July 2021 – The Katmal Limited Blog

Streamlining the licensing of Small Modular Reactors, WNA Webinar

WNA webinar

I watched the World Nuclear Association webinar about streamlining the licensing of Small Modular Reactors on July 28th. This was an interesting event with some good speakers. It is currently available on-line here.

The grumble behind the event is that, while companies want to sell their reactors around the world the pesky regulators in each country they want to build in want their say on the suitability of the design and this is tiresome, time consuming, expensive and may lead to country-specific design changes. The speakers made a good case that their jobs would be easier and that SMRs could start generating energy sooner if the regulatory barriers were at least lowered. We were also told that this is important for decarbonising the world energy market which is a relatively new way the SMR companies are trying to lean on Governments.

The audience was challenged by Tom Bergman, Vice President of Regulatory Affairs, NuScale (a leading SMR design/build Company from the USA) with the question “Do you believe that a design approved in the USA is not fit for somewhere else?”. Maybe we could ask him if he would be happy for a British designed reactor, approved by the British regulators and built in Britain to be operated in his backyard without US inspection of the safety case, design, build and operation? We also heard from Sol Pedre, Manager of CAREM project, the National Atomic Energy Commission, Argentina (CAREM is a simplified PWR being built in Buenos Aires province) who, rather naively in my opinion, thought that if they could build and operate a reactor in Argentina then that should go a long way to convincing other regulators that the design is safe enough for worldwide deployment.

Nadezhda Salnikova, Head of Business Development Department of Afrikantov OKBM, JSC, ROSATOM (this is the company that designs and builds Russia’s nuclear propulsion projects such as submarines, icebreakers and floating nuclear power plant) commented that they produce plant for use within Russia under Russian regulatory supervision but the floating power stations can go anywhere. A lack of global licensing means extra work for the Company and work for the local regulators that may be beyond their capabilities.

It was suggested that new nuclear nations could simply accept the regulatory approval of the country selling the reactor. I suspect that this runs counter to IAEA expectations but might be acceptable if a floating plant was to be temporarily positioned following some crisis and operated by experienced staff. This is little different to a nuclear-powered submarine or ice breaker visiting a foreign port.

I have some sympathy for the potential loss of design stability caused by local requirements. This potentially makes the design chain and build more complex but we are talking about an industry that, according to the IAEA had more than 70 SMR designs running in 2020 (Ref. here) while NuScale have designed 50, 60 and 77 MWe versions of their reactor before building any. Design updates do not seem to be a particular problem. Meanwhile modern flexible manufacturing systems should enable slightly different builds to be accommodated on the production lines without reducing shareholder value too far.

The problem with attempts to produce global standards is that most countries agree with the concept providing that the world adopts their existing standards (hence my question to Tom Bergman above).

This event did not really explore the barriers to closer working of the regulators across the world and the advantages that might accrue from converging regulation. I would be interested to see a comparison of the regulators. What do they do in a similar fashion? what do they do differently? How much scope do their national laws and guidance give them to meet in the middle? Why would they want to do this? How much of the licensing effort is based on design and how much on siting, building and operating? Knowing this, we might then be in a better position to move partial streamlining of international licensing from an aspiration to a realistic target. (This information may be available in the WNA report “Design Maturity and Regulatory Expectations for Small Modular Reactors” which I haven’t yet read in full).

Small Modular Reactors are often based on evolutions of proven technology with enhanced levels of safety built in. Much of the additional safety comes from the small size and layout of the plant greatly reducing vulnerable pipework and reducing dependency on active systems for layers of safety. They have reduced the number of systems (valves, pumps, filters, tanks, chemicals, switches etc) that need to be considered. It seems logical to assume that their safety cases are simpler and fewer systems means fewer things to understand and approve. Design approval should be quicker.

Importantly the construction takes place in factories, possibly in a foreign country. What expectations will the regulator have for quality control and will they require to inspect the reactor during build?

If governments wish to see SMRs contributing to low carbon electricity, district heating, process heating and hydrogen production in the not-too-distant future then they do need to encourage regulators to do their bit to hasten the process without compromising safety. Generic Design Assessment (GDA), which takes about 4 years and is not mandatory, is far from the only issue. They also need to consider how the licensing of sites and operators will be undertaken if the market penetration talked about comes to pass.

