risk assessment process, improving its transparency and using it appropriately, while also moving toward a more precautionary approach.”

    Additionally, we urge deleting the phrase “(making decisions with uncertainty).”

    *The Network agrees that prevention of emergencies should be the initial focus, as outlined in the vision statement (p. 13). In addition, the Network would provide more emphasis on the importance of community right to know. A valuable resource on this concept is the APHA resolution 2002-5, “Preserving Right-To-Know Information and Encouraging Hazard Reduction to Reduce the Risk of Exposure to Toxic Substances.” As this resolution notes, worker and community right-to-know is “an essential information tool for public health and safety improvements and affirms that information about hazardous conditions allows individual citizens as well as their elected representatives to make informed choices about their own and their community’s health and safety and improves the prevention, recognition and treatment of conditions related to environmental exposures.” And that “right-to-know about chemicals in one’s neighborhood or work-place or near one’s child’s school is not only an important right in our democracy but a vital component of public health. . ..”

    *On p. 13, the Network recommends changing this sentence:

    “Programs should assure the security of dangerous chemicals during manufacturing, storage, transport and use, preventing accidental or intentional releases.”
    To:
    “Programs should assure the security of dangerous chemicals during their lifecycle, including manufacturing, storage, transport, use and disposal, preventing accidental or intentional releases.”

    *On p. 16, the report states:
    “For example, another key lesson learned from the Gulf oil spill is that the responsible party should establish, in conjunction with the Incident Commander, a comprehensive injury and illness reporting system to ensure full reporting of ALL safety and health related issues experienced by clean-up workers.”

    Network urges that health tracking be required for ALL individuals in affected communities, to include but not limited to clean up workers and their families.

  21. Diane VanDe Hei

    Association of Metropolitan Water Agencies

    Attached please find comments from the Association of Metropolitan Water Agencies. Thank you for the opportunity to comment.
    File: AMWA_NationalConversation_chemicalsafetycomments.pdf

  22. Laurie Miller

    American Chemistry Council

    Dear Sir or Madam:

    The National Conversation’s draft workgroup recommendations represent a good first step in increasing the dialog with the public health community about the important issue of public health and chemical exposures. The diversity of topics covered in the Conversation is extensive. Work Group members should be commended for expending so much time and effort addressing issues ranging from regulation of chemicals in commerce under the Toxic Substances Control Act to assessment of Superfund sites, consideration of environmental justice concerns, and chemical security issues.

    That said, ACC was disappointed with many of the process aspects of the National Conversation. It was never exactly clear for whom the recommendations were being developed, and for what purpose. It was never clear how the Leadership Council was supposed to treat the recommendations of the work groups. In retrospect, we think the National Conversation would have been more productive if it had been organized as a Federal Advisory Committee because that format would have provided greater discipline to the process. The process issues made it difficult for our organization to contribute to the Conversation in a comprehensive way.

    In addition, some of the specific draft action recommendations of the work groups reveal major gaps in understanding what information is already available on chemicals today, how chemicals are regulated and managed under a myriad of federal and state laws, the science of risk assessment and toxicology, the complexity of the chemical value chain, and the practical considerations that must be taken into account when regulating chemicals in commerce. ACC supports modernization of the Toxics Substances Control Act (TSCA). As we are certain the Working Groups understand, TSCA is a very complex issue and modernizing the statute is not a simple prospect. Not all of the recommendations of the work groups relate to TSCA modifications, but several reflect a basic lack of understanding of many of the complexities of chemical regulation. These comments do not address every recommendation, but our comments focus on ACC’s broader concerns about some of the work groups’ recommendations. The comments that follow focus on the Chemical Emergencies Work Group’s draft report.

    Comments on the Chemical Emergencies Work Group Recommendations:

    ACC agrees with the themes that the Chemical Emergencies Work Group chose to create their recommendations: prevention, planning, comprehensive training, and coordination and integration. We believe that the Work Group could greatly strengthen its report by enhancing the context around the theme of prevention, thereby broadening the array of tools that are available and used by chemical facilities to prevent chemical emergencies.

