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MANAGING INCIDENTS PRESENTING ACTUAL
OR POTENTIAL RISKS TO THE PUBLIC HEALTH:
Guidance on the Roles and Responsibilities of Incident Control Teams
Annex 2
National Health service in Scotland: Responding to Emergencies REVISED ANNEX M
INCIDENTS INVOLVING CHEMICALS
M1. Introduction
1. Worldwide, there are more than 11 million known chemical substances, of which some 60,000-70,000 are in regular use. A significant number of these are hazardous to health when inhaled, ingested or absorbed through the skin. Such exposures might be chronic, for example in a workplace situation, or acute, for example as a result of an accidental exposure.
2. This guidance is concerned primarily with acute chemical exposures, for incidents that might occur at an industrial site, during transportation of chemicals, during disposal of chemical waste, or through acts of chemical terrorism. The general aim is to ensure a well-planned NHSScotland response within the concept of 'Integrated Emergency Management' (IEM) adopted by central and local government. This document therefore provides guidance on how the NHS Boards can fulfil their responsibilities for the protection of health and the provision of health care in co-ordination with other agencies including the ambulance, police and fire services and central and local government.
3. The nature of many chemical incidents is that they present continuing threats to the health and safety of responding emergency service personnel. Such threats might include fire, explosion and illness or injury due to exposure to hazardous chemicals. The Health and Safety at Work Act 1974 and subsequent regulations, place specific duties on employers (including the NHSScotland and the Scottish Ambulance Service) to make appropriate provisions to safeguard the health and safety of their employees. This same legislation also places specific duties on employees to take reasonable steps to safeguard their own health and safety and that of others. This Annex also provides guidance, therefore, on appropriate health and safety provisions for healthcare staff when responding to chemical incidents.
M2. Roles and Responsibilities
4. Many chemical incidents demand a multi-agency response, proper co-ordination of which requires clarity over their individual roles and responsibilities. The general roles and responsibilities of various agencies including the police, fire brigade etc are described throughout the main body of this document and in Annexes A through H. In this section, we consider the particular roles and responsibilities for agencies responding to incidents at one or more sites where a release of chemicals has occurred. It is acknowledged, however that in some circumstances, such as chemical pollution from incidents occurring overseas, no specific site of release might be identifiable.
The Police
5 Arrangements for overall command and control at the site of a major chemical incident will normally depend on the magnitude of the required response.
6 For the least serious of incidents such as a small domestic fire resulting in minor smoke inhalation, each of the emergency services has its own operational responsibilities and deploys its resources under the command of its own incident officers. Close liaison is, however essential, for example to ensure that all casualties have been located and, where appropriate, the police will normally act as the co-ordinator of the overall response at the scene.
7 For incidents of greater severity, for example where a number of members of the public have been exposed to an ongoing release of chemicals due to a factory incident, each of the emergency services will have its own Incident Commander and co-ordination of the activities under the control of each of these commanders will usually fall to the police.
8 An example of a very large incident, would be a major explosion at an industrial site regulated under the provisions of the Control of Major Accident Hazards (COMAH) Regulations 1999, involving a large number of casualties and a continuing threat. Such incidents require strategic decisions about deployment of resources, managing populations, etc and a more formal command structure, perhaps involving an off-site emergency room, would normally be established by the police.
9 An incident involving chemical terrorism or the need for sheltering or evacuation of the local population would normally be managed by the police. Special provisions for incidents involving deliberate release of chemicals are described in separate SE Guidance.
The Fire Service
10 In some cases, fire service personnel will be the only responders who have the necessary equipment and training to allow them to work safely near to the source of a chemical incident. Therefore, at the immediate scene of a chemical incident that presents an ongoing threat to the public or to emergency personnel, the fire brigade will take appropriate steps to identify the chemicals concerned and set-up appropriate cordons around the contaminated area. Depending on the severity of the threat, these might include an "inner cordon" with access normally restricted to fire brigade officers who will rescue casualties from within it. Treatment and triage of these and other casualties would normally be carried out by ambulance and medical staff working within an "outer cordon" identified by the fire service as combining the necessary requirements for operational safety and efficiency. Defined (but less stringent) access restrictions also apply for the outer cordon.
11 Casualties of a chemical incident might require decontamination ahead of medical treatment or release from the scene. Separate guidance for the emergency services on decontamination is provided elsewhere and this defines the roles and responsibilities on the fire service particularly in the provision of "mass decontamination" (for example using cold water sprays).
