TERRORISM AND TURNOUTS: THE CONTROVERSY

EACH DEPARTMENT MUST DECIDE HOW IT WILL RESPOND TO A TERRORIST INCIDENT-A VERY REAL THREAT TODAY-AND THEN TRAIN AND EQUIP ITS PERSONNEL ACCORDINGLY.

BY DAVID F. PETERSON

MOST fire service personnel would agree that haz-mat response experience has benefited their careers. I know I am a better firefighter because of my involvement in haz mat, and it certainly has been very stimulating and thought provoking. But just when you think you have a pretty good handle on things, along comes something that adds another wrinkle to the things you have learned.

In 1999, the United States Army Soldier and Biological Chemical Command (SBCCOM) issued Guidelines for Incident Commander’s Use of Firefighter Protective Ensemble (FFPE) with Self-Contained Breathing Apparatus (SCBA) for Rescue Operations During a Terrorist Chemical Agent Incident. It guides incident commanders on response tactics at chemical nerve agent releases. You can download this 65-page document at www.nbc-prepare.org.

Although this document provides guidance that definitely adds a new wrinkle to tactical response, it is designed for terrorism incidents, which many still believe are haz-mat incidents that involve more victims and have the element of surprise. This information has been available for more than two years, but many responders and fire departments are not aware of it. Those who are aware of it require much time to digest and understand the report. The guide is controversial because it contradicts other documents.

Interestingly, in an informal poll of 120 haz-mat and terrorism response associates I conducted last summer, 65 percent of the respondents would not personally endorse the SBCCOM guidelines, and very few fire departments in the United States have endorsed them. Below I have provided other viewpoints from these professional associates. I include a brief overview of the SBCCOM guidelines but strongly recommend that you read the entire document and then carefully consider the material and its guidance before you implement it. The information is presented to help you to make an informed decision and to better understand the weight of an incident commander’s decision. Ultimately, you will decide if implementation is appropriate for your locale.

SBCCOM GUIDANCE
The SBCCOM guidance is commonly referred to as the “3-30 Rule” because of the time elements outlined. The two-part general guidelines issued state: “Standard turnout gear with SCBA provides a first responder with sufficient protection from nerve agent vapor hazards inside interior or downwind areas of the hot zone to allow 30 minutes rescue time for known live victims. Self-taped [with duct tape] turnout gear with SCBA provides sufficient protection in an unknown nerve agent environment for a 3-minute reconnaissance to search for living victims (or a 2-minute reconnaissance if HD [the military designation for mustard agents] is suspected).” The guidelines also contain maximum reconnaissance exposure times for other “quick-fix” configurations (see Figure 1).

The Nunn-Lugar-Domenici Domestic Preparedness Program empowered the SBCCOM to do this research and produce these guidance statements because in the absence of haz-mat response teams, many fire departments responding to such an incident usually will not have Level A (all-encapsulating, chemical-resistant suits) entry equipment. Specifically, incident commanders needed to know how well FFPE and SCBAs would protect first responders in terrorist attacks involving chemicals.

To obtain these data, the SBCCOM conducted a series of tests with Montgomery and Baltimore County (Maryland) fire department personnel. These firefighters determined how well FFPE and SCBAs protect responders from injury, incapacitation, or death while operating in environments containing chemical agent vapor. The guidance statements were formulated based on the test results. Firefighters from six additional fire departments and fire personnel from across the country were also included in the final stages of the SBCCOM report.

The SBCCOM document is very specific in that the report recommendations are not mandates or requirements but operational guidance. Each locale must decide how it will respond to a terrorist incident and then train and equip personnel accordingly. The guidelines encourage each jurisdiction to use the guidance to establish policy.

SBCCOM TESTING METHODOLOGY
Firefighters in full fire protective ensemble and SCBA were exposed to the chemical nerve agent simulant methyl salicylate under test conditions to measure the Physiological Protective Dosage Factor (PPDF). These trials were called the “man in simulant trials” or MIST. Participants were fitted with absorbent pads in 17 different locations under their FFPE and performed mock rescue operations for 30 minutes inside a chamber. After each trial, the pads were quantitatively analyzed for the presence of the chemical simulant. Recommendations were written based on the results of these tests. This report evaluated only vapors of simulated nerve gas and did not address aerosols or liquids. The testing did, however, reveal that turnouts protected personnel better from aerosols than from vapors.