    The report emphasizes the use of safer chemicals and technologies under the theme of prevention. Although ACC member companies generally support this concept, execution is not as simplistic or as straight forward as the report suggests. To the contrary, identifying safer chemicals and/or technologies involves comprehensive evaluation, including evaluation of risk tradeoffs. Each facility is unique in the chemicals it produces, how these chemicals are produced, handled and stored, and in its community setting. Risk-based evaluation of a chemical process for a potential modification to improve its inherent safety (or an “inherently safer technology (IST)) involves evaluating the modification for its potential effect on the integrity of the chemical product or process and for its own set of potential risks to the public or the environment. The economic feasibility of modification also requires consideration. Evaluation of one or more of these factors may indicate that the modification would not significantly reduce risk, may shift significant risk elsewhere and/or be technologically or economically infeasible. Even substitution of one chemical for another that may be considered a safer alternative, once thoroughly analyzed in the context of the process in which it will be applied may not adequately address risk or be feasible.

    ACC strongly recommends that the Work Group review DHS’ recently published report, Final Report: Definition for Inherently Safer Technology in Production, Transportation, Storage, and Use (http://www.aiche.org/uploadedFiles/CCPS/Resources/KnowledgeBase/IST%20Final%20Definition%20Report.pdf). In addition, the Center for Chemical Process Safety (CCPS) has published its second edition of “Inherently Safer Chemical Processes: A Life Cycle Approach” (Ref 1), which contains a wealth of information and numerous pages of references regarding all aspects of inherent safety (IS). These work products were developed by stakeholders with a variety of backgrounds, including government, industry and academia. We believe that this information would help the Work Group frame the concept of “safer” within the report. It would also point to the other tools that chemical facilities use to reduce safety and security risks. In addition, these sources would frame the concepts of “inherently safer” and “inherently safer technology,” which are concepts either directly or indirectly discussed in the report.

    By definition, IS concepts are consequence-based. That is, IS techniques apply only to the magnitude of the outcome of an event, not to its probability of occurrence. Thus, using IS as an exclusive decision-making criterion precludes the use of some of the best risk reduction methodologies available to industry and government. A true risk-based approach must include consideration of both parts of the risk equation to arrive at an appropriate conclusion. Therefore, ACC believes that IS, as a consequence-only technique, can only be properly used in a holistic risk management framework, and is an important tool in the risk minimization toolkit.

    The Work Group’s report indicates that the preferred approach to this issue is that presented in H.R. 2868 in regards to the reauthorization of the Chemical Facility Antiterrorism Standards (CFATS). This approach is strictly consequence based, however. There are several instances elsewhere in the Work Group’s report that support the practice of risk assessment and use of risk based decision making. Thus, the report’s support of the approach laid out in H.R. 2868 is inconsistent, but more importantly, restrictive. Under a risk-based framework, a facility that finds IST alternatives to be infeasible has the flexibility to apply other measures, or “layers of protection” to the process that would not be considered under a consequence-based IS evaluation. CFATS already consists of risk-based performance standards which give facilities the flexibility to consider all possible risk-reduction options, including IS approaches.
    The Work Group indicates in its report that it also supports the aspect of H.R. 2868 that would allow the Federal government to require implementation of safer chemicals or technologies. Because of the complexities involved in determining IST alternatives, we are concerned about the efficacy of any government regulatory framework that would evolve out of such a mandate, particularly if it is based on a consequence-only approach like that in H.R. 2868. Even if government experts would be included in the regulatory decision-making process, such a mandate could easily drive DHS to generate “off the shelf,” remedies rather than address site-specific safety and security risks. This approach appears overly simplistic and unnecessarily prescriptive.

    In order to build a stronger foundation for prevention in the Work Group’s report, ACC believes that the Work Group should integrate the full range of information on this issue into the report rather than focus on a single risk reduction tool or approach that may or may not be reduce the most risk at chemical facilities. Likewise, the Work Group could strengthen Recommendation #6 by considering solutions beyond legislation for such a tool or approach. Unless stakeholders are well educated on this issue, they will not have the ability to affect the changes that this effort seeks.

