The recent string of chemical fires has shed light that first responders may have little or no information about on-site chemicals when responding to an incident at a facility. While this problem is not uncommon, department leaders do have options to address this lack of information sharing. Depending on the context, relationships with a chemical facility’s emergency teams can be improved by expanding disaster plans, participating in the Local Emergency Planning Committees, and if the facility is a terrorism risk, increase the use of the Department of Homeland Security’s (DHS) IP Gateway for secured chemical sites.
Local Emergency Planning Committee (LEPC)
Information on chemical sites can also be conveyed through active participation in the community’s LEPC. A recent study showed an interesting paradox: the most successful LEPCs cited local government support as the most significant contributing factor, but it also stated that low participation (including local governments) was the greatest obstacle to success. Local fire departments’ involvement is a vital component of getting their members chemical information and establishing relationships with the chemical sector.
First Responder and Industry Collaboration
The American Chemistry Council’s Responsible Care program, Society of Chemical Manufacturers and Affiliates (SOCMA), and the American Petroleum Institute (API), may be an avenue for better information exchange. Their members are always continuously improving relationships with local emergency responders. Find out if a facility participates and leverage these more.
The OSHA Hazard Communication Standard has requirements on Safety Data Sheets (SDS). This is one area where the local responders can give input to the industry so that the SDSs are updated and readily available to responders in an emergency. This leads to the right information at your fingertips when you need it.
The OSHA’s Process Safety Management standard has requirements on emergency response for facilities subject to it. If the facility in your local area is a process safety management (PSM) facility, then it’s an opportunity to partner together before an emergency. EPA’s EPCRA (Emergency Planning and Community Right-to-Know Act) was created to help communities plan (as you all know). There is a lot that can be done under EPCRA to aid local responders.
Infrastructure Protection (IP) Gateway
The U.S. Government Accountability Office (GAO) also identified the lack of chemical information for firefighter and other emergency personnel for high-risk chemical facilities.[i] Among other things, the DHS’ Chemical Facility Anti-Terrorism Standards (CFATS) program shares protected on-site chemicals through the IP Gateway, which may not be reported to either LEPCs or emergency responders. However, the GAO also found that the IP Gateway was not widely used at the local level mainly because local agencies did not know about the program and/or DHS did not sufficiently promote access to the IP Gateway due to a large number of emergency personnel across the country. To help properly prepare our emergency responders, DHS has updated its website to offer information about how to engage the IP Gateway program and provides other actions being taken to share information.
To increase the chemical information available to firefighters requires a combined effort by fire departments to work directly with chemical facilities on disaster planning; additional support by elected officials and department heads to increase or mandate participation LEPCs; and communication with DHS on accessing and utilizing the IP Gateway for high-risk chemical facilities. More research and discussion are needed to find the right combination of efforts to communicate chemical information during emergencies, but these actions can mitigate the problem of leaving our firefighters and fellow emergency responders with little or no information.
Bryan Sky-Eagle, JD, CFO, is a district chief with the Houston Fire Department with 20 years of experience. Sky-Eagle is also a practicing attorney with 15 years in labor and employment law. He also serves as a member of the IAFC’s Terrorism and Homeland Security (T&HS) Committee. You can connect with on Twitter at @BSkyEagle.
[i] United States Government Accountability Office. Critical Infrastructure Protection, DHS Should Take Actions to Measure Reduction in Chemical Facility Vulnerability and Share Information with First Responders. GAO-18-538. August 2018.