What will the siting requirements be? Currently the UK process spends a lot of time and effort considering if a particular site is suitable for a reactor. That may be acceptable if you are only going to build one or two sites a decade but we cannot expect, for example, a foundry to spend years of effort to get permission to use a small (or even micro) reactor to melt metal. What siting processes do we need if, for example, six reactors are going to built and deployed each year?

In the UK the ONR has recently announced new guidance for parties requesting Generic Design Assessment of SMRs and AMRs (Advanced Modular Reactors). It would have been interesting to hear a discussion of this guidance, and the strategy behind it, to see if it goes someway to meeting the aspirations of the reactor manufacturers.

The UK 10 point plan calls for demonstrator SMR and AMR deployment in the early 2030s. But what is the strategy to deploy them, including siting them, in the following years?

I started listening to this webinar thinking about the issue of using one design of reactor in several different countries but ended up thinking that a more difficult issue (in the UK) may be that of gaining public and regulator acceptance of many more nuclear reactors doing a wider range of jobs requiring them to leave their large, well-protected sites, in the countryside with their hundreds of well qualified workers and instead sit in one corner of an industrial site or in the outskirts of a town and with a much smaller staff. This is a national, rather than an international, issue.

I’m grateful to the WNA for organising this webinar and for the speakers who gave their time. It is an interesting topic and was well presented. A good case was made that life for a reactor vendor would be easier if some of the regulatory barriers were streamlined. It was not made obvious that this was likely or even possible. The question in the webinar title was not answered.

Keeping the ICRP Recommendations Fit for Purpose

The science behind radiological protection is complex. It starts with the physical interaction between ionising radiations and the material that composes the human body (and other biota), then considers the potential changes induced by these interactions, including the response of different issues within the body and the whole body implications of those local responses, and tries to quantify the harm that might be done (detriment). It then considers the acceptability of this harm in terms of the tolerability of risks and by putting them into perspective with other risks. It also considers how different groups and individuals might respond if exposed, recognising workers, the public and patients as different groups with different potential gains and losses and planned, existing and emergency exposure situations. The field thus encompasses physics, biology, sociology, ethics and politics.

The International Commission on Radiological Protection was “established to advance for the public benefit the science of radiological protection, in particular by providing recommendations and guidance on all aspects of protection against ionising radiation. The Main Commission is the governing body, setting policy and giving general direction” (Ref). The recommendations of the ICRP form the basis of radiological protection around the globe. A useful review of the effects of this last major restatement of the recommendations can be found in a PHE paper “Application of the 2007 Recommendations of the ICRP to the UK”. (Ref)

ICRP have now pre-released a major discussion document as an early step in the consultation process for the next round of recommendations. Christopher Clement et al 2021 J. Radiol. Prot. in press. On line (updated version) available at https://iopscience.iop.org/article/10.1088/1361-6498/ac1611. This article is based on the accepted manuscript 20 July 2021.

In this we are reminded that the objective of the system of radiological protection described in ICRP-103 is “to contribute to an appropriate level of protection for people and the environment against the detrimental effects of radiation exposure without unduly limiting the desirable human actions that may be associated with such exposure”. The review that preceded this document started 20 years ago and took 10 years. “While it is safe to conclude that the System is robust and has performed well in relation to the protection objectives, the System must adapt to address changes in science and society to remain fit for purpose.

It is suggested that the ICRP-103 objective to prevent tissue reactions (deterministic effects to us oldies) should be modified to recognise that there are medial situations, emergency situations (and space exploration) where tissue reactions may be tolerated to achieve the desirable benefit of a particular activity. This seems sensible but is going to add, rather than remove, complexity.

A review of the lifetime risk estimates imbedded in the concept of detriment is due a review to reflect the evolution of scientific knowledge of risks and expert judgement. “In addition, explicit recognition of differences in detriment with age at exposure and between males and females could improve the clarity of application of the System, showing, in particular, that risks to young children are greater than risks to adults, and that risks to older individuals are low.” This could be useful, for example, in removing the perceived need to evacuate elderly people from their homes during a radiological or nuclear emergency to avert radiation doses of as little as 30 mSv which are of no real threat to them.