  23. Pamela Schnepper

    Dose Environmental

    I’d like to applaud ATSDR for recognizing the need for this effort, and for the manor with which it has been conducted thus far. My review of this excellent report by the Chemical Emergencies work group is from the perspective of a chemical emergency preparedness and response planner.

    I believe the workgroup was particularly insightful with the statements on page 9;

    “In 1989, a phenomenon called The “Paper” Plan Syndrome was identified (EPA, 2008). This was described as the illusion of preparedness based on a system with written plans that are, among other things, not tied to funding and the resources necessary to carry them out.”

    and page 12;

    “While a community’s “Right to Know” is well established as a principle, it has, in many instances, effectively been rescinded under the guise of national security, confidential business information, or trade secrets.”

    As there may be political will to minimize perceived regulatory burdens on industry, direct federal oversight for compliance with environmental laws and programs is necessary.

    Recommendation #1
    In establishing an “Office of the Chemical Emergencies Coordinator”, it seems an omission that there is no mention of EPA. Also, while the workgroup specifically described some of the relevant roles toxicologists play in chemical emergency response, it seemed odd to omit the important role of regulatory and public health toxicologists.

    Recommendation # 9
    I’d like to add that all chemical release events are environmental issues, the EPA and state environmental agencies should play a major role in any simulated chemical release emergency response exercises.

    Recommendation # 11
    CAMEO is a federally supported, easy to use tool for chemical emergency planning and response that uses the same underlying chemical databases and modeling tools as WISER. The CAMEO software suite has the capacity to be used for all aspects of emergency response including tracking health information.

    In my opinion, we have the tools, but we do not always have support to ensure that the tools are used at a local level, as we would if the Local Emergency Planning Committee (LEPC) system were functional. The most effective approach to address many of the noted short-comings of chemical emergency preparedness and response, is to improve compliance with existing environmental laws and programs by increasing federal involvement.

    I’d like to suggest an added specific recommendation, that the federal government ensure local compliance with the Emergency Planning and Community Right-to know Act (EPCRA) and provide direct support for local-level CAMEO training and utilization by LEPCs. This would satisfy the final recommendation of the Systems and Coordination Subgroup (page 4) “to develop or improve systematic coordination of efforts by industry, local community organizations/groups, city, state, and federal agencies to prevent chemical incidents, reduce hazardous chemical use, and to provide communities with the appropriate education and skills necessary to gain access to chemical information and learn to respond effectively to chemical emergencies.”

    Thank you for the opportunity to comment.

    Pamela Wadman Schnepper, MS
    Senior Toxicologist
    DoseEnvironmental.com

  24. Anna Hrybyk

    Louisiana Bucket Brigade

    1. Insufficient data: The ATSDR NTSIP program does NOT handle accidents in the petroleum industry, which is a glaring oversight that MUST be mentioned in this section.

    2. Currently the responsible petrochemical facilities are the ones in control of communicating risks when an accident occurs at their facility. They often do not report the totality of what was released and are sure to send out the message that it does not in any way harm human health. Two weeks ago, Chalmette Refining in Louisiana stated to the media that it dumped 2,000 pounds of spent catalyst on a community while they were sleeping (with their windows open) and stated that it did not pose a risk to human health. Once we finally requisitioned the report we find out that it was actually 19 tons and the material data safety sheet said not to touch it with bare hands and to discard clothing that had been touched by it. Companies will do whatever it takes to preserve their profit margin NOT protect the public.

    3. Fenceline perimeter monitoring should be apart of preventing/planning for accidents. This would also work to sort out the truth form fiction on the exact nature and quantity of the releases.

    4. In coordinating and integrating responses, you should add residents as a stakeholder to be coordinated with. Residents shouldbe empowered to monitor the faciliaties using air samples, photos and citizen reporting tools like the Chemical Accidents Crisis Map (www.oilspill.labucketbrigade.org).