Chemical Nerve Agents
You must know what kind of chemical agents are referred to in the SBCCOM document to understand the hazards involved. Nerve agents are synthetically developed chemicals designed to kill troops. They are lethal in very small doses if inhaled or absorbed through the skin. In some cases, a mere drop can kill. Some call these nerve agents “pesticides with attitude”; they are structurally similar to organophosphate chemicals (e.g., parathion and malathion) but much more toxic. They affect the transmission of nerve impulses in the human nervous system. Exposure leads to death within minutes as body systems rapidly shut down because of the nerve agent’s effect on the body’s production of a vital enzyme called acetylcholinesterase.

Tabun. The German scientist, Dr. Gerhard Schrader, began experimenting with new types of pesticides in 1934 and ultimately developed the first nerve agent, Tabun, in 1936. Schrader found Tabun to be extremely toxic to insects. He was accidentally exposed to it himself in his lab, and he noticed that his pupils had contracted and he had developed shortness of breath. Because of then-current German laws, Schrader was required to report his findings to the Nazis because of potential military significance. His discovery was patented and kept secret. He moved to a new laboratory to work on additional nerve agents for Germany.

In 1939, the Germans started a pilot plant to produce Tabun in Raubkammer, Germany; a full-scale plant in Brzeg Dolny, Poland, began producing the nerve agent in 1942. Despite many precautions to ensure safe production, 300 accidents occurred before production began; at least 10 workers were killed. Production was extensive since the Germans manufactured 12,000 tons of Tabun during World War II. The American military designation of Tabun is “GA.” It is a member of the “G” (i.e., German) agents, which are chemical nerve agents. Tabun was used between 1984 and 1988 in the Iran-Iraq war.

Sarin. In 1938, Schrader led a team that included three other scientists that discovered Sarin, another lethal synthesized organophosphate chemical. Sarin actually gets its name from its discoverers; Schrader, Ambros, Driger, and van der Linde. The Germans manufactured as much as 10 tons of Sarin during World War II. The American military designation of Sarin is “GB.”

In The Cult at the End of the World (New York: Crown Publishers, 1996), authors David E. Kaplan and Andrew Marshall state that Sarin is “one of most aggressively lethal substances known to chemical science.” Indeed, it is estimated that six milligrams of liquid Sarin could kill a 140-pound person. The Japanese cult Aum Shinrikyo manufactured Sarin and then deployed it in the June 1994 Matsumoto, Japan, and the March 1995, Tokyo, Japan, incidents in which 18 people died and more than 5,000 victims were affected.

Soman. In 1944, another German scientist, Richard Kuhn, discovered Soman while working on the pharmacology of Tabun and Sarin. Germany did not produce any Soman in World War II, but it is considered the most lethal G agent. The American military designation of Soman is “GD.” Tabun, Sarin, and Soman are just three of the more than 2,000 new organophosphate compounds synthesized by the Germans during World War II.

“V” agents. They were developed through simultaneous efforts between several chemical companies and other scientists working independently in 1952 and 1953. One source cites British scientist R. Ghosh as the discoverer of VX in 1948. In 1958, the U.S. selected VX as the agent to manufacture and use for warheads; 5,000 tons of it were manufactured from 1961 to 1968.

“H” agents. These mustard chemical agents are also known as blister agents or vesicants because of their serious skin contact hazards: extreme pain and large blister formation. Eventually, the large blisters rupture, leaving open wounds that are susceptible to infection. Inhaled blister agents also represent an extreme life hazard. Blister agents were developed in World War I; the Germans used them on the Russian front in 1915.

The American military classifies mustard agents as “HD.” They are an unlikely threat because they freeze at temperatures below 58°F. Mustard agents have a very disagreeable garlic-like odor that can be detected below their lethal concentration. Most people will self-evacuate before they are incapacitated.

Keep in mind that all of the materials above are normally liquids but are extreme contact hazards. Skin absorption is the normal route of entry, but these liquids can be aerosolized into tiny suspended particles in the air with dispersion devices. Then, inhalation becomes the primary route of entry. This most likely would be the method terrorists use to expose a large number of people; the delivery method may be very crude, but it would be effective. The SBCCOM report does not address aerosol or liquid hazards; but, again, testing revealed some turnouts protected personnel better from aerosols than from chemical vapors.