The discussion paper points out that the current system “principally deals with health effects resulting directly from exposure to radiation” which is not entirely in line with the WHO definition of health as “a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity”. Including mental and social wellbeing in the system can only make it much more complicated, situation dependent and subjective (but pretty much removes the need to worry about the physics of the fundamental interactions).

There is a section (Section 2.3) on the protection of the environment and non-human biota. I have always considered this a job creation scheme for radiobiologists and mathematical modellers (of which I used to be one) and of little practical value in the real world of radiation safety. I realise that this view sees me ejected from the moral high ground.

In Section 2.5 the paper reports that “There have been many requests for more guidance on how to balance societal, economic, and other factors in the optimisation of protection and safety, requiring input from many fields of expertise” and summarises the work that ICRP have published in this general area. This includes ICRP Task Group 114 which seems to suggest that there are occasions where the lowest exposures or risks are sought when a better balance could be achieved to advantage.

Also in this section is a discussion of a more holistic approach in safety assessments of medical facilities. Again, this seems to be running the risk of making the system more complex and maybe asking too much of one stream of work.

Section 2.6 discusses dose limitation and worries that, since it only applies to planned exposure situations, it fails the “ethical obligation to protect individual people under all circumstances”. This seems to me to be a bit like worrying that the seat belt and airbags in my car don’t provide me with any protection when I am walking around a shopping centre.

The report suggests a broader principle which would apply in all situations and encompass the concepts of limits, constraints and reference levels, possibly combining the latter two concepts into one. This is an interesting thought, worth thinking about provided the ICRP are willing to back peddle if it does not work out as hoped.

Dose constraint

A prospective and source-related restriction on the individual dose from a source, which provides a basic level of protection for the most highly exposed individuals from a source and serves as an upper bound on the dose in optimisation of protection for that source. For occupational exposures, the dose constraint is a value of individual dose used to limit the range of options considered in the process of optimisation. For public exposure, the dose constraint is an upper bound on the annual doses that members of the public should receive from the planned operation of any controlled source.

Reference level

In emergency or existing controllable exposure situations, this represents the level of dose or risk, above which it is judged to be inappropriate to plan to allow exposures to occur, and below which optimisation of protection should be implemented. The chosen value for a reference level will depend upon the prevailing circumstances of the exposure under consideration.

ICRP-103

The report states that “defining a fundamental principle to protect the individual would result in a System where all three fundamental principles apply under all circumstances regardless of the exposure situation or category. This change would require the re-examination and clarification of the distinctions between limits, constraints, and reference levels”. (I’m not sure how you can put a useful dose limit on an accident or malicious use of radiation).

Section 2.7 suggests that the experience of using the three exposure situations introduced by ICRP-103 has led to the opportunity to update, clarify and expand the guidance. This seems reasonable and the application to space travel interesting.

ICRP identify ethics, communications and stakeholder involvement and education and training as important overarching considerations and briefing discuss each in turn in Section 3.

It is proposed to use absorbed dose (in gray) for the control of doses to individual organs and tissues for the avoidance or minimisation of tissue reactions leaving equivalent dose (in sievert) as an intermediate step in the calculation of effective dose. “Radiation weighting could then be considered separately for tissue reactions and stochastic effects for the calculation of radiation-weighted absorbed dose in Gy and effective dose in Sv, respectively.” This is intended to “apply scientific knowledge more appropriately and simplify radiological protection, with a clearer distinction between organ/tissue doses in absorbed dose in Gy and effective dose in Sv”. This does seem more transparent than the switch we currently make from seiverts to grey at (an arbitrary) high dose as at low dose you are concerned about stochastic effects and high doses with tissue reaction.

The paper reports discussions with ICRU with the intention that “the measured quantities for the estimation of effective dose would be related directly to effective dose in the reference phantoms, renamed as ‘dose quantities’ (ambient and personal dose) rather than ‘dose equivalent quantities’. Operational quantities for the measurement of doses to the skin and lens of the eye will become ‘absorbed dose quantities’”. Another episode where those of us who work around radiological protection are required to forget the hard learned jargon we work with and replace it with a different set.

