Government and Employer Intervention to Address Inequality

Sources:
“Inequality and the American Dream.” The Economist.com, 15
Jun 2016, www.economist.com/leaders/2006/06/15/inequality-
and-the-american-dream.
Kornbulh, Karen. “Win-Win Flexibility: A Policy Proposal.”
NewAmerican.org, New America Foundation, June 2005,
www.newamerica.org/documents/356/win-win-flexibility-a-
policy-proposal.
Suroowiecki, James. “A Fair Days Wage.” NewYorker.com¸ 9
Feb. 2015, www.newyorker.com/magazine/2015/02/09/fair-
days-wage.
Prompt
The Economist editorial discusses the general trend in America
of increasing economic inequality and its relationship to the
American Dream of making it big, ending with suggestions for
government safety-net programs. The Kornbluh and Surowiecki
essays also note increasing inequality and propose or argue for
specific policies on the part of companies to aid in the lives of
their employees.
Basing your response on the readings, answer the following
question: To what extent do you think that employers or the
government should intervene to improve the lives of ordinary
Americans? Which of the proposed remedies do you think will
have the most positive effects on people and best address
economic inequality? What other consequences might any of
these remedies have? You may also argue for a different
proposal after first arguing against the ones proposed in the
readings. Be sure that your resulting essay includes and
addresses ideas from all three of the sources and cites them
appropriately.
Follow these guidelines below in completing your response
1) Write on regular notebook paper. Your instructor will inform
you how to format the exam in terms of where to place your

MSU ID number and course section number.
2) Strive to produce a 400- to 500-word response.
3) Write on one side of the paper and skip every other line.
4) Write in ink only. Should you need to make changes in your
draft, draw two or three lines through any changes/deletions you
wish to make. Arrows indicating insertions are acceptable
provided their path is easy to follow.
5) Demonstrate your understanding of MLA citation form by
using in-text citations (Number the pages “1” and “2” to
indicate the front and back of an article if necessary).
Construct a Works Cited page based upon the citations at the
top of the first page of the test prompt under the title of the
article. Instead of copying the long url, you are permitted to
shorten it to the elements in blue bold face.
6) You may make use of a dictionary and thesaurus during the
exam period
Module 1: Introduction to Emergency Management
Topics
I. What Is Emergency Management?
II. The Contingency Plan
III. Introduction to Federal and State Government Emergency
Management Programs and Emergency Response Plans
IV. Federal Emergency Management Plans
V. State and Local Plans
VI. Facility or Employer Plans
VII. Federal Disaster Investigative Agencies
VIII. Brief Introduction to National Voluntary Standards, Trade
Associations' Programs, and International Programs
IX. International Programs
X. Hazard Analysis, Risk Analysis, and Risk Management

XI. The DOT Emergency Response Guidebook
In this module, we introduce the basic elements of emergency
management and discuss briefly the breadth and depth of
emergency planning and preparedness. We will use the
term preplan to refer to the preparedness and prevention plan.
Emergency management involves management preparations for
anticipated emergencies that include a pre-emergency planning
document called a contingency plan. The contingency plan
describes how to deal with
· potential man-made hazards, such as fires, explosions,
terrorist attacks, or vessel failures that release hazardous
materials
· potential hazards caused by nature, including those caused by
weather, such as floods, or those caused by natural phenomena,
such as erupting volcanoes
I. What Is Emergency Management?
For our purposes in this course, we can define emergency as an
unplanned or unintended event, terrorist incident, or disaster
that creates a hazard. Emergency management is the art and
practice of assessing or evaluating these hazards and
implementing methods called controls to protect people,
property, and the environment.
The assessment and evaluation of serious hazards should be
systematic, and the steps taken should be documented
appropriately. Emergency management staff convert this
documentation into a contingency plan for these events. The
objective of the plan is to keep people, the community, the
business, and the environment safe even if a disaster or near-
disaster occurs that could harm them. Out of the formal
emergency management plan emerges a contingency plan, which
details the steps for mitigating the consequences of exposure to
serious hazards.
The first part of the contingency plan is a preplan describing the
pre-positioning of emergency equipment and supplies and
strategies for handling anticipated emergencies.

The second part of the contingency plan describes the handling
of the actual emergency and states clearly who is in charge of
an emergency, for example at a facility site. This part of the
plan details who does what during the actual emergency and
lists the procedures to be followed to protect the emergency
responders, the property, and environment during the actual
emergency.
The recovery plan is the second part of the emergency
management plan but it is often overlooked when the emergency
management plan or the contingency plan is assembled. The
recovery plan describes how to provide relief for those who are
adversely affected by the release or the harmful event and to get
the business or entity back in operation.
The graphic below gives a general idea of what constitutes a
contingency plan.
II. The Contingency Plan
The principle document of emergency management is the
contingency plan, which includes various contingencies to
address specific types of emergencies anticipated by the
organization or planning group. These plans must be as simple
as possible while providing adequate guidance to those in
charge of handling the emergency. A simple plan is much easier
to implement during an emergency than a complex one.
The contingency plan for each facility should be coordinated
with the contingency plan for the local community to better
assure that community assets for emergencies are made more
readily available to the facility if and when emergency strikes.
This is also true for larger emergencies and disasters up to and
including states coordinating their plans with the federal
regional plans.
Each contingency plan must include a chapter or section
addressing the emergency response so that all the necessary
notifications are made, the means for obtaining the resources
required to control the event are clear, and the line authority is
established for managing the emergency event. The plan must

also describe what recovery efforts will be undertaken, the ways
in which victims will be cared for in the aftermath, and the
means for restoring the business or other entity.
Priorities of Emergency Management
The contingency plan has several priorities that are ranked
hierarchically. They are
1. protecting the lives of people and animals
2. protecting property
3. protecting the environment
We will discuss each of these below.
First Priority—Protecting the Lives of People and Animals
The most important priority of emergency management is
protecting lives. When there is an emergency incident and a loss
of life, the contingency plan must include the steps emergency
responders are expected to take to handle the situation.
Human lives must be protected and saved if at all possible,
short of sacrificing the lives of rescuers for the lives of the
victims of the incident. Humans are naturally motivated to
protect themselves, their families, and their friends from harm.
This motivation often expands to include protecting one's
neighbors and communities. Some of this protection is
government mandated. The goal is for all involved parties to
work together, following the contingency plan and using
available resources to handle emergencies to protect the
community, the company, and themselves. A related goal is to
prevent the disaster from spreading to nearby areas.
When the recovery of human remains is involved, personnel
must respect the dignity of the victims and the victims' families
and friends. It is critical for emergency response personnel to be
professional and mindful of how their recovery actions may be
perceived by the family, the media, and the general public.
A subpriority is saving the lives of companion animals or pets.
If present, the protection of other animals such as farm animals,
zoo animals, and wildlife should also be addressed in this
section or chapter of the contingency plan.
Second Priority—Protecting Property

The second most important priority is to protect property and
other physical assets from destruction or damage. The objective
of this priority is to describe within the contingency plan the
steps to be taken to protect property from harm, whether it be an
original copy of the Declaration of Independence or a business's
computer network, machinery, or inventory. (This property-
protection priority builds on the self-protection and self-
preservation motivation.)
Property should not, however, be protected at the expense of
lives or the environment. Remember that protecting wildlife—
including life in bodies of water—is part of the first priority.
This property-protection element of the contingency plan should
describe cooperative efforts and laws and regulations requiring
private and public enterprises to contribute to the overall level
of preparedness to help protect the community at large.
Building and fire codes are examples of government regulations
designed to help protect property as well as lives. Each entity
should help the community to better handle anticipated
emergencies.
Third Priority—Protecting the Environment
The last priority discussed in the contingency plan is protection
of the environment. Again, various laws require private and
public enterprises to work together to protect sensitive
environmental areas or to minimize any harm to the
environment in general. These laws and regulations also
mandate emergency response and recovery planning to better
assure quick, effective response to minimize potential
environmental damage if and when an emergency incident
occurs.
Within the environmental protection priority are the following
subpriorities:
1. protecting sensitive wilderness areas
2. protecting areas in which people make a living, such as
waterways in which shellfish or fish are caught
3. protecting the overall environment of the local or larger
community

