Attachment_33 _Chemical_Surety_Standards_Document.pdf

Training Delivery Services

Attachment 33

Chemical Surety Program Standards Document

Federal Emergency Management Agency

(FEMA)

Center for Domestic Preparedness

(CDP)

Chemical, Ordnance, Biological, Radiological Training Facility

(COBRATF)

Chemical Surety Program Standards Document

(CSPSD)

EFFECTIVE DATE: August 15, 2014

Charles M. King Superintendent Center for Domestic Preparedness

Date: _____________

Kathleen Fox Deputy Assistant Administrator National Preparedness Directorate

Date: ______________ i

Foreword

The COBRATF was built in 1986 by the United States (US) Department of Defense (DOD), US Department of the Army (DA), and operated as the Chemical Defense Training Facility (CDTF) by the DA at Fort McClellan, Alabama. Fort McClellan was closed in 1999 as a result of a base realignment and closure action. Section 1065 of the National Defense Authorization Act (NDAA) for FY 2000 authorized the transfer of chemical nerve agent from DOD to the US Department of Justice (DOJ) after the Secretary of Defense certified DOJ’s readiness to receive chemical nerve agent. It also required the Secretary of Defense to report annually regarding the disposition of chemical nerve agents transferred under this section. Sections 430 and 1511 of the Homeland Security Act of 2002 transferred the authority to receive and store chemical nerve agent from the Attorney General to the Secretary of Homeland Security.

Subsequent internal delegations of authority within the Department of Homeland Security (DHS) have assigned responsibility for these functions to the FEMA National Preparedness Directorate (NPD) of which the CDP is a component.

The DHS and DOD entered into a Memorandum of Understanding (MOU) to establish the conditions and procedures for which DOD will transfer chemical nerve agents and provide technical expertise and training support related to DHS’ mission to coordinate the Nation’s preparedness efforts for acts of terrorism. The MOU supports the DHS mission, including emergency responder training, to prevent, deter, interdict, and respond to terrorist acts involving toxic chemical weapons grade chemical and biological agents, radiological materials, and hazardous materials.

FEMA and the CDP developed Interagency Agreements (IAAs) with DOD components Army Materiel Command (AMC) and Edgewood Chemical Biological Center (ECBC) in order to execute the requirements established within the DOD and DHS MOU.

The DOD’s/DA’s requirements for a Chemical Surety Program (CSP) are detailed in directives, regulations, and pamphlets. The DHS/FEMA has no such overarching documentation. While DHS/FEMA is not bound by DOD/DA requirements, this CSP is patterned closely after the DOD/DA CSP. This document, coupled with supporting documents identified within, describes the overall requirements that structure the DHS/FEMA/CDP CSP.

The CDP’s CSP is designed to ensure safe handling and storage of chemical nerve agents GB and VX, ensure the reliability of personnel having access to chemical nerve agents, and to properly safeguard against theft, loss, diversion, or unauthorized access or use of the chemical nerve agents.

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Table of Contents

Foreword ................................................................................................................................................................. i

CHAPTER 1: GENERAL INFORMATION ..................................................................................................... 1-1

CHAPTER 2: PERSONNEL RELIABILITY ................................................................................................... 2-1

CHAPTER 3: CHEMICAL NERVE AGENT SECURITY ............................................................................. 3-1

CHAPTER 4: ENVIRONMENTAL, SAFETY, AND OCCUPATIONAL HEALTH .................................... 4-1

CHAPTER 5: QUALITY MANAGEMENT ...................................................................................................... 5-1

CHAPTER 6: CHEMICAL NERVE AGENT ACCOUNTABILITY ............................................................... 6-1

CHAPTER 7: CHEMICAL NERVE AGENT EMERGENCY RESPONSE ................................................ 7-1

APPENDICES .................................................................................................................................................... 7-1

1-1

CHAPTER 1: GENERAL INFORMATION

1-1. Purpose

In accordance with the MOU between DOD and DHS, the CSPSD establishes requirements and assigns responsibilities for the CDP’s CSP, ensuring supporting documentation and standard operating procedures properly safeguard against theft, loss, diversion, or unauthorized access or use of chemical nerve agents.

