FEMA_Key Planning Factors and Considerations for Response to Recovery from a Chemical Incident_June 2022.pdf

Key Planning Factors and Considerations for Response to and Recovery from a Chemical Incident

June 2022

Record of Change

Date Action Type (Review or Revision)

Printed Name Signature

06/09/2023 This document has been updated as of 06/09/2023 to reflect the reorganization of the Chemical, Biological, Radiological, and Nuclear (CBRN) Office to the Office of Emerging Threats (OET). No other changes to the document content have occurred.

Key Planning Factors and Considerations for Response to and Recovery from a Chemical Incident

This document was prepared by the FEMA Office of Emerging Threats (OET)

Purpose of this Document and Intended Audience Planning for response to and recovery from a chemical incident requires additional considerations beyond all-hazards preparedness planning. Key Planning Factors and Considerations for Response to and Recovery from a Chemical Incident provides planning guidance and serves as a reference for regional, state, local, tribal, and territorial (SLTT) departments and agencies that are planning for chemical incidents. The document includes strategic and operational issues for consideration when developing response and recovery plans for a chemical incident. Other stakeholders such as SLTT governments, non-governmental organizations, and the private sector will also find this document to be useful as it supports and complements their planning efforts in responding to and recovering from chemical incidents.

Table of Contents

Purpose of this Document and Intended Audience

While you Read

Prologue

1. What Is A Chemical Incident?

2. Industrial Accidents — Chemical Supply Industry

2.1. Flooding at a Chemical Plant

2.2. Chemical Leak into Waterway

3. Industrial Accidents — Agricultural Industry

3.1. Pesticide Exposure in Farm Workers

3.2. Contaminated School Lunches

4. Transportation Accidents

4.1. Rail Tank Car Rupture

4.2. Train Derailment

5. Deliberate Events

5.1. Attempted Assassination

6. What do These Chemical Incidents Have in Common?

7. Common Characteristics of Chemical Incidents

8. Barriers to Preparedness for Chemical Incidents

Key Planning Factors for a Chemical Incident

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KPF 1 “Prime the Pump” Pre-Event Planning

1. Why Pre-Event Plan?

1.1. Keep in Mind: Natural Hazards Incidents are More Familiar than Chemical Incidents

2. Engage with Local Chemical Incident Planners and Create Stakeholder Working Groups .. 30

2.1. Identify and Create Stakeholder Working Groups

2.2. Engage with Existing Chemical Incident Planning Resources

2.3. Leverage Planning Groups

3. Identify and Understand the Community’s Chemical Risks and Current Capability Gaps ... 33

3.1. Chemical Risk Assessment

3.2. Critical Infrastructure

4. Understand How Time-Sensitive Decisions Are Made in Crisis Situations

4.1. Establish Decision-Making Processes

4.2. Evacuation/Sheltering

4.3. Decontamination and Population Monitoring/Environmental Remediation

4.4. Waste Management

4.5. Establish Clearance Goals

4.6. Establish Protocols and Procedures for the Prioritization of Medical Resources

5. Treat the Community’s Entire Response as a System of Systems

5.1. Resource Requirements and Sources

6. Develop a “Whole Community” Concept of Operations

6.1. Population Considerations

6.2. Develop Community-Wide and Partner Messaging Strategies

6.3. Develop Operational Plans/CONOPS and Response Support Materials

6.4. Develop and Deploy Training, Exercises, and Response Support Materials

KPF 2 Recognize and Characterize the Incident

1. Incident Recognition

2. Active Environmental and Industrial/Utility Facility Monitoring

2.1. Chemical Detection Technologies for Active Recognition

2.2. Workplace Exposure Monitoring

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2.3. Active Monitoring of Public Venues

2.4. Active Monitoring for Food Contamination

2.5. Active Monitoring for Illicit Compounds

3. Surveillance/Passive Venue and Population Monitoring

3.1. Surveillance/Passive Monitoring of Public Venues

3.2. Human and Veterinary Health Surveillance Systems

3.3. Surveillance for Food Contamination

3.4. Response Initiation

4. Incident Characterization: Substance and Site

4.1. Substance Identification and Characterization

4.2. HazMat Teams

4.3. Detection of Low-Volatility Agents (LVAs)

4.4. Site Assessment/Characterization/Determine the Extent of Contamination

4.5. Modeling the Release (if applicable)

4.6. Substance Identification in Food Contamination Events

4.7. Intentional Acts

KPF 3 Communicate with External Partners and the Public

1. Recognize the Importance of Communications

2. Recognize the Importance of Partner Communications: Lessons from Tokyo22,32

3. Communications for a Coordinated Response

3.1. Communicate to Coordinate with Response Partners

3.2. Locally Executed Response

3.3. State, Tribal, and Territorial Managed Response

3.4. Federally Supported Response

3.5. Leverage Partner Resources to Provide Informed Public Guidance

3.6. Private Sector Engagement

3.7. Coordinate with Response Partners to Communicate with the Public

3.8. Co-Activation of a Joint Information Center and Emergency Support Functions (ESFs)34,35,37

3.9. Emergency Support Function #15 – External Affairs Annex43

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4. Communications for an Informed Public