In Section 4.2, discussing effective dose, the paper discusses the increased use of more accurate and differentiated anthropomorphic phantoms leading to more accurate and transparent values of detriment and relative detriment separately for males and females of different age groups. The report suggests that “Revisions to the methodology of calculation of effective dose could improve its suitability for the assessment of risk. Best estimates of health risk should be calculated using estimates of absorbed doses to organs/tissues and age- and sex-specific risk models for individual types of cancer, but risk estimates at low doses will still be subject to the uncertainties inherent in risk projection models”. The question this raise in my mind is “are the age and sex differences larger than the uncertainties in the estimates?”

It is suggested in Section 4.4 that the revision of dose per unit intake values in the light of the new recommendations should be more rapid than previous experiences due to preparatory work and experience gained. This seems to be a reasonable hope.

Section 5 suggests a review of the classification of radiation effects as either stochastic effects or harmful tissue reactions to ensure that it remains fir for purpose, suggesting that “For example, for protection purposes, it may be useful to distinguish between severe and other tissue reactions, or between short-term and long-term health effects”. This seems reasonable. There are occasions where the gain from a process may be worth suffering a mild or temporary tissue effect.

Since the last recommendation were made there has been considerable research and epidemiological study of the impacts of low exposures to ionising radiation. A Task Group is currently reviewing the linear no threshold assumption in the light of this work. It looks likely to survive.

It is almost certain that different people have different susceptibility to harm from ionising radiation but likely that there is insufficient information to include this in a system to protect workers and the public. “However, there are already efforts to individualise radiological protection of patients which should be considered in the review of the System, taking into account scientific, ethical, and practical aspects”.

Similarly, there is now more information on heritable effects that should be considered.

Likewise, there is more data on relative biological effectiveness and it is likely that a more sophisticated approach may now be appropriate.

The idea that “detriment could be calculated separately for males and females and at different ages at exposure, and the corresponding values of relative detriment could be used directly in the calculation of effective dose, rather than the current use of simplified age- and sex-averaged tissue weighting factors” sounds good. As does “explicit treatment of detriment from irradiation in utero could also be re-evaluated”.

There will also be a conversation about the replacing detriment with other proposed measures of harm such as fatality or disability-adjusted life years.

The discussion paper concludes that “The last review of the System of Radiological Protection was initiated 23 years ago, and the current General Recommendations (ICRP, 2007) were published 14 years ago. The System has performed well and remains robust, and there are significant practical benefits to stability in the System. Nonetheless, it must progress to remain fit for purpose as society evolves, scientific understanding advances, and new uses of ionising radiation emerge”.

The ICRP and others continue to research the effects of ionising radiation on people, biota and the environment. A time comes when the strengths and weaknesses of the current system should be discussed and new knowledge should be systematically reviewed incorporated into a revised international system of radiological protection. It appears that that time is approaching. This paper is one step in the consultation process. An ICRP Digital Workshop on 19 – 20^th October is another step (Ref).

I shall watch this process develop with interest and get involved if I deem it good use of my time.

IAEA EPR-Medical Physicists 2020 – Guidance for Medical Physicists Responding to a Nuclear or Radiological Emergency

https://www.iaea.org/publications/13483/guidance-for-medical-physicists-responding-to-a-nuclear-or-radiological-emergency

In the event of a nuclear or radiological emergency hospital medical physicists may find themselves providing front-line response to the event or supporting their hospital’s efforts to triage and treat potentially contaminated casualties.

The objective of this IAEA publication is to guide the trained clinically qualified medical physicists (CQMP[1]) to act appropriately in a nuclear or radiological emergency and ensure that an efficient and coordinated contribution is made to the management of such an emergency. The knowledge of the CQMP can be vital in the preparedness and response to nuclear or radiological emergencies.

The report is accompanied by a pocket guide which summarises most of the concepts given in the full report and is designed as a working aid. But at 78 pages it would require an unusually large pocket. Rather than be an on-the-day aide-memoir the pocket guide covers a lot of preparedness information from the main report. EPR_Pocketbook_web.pdf (iaea.org)

The main report starts with an introduction to emergency planning giving various definitions of emergencies and then a quick overview of the roles the medical physicist might occupy in the local and nation emergency response plans. The noted roles are:

Radiological assessor (RA) requiring a qualified expert in radiation dosimetry;
Scientific and technical advisor giving advice on matters related to a nuclear or radiological emergency;
Trainer in radiation protection providing training within their own clinical environment and, possibly, within and beyond their hospital. During the emergency the trainer will be able to provide quick briefings on radiation protection to the emergency teams.