1-2. Applicability and Scope

This document applies to all CDP Federal and contract employees.

1-3. Supersession

This document supersedes the CDP COBRATF Standards Document for Use of Chemical Agents, September 2010.

1-4. Authorities/References

Required and related publications are listed in Appendix A.

1-5. Policy

A. Chemical nerve agents are transferred to CDP from DA under the provisions of the MOU between DHS and DOD.

B. Third party oversight and technical assistance is provided by AMC and ECBC under the provisions of IAAs.

C. The CDP will maintain a CSP consisting of the following functional areas:

1. Personnel Reliability

2. Chemical Nerve Agent Security

3. Environmental, Safety, and Occupational Health (ESOH)

4. Quality Management

5. Chemical Nerve Agent Accountability

6. Chemical Nerve Agent Emergency Response

1-6. Acronyms and Definitions

A glossary of terms and acronyms is listed in Appendix B.

1-2

1-7. Responsibilities

A. The Superintendent is responsible for:

1. Ensuring adequate resources, management controls, safe handling and operational procedures are in place to safeguard against theft, loss, diversion, or unauthorized access or use of chemical surety material;

2. Serving as the adjudicating official rendering final decisions on all Contractor/Employee Reliability Program (CERP) appeal actions. The final decision cannot be contested.

B. The Director of Business Operations is responsible for providing oversight to the budget, information technology, physical security, information security, personnel security, environmental, safety, and logistical support.

C. The Director of Special Programs is responsible for administering the CERP as defined in the CERP Manual.

D. The Director of Training and Education (T&E) is responsible for:

1. Developing, implementing, and managing all COBRATF documents and Standard

Operating Procedures (SOPs);

2. Certifying the CERP Certifying Official and Alternate Certifying Official;

3. Preparing and implementing the CERP.

E. The Assistant Director (AD) of the COBRATF is responsible for:

1. Providing Federal management and oversight for all COBRATF activities;

2. Serving as Certifying Official for all personnel in the CERP.

1-8. Reporting Requirements

A. A chemical event may occur at any time as a result of natural forces, civil disturbance, a major accident or incident, or deliberate act. A Chemical Accident (CA) is a chemical event resulting from non-deliberate acts where safety is of primary concern. A Chemical Incident (CI) is a chemical event resulting from deliberate acts (terrorism or criminal) where security is of primary concern. Chemical events will be reported to ECBC and FEMA through operational channels from the CDP Operations Center.

B. Chemical agent monthly consumption reports and semiannual 100% physical inventory reports will be sent to the DOD Schedule 1 Accountability Manager as required by the MOU between DOD and DHS.

C. Inspection Coordination/Reports:

1-3

1. DHS will coordinate no less than 60 days’ advance notice of inspections with DOD.

2. DHS will maintain the inspection reports.

D. Request for chemical agents will be made to the Office of the Assistance Secretary of Defense IAW the MOU between DOD and DHS.

1-9. Forms Prescribed

See applicable supporting plans and SOPs for required forms.

1-10. Questions

The Chemical Surety Officer (CSO) or AD COBRATF will address questions concerning the CDP’s CSPSD.

2-1

CHAPTER 2: PERSONNEL RELIABILITY

2-1. The CDP will establish and implement a Contractor/Employee Reliability Program (CERP) that ensures each individual who has authorized access to chemical nerve agent attains and maintains the highest reliability standard. Minimum standards/requirements for the CERP are identified in this section. The implementation and maintenance of the CERP will be defined in the CERP Manual which will include procedures for:

A. Identifying positions with duties that afford access to chemical surety materials;

B. Designating officials who will certify the reliability and suitability of individuals for the

CERP;

C. Screening, evaluating, and certifying individuals for the CERP;

D. Continuing evaluation of individuals enrolled in the CERP;

E. Taking actions regarding an individual’s participation in the CERP.

2-2 Pre-placement screening and evaluation of candidates for the CERP will include:

A. An initial interview to inform and instruct the candidate regarding significance of work, importance of reliable performance, CERP standards; individual’s ability to wear personal protective equipment (PPE); random drug testing; safety and security considerations; and continuing evaluation.

