Letters to the Editor: February 2021

2020 Emergency Response Guidebook

ERG Not Good Enough?

As a member of the Fire Engineering Editorial Advisory Board, I (Noll) have been asked to coordinate a response to the article “The Emergency Response Guidebook (ERG): Not Good Enough, Not Safe Enough” by Dr. Vyto Babrauskas (November 2020). This response reflects the views and perspectives of the 13 signatories to this letter. These individuals are active participants in various organizations within the national and international hazmat response community and collectively bring more than 350 years of background and experience as hazmat emergency responders.

We appreciate this opportunity to reply and affirm that all parties share a commitment to the goals of (1) emergency responder safety and (2) ensuring that responders have accurate information to mount a safe and an effective risk-based response. In today’s world, where open debate is often silenced or focused on social media forums, it is important to have these issues be presented and discussed in an open and a transparent manner. Although we may have differences of opinion on the focus of the article, open discussion, challenge, and debate are healthy, especially when pertaining to emergency responder safety.

Based on our collective hazmat emergency response experiences responding to hazmat emergency incidents, we believe that the article does not accurately reflect the intended application, scope, or usage of the Emergency Response Guidebook (ERG) by the fire service and hazmat emergency response community.

The ERG is published by the U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA), an agency of the U.S. Department of Transportation (DOT), and has been an important reference document for more than 45 years. In asserting that there are “systemic problems” associated with the use of the ERG, Dr. Babrauskas fails to provide an objective analysis of the ERG and would potentially cause emergency responders to question the use of a document that, in our collective experience, has been shown to be an effective information resource for first responders. Like any technical resource, the ERG has its strengths and weaknesses, and these should be vetted as part of planning and training processes. Based on our experiences in using the ERG at real-world hazmat incidents, we strongly disagree with the statement that the ERG is “not good enough or safe enough” for use by the fire service and other first responders.

We offer the following points:

  • Dr. Babrauskas states, “The ERG does not comprise an adequate effort to ensure all emergency responders receive sufficiently good information so that everyone goes home.” He misses the original intent of the ERG to provide a basic, easy-to-access reference guide for the initial stages of a hazmat transportation incident.
    The author implies that the ERG is the only and primary tool in the hazmat reference information toolbox. In reality, emergency responders are required to be trained to the Hazardous Materials Awareness or Operations level based on their assigned tasks. Although the ERG is intended be an INITIAL hazmat reference source, it is not the ONLY tool in the hazmat information toolbox. Comments by the author also ignore the value of preincident planning and reviewing safety data sheets (SDS) and Tier I and II data that would be available at fixed facilities subject to Occupational Safety and Health Administration and Environmental Protection Agency planning requirements. The bottom line is that the ERG complements a risk-based hazmat response process but is not a replacement for effective and focused hazmat planning, training, and preparedness.
  • As noted, the ERG has been in use for more than 45 years within the hazmat transportation community. Since 1996, the United States, Canada, Mexico, and other countries have worked together to publish updated editions of the North American ERG every four years. Unlike government regulations that are seldom revised and updated, the ERG has been subject to a timely and consistent review process that is comparable to those used in the voluntary consensus standards community [e.g., National Fire Protection Association (NFPA)]. Our collective experience is that the DOT has made significant outreach efforts to the emergency response community, industry, and government for their input, and the current edition reflects that collective experience.
    In addition to the ERG publication itself, its guidance information has also been incorporated into many other government and nongovernment response resources. These include the NOAA CAMEO Chemical Database; the Wireless Information System for Emergency Responders, which is an app and Web site developed by the National Library of Medicine; and the AskRAIL® app developed by the American Association of Railroads. It should be noted that these technical information sources also combine guidance from multiple reference sources (e.g., ERG, NIOSH Pocket Guide, and U.S. Coast Guard CHRIS Manual) into a single document.
  • ERG scope, application, and target audience: The outside cover page of the ERG clearly states that the ERG “… is intended for use by first responders during the initial phase of a transportation incident involving dangerous goods/hazardous materials.” Most responders would define “initial phase” as the first 15- to 30-minute window of the incident timeline. The ERG recommendations and guidance are intended for hazmat transportation incidents, not for use at fixed facilities, where storage containers and inventory quantities greatly exceed those found in the rail, motor carrier, and maritime transportation modes and require different public protective action guidance. We would agree that some responders do use the ERG for nontransportation incidents; however, we believe this is related more to training and education on the appropriate use of the ERG rather than “gaps” with the ERG guidance.
  • Poor editing and technical inaccuracies: We believe that the DOT has established numerous opportunities for user input into the ERG review process. This process has included seeking direct input from product, container, and emergency response technical specialists. The Initial Isolation and Protective Action Distances listed in Tables 1 and 3 in the “Green Section” of the ERG are the result of an ongoing project with federal government laboratories and incorporate the latest in toxicological data, atmospheric dispersion, and vapor deposition modeling. The validation of the results from the 2015-2017 Jack Rabbit Project full-scale chlorine release tests is an example of this review process. Similarly, the specific guidance in the Orange Guide pages is based on available data and peer review by product and emergency response technical specialists. Finally, the DOT has always welcomed comments and suggestions for improvement of future ERG editions at ERGComments@dot.gov.
    Dr. Babrauskas is a former researcher and employee with the National Institute of Standards and Technology (NIST). In that capacity, he understands the extensive review processes associated with the publication of government documents and the number of technical and legal document reviews that are undertaken. Presumably, he has submitted his thoughts and recommendations to PHMSA/DOT.