12 The fire service will normally take principal responsibility for identifying the chemical(s) in question and for obtaining basic information on their toxicity in terms, for example, of their labelling under the Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP). (These require an "indication of danger" in terms of internationally recognised pictograms and "risk phrases" (e.g. R23 means Toxic by inhalation).) The brigades also have access to appropriate chemical information databases such as that of the National Chemical Emergency Centre (NCEC) and to appropriate sources of expert advice and technical support. They will also be able to obtain predictions from the Meteorological Office of the likely behaviour of any airborne pollutant. Co-ordination of the collection of any environmental samples required for subsequent chemical identification would also fall to the fire service or, in their absence or where forensic evidence is needed, the police.
The Scottish Ambulance Service.
13 The Scottish Ambulance Service (Annex D) is responsible for triage, decontamination and medical treatment of casualties at the scene of a chemical incident and for getting those deemed to be in need of secondary care to hospital. In fulfilling these responsibilities at the site of a chemical incident, ambulance personnel will work closely with the Medical Incident Officer (Section 3.9 of the main body of this document) and the Site Medical Team (Section 3.11).
14 The Ambulance Service as employers are bound by the requirements of the Health and Safety at Work Act 1974 and subsequent regulations to fulfil these operational responsibilities with due regard to the safety of their employees and others who might be affected by their activities. This latter group would include, for example, members of the public who might be injured by ambulances travelling to and from the scene.
15 Health and safety provisions for ambulance service personnel will include reasonable precautions to ensure that they will not be unduly exposed to hazardous chemicals or other dangers at the scene of a chemical incident. These provisions should
not rely on the issue of personal protective equipment alone but should consider alternative measures to minimize the threats. These measures might include ensuring that any activities at the site of the incident are carried out in a well ventilated area upwind of the chemical release, that suitable provisions are made for escape in the face of any acute increase in the level of threat (such as a change in the wind direction), provision of real time instruments to measure ambient chemical concentrations etc.. The Scottish Ambulance Service should also arrange for regular training and practice in the implementation of all such health and safety provisions.
16 These measures should be augmented by provisions for the issue and maintenance of adequate and suitable PPE and for training in its use, in accordance with the requirements of the Personal Protective Equipment at Work Regulations 1992.
17 Separate guidance for the emergency services identifies the Scottish Ambulance Service as having principal responsibility for decontamination of contaminated casualties at the scene of an incident. Ideally this will involve the use of mobile decontamination units, though in certain circumstances improvised decontamination methods might be applicable. The need for decontamination of ambulance staff working in potentially contaminated areas or with contaminated casualties should also be considered.
The Health and Safety Executive
18 Health and safety at work is a matter reserved for the UK Government. The Health and Safety Executive (HSE) has responsibility for ensuring the health and safety of people at work and of any members of the public who may be affected as a consequence of work. These responsibilities include ensuring that major industrial sites have emergency plans in place in accordance with the requirements of the Control of Major Accident Hazards (COMAH) Regulations 1999.
19 The HSE enforces the requirements of the Health and Safety at Work Act 1974 and subsequent regulations (such as the Personal Protective Equipment at Work Regulations 1992), which include provisions for the health and safety of emergency service personnel responding to chemical incidents.
20 The HSE is also responsible for investigating the cause of any chemical incident notifiable under the Reporting of Injuries, Diseases and Dangerous Occurrences (RIDDOR) Regulations 1995 at any industrial operation. Any such investigation will only begin when the acute phase of the emergency response is over and the area in question has been deemed safe to enter by the fire brigade or police.
Site operators
21 The primary responsibility for controlling and minimizing risks to health and safety at an industrial site rests with the site operator. Under the Notification of Installations Handling Hazardous Substances (Amendment) Regulations 2002 (NIHHS), site operators must notify the HSE of every site at which specified quantities of hazardous substances are present. Sites at which the industrial process or the nature and quantity of stored substances present a major accident hazard might also be subject to the Control of Major Accident Hazard (COMAH) Regulations 1999.
22 The NIHHS and COMAH Regulations do not apply to every site at which hazardous chemicals may be present in sufficient quantity to pose a significant threat to the health of people in the vicinity. Nevertheless, operators of these sites are bound by the general requirements of the Health and Safety at Work Act 1974 to take all reasonable precaution to minimize the threat that their operations pose to the health and safety of their workers and the local population.