B. A medical examination, to include a category-specific nerve agent medical surveillance examination, respirator clearance, urine drug screen, and PPE evaluation with regard to the individual’s documented ability to wear required PPE.

C. Verification of U.S. citizenship.

D. Local and national background checks. The minimum personnel security investigation required for Federal civilian and contractor personnel in a CERP is a Single Scope Background Investigation.

2-3 Disqualifying Factors. The following factors are absolute disqualifiers for enrollment of individuals in the CERP:

A. Any record of felony convictions.

B. More than two (2) misdemeanor convictions within the last seven (7) years (excluding minor offenses under a $750.00 fine).

C. Current or pending charges for any felony criminal offense.

D. Use of narcotics, marijuana, cocaine, PCP, LSD, "designer" drugs, or other controlled substances (including amphetamines or barbiturates) not prescribed by a physician

2-2 within the past seven (7) years.

E. Verified positive urine drug screen or “refusal to test”. See Section 2-4 below, for disqualification consideration.

F. Involvement in trafficking, cultivation, processing, manufacturing, or sale of any narcotic or illicit drug (including marijuana or cannabis-based products).

G. Current diagnosis by a physician (Substance Abuse Professional) as alcohol or drug dependent (as defined in the Diagnostic and Statistical Manual of Mental Disorders (DSM) (current version).

H. Impaired ability to safely wear required PPE.

2-4 Disqualifying Considerations. The following factors are considered and may be the basis for disqualification from participation in the CERP:

A. Current diagnosis of alcohol abuse or occurrence of an alcohol-related incident within the past seven (7) years.

B. Inappropriate attitude, conduct, or behavior. In determining reliability, the Certifying Official will conduct a careful and balanced evaluation of all aspects of an individual.

Specific factors to consider include, but are not limited to the following:

1. Negligence or delinquency in performance of duty.

2. Conviction of, or involvement in, a serious incident indicating a contemptuous attitude toward the law, regulations, or other duly constituted authority. Serious incidents include, but are not limited to assault, sexual misconduct, contempt of court, making false official statements, habitual violation of traffic laws, and domestic violence.

3. Poor attitude or lack of motivation. Poor attitude can include arrogance, inflexibility, suspiciousness, hostility, or flippancy toward CERP responsibilities and extreme moods or mood swings.

4. Aggressive or threatening behavior toward other individuals.

5. Attempting to conceal potentially disqualifying information (PDI) from the Certifying Official through false or misleading statements, or by willfully neglecting to report current PDI.

6. Serious progressive illness.

7. Financial irresponsibility.

8. Attempted suicide.

9. Any medical condition, medication use, or medical treatment that may reasonably result in an altered level of consciousness, impaired judgment or concentration, or impaired ability to perform the physical requirements of the duty position.

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10. Abuse of drugs/substances more than seven (7) years before the initial CERP interview.

11. Use of another’s prescription drugs, or in an effort to self-medicate, inadvertently or deliberately exceed the recommended safe dosage on the medication’s packaging of over the counter substances, or who improperly use their own prescribed medications.

2-5 CDP employees will protect Personally Identifiable Information (PII) and medical health information in accordance with the Health Insurance Portability and Accountability Act of

1996 (HIPAA).

2-6 The Certifying Official will complete the following within 90 days of appointment:

A. Review all records to include personnel, CERP, and medical;

B. Review and discuss all documentation addressing Potentially Disqualifying Information

(PDI) with the outgoing Certifying Official;

C. Conduct interviews with each CERP individual.

2-7 The CERP Administrator will:

A. Provide administrative oversight and assistance to the Certifying Officials;

B. Maintain the CERP records;

C. Publish the CERP Duty Roster;

D. Maintain and publish the CERP Manual.

2-8. References:

A. Health Insurance Portability and Accountability Act of 1996 (HIPAA)

B. Privacy Act of 1974

C. DHS Handbook for Safeguarding Sensitive Personally Identifiable Information

2-9. CDP Supporting Documents:

A. CERP Manual

3-1

CHAPTER 3: CHEMICAL NERVE AGENT SECURITY

3-1. The CDP will implement security measures commensurate with standard personnel, information, and physical security practices to ensure the chemical surety material is safeguarded to prevent theft, loss, seizure or unauthorized access, use, or diversion.