There are a number of points on which we agree with Dr. Babrauskas, including the following:

  • Risk evaluation at hazmat incidents, especially low-frequency/high-consequence scenarios, should be based on the basic and standardized principles taught in Hazardous Materials Awareness and Operations level training and should not be predicated on the use of a single technical information source. In simple terms, the training should drive the development of preincident plans for hazmat target facilities prior to any incident and the evaluation and use of multiple reference sources (e.g., ERG, SDS, product and container specialists, and the use of technical information sources such as CHEMTREC®) when an incident does occur.
  • Revisions and updates to emergency response guidebooks and technical information sources must be based on an analysis of the science driving the changes. The questions raised by Dr. Babrauskas on the guidance listed for lithium ion batteries and ammonium nitrate (AN) merit further analysis and discussion. For example, as a result of a 2014 AN tractor trailer explosion in Queensland, Australia, additions were made to Guide 140-Oxidizers of the 2018 Australian ERG to focus greater attention on AN’s explosive hazards. Our initial review of that guidance is that the same additions should be considered for the North American ERG. However, these potential changes do not negate the value of the ERG as an effective tool for the initial phase of a transportation hazmat incident, and its continued use by trained Awareness and Operations level responders should be strongly supported.
  • We agree that most firefighters are generally not chemists or chemistry specialists. Bretherick’s Handbook of Reactive Chemical Hazards is an excellent reference source when dealing with chemical hazards and is likely to be found in the reference library of most hazardous materials response teams. However, it is not a reference source used by the majority of Awareness and Operations level responders in the absence of a hazardous materials technician. It also underscores the need for a simple, basic, and easy-to-access reference source for the initial minutes of a hazmat incident, which the ERG provides.
  • The number of products contained in the various hazmat emergency response technical information sources varies widely, and to argue that one is somehow better than another is based totally on individual preference. As previously noted, every technical reference source has both advantages and limitations. For example, an Awareness or Operations level responder will likely use either the ERG (63 guide pages), the NIOSH Pocket Guide to Chemical Hazards (approximately 200 chemicals), or a product-specific SDS, since these are the primary reference sources discussed in Awareness and Operations level training. An experienced hazmat emergency responder would also communicate directly with a product or container technical specialist through CHEMTREC or similar systems.

Finally, Dr. Babrauskas states, “An important question is, did the West (TX) firefighters act correctly according to the ERG prescriptions? Unfortunately, the answer is yes.” This suggests that the use of the ERG was directly related to the tragic incident outcome. Investigation of the incident by the U.S. Chemical Safety Board and the Texas State Fire Marshal’s Office found no evidence that suggests the West firefighters consulted the ERG. This statement by Dr. Babrauskas also overlooks the facts, contributing factors, and findings included in both investigations.

The Firefighter Fatality Investigation Report (FFF FY 13-06) issued by the Texas State Fire Marshal’s Office presented a number of findings while emphasizing the following: “Firefighting is not an exact science, and through post-incident analysis of most emergency incidents, it is not unusual that a number of performance problems are identified …. The findings and recommendations listed below are re-statements of lessons that have been identified in previous investigations and firefighter fatalities, and recommendations that have been widely adopted as standard practices within the fire service.”

  • Finding #1: The initial responding fire department did not have standard operating procedures for emergency operations.
  • Finding #2: There was no prefire or preincident plan of this facility.
  • Finding #3: The incident clearly demonstrates the critical importance of establishing a comprehensive incident management system to provide command, control, and coordination of emergency operations. The absence of command and control and the failure to create and communicate an incident action plan resulted in an uncoordinated and unmanaged fireground operation.
  • Finding #4: The fire department did not approach this fire as a commercial structure with hazardous materials but rather initiated residential structural firefighting practices with which they were familiar. There was no appearance of an appropriate firefighting strategy based on (1) an accurate size-up, (2) a realistic evaluation of the available resources, (3) the capabilities of crews responding to an operation of this scale, and (4) the application of risk management principles.
  • Finding #5: Firefighting operations were not conducted in a manner that incorporated national and industry recognized safety standards and practices.
  • Finding #6: All fire department members must be properly trained and qualified to perform their assigned duties.
  • Finding #7: The fire department had no authority or regulatory governance over material storage or building (fire) preventive measures in this incident.
  • Finding #8: There was no fire prevention code adopted by the local jurisdiction. Currently, the regulatory landscape for fire prevention is inconsistent from jurisdiction to jurisdiction.
  • Finding #9: There was no hazardous material program adopted by the local jurisdiction.