    5. Residents who live near hazardous industry, particularly community leaders, shouldbe trained to respond to chemical emergencies. One way to do that is to include a robust HazMAt module in the CERT and encourage residents in vulnerable areas to get trained. Particular attention should be paid to areas that suffer compounded risks during natural disasters. For example, in Louisiana, 64% of the pollution from refineries into the water occurs during storms. Hurricanes and tropical storms present a grave danger to those communities on the fencelines of petrochemical plants.

    6. The Poison Control Center should be encouraged by this working group to code calls for chemical emergencies hjust as they have done for the BP Oil Spill so that we can track health impacts from chemical emergencies.

    7. ATSDR and DHH infrequently and inadequately perform health consultations for chemical emergencies. It is dangerous without an independent body working with ATSDR to charge them with your recommendation #5. ATSDR relies too much on what the company and the Department of Environmental Quality tells them and not enough on what communities actually experience.
    File: LABBcommonground.pdf

  25. Kathy Curtis

    Oregon Toxics Alliance...

    Oregon Toxics Alliance, Northwest Indiana Toxics Action Project, Alliance of Nurses for Healthy Environments, Alaska Community Action on Toxics, University of Alabama Hospital Highlands, Oregon Environmental Council, Clean New York, Environmental Health Fund, Citizens’ Environmental Coalition

    Comments to the Centers for Disease Control & Prevention regarding National Conversation on Public Health and Chemical Exposures
    Workgroup Reports

    General Comments:

    The Massachusetts TURI program should be made into a federal program, using a similar structure. It is funded by a user fee that companies pay based on the amount of hazardous materials they use. The fees are used to support programs that work with companies to help them reduce their use of hazardous chemicals, which then reduces the fees they have to pay to the program. In addition, companies that reduce their hazardous chemicals also reduce costs to store, ship, and dispose of them, which usually saves them money overall.

    Children are generally not called out in any of the work group reports, yet they are a specific vulnerable population: they cannot identify risks, remove themselves from harm, or describe exposures or events. Neither CDC’s Environmental Public Health Tracking nor the National Children’s Study collect information regarding children’s exposures in schools or child care centers, but they should be. When those are mentioned in various work group reports, it would be prudent to add that EPHT and NCS need to swiftly address these well-known data gaps with revised work plans. Children have exposures “on the job” in schools and child care centers and outnumber adults by about ten to one (depending on age group and health status) in those settings, but children/families have no recourse and no public services to intervene or to track or research those exposures.

    Chemical Emergencies Work Group:

    The Chemical Emergencies report did a superb job of placing inherently safer technologies and other preventive methods as a priority.

    Change Recommendation #6 to read as follows:

    In the body of this report, it was identified that there are laws addressing risk management preparedness and response, but no law addressing primary prevention of chemical emergencies. The House of Representatives has acted to fill this gap by passing H.R. 2868, The Chemical and Water Security Act of 2009. The act would require facilities to assess, and in certain cases to implement, safer and more secure alternatives that can reduce or eliminate the possibility of acute release of toxic inhalable gases. The legislation authorizes funds for implementation. It assigns authority over private sector facilities to DHS under the existing Chemical Facility Anti-Terrorism Standard. It assigns authority over Drinking Water Facilities to EPA under the Safe Drinking Water Act, and for wastewater facilities it assigns authority to EPA under the Clean Water Act. For this legislation to be implemented successfully, it will require cooperation between these agencies and other agencies with relevant expertise. The Senate should pass similar legislation and the President should sign it.

    The only certain way to protect our communities is to remove the possibility of a toxic gas release by converting facilities to safer, more secure alternative technologies. There are many existing off-the-shelf remedies that can be used. Bleach plants can reduce danger to employees and surrounding populations by generating chlorine on-site without rail shipment and bulk storage. Water utilities could convert from chlorine and/or sulfur dioxide gas to liquid bleach or ultraviolet light. Petroleum refineries could replace hydrofluoric acid with sulfuric acid or solid acid catalysts. The primary criterion for substitution should be to reduce peoples’ potential exposure to acutely toxic gases. Additional criteria should be to reduce the probability of release and/or to reduce the toxicity of the material that would potentially be released.

