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Is it Worth the Risk?

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July 10, 2023
Tom Miller, TRANSCAER West Virginia State Coordinator

First Responders are used to facing and taking risks every day – that is a part of the job description. We use our knowledge, training, and experience to make critical decisions in often challenging situations. We often rely on communication centers, on-scene resources, and other available intelligence to help us make those decisions. Effective risk assessment, management and planning can help prevent bad situations from getting worse and decrease the threat potential (life, property, environment) posed by an event. 

Many fire departments, both career and volunteer, do pre-fire planning but many fail to do comprehensive risk assessments or further all-hazards planning, including detailed hazardous materials risk assessments. Having travelled the country doing training, I am often told that: (a) “…it takes too much time and resources”, or; (b) “…there are too many hazardous chemicals to worry about detailed planning”, or; (c) “…we just deal with it as they happen.” From time to time when Tier II forms are received, they will be filed in a notebook or scanned into a system and then ignored unless there is an incident. Sometimes, alarm assignments are designed and noted but not fully tested or evaluated in drills or exercises to help ensure efficacy or if the right amount and type(s) of resources are being assigned to the potential risk(s). There is often heavy reliance on industrial response teams or regional assets without any true assessment or knowledge of their capabilities and/or limitations. Facility or site tours could help augment pre-incident knowledge but are often “best behavior” situations with no real “kicking the tires” capability assessments being conducted. Integral training like National Incident Management System (NIMS) or spill/leak drills are often conducted in a compartmentalized format as opposed to being truly open and integrated with all of the key players being involved in the learning process. The premise is that, in theory, it will all come together when and if there is an incident.

Training models across the nation are moving to a risk-based response. To prepare for that mode, the Authority Having Jurisdiction (AHJ) needs to conduct a risk assessment. That risk assessment can vary from a focused approach to a broad based, all-hazards type of assessment. The AHJ may conduct an internal risk analysis or may contract a qualified 3rd party to perform the assessment. The Local Emergency Planning Council (LEPC) may challenge members to submit their own facility specific risk assessments and then compile them into a broader area wide or regional document. There is a great deal of latitude in how risk assessments are done and what elements need to be included. There are resources that can assist the AHJ in the process such as NFPA 475 “Recommended Practice for Organizing, Managing, and Sustaining a Hazardous Materials/Weapons of Mass Destruction Response Program, 2022 Edition” and FEMA’s “Threat and Hazard Identification and Risk Assessment (THIRA) and Stakeholder Preparedness Review (SPR) Guide- May 2018”, or NIOSH’s Current Bulletin 69: “NIOSH Practices in Occupational Risk Assessment – 2020 Edition.” Each of these, and many other resources can help your and your organization get started on the path to conduct a valid hazardous materials risk assessment.

When conducting your risk assessment(s), there are core elements that should be included in any model that you choose to utilize, they are:

  1. Involve and/or engage key stakeholders – work to build partnerships and collaboratives.
  2. What products or chemicals might we be dealing with and in what quantities?
  3. What is the specific life, health, environmental, and/or safety risks associated with those chemicals or products?
  4. What type(s) of environment(s) might we face those risks – i.e. transportation (highway, rail, marine, air, etc.), fixed facility, or other?
  5. What resources are available currently and what will be needed should we be faced with an incident involving those chemicals and/or materials, i.e. equipment, manpower, training, support (mutual or automatic aid), etc.?
  6. How do we get from our current response posture to a needed or a desired response posture?

The risk assessment, once completed, is only effective if it is then taken and incorporated into future planning. That incorporation includes, but is not limited to training, procurement, exercise planning, mitigation strategies, potential contingencies, and budgets. As with all planning, often times there will be cost to benefit comparisons, “if then analyses”, and, of course, “acceptance of the risk.” Due regard and caution should be used when adopting an “acceptance of the risk” posture as that may open up a host of other legal and/or liability issues for the AHJ.

With a more specific focus on training, there are lots of both public sector and private training resources available to help you and your AHJ become better prepared for tackling the potential risks that you may face. TRANSCAER is one of those resources but so are State Fire and Hazmat Training programs, the National Volunteer Fire Council’s (NVFC) Partners In Training (P.I.T) Crew Training program, IAFC Haz Mat Training programs and conferences, IAFF Haz Mat Training programs, and a host of others. Training is available for specific products, containers, and practices such as decontamination and mitigation. Courses are available in a host of different formats from on-line, to blended learning, to all hands-on. It is important for the AHJ to properly vet the training and to be able to attach the proposed training to the mitigation of a specific risk or a set of risks. Part of the training program should include some type or form of drill or exercise to adequately assess the efficacy and impact of the implemented training program. “Did the training accomplish what we were hoping to achieve?

We all know that “Rome wasn’t built in a day…” and the risk assessment process will take time.  Take a 30,000-foot view of the risk posed within your AHJ and find a starting point. Go from what you know to what you need to know and then on to what you would like to know. Understand and accept that conducting risk assessments is an ongoing and not a static process. At the end of the day, not conducting risk assessments is simply not worth the risk.


About the Author:

Tom Miller is a 38-year veteran of the West Virginia fire service.  He is a Pro-Board-certified Fire Instructor III and a Hazardous Materials Technician & Incident Commander.  Tom has been an Adjunct Instructor with West Virginia University Fire Service Extension since 1990 and has written numerous courses on specialized topics in emergency response and delivered them across the country.  He is the West Virginia Director to the NVFC and the TRANSCAER Coordinator for West Virginia.  Tom serves as the Chair of the NVFC’s Hazardous Materials Response Committee and its Pandemic Response Task Group, as well as serving as an SME on various other Technical Committees and organizations including API, PHMSA, the DoD, and the National Security Council.  Tom also serves on the Homeland Security; Standards & Codes; and Health, Safety & Training committees of the NVFC.  He is a Principal on the NFPA 470 Technical Committee.  Tom has a Bachelor of Science degree from West Virginia State University and a Master of Arts degree from the School of Education and Professional Studies at Marshall University.