Applying the Priorities
All three of these basic elements of emergency management—
the protection of lives, property, and the environment—must be
considered fully in every major emergency that occurs within
the local community, and so these basic elements must be
addressed in the contingency plan.
Small emergencies that may occur within a plant or building
may have little effect on the environment. Those emergencies
that begin in or spread to the external environment require
emergency management staff to consider their impact on the
environment as well as on life and property. Emergency
management responsibilities include anticipating realistic
extensions of a given emergency and planning for them. Such
extensions must be addressed in the contingency plan when it is
first written and when it is revised.
To put these basic priorities and their subpriorities into a
meaningful hierarchy, the planner must evaluate systematically
those hazards or events the contingency plan is to address.
Planners must know how to identify the types of emergencies
that must be addressed and the hazardous characteristics of
materials, equipment, or processes that are present. They must
also be able to make hazard and risk assessments of these
hazardous situations. The location of people and property in
relationship to the hazard being evaluated must also be
considered.
An assessment analysis must be performed for each man-made
hazard and for harmful nature-caused events such as floods,
tornadoes, or hurricanes. In determining the potential man-made
hazards or acts of nature that could cause an emergency,
planners should also assess systematically their effects on life,
property, and the environment, including private enterprise, the
local community, and government. You will find more detail in
module 3.
Accident Prevention
Integrated as part of the safety and health management or risk-
management program, emergency management programs are

intended to prevent emergencies if possible, as well as to
prepare for them if they do occur.
As the name implies, accident prevention efforts should be used
to the fullest extent possible to prevent the harmful event from
ever occurring. It's difficult, however, to prevent terrorist
events and nature-caused disasters. The primary goal of
accident prevention is to keep people from being injured and the
harmful event from happening by implementing a variety of
control measures. These measures may not be totally effective,
however, and the business must develop a contingency plan for
handling harmful events. When a disaster does occur,
emergency management is applied to bring the event to the most
successful conclusion feasible in terms of protecting life,
property, and the environment.
III. Introduction to Federal and State Government Emergency
Management Programs and Emergency Response Plans
Some of the federally and state-mandated plans address only the
employer's or local government's obligation to provide
emergency response and recovery services during and after an
emergency. These plans may not address other issues that a
good emergency management program or plan should address.
Emergency response planning efforts are typically constrained
by how much authority the government possesses.
We will look at some of the federal laws, regulations, and
programs that federal and state agencies are implementing to
improve emergency management practices and programs. You
will find more details in module 5.
Most of the major cabinet-level departments and independent
federal agencies now have some involvement in emergency
management. The security changes in the past decade that
culminated in the creation of the U.S. Department of Homeland
Security in 2003 have enhanced the roles of federal, state, and
local governments in preventing terrorist attacks and in
preparedness and emergency management. These changes have
improved capabilities for emergency prevention, response, and
recovery. We will discuss two examples of this new federal

effort, the USA Patriot Actand the Office of Domestic
Preparedness (ODP) Emergency Responder Guidelines.
The USA Patriot Act
The USA Patriot Act (P.L. 107-56) requires the Department of
Transportation (DOT) and the Department of Homeland Security
to use the Federal Bureau of Investigation (FBI) to do
background checks on every applicant for a commercial driver's
license (CDL) for hazardous materials transport.
The DOT's Federal Motor Carrier Safety Administration has
issued regulations (49 CFR 383) for licensing CDL drivers that
prohibits any state from issuing, renewing, transferring, or
upgrading a license to operate a motor vehicle transporting a
hazardous material until certain evaluations are completed.
When someone applies to a state department of transportation
for a CDL for hazardous materials transport, the following
actions are taken in the order listed below.
1. The state agency forwards the truck driver's licensing request
to DOT.
2. The DOT Federal Motor Carrier Safety Administration asks
the FBI to conduct a background records check of the applicant.
3. The results of the FBI records check are sent to the
Department of Homeland Security's Transportation Security
Administration to ensure that the applicant does not pose a
security threat that would otherwise warrant a denial of the
hazardous materials endorsement.
4. The secretary of transportation officially determines whether
the applicant does or does not pose a security risk and informs
the state licensing agency.
Evaluating drivers before issuing CDLs is only one of the new
policies. Approved drivers must now meet additional safety
training requirements. Among these requirements are the
following:
· drivers must be familiar with the general provisions of the
hazardous materials regulations (HMR) and able to recognize
and identify hazardous materials
· drivers must know about specific HMR requirements

applicable to the driver's functions
· drivers must be familiar with emergency-response information,
self-protection measures, and accident-prevention methods
· companies must provide security-awareness training that
includes company security objectives, specific security
procedures, employee responsibilities, and actions to take in the
event of a security breach
For additional information on security plans, go to the U.S.
Department of Homeland Security Web site and search for the
terms preparedness, response, recovery, and cybersecurity. (See
the Relevant URLs list in the Additional Information section of
the syllabus.)
ODP Emergency Responder Guidelines
The second example of new federal efforts are the guidelines
issued by the federal Office of Domestic Preparedness (ODP),
which is now part of the Department of Homeland Security,
having moved from the Department of Justice. The
ODP Emergency Responder Guidelines are not regulations but
have been published to enhance the capabilities of state and
local jurisdictions to prepare for and respond to incidents of
domestic terrorism involving chemical and biological agents
and nuclear, radioactive, and explosive devices.
These guidelines address the training, skills, and knowledge
that law enforcement, fire service, emergency medical service,
emergency management, hazardous materials, and public works
personnel should have to deal with events involving weapons of
mass destruction.
ODP provides grant funds to enable state and local agencies to
purchase specialized equipment for emergency response
agencies, provides critical training to emergency response
personnel, supports state and local emergency-response
exercises, and provides technical assistance to state and local
emergency response agencies and public officials. For
additional information on ODP programs, go to the Web site of
the Department of Homeland Security, Office of Domestic
Preparedness.

IV. Federal Emergency Management Plans
Two principal federal emergency management plans are in use
today:
1. National Oil and Hazardous Substances Pollution
Contingency Plan (NCP)
2. National Response Framework (NRF)
National Oil and Hazardous Substances Pollution Contingency
Plan
The National Oil and Hazardous Substances Pollution
Contingency Plan (the short title is National Contingency Plan)
is operated by the National Response Team (NRT). It was
created from various environmental laws, including the
Comprehensive Environmental Response, Compensation and
Liability Act (Superfund Act) and the Oil Pollution Act (OPA).
The NRT comprises the 16-plus federal agencies with major
responsibilities for programs that affect the emergency
management field. The NRT is co-chaired by the U.S. Coast
Guard (USCG), now part of the Department of Homeland
Security, and the Environmental Protection Agency (EPA).
The USCG and the EPA have a lead role in helping state and
local agencies handle emergencies, principally those involving
chemical hazardous materials and oil-related product spills. The
USCG is the lead federal agency for helping with waterborne
spills in navigable waters. EPA is the lead for all others, and
each agency has trained federal on-scene emergency
coordinators who will respond to an incident under the authority
of their agency. If the emergency responders are not doing a
proper job, the federal on-scene coordinator may take control of
the incident.
Each of the 10 federal regions has a response team that operates
under the overall direction of the NRT. These teams comprise
representatives of federal agencies in the region who help the
states within the region. For more information on the National
Contingency Plan and the NRT, go to the EPA Web site and
search for National Contingency Plan (see the Relevant URLs

list in the Additional Information section of the syllabus).
National Response Framework
The second federal emergency management document is the
National Response Framework (NRF), which details how the
federal government will conduct response activities to
nonmilitary domestic emergencies. The NRF, which integrates
emergency response and law enforcement elements into a
national strategy, builds on and supersedes the U.S. Government
Interagency Domestic Terrorism Concept of Operations Plan
and the Federal Radiological Emergency Response Plan. As the
core operational plan for national incident management, the
NRF establishes national-level coordinating structures,
processes, and protocols that are incorporated into existing
federal interagency incident or hazard-specific plans like the
NCP and the emergency response assistance mandated by the
Robert T. Stafford Disaster Relief and Emergency Assistance
Act (P.L. 93-288, as amended). The Federal Emergency
Management Agency (FEMA), which is part of the Department
of Homeland Security (DHS), is the primary coordinating
agency for disaster response and recovery activities under the
Stafford Act for DHS. FEMA has signed agreements to
implement mandates under the Stafford Act with 27 federal
departments and agencies and the American Red Cross.
The American Red Cross functions as a federal agency in
coordinating the use of federal mass-care resources in a
presidentially declared disaster or emergency. Under the
Stafford Act, a governor may ask the president to declare a
major disaster or an emergency if an event is beyond the
combined response capabilities of the state and affected local
governments.
Based on the findings of a joint federal-state-local Preliminary
Damage Assessment indicating the damage is of sufficient
severity and magnitude to warrant assistance under this act,
assistance is then implemented by presidential declaration. No
direct federal assistance is authorized prior to this declaration.
In making a declaration to render federal assistance, the

president designates a federal coordinating official (FCO) to
coordinate the federal response.
If there is an event involving weapons of mass destruction or
some other terrorist incident, those who caused the event have
committed a federal criminal act. Under the Stafford Act, the
president can declare an emergency and offer assistance without
being asked to do so by a state governor. In this situation, the
FBI representative on the scene will usually be designated the
FCO to work with all of the agencies and organizations that
respond to help with the emergency, the investigation of the
event, and the recovery.
The NRF has emergency planning relationships with
· the National Contingency Plan
· the federal radiological emergency response plan
· the Department of Health and Human Services (HHS) Health
and Medical Services Support Plan for the Federal Response to
Acts of Chemical and Biological (CB) Terrorism
· the National Plan for Telecommunications Support in Non-
Wartime Emergencies
· other federal, state, and local plans
The NRF is divided into two parts: the Basic Plan and the
Emergency Support Function and Other Annexes. Regional
support teams help implement the federal assistance programs
and distribute supplies along with the emergency response team
that supports the FCO in coordinating the overall federal
disaster operation.
V. State and Local Plans
SARA Title III
Creation of SERCs and LEPCs
The Union Carbide plant disaster in Bhopal, India, in 1984
resulted in action in the United States to review what
emergency response capabilities were available at the local
level. The Superfund Amendments and Reauthorization Act
(SARA) was passed in 1986. Title III of this act is known as the
Emergency Planning and Community Right-to-Know Act
(EPCRA). SARA and EPCRA are major pieces of federal