    Although primary prevention will not be possible in every case and some risks will always need to be managed, prepared for and responded to, the above examples of existing, off-the-shelf technologies indicate that there are many opportunities for primary prevention that have not yet been realized. A law requiring assessing opportunities for, and in some cases, implementing safer technologies will lead to much risk reduction.

    Recommendation #5 does not include a subsection on defining how health care providers can diagnose, respond, and encourage community agencies and parents to protect children from chemical emergencies. Children aren’t covered at all in this document on chemical emergencies

    Under Training and Capacity, “The nation’s emergency response must include training in diagnosing and treating children’s exposures to chemical emergencies and spill events, including pesticide exposures.” should be inserted in the opening paragraph. Page 14 should insert child-specific needs and recommendations regarding training of responders, diagnoses, tracking, med supplies, post-event remediation of child-serving facilities, etc.

    P 16, problem narrative- “Post-BP Oil Spill (2010), just as post-Katrina (2005) and post-9/11 (2001-02), no federal agency issued any public health advisories on preventing children’s exposures that cited examples of children’s symptoms from exposure to crude oil or benzene, or that urged local agencies to ensure that child-safe remediations of contaminated facilities were successfully conducted (homes, schools, playgrounds).” should be replaced with a new recommendation: HHS and EPA should collaborate with the Commission on Children and Disasters to ensure that one lead agency is required to issue timely, accurate public health advisories to all state and city public health agencies, health care providers, and schools that address how to prevent harm to children, recognize and treat symptoms of children’s exposures, provide medical tracking, and remediate chemical contaminants affecting children.

    The process described in line #333, is only recommended, but should be required. Under II. CURRENT STATUS OF ISSUES UNDER CONSIDERATION, line 341 should be expanded to read as follows: The private sector should work with local emergency management agencies to help plan for response as well as to address inconsistencies in communication and messaging during an event. Hospitals should participate with local health departments in the Continuity of Operations Plan (COOP) in order to continue essential operating functions and facilitate recovery should a disaster occur. (http://www.fema.gov/government/coop/index.shtm#0
    http://www.hrsa.gov/emergency/)

    Immediate action needed to prevent catastrophic events at high risk chemical facilities

    There was no thorough discussion of the serious threats posed by high risk facilities (those capable of resulting in a catastrophic incident with explosions or release of deadly gases) and the need for government to immediately address this situation. Concerted government efforts are essential immediately to systematically prioritize and inspect all high risk facilities, identify safety concerns and require timely corrections. This recommendation should be classified as prevention. EPA, OSHA and other agencies should be involved. At minimum, all of the following should be reviewed:

    • Storage and processes involving extremely hazardous substances,
    • Whether scheduled maintenance has been undertaken on a regular basis,
    • All Incident Reports involving workers & subcontractors in the last five years,
    • Whether high volume inventories of EHSs are really necessary,
    • Whether warning signals are working, and
    • Management structure for all high hazard processes.

    Despite the fact that hundreds of facilities pose catastrophic risks in and of themselves, they have been exempted from compliance with additional security measures related to terrorism for an additional 3 years. The waiver of these requirements should be mentioned on p. 10. The public should be told that the riskiest terrorism targets have not yet been required to comply with security measures, required of less risky facilities. Terrorism itself has increased the secrecy surrounding these facilities, and reduced the public’s access to information. There are woefully few government inspectors working on gas line safety. Ignoring high risk facilities or failing to appreciate the many warning signs could result in thousands of deaths and severe injuries.