5. Provide Time-Critical Messaging

5.1. Advance Preparation of Messages

5.2. Response Communication Guidelines41,46

5.3. Timely Dissemination of Messages

5.4. Use of Duplicative Outlets for Message Dissemination

6. Strategies for Effective Communications

6.1. Understand your Audiences

6.2. Conduct Pre-Incident Preparedness Campaigns

6.3. Secure Technical Assistance

6.4. Communications Considerations for Large-Scale, Intentional, and/or Unattributed Incidents

6.5. Communicate Throughout Response and Recovery

6.6. Communicate with Empathy: Create Validating and Empathetic Messaging

7. Best Practices for Communicating Risk in an Emergency

KPF 4 Control the Spread of Contamination

1. Control the Spread of Contamination

2. Initial Containment and Cleanup

2.1. Contamination Control Mechanisms

2.2. Incidents on Land

2.3. Incidents in Bodies of Water

2.4. Oil Release Incidents

3. Human, Animal, and Equipment Decontamination

3.1. Equipment Decontamination

3.2. Human Decontamination

3.3. Animal Decontamination

3.4. Site Localization of Decontamination

4. Other Protective Actions

4.1. Evacuation/Sheltering

4.2. Site Security, Site Access, and Travel Control

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4.3. Facility Closure

4.4. Food Recall

4.5. Isolation of Goods and Materials

KPF 5 Augment Provision of Mass Care and Human Services to Affected Population

1. Provide Support to Affected Populations

1.1. Mass Care and Human Service Providers

1.2. Evacuation and Sheltering

1.3. Mass Care and Community Lifelines

1.4. Information and Human Services Centers

1.5. Decontamination Support

1.6. Considerations for Animals

2. Anticipate Public Fear and Mental Health Challenges

2.1. Populations at High Risk

2.2. Long-Term Considerations

3. Federal Assistance for Mass Care and Human Services

3.1. Animal Care Resources

4. Special Mass Care and Emergency Assistance Considerations

KPF 6 Augment Provision of Health and Medical Services to Affected Population

1. Provision of Medical Care

1.1. Provision of Timely Care

1.2. Medical Treatment for Chemical Casualties

1.3. Availability of Medical Countermeasures

1.4. Veterinary Care

1.5. Resilience of Medical Infrastructure

1.6. Additional Public Health Considerations for Provision of Care in Disasters

1.7. Agricultural Incidents

1.8. Fatality Management

2. Federal Assistance for Health and Medical Services

2.1. Personnel and Material Assistance

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2.2. Space and Systems Assistance

KPF 7 Augment Essential Services to Achieve Recovery Outcomes

1. Recovery Begins During Planning and Response

1.1. Set and Review Priorities for Recovery

1.2. Potential Recovery Limitations

2. Support the Affected Population and Community in Achieving Recovery Outcomes

2.1. Maintain Communications with Partners and the Public

2.2. Ensure Continuity of Operations (COOP) and Continuity of Government (COG)

2.3. Recovery from Food or Agriculture Incidents87

3. Long-Term Environmental Containment and Site Remediation

3.1. Approaches to Site Remediation

3.2. Meeting Established Clearance Goals

4. Anticipate Waste Management Challenges

4.1. Planning for Waste Management and Storage

4.2. Waste Treatment, Storage, Handling, Transportation, and Disposal Regulations85

4.3. Oil Spill Waste Management52

5. Managing a Complex Chemical Disaster

Federal Preparedness, Response, and Recovery

1. Federal Support for the Response to Chemical Incidents

1.1. Federal Interagency Coordination

1.2. Unified Coordination Group (UCG)

1.3. Additional National Support Mechanisms: The National Guard

1.4. Relevant Legislation and Doctrine

1.5. Law Enforcement/Investigative Response for Suspected Deliberate Incidents

1.6. Federal Funding for Response and Recovery

2. Federal Support for Recovery Following Chemical Incidents

3. Federal Response to and Recovery from Food and Agriculture Impacts of Chemical Incidents

Planning, Decision Support, and Modeling Resources for Chemical Incidents

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References

Photo Credits

Appendix A. Chemical Substances and Hazard Information Resources

Appendix B. Health Effects of Chemical Exposure: Toxidromes

Appendix C. Chemical Incident Policy, Legislation, and Regulations

Legislation

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

Clean Water Act and Oil Pollution Act (CWA/OPA)

Clean Air Act (CAA)

Occupational Safety and Health Act (OSHA)

Marine Protection, Research, and Sanctuaries Act (MPRSA)

Safe Drinking Water Act (SDWA)

Resource Conservation and Recovery Act (RCRA)

Toxic Substances Control Act (TSCA)

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

CERCLA and CWA/OPA

Superfund Amendments and Reauthorization Act (SARA)

Emergency Planning and Community Right-to-Know Act (EPCRA)

Stafford Act

Doctrine and Regulations

National Oil and Hazardous Substances Pollution Contingency Plan (NCP)

