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Volume 31, Issue 1

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By their very nature, responses to emergency incidents, such as chemical spills, fire or other sudden environmental impairments, are performed under less than optimal conditions. As a result of this less than favorable operating environment, the success of such an emergency operation relies on rapid, accurate assessment of the situation, devising an appropriate plan and the successful implementation of that plan. Although many very specific Standard Operating

Procedures (SOP's) have been developed by very knowledgeable groups, the following presentation outlines a simple, yet very flexible management system that is applicable to many, if not all types of situations. The Emergency Systems Operational Control Instructions (ESOCI) Principle' provides a framework from which an incident manager can rapidly, yet simply, gain control of an incident and to assist in providing consistent management of the costs, liabilities, and other associated risks.

In many cases, the first responder will not be a trained environmental, health and safety (EHS) representative of the Responsible Party, (RP), especially to a transportation-type incident. As the RP's representative, it is paramount that a system be in place to get you, the Incident Manager (IM), involved as quickly as possible. For most hazardous material incidents, responders from the public sector (state agencies, fire departments, etc.) or their designated contractors will be the first to arrive on scene. Although most are very qualified in dealing with many of these types of emergencies, the objectives and priorities that these groups must meet may not necessarily be the same or even consistent with your priorities, with the obvious exception of human health and safety. For whatever reason, there are times where the entire response is completely directed by someone not acting on behalf of the RP. Most of the time it is due to the RP's reluctance to get involved, or that the RP thinks that a public agency is responsible for the clean up. The public agencies are tasked with protecting public health and safety, and to this end, if the RP does not effectively respond, the agency has the authority to finish the clean up'.at the RP's expense. However, even under more cooperative circumstances, a first responder may unknowingly exacerbate the problem by performing tasks, which although they are designed to protect public health and safety, may not be necessarily the most effective, in the long run. Examples of such are: washing away the spill, creating large isolation zones, or initiating an evacuation. Even the simple act of doing nothing, which on the surface appears to be a safe decision, can have dire consequences.

Equally important is to evaluate the capabilities experience, judgment, qualifications and authority of who is currently acting as the on-scene coordinator (OSC). Clear and accurate information is crucial during the first hour of an incident. This is where the problems start. The key to managing and thereby reducing your risk is to control the incident early on. The ESOCI Principle' outlines a rapid, standardized approach to assisting the IM in gaining control of the incident.

The basic components of the ESOCI Principle' are:

E- Evaluate
S- Strategize
O- Organize
C- Control
I- Implement

Evaluate:

The evaluation function is primarily concerned with determining the nature and extent of the problem, so that an effective corrective action strategy can be implemented. Understanding the nature of the incident is of the utmost importance, not only for health and safety reasons, but also as to aid in effective resource management. The challenge that faces every Incident Manager is to identify, quantify and prioritize enough pertinent information in a short period of time, such that appropriate protective measures can be taken, with minimal risk to the responders and the general public. This systematic process to identify, analyze and quantify the hazard is known as a risk or hazard assessment. For a chemical release the typical information that may be obtained for such an evaluation is outlined in Table 1.

Table 1: -type of material(s) released

-volume of material(s) released
-chemical and physical properties of chemical(s) of concern
-potential sensitive receptors (sewers, drainage, surface water, etc.)
-potential for fire and/or reactivity (especially water-reactive)
-potential pathways for dispersion (drainage, air) -where will the spill migrate.
-weather (current and near future)
-terrain (gradient, access, etc.)
-present status of incident (what has been done so far)
-population density and type

As previously stated, the hazard assessment is important in order to aid in understanding the nature of the emergency. The IM uses the information in order to create a comprehensive initial action plan, (IAP), to aid in safely and effectively controlling and mitigating the incident. Selected tasks that are part of an IAP are listed in Table 2.


Table 2: -identify immediate protective measures

-setup control zones and limit access
-select appropriate personal protective equipment
-define rescue procedures
-define decontamination procedures
-define site entry procedures
-evaluate the need for evacuation (if necessary)
-perform a vulnerability analysis for other assets at risk
-establish the overall approach or strategy

The appropriate methodology used to gather the necessary information is a function of the incident. It is up to the Incident Manager to determine which methods are appropriate for incident. However, much of the information needed to perform a basic incident characterization can be obtained via a number of methods. For chemical emergencies some potential sources of information are listed in Table 3.

Table 3: -visual (leaks, vapor clouds, labels/placards, other markings)

-visual (number and type of containers)
-visual (physical state, color, odor, sounds, heat, fire, etc.)
-transporter or shipper information (i.e. shipping papers/bills of lading)
-material safety data sheets (MSDS's)
-interviews (driver, on site personnel, etc.)
-direct reading instruments (monitoring)

Another useful source of information is the IAP. Most entities that have the potential to be involved in an emergency type incident, have some form of Emergency Response or Contingency Plan. The plan is designed to outline general procedures to respond to an emergency and will usually have an ' Initial Action' section that is tailored to the specific types of potential emergencies that were pre-identified. This can be an excellent quick outline of the general EHS concerns and the appropriate countermeasures for the specific chemical emergency.

When using any generalized information source, such as placards or the DOT guidebook, the IM must evaluate the information with caution and be cognizant of its limitations. For example: the Class 8 Corrosive placard identifies the cargo as being corrosive, but does not identify if the chemical is an acid or a base. Obviously the course of action would be significantly different.

Even upon the discovery that the chemical is an acid, it is of considerable importance to determine which acid. Again your approach to a hydrochloric acid situation is different that if the acid were hydrofluoric.

Occasionally there may be a tendency to hold up initial containment and control activities if all of the information is not readily available. Although this is a prudent practice for complex incidents or incidents involving very hazardous chemicals, it is not always necessary to wait for a chemical-specific MSDS, or other detailed information, to initiate appropriate actions. As a proactive Incident Manager, you can assess what you know from a myriad of other sources such as placards, tanker types, shipper information, etc. Then with a general knowledge of hazardous materials chemistry you can determine an appropriate, safe action to mitigate the incident. Note, however, that this is a very critical decision, in that the on scene coordinator is balancing a timely and effective mitigation of an incident, against the more typical, and more conservative, approach of delaying any action until more information is obtained. An example of an incident that requires immediate action (by trained personnel) is that of monomers in which the inhibitors have been driven off and the monomer is starting to undergo polymerization. Such reactions under pressure can be a disaster if not attended to in a timely and appropriate manner. However, note that such decisions for more immediate action are not to be taken lightly. Such decisions should only be made by those who possess the appropriate knowledge and experience, and should be applied on a case-by-case basis. Also, do not allow internal and/or external influences, such as corporate politics, media, public pressures, etc. force you into a hurried, unplanned action. You will never have 100% accurate and timely information, however proper hazard identification, although not necessarily 100% complete, and the characterization of the hazard (how will it behave), is paramount for the safety implementation of any response.

Once the hazard(s) has been identified, the next step is to determine the degree of impact the incident has on public health, property and the environment, as well as the risk (or future probability of harm) that the hazard poses.

This includes assessing the potential secondary impacts. Such secondary impacts include:

-contaminated runoff
-vapor generation
-potentially reactive incompatibilities (including water)

Strategize:

Once the incident has been characterized to a sufficient degree, the next step is to determine what is to be done to control and mitigate the incident. The IM is to develop the incident strategy or plan addressing both the strategic goals, as well as defining the tactical objectives necessary to attain these goals. As chemical incidents are very dynamic, the IM should continually monitor and reevaluate the incident. And so as field/site conditions change so will the tactics to mitigate the situation. Therefore, any plan must be flexible enough to be modified to fit the dynamics of the situation. The purpose of this plan is to provide the skeletal framework in which the specific details, appropriate for the hazards of concern, are addressed in a coordinated, focused effort in order to attain the incident objectives.
In general, the IM, acting on behalf of the Responsible Party, has six responsibilities to fulfill, (Table 4).

Table 4: -protect human health and safety

-minimize property damage
-minimize impact to the environment
-determine (and keep within) regulatory compliance
-maintain public relations
-financial responsibility

These responsibilities provide the overall strategic guidance to further develop an appropriate overall plan of attack to address the incident. Once the major objectives have been identified, the IM must use the information obtained during the incident evaluation stage in order to:

-set priorities (in what order or time frame must these tasks be done)
-evaluate available resources (what resources are available in the time frame that is set)
-evaluate available personnel (do we have the manpower to apply to the specific tasks in the given time frame)
-evaluate recommended courses of action

Note that data/information is being gathered continuously and needs to be constantly reviewed so that response tactics, health and safety concerns, and other issues can be modified to address the changing incident conditions.

Once the objectives have been identified for a given set of site conditions, many decisions must be made. These decisions can be grouped into four categories. These categories are:

  • Immediate attention (control)
  • Stabilization of the incident
  • Resolution
  • Site restoration

Table 5 details the typical tasks in each category.

Table 5: immediate attention (control):

-site boundaries/entry procedures
-hazard identification control
-ignition sources
-PPE selection
-rescue procedures

stabilization of the incident:

-firefighting (including BLEVE control)
-release control (including leaks and vapor clouds)
 -decontamination procedures

resolution of the incident:

-product transfer
-clearing wreckage
-decontamination of personnel
-environmental evaluation

restoration of the site:

-site decontamination
-waste management
-public image concerns
-business recovery

Organize:

The organization function is primarily concerned with the effective management of the resources (manpower, equipment and supplies) at an incident. Depending on the size and complexity of an incident, the IM has a number of options that will enable him to successfully manage his resources. The Incident Command System (ICS) provides the IM with a guiding framework from which the response organization can be either ramped up or scaled back in order to best fit the incident at hand. The ICS is a very comprehensive management system that provides a means to coordinate the efforts of individual entities and agencies to effectively work towards a common set of objectives, while maximizing safety and resource accountability. In general , the ICS is composed of eight functions, (Table 6).

Table 6: -Command

-Operations
-Planning
-Logistics
-Finance/administration
-Safety
-Information
-Liaison

ICS, through these major functions, achieves this mission by providing standards and procedures for a variety of concerns. Several of these concerns are outlined in Table 7.

Table 7: -command, coordination and control (span of control -usually 3 to 7 entities)

-unity and chain of command (lines of authority and communication)
-strategic and tactical planning (Incident Action Plan - IAP)
-implementing tactical operations and field reporting
-resource management (manpower, equipment, materials and money)
-procurement and logistics
-integrated communication system
-documentation and information management system
-financial accountability for costs control and claims handling
-safety systems

A key element of the IC system is that it creates a specific chain-of-command in order to coordinate and facilitate decision-making. Furthermore, it defines specific authority and responsibilities for the entities involved thereby ensuring a coordinated effort. The general concept is one of 'the whole is greater than the sum of its parts'.

As previously stated the nature and extent of an incident will generally dictate the size and structure of the response organization. At a minimum there should be someone who assumes the role of the initial on-scene coordinator (OSC). ICS is designed to readily expand from a single on-scene coordinator to a full blown ICS staff if necessary. Many of the incidents we face do not require staffing for all the ICS major functions and it is up to the IC to determine if it is necessary to activate and assign an individual to a specific function. However, if these positions are not filled by an individual, the function itself, and the tasks assigned to that function, remain the responsibility of the Incident Commander (IC), who is, for most incidents, the senior officer of the public response organization (generally the fire department, fire marshal, etc.) This may be modified depending on the type of incident, other response organizations, and other special circumstances

Control:

The main purpose of the control function is to determine if the tasks being performed are appropriate and if they are effective in achieving the objectives set by the IM. The control function addresses a number of concerns such as, but not limited to:

  • Health and safety
  • Resources (manpower and materials)
  • Information
  • Costs (money)

Health and safety control measures should be implemented as quickly as possible in order to:

-help to maintain a safe situation
-reduce the possibility of exposure
-prevent or reduce the detrimental impact of an incident
-minimize transfer of contaminants to clean, unaffected areas and personnel
-to aid in rescue, evacuation and recovery activities

Resources-type control measures enable the IM to better manage the resources (manpower, equipment and materials) assigned to the incident. In the ICS, personnel and equipment are accounted for using a procedure that requires that these resources be 'checked in' by specific individuals, at prespecified locations. All resources assigned to the incident are tracked as to their specific kind or type so that they may be assigned to specific operational units as needed.

Similarly, each resource's operational status, such as in-service, available, or out-of-service is also identified.

The control of information is a very important aspect in the effective handling of an incident. Specific information control issues include:

-Situations/status: all field information is collated and processed by the Planning Section for review by the IC, IM or unified command (UC).
-Media: all information to be released to the media is pre-approved by the IC or UC, and released to the media through the Information Officer.
-Regulatory: similarly, all information to be given to the regulatory agencies is either through the Command function (note that some regulatory agencies may be part of the UCS), or via the Liaison Officer, if the agency is a supporting agency.
-Documentation: all information related to the incident is to be captured and documented.

As with any project, cost control is a major concern. In ICS, the Finance Section handles the tracking of all the costs associated with the incident. On smaller incidents, there may not be a specific section or unit assigned to handle this function, however the importance of cost tracking should not be underestimated. This is not only for the effective use of the financial resources, but also for the insurance claims issues that most undoubtedly will arise as a result of the incident.
Implement :

The implementation function is where it all comes together. As a proactive IM you have:

-evaluated the situation identifying the hazards and their associated risks
-determined and selected a plan of action
-identified the resources needed to perform the tasks at hand
-a management structure to facilitate communication, coordination and information flow
-set up control guidelines to determine the effectiveness of your plan.

As discussed earlier, the IM should have already implemented the applicable Initial Action Plan (IAP) as outlined in the Emergency Response/Contingency Plan. Also as part of the implementation function, the IM should initiate a pre-established process model that provides a framework to aid in successfully completing the operation. One such process system model is the Arrowhead Concept' (Indelicato, 1997). The Arrowhead Concept' is a process model designed for transportation-related hazardous materials incidents, but can easily be applied to non-transportation-related incidents. It provides an integrated modular approach that is comprehensive in scope, yet flexible enough to address many if not all, emergency situations.

The Arrowhead Concept' divides a release incident into two main phases:

Response Phase: The activities performed during this phase are done under urgent, immediate conditions, with little time for any detailed planning. A unique characteristic of this phase, as recommended in the Arrowhead Concept', is that the tasks are performed concurrently (parallel operations), and not in sequence as traditionally done. The stages that comprise the response phase are :

-initial communication and coordination
-release containment and control (abatement)
-regulatory notification and negotiations

Resolution Phase: The tasks performed during this phase are done in a much more ordered sequence and are usually not done under such urgent conditions. This allows for the IM to better evaluate and select 'best-management practice'-type solution. The resolution phase is composed of the following stages:

-clean up and remedial activities
-waste characterization and disposition
-report and closure

Conclusion:

Response to an emergency should not be a 'crisis reaction', but rather a coordinated, proactive effort that successfully meets the goals of:

-closing the incident
-controlling costs
-maintaining regulatory compliance
-minimizing liability

The ESOCI Principle' is inherently simple in its design in order to facilitate it use. It provides a common sense thought process that integrates well-established management principles with standardized procedures for handling emergency incidents. Application of the ESOCI Principle' will enable the IM to maintain a steady course of action through the incident, and to ultimately achieve the strategic goals set for the incident.


Greg Indelicato is the Director of Operations for General Integrations, L.L.C. based in Dallas, TX. General Integration provides Environmental Program Management and Services specifically for emergency operations and remediation technologies for spills and impaired property response, recovery and restoration. This email address is being protected from spambots. You need JavaScript enabled to view it.