legislation that authorized EPA and other federal agencies to
issue regulations addressing emergency management needs.
They have moved the United States ahead in preplanning for
anticipated emergencies.
SARA, through EPCRA, requires every state to set up an
infrastructure for preplanning for emergencies at the local level.
The EPA regulations under EPCRA require each governor to
appoint a state emergency response commission (SERC). After
some difficulties in a few states, all states now have a SERC.
The SERC divides the state into local planning districts. In most
states, but not all, the existing counties or, in the case of
Louisiana, the existing parishes, have been designated as the
local planning districts.
What Is a Local Emergency Planning Committee?
The Local Emergency Planning Committee (LEPC) is to be the
local source of information for its citizens on chemical hazards
and related information within the community. An LEPC
comprises representatives from every major organization that
has anything to do with handling emergencies within the
planning district. These representatives include
· local government officials
· firefighters
· hospital and emergency medical staff
· police
· business leaders
· Red Cross volunteers and staff
· staff from similar nonprofit organizations involved with relief
work
It is anticipated that by working together to develop an
emergency response plan for their community, better
coordination among these diverse groups will occur, and they
will better understand each organization's role in helping the
community in a disaster or other emergency.
Functions of LEPCs
The major cities have also been named as planning districts.
Each district has its own LEPC, and each LEPC has a number of

goals it is expected to meet under EPCRA. These include
developing, with public involvement, an emergency response
plan. Each plan must
· identify the facilities that contain extremely hazardous
substances and the routes used to transport them (many LEPCs
have used the hazardous materials placarding of transportation
vehicles as a base of information)
· describe the emergency response procedures to be followed
and designate a community coordinator to help implement the
plan
· include the emergency notification procedures, the methods
for determining the occurrence of a release, the probable
affected area and population, and the emergency-related
equipment and facilities available for emergency use from the
community and the industries in it
· include the evacuation plans, the training program for
emergency responders, and the methods and schedules for
exercising the LEPC plan
More information on EPA's role is available on the EPA Web
site and its "RCRA, Superfund & EPCRA Call Center" page (see
the syllabus).
To suggest what chemical hazards to plan for, EPA published a
list of substances that are extremely hazardous based on toxicity
to humans. EPA also required employers that had such
chemicals above the threshold quantities to report this fact to
the LEPC and to the local fire department, using prescribed
forms or listings.
LEPCs also received Tier One and Tier Two forms from
businesses that had hazardous materials or hazardous substances
requiring an OSHA material-safety data sheet (MSDS) when
such materials were above the threshold planning quantity.
OSHA has changed its hazard communication standard, and now
the MSDS is known as a safety data sheet in the revised
standard. Most businesses used the Tier Two form so they could
report once instead of twice. (Businesses were required to

report on a Tier One form that they had the materials. Then if
the LEPC wanted additional information, it could request the
Tier Two form, which had the location and other relevant
information about the materials. So most businesses that had to
send in a Tier One form just opted to send in the Tier Two and
be done with the required reporting. Thus, they didn't have to
wait for the LEPC to come back with a second request. The Tier
Two had everything the Tier One had, plus the additional
information on location.) Recently, EPA has requested
additional information on Tier Two reports, including the
number of people working at the facility, whether the facility is
covered by the EPA Risk Management Rule Plan (RMP), and
the current contact phone numbers and email addresses for
facility contact persons.
Some SERCs also compiled a list of chemicals and where they
were stored on plant sites, which is part of the Tier-Two form.
The state SERC received the information and compiled a
complete list of all the chemicals and which firms had them.
This list would be used by state agencies and LEPCs. Some
states, such as Maryland, require plant sites to update this list
of chemicals every two years and send it to the State
Department of the Environment.
To improve their overall effectiveness, LEPCs, in conducting
the training drills and exercises described in their plans,
coordinate with other agencies such as hospitals, which also
must participate in training drills to keep their emergency room
certifications from the Joint Commission on Accreditation of
Healthcare Organizations.
At the federal level, a support structure has been put in place to
help SERCs and LEPCs and for other purposes. The NRT's
regional response team structure follows the structure
established by the federal government in providing services to
the public through the 10 federal regions. The NRT's National
Contingency Plan that was discussed earlier was created to
coordinate the federal agencies' preparedness, planning, and
response responsibilities on a national level.

SARA required the NRT to develop and publish guidance
documents to help LEPCs develop, improve, and implement the
emergency response plans for which they are responsible. In
addition, several documents such as
· NRT-1: Hazardous Materials Emergency Planning Guide,
· NRT-2: Developing a Hazardous Materials Exercise Program,
and
· NRT-1A: Criteria for Review of Hazardous Materials
Emergency Plans
provide a mechanism by which the SERC and the Federal
Regional Response Team can review each LEPC plan. The
LEPC is required to conduct an annual review of its emergency
response plan. Find out more about EPA's emergency
preparedness by going to its Web site and searching
for LEPC (see the Relevant URLs list in the Additional
Information section of the syllabus).
National Response Center
The National Response Center, which USCG operates 24 hours
a day, seven days a week, receives reports of accidental oil-and-
hazardous-substance and hazardous-materials incidents from
across the nation. Some of these reports may trigger federal
responses. Every spiller of a chemical at or above the reportable
quantity has only 24 hours to report the spill to the National
Response Center. Several EPA, USCG, and DOT regulations
mandate the reporting of hazardous substance releases. The
National Response Center compiles its reporting data and shares
it with the public.
VI. Facility or Employer Plans
We will discuss the following facility or employer plans:
· National Response Team's One Plan
· EPA and USCG
· U.S. Department of Homeland Security and FEMA
· National Oceanographic and Atmospheric Administration
(NOAA)
National Response Team's One Plan
Recently the NRT has developed the Integrated Contingency

Plan Guidance (the One Plan), which integrates multiple federal
regulatory requirements into one document. The One Plan is
intended to be used by private enterprises to prepare emergency
response plans for responding to releases of oil and
nonradiological hazardous substances. The NRT is thus
providing a mechanism for consolidating the multiple plans
businesses may have prepared to comply with various federal
and state regulations into one functional emergency response
plan or integrated contingency plan (ICP).
The ICP brings together into one guidance document the
following emergency response planning regulations:
· EPA's Oil Pollution Prevention Regulation (Spill Prevention
Control and Countermeasure, or SPCC, and Facility Response
Plan requirements)—40 CFR 112.7(d), 112.20, and 112.21
· Department of the Interior—the old Mineral Management
Service was replaced after October 2011 by three separate
agencies, with the Bureau of Safety and Environmental
Enforcement requiring the Facility Response Plan regulation—
30 CFR 254
· Department of Transportation (DOT), Research and Special
Programs Administration's (RSPA) Pipeline Response Plan
regulation – 49 CFR 194
· USCG's Facility Response Plan regulation—33 CFR 154,
Subpart F
· EPA's Risk Management Programs regulation—40 CFR 68
· Occupational Safety and Health Administration's (OSHA)
Emergency Action Plan regulation—29 CFR 1910.38; Process
Safety Management Standard—29 CFR 1910.119; and
Hazardous Waste Operations and Emergency Response
(HAZWOPER) regulation—29 CFR 1910.120
· EPA's Resource Conservation and Recovery Act (RCRA)
Contingency Planning requirements—40 CFR 264, Subpart D,
40 CFR 265, Subpart D, and 40 CFR 279.52
For further details about these regulations on emergency
response planning or to obtain copies, go to the EPA Web site
and search for One Plan (see the Relevant URLs list in the

Additional Information section of the syllabus).
The One Plan is organized into three major sections, "Plan
Introduction Elements," "Core Plan Elements," and "Annexes,"
which are described below.
1. "Plan Introduction Elements" includes the purpose and scope
of the plan; the table of contents; general identification
information about the location, owner, mailing address, and
phone and fax numbers; key contacts for the plan; and other
information.
2. "Core Plan Elements" covers the initial actions to be taken by
those who discover an emergency, the initial emergency
response procedures for internal and external notifications, and
the procedures for preliminary assessment of the emergency
scene, such as type of hazard, magnitude, and areas threatened
by the emergency. This section also covers the procedures for
setting objectives and priorities for response, such as
· immediate goals for protecting employees and the public
· mitigating actions to control release
· containment and recovery as needed
· identification of personnel and equipment needed to handle the
response
· procedures for implementing the tactical plan
· procedures for mobilizing resources
· termination and follow-up actions
This section's guidance for private enterprises also must be
interfaced with the LEPC's plan and, if appropriate, the Area
Committee's Contingency Plan created under the Oil Pollution
Act of 1990 (OPA) section 4202(a)(6).
3. "Annexes" contains a number of annexes that address the
emergency response management system, including the
command structure for managing an emergency incident or
event. Most emergency response plans use the Incident
Command System (ICS) or the National Incident Management
System (NIMS). Both traditionally have a single incident
commander supported by a command staff.
The NIMS includes both the ICS and the Unified Command

System used for larger emergency responses in which
representatives from the federal and state on-scene coordinators
and the responsible party work together as the command
structure. The Unified Command System allows all parties who
have jurisdictional or functional responsibility for the incident
to develop jointly a common set of objectives and strategies and
to work together to carry them to conclusion. The Unified
Command System is recognized in the National Contingency
Plan developed by the NRT. Section III also covers salvage
plans, waste management, financial aspects for the cost of the
response, incident documentation, training and exercises or
drills, and other subjects.
EPA and USCG
The EPA co-chairs the NRT and has many other emergency
management responsibilities. The Chemical Emergency
Preparedness and Prevention Office is EPA's lead office for
helping with emergency management issues. It has developed
fact sheets, guidance documents, newsletters, and other
materials to help interested organizations and individuals
improve the level of emergency preparedness and planning. For
more information on this office, go to the EPA Web site and
search for Chemical Emergency Preparedness and Prevention
Office (see the Relevant URLs list in the Additional
EPA has promulgated emergency management plan requirements
for facilities to comply with under the following laws:
· Clean Water Act: 40 CFR 112.1 through 112.7 requires Spill
Prevention, Control and Countermeasure (SPCC) and storm-
water plans
· Clean Air Act: 40 CFR 68 requires Risk Management Plans for
Fixed Facilities, including a worst-case scenario as part of the
planning process
· Resource Conservation and Recovery Act (RCRA): 40 CFR
264 and 265 requires a Contingency Plan for Hazardous Waste
Spills or Accidental Releases
· Oil Pollution Act: 40 CFR 112.20 to 112.21 requires Facility