Carriers of hazardous materials
23 Surface transport of hazardous materials is governed by the "Carriage of Dangerous Goods (Amendment) Regulations 1999" and a range of related regulations on specific issues such as labelling, and on specific classes of materials such as radioactive substances. The HSE has published a number of related guidance documents and their free advice leaflet "
Are you involved in the carriage of dangerous goods by road or rail?" August 1999 (available at
http://www.hse.gov.uk/pubns/indg234.pdf) provides an overview.
24 The most common transport-related incidents involve actual or threatened accidental spills for which the first priority of the NHS or SAS staff will be to ascertain the chemicals involved and their related risk to health and safety. This information can normally be obtained via the labelling on the packaging or tanker and labelling requirements are defined in the "The Carriage of Dangerous Goods (Classification, Packaging and Labelling) and Use of Transportable Pressure Receptacles Regulations 1996" (and other related regulations including CHIP (see paragraph 12 above)). For example, the packaging of ammonium polysulphide solution should carry the appropriate "Danger sign" pictogram to identify its classification a 'corrosive substance' (Class 8) and also a "Subsidiary hazard sign" which classifies it as 'toxic' (Class 6.1). The packaging should also carry the unique 'UN' number for this material (UN 2818).
25 SAS staff and NHS staff who might require to attend chemical incidents should be familiar with the general requirements of these labelling systems and with the related mechanisms for obtaining appropriate detailed information on risks and on treatment of casualties.
The Local Authorities.
23 Annex G identifies Local Authorities and NHS Boards as having joint statutory obligations for protecting the health of their local populations and this extends to management of public health incidents. In addition, the Control of Major Accident Hazard (COMAH) Regulations 1999, which cover most major chemical and petrochemical plants, require that local authorities make and maintain, comprehensive emergency plans to deal with off-site effects of any major accident at the site.
24 A major role for the Local Authorities in chemical incident response is likely to come after the immediate response phase of an emergency. The local authority might then assume, from the police or other initial co-ordinator, overall leadership for restoration of-contaminated land and water (in close liaison with the Scottish Environment Protection Agency) and any other local activities needed to restore normality.
The Scottish Executive Health Department (SEHD).
25 Within the general responsibilities of the SEHD for emergency planning in NHSScotland, as described in Chapter 2 of the main text and in Annex A, the SEHD's Emergency Planning Officer is responsible for regular auditing of the NHS Boards' individual emergency plans, including those for chemical incidents (Section M3) and for ensuring that the provision of these plans are exercised regularly.
26 For incidents involving more than one NHS Board area, operational co-ordination of the overall NHSScotland response will normally be the responsibility of the NHS Board in whose area is the incident is principally sited. The SEHD will confirm or nominate the lead NHS Board as necessary.
Acute Hospital Trusts
27. Acute hospital trusts must ensure that satisfactory arrangements are in place for the provision of health care to any casualties of a chemical incident. These casualty management arrangements should be documented in local emergency plans.
28. The casualty management provisions of these plans should require that the acute hospital trust will;
(i) co-ordinate the operational NHS response, on the receipt of casualties from the scene of a chemical incident;
(ii) ensure that staff are prepared for their roles, through the provision of appropriate training programmes; and that they have access to the advice and expertise needed to provide medical care to casualties of a chemical incident;
(iii) on the basis of a preparatory risk assessment, provide the facilities and equipment necessary for staff to fulfil their roles in a safe working environment: these include decontamination facilities at casualty receiving hospitals safe working facilities with adequate ventilation etc and personal protective equipment.
NHS Boards
29 Within the general healthcare and emergency planning responsibilities of each of the NHS Boards (as described in Chapters 1 to 3 of this document) the local Director of Public Health (DPH) is responsible for ensuring that local emergency plans contain appropriate provisions for chemical incident response. This should cover all aspects of the NHSScotland procedures involved from triage, decontamination and treatment of patients at the incident site through to admission to hospital. It should also provide for those in need of other forms of medical assistance such as trauma counselling and for provision of information to the public. A general overview of the scope required for these plans is given in Section M3.
30 In each of the NHS Board areas, there will be a number of sites where a variety of hazardous chemicals are stored or used. The DPH should take reasonable steps, in liaison with the emergency services, to familiarise him/herself with the range of sites and the principal chemical hazards that they present.
31 No comprehensive information will be available on the full range of chemicals transported through each of the NHS Board areas. However, the DPH should seek information from consignors and consignees on any regular bulk movements of dangerous chemicals within or through their areas or of any single movements that might present a particular threat. Liaison with the police, fire brigade and local authorities is recommended.
32 During a chemical incident, employees of the NHS Boards, who might include the Medical Incident Officer and the Site Medical Team, will work closely with employees of the Scottish Ambulance Service. The NHS Boards are subject to the same employers responsibilities outlined in Paragraph 14 above and provisions for the health and safety of medical staff should accord with those outlined in Paragraphs 15 through 17.
Scottish Poisons Information Bureau
33 The Scottish Poisons Information Bureau is part of the National Poisons Information Service. The Bureau provides a 24-hour information service (Tel:
0870 600 6266) including clinical advice, and should be regarded as the primary source of advice for the NHS in Scotland on the diagnosis, investigation and management of people exposed to chemical substances. It also maintains TOXBASE, an online database of information, which is available to registered users at
http://www.spib.axl.co.uk/toxbaseindex.htm. TOXBASE carries information on the hazardous nature of chemical substances, their ingredients, the symptoms that might arise by various routes of exposure and their appropriate treatment.
Scottish Centre for Infection and Environmental Health (SCIEH)
34 SCIEH is available to reinforce, advise or otherwise support NHS Boards' public health medicine expertise. It has particular skills in epidemiology, in surveillance and control of infection and has in-house veterinary and environmental health specialists. SCIEH maintains liaison with "The National Focus for Chemical Incidents" (a Government funded source of further specialist advice and assistance) and can call on its support and that of other specialist help as may be required. SCIEH thus provides to NHS Boards a one-stop-shop source of technical public health advice and assistance. Their website is at
http://www.show.scot.nhs.uk/scieh/ and their 24 hour contact number is
0141 300 1100.
M3 General emergency planning requirements for a chemical incident response
35 Each Director of Public Health is responsible for ensuring that their NHS Board's emergency plans include adequate and suitable provision for chemical incident response. In common with the other elements of these emergency plans, the provisions for chemical incidents will be subject to regular review by the NHSScotland Emergency Planning Unit.
36 Plans should include the following elements.
(i) A defined system, jointly agreed with the other emergency services involved and including acute hospital trusts, for prompt notification of incidents to their respective control centres. This should include an outline protocol for establishing appropriate incident control teams.
(ii) A defined protocol for communication with the Scottish Centre for Infection and Environmental Health (SCIEH). SCIEH will provide advice on the appropriate response on the basis of their own expertise and through their links with the National Focus for Chemical Incidents.
(iii) A defined protocol for communicating with the National Poisons Information Service and for access to their TOXBASE Information Service. (Directors of Public Health should ensure that all appropriate organisations including hospitals and GPs within their particular area are registered users of the TOXBASE Information System.)
(iv) Appropriate protocols for liaison with frontline staff. (A general instruction should be issued that all frontline staff who might need to response to a chemical incident and who carry a mobile phone should have the 24 hour telephone numbers for (at least) the following organisations logged into its electronic phone book. The Scottish Centre for Infection and Environmental Health (0141 211 3600), The Scottish Poisons Information Bureau (070 600 6266), the NRPB (01235 834 590), and the Food Standards Agency (01224 285 107).)
(v) Provisions for the health and safety of staff attending the site of a chemical incident or receiving casualties. These provisions should include the issue and maintenance of adequate and suitable Personal Protective Equipment and training in its use, in accordance with the requirements of the Personal Protective Equipment at Work Regulations 1992.
(vi) Protocols for casualty management. These should include arrangements for providing chemical decontamination equipment both at the scene of a chemical incident and at hospitals and provisions for training in its use.
(vii) Provisions for the collection of samples of blood, urine etc for the purposes of chemical identification and forensic evidence.
(viii) Arrangements for storage, access and distribution of appropriate pharmaceutical supplies including antidotes.
(ix) Arrangements for provision of information to the public.
(x) Arrangements for providing psychological support, particularly for those seeking treatment who have not actually been exposed.
(xi) Reference to the NHS Board's general provisions for accommodating a major short-term increase in hospital admissions. This should include co-operative working with other NHS Boards for chemical emergencies that span more than one NHS Board area.
(xii) Arrangements for post-incident reporting.
37 Plans should also provide that any proposed substantial changes will be discussed and agreed with the Scottish Executive's NHSScotland Emergency Planning Unit and with the local authority, the local fire and ambulance services and the police.
38 Chemical incident response plans should be exercised on a regular basis.
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