National Response Framework (NRF)

Response and Recovery Federal Interagency Operational Plans (FIOPs)

Oil and Chemical Incident Annex (OCIA)

Food and Agricultural Incident Annex (FAIA)

Appendix D. Chemical Planning and Notification Requirements for Responsible Parties ... 272

Planning Requirements

Reporting Requirements

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RCRAInfo

National Emissions Inventory (NEI)

Permit Compliance System (PCI) and Integrated Compliance Information System (ICIS) .. 276

Notification Requirements

Appendix E. Federal Funding for Incident Response

Agency-Appropriated Funds

Responsible Parties (RPs)

NCP-Related Funding Sources

Local Government Reimbursements (LGR)

Stafford Act Funding

FEMA Grants

Appendix F. Emergency Support Functions (ESFs)

Appendix G. CBRN Emergency Response Assets and Teams

Appendix H. Environmental Containment and Remediation Options

Overview of Environmental Remediation and Containment Options

Destruction or Alteration of Contaminants

Extraction or Separation of Contaminants from Environmental Media

Immobilization of Contaminants

Selection of Treatment Approach

Appendix I. Medical Countermeasure Distribution Process: A Coordinated Response

Appendix J. Acronym List

Appendix K. Glossary of Terms

This document was prepared by the FEMA Office of Emerging Threats (OET) 1

While you Read Throughout Key Planning Factors and Considerations for Response to and Recovery from a Chemical Incident, you will find a system of specialized callout boxes which denote opportunities to take action, coordinate with other governments or agencies, or reference external materials. A guide to those specialized callout boxes is provided here.

Action Item

A suggested activity to complete during planning

Coordination Opportunity

An example of interagency coordination highlighted in the content

Refer To

Guidance for locating more information from a separate resource

What Would You Do?

A critical thinking exercise or discussion question

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Prologue Key Planning Factors and Considerations for Response to and Recovery from a Chemical Incident is written for response and recovery planners at the regional, state, local, tribal, and territorial levels. A coordinated response and recovery effort will include all levels of government in addition to the private sector, non-governmental organizations, and, potentially, international partners: Planning for a chemical incident requires additional considerations beyond all-hazards preparedness planning, so this document includes strategic and operational issues for consideration when developing response and recovery plans for a chemical incident.

1. What Is A Chemical Incident?

The rise to prominence of the chemical industry over the past century and current use of innumerable chemicals in everyday life have increased the risk of exposure to or contamination by a host of substances that can threaten human, animal and/ or environmental health. Exposures may result from industrial or transportation accidents, from unintended contamination of products or from deliberate chemical releases. The recent use of chemical agents in warfare and in assassinations highlights how preparedness activities must accommodate both intentional and accidental chemical incidents. Whether a chemical incident is accidental or intentional, planning is necessary to mitigate all public and environmental health emergencies.

A chemical incident includes a wide scope of events and refers to the release, or potential release, of a chemical substance

1. that harms people, animals and/or the environment, regardless of accidental or deliberate cause, and/or

2. for which response needs have the potential to overwhelm state and local resources (both governmental and private sector), and/or

3. for which the Environmental Protection Agency (EPA) and/or the United States Coast Guard (USCG), co-Chairs of the National Response Team (NRT) for Oil and Chemical Spills under the National Oil and Hazardous Substances Pollution Contingency Plan (NCP),1 deems that support is or will be required.

Note that response activities may be authorized in response to threatened discharges of hazardous substances that have not yet occurred, and that many chemical incidents are small in scope and scale do not require NCP-directed response activities. Further, if the substance released does not qualify as a hazardous waste, the incident may require federal response support under authorities other than the NCP; the NCP also does not cover releases into drinking water supplies due to normal deterioration of the water system.

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In a chemical incident, harm to people, animals and/or the environment can result from chemical “exposures” and/or chemical “contamination.” Chemical exposure occurs when a chemical substance is absorbed into the body, while for humans (and animals), contamination means having a substance on one's clothing or body. For humans and animals, chemical substances are potentially hazardous by ingestion, inhalation and/or dermal contact. Thus, dangerous chemical exposure or contamination can come from food, water, air, or contaminated surfaces, and the spread of chemicals in the environment (such as through air and/or water movement) increases the risk of human and animal contamination and exposure.

The actions that must be taken by first responders to initiate incident response depend upon whether a chemical release has caused environmental, human, and/or animal exposures, contamination, or both.

PPE-clad responders cleaning an oil spill with pom-poms and rakes

Possible chemical incidents range considerably in their scale and their potential harm to public health and the environment. Some types of events happen frequently (mishaps during the transportation of chemicals) whereas others have happened rarely (deliberate chemical attacks).

Preparedness activities should consider all of these factors when formulating plans and making decisions because the complexity of responses required will also vary with scale and the nature of the substance released. For example, a large-scale terrorist attack with a persistent chemical might result in a number of injuries from exposure and require decontamination operations, while a small-scale accidental chemical release of a chemical vapor may involve exposures but not contamination and therefore may require a far less complex response. In addition, the release of pollutants or contaminants that may reasonably be anticipated to cause harmful health effects upon exposure will require more capability and deliberate planning during the response.