Response Plans
More details on the EPA's role in emergency management will
be presented in modules 3 and 5.
The USCG, which is now a major part of DHS, is co-chair of
the NRT and has many other emergency management
responsibilities, including helping to protect American ports
from terrorist attacks and saving lives on navigable waterways.
The USCG, as mentioned earlier, operates the National
Response Center, which receives all federally required reports
of spills and accidental releases of hazardous materials,
hazardous waste, oil and related products, chemicals, and so
forth. It provides a toll-free number nationwide for persons to
use in making their reports of releases at or above the
established reportable quantity limits for the material in
question. The responsible party must make the report within 24
hours of the release. For additional information on this center,
go to the USCG Web site and search for National Response
Center (see the Relevant URLs list in the Additional
The USCG is responsible for implementing the Oil Pollution
Act requirements for the protection of U.S. waterways and
ports. As part of the implementation efforts, area committees
have been established for the major U.S. domestic ports, and
each area committee performs duties similar to those of LEPCs.
For more information on domestic port emergency planning, go
to the USCG Web site and search for Area Committees (see the
Relevant URLs list in the Additional Information section of the
syllabus).
In addition to the area committees’ activities, the USCG has
promulgated requirements for vessel owners to develop and
implement vessel response plans; security measures for ships
and ports; and requirements for port facility owners to develop
and implement facility emergency response plans, including
security measures.
U.S. Department of Homeland Security and FEMA
The U.S. Department of Homeland Security (DHS) was created

in 2003 and was given cabinet-level status. FEMA, which had
been an independent federal agency that coordinated the federal
government's role in helping the states prepare for natural
disasters and some man-made disasters, such as terrorist
incidents or dam failures, has been merged completely into this
new department. FEMA had taken over the role of the old Civil
Defense Preparedness Program. State and local governments
have created similar coordinating agencies.
Now DHS, using FEMA, serves as the lead agency in organizing
assistance to other countries when a natural disaster occurs and
the host country requests assistance from the United States.
DHS established and maintains the National Response
Framework document for the federal government mentioned
earlier. DHS and FEMA provide some hazard mitigation
planning and grant programs for prevention measures under the
Stafford Act. DHS has also issued mandatory rules for Chemical
Facility Anti-Terrorism Standards to enhance the security of
chemical plant and oil refinery facilities (6 CFR 27, April
2007). These standards require facility owners to conduct
security vulnerability assessments, develop site security plans,
perform background checks on staff members, perform
inspections and audits, and carry out other measures. For more
details, go to the DHS Web site and search for chemical
security (see the Relevant URLs list in the Additional
The National Fire Academy and Emergency Management
Institute
The Department of Homeland Security and FEMA support
emergency management efforts through training programs. The
National Fire Academy (NFA) and the Emergency Management
Institute (EMI), both based in Emmitsburg, Maryland, provide
training for emergency responders. The National Fire Academy
and the National Fire Administration of FEMA train the nation's
fire service officer corps. The Emergency Management Institute
trains emergency managers and law enforcement officials
involved in handling emergencies in their local jurisdictions.

For more information on the NFA and the EMI, go to the FEMA
Web site and search for those terms (see the Relevant URLs list
in the Additional Information section of the syllabus).
National Oceanographic and Atmospheric Administration
The National Oceanographic and Atmospheric Administration
(NOAA) is the lead federal agency in tracking weather events
that have the potential to destroy lives and property. The
National Weather Service, an agency within NOAA, provides
the weather watches and warning designations for potentially
harmful weather events. For additional information, go to the
NOAA Web site and click on the weather icon (see the Relevant
URLs list in the Additional Information section of the syllabus).
NOAA has the past weather database that can be useful in
determining what types of emergencies to cover in a
contingency plan. NOAA helps directly in the emergency
management arena because it supports emergency responders in
several ways. First, it develops databases for chemical hazards
and the necessary software to use them. This system is known as
CAMEO II. For more information, go to the NOAA Web site
and search for CAMEO (see the Relevant URLs list in the
Second, NOAA can provide plume modeling for hazardous
releases into the air or onto a waterway. This modeling can help
determine the direction and hazard level of a vapor cloud or
contaminant. NOAA's software to display the plume over
relevant maps and the airborne software is called ALOHA. For
more information, go to the NOAA Web site and search
for ALOHA (see the Relevant URLs list in the Additional
Third, NOAA has relevant maps for each county in the country
that can be downloaded and used by emergency responder
organizations. These maps are in a software program known as
MARPLOT. For more information, go to the NOAA Web site
and search for MARPLOT (see the Relevant URLs list in the
VII. Federal Disaster Investigative Agencies

Two independent federal agencies have the authority to
investigate man-made disasters or incidents and to publish
reports of their findings. Each is composed of a five-member
board with a staff and teams that can be sent out to investigate
incidents under their authority. These two agencies are
1. the National Transportation Safety Board
2. the Chemical Safety and Hazard Investigation Board
National Transportation Safety Board
The National Transportation Safety Board (NTSB) has the
authority to investigate any transportation incidents or disasters
such as airplane crashes, train derailments, pipeline ruptures,
and shipping incidents. The NTSB provides some transportation
disaster assistance to victims and families that have been
affected by a transportation incident. For information on NTSB
investigations and their disaster assistance, go to the NTSB
Web site (see the Relevant URLs list in the Additional
Chemical Safety and Hazard Investigation Board
The Chemical Safety and Hazard Investigation Board (the
Chemical Board) has authority to investigate industrial and
commercial non-transportation disasters or incidents. The
Chemical Board's mission and reports can be found at its Web
site (see the Relevant URLs list in the Additional Information
section of the syllabus).
These investigative bodies send their representatives and
investigators to the scene of an emergency incident. If any
criminal activity is suspected, the FBI responds along with local
authorities. The Bureau of Alcohol, Tobacco, Firearms and
Explosives, now part of the U.S. Department of
Justice, responds if explosives are thought to be involved in the
event in some manner.
VIII. Brief Introduction to National Voluntary Standards, Trade
Associations' Programs, and International Programs
Several national consensus-writing and standards-adopting
organizations address topics related to emergency management.

We will now describe these organizations.
National Voluntary Standards
National Fire Protection Association
The National Fire Protection Association (NFPA) in Quincy,
Massachusetts, has developed and published a variety of
documents useful in the emergency management arena. These
include emergency responder training standards, a model
building code and fire prevention code, a standard on
emergency services, an incident management system,
disaster/emergency management and business-continuity
programs, a recommended practice of pre-incident planning, and
others. These documents have been made available to members
of NFPA and others for voluntary use, and some have been used
for regulatory purposes by government agencies. For additional
information on NFPA, go to its Web site (see the Relevant
American National Standards Institute
Another national consensus standards-writing and -adopting
organization is the American National Standards Institute
(ANSI). It has adopted a variety of safety standards and
mechanical safety codes such as those for elevators and boilers
that were developed by the American Society of Mechanical
Engineers. ANSI serves as the U.S. representative to the
International Standards Organization (ISO), which works on
developing worldwide standards for industrialized nations on a
variety of topics including the ISO 14001 standard for
Environmental Management Systems.
State and local governmental authorities do adopt as mandatory
regulations many of the ANSI standards and NFPA codes for
public safety that affect emergency preparedness and prevention
requirements.
International Code Council
The International Code Council (ICC) was created by various
model building code groups that wanted to develop a single
model building code for the whole country to replace the old
regional model building codes that were used in the last

century. The Building Officials and Code Administrators
International, Inc., the Southern Building Code Council, and
others came together to develop the International Building
Code, the International Fire Code, and other building code-
related documents for use by building officials and code
administrators at the local and state levels of government. The
NFPA did not support some of the types of changes that were
being made by the ICC in its development of the International
Building Code, so it developed its own model building code and
other building code support documents, which are mentioned
above. For more information on the ICC, go to its Web site (see
the syllabus).
Trade Association Programs
Many trade associations give their members guidelines and
assistance to help them prepare to handle emergencies on their
premises and to protect the general public. One such
organization is the American Chemistry Council (ACC), which
represents more than 90 percent of U.S. commercial chemical
producers. It established and runs the Chemtrec 24-hour
emergency response communication service that is recognized
in the DOT Emergency Response Guidebook. Chemtrec is one
of the primary sources of accurate and current chemical hazard
information that is widely used by emergency responders across
the United States.
Responsible Care Management System Program
The ACC initiated the Responsible Care Management System
Program (Responsible Care) in the United States in 1988. The
council requires all its members to implement this program, and
it has been shared with other chemical manufacturing industries
worldwide.
The Responsible Care Program has been expanded to include
the transportation of chemicals. The ACC provides the
Chemtrec system to support emergency responders, as well as
the Transcaer program, which supports chemical transportation
safety. Transcaer is a voluntary national outreach effort that

helps communities that have major transportation routes within
their jurisdictions, and the Chemtrec system provides
emergency responders with information on members' chemical
hazards, as well as other relevant information to enhance
transportation safety. Transcaer assists in planning, assessing,
and revising a community’s hazardous-materials emergency
response plan, and it can help with the training exercises that
are used to evaluate the community plan. For more information,
visit the ACC Web site and search for Responsible Care
Program, or click the Safety tab to learn more about
transportation safety and other safety topics (see the Relevant
IX. International Programs
The United Nations (UN) has a number of programs that involve
emergency management of man-made and natural disasters. The
Organisation for Economic Co-operation and Development
(OECD) and the International Labour Organization (ILO) have
both developed documents to assist member nations in handling
man-made emergencies. The OECD published the Guiding
Principles for Chemical Accident Prevention, Preparedness and
Response in 1992 as guidance for governments, industry, labor,
and others in establishing programs and policies related to
prevention of, preparedness for, and response to emergencies
involving hazardous substances.
The ILO has developed and published convention No.
C174, The Prevention of Major Industrial Accidents, which
addresses the preplanning for and the response to major
industrial disasters. This document also provides guidance for
incidents that cross national borders. It establishes roles for
government, industry representatives, and workers in handling
on-site and off-site emergencies, among other subjects. This
convention is written so that it can be adopted as a national
code by the member states of the ILO. It is the first ILO
convention to address public safety issues and environmental
issues along with workplace issues. The ILO has developed and
adopted other conventions, such as the C170 Chemicals