Also, these nerve and blister agents are not very volatile-i.e., they do not readily evaporate. These agents tend to remain as liquids for long periods of time. Nerve and blister agents have relatively low vapor pressure, which is a measure of a chemical’s tendency to vaporize at ambient temperature. Since these agents have low volatility and vapor pressures, they will not usually present an inhalation exposure problem. Warmer temperatures affect these qualities. Volatility and vapor pressure also indicate how persistent a chemical will be in the environment. Therefore, a chemical with low volatility and low vapor pressure will be very persistent.

Some haz-mat specialists hail the SBCCOM guidance because through science and research we now have empirical evidence with which an incident commander can make a better decision on whether to send responders into a terrorism incident involving nerve agents.

Still, other specialists say that this guidance contradicts everything they have learned from past training and it even contradicts existing regulations, consensus standards, and responder guidelines. The Occupational Safety and Health Administration’s (OSHA) regulation Hazardous Waste Operations and Emergency Response (HAZWOPER, CFR 29. 1910.120) specifically states that first responders should respond defensively to haz-mat incidents. This is also the strategy the National Fire Protection Association (NFPA) Standards 471, Recommended Practice for Responding to Hazardous Materials Incidents, and 472, Professional Competence of Responders to Hazardous Materials Incidents, recommend. Firefighters should receive appropriate training to do their jobs safely as described for the First Responder-Operations Level. While it is true that firefighters can respond offensively at incidents for which they are properly equipped and have had appropriate training (sometimes referred to as Operations Level-Enhanced), many fire departments have not provided the needed training.

Additionally, many haz-mat response training courses, such as the Environmental Protection Agency (EPA) 165.15, Emergency Response to Hazardous Material Incidents, and the International Association of Fire Fighters (IAFF) course recommend a defensive approach to haz-mat incidents for first responders. These courses seek to prevent responders from becoming victims themselves.

OTHER RESPONSE GUIDES
USDOT. The U.S. Department of Transportation Emergency Response Guidebook (ERG), 2000 edition, contains 61 separate guides that assist responders with initial response actions at hazardous materials incidents. This is also the first edition of the ERG that specifically addresses chemical nerve agents and mustard gas hazards (Guide 153). The guides contain recommendations for when to use FFPE or structural fire protective clothing (SFPC) and perhaps specialized chemical clothing. The ERG also contains information about the use of SFPC for rescue and the protection it affords. Finally, the ERG also states that the incident commander makes the decision to perform this operation only if an overriding benefit can be gained (i.e., perform an immediate rescue, turn off a valve, etc.). The big precaution, especially with Guide 153, is that SFPC is not recommended for chemical nerve agent response.

FEMA. In May 2000, the Federal Emergency Management Agency (FEMA), the United States Fire Administration, the National Fire Academy, and the United States Department of Justice’s Office of Justice Programs issued a guidebook for emergency responders entitled Emergency Response to Terrorism Job Aid-Edition 1.0. This guide is also intended for responder field use at terrorism incidents. Under the chemical response section, it has a checklist for response recommendations including “Complete a hazard and risk assessment to determine if it is acceptable to commit responders to the site”; “Personnel in structural PPE/SCBA should not enter areas of high concentration, unventilated areas, or below-grade areas for any reason”; and “Personnel in structural PPE (personal protective equipment)/SCBA may enter the hot zone near the perimeter (outside of areas of high concentration) to perform life-saving functions.” It is clear from this guide that entry into chemical nerve agent atmospheres with SFPC is not recommended.

National Domestic Preparedness Office. In November 1999, the National Domestic Preparedness Office, together with several federal agencies and national associations, issued another guide for incident commanders, “On-Scene Commander’s Guide for Responding to Biological/Chemical Threats.” It lists the actions first responders should consider in response to biological and chemical terrorism threats, reinforcing the guidelines with several scenarios. The highest level of PPE is to be considered in the guides and used for self-protection in handling victims. This guide, however, does not mention the rescuing of victims at terrorism incidents involving the release of chemical nerve agents. These documents that have been geared for first responders may indicate that our own federal agencies contradict themselves in these guides.