3-2. The CDP is subject to complying with the Chemical Facilities Anti-Terrorism Standards

(CFATS) Risk-Based Performance Standards (RBPS); therefore, the CDP will prepare a Security Vulnerability Assessment (SVA), which identifies facility security vulnerabilities, and develop and implement a Site Security Plan (SSP), which includes measures that satisfy the RBPS.

3-3. The CDP will complete the online questionnaire using DHS’s Chemical Security

Assessment Tool (CSAT) to determine the chemicals of interest and associated security measures required to maintain a DHS approved SSP.

3-4. The CDP will comply with requirements to manage Chemical-Terrorism Vulnerability

Information (CVI), which is the information protection regime authorized by DHS to protect from inappropriate public disclosure any information developed or submitted pursuant to Section 550 of the Homeland Security Appropriations Act of 2007. This includes information that is developed and/or submitted to DHS pursuant to the CFATS regulation which implements Section 550.

3-5. Chemical facilities expect that the information provided to DHS will be protected from public disclosure or misuse. The DHS expects individuals in possession of CVI to safeguard it with equal care. Following the requirements in 6 Code of Federal Regulations (CFR) §

27.400 and the guidance in the Safeguarding Information Designated as CVI Revised Procedural Manual ensures sensitive information about the Nation's high-risk chemical facilities is safeguarded.

3-6. In addition to measures that satisfy the RBPSs, the SSP will consider and include:

A. Threat analysis. Review of the Annual Federal Bureau of Investigation Vulnerability Assessment (VA). Consider local threat assessment based upon intelligence and law enforcement sources. The Supervisory Security Specialist will make an evaluation of threats from terrorism, espionage, theft, and vandalism. The threat analysis should consider any recent security incidents (chemical or non-chemical) affecting the facility/mission. The threat analysis shall be updated at least annually or more frequently if changing conditions or activities warrant modifications.

B. Limited and exclusion areas.

1. The Restricted Area (RA) is the area inside the surety fence.

2. The Limited Area (LA) is a restricted area that surrounds one or more exclusion areas. The laboratory within the COBRATF Training Building is the LA when chemical agents are secured in the vault.

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3. The Exclusion Area (EA) is the restricted area immediately surrounding the chemical agents, i.e., the vault in which chemical agents are contained and secured.

4. A Temporary Exclusion Area (TEA) will be designated when the chemical nerve agent is removed from the vault/secure chemical nerve agent storage container. In the training building, this area will be working areas in the chemical nerve agent laboratory. During training operations, the chemical agent container used to transport the agent will be designated as the TEA and must be under the physical control of at least two CERP certified persons in accordance with the two-person rule. The TEA is terminated when the chemical surety material in the chemical agent container has been expended or neutralized.

C. Equipment and devices to detect or delay intrusion. Type and construction of storage areas/containers [walls, windows, openings, ceilings, and floors of such areas, and containers (provide estimated delay time for forced entry)]; security lighting (types, locations, inspections and maintenance, emergency actions for power failure);

protective alarm sensors (types, locations, monitoring and use, tests, inspections and maintenance, records, and logs, actions by security forces or local police and designated facility personnel when alarms occur or when the system, or any part of the system, becomes inoperable); duress systems, warnings and alarms, power sources (types and capabilities); communications systems (types, locations, use, tests, inspections and maintenance, records, and logs); locks and keys [types, use, locations, controls, logs, and accountability (two-person control keys)]; perimeter boundaries with type, construction, gates (type and hours of operation); and delay systems (i.e., Jersey barriers, gates with types and locations).