Convention in 1990, the C155 Occupational Safety and Health
Convention in 1981, and others, to assist ILO member states.
The EPA Risk Management Program, under 40 CFR 68, and the
OSHA Process Safety Management Program, under 29 CFR
1910.119, address the major components of the ILO C174
Convention for the United States.
The UN also adopted a convention on the "Transboundary
Effects of Industrial Accidents" in 1992. This convention was
developed to assist member nations in establishing formal
governmental codes stating the procedures for handling
emergencies involving unwanted hazardous chemical releases
and other emergencies, with special emphasis on cross-border
incidents to enhance greater cooperation and coordination
among nations that share common borders. Additional
information is available on the UN Web site (search for OECD).
Also see the ILO Web site (see the Relevant URLs list in the
The UN has many other activities involving
· nuclear safety
· international transportation of dangerous goods (hazardous
materials in the U.S.)
· biological and chemical weapons that could be used in a
terrorism incident
· major weather-related events (see World Meteorology
Organization)
You can find more information on these topics by going to the
UN Web site and searching for relevant terms.
Many of the UN efforts addressing these subjects have been put
into a convention for the UN members to adopt as law for each
member's nation. Complementary organizations such as the
International Red Cross and the Red Crescent also provide their
services during some of these related emergency events.
Additional information on these voluntary international
organizations will be provided in module 6.
X. Hazard Analysis, Risk Analysis, and Risk Management
Hazard Analysis

A hazard is something such as a chemical or process or weather
event that can harm people, property, and/or the environment.
The more serious the hazard, the greater its capacity to cause
serious harm. The level of hazard depends on the characteristics
or properties of the material, process, or event. These properties
cannot typically be changed, but the severity of the exposure to
them and the harm caused by them can be measured and must be
controlled.
Hazard analysis is the process by which one evaluates those
serious hazards that are present on the site and prioritizes them
according to when they will be addressed and what means or
methods are available or could be available to control them.
Hazard analysis has three basic steps:
1. identifying or recognizing the hazard and its location on the
site
2. understanding or assessing the hazard and its potential for
harming people, property, and the environment (this step does
not include any calculations on the frequency or probability of
the event happening, only that it is present on the site and has
the potential to cause serious harm to people, property or the
environment)
3. identifying readily available or obtainable controls that could
reduce the severity of the exposure or contribute to mitigation
of the hazard to people, property, or the environment
Various methodologies have been developed to systematize the
approach to hazard analyses, ranging from somewhat
unsophisticated methods to extremely complex models. Some
examples of recognized methodologies are:
· hazard and operability study
· failure mode and effects analysis
· fault-tree analysis
· what-if
· what-if and checklist
OSHA has required employers to use hazard analysis methods
through its Process Safety Management standard, which was
required by the Clean Air Act Amendments of 1990 (CAAA).

EPA has used hazard analysis in selecting chemicals to
designate as extremely hazardous substances under SARA and
EPCRA. The list of extremely hazardous substances has been
used as the starting point to collect information on the serious
chemical hazards present in the local community and to begin
developing the local emergency response plan, as was
mentioned earlier. EPA has also used hazard analysis in
implementing the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) for determining
which sites to include on the National Priorities List and for
determining cleanup criteria for selected sites.
Risk Analysis
A risk differs conceptually from a hazard. Risk is the chance or
probability of a hazardous event occurring. The more likely a
hazardous event is to occur or the more frequent the occurrence,
the greater the chance that people, property, or the environment
will be adversely affected by the event. The two types of risk
are acute and chronic risks. Acute risks normally have the
potential to cause life-threatening harm to people at the
beginning of the event. Chronic risk may only be a periodic
equipment failure that disrupts a process because it occurs
frequently.
Risk analysis is the process used to measure the probability of a
hazardous event occurring. It includes the step of making a risk
assessment, which, for example, separates the intrinsic
properties of the chemical from the risk associated with some
exposure level and its duration. The exposure level and time-of-
exposure measurements may be based on estimates by experts in
the field or on quantitative data collected over many years. No
matter how well designed and reliable a control measure is, it is
subject to some level of failure.
Risk Management
Risk management is the ranking of serious hazards to people,
property, or the environment, and the use of risk analysis in
making decisions about the cost effectiveness of instituting one
control measure over another to help prevent or mitigate the

hazardous event. Risk management evaluates available control
measures to prevent the incident or to reduce the level of
potential damage that could result from an incident.
The first priority in risk management is to prevent the
hazardous event. If prevention is unsuccessful or impossible,
then minimizing the potential damage becomes the priority. In
conducting a risk analysis, risk management must consider both
internal and external factors in recommending to management a
course of action to follow to control the level of risk. Examples
of internal risk factors are employee or public exposure levels
and downtime resulting from a response to the emergency.
External factors include the public's response (either positive or
negative) to a hazardous event and the effect that response has
on the organization's public image.
Risk management helps an organization's managers determine
the sequence for controlling hazards and the control measures to
implement given the available resources. Every private and
public enterprise wants to get the most benefit for each dollar
spent on hazard-control measures. When the controls fail and
the alarms are sounded—whether they are automatic or manual
procedural steps—emergency management is activated to bring
the emergency event to the most satisfactory conclusion
possible.
For information on the government mandates for risk
management programs, see the EPA Risk Management Program
requirements in 40 CFR 68, issued under the CAAA. Also, DHS
has mandated (in 6 CFR 27) risk management programs for
chemical facilities, as mentioned earlier. Go to the DHS Web
site and search for chemical security for more details (see the
Relevant URLs list in the Additional Information section of the
syllabus). EPA is also using risk management in implementing
CERCLA and RCRA cleanup strategies and for determining the
ranking of clean-up sites on the National Priorities List.
XI. The DOT Emergency Response Guidebook
The United States has entered into a treaty with Canada and
Mexico, known as the North American Free Trade Agreement

(NAFTA). Among other things, it addresses issues regarding the
transportation of hazardous materials across borders.
Emergencies that may occur at the borders are also part of an
expanded understanding among the three nations about how they
will cooperate to protect people, property, and the environment.
For many years, USCG and Canadian authorities have
cooperated in controlling waterborne spills in the Great Lakes,
waterways between Washington state and British Columbia, and
those on the east coast of Maine. The NAFTA treaty has also
formalized this cooperative effort between these two countries.
All three countries have also contributed to the creation of
the Emergency Response Guidebook, published by DOT's
Research and Special Programs Administration. This guidebook
is an essential reference used by emergency responders to
chemical spills and transportation incidents involving hazardous
materials in all three countries. It has been published in French,
Spanish, and English and is typically updated every three years.
A number of federal regulations require the use of
the Emergency Response Guidebook, and it has become one of
the basic tools for emergency responders and those involved in
transporting hazardous materials. For example, under the OSHA
rule for Hazardous Waste Operations and Emergency Response
(HAZWOPER) 29 CFR 1910.120, the first level of formal
emergency responder training requires an understanding of
the Emergency Response Guidebook and its use.
Congress mandated EPA to adopt the HAZWOPER rule as an
EPA rule (in 40 CFR 311) to cover other emergency responders
over whom OSHA has no jurisdiction.
Using the Emergency Response Guidebook
The DOT Emergency Response Guidebook is color-coded to
help first responders find essential information quickly in the
event of an incident involving the transportation of hazardous
materials.
The yellow-bordered pages list the names of hazardous
materials by ID numbers, given in numerical order, and give the
corresponding guide numbers to use to find the safety

recommendations. The names of hazardous materials that are
extremely toxic are highlighted, and more information is given
in the green-bordered pages.
The blue-bordered pages list the names of hazardous materials
in alphabetical order and give the corresponding guide numbers
to use to find the safety recommendations. The names of
hazardous materials that are extremely toxic are highlighted,
and more information is given in the green-bordered pages.
The orange-bordered pages give the safety recommendations
and emergency response information for each guide number
identified in the yellow-bordered and blue-bordered pages.
The green-bordered pages identify toxic materials by ID number
and recommend safe distances from these materials according to
whether the spill is large or small or whether it is night or day.
They provide an initial isolation distance and a protective
isolation distance.
Here is a brief summary of the steps to follow in using the ERG.
· Identify the material by its 4-digit ID number or by its name.
· Look up the ID number in the yellow-bordered pages or the
name in the blue-bordered pages to get the guide number for the
material.
· Use the guide number in the orange-bordered pages to find
safety recommendations and emergency response information.
The highest-ranked hazard to humans will be listed first.
· Find additional recommendations in the green pages by using
the ID number if a name was highlighted in either the yellow-
bordered or blue-bordered pages.
The Practical Applications component of this module has some
problem scenarios where you can practice using the
DOT Emergency Response Guidebook.
For additional information, go to the Web site of the
DOT Emergency Response Guidebook (see the Relevant URLs
Module 5: Federal, State, and Local Government Emergency