    Immediate action needed to prevent catastrophic events at nuclear facilities

    While this workgroup is titled Chemical emergencies, there must be an appropriate expansion of scope. Nuclear power plants, waste sites and radioactive contamination is widespread. Radioactive materials are transported through communities, many of which pose unique considerations for emergency response and prevention. The separateness of radiological hazards vs. hazardous chemicals has been the result of the regulatory structure, but in our communities both of these hazards are present and emergency responders and health personnel would be required to respond. Concerted government efforts are essential immediately to systematically prioritize and inspect all nuclear plants and waste facilities, identifying safety concerns and requiring timely corrections. This recommendation should be classified as prevention. NRC, EPA, OSHA and possibly other agencies should be involved.

    Unresolved safety issues affect many nuclear plants and other unique problems affect individual plants. In general, the nuclear fleet is aging and in the process of renewing licenses. A Chernobyl type disaster in the US could have severe consequences. We need to ensure the highest level of safety for these facilities. We repeat the recommendation for high risk chemical facilities here.

    Prevention-uniquely different from Preparedness-received inadequate attention

    Prevention should be more prominent in the Chemical Emergencies workgroup report. It also should be a separate activity and clearly delineated from “preparedness”. There is much wrong with the whole national emergency response program for chemical emergencies. Since funding is a problem, far more can be gained with limited dollars from prevention of chemical disasters than from building up an adequate response network. We should do both.

    We recommend a significant expansion of prevention training– particularly for fire personnel, municipal officials and environmental agency personnel. The whole concept of Local Emergency planning was an excellent one, but this terrific law and idea was supposed to move forward with no funding, when highly technical analysis and enormous work was involved.

    Currently greater than 95% of resources are devoted to preparedness and response, even when prevention is part of an organization’s mission. Tasking a government agency with prevention and everything else will ensure that prevention gets no attention– unless it is in a separate department with a separate budget and clear mandates, while still ensuring integration and coordination by facilitating reports back so that all parts of the system understand what prevention work is being done.

    Post incident review with all involved parties and identification of lessons learned is essential to prevention. If this process is really used as a tool, an event at one facility may relate to all similar facilities. This could enhance prevention recommendations and be used as a training exercise.

    The report should cite the success of New Jersey’s chemical accident prevention law, the Toxic Catastrophe Prevention Act. New Jersey’s law and implementation has reduced the overall number of high hazard facilities and increased safety. New Jersey has now adopted a rule regarding inherently safe technology, which will require compliance for all covered facilities.

    We further recommend a listing of common prevention activities within the report:
    • Substitute chemicals used for less hazardous ones
    • Reduce the volume of chemicals stored on site
    • Isolate the process from other hazardous processes to prevent interaction
    • Automatic shutoff valves, redundant safety devices and other inherently safer technologies
    • Preventive required maintenance

    Our national emergency response system, established for natural disasters, needs to expand its scope and put health agencies in charge of protecting workers and the public

    In the two serious disasters involving exposure of thousands of workers to hazardous substances, no agency was responsible for issuing precautionary health and safety recommendations for workers. In the case of the World Trade Center, this failing resulted in delayed funding for studies of workers health and for health damages. But few lessons were learned regarding future disasters and the need for precautionary health measures during initial response efforts, to be used during the oil spill disaster in the Gulf.

    Currently there is no direct authority for health and safety issues in disaster response. Chemical hazards in particular have no established response mechanisms and no funding.There must be clear authority for one or more health agency to take emergency action to prevent health impacts to workers and the public and this must take precedence over all other priorities.

    We urge the workgroup to make a strong funding recommendation

    Beginning on page 9, the issue of limited funding is briefly discussed, but the workgroup does not make a recommendation for more funding. This is problematic, given the seriousness of this issue, and antithetical to accomplishing the rest of the recommendations in the report. The report should recommend funding.

    Injury and illness reporting systems should be managed by government officials

    Responsible parties of any chemical or health and safety incident have no business being involved in a comprehensive injury and illness reporting system. Health and Safety information as well as injury and illness reporting must be managed exclusively by government officials whose primary mission is these functions. A responsible party has a clear and serious conflict of interest in collecting accurate injury and illness information, which could later be used in assessing damages against them. This must be the job of government agencies, whose primary expertise is health.