There are several escalating layers of systems for the federal response to chemical incidents, allowing for appropriately-scaled responses to incidents that range from the less serious to those that may have catastrophic impacts. In the case of smaller incidents, the state, local, tribal and territorial (SLTT) governments, and/or the Responsible Party (RP) are often able to effectively address the response on their own. As incidents become larger and the responses more complex, the NCP may be activated, requiring a Federal On-Scene Coordinator (FOSC) from the EPA or USCG.

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In response to the most serious incidents, for example those cases involving a Presidential Disaster Declaration under the Stafford Act, the Federal Emergency Management Agency (FEMA) provides enhanced resource coordination under the National Response Framework2 in support of FOSC authorities. (See the Federal Preparedness, Response, and Recovery section of this document for more information.) Historically, very few high-consequence chemical incidents have involved a Stafford Act declaration – such as the 1962 Louisiana and Mississippi chlorine barge accident and the evacuation of the New York Love Canal Chemical site in 1978. More recently, a 2014 West Virginia chemical spill (described below) and the 2016 Flint, Michigan water contamination events have been declared emergencies under the Stafford Act.

Even emergencies that do not rise to the level requiring a Stafford Act declaration may tax local abilities to respond and recover. This document will provide key insights necessary to inform a successful response. To set the stage for these discussions of key response and recovery activities, several chemical incidents are discussed briefly here. Events illustrative of three categories are presented: industrial accidents, including events occurring in the chemical supply and agricultural industries; transportation accidents, including events related to the movement of large quantities of chemicals; and deliberate events, in which chemicals were employed with the intent to cause harm.

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Flooding at a chemical plant in the wake of Hurricane Harvey

2. Industrial Accidents — Chemical Supply Industry

2.1. Flooding at a Chemical Plant

In the wake of Hurricane Harvey in late August 2017, extreme flooding at a chemical plant in Crosby, TX, led to a series of events that culminated in the spontaneous combustion and release of peroxide compounds.3 By the time the all-clear was given in early September, in excess of 350,000 pounds of organic peroxide had burned, and more than 200 residents evacuated from within 1.5 miles of the facility had been out of their homes for a week.

As Harvey bore down on Texas, employees prepared the facility to ride out the storm. Flooding in the area was not unusual, but floods had never disabled the safety systems in place. This time, unimaginable amounts of rain would fall, and the resulting flooding would exceed equipment design elevations. In this case, multiple layers of protection failed despite highly trained workers remaining on-site to implement the facility's preparedness plans – which were, unfortunately, still inadequate.

The plant lost power, backup power, and critical refrigeration systems, with catastrophic results.

Without refrigeration, some of the organic peroxide compounds on site combusted in just a few days, releasing toxic smoke into the surrounding area. Hampered by the damage and closures wrought by the hurricane, plant personnel and local emergency responders had few options to ensure a speedy and safe conclusion to the incident. They elected to plan and perform a controlled burn of the remainder of the facility's compounds.

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Smoldering remains of the first refrigerated trailer to combust

Emergency response officials had initially decided to keep the local highway open because it served as an important route for hurricane recovery efforts in the area even though it ran through the evacuation zone around the facility. Eventually, five police officers in four vehicles driving down the highway toward the facility reported being exposed to a smoke cloud coming from the facility; they quickly experienced nausea, headaches, sore throats, and itchy watering eyes, and requested medical assistance. Following this event, all travel on the highway was stopped. In all, 21 people sought medical attention from exposure to toxic fumes generated by the decomposing peroxides.

Smoke rising from the chemical plant fire

The plans, efforts, and experience of facility employees were not enough to stave off a flooding disaster, particularly one beyond the imagination of the plant's safeguard planners.

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Timeline of incident due to chemical plant flooding and subsequent fires

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Chemical storage tanks alongside the Elk River near Charleston, West Virginia

2.2. Chemical Leak into Waterway

On January 9, 2014, 11,000 gallons of crude methylcyclohexanemethanol (MCHM) leaked from a corroded tank at a chemical storage and distribution site in Charleston, WV, into the nearby Elk River.4 The substance flowed downstream, quickly traveling the 1.5 miles to the intake for the West Virginia American Water (WVAW) water treatment facility. A week later (January 17), MCHM was detected as far as 400 miles downriver, in Louisville, Kentucky.5

The incident was recognized because of the resulting odor, first by the public (in the morning) and then by WVAW (in the afternoon). Based on initial, mistaken information regarding the identify and quantity of the leaked substance, WVAW assumed its system was capable of fully treating and removing the chemical from the water. Later that afternoon, WVAW realized that in fact, it could not, and the drinking water within WVAW’s distribution system was contaminated.