3-7. References:

A. CFATS RBPS

B. CSAT

C. 6 CFR § 27.400

D. Safeguarding Information Designated as CVI Revised Procedural Manual

3-8. CDP Supporting Documents:

A. CDP SVA

B. CDP SSP

4-1

CHAPTER 4: ENVIRONMENTAL, SAFETY, AND OCCUPATIONAL HEALTH

4-1. The CDP will provide a safe and healthful work environment for federal employees, contractors, participants, and visitors. The CDP will operate in an environmentally responsible and compliant manner. In order to meet these commitments, the COBRATF will establish, implement, and maintain ESOH systems and programs patterned after the “Plan-Do-Check-Act” method, an iterative four-step management method used for the control and continuous improvement of processes and products, to include:

A. Safety and Occupational Health (SOH) Program. The SOH program is two-fold with one part focused on a systems approach to safety and occupational health, and the other focused on individual patient care. These components are communicated in the CDP Safety and Occupational Health Manual.

1. The systems component is based on the American National Standards Institute

(ANSI)/American Industrial Hygiene Association (AIHA) Z10 Voluntary Consensus Standard (American National Standard – Occupational Health and Safety Management Systems). The CDP will establish a written policy which includes the following commitments:

a. Protection and continual improvement of employee health and safety;

b. Effective employee participation;

c. Conformance with CDP’s unique health and safety requirements;

d. Compliance with applicable occupational health and safety laws and regulations.

2. The patient care component utilizes a multi-disciplinary team of heath care professionals [(physicians, physician assistants, registered nurses (including nurse practitioners)] and other health care providers (licensed practical/vocational nurses, emergency medical technicians/paramedics) all operating within their scope of practice (credentials, responsibilities, and legally authorized practice). The patient care component detailed in the CDP Safety and Occupational Health Manual includes:

a. Medical screenings and examinations for fitness for duty including the ability to wear required personal protective equipment and clothing under the conditions expected;

b. Relevant medical surveillance for signs and symptoms of exposure to the physical (noise, heat, etc.), chemical, biological, and radiological hazards;

c. Initial assessment, field triage, acute injury/illness care, and referral for treatment (if indicated) of any injuries or illnesses related to hazards encountered by the patient in the course of his/her job or training;

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d. Compliance with all applicable state and federal statutes associated with the health care professionals and other health care provider’s scope of practice.

B. Environmental Management Program (EMP). This program is based on DHS and FEMA policies and directives implementing Executive Order (EO) 13148, EO 13423 and EO 13514. This program will help:

1. Minimize how COBRATF operations negatively affect the environment;

2. Comply with applicable laws, regulations, and other environmentally oriented requirements;

3. Continually improve the EMP.

C. Environmental Monitoring. The COBRATF will establish a written environmental monitoring document which considers the below listed factors and selected sample locations at a frequency and calibration level that will enable informed decisions regarding the adequacy of existing exposure controls compared to established exposure guidelines. Following guidance contained in this document will ensure informed decision making regarding removal of items from locations where exposure to liquid or vapor chemical nerve agent may have occurred, and who and under what conditions removed items may be released. This document will include air sampling but may also include surface wipe testing and solid/porous/liquid media testing based on the exposure conditions.

1. Rationale for Sample Location Selection. Due to high toxicity of the chemical nerve agents VX and GB, it is prudent to conduct environmental monitoring at key locations associated with chemical nerve agent training operations. Sample point selection is determined by:

a. The chemical, physical, and toxicological properties of the specific chemical nerve agent;

b. The quantity and quality of chemical nerve agent in use;

c. The exposure controls in place at the use location (engineering, administrative, and personal protective equipment);

d. The route and duration of potential exposure;

e. The potentially exposed population (e.g. workers, general public, etc.).

2. Airborne sampling will comply with the Chemical Agent Standard Analytical Reference Material Quality Assurance Plan (CASARMQAP).

3. Airborne Exposure Limits. For purposes of this document the Airborne Exposure Limits (AELs) established by the Centers for Disease Control (CDC) shall be used as the primary comparison criteria. The table below lists AEL values. In the event that these values are updated, the AD COBRATF will evaluate those changes, and

4-3 make a written determination regarding implementation of the values and the implementation schedule.