The medical physicist may serve in a pre-hospital function supporting triage teams and decontamination actions or in the hospital providing advice and training to medical staff.

I think I would have preferred the report to start with what a nuclear or radiological emergency might look like to hospital staff: many people turning, some injured, some contaminated (some both injured and contaminated), many worried well. This may better grab the reader’s attention.

The concept of a scalable incident command system, allowing multi-agency coordination and rapid decision making over a range of scale of event and the medical physicist’s position in the chain of command are discussed. The importance of each player knowing who they report to and to whom they are responsible in a crisis organisation and the understanding that this may not align with normal management is stressed. The diagram given here, cut and pasted from another document, is not helpful. Showing the medical physicist’s position in a chain built round them might have been better.

In section 4, the report runs through the preparedness phase tasks of risk assessment, training, criteria for exposure, potential roles and responsibilities, personal protection and radiation monitoring, procedures for donning protective clothes & monitoring. This section is not a model of clarity and covers material that a medical physicist might be expected to know.

Section 5, which covers activities related to the response, sees the medical physicist implementing the hospital emergency response plan and ensuring that the facility is protected. They will provide briefings on radiological protection and what may occur during the handling of contaminated patients and they will ensure that proper arrangements are followed to minimise the impact on the hospital resulting from the presence of contaminated patients. This section comes with a useful flow chart tracing the possible pathways to treatment for casualties with different combinations of needs, a list of equipment that might be useful and a list of possible actions (including a flow chart showing different actions assigned to different roles in a coordinated manner).

There is also a section labelled the radiological control of areas which is cut from another document and outlines the demarcation of areas for different purposes and the control of people moving through the system to minimise the spread of contamination. Maybe this material should be in the planning section.

Section 6 is entitled early dose magnitude estimation and decontamination. It suggests that accurate dose assessments are unnecessary in the response phase of an emergency; what is needed is a magnitude assessment: is there a problem with either external radiation or contamination that must managed along with the casualty’s clinical needs?

The report discusses how to assess external radiation dose and reviews the gamma ray constant and inverse square law which will probably not be new to many medical physicists. It also mentions a few computer tools such as the Rad Pro Calculator and the Radiation Emergency Medical Management (REMM) dose calculator which are useful to have available.

There are some tables showing how radiation dose can be deduced from observations about which symptoms show and how long after the exposure they show. Versions of these tables should be in the hospital’s emergency data set.

The report suggests that “Internal radiation doses can be extremely complicated to determine” and that “The aim of the assessment of internal contamination is to quantify the incorporation of radioactive material into the body and to estimate the committed effective dose and, where appropriate, the committed equivalent dose to demonstrate compliance with dose limits”. I think that this is appropriate for individual cases of internal contamination following operational mishap but is wrong in the context of responding to a nuclear or radiological emergency. Here the purpose would be to determine what, if any, medical care the casualty might require because of the exposure.

There is a short section on decontamination of casualties. I am sure I have read better.

In the section on the protection of the public (Section 6.2) the report mentions using plume models etc. to estimate deposition levels but gives no clue about how to manage the results. It also talks about determining isodose curves around sealed sources to help the determination of public external exposure.

The collection of excreta for radionuclide analysis is mentioned but no details of the assay methods or reference to dosimetry models used to estimate dose.

After the initial crisis stage there may be a requirement to improve dose estimates. Section 7, which discusses this area has some “key considerations” and some equations but little in the way of practical advice. Maybe following the references quoted may prove more helpful.

In Section 8 it is argued that Medical Physicists should “enhance their communications skills, so that they can contribute to the timely dissemination of relevant information and contribute, all with the response team, in managing individuals and professionals involved in nuclear or radiological emergencies”. You might have thought that these skills, as opposed to speaking to worried members of the public, came with their job.

The psychosocial aspects of nuclear or radiological emergencies gets a sub-section but this does little more than point to further references.

The rest of the section is a very brief overview of communications skills.

Section 9 is a more helpful section on the contents of a “grab and go” bag. This includes dosimeters (EPD and badges), survey instruments, protective equipment, data sheets and forms and miscellaneous tools.