OSHA GUIDANCE
I posed several questions to OSHA regarding the SBCCOM guidelines in relation to HAZWOPER in a formal letter. In follow-up phone calls (and off the record), one OSHA representative commented that an offensive response into a nerve agent atmosphere while wearing turnout gear and SCBA may be regarded as a “serious violation” according to HAZWOPER. The potential for a fine would be very real. Up to this point, a formal position from OSHA has not been promulgated in response to nerve agent releases at domestic terrorism incidents.

In a related area, and contrarily, OSHA has issued “Interpretive Quips” (IQs) in reference to HAZWOPER that clarify the concept of rescue in haz-mat environments. In these documents, OSHA has stated that first responders’ entering hazardous materials hot zones to rescue victims is a “technical violation” of the Hazwoper regulation. However, a citation would not be issued. Logic would dictate the same could be surmised with rescues in nerve agent atmospheres.

Finally, OSHA can also issue citations for events in which there are no specific regulations but that present an unreasonable danger to a worker. This is the “general duty clause”; it is based on the premise that employers are required to provide a safe workplace for each employee. Employers are to provide effective training for employees along with the proper engineering and administrative work controls to prevent injuries. Response agencies should contact their own state OSHA office for more guidance on compliance issues.

Comments
I received these comments and others from fire service and haz-mat team personnel in my informal survey.

  • Part of the definition of Operations Level is not only responding defensively but also for the purpose of protecting the public, property, and the environment. As such, rescue fits within that definition. Nothing ever said we cannot let Operations Level personnel enter the hot zone as long as they have been properly trained and are wearing proper PPE.
  • Keep in mind that the OSHA cowboys and the lawyers are not on the battlefield.

PPE ISSUES
Turnout gear (TOG), structural firefighting protective clothing (SFPC), and the firefighting protective ensemble (FFPE) are designed only for structural firefighting and not for hazardous materials response or terrorism agents, according to NFPA 1971, Standard on Protective Ensemble for Structural Fire Fighting-2000. This is especially true if you talk to the structural firefighter clothing manufacturers. In fact, the NFPA 1971 label states that the garment “may not provide protection for proximity or fire entry applications or for protection from chemical, biological, or radiological agents.” In recent years, NFPA 1971 has also changed terminology in relation to the moisture barrier, which was once called the “vapor barrier.” The change was significant because this barrier did not prevent vapors from contacting the wearer. The NFPA 1971-2000 edition requires the use of a breathable or permeable moisture barrier because of heat-stress concerns. Recognize, however, that gas and vapors can more easily penetrate through permeable moisture barriers. Also, because of the design of moisture barriers, it is a two-way street! To reinforce the statements in NFPA 1971, the Fire and Emergency Manufacturers and Services Association (FEMSA) includes a similar statement in the official user’s guide that comes with each new garment. Essentially, these statements merely indicate the limitations of structural firefighting clothing.

Even the 2000 DOT ERG has guidance that states that turnout gear provides “limited protection” from hazardous materials or dangerous goods. Turnouts should not be used for many spill situations. To go further, the 2000 ERG contains guidance for the nerve agents in Guide 153; it states that turnouts provide only limited protection. Essentially, SFPC will provide responders with limited protection for only “in and out” operations. Many haz-mat training programs also teach the above points. The interesting thing is that out of the 61 total guides, 21 guides state that SFPC will provide only limited protection for responders engaged in activities such as victim rescue. The only guides that list SFPC as providing adequate protection are three of the radiation-related guides. All other guides recommend specific chemical clothing.

Regarding vapor protection, it is extremely important to realize the limitations of structural gear. Jeffrey O. Stull, an international protective clothing specialist and owner of International Personnel Protection, Inc., states that turnouts offer no vapor protection and that taping interface areas does not provide a consistent barrier. Stull also advises that all wearers need to know that gases and vapors readily penetrate turnout clothing. Remember, turnout gear ensembles are only as effective as the weakest link-the neck and head area between the SCBA facepiece and the top of the turnout coat and collar.