Timeline of incident due to chemical storage tank leak into the Elk River (Part 1)

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Map of leak location on the Elk River

A Do Not Use (DNU) order was issued for ~300,000 residents across portions of nine counties, restricting usage of tap water for drinking, cooking and bathing for four to nine days. The DNU order resulted in closures of many businesses, schools and public offices. During this time, FEMA, the West Virginia National Guard, first responders, city governmental agencies, civic groups and multiple state agencies worked together to ensure affected residents had water available: more than 2 million one-gallon jugs and nearly 30 million bottles of water were distributed to the public. The geographic and economic extent of the effects and the need for coordinated response led to the declaration of an emergency via the Stafford Act on January 10.

Response to the incident was further plagued by misinformation. In fact, it was after the DNU was lifted – 12 days after the leak – that the site operators announced that a mixture of polyglycol ethers (PPH) had been released along with the MCHM, because they were stored within the same tank.

Neither emergency responders nor WVAW had been provided with safety data sheets (SDS) for PPH, a substance known to cause adverse health effects, during the incident.

Timeline of incident due to chemical storage tank leak into the Elk River (Part 2)

Over the 2 weeks following the spill, area public health officials noted a surge of several hundred patients experiencing nausea, rashes, vomiting, abdominal pain and diarrhea following exposure to the water through inhalation, ingestion and/or skin contact. These patients were treated and released.

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Residents in the Charleston area were given unclear and conflicting advice due to available information changing over the course of the incident. Some residents noticed an unpleasant odor in the water for several weeks following the leak, even after flushing piping as directed. As a result, many residents did not believe the water was safe to drink after water restrictions were lifted.

Summary of emergency department visits for 369 individuals treated January 9- 23, 20144

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California vineyards used pesticides heavily in the 1970s

3. Industrial Accidents — Agricultural Industry

3.1. Pesticide Exposure in Farm Workers

During the 1970s, California grape growers relied heavily on organophosphorus pesticides which were known to be toxic to humans. At the time, fieldworkers were protected from harmful exposure by restricting their access to treated fields for days (or weeks) after pesticide application. Growers who used organophosphorus compounds were required to have an emergency medical plan, including arrangements for proper medical care of workers accidentally exposed to harmful levels of pesticides.6

On the evening of September 9, 1976, a private physician in Madera County, CA, alerted the local health official to a potential chemical poisoning.6,7 The physician had already treated 25 field hands from a single vineyard, and now had another large group of workers, brought in by the same labor contractor, who were all suffering from nausea, vomiting, dizziness, and weakness. The health official’s call to the local community hospital emergency room confirmed that a number of fieldworkers had been treated there for similar symptoms over the past day or two as well. The health official made arrangements with the county agricultural commissioner to begin a joint investigation at the vineyard the next morning.

California Department of Food and Agriculture (CADFA) laboratory analyses of vine foliage samples from vineyard locations where the workers had been harvesting when they became ill identified high levels of dialifor (Torak®) and phosalone (Zolone®), both organophosphorus pesticides in the same class of chemical as the nerve agent sarin. Workers had apparently been allowed into recently-treated areas before the expiration of the required 30-day safety interval for dialifor, and had suffered exposures to pesticide residues through the skin. In all, 118 workers from a 120-person grape-picking crew at the vineyard became ill. Of these, 85 received medical attention and three were hospitalized.

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Timeline of incident due to vineyard worker exposure to organophosphorus pesticides

The incident may not have been noticed and worker exposures likely would have continued without the cooperation of several state and local agriculture and health agencies including CADFA, the Environmental Protection Agency, the California Department of Health, and the California Division of Industrial Safety (CAL-OSHA), and the Madera County Agricultural Commissioner's Office. Even so, this event represents the largest known single incident of such poisoning among fieldworkers in the US. The large number of acutely ill patients severely taxed medical resources; as a result, comprehensive reporting of emergency treatment by physicians fell by the wayside.

The vineyard owner was ordered not to harvest grapes from fields containing unsafe levels of pesticide residues. He sustained significant losses while his vineyards were under quarantine and had to pay substantial medical expenses and a fine for violating state regulations concerning the proper use of pesticides.

Neither dialifor nor phosalone have been used in agriculture in the US for decades.8

Application of pesticides by field workers poses risks for chemical exposures

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School lunch programs serve many children nationwide

3.2. Contaminated School Lunches

On November 25, 2002, several students eating the school lunch in Will County, Illinois, noted an ammonia-like odor in the chicken tenders, but ate them anyway. Within an hour, dozens were vomiting in school bathrooms and hallways. The school notified the county health department, which alerted the five local hospital emergency departments to the incoming 18 ambulances transporting 42 children and two adults. In all, 157 people (151 students and 6 teachers) became ill.

Miraculously, no one was hospitalized, and many of the affected individuals reported feeling well within hours of onset.9

Soon after, the Illinois Department of Public Health found ammonia at levels greater than 1,000 ppm in heated chicken tenders and nearly 2,500 ppm in frozen chicken tenders from the school. Although aqueous ammonia used in food processing is “Generally Recognized as Safe” (GRAS) by the US Food and Drug Administration (FDA) and levels are not limited, ingestion of ammonia at levels higher than normally found can cause gastrointestinal illness and damage, even death at sufficiently elevated levels, due to its caustic nature. The ammonia levels measured in the chicken tenders were well above both the usual limit of 15 ppm in food10 and the < 50 ppm ammonia odor threshold.11 This incident illustrates the unfortunate truth that, given the right circumstances, individuals will ignore unpleasant and recognizable indicators and put themselves at risk of exposure.