Airborne Exposure Limits in mg/m3

Standard Name Population Exposure Scenario VX GB (Sarin)

Immediately Dangerous to Life and Health (IDLH)

CDP staff, contractors, participants

Acute 30 minute exposure

0.003 0.1

Short Term Exposure Limit (STEL)

CDP staff, contractors, participants

Occasional (4x/day) 15 minute exposure

0.00001 (1x10-5)

0.0001 (1x10-4)

Worker Population Limit

(WPL)

CDP staff, contractors, participants

8 hr daily / multi yr time weighted average (TWA)

0.000001 (1x10-6)

0.00003 (3x10-5)

General Population Limit

(GPL)

Civilian general population

24 hr/daily lifetime weighted average

(TWA)

0.0000006 (6x10-7)

0.000001 (1x10-6)

4. Decontamination. Decontamination procedures and a protocol for release of items potentially exposed to chemical nerve agent liquid and/or vapor shall be established by the AD COBRATF.

a. The protocol shall consider the following:

(1) The type and duration of chemical nerve agent exposure (e.g. liquid vs.

vapor, IDLH vs. STEL, etc.);

(2) The level of residual contamination which may be present versus the exposure scenario;

(3) To whom the item is released (e.g. Government vs. public, trained chemical nerve agent worker vs. untrained, etc.).

b. Decontamination procedures will include:

(1) Routine laboratory decontamination;

(2) Emergency/Spill decontamination;

(3) Appropriate and adequate decontaminating material;

(4) Material, instruments, and equipment exposed to liquid chemical nerve agent;

(5) Laboratory specific equipment, glassware, and surfaces;

(6) Personnel decontamination;

(7) Decontamination of waste items;

(8) Decontamination of chemical nerve agent;

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(9) Decontamination of training aid surfaces.

c. The COBRATF operates an incinerator that provides final decontamination and bulk reduction of non-hazardous liquid and solid waste. The incinerator is permitted by the Alabama Department of Environmental Management (ADEM) and is in full compliance with all Federal, state, and local regulations. All hazardous waste will be removed/transferred to a licensed hazardous waste disposal facility.

4-2 References:

A. ANSI/AIHA Z10 Voluntary Consensus Standard

B. ADEM Permit Number 301-0070, Unit Number X001

C. CASARMQAP

D. 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses

E. 29 CFR 1910, Occupational Health and Safety Standards

F. DHS Directive Number: 023-01, Environmental Planning Program

G. DHS Management Directive Number: 023-02, Environmental Compliance Program

H. DHS Directive Number: 025-01, Sustainable Practices for Environmental, Energy and

Transportation Management

I. DHS Handbook for Safeguarding Sensitive Personally Identifiable Information

J. EO 13148, Greening the Government Through Leadership in Environmental

Management

K. EO 13423, Strengthening Federal Environmental, Energy, and Transportation

Management

L. EO 13514, Federal Leadership in Environmental, Energy, and Economic Performance

M. Federal Register, Department of Health and Human Services, Mandatory Guidelines for

Federal Workplace Drug Testing Programs

N. DHS Handbook for Safeguarding Sensitive Personally Identifiable Information

O. HIPAA of 1996

P. Privacy Act of 1974

Q. MOA between CDP and Regional Medical Center of Jacksonville

R. MOA between CDP and Stringfellow Memorial Hospital

4-5

S. MOA between CDP and Northeast Regional Medical Center

T. 2003 Federal Register. Volume 68, No. 196. October 9, 2003: Department of Health and Human Services (DHHS) Centers for Disease Control and Prevention (CDC) Final Recommendations for Protecting Human health from Potential Adverse Effects of Exposure to Agents GA (Tabun), GB (Sarin), and VX

U. CDC, 2003. Federal Register. Volume 68, No. 196. October 9, 2003: Department of

Health and Human Services (DHHS) Centers for Disease Control and Prevention (CDC); Final Recommendations for Protecting Human health from Potential Adverse Effects of Exposure to Agents GA (Tabun), GB (Sarin), and VX, pp 58348-58351.

4-3 CDP Supporting Documents:

A. CERP Manual

B. CDP Safety and Occupational Health Manual

5-1

CHAPTER 5: QUALITY MANAGEMENT

5-1. Quality management is conducted using the Total Quality Management (TQM) approach defined in the International Organization for Standardization (ISO) 9001 series of standards. The CDP will use the process management model to ensure compliance to ISO 9001 and maintain certification to the CASARMQAP.