    Global Harmonized System

    This report strongly favors the global harmonized system, but improvements are needed in the system and that US government should work toward that end. It depends on currently available data for its classification criteria, which do not require retesting of chemicals.

  26. Mark Kirk

    DHS

    Please see attached for comments from FEMA
    [file]http://resolv.org/site-nationalconversation/files/2011/02/9-160FEMAResponseNationalConversation Group Reports Posted for Public Comment-1.docx[/file]

  27. Mark Kirk

    DHS Office of Health Affairs

    Please see attached document.
    [file]http://resolv.org/site-nationalconversation/files/2011/02/CEWG Draft Report 08 21 10_Kirk edits.doc[/file]

  28. Mark Kirk

    DHS Office of Health Affairs

    Please see attached document for comments
    [file]http://resolv.org/site-nationalconversation/files/2011/02/CG-533 Comments for Chem Emergencies.docx[/file]

  29. Mark Kirk

    DHS Office of Health Affairs

    Please see attached document for comments.
    [file]http://resolv.org/site-nationalconversation/files/2011/02/Chemical Emergencies Report -IP Comments.docx[/file]

  30. Michael Jacoby

    I would like to start by thanking the Chemical Emergency Work Group for putting together this Final Draft Report available for public comment which brought awareness to many of the deficiencies we have within our systems today.

    In general I think that the workgroup should address some of the known deficiencies before recommending that a new federal government office or program be established.

    The solutions for correcting these deficiencies are simple and should bring awareness to some of the existing federal databases that can be used by all three disciplines such as fire service EMS and law enforcement while giving the public, non-governmental organizations (NGO) the ability to oversee the cooperation between federal, state and local entities.

    This Draft Report is one of the best reports I’ve seen in recent years but I would like to address three major areas of concern to me in this report as I believe the priority focus should be on the protection of our children and other vulnerable populations no matter what the demographic etc.

    *On p. 10, line 451 3) Insufficient Laws, Can anybody find in any of these federal laws the requirement to check the data being supplied through our systemic process of information collection?

    Note: I believe that if an effort is made to address this basic data verification requirement for a site’s locational data, that the rest of the pieces of this “Big Picture” should start to fall in place so those with children, day care centers, healthcare facilities and individuals with concern or others requiring special needs who might already be on a state’s hypersensitivity registry list will then be getting accurate updated information for their protection in times of need or times of crisis once a hazardous material response plan has been activated and then relayed to your emergency communications centers to start response and recovery procedures.

    In my opinion this type of basic awareness information pertaining to data verification could be done by simply involving the public.
    See attached link below for an example of a model of how to evacuate residents in need called ECRIN (Evacuating County Residents In Need) Project that might help some local communities until a solution is found. http://www.ychsd.org/ECRIN/tabid/431/Default.aspx

    *On p. 6, 285 : train to initiate an emergency response notification process.

    Without getting into too many details about the issue of relay time after a Hazardous Material Management Plan (HMMP) has been initiated, that is then added to a responder’s response time is something that I feel should be explained in detail in this report for the benefit of the public and other groups.

    Could you take a few moments and review the language in this report to maybe help those who do not understand how much time is actually involved when using official channels, until responders are on scene to initiate an emergency notification process and the effectiveness of said systems?

    Note: Not everybody opts to sit in front of their entertainment devices 24 hours a day or has an emergency radio, hard line telephone etc. operational especially if you are like many throughout our nation who might spend your time outside of your home with your loved ones exposed to the atmosphere.

    The following is also some testimony that I found interesting, that could be brought to the attention of others that is available on the internet, just Google: IAEM Gispert June 4, 2008.

    Also I did not see anything mentioned in this

    Summary: I agree that training is foremost and should be brought to the attention of all first responder groups, federal, state and local agencies to include the general public so that these problems can be quickly resolved.

    Good Job!