Unfortunately, we learn once again that the past is not the past but is often the future looking to be relearned.

The esteemed Frank Brannigan often said in many of his classes on building construction and the fire service that firefighters do not go to bed one night and wake up the next morning only to discover that a new structure, facility, or hazmat target hazard was constructed in their community without their knowledge. It is the combined responsibility of our elected officials, government agencies, facility management, and emergency planning and response communities to ensure that emergency responders know the hazmat risks in their communities and have the knowledge to safety and effectively respond to the likely scenarios they will encounter. No single technical reference source, including the ERG, can overcome the significant gaps created in the absence of effective preincident planning, training, and prevention activities that embrace a risk-based “whole community” concept.

Gregory G. Noll
Past Chair
NFPA Technical Committee on
HM/WMD Emergency Response

Dr. Christina Baxter
Member
NFPA Technical Committee on
HM/WMD Emergency Response

Timothy Butters
Former Deputy Administrator
U.S. DOT, Pipeline and Hazardous
Materials Safety Administration

Andy Byrnes
Member
NFPA Technical Committee on
HM/WMD Emergency Response

Rick Edinger
Chair
NFPA Technical Committee on
HM/WMD Emergency Response

Manny Ehrlich
Past Board Member
U.S. Chemical Safety and
Hazard Investigation Board

Timothy R. Gablehouse
Past President
National Association of SARA
Title III Program Officials

Michael S. Hildebrand
Past Member
NFPA Technical Committee on
HM/WMD Emergency Response

Robert Ingram
Member
NFPA Technical Committee on
HM/WMD Emergency Response

David Matthew
Member
NFPA Technical Committee on
HM/WMD Emergency Response

Thomas Miller
Chair
NVFC Hazardous Materials
Response Committee

Robert Royall
Chair
IAFC Hazardous
Materials Committee

Ken Uzeloc
Canadian Association of Fire
Chiefs Representative to
NFPA Technical Committee on
HM/WMD Emergency Response

Wayne Yoder
Liaison
NFPA Technical Committee on
HM/WMD Emergency Response

Vyto Babrauskas responds: Gregory Noll and his colleagues presented a collection of information on several topics, none of which focuses on how to make the ERG a better document, one that gives reliable safety advice to first responders. I would suggest that, since they evidently have a strong interest in the ERG, they consider presenting to the DOT some concrete, detailed suggestions so that the next edition of the ERG would give first responders a better chance of survival. I already have provided an outline of the improvements needed, but to actually develop the details requires a sizable effort, which this group will hopefully undertake to assist with.

Noll states that there is no evidence that the first responders at West, Texas, consulted the ERG during the incident. That is not the point. The point is that they did effectively what the ERG would have them do, and 10 of them were killed in the ensuing detonation. I find it beyond comprehension that the authors of the newer editions of the ERG did not consider it worth their while, as a minimum, to revise the section on AN so as to give better safety instructions. But, as I have tried to convey in my article, there are many other chemicals that present serious dangers to first responders. In the safety profession, it is not enough to be reactive—one must be proactive if significant improvements are to be achieved. Thus, the whole document needs to be improved, not just the Guide dealing with AN.

And, as I also stated, force fitting all chemicals into very broad Guides is not a good idea. There are some chemicals whose hazards are indeed very similar, but there are many that have unique traits. Thus, group Guides may be an adequate scheme for certain chemicals, but chemicals such as AN, which (a) are in very wide use and (b) pose serious life-threat hazards and have some unique traits, need to be addressed individually, not as a group. Just to make this point clear, both AN and calcium hypochlorite are oxidizers, and both are put into Guide 140 of the ERG. Cal hypo is also well-known for numerous very serious incidents. But its main hazard comes from its self-heating propensity, which is not the case of AN, where the main hazard has been attack from an external fire. Furthermore, while the danger with AN is a detonation, the cal hypo explosions have generally been relatively modest deflagrations, primarily because of physical confinement. Putting two such disparate substances into one Guide is a guarantee that well-focused safety information will not be provided.

I wish this group success in helping to develop the needed improvements to the ERG.

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