Management Regulations and Programs
Topics
I. Federal Government Regulations and Programs Affecting
Emergency Planning and Preparedness
II. State and Local Government Regulations and Programs
Affecting Emergency Planning and Preparedness
In this module, we discuss the programs that various levels of
government have available to support the field of emergency
management. Some programs support efforts to develop
effective contingency plans and area and local emergency
response plans and their implementation. They also provide
funding for equipping and training the emergency response
community to become more proficient in handling specific types
of emergencies.
I. Federal Government Regulations and Programs Affecting
Emergency Planning and Preparedness
Office of Technology Assessment
Following the disasters in Bhopal, India, and in Chernobyl, the
U.S. Congress asked the Office of Technology Assessment
(OTA) to determine the readiness of U.S. emergency services to
handle hazardous materials emergencies. The OTA
report, Transportation of Hazardous Materials Summary (July
1986), found that the emergency response services lacked
training in handling hazardous materials emergencies.
According to the report,
· less than a quarter of the police and fire emergency services
have received adequate training to address a hazardous
materials emergency
· most local emergency response forces have insufficient
financial resources to take advantage of available training
· a national strategy to provide hazardous materials emergency
response training to local and regional personnel at either the
basic or advanced levels is an urgent national priority
As a result of this OTA report and others, the federal
government initiated efforts to enhance the training of the

emergency response community through grants, model training
programs, and other measures. Since 9/11, the federal
government has improved significantly its commitment to assist
state and local emergency responders.
Environmental Protection Agency (EPA)
EPA provides a number of educational documents to inform
employers, employees, and citizens of their rights and
obligations under the laws and regulations it administers. The
EPA Risk Management Program is one good example. The
National Safety Council's Environmental Health Center, in
cooperation with EPA, has developed several booklets to
educate the public about chemical hazards in their communities
and how to help plan for them. Two of these booklets are:
1. Guides to Chemical Risk Management—What Makes a
Hazard Hazardous: Working with Chemical Information (EPA
1999)
2. Guides to Chemical Risk Management—Chemical Safety in
Your Community: EPA's New Risk Management Program (EPA
1999)
For additional information on chemical safety in the
community, go to the EPA Web site and search
for LEPC or chemical emergency preparedness and
prevention or CEPPO (see the Relevant URLs list in the
The Risk Management Program rule requires that facilities it
covers develop worst-case scenarios for a chemical release, but
politicians and others fear that terrorists could use this
information. The original purpose of worst-case scenarios was
to help local emergency planning and response committees to be
better prepared by planning for such events. It was also hoped
that facilities would learn to conduct their business so as to
prevent such events.
Today, EPA is working with local authorities and others to
ensure that only authorized organizations and individuals can
gain access to the worst-case scenarios and that the information
is not released to the public at large. EPA, in cooperation with

state and local authorities, has established federal reading
rooms in every state where printed copies of the worst-case
scenarios and related offsite consequences analysis can be
reviewed. To keep this information from terrorist organizations,
these paper copies may not be removed, photocopied, or
otherwise reproduced, although note taking is allowed. For
additional information on these reading rooms, go to the EPA
Web site (see the Relevant URLs list in the Additional
EPA has also developed a variety of documents to help facility
owners better understand their obligations in preventing
emergencies, plan and develop contingency plans for those
types of emergencies they anticipate could occur, and interface
their plans with the local emergency planning committee’s plans
for the community.
EPA has provided industry guidance for a variety of facilities
covered under the Risk Management Program such as ammonia
refrigeration plants, propane storage facilities, and others. For
more information on the EPA outreach to help facilities comply
with the Risk Management Program rule, go to the EPA Web
site and search for RMP or your topic of interest.
Occupational Safety and Health Administration (OSHA)
OSHA has published and made available to the public its field
enforcement directives to its field staff, as well as several
booklets to help organizations and employers that are
developing contingency plans and want to ensure that they are
meeting the relevant mandatory OSHA standards. OSHA has
provided further guidance on its Hazardous Waste Operations
and Emergency Response standard (HAZWOPER) 29 CFR
1910.120 through its directives CPL 02-02-071 and CPL 02-02-
073, addressing emergency planning. Two booklets that are
helpful are:
1. Fire Service Features of Buildings and Fire Protection
Systems (2006)
2. Preparing and Protecting Security Personnel in
Emergencies (2007)

OSHA was required by the Clean Air Act Amendments of 1990
to issue its Process Safety Management standard (PSM) as EPA
was required to issue its Risk Management Program rule (RMP),
as has been stated earlier. EPA has developed several booklets
on its Risk Management Plan and Program (RMP) regulation.
Some of the EPA Web sites present information that directly
addresses this regulation. The booklets will also help you
understand the OSHA Process Safety Management (PSM)
standard because EPA has adopted the OSHA PSM rule into its
own rule, calling it EPA Program 3. This Program 3 is the most
stringent level of regulation of the EPA RMP rule, and the EPA
guidance would also help you understand the OSHA PSM rule.
OSHA, too, has published helpful guidance on its PSM rule and
some field directives, including CPL 02-02-045 and CPL 2-
2.45A. These EPA and OSHA guidance documents will be
helpful to those preparing contingency plans and emergency
response procedures for facilities that are affected or covered by
these regulations.
OSHA has revised its Hazcom standard to be compatible with
the UN transport safety requirements for classification of
chemicals/materials and for labeling and warnings on chemical
packaging. OSHA has now adopted the 16-section format for all
safety data sheets for use in worker training. There are new
criteria for describing various types of hazards when workers or
emergency responders are exposed to such chemical hazards.
The revised Hazcom standard is found in 29 CFR 1910.1200, as
was mentioned in module 2.
For more information on PSM, HAZWOPER, and Hazcom
compliance issues, go to the OSHA Web site, click the
Enforcement tab, and search for the directive of interest.
U.S. Department of Transportation (DOT)
As a result of the OTA study discussed earlier, the Hazardous
Materials Transportation Act was revised to include a fee
schedule that was implemented by DOT to provide funds for the
Hazardous Materials Emergency Preparedness (HMEP) grants
program. This program supports hazardous material emergency

response planning and training activities and related measures
conducted by states, local governments, and Indian tribes.
Congress had intended that over 14 million dollars would be
made available annually from this grant program, but in early
2003, DOT had to make adjustments to the fee schedule to
assure this funding.
Amendments to this act require DOT to also develop a training
curriculum to accompany the HMEP training grants. An
assessment tool must accompany the curriculum to better assure
that public-sector employees can respond safely and effectively
to hazardous materials emergencies. The curriculum guidelines
were developed in cooperation with DOT, the Federal
Emergency Management Agency (FEMA), and others.
FEMA processes the grants to the states. These grants must be
spent on training those public employees involved with
prevention efforts, emergency response planning, and
emergency response operations. The curriculum has been
developed to ensure that the public emergency responders who
take this training are better able to meet the OSHA, EPA, and
DOT emergency planning and response training levels as stated
in their regulations. It is also written to meet the relevant
National Fire Protection Association standards addressing
emergency response to hazardous materials events, while also
meeting the requirements of Presidential Directive No. 5 and
the NIMS.
Department of Energy (DOE)
DOE has developed a program to remove hazardous transuranic
waste from temporary storage sites around the country to a
permanent site at the Waste Isolation Pilot Plant (WIPP) near
Carlsbad, New Mexico. Transuranic waste consists of clothing,
tools, equipment, and other such items that have been used in
research and other activities over the years that are
contaminated with trace amounts of man-made radioactive
elements, mostly plutonium, uranium, and so on. No high-level
waste or spent nuclear fuel is included in this waste. Most of
this waste comes from DOE and Department of Defense

research facilities that have been storing it on their sites.
The best way of moving this waste is in Trupact-II containers
on trucks. The Nuclear Regulatory Commission has certified
these containers, and they have passed a rigorous testing
protocol to demonstrate their ability to contain the waste under
extreme accident conditions.
In 1988, DOE initiated an emergency-response training program
to prepare for the beginning of shipments in 1999. The program
was offered at no cost to emergency response personnel along
the routes upon which the waste would be shipped to New
Mexico. The WIPP legislation required this training program,
and OSHA had to approve the curriculum before it could be
offered more widely.
OSHA assured that the program would help meet its
requirements for hazardous materials emergency response. The
training focused on ways of avoiding ionizing radiation and
related incidents, a major concern of DOE. DOE has covered the
cost of training thousands of emergency responders under this
program. The shipments of more than 83,000 containers made to
date have experienced no major incidents. For additional
information, go to the DOE Web site and search for WIPP.
Other Agencies
U.S. Department of Homeland Security
The Department of Homeland Security (DHS), which includes
FEMA, distributes grants to state and local governments to
enhance the emergency preparedness of first responders to
potential terrorist incidents. Grant monies are used to develop
emergency response plans and to purchase needed equipment,
supplies, and training to handle terrorist incidents.
DHS includes the U.S. Coast Guard (USCG), which is the co-
chair for the National Contingency Plan, and DHS maintains the
National Response Framework document. FEMA is the lead
agency for DHS in carrying out emergency response work under
the Robert T. Stafford Act. For more information on the DHS
programs and grant program, go to the DHS Web site and search
for your topic of interest.