5-2. The Director, T&E will publish a COBRATF Quality Manual (QM) in support of the CDP’s

Quality Directive. The Director, T&E will ensure the QM is reviewed annually.

5-3. The QM will include the following:

A. The scope of the quality management system, including justifications for any exclusion(s);

B. Reference to the documented procedures required to facilitate an effective quality management system;

C. A description of the interaction between processes of the quality management system.

5-4. The AD COBRATF is designated as the Quality Management System Representative.

5-5. The AD COBRATF will publish quality management procedures and quality control checks for operations, procedures, and processes.

5-6. References:

A. ISO 9001

B. CASARMQAP

5-7. CDP Supporting Documents:

A. CDP Quality Directive CDP 540-1-00

B. CDP COBRATF Quality Manual

6-1

CHAPTER 6: CHEMICAL NERVE AGENT ACCOUNTABILITY

6-1. The CDP will establish and implement inventory management procedures for chemical agent that ensures agents are maintained under a system of records that provides full authorized accountability and tracking from acquisition through use, destruction, or transfer.

The procedures will maintain a continual measured value of the amount of each chemical agent on hand and agent consumed in preparation for and during training. The minimum standards/requirements for inventory management are identified in this section. The implementation procedures and maintenance inventory management will be defined in a written document which will address/define at a minimum:

A. Processes, to meet requirements in the MOU between the DHS and the DOD, for:

1. Requesting chemical agents from and providing funding to DOD;

2. Providing to DOD, a list of personnel authorized to receive chemical agents;

3. Preparing and submitting monthly chemical agent consumption/inventory reports;

4. Performing and reporting the results of semi-annual/annual 100% physical inventory of all chemical agents (June and December each calendar year) to DOD.

B. Definition of program roles, responsibilities, limitations, and authorities for all personnel accessing/handling chemical agents; generating program supporting records/reports;

documenting agent use; and performing inventories per documentation.

C. Procedures to record, document (with defined QA/QC checks) the storage, issue, receipt, destruction, and disposal of chemical agents.

D. Prescribed inventory management forms and supporting records for the purposes stated in Paragraph 6-1.

6-2. The Accountable Officer will prepare and maintain the inventory management procedures to account for neat chemical agent in a manner that generates a traceable audit trail to maintain a continual measured value of the amount of chemical agent on hand and consumed in preparation for and during training. The Accountable Officer will be made responsible for reporting agent utilization based on the MOU between DOD and

DHS/FEMA.

6-3. References:

A. MOU between DHS/FEMA and DOD

B. IAA between CDP and ECBC

7-1

CHAPTER 7: CHEMICAL NERVE AGENT EMERGENCY RESPONSE

7-1. The CDP will maintain a Memorandum of Agreement (MOA) with local hospitals to ensure adequate medical support is available in the event of a chemical event that exceeds onsite response capabilities.

7-2. The CDP will procure services from the Anniston Police Department and the Anniston Fire

Department for actual emergency response and exercises as outlined in a CDP Statement of Work.

7-3. The COBRATF staff will prepare for and exercise onsite response capabilities at a minimum of once per quarter to measure the ability to respond to, secure, control, and recover from a chemical event or other hazard impacting the facility and surrounding environment. As a minimum, one annual exercise will be coordinated with external support agencies. The exercises will focus on specified tasks, and demonstrate individual and collective response capability. The CSO will conduct after action reviews and document lessons learned to facilitate continual improvement of response readiness.

7-4. The AD COBRATF will publish an Incident Management Manual (IMM) which includes:

A. Reporting

B. Operations

C. Notification

D. Evacuation and Shelter in Place

E. Security Incidents

F. Fire and Smoke Emergencies

G. Safety Incidents

H. Emergency Medical Care

I. Utility Emergencies

J. Communications

7-5. References:

A. Statement of Work for Anniston Police Department and Anniston Fire Department

B. MOA between CDP and Regional Medical Center of Jacksonville

C. MOA between CDP and Stringfellow Memorial Hospital

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D. MOA between CDP and Northeast Regional Medical Center

E. MOU between DHS and DOD

7-6. CDP Supporting Documents:

A. COBRATF IMM

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APPENDICES

APPENDIX A – Authorities/References

ANSI/AIHA Z10 Voluntary Consensus Standard

ADEM Permit Number 301-0070, Unit Number X001

CASARMQAP

6 CFR Part 27, Chemical Facilities Anti-Terrorism Standards

29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illnesses

29 CFR Part 1910, Occupational Health and Safety Standards

CDP COBRATF Incident Management Manual

CDP Quality Directive CDP 540-1-00

CDP COBRATF Quality Manual

CDP Safety and Occupational Health Manual

CDP COBRATF SSP

CDP COBRATF SVA

CERP Manual

CFATS RBPS

DHS Directive Number: 023-01, Environmental Planning Program

DHS Directive Number: 025-01, Sustainable Practices for Environmental, Energy and Transportation Management

DHS Management Directive Number: 023-02, Environmental Compliance Program

EO 13148, Greening the Government Through Leadership in Environmental Management

EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management

EO 13514, Federal Leadership in Environmental, Energy, and Economic Performance

Federal Register, Department of Health and Human Services, Mandatory Guidelines for Federal Workplace Drug Testing Programs

Health Insurance Portability and Accountability Act of 1996 (HIPAA)

IAA between CDP and AMC

IAA between CDP and ECBC

ISO 9001

MOU between DHS and DOD

MOA between CDP and Regional Medical Center of Jacksonville

MOA between CDP and Stringfellow Memorial Hospital

MOA between CDP and Northeast Regional Medical Center

7-2

Public Law 109-295 (DHS Appropriations Act of 2007), Section 550

Safeguarding Information Designated as CVI Revised Procedural Manual

Statement of Work for Anniston Police Department

Statement of Work for Anniston Fire Department

MSDS for VX

MSDS for BG

APPENDIX B – Acronyms and Definitions

AD – Assistant Director

ADEM – Alabama Department of Environmental Management

AEL – Airborne Exposure Limits

AIHA – American Industrial Hygiene Association

AMC – Army Materiel Command

ANSI – American National Standards Institute

CASARMQAP – Chemical Agent Standard Analytical Reference Material Quality Assurance Plan

CDC – Center for Disease Control and Prevention

CDP – Center for Domestic Preparedness

CDTF – Chemical Defense Training Facility

CERP – Contractor/Employee Reliability Program

CFATS – Chemical Facility Anti-Terrorism Standards

CFR – Code of Federal Regulations

COBRATF – Chemical, Ordnance, Biological, Radiological Training Facility

CSAT – Chemical Security Assessment Tool

CSO – Chemical Surety Officer

CSP – Chemical Surety Program

CSPSD – Chemical Surety Program Standards Document

CVI – Chemical-Terrorism Vulnerability Information

DA – Department of the Army

DHS – Department of Homeland Security

DOD – Department of Defense

DOJ – Department of Justice

ECBC – Edgewood Chemical Biological Center

EMP – Environmental Management Program

EO – Executive Order

7-3

ESOH – Environmental Safety and Occupational Health

EA – Exclusion Area

FEMA – Federal Emergency Management Agency

GB – Sarin Chemical Nerve Agent

GPL – General Population Limit

HIPAA – Health Insurance Portability and Accountability Act of 1996

IAA – Interagency Agreement

IDLH – Immediately Dangerous to Life and Health

ISO – International Organization for Standardization

LA – Limited Area

MOA – Memorandum of Agreement

MOU – Memorandum of Understanding

NDAA – National Defense Authorization Act

NPD – National Preparedness Directorate

PDI – Potentially Disqualifying Information

PII – Personally Identifiable Information

PPE – Personal Protective Equipment

QM – Quality Manual

RBPS – Risk-Based Performance Standards

SOH – Safety and Occupational Health

SOP – Standard Operating Procedure

SSP – Site Security Plan

STEL – Short Term Exposure Limit

SVA – Security Vulnerability Assessment

TEA – Temporary Exclusion Area

T&E – Training and Education

TQM – Total Quality Management

TWA – Time Weighted Average

US – United States

WPL – Worker Population Limit

VX – Chemical Nerve Agent