Additionally, regarding personal protective equipment and terrorism agent response, the NFPA has developed Standard 1994, Protective Ensembles for Chemical or Biological Terrorism Incidents, for domestic terrorism protection. This new standard, approved at the May 2001 NFPA Standards Council meeting, will not list turnouts as adequate protection from nerve agents for first responders. Only garments designed with NFPA 1994 performance criteria and that pass stringent third-agency testing will be listed as suitable for terrorism agent response. At this time, there are no garments on the market that comply with NFPA 1994.

There is also recent information that has been brought to light by the fire service and researchers at the National Institute of Standards and Technology’s (NIST) Building and Fire Research Laboratory (BFRL) regarding a new problem with turnout gear. J. Randall Lawson, a physical scientist at BFRL, cites a problem where outside moisture on the turnout gear can be transported through the system’s permeable moisture barrier to the firefighter. Lawson calls this the “hot water vapor transport theory” and warns that this problem not only brings a potential for burn injury but also could add serious problems with exposure to hazardous materials. While this research has been challenged by some agencies and companies, it has raised some red flags regarding the overreliance on turnout gear at terrorism incidents.

Also, consider the military philosophy on protecting personnel on the battlefield from the hazards of nerve agents. The military issues Mission Oriented Protective Ensemble (MOPS) gear for its troops to protect them when nerve agents have been or may be deployed on the battlefield. MOPS gear is worn at the discretion of the mission commander. It is not designed for use in a known chemical environment but for escape from such an environment where nerve agents have been used. The military uses chemical warfare defense ensembles (CWDE) for working in chemical or biological environments. They include the chemical protective suit, which has a charcoal liner; hood;, gloves; boots; and a negative-pressure filter mask. This suit is very hot to wear for long periods and is also very expensive. The latest technology involves garments that employ selective permeable membranes in a lightweight, two-piece suit called the “JSLIST” (Joint Service Lightweight Integrated Suit Technology). These suits have proven to be cooler for the wearer while still providing adequate personal protection. This technology may eventually be available to first responders for protection from chemical nerve agents.

The main consideration with this information is that even the military will decide to wear the appropriate level of personal protection in response to the environment that is presented. Even the MOPS gear is designed for a rapid exit from a nerve agent atmosphere only. Entry into these environments is only with the PPE designed for the hazard in the environment.

Comments
PPE:

  • The real issue is one of percutaneous exposure (exposure of skin to vapor or gas). Organophosphates are not tissue destructive like chlorine or anhydrous ammonia. Nerve agents have very low vapor pressures, and they have relatively poor percutaneous absorption, as do most nontissue destructive dermal exposure substances.
  • You have to decide what your comfort level is for personal protective equipment. If you had only turnout gear with duct tape, what would you use?

Turnout Gear Taping:

  • I think the additional protection that the duct tape provides would be used very quickly.
  • There are many people who believe that using duct tape is unsafe.
  • The controversial area is the whole taping scenario. It’s one thing to find yourself in such an atmosphere without prior knowledge and to be protected because your PPE has the capability. It’s another thing to tape up and enter a chemical/biological environment assuming that the taped garment is going to perform with any degree of consistent reliability.

RISK ASSESSMENT
In the world of risk analysis, it is prudent to weigh the risks against the potential benefits at any emergency. Appropriate questions to ask are

Is the response worth what responders hoped to gain?

Is it acceptable to risk the lives of firefighters to save victims who may end up dying?

Are the risks worth the potential gain?

Also, how many hospitals in your area have enough atropine and 2-PAM chloride on hand to save the victims who have been exposed to nerve agents? In the aftermath of the March 1995 Tokyo Sarin release, only 10 hospitals out of 212 had sufficient amounts of antidotes to treat the approximately 5,000 victims. Case studies involving organophosphate exposures indicate that up to approximately 20,000 milligrams of atropine may be needed to treat each patient, depending on exposure. Additionally, large supplies of 2-PAM may also be needed. A possibly more important question would be, Are there adequate supplies of antidotes to treat exposed responders? Honest answers to all these questions are needed to conduct effective pre-event risk assessments.

Some other pertinent questions are, Will you be part of the problem or part of the solution through your involvement? Would you feel comfortable ordering your personnel into these environments with turnouts and SCBAs? These are hard and tough questions that need to be addressed before the terrorism event occurs.