National Institute for Occupational Safety and Health
The National Institute for Occupational Safety and Health
(NIOSH) is the research arm for OSHA and the Mine Safety and
Health Administration (MSHA). NIOSH is the approval agency
for testing and certifying respirators for inhalation protection
that are used to meet OSHA and MSHA requirements. NIOSH
has developed chemical data information sources on its Web
site, and it has established the Emergency Response Safety and
Health Database to assist emergency responders and emergency
planners in their work. This emergency response database
covers biotoxins, blister agents, nerve agents, lung-damaging
agents, and many other substances. For more information on
NIOSH, go to its Web site and search for Emergency Response
Safety and Health Database, or for other topics of interest.
Agency for Toxic Substances and Disease Registry
A small agency within the Centers for Disease Control (CDC) in
the Department of Health and Human Services, the Agency for
Toxic Substances and Disease Registry (ATSDR) supports the
emergency response community in a number of areas involving
medical care and air contaminant sampling and analysis.
ATSDR has:
· sent teams to assist with the emergency response to
bioterrorism incidents
· published medical management guidelines for mass casualties,
including recommendations for on-scene emergency care, pre-
hospital care, and hospital medical management of patients
exposed to hazardous materials
· worked with others to develop additional medical management
guidelines
· assisted the CDC emergency operations center
· worked through the federal regional response teams and the
Public Health Service Commissioned Corps Readiness Force to
assist state and local emergency response operations
· developed disaster response training documents and videos
based on lessons learned from actual incidents to assist local
communities in developing more effective disaster planning

documents
· developed an emergency medical planning guide, hospital
emergency planning guide for contaminated patients, and other
supporting videos and documents
ATSDR provides technical assistance to community emergency
planners in designing, implementing, and evaluating realistic
scenarios to test emergency response plans and contingency
plans. Such assistance is usually aimed at hospital emergency
staffs, on-scene emergency medical care professionals, public
health officials, and hazardous materials response teams.
After the World Trade Center disasters, ATSDR helped the New
York City Department of Health sample the air and dust in
residences in lower Manhattan. It developed a draft sampling
plan and conducted the technical review of the analytical results
from the sampling efforts to determine whether city residents
were being exposed to harmful substances. For more
information on these environmental testing efforts in lower
Manhattan, go to the ATSDR Web site (see the Relevant URLs
ATSDR is just one of many agencies within the CDC. It and the
Public Health Service play the lead roles for the Department of
Health and Human Services in helping and cooperating with the
other federal agencies in supporting emergency planning and
response efforts to WMD events and other national medical
emergencies like the SARS, West Nile Virus, and influenza
emergencies.
II. State and Local Government Regulations and Programs
Affecting Emergency Planning and Preparedness
The flow of federal funds to state and local governments has
encouraged the development of contingency plans, the
assessment of the vulnerabilities of various buildings and public
assembly areas, and the equipping and training of first
responder units to better handle potential terrorist and other
events. These funds enable local emergency response units to
purchase:
· thermal imagers to better locate hot spots in buildings and

structures during fire or bomb emergencies
· test kits for nerve agents, gas monitors for oxygen and carbon
monoxide, and other gear
· hazardous materials response trailers equipped with chemical-
resistant suits, respirators, and other appropriate equipment that
could be needed in an emergency response to a hazardous
material or WMD incident
· bomb-detecting robots and bomb suits for personnel
We will now discuss some emergency planning and
preparedness programs in Maryland and New Jersey to give you
an idea of what states are doing in the field.
Maryland Programs
The governor of Maryland established an Office of Homeland
Security within the Maryland Emergency Management Agency
(MEMA) to serve as the direct liaison to the U.S. Department of
Homeland Security and to coordinate with all state departments
and agencies and local jurisdictions responsible for homeland
security and emergency preparedness. This office is involved
with the Maryland Terrorism Forum, which includes
representatives from the major Maryland state agencies such as
the state police and the departments of health, environment, and
transportation, as well as MEMA.
The office, coordinating with the federal Office of Domestic
Preparedness, offers training to emergency response
organizations in Maryland and distributes federal grant monies
to hazardous materials teams throughout the state. For more
information on Maryland's homeland security efforts, go to the
Maryland state Web site.
Working with local authorities, MEMA has developed disaster
evacuation plans and procedures for hurricanes and other
emergencies. It has provided to Maryland citizens hazard-
awareness information on a variety of nature-caused disasters
such as floods, tornadoes, and fires. It also provides emergency
management alerts and preparedness information and serves as
the liaison with FEMA. For more information on MEMA, go to
its Web site (see the Relevant URLs list in the Additional

New Jersey Programs
The State Police, the Office of Emergency Management, and the
Hazardous Materials Emergency Response Planning Unit in
New Jersey cooperated to develop model training programs for
various levels of emergency response competency. They have
developed two levels of training for first responders to WMD
events. The first level of training focuses on awareness, and the
second focuses on operations. They have also developed model
training programs for New Jersey hazardous materials
emergency response that include the awareness, operations, and
technician levels.
These courses are being used statewide to help standardize the
level of training for various levels of emergency response and
to improve the quality, effectiveness, and safety of the
emergency responders. They are structured to help the local
emergency responders who complete them to meet the OSHA
and EPA regulatory training requirements for those responding
to hazardous materials emergency events.
These New Jersey agencies have also developed refresher
training courses to help New Jersey emergency responders
maintain their competencies.
Other State Efforts
All the states are now involved in advancing their emergency
planning efforts and emergency response capabilities to a higher
level of preparedness than before 9/11. They are now better able
to meet the requirements of SARA Title III—the Emergency
Planning and Community Right-to-Know requirements.
Continuing effort is required to keep contingency plans, LEPC
plans, and others current with existing and expected conditions
and to ensure that they address all types of potential
emergencies.
Module 4: Emergency Management Response Systems
Topics

I. Introduction to Command Systems
II. Weapons of Mass Destruction Events
III. Nature-Caused Disasters
IV. Cleanup and Recovery Operations after a Disaster
V. Business Recovery Planning
I. Introduction to Command Systems
The command and control of an emergency by teams of people
trained to work together goes back to Roman times. When
Rome's legions were conquering empires, Roman military
leaders used some of their best soldiers and unit leaders to fight
fires within cities and towns to minimize the property damage
to those they conquered. Military command structure has been
used for centuries for major fire-fighting teams or units
worldwide. In the United States, both volunteer and
professionally staffed fire departments continue to use military
command structures.
The U.S. Forest Service developed the National Interagency
Incident Management System (NIIMS), the first federal
government command and control system to manage major
wildfires in the Western states and other areas. It combines the
resources of federal, state, and local governments with private-
sector resources to combat major forest fires around the
country. Because large forest fires often cross state boundaries,
multiple levels of government must coordinate their efforts to
combat and extinguish them. The NIIMS is the basis for the
now-established National Incident Management System (NIMS)
that has been adopted under the NationalResponse Framework
(NRF), and is required training for all emergency responders
who may be called upon to help or assist with a national
emergency under the NRF.Presidential Directive No. 5
establishes the requirement for all emergency responders to be
trained in the NIMS.
The NIMS has established the foundation upon which the
incident command system and the unified command system are
built. Both the NIMS and the incident command system have the

organizational systems required to handle the emergency being
faced. These systems can be simple for small incidents and can
be expanded into more complex management structures to
handle massive incidents. Both the incident command system
and the unified command system are recognized as part of the
NIMS, as mentioned in module 1.
We will discuss both the incident command system and the
unified command system below.
Incident Command System
The incident command system (ICS), sometimes known as
the incident management system, is the major organizational
structure used for responding to and managing emergencies on
the scene in the United States. OSHA, when it promulgated the
HAZWOPER rule in 1989, mandated that an ICS be used to
manage hazardous-materials incident emergencies and to protect
emergency responders. That rule specified that one person
would manage the on-scene activities and bring the emergency
event to a successful conclusion.
The ICS, as it has evolved, has an incident commander, who
usually functions from the command post, and four functional
sections. Liaison officials from other organizations involved in
the emergency response, the public information official (PIO),
and the lead safety officer all report directly to the incident
commander.
The four functional sections—administrative, logistics,
planning, and operations—are on a somewhat equal level below
the incident commander. The head person for each of these
sections reports directly to the incident commander. For
additional information on the ICS, see the Relevant URLs list in
the Additional Information section of the syllabus.
Figure 4.1 is a simple organizational chart of the on-scene ICS.
Figure 4.1
Organizational Chart of the Incident Command System
We will now describe the four functional sections of the ICS.
Administrative Section

The administrative section is responsible for administrative and
financial obligations and tracking costs involved with the
incident. It will be involved with procurement actions in
support of the logistics section, such as purchasing equipment
and supplies called for by the IC. It will also track work hours
and expenditures, process insurance claims, and gather damage
estimates and costs.
When criminal acts may have been involved in creating the
emergency, the administrative section provides support for
gathering evidence and documenting the chain of custody of the
evidence until the emergency incident is over. Such
documentation helps ensure that the evidence is not tampered
with or altered so as to make it unusable in a criminal court
proceeding. The police have rigid rules for maintaining the
chain of custody, and proper documentation goes a long way to
verify that the evidence has been properly handled and
packaged. The administrative section turns all the evidence and
related documentation it has obtained during the emergency
back over to the law enforcement authorities.
Logistics Section
The logistics section is responsible for obtaining the supplies,
staff, equipment, and food required by the emergency
responders as authorized by the IC. It provides the facilities,
ground support, medical rehabilitation, and communications the
emergency responders need. Coordinating with the operations
section, it also provides the staging areas for emergency
response units that are called in to help, but that are not
dispatched directly to the incident scene immediately upon their
arrival. These staging areas are usually out of harm's way but
near the incident scene, which permits them to move promptly
to their assignment area once it is determined.
Planning Section
The planning section supports the IC in forming the strategy
and tactics to be used in controlling the emergency. It
documents the emergency response objectives and goals
established by the IC.

This section gathers the information needed by the emergency
responders. It also receives from the other functional areas
information on how well the strategy and tactics are working in
bringing the emergency to a successful conclusion. Such
information typically includes
· current safety data sheets
· chemical cards with information about the hazardous materials
that may be involved in the incident
· the wind direction and speed and current weather reports for
the immediate area of the incident
· a current topography map or layout of the emergency scene
area
The planning section also obtains the information the employer
for the site may have reported, such as the Tier 1 and Tier 2
forms addressing hazardous materials onsite, along with
building diagrams and floor plans.
The section, coordinating with the other sections under the IC's
leadership, develops the incident action plan. It helps the IC
obtain technical experts that are needed on the scene and helps
formulate the recovery plan. Finally, it helps in demobilizing
the emergency response units on the scene when they are no
longer needed.
Operations Section
The operations section implements the IC's incident action plan
or plans. It uses the tactics and follows the strategy that the IC
for the emergency has adopted, including fighting fires,
rescuing victims, and providing emergency medical assistance.
We will describe this section in greater detail later in the
module.
Unified Command System
The incident command system normally works well for most
emergency incidents. When such incidents become larger and
cross state or national borders, or involve multiple levels of
government agencies with specific responsibilities for the area
involved in the emergency scene, then the unified command
system provides a more functional management structure for all

concerned.
The unified command system brings together the assigned
leaders for each of the organizations that have responsibility for
some aspect of the area involved in the emergency scene. It
provides the structure for them to work as a team and to set
common objectives and strategies that all will support. This
system is responsible for the overall management of the
incident.
Typically, the unified command will include the federal on-
scene coordinator, a state on-scene coordinator, the IC (or ICs)
who manages emergencies in the locale, the facility or vessel
management official whose property is involved with the
emergency or the responsible party, and others.
Emergency Communications
Emergency communications, one of the functions of the
logistics section, is a critical element in determining the success
of an emergency response. All participants at all levels of an
emergency response must communicate clearly, concisely, and
effectively with each other.
Effective emergency communications are essential to protect
emergency responders and the general public. If conditions at
an emergency scene necessitate evacuation, effective emergency
communications can mean the difference between life and death
for both emergency responders and the public.
If it is anticipated that mutual-aid emergency responding units
that use different radio frequencies and terminologies will come
from other areas, the emergency communications setup should
be planned accordingly. Liaison officials may have to be
assigned to the IC's staff or stationed at the command post to
provide clear, accurate communications to these units. These
officials should use their radios to relay the IC's instructions to
their units, to keep them informed, and to relay communications
from the mutual aid units to the IC. Another option is to place
liaison officials at the station of the commander who heads the
operations section. As the NIMS training effort progresses
across the nation to all emergency responders, this type of

problem will diminish on emergency scenes.
As we have mentioned, in the World Trade Center tragedy,
emergency responders found that when they were inside the
buildings, their radios did not work very well when they tried to
communicate with outside units or with the alarm headquarters.
Using cell phones helped, but then those phone lines became
overloaded. Planning for situations such as this is essential for
effective emergency communications. Many large buildings
install repeaters for cell phone reception, but police and fire
department radio communications are not always considered or
included in the building design. The Federal Communications
Commission (FCC) is now addressing the public radio spectrum
to help improve police and fire department radio reception by
creating separate parts of the spectrum for police radio
communications in one range and fire department radios in a
different range, to help eliminate interference between them and
to exclude all others from using these specific parts of the
public spectrum for any other purpose.
One of the goals of every IC is for all of the emergency units
under his or her direction to use clear text and standard
terminology in all radio communications to prevent any
misunderstanding. This is one of the NIMS objectives as well.
In a massive emergency incident, the emergency operations
center (EOC) may coordinate with representatives from
involved cities and states and with federal agency
representatives to plan the community's emergency response
objectives, using the unified command system. The center is
usually a fixed facility that has computer networks, maps,
equipment, and supplies to help support a wide array of
emergency response scenarios.
In a large-scale event, the IC is the on-scene manager, but she
or he will report to the EOC and the lead official or officials in
charge of the overall emergency response effort. Unified
command structures generally will work from the EOC and not
from the actual emergency incident scene.
Large-scale events such as nature-caused disasters or WMD

events could have multiple emergency scenes over a wide area.
Each emergency scene would have an IC who would report back
to the EOC. It is the responsibility of each IC to keep EOC
officials abreast of the progress or lack of progress involved at
her or his scene so that a more comprehensive approach can be
applied to control the hazardous conditions at various locations
throughout the affected area.
The EOC, rather than individual ICs, will be the main conduit
of public information to keep the press and citizens abreast of
what actions they must take to protect themselves and their
families. The EOC, from its planning efforts, will have a variety
of ways to communicate with the press and public about the
status of emergencies and to dispel any misinformation that may
have been generated that could cause unwarranted fear among
local citizens.
The EOC, in coordination with ICs, should develop a media-
management plan and set up a joint information center as the
outlet for public information from all levels of government
involved with the EOC. The EOC is an ideal setup for use by a
unified command system for managing large emergency events.
Emergency Response Operations
The operations section, one of the basic parts of the incident
command system discussed above, serves as the main group of
responders implementing the strategy and using the tactics
adopted by the IC or the unified command. If the emergency
involves hazardous materials, the section commander or
operations officer will assign a safety officer to work in this
immediate area. This safety officer will report any findings or
problems to the overall safety officer designated by the IC, as
well as to the operations officer.
One of the first steps the IC and the operations officer take is to
size up the emergency scene to determine the nature and
location of the problem(s) and where the best route of entry is
to begin to control the hazard(s). This initial assessment is done
first from a distance. If necessary, a reconnaissance team will
be dispatched into the hazard area to better determine the nature

of the emergency. This team may take samples of materials for
further analysis.
The location of the hazard or hazardous material is called the
"hot zone," and it is deemed the most dangerous area on the
incident scene. The IC, after discussions with the operations
officer and others, will decide what course of action to take.
This course of action is called the incident action plan. An entry
team of two or more will enter the hot zone to begin to control
the hazard and implement the steps to achieve the IC's goals and
objectives.
The decontamination process is an important part of the
emergency response and is the responsibility of the operations
section. Typical decontamination efforts are conducted in the
zone next to the hot zone called the "warm zone."
On-Scene Hazard Zones
Under the incident command system, to control access to the
danger areas, the operations section establishes four zones at
hazardous materials incidents. They are the hot zone, the warm
zone, the cold zone, and the public zone. Figure 4.2 shows
emergency on-scene hazard zones and other related areas.
Figure 4.2
Hazard Zones
We will discuss each of these zones below.
The Hot Zone
The first zone is set up around the hazardous area and is called
the hot zone. To provide some margin for any spreading of the
material, the hot zone normally is larger than the actual area
that is thought to be highly contaminated. The perimeter of the
hot zone is known as the contamination perimeter.
The emergency responders entering the hot zone in the early
stages of the emergency response must be fully protected
against known and unknown hazards. The reconnaissance team
(recon team), composed of two or more persons wearing full
protective gear, should be the first group of emergency
responders to enter the hot zone. The IC will attempt to

minimize the exposure of the emergency responders to the
hazards and will use the smallest number that will be able to
survey the hot zone and take samples of materials.
Once the recon team presents the results to the IC and the
operations officer, the entry team's work routine will be
established. The entry team(s), working in pairs or larger
groups, will be instructed as to what work must be done inside
the hot zone. Then they will enter the hot zone to perform this
work. The recon team and the entry team are the only
emergency responders permitted in the hot zone during the
emergency.
The Warm Zone
The second zone outside of the hot zone is called the warm
zone. In it, a decontamination corridor is established that serves
as the entry and exit point from the hot zone to the warm zone.
All responders who enter the hot zone must come back through
this corridor to be decontaminated, which helps prevent the
spread of the hazard to areas outside of the hot zone. Medical
monitoring of hot-zone workers will be conducted in the warm
zone.
The hazardous materials safety officer will be in the warm zone
at times during the emergency response, along with the team
leader(s) for the recon and entry teams as they conduct their
work in the hot zone. The team leaders observe the work of
their teams and are in radio contact with them while they are in
the hot zone. Those emergency responders involved with the
decontamination process for the recon and entry team members
when they leave the hot zone will also be in the warm zone. The
perimeter around the warm zone is known as the safety
perimeter.
The Cold Zone
The third zone, called the cold zone, has the access or entry
point into the warm zone to control which responders enter into
the warm zone. The hazardous materials staging area will be in
the cold zone along with the tactical command post of the
operations section leader. The perimeter of the cold zone is

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