Emergency Planning advice and regulation – Page 2

Improved public messaging for evacuation and shelter in place.

FEMA have just published on the internet a very interesting paper entitled “Improving Public Messaging for Evacuation and Shelter‐in‐Place Findings and Recommendations for Emergency Managers from Peer-Reviewed Research” (April 2021) (link here). It reports the findings of a comprehensive literature review on the factors that affect the level of compliance with advice on personal protective actions (Shelter in place and Evacuation) in the event of a storm, flood or wild-fire. While these situations are not entirely analogous to radiation emergencies and there may be differences in the behaviour of UK and US populations when faced with an external event, there may be some important messages for UK planners to be gleaned from this work.

The work is related to the Protective Action Decision Model proposed in the literature (see figure) which attempts to identify the cues people may be sensitive to, the level and nature of prior consideration, and the on-the-day perception of the threat, possible responses and how others are responding which may influence decision making.

The key advice to those planning systems to warn and inform the public is to understand the potential impediments to action and take steps to address these barriers in advance, provide consistent advice through multiple trusted channels and to provide frequent updates.

Among many observations, those that seemed most relevant to the UK nuclear industry include:

Individuals find environmental cues such as sights, sounds or smells that indicate an impending threat an aid to decision making. This puts the nuclear industry at a disadvantage because we cannot show pictures of storm clouds, fast flowing rivers about to burst their banks or raging forest fires. On the other hand, we have the dread many people feel about radiation helping to focus minds.
It was noted that, in response to a wildfire, individuals could be categorised into three broad groups:
- - Wait and see (the largest group);
  - Stay and defend;
  - Likely to evacuate.

Seeing neighbours evacuate or other leave was a predictor of increased evacuation across a number of hazard types. This is a well-documented response to an alarm and most people will have observed it where they have been in a building when the fire alarm is tested; many people look to others and copy their behaviour.

Receiving messages from family and friends in addition to the local authority influenced decision making. Many people will seek confirmation of the preferred path of action from their social circles before acting.
Local governments and businesses provide important social cues that can impact on risk perception. Advice to evacuate an area, or even to shelter in place, could be undermined if council employees continued activities such as cutting grass and collecting waste in those areas.
Receiving several consistent warning messages from multiple, credible and trusted sources increases the rates of compliance.
People tend to use social media as a complementary rather than their primary source of information. Social media was also often used to amplify or share information with others.
As mobile phone ownership is now more prevalent than home landlines, public alert and warning calls to landline phone numbers are becoming less effective. The increased reliance on mobile phones may also result in bandwidth congestion during an incident. In the UK where fraction of homes and offices with land lines is falling while the procession of mobile phones is increasing. (See Table A45 in ONS report here which implies that 82% of households have land lines and 90% have mobile phones).
Households with multiple vehicles evacuated in multiple vehicles often with staggered leaving times. This is in the context of an impending storm but is plausible in a radiation accident if only as a mechanism for protecting their vehicles. This would add to traffic congestion.
There is strong agreement across studies and hazards that women are more likely to take appropriate protective action (SIP or evacuate) than men.
Parents with children in the household tended to have more difficulties with making the decision to stay or to leave for hurricanes and flooding. While some of their concerns may be similar to those of other households (e.g., traffic congestion, fuel availability, uncertainty regarding destination, cost), children in the household, especially younger children and larger numbers of children, raised the anxiety level and increased logistical challenges, which caused delays in decision making. Again the dread of nuclear may balance these concerns.
Having a pet, especially where there is a strong attachment to the pet, decreased the likelihood of evacuation. Many studies highlighted concerns about shelters accepting pets, the added cost of evacuating with pets and the logistics of having a pet at a shelter as impediments to evacuation.
Adults who have dementia or other cognitive disabilities and a caregiver(s) who would evacuate with them have evacuation rates that are the same as, or lower than, others. Caregivers were concerned with the potential for those in their care to be exposed to stigma and lack of privacy in a shelter. They were also concerned that unfamiliar settings would exacerbate their symptoms. Family and friends (the social network) tended to play an important role in determining whether to evacuate or not.
Adults with dementia and their caregivers who did go to shelters experienced a range of difficulties, including increased agitation, emotional distress and disorientation. It was challenging for caregivers to provide normal levels of care and comfort in this environment.
Care facilities and their caregivers were challenged in making the decision whether to evacuate or not, given their sense of responsibility to their residents. This research also indicated the importance of care facility residents and their families deciding (and documenting) who would care for them in a disaster (e.g., whether or not they would evacuate to a family’s residence) and then not changing that decision as the threat neared.
Having a household plan increased the likelihood of taking the appropriate Shelter in Place protective action for a tornado. This may be presumed to apply for any threat, underlining the importance of prior information that encourages preparation.
Studies found that individuals grapple with many concerns when deciding to evacuate. According to these studies, the following concerns delayed or negatively influenced the decision:
- - Traffic congestion and the availability of fuel;
  - The ability and cost of evacuating with pets;
  - Costs of evacuation, including travel costs;
  - Potential issues around the legal status of undocumented immigrants;
  - Individuals faced with a public shelter as their primary destination had more reluctance to evacuate. Their concerns include crowding with strangers and being located farther away from social networks.