Section 10 gives a very detailed suggested syllabus for training medical physicists and reading lists which are predominantly IAEA publications and would need a fairly large bookshelf to hold and some considerable time to read.

Appendices provide more detailed advice on reception area layout, tags and forms and summary of OILs and reactions to their exceedance.

This is a potentially useful document for hospitals when considering their plans to cope with a nuclear or radiological emergency and considering how to use their radiation specialists. However, it is not only very uneven in the level of detail given but also does not seem to have considered what skills and knowledge the radiation specialist already has and where they might need some training.

It could be better.

[1] See IAEA Human Health Series No. 25, “Roles and Responsibilities, and Education and Training Requirements for Clinically Qualified Medical Physicists”

FEMA – Key Planning Factors and Considerations

What would you do?

…if a dozen dead birds are found near a truck accident site?

…if 20 people complain of tingling in the mouth after eating at a fast-food restaurant?

FEMA have some answers. They have published a new 324-page document discussing key planning factors and considerations for response to and recovery from a chemical incident August 2021).

https://www.fema.gov/sites/default/files/documents/fema_chemical-kpf_060321.pdf

The report shows the potential complexity of responding to a chemical event. Unlike radiological events, chemical events could result in overwhelming numbers of acute casualties, some of which require urgent medical attention with the correct treatments and anti-toxins for the chemical involved – which may not be identified at the start of the event. First responders may be in immediate danger from the contamination themselves, something that is not likely to be true to the same extent for radiological emergencies.

There are broad similarities between the response to a chemical event and to a radiological event (a dangerous substance that can move with air and/or water movements, the need to make decisions with weak information, a complex issue to explain to the public while needing them to urgently take heed of advice, a potentially complex recovery process) but also important differences (rapid onset of medical crisis, wider range of substances to understand).

The FEMA report provides brief details of several chemical accidents, showing the range of events that are included in this class and the complexity of response. It also identifies and discusses the characteristics that are common to chemical accidents which includes the fact that their on-set can be rapid, a quick and effective response is required to save lives, first responders can become exposed, decisions need to be made quickly with a limited understanding of what has occurred, large areas can be affected, communications with the public and between responders is important, medical facilities can be overwhelmed and recovery may take a long time.

It then lists seven Key Planning Factors (KPF), each of which is then given a chapter:

1. “Prime the Pump” Pre-Event Planning;
2. Recognize and characterise the Incident;
3. Communicate with External Partners and the Public;
4. Control the Spread of Contamination;
5. Augment Provision of Mass Care and Human Services to Affected Population;
6. Augment Provision of Health and Medical Services to Affected Population;
7. Augment Essential Services to Achieve Recovery Outcomes.

It justifies pre-planning with the observation that “A large-scale chemical incident with mass casualties is a realistic threat facing both urban and rural communities nationwide. The risk of misuse or accidents involving toxic industrial chemicals (TIC), which are widely stored in large quantities and are routinely transported by rail, waterway, highway, and pipeline, is substantial”. They also believe that a terror attack using chemicals is credible.

Multiagency planning and preparation are required to face this threat and enable a prompt and effective response. A “whole community” concept of operations is suggested.

The report suggests a systematic approach to planning and preparedness with several discrete steps recommended, each of which is explained in detail with lists of suggested consultees, reference documents, check lists and resource requirements.

It stresses the importance of agreeing how decisions will be made suggesting a process whereby stakeholders agree which decisions will need to be made, the minimum information needed to make them and the potential sources for that information. Decision making processes should be established to select among available options for evacuation, shelter-in-place, decontamination and waste management balancing political/social priorities and public health protection against time and cost constraints, and, therefore, should include discussion of reimbursement/ compensation for resources provided and contingencies if resources are damaged, destroyed, etc.

Another important area for discussion is medical resources. The planning process should establish protocols and procedures for the prioritization of medical resources.

There are a range of ways in which a chemical event can become known – this varies from automatic alarms on chemical plant, reports of smells or gas clouds, reports of unexplained illnesses or collapses of people or animals, active monitoring of public spaces and food. The quicker these signs can be picked up the better. The report discusses possible indicators, what they might mean and how best to use them. By considering what signs might be available and what they might mean in advance the planners increase the likelihood that an event can be detected earlier allowing a better response.