Some cities have completed this risk analysis and have either endorsed the SBCCOM guidance, elected to modify the guidance, or chosen not to follow the guidance. (See Figure 2.)

Military Mindset
Also consider that some people wonder about the mindset of those who devised these guidelines. Since a military organization formulated the guidelines, is the concept of “acceptable losses” built into the guidance? In the military, it is always the mission above the men, and every soldier knows that HE may be sacrificed to achieve success. In the fire service, this is simply not the case-quite the contrary. It is indeed rare for an incident commander to plan for acceptable losses at emergencies. Risk-benefit analysis again must be your guideline at these incidents. In defense of these guidelines, there are some specialists who believe that sbccom was designed with fire service objectives in mind when the plan was written.

The SBCCOM guidelines suggest that the risk of using turnout gear in nerve agent atmospheres is low or at least manageable, but the incident commander decides whether to follow the guidelines. Some specialists have wondered if we are merely playing the odds with all of this. Is it merely a roll of the dice at these incidents? Playing with chance is not prudent and perhaps the best question regarding risk assessment is, What is reasonable?

Comments

  • I have yet to see a fire chief plan for acceptable losses. It is entirely correct in stating that the military programs a loss factor into its thought process.
  • Do not forget several points, one of which is, Aberdeen [Proving Ground] in Maryland [where SBCCOM operates] is not a recognized testing facility with credible credentials within the fire community. It is operated 100 percent by military personnel. Lastly, the development of the conclusions-the so-called guidelines-was based on an inside analysis of the data and was authored by military personnel who conducted the tests, not anyone connected to the fire community. In short, with no further discussion, the guidelines are not reasonable.
  • These tests were conducted at the behest of the fire service representatives who have been working with SBCCOM. I believe that the values clash was accurate several years ago, but I think that the SBCCOM folks now have a pretty good appreciation for the fire service’s view of the world.
  • I do not question the mindset of the guidelines. If it were just the military making these recommendations for its own troops, there would be cause for suspicion. With all the participation of the fire departments mentioned, there was ample opportunity for them to discredit the study; to my knowledge, they have not.
  • The reality is that if fire department personnel are faced with a terrorism situation where some people are down and others are ambulatory because of a suspected nerve agent or blister agent exposure, our people will probably do whatever is necessary to “do the job,” even at great risk to themselves. This information provides some objective technical basis for risk evaluation.
  • After much debate, we opted to implement this guidance into our WMD training. However, we opted to not even mention the self-taping. There are too many things that can go wrong and too little time to detect them. Our priorities are and always have been: (1) life-ours and then theirs; (2) property; and (3) environment. If the victims have no chance of survival, we have no mission! Also, viable victims will not survive if we have to wait on Level A entries. These firefighters have only one objective at this point-to snatch and drag as many living victims out of the area as soon as possible.
  • The reasoning is prudent. If people without any PPE can survive, the firefighters in FFPE have a much higher protection factor.
  • We need to base what we do on the hazards and risks of the incident situation and not strictly on protocols or procedures.
  • There isn’t always a right or wrong way. There are a lot of different tactics to achieve the same strategic goal. What works in scenario A may be totally inappropriate for scenario B.
  • Information we have analyzed supports that using firefighters in turnouts and SCBAs for emergency rescue, gross decon, and assisting victims in some cases is reasonable. Most important is the issue of risk analysis. In my view, this is the key to the entire study.
  • No surprises here. It comes back to a risk assessment. If we show up five or 10 minutes after the call comes in and we still have clearly viable patients, I am to consider a “grab and go” rescue using my PPE and SCBA.

LEGAL CONSIDERATIONS
One last consideration concerns the legal aspects of following these guidelines. You need to think over the consequences of sending responders into atmospheres contaminated with nerve agents and having them become victims. Questions to seek appropriate answers for are:

Are any victims on our side acceptable?

What is the standard of care from a legal standpoint, not to mention malfeasance concerns?

Is there a possibility of new court cases, both civil and criminal? (We have witnessed court cases in the past where individual incident commanders have been successfully sued for decisions they made at emergency incidents.)

What preparations can be conducted to avoid such legal problems?