On the basis of the observations a number of recommendations were made:

Use websites and social media platforms and work with local media to provide authoritative, time-stamped, geo-tagged photos and videos of hazards such as rising waters and wildfires. Encourage individuals to share those visuals with friends and family, including via social media. Again, there are differences between these events and radiation emergencies to take into account but there is something to take away from this recommendation.
Warning messages should be clear, consistent and strong but not overly dramatic. Mandatory evacuation orders had more weight than voluntary ones and also carried increased media coverage.
Changing the geographic areas subject to advice can cause confusion and a resulting drop in compliance. This should be minimised where practical.
Messages that clearly described the probable personal impact of the hazard helped individuals realise that they would be personally impacted which motivated protection action.
Visuals such as maps and photos improve message comprehension and support decision making.
Authority figures acting as role models and being seen to comply is helpful.
Tourists who sought information from tourist offices rather than hotel staff were more likely to evacuate (this was in the context of a major storm brewing).
The current event should be compared to those that have posed similar threats. Hopefully nuclear industry will ever have a good back catalogue.
In the preparation stage relationships should be built with television and radio forecasters and other journalists likely to cover the story should it arise.
People should be encouraged to sign up to relevant alert and news feeds, including during the event.
There should be a mechanism in place to follow and monitor the social media of authoritative sources to keep information consistent and address inconsistencies and inaccuracies if they occur. In the UK we also try to coordinate the media lines taken before media releases are issued.
Communications strategies should be tailored to gender differences. For example, given that women are more likely than men to take protective actions, messaging on preparedness should consider the use of outreach channels geared toward women.
Include individuals with disabilities, access and functional needs, and associated advocacy organizations in developing and reviewing community plans for evacuation.
If an evacuation may be called for then consider breaking the news at a time that allows the travel to be completed during daylight hours.
When issuing evacuation orders, explain the risks that led to the decision to evacuate some zones and why other zones are not evacuating.
Provide information about public shelters, including items associated with comfort (e.g., availability of power, air conditioning, rest rooms, and space for families and pets) as well as services for individuals with disabilities and access and functional needs.

The slide library available here is a very good way to assimilate the information given in this report.

IAEA Nuclear Security Series No. 41‑T

Technical Guidance Preparation, Conduct and Evaluation of Exercises for Detection of and Response to Acts Involving Nuclear and Other Radioactive Material out of Regulatory Control

The IAEA’s Nuclear Security Series provides international consensus guidance on all aspects of nuclear security to support States as they work to fulfil their responsibility for nuclear security. The IAEA states that “The overall objective of a State’s nuclear security regime is to protect persons, property, society, and the environment from the harmful consequences of a nuclear security event. With the aim of achieving this objective, States should establish, implement, maintain and sustain an effective and appropriate nuclear security regime to prevent, detect and respond to such events. The nuclear security regime covers nuclear material and other radioactive material, whether it is under or out of regulatory control, and associated facilities and associated activities throughout their lifetimes.”

The steps on the way to achieving this include the development of a national detection strategy, the development of detection systems and the processes to monitor and act upon alarms. The response to a genuine event includes notification and confirmation/assessment, location and categorisation, recovery of sources and collection and preservation of evidence. These are explained in detail in IAEA Nuclear Security Series No. 15.

There is an expectation stated in paragraph 6.21 that “The State should carry out exercises under the plan using credible scenarios. Competent authorities should perform exercises and drills at regular intervals, in order to evaluate the effectiveness of the plan. When possible, States should consider participating in regional and international exercises and drills.” IAEA Nuclear Security Series No. 41‑T gives a comprehensive account of how these could be managed.

Exercises can be based on a structured and moderated discussion (a table top exercise) or on activities performed in an operational or field situation to enact a realistic scenario in a manner that simulates, to some extent, the stress and practical constraints of an actual incident (a drill or field training exercise).

The steps taken to plan an exercise include:

Determination of the key activities to be exercised – the scope and objectives of the exercise;
The format and type of exercise, identifying the constraints that these impose;
Agreeing a planning timeline with the key stakeholders;
Developing and approving an exercise scenario;
Identifying the exercise participants and their roles and determining how any gaps where organisations are not playing will be filled;
Developing evaluation criteria.

The report goes through these steps in more detail giving useful advice and warnings as it does. It defines the roles of Exercise Director and exercise planning team; controllers and facilitators, evaluators and players and the support from media spokesperson, observers, safety officer, qualified expert in radiation protection and the rapporteur.

Section 4 of the report discusses: setting up the exercise and preparing for exercise safety; providing exercise briefings; conducting exercise play; and holding debriefing activities and section 5 evaluation.

Appendix 1 gives a useful list of example key activities and actions while Annexes give templates for exercise planning, exercise documentation, assessment and feedback forms and exercise reports as well as an example exercise scenario.

This report is a useful read and contains useful resources for anyone planning such an exercise.

Learning for nuclear emergency planning from COVID-19?

The model of the UK response to a nuclear emergency that results, or may result, in a plume of radioactive material spreading across populated areas of the countryside is to get the local responders, notably the local authority, emergency services and health services, in one place to discuss, decide, coordinate and respond.

Within the model is a unit called the Science and Technical Advise Cell (STAC) with the mission “to ensure timely coordinated scientific and technical advice during the response to an emergency”. We were told that “The STAC should bring together technical experts from those agencies involved in the response and who may provide scientific and technical advice to the Gold Commander. The purpose of the cell would be to ensure that, as far as possible, scientific or technical debate was contained within the cell so that the SCG (and others involved in the response) received the best possible advice based on the available information in a timely, coordinated and understandable way.”

Implicit in this process is the assumption that in any event there is an objective truth and that if scientists chat about it for a while they will determine and understand that truth and be able to explain it to the decision makers who have been too busy on other aspects of the response to explore the science for themselves. The decision makers will be jolly grateful to the STAC and, armed with the scientific consensus, will go on to make the right decisions. They might even say time after time that they are being driven by the science.

In this ideal world, these decisions will be reported to the public and to the media, will be implemented and the crisis will be bought to a close. Also in this ideal world the decisions turn out to be the “right” decisions and the only decisions that could be considered to be “right”, all other options, explored and unexplored, being “wrong”.

One thing we have definitely seen with the coverage of Covid-19 is that the media will not just forward your advice to the public as you might hope. Instead they will turn out an army of interpreters who, fearful that Mrs Miggins and her neighbours will not understand that those in a defined area are being asked to shelter and those outside the area are not, will explain at length what they think “shelter” means and why it has been recommended. They will then find a talking head to explain it again and then another to say that the previous interpretation was wrong and that the public should be being advised to do something else entirely. They will summarise by saying that there is a lack of clarity in what the advice is and who it applies to before cutting to a member of the public who will confirm, in response to a loaded question, that they don’t understand the advice and that they are very worried.

Returning to the decision making, the major issue is that the science does not give all the answers. We may be able to estimate radiation doses to the public, with and without protective actions, but these will be educated guesses rather than accurate. The amount of dose saved (benefit) that makes a protective action (with a cost) worthwhile is debatable and probably different for different people in different situations. The decision to interrupt the lives of people and ask them to stay in their homes knocking back stable iodine tablets is therefore a judgement call not the outcome of a neat equation. This is particularly true when you realise that the estimates of future doses are horribly dependent on assumptions made about what is happening, and what is going to happen, in the bowels of a damaged nuclear facility, what the weather will be when the activity gets out and where the members of the public will be and what they will be doing. Again the media will bring out an army of “experts” to discuss the technology, the science and the decision making process and will argue that the science is debatable, the process flawed and that any of the decisions made are dubious.

Maybe what should happen is that advisors advise and decision makers decide. The spokesperson issuing the advice should state that the decisions have been taken by the Strategic Coordination Group who took into account scientific advice, advice about the incident and how it could develop and the concerns of and for the people affected.

The media should be asked to transmit the advice as given and to resist reheating and reinterpreting it.

That will work.

What are the lessons for the nuclear industry from Covid-19? How do we ensure that our protective action decision making process is robust, transparent, unambiguous and trusted to ensure a high level of public compliance and optimum dose reduction?

REPPIR 2019 Transition

The REPPIR 2019 regulations come into force on 22^nd May 2019. http://www.legislation.gov.uk/uksi/2019/703/contents/made

Any person who had a duty under REPPIR 2001 can continue to use these older regulations until May 2020 when they must be fully compliant with the newer regulations.

So what has to happen within the next 14 or so months?

Regulation 3 (application) is fairly straight forward. The operator must compare their holdings of radioactive material with schedules to determine if the regulations apply to them.

A written “hazard evaluation” is required for sites that pass the regulation 3 test (regulation 4). Preparing this from scratch could be onerous for a complex site but most will already have done a lot of the preparatory work in their safety cases. For licensed sites, in particular, a lot will depend on how the regulators want the work presented. If they are content that the safety case is the written hazard evaluation then little work is required. If they want a special document to cover the regulation then a great deal of work may be required to extract information from the safety case, present it and have the document verified and approved. A document of this nature may have to go to the Safety Committee at least once. A time and resource consuming process.

If the hazard evaluation concludes that there is the potential for a radiation emergency then regulation 5 requires a consequence assessment to “consider and evaluate a full range of possible consequences of the identified radiation emergencies, both on the premises and outside the premises, including the geographical extent of those consequences and any variable factors which have the potential to affect the severity of those consequences”. This could be a lot of work and since it all boils down to “how far out should we be prepared to implement prompt countermeasures” it is largely wasted effort as this result can be achieved with far less work.

Regulation 6 requires the hazard evaluation and consequence assessment be kept under review and updated if anything significant changes. This is no different to the old regulations.

The results of the consequence assessment must be reported to the local authority in the form of a “consequences report” (regulation 7). A meeting between the local authority and the operator should be offered to discuss this report and the operator must comply with any reasonable request for more information.

The local authority then has two months to decide on the extent of the DEPZ and to report it to the operator and regulator. This seems to be a bit ambitious since the regulators, who had more expert resource and a deep understanding of the sites’ safety cases could take several years from receipt of a Hazard Identification and Risk Evaluation document (a required document in REPPIR 2001) to determining a detailed emergency planning zone.

Regulation 9 provides the rules for setting an outline planning zone, a new feature. This is set by a series of rules but only time will tell if these rules result in clear answers.

Regulation 10 requires the operator to produce an emergency plan based on guidance about principles, purpose and content given in schedules. It is likely that operators will have to review their on-sites plans to ensure compliance but not at all clear that this effort will lead to better emergency preparedness. This review will probably fit comfortably within the one year transition period but it will require resources.

Regulation 11 sets the requirement for a local authority off-site plan. Again this will already be in place for most sites but a review against the new guidance would probably be called for. There are a number of changes to dose control and limitation (regulations 18, 19 and 20) that will need to be thought through. Local authorities may find this hard to resource.

A new element of the regulations is the concentration on keeping doses below 100 mSv. There are good reasons to propose this (the IAEA support for the statement that no harm occurs for exposures below 100 mSv, for example) but it may be difficult in some cases, particularly for unlikely severe accidents. The operators may need some time to think through this issue.

The review and testing of plans (regulation 12) is little changed from REPPIR 2001. The only issue might be the disruption to the review and testing programme caused by the introduction of new regulations.

The new regulations demand a lot of consultation, co-operation and agreement (regulations 7, 9, 10, 11, 12, 13, 14, 15, 18, 20, 21, 24). Consultees include other local authorities, category 1 responders, health authorities, public health organisations, regulators, employers, employees. This is well meaning but it takes time and resources and takes the consultees away from their day jobs.

In summary. Within a year of May 22 2019 the operators of nuclear sites are expected to produce a consequence assessment and a consequence report based on their safety cases, the local authority are expected to use this information to determine the extent of planning zones, the operator and local authority are to produce emergency plans compliant with the revised regulations and a significant number of groups are to be consulted, informed or trained.

Writing significant reports in the nuclear industry tends to take a while. They need to be drafted and verified. Reports with the importance of the two related to these regulations would normally go to the site’s nuclear safety committee for review and approval. This is a time consuming process, particularly if the committee wish to see changes and resubmission, which is not an uncommon result particularly for novel reports, as the first of these will be.

The local authority are allowed two months to consider the information provided by the operator and the layout and demographics of their area to decide upon the extent of the planning zones. They will need a process to brief their chief executive and get the conclusion endorsed within this timescale.

Emergency plans may have to be updated if the detailed emergency planning zones have changed (and if they haven’t then pretty much all of the work leading up to this stage has been pointless). Plans will have to be updated to account for the differences in expectations between the 2001 and 2019 regulations, in particular the outline planning zone, the 100 mSv reference level and changes to emergency dose terminology.

It is going to be a busy year chasing tight timescales for some in the local authority and nuclear industry emergency planning world.

REPPIR 2019

REPPIR 2019 has been laid before parliament. The regulations can be found here.

These Regulations may be cited as the Radiation (Emergency Preparedness and Public Information) Regulations 2019 and come into force on the 22nd May 2019.

Two new pieces of advice for local authority emergency planners

Local authorities’ preparedness for civil emergencies: A good practice guide for Chief Executives And A councillor’s guide to civil emergencies

The Ministry of Housing, Communities & Local Government has reissued advice to local authorities on preparedness for civil emergencies (Local authorities’ preparedness for civil emergencies: A good practice guide for Chief Executives, November 2018). This document, which is not intended to be prescriptive, lists 10 aspects it would expect to see in a well prepared authority.

In the introduction Jake Berry MP states that the nature of emergencies facing us continue to increase in variety and complexity “terror attacks in London and Manchester, the use of nerve agent in Salisbury and the devastating fire at Grenfell Tower have tested the resolve of our communities and reminded us all of the importance of local authority leadership in times of crisis”.

The section entitled “are you ready” asks nine questions about:

the ability of residents to contact the authority including out of hours and on bank holidays;
the authority’s ability to communicate risks and to warn and inform people in the area, including tourists and other visitors, before, during and after an emergency;
the ability of senior staff and elected members to manage in an emergency, including managing the authority’s role and as a senior officer within the strategic response and recovery mechanisms;
the testing of plans to ensure that they address local risk and resilience standards and describe how to maintain essential services, ensure business continuity and contain agreements with other local authorities for support in a crisis;
the resilience of supply chains;
the role of the authority within the LRF and the accuracy of the role description in multi-agency plans and the ability to deliver;
resource plans for no notice and sustained emergencies, including over holiday periods;
a knowledge of the authority’s strengths and weaknesses and where support and further resource can be obtained;
the ability to assess the full impact of an emergency on community needs.

The report discusses the role of the local authority in civil resilience in terms of the CCA, in which the local authority is a category 1 responder.

Importantly the regulations or guidance require that the local authority “to ensure that they can continue to exercise their functions in the event of an emergency. The duty relates to all functions, not just emergency response functions”. This appears to include the ability of an authority to provide support to any population within countermeasure zones during a nuclear emergency. “Plans should be clear about what operational support the local authority will put in place for different emergencies, and how this can be activated in and out of business hours” …. “Plans must be clear about how this support will be activated and managed. This support could include on the ground community alerting, for example, door knocking, checking on vulnerable residents, operating rest centres and providing on-going welfare support for people directly affected by emergencies”.

To achieve this all business critical functions should have robust business contingency plans for the services that the authority delivers and those that are contracted out.

An example that is pertinent to nuclear authorities is “consider building ‘all-risk resilience’ into contracts (for example, how to ensure domiciliary care is delivered during petrol shortages or severe disruption to transport networks)”. Reinforcing this is the statement that “Local authorities are expected to manage the humanitarian aspects during emergencies. This requires staff at all levels to be effectively trained to deal sensitively with victims and survivors, including their friends and family. Training and exercising reserves and volunteers builds a further level of resilience in the event of concurrent or long duration incidents”.

An example of communicating with the public given is that of Calderdale Council which utilised social media during floods in December 2015. It is claimed that the council reached over 420,000 people on Facebook and received over 1 million impressions on Twitter.

On the matter of community leadership the document states that “The public, media and politicians will also look to the council to provide information and clarity on what has happened, what is still happening and what will happen next”.

The importance of training and exercising is stressed. It builds “confidence and competence to enable robust delivery of the local authority role whether it is delivered in response or recovery”.

A list of useful documents is given at the end of the document.

This is a document that should be read by the local authority manager responsible for emergency planning and by the Chief Executive of the authority fairly regularly. It might be a useful one to have on the desk when performing periodic readiness or accountability reviews. At a mere 27 pages it makes a welcome change from some of the “door stop” guidance documents that sap the will to live.

A related document, A councillor’s guide to civil emergencies” has also been updated recently (November 2018). The forward mentions that the last version was issued in 2016 but reports that a lot has happened since then with terrorist attacks, tower fires and nerve agent attacks within the UK.

This document introduces some core terms including the definition of a civil emergency, the difference between a rising tide and a no-notice event, categories of responders and levels of response.

A number of case studies are discussed.

The overview section outlines the responsibilities of councils and individual councillors and, later, the role of leaders, portfolio holders and Ward councillors. These headings are then revisited in sections devoted to “preparedness and resilience”, “response”, and “recovery”.

Appendices give suggested questions for leaders/portfolio holders (Appendix 2) and scrutiny committees (Appendix 3) to ask.

This document is a good read and a useful resource for councils and councillors.

Human Medicines (Amendment) Regulations 2018

The Human Medicines Regulations 2012 have been amended from the 1st April (Human Medicines (Amendment) Regulations 2018) to clarify the legal position of nuclear off-site plans that rely on the speedy distribution (or pre-distribution) of stable iodine tablets and provide advice to the public to take them. This is a useful step forward.

According to the explanatory note attached to the regulations “Regulation 12 amends Schedule 17 to the 2012 Regulations so that pharmacy medicines containing Potassium Iodide or Potassium Iodate can be supplied in the event of a radiation emergency by persons acting in accordance with an off-site emergency plan or by persons listed in Part 1 or 2 of Schedule 1 to the Civil Contingencies Act 2004.”

My understanding of the situation is now that for fixed nuclear reactor sites: (Based on Sizewell off-site plan and Highland Council’s Highsafe submarine plan).

The Director of Public Health determines the areas that pre-distribution of stable iodine should take place in.
The tablets are distributed (“supplied”) by a body such as NHS England or Navy (now permitted under the revised regulation if the radiation emergency has occurred or an event has occurred that could reasonably be expected to lead to a nuclear emergency has occurred although the legality of pre-distribution could be clearer).
On the day the Operator (who is likely to be the first to know that there is a serious release of radioactivity) alerts the public and advises them to take the pre-distributed tablets, having prior authorisation from the Director of Public Health to do this.
If tablets are indicated beyond the pre-distribution range then “PHE would be responsible for coordinating the delivery of additional tablets and NHS England would be responsible for arranging distribution to the public”.

It is easier to scare than to reassure. The Shamisen project report

The EU-OPERA SHAMISEN project started in December 2015. One driver for this project was the realisation that existing recommendations on nuclear accident dose control had an almost exclusively technical focus which was directed towards the decision making process of experts while failing to consider the impact on the general populations. Both Chernobyl and Fukushima taught us that averting dose is only part of the process of protecting the public; social, ethical, psychological issues are as important, if not more so. What was needed was a set of recommendations that would contribute to health surveillance and related communication with affected populations after nuclear accidents.

The project has now reported (here). It presents a number of recommendations and, for each one, it briefly explains why they make the recommendation, how it can be satisfied and who should take the lead. This is a very good format for this type of document.

Of particular interest to me are:

R7 Build a radiation protection culture between radiation protection experts, healthcare workers, professionals and the general public. This is a very big ask. Radiation Protection is eye wateringly complex and it takes several hours to explain the basics to people with a good science education. The big questions are how are the healthcare workers going to find the time to listen and how are you going to convince the public that they need to devote the time and effort to learning. After an accident in their area I think we’d have their attention but not before. This is a laudable ambition, teaching materials can be written (indeed many good examples already exist) but after that there are no quick wins.

R8 Establish early response and communication protocols with responsibilities and roles clearly laid out. Engage relevant stakeholders in the establishment of these protocols, and prepare the necessary material and channels to communicate with the public (including social media). This is part of the preparedness phase. Much of this is already part of basic emergency plans. Off-site plans invariably list who should be alerted and define the roles and responsibilities of responders. Maybe more could be done to prepare information and discuss how it could be presented to the public on the day of an event and in the days and weeks following an event.

R10 Prepare and facilitate training and education material and resources adapted to healthcare and other professionals, as well as other stakeholders. This is another laudable ambition to pre-position healthcare, community leaders and teachers with suitable knowledge and teaching materials ready to step and inform and reassure the public if the worst happens. Again the problem is one of time and focus. Healthcare professionals have a lot of competing issues to consider as they strive to support the community health.

R13 Foster participation of stakeholders and communities by engaging them in emergency preparedness, including planning for socio-economic health surveillance and, where appropriate, epidemiology. Again the industry and the government already does a lot in this area with regular meetings with community groups and community group representation on multi-agency emergency planning meetings. This tends to be more about the arrangements to promulgate and alert and support early countermeasures rather than socio-economics and epidemiology. (Having said that health physics is a challenge to teach it must be recognised that it is relatively straightforward compared to epidemiology).

R14 Ensure prompt sharing of accurate and reliable information (e.g., plant conditions, radiation dose, radiation protection actions) between nuclear plant representatives, authorities, experts and the population. The paper has a great quote here; “it is easier to scare than to reassure”. Talking about the tendency of misinformation to quickly fill any gaps in communication it reports that “a recent study found that, during the Zika virus outbreak, the most popular social media health stories were the least accurate”. This isn’t a surprise but it does focus us on the reality of public communication – it is difficult. The authors conclude this section by saying that “the benefits of online information offer the public a unique opportunity to learn about nuclear power, which may outweigh the costs associated with “internet cacophony”.

I find the recommendation R18 Provide support to populations who wish to make their own measurements, recommending reliable equipment and resources (e.g., apps, social media, information centres) that can contribute to the characterisation of population exposure and its evolution a little hard to agree with. Radiation detection is relatively easy. Radiation measurement is quite difficult. Interpretation of radiation measurements in terms of harm is difficult. There could be benefits from providing groups of people immediately affected by the incident with a group EPD to give a quick assessment of their dose during the acute phase, and providing everyone who returns from evacuation with a personal TLD (collected and read by the authorities) to assess their doses systematically. But I would hesitate to encourage unskilled people to wield unfamiliar radiation monitors and use the results to affect their behaviour.

The recovery phase recommendations all have merit and consideration of this document should be included in any recovery phase planning effort.

What do we need to do better as a result of this advice?

I think that the idea of building up radiological protection knowledge capital prior to an event is sensible but difficult. Encouraging healthcare professions, community leaders and people the community might trust such as teachers is always going to struggle against competing calls on their time and attention. Given that other threats such as flu pandemic, other health scares and themes such as mental health, diet and obesity are more likely to impact they are more likely to take the training time of these people. The industry’s outreach and information programmes should continue.

Early response tools, such as briefing material, are often spoken about and nuclear operators tend to have trained Media Technical Briefers to explain the complexities of nuclear accidents and health implications on the day. A review to see if more can be done, particularly with emerging technology and communications channels, should be undertaken periodically.

Summary

This report is well thought out, well presented and valuable. It deserves to be read by nuclear emergency planners and those responders with responsibility for advising and supporting members of the public before, during and after an accident.

Protective Action Guides

In the United States the Environmental Protection Agency issues “Protective Action Guidelines” (PAGs) which satisfy the same role that Emergency Reference Levels (ERLs) do in the United Kingdom. The Protective Action Guide (PAG) manual contains radiation dose guidelines that would trigger public safety measures, such as evacuation or staying indoors, to minimize or prevent radiation exposure during an emergency.

The 2017 PAG manual is a significant document (101 Pages) which has chapters devoted to:

Early phase protective action guides;
Emergency worker protection;
Intermediate phase protective action guides;
Planning guidance for the late phase.

For the early phase it provides a PAG for shelter in place or evacuation of the public of 10 to 50 mSv projected dose over four days. This is accompanied by a note that suggests that actions should start at 10 mSv projected dose and take whichever action or actions result in the lowest exposure for the majority of the population. This is broadly consistent with IAEA advice and UK practice although the UK ERLs are based on averted dose rather than projected.

The stable iodine PAG is 50 mSv to the infant thyroid from exposure to radioactive iodine.

Emergency workers should be limited to 50 mSv over the entire response or per year unless there are extreme circumstances (such as saving life or preventing a significant release).

The report warns that: “In the early phase, there may be little or no data on actual releases to the environment and responders may have to rely on crude estimates of airborne releases. Decision time frames are short and preparation is critical to make prudent decisions when data are lacking or insufficient.”

The report suggests that