The next step is to characterise the release and its extent with the safety of first responders as a high priority. This requires equipment, training and coordination.

There is a nice discussion about atmospheric dispersion and modelling.

The third KPF refers to communication with external partners and the public. It stresses the importance of communication to enable a coordinated response across multiple agencies, jurisdictions and levels of authority and to inform the public providing key information and advice on self-preservation while countering misinformation and misperceptions.

The section discusses how communications can support a coordinated response, how to inform the public, how to provide time-critical messaging, strategies for effective communications, and best practice (the latter being a useful checklist of 13 elements).

Controlling the spread of contamination (KPF 4) may save lives and will protect the environment. Depending on the nature of the incident, controlling the spread of contamination may involve environmental containment and/or remediation efforts; decontamination of people, goods, or property; and interventions such as evacuations and food recalls. A lot of important decisions may be needed, and considerable expertise and resource bought to bear.

The support of the affected population (Augment provision of mass care and human services to affected population) (KPF-5) provides life-sustaining and human services to disaster- affected populations, including feeding operations, emergency first aid, distribution of emergency items, and family reunification. Additional resources and services may need to be mobilized to support individuals with disabilities, limited mobility, limited English proficiency, children, household pets, and service and assistance animals. Mass evacuations result in a varied group requiring a range of support services.

The basic objective for Emergency Mass Care is to provide for basic survival needs including food, water, emergency supplies, and a safe, sanitary, and secure environment but hopefully it would go beyond that and cater for other needs, reducing the potential for psychological harm.

The report discusses the support that sheltered and evacuated populations might have and the multi-agency strategies that might be considered to prepare to meet these needs, the facilities that may be required to manage evacuations, provide respite, assistance and shelter.

KPF 6 is concerned with augmenting the provision of health and medical services to the affected population. A chemical event could result in a rapid build-up of casualties requiring specialist assistance, including determination of the active agent, the appropriate medical care and the steps required to protect the responders and medical facilities from contamination.

The report discusses medical treatment for chemical casualties which may require that the symptoms presented are treated while the active agent is unknown i.e. provision of oxygen to those exposed to a lung irritant.

The report mentions “CHEMPACKS” which are containers of nerve agent antidotes placed in safe locations around the country (the USA). I do not know if this system is replicated in the UK. The report recognises limitations to this system.

The Tokyo nerve agent attack in March 1995 was serious – 12 people died, 54 were severely injured, and around 980 were mildly to moderately affected. However, most of the 5000-seeking help, many of them with psychogenic symptoms, were understandably worried that they might have been exposed. This demonstrates the value of rapid information dissemination via the media in reassuring the public. It also shows the importance of effective triage at receiving centres in ensuring that medical resources are reserved for those who really have been exposed.

The final KPF is “augment essential services to achieve recovery outcomes”. This section suggests that recovery begins during the planning and response phases. It divides the recovery into three overlapping stages: short term (days), intermediate (weeks – months) and long term (months – years).

Activities and resources needed to attain recovery outcomes will vary depending on the scenario, context, and location of the chemical incident as well as the incident’s impacts on the local infrastructure, economy, and workforce.

The overall objectives of recovery plans and prioritizations are to restore critical services as quickly as possible to limit cascading effects, and to return the affected community to a sense of normality.

After discussing each of the KPFs the report discusses federal preparedness, response and recovery, outlining the four escalating tiers of federal response. These are (1) an on-scene coordinator assessing the situation and watching the response (2) escalation to invoke the National Oil and Hazardous Substances Pollution Contingency Plan (3) a request to the Department of Homeland Security for coordination capabilities and additional federal agency support (4) a Presidential Disaster Declaration under the Stafford Act. These are discussed in turn with examples.

The report provides links to a wide range of additional information and both planning and response tools. Appendices provide a wealth of information including an overview of nine common toxidromes (syndromes caused by exposure to dangerous levels of toxins), a review of US chemical incident policy, legislation and regulation and chemical planning and notification requirements for responsible parties, environmental containment and remediation options, a flow chart showing how medical attention can be targeted and coordinated.

This is a detailed document covering a wide range of material. For a person with responsibility for planning for, or responding to, a chemical incident in the US it is probably a must read. For people with similar responsibilities elsewhere it is a recommended read – read it and compare your level of readiness with that described.