An investigation revealed that the chicken had been exposed to a spill of liquid ammonia (a common refrigerant) during storage in a warehouse facility a year earlier, in November 2001. Instead of being destroyed, over 300 cases of the product were re-packaged and stored for months before being distributed to nearly 50 schools throughout Illinois. At least four other schools had noticed an ammonia smell from the chicken, and one school had served the product on October 2, 2002;

luckily, no unusual illnesses were noted at these schools. After the November 2002 incident, all remaining product was destroyed.

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Timeline of incident due to ammonia contamination of chicken used in school lunches

This incident illustrates the importance of public health preparedness plans that include two-way communication between emergency and health departments. Such communications can give medical personnel valuable minutes to prepare for the arrival of large numbers of patients and review information that might allow for a more rapid diagnosis of unfamiliar conditions and preparation of an antidote, thus potentially helping save lives.

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Railway tank cars transport a variety of hazardous chemicals in large quantities

4. Transportation Accidents

4.1. Rail Tank Car Rupture

On the morning of August 27, 2016, a rail tank car freshly loaded with nearly 180,000 pounds of liquified chlorine ruptured in New Martinsville, WV.12 Over the next 2.5 hours, the entire load was released into the air as yellow-green chlorine vapor and migrated with the wind south along the Ohio River valley.

Security camera footage showing chlorine vapor cloud moving through the area

Employees immediately initiated a chlorine release alarm and the facility area was evacuated.

Incident command posts were activated for Marshall and Wetzel counties, WV, and Monroe County, OH. Nearly two thousand households spread over three counties located within a 5-mile radius of the facility were ordered to evacuate. Adjacent industrial facilities activated shelter-in-place procedures.

Traffic was halted on nearby state routes and rail lines, and the US Coast Guard halted commercial river traffic on the Ohio River. Because response plans were in place, officials in the area were able

This document was prepared by the FEMA Office of Emerging Threats (OET) 16 to rapidly implement response activities appropriate to the release event, and successfully protected area populations.

Map of 5-mile evacuation zone

The incident resolved quickly because liquid chlorine evaporates quickly and the resulting vapor cloud dissipated within a matter of hours. Community evacuations were lifted late that afternoon, after the WV Department of Environmental Protection (WV DEP) Homeland Security and Environmental Response Group (HSER) found no detectable chlorine at several nearby locations.

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Fireball resulting from petroleum crude oil rail tanker derailment in Quebec

4.2. Train Derailment

During the early morning hours of July 6, 2013, the citizens of Lac-Mégantic, Quebec were awakened by fires and explosions caused by the derailment of 63 train tank cars carrying petroleum crude oil.

The incident destroyed 40 buildings and claimed 47 lives. Two thousand people were evacuated.13

The day before, the lead locomotive of the train had been experiencing mechanical difficulties.

Although smoke was coming from the lead locomotive stack, it was decided repairs could wait until the following morning. That night, the train was parked in Nantes (7.2 miles from Lac-Mégantic) on a descending grade. Overnight the train’s brakes failed and at about 1:00 AM the train started to roll downhill toward Lac-Mégantic, picking up speed as it proceeded down the grade. It passed through 13 level crossings before derailing near the center of town at a speed of 65 mph. Nearly 6 million liters of petroleum crude oil were released, causing a large fire and multiple explosions.

Timeline of incident due to derailment of train carrying petroleum crude oil in Canada

This document was prepared by the FEMA Office of Emerging Threats (OET) 18

More than 1,000 firefighters from 80 different municipalities in Quebec and six counties in Maine participated in what was reported to be the largest fire response in recent Quebec history.

Approximately 33,000 liters of foam – a quantity not available locally, but transported in from 180 km away – were applied to the fire to get it under control. In addition to the immediate danger from fire, the downtown area and an adjacent river and lake were contaminated with spilled crude oil and firefighting foam. Numerous organizations supported the response, including the Montreal, Maine & Atlantic Railway (MMA), Canadian National (CN) railway, the Railway Association of Canada (RAC), the federal and provincial governments, World Fuel services, Inc. (WFSI), the importer (Irving Oil Commercial GP), the petroleum industry, and environmental remediation companies.

Remnants of tanker cars in the aftermath of the Lac-Mégantic train derailment

Throughout the immediate accident response, regular coordination meetings were held to discuss priorities, actions and methods, and overall response progress. However, at the time of this accident, an emergency response assistance plan (ERAP), which guarantees that resources required to assist local responders during an accident will be readily available, was not required by Transport Canada’s Transportation of Dangerous Good (TDG) Regulations for petroleum crude oil. In fact, at one point during the early response to this accident, work at the site stopped for several hours due to concerns about the ability of the MMA railway to cover emergency response costs. The stoppage affected the progress of both emergency response and environmental remediation efforts – in some areas, oil migrated back into zones that had earlier been declared safe.

Through the years, recovery efforts have faced considerable challenges. The oil spilled and the ensuing fires wreaked havoc on the local environment, including the contamination of multiple water sources and the town’s soil to a depth of 3 m.14 In the years following the accident, costs for rebuilding and environmental remediation have mounted; estimates have run into the hundreds of millions if not billions of dollars.15 Even now, more than five years later, reconstruction is ongoing, and the question of who will foot the bill for the recovery efforts remains unanswered.16

This document was prepared by the FEMA Office of Emerging Threats (OET) 19

Ambulance responding to an emergency in the UK

5. Deliberate Events Deliberate chemical incidents, defined here as those in which there is intent to do harm, present special challenges to responders in terms of identifying the substance used and maintaining public calm and trust, even when the public is not immediately threatened.

5.1. Attempted Assassination

On March 4, 2018, former Soviet/Russian spy Sergei Skripal and his daughter Yulia were found unconscious on a park bench in Salisbury, UK. Although the Skripals may initially have appeared to be suffering an opioid overdose in that they were lethargic and talking incoherently when conscious, within a few days, testing by the Defence Science and Technology Laboratory (DSTL) had determined that the targets had been poisoned by a novichok nerve agent,17 a realization that may have saved the lives of the Skripals and a responding officer.

Investigation of the incident revealed that nine sites within Salisbury required specialized nerve agent decontamination; three of these were in the city center. Clean-up work at each site involved testing, removal of potentially contaminated items, chemical cleaning and retesting. The work was overseen by the Department for Environment, Food & Rural Affairs (DEFRA) and supported by DSTL, Public Health England, the Department for Health and Social Care, the Home Office, and the Ministry of Defence (MOD). Presciently, Ian Boyd, DEFRA’s Chief Scientific Adviser and chair of the decontamination assurance group overseeing the work, said “Meticulous work is required and we expect it will be a number of months before all sites are fully reopened.”18 In fact, even with the help of hundreds of specialist military personnel, it was nearly a year later and at a cost of ~£12million that all Salisbury city sites were finally declared safe.18,19

Then, in July of that same year, a couple was poisoned in the nearby town of Amesbury. They had found a bottle of perfume in the trash that had been laced with the novichok agent. One of the

This document was prepared by the FEMA Office of Emerging Threats (OET) 20 couple died as a result.20 This second poisoning added significantly to the resources needed for clean-up efforts, and to the unrest of the public in the area.

Timeline of incident due to attempted assassination with a chemical substance

This deliberate event illustrates the need for access to and coordination with highly specialized sampling and decontamination personnel and law enforcement/intelligence officials during the response to an event.

This document was prepared by the FEMA Office of Emerging Threats (OET) 21

6. What do These Chemical Incidents Have in Common?

First, time is of the essence.

Appropriate response actions taken in the first few minutes to hours can save many lives.

The individuals in the narratives experienced health effects within minutes to hours of the chemical’s release demonstrating that response actions taken in the first few minutes to hours can save many lives. Early and accurate diagnosis of symptoms can alert responders to an ongoing event. Since prevention is far better than having to respond to chemical exposures, proper planning is essential to allow responders to take advantage of this window of opportunity. Thus, community-specific response guidance must be developed prior to the event.

Communities should assess their local threats and response capabilities during the planning process. The immediacy of health effects resulting from chemical exposures implies that local and state healthcare facilities will be quickly (albeit possibly briefly) overwhelmed with requests for medical treatment. Plans and protocols that contribute to the swift and accurate diagnosis of affected individuals and identification of the causative substance will help alleviate strains on first responders and healthcare providers. The short response window also means that response activities will often be led in large part by state, local, tribal, and territorial (SLTT) officials;

communities should therefore plan to support these offices.

Second, uncertainty always exists.

Useful, reliable information to guide decisions is often not available in the initial stages of a response.

Useful, reliable information to guide decisions is often not available during the initial stages of a chemical incident response, which is particularly problematic given the often time-urgent nature of key response decisions. Responders should expect that situational awareness will be rudimentary and information gathering will be ongoing during the response, but even interim data can feed into decision-making. During the planning process, planners should identify the minimum information required to make key response decisions and determine how to obtain this information quickly.

Default response actions should be developed to use when event-specific information is not available. Carefully crafted communications are key to maintaining public calm, trust and cooperation.

Many response activities can proceed in the absence of detailed information about the responsible chemical substance(s). However, when responders are forced to act without full knowledge of the identity of the substance(s) involved or the extent of contamination, they, the community, and the environment are at risk of continued exposure. Again, the rapid and continuous gathering and sharing of information can help mitigate this risk.

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Third, recovery is complex.

Actions taken during the response have the potential to significantly reduce the time and cost spent recovering from the event.

Actions taken during the response to a chemical incident have the potential to significantly reduce the time and cost spent recovering from the event. For example, actions taken to minimize spread of contamination can limit the area that must be decontaminated and help protect critical infrastructure. Similarly, early efforts to identify exposed individuals can facilitate long-term medical care and monitoring. Therefore, both response and recovery needs should be considered while developing regional response plans. While SLTT officials in large part lead immediate response activities for chemical release incidents, federal officials may play larger roles in later recovery and remediation activities.

7. Common Characteristics of Chemical Incidents Harm to human health, infrastructure and the environment may occur in the immediate aftermath of a chemical incident, regardless of whether it was accidental or the result of a malicious act. The geographic area affected by an incident may be large and consequences may occur in multiple communities as contamination is moved by air or water. Cross-jurisdictional collaboration and coordination among multiple agencies at all levels is key to effectively responding to and recovering from a chemical incident.

Common characteristics of chemical incidents

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The narratives presented above were chosen to illustrate these and other important and common characteristics regarding the recognition of, response to, and recovery from different types of chemical events. For example:

Decisions must be made in the face of uncertainty. Uncertainty comes from the unexpected, such as when the chemicals stored at a flooded plant would combust, from misinformation, such as the inaccurately identified chemical leak that a local water treatment plant initially thought it could remove, and from a lack of information, such as the lack of information on the substance that was causing illness observed in farm workers or schoolchildren. In all of these cases, initial steps had to be taken to respond and reduce further risk to the public without knowing the full context of the incidents. Uncertainty will be present during planning as well; development of plans that have the flexibility to address a wide variety of scenarios is key to rapid response initiation.

First responders can become exposed. Concerns abound regarding the potential for exposure to illicit drugs during the course of their work among first responders. Following the attempted assassination in the UK, multiple first responders became contaminated with and suffered health effects from the at-the-time unknown chemical substance, because quick responses were required in the absence of information regarding the cause of the targets’ illnesses. In another example, first responders fighting the crude-oil fed blaze caused by a train derailment were forced to take short shifts to avoid falling ill from the toxic fumes emanating from the site.

Interagency cooperation and integrated operations are key to response and recovery efforts. In multiple incidents described, the ability to respond quickly and/or to prevent further illness or spread of contamination required communication and coordination between multiple agencies or organizations. The example of contaminated food demonstrates how public health preparedness plans that include two-way communication between emergency and health departments can facilitate lifesaving activities. For deliberate events and accidents, support of ongoing investigation is essential, and the incident management and investigative efforts must be coordinated. Even actions as seemingly routine as shutting down roads near the site of an incident and providing adequate medical treatment to injured/ill individuals often will require the efforts of multiple responders and offices. To provide adequate capacity, resources may be needed from multiple jurisdictions and/or healthcare facilities.

Communication with the public is vital. The ability to maintain public trust and transmit new information as it is learned as a situation unfolds, with the goal of reducing risk to the public, rests upon the implementation of appropriate communication strategies. In events that require the public to take protective actions – such as the evacuations/sheltering following flooding of a chemical plant or the rupture of a single tanker car full of chlorine, or the Do Not Use instructions following the contamination a water supply – the timely provision of accessible information from trusted sources is essential for ensuring public cooperation.

Even small events can have large and possibly extended consequences. Following the chemical leak into a waterway and the attempted assassination described, the lives of the public were upended for weeks, local businesses suffered in the aftermath and contaminants were found substantial

This document was prepared by the FEMA Office of Emerging Threats (OET) 24 distances away from the original incident. Meanwhile, the contamination of foods at a single warehouse had the potential to sicken children across an entire state, and the contamination of agricultural workers with pesticide at a single site was enough to overtax local healthcare support capacity.

Large events can have massive and extended consequences. Loss of power and environmental (temperature) control at a flooded chemical plant and the ensuing combustion of hundreds of thousands of pounds of chemicals kept residents out of their homes for more than week. In a prime example, decontamination and reconstruction activities are still ongoing more than five years following the derailment of a train carrying crude oil; cleanup costs have skyrocketed and it is unclear who will ultimately foot the bill.

Common characteristics such as these will appear throughout the Key Planning Factors and Considerations for Response to and Recovery from a Chemical Incident. Keeping them in mind while reading the rest of the document will help guide the development of planning and preparedness activities appropriate for each community.

Refer To

Oil and Chemical Incident Annex (OCIA) to the Response and Recovery Federal Interagency Operational Plans (FIOPs) (February 2021)

This information is supplemental to the Response and Recovery FIOPs and other subordinate plans. The OCIA and accompanying documents do not alter or impede the ability of any state, local, tribal, territorial, insular area, or federal agency to execute authorities or meet responsibilities under applicable laws, executive orders, and directives.

8. Barriers to Preparedness for Chemical Incidents Industrial chemicals, chemical facilities, chemical waste disposal, and chemical disasters have had disparate, historic and ongoing impacts on underserved populations, including populations of color.

Historically burdened communities are often located in higher-risk areas near these sites, and also are often disproportionately impacted by chemical incidents. With this knowledge, and pursuant to the 2021 Executive Order On Advancing Racial Equity and Support for Underserved Communities Through the Federal Government (EO 19385),…