Should your city attorney or legal counsel be involved in these decisions?

Even though the guidelines are not considered a legal document, they are encouraged to be used to establish policy. Since policy can become a legal issue, agencies need to exercise great care in what policies are developed. Policies can become liabilities that can hinder legal defenses. One last consideration is that the largest firefighter union, the IAFF, has not and will not endorse the SBCCOM guidelines. The IAFF considers responses to nerve agent emergencies in turnout gear to be an excessive risk for firefighters.

Comments

  • As for the liability issue, that comes with our jobs and the territory. Accept that people are going to cite, question, or litigate your decisions after the fact. The real issue is, What can I do to protect myself and validate my decision-making process and the actions taken?
  • “It’s all fun and games until somebody loses an eye” is a phrase that we have all heard, and it applies here. If someone is injured under these circumstances, lawyers will have a field day if they know the right questions to ask.
  • If any product should have a vapor for which protection is needed, the bunker gear plan, I feel, would fall by the wayside fast in court.

Terrorism, a remote possibility, has forced emergency response agencies to become better prepared for a terrorism event. The SBCCOM document has provided information to assist incident commanders in making informed decisions on whether to commit personnel with SFPC and SCBAs to possible nerve agent atmospheres to rescue survivors. This information can be crucial to successful planning efforts. However, before the event occurs, response agencies must carefully consider their actions and always keep their limitations in mind. In this light, the SBCCOM guidelines mainly address the survivability of properly protected responders at these events. In the absence of hazardous materials response teams, what is the next best option? The guidelines should not necessarily be used to conclude that turnouts could be used for deliberately entering nerve agent atmospheres. Finally, keep in mind that this study is the first of its kind and that, therefore, the jury may be out with these recommendations at least until further documentation is produced. Still, this study does make the new NFPA 1994 standard even more timely and poignant.

Final Comments

  • Jeffrey O. Stull: Relying on current turnout clothing to provide protection against chemical agents is taking an unnecessary risk. This clothing will not protect against vapors and often is not liquid tight. I do not think it is prudent to risk further lives based on assumptions that dictate very limited response times under highly hazardous situations.
  • J. Randall Lawson: Firefighter protective clothing will degrade in protective performance with use. Probably the most easily damaged item in the garment is the moisture barrier. Seams leak, cracks develop, some moisture barriers may delaminate, and there is general degradation with age and exposure to UV light, the sun, and other chemical exposures including hazardous smoke, soot, and gases created by fire. Who is to say your older gear is going to protect you from a WMD agent exposure?
  • I think the referenced document is a valuable tool for incident commanders.
  • Bottom line-it doesn’t say you should use SFPC. Few would disagree the CPC should be the preferred choice when available. However, the SBCCOM paper does provide me with objective information to evaluate the risks of using SFPC as a level of available protection.
  • The SBCCOM document is a tool; like any other tool, it has to be utilized correctly.
  • I believe that these data have a place in our planning for extreme emergencies. A report like this, if improperly applied, can lead to catastrophic results.
  • I see this information as a valuable resource in the risk assessment process. No one is saying that you must perform entry wearing SFPC. But at least I now have some solid technical information that I can use in the risk assessment process if I find myself in that situation. Remember, the fire service doesn’t get to “deal the cards” at the events to which we respond.
  • Nothing in this report suggests that we should all be using turnout gear for WMD response. The report was commissioned to see what kind of protection turnout gear offered and, if it offered protection, then at what level? What we have found is that it does offer protection in a WMD environment and if it is all you have and YOU decide to take the risk, then it offers some data as to how much protection you have.

Hopefully, you agree there are many things to consider with regard to endorsing these SBCCOM guidelines. One thing is clear, however: A prudent response agency will think through its response to terrorism incidents before it is confronted with such an emergency. The intention of this article was to present the issues to assist you in making an informed decision. Perhaps the ultimate consideration comes down to what you would feel comfortable having your personnel do.

According to the Department of Defense (DOD), it is extremely difficult and very unsafe to manufacture chemical terrorist agents. Even though the Japanese cult Aum Shinryko did so, it needed millions of dollars and the guidance and help of some top scientists. The DOD still maintains the chance of a terrorism incident is greatest with first explosives, then chemicals, then biological agents, then radioactive agents.

While the chance or risk of a chemical terrorism incident is quite low in the United States, the old Boy Scouts’ motto of “Be Prepared” never rang truer. I know what I would do. Do you?


DAVID F. PETERSON, a 21-year veteran of the fire service, is a lieutenant with the Madison (WI) Fire Department and the operations and training coordinator for the Regional Level A Haz-Mat Response Team. He is the owner of Americhem Safety & Environmental, LLC, a haz-mat training and consulting firm in Janesville, Wisconsin. He is also an IAFF Master Trainer, an adjunct instructor for the National Fire Academy and the Emergency Management Institute, and an FDIC presenter. He is a member of the NFPA Classification and Properties of Hazardous Chemical Data Committee. He is the founder and past president of the Wisconsin Association of Hazardous Materials Responders, Inc.


Chemical Nerve Agents: Relative Hazards
The chemical nerve agents described in this article are all extremely lethal, but the following comparisons (from numerous sources) indicate that some agents are more dangerous or lethal than others:

  • Parathion is one fifth as toxic as Tabun.
  • Malathion is 240 times less toxic than Tabun (lethal dose is 60 grams for 150-pound person).
  • Carbaryl (i.e., Sevin) is 100 times less toxic than Tabun.
  • Sarin is 26 more times lethal than cyanide gas.
  • Sarin is 20 more times lethal than potassium cyanide.
  • Soman is considered the most lethal G agent.
  • VX is 10 times more lethal than Sarin.


Terrorism and Turnouts: the Controversy

Figure 2. Terrorism and Fire Department Response

Chicago, Illinois
The department has decided to follow SBCCOM guidelines but has not included them in its written SOPs/SOGs. All personnel have been trained to respond with recommendations in mind. Mindset is (1) If victims have no visible liquid or respiratory problems, firefighters in TOG and SCBAs will be adequately protected to assist victims; and (2) Decon with water, but soap would be better if available.

Fairfax County, Virginia
After discussion and proper training, firefighters have been advised to use TOG and SCBAs if victims are not experiencing any signs or symptoms. They can enter and assist with evacuations for up to 30 minutes. If victims are experiencing signs and symptoms, firefighters are allowed to enter and assist for only three minutes.

Honolulu, Hawaii
Firefighters can use TOG and SCBAs to assist evacuees, but hot zone entry is not allowed. Also, a maximum of only one air bottle may be consumed before firefighters must exit and be decontaminated.

Houston, Texas
Firefighters are allowed to use TOG and SCBAs to rescue victims, but the practice of using duct tape is not followed. The snatch and drag concept is used for training.

City of Los Angeles, California
Firefighters have been issued Level B ensembles and Mark I autoinjectors and have been advised not to enter the hot zone. They use other equipment to decontaminate victims and contain personal items. Mark I injectors have 2 mg of atropine and 600 mg of 2-PAM Chloride (pralidoxime chloride).

Milwaukee, Wisconsin
All personnel have been trained in WMD and the SBCCOM guidelines, but no formal SOP/SOGs have been issued. Fire officers are expected to make decisions on whether to use TOG and SCBAs for rescue situations.

New York, New York
The Fire Department of New York (FDNY) does not follow SBCCOM guidelines. It follows its own unique system for responding to terrorism incidents. The guidelines are not written because it would become public information. Guidelines are as follows:
The first wave of responders uses TOG and SCBAs for rescue of victims.
The second wave (if needed) is Level A from personnel on rescue or ladder companies. These would be designated Chemical Protective Clothing (CPC) companies that are supplied with Level A suits. All these personnel have received an eight-hour course on Level A training. 700 Level A suits have been issued to ladder companies.
The third wave (if needed) is technician units.
The fourth wave (if needed) is specialist units from the FDNY Haz-Mat Team.
FDNY has 203 engine companies and 140 ladder companies in service.

Sacramento, California
All fire departments and police departments in the county use chemical protective clothing for responding to terrorism incidents. These jumpsuits are single-use NFPA compliant with one-hour permeation resistance. More than 1,000 garments have been purchased. The Sacramento Fire Department does not and will never recommend the use of TOG for the specific intended purpose of rescue at a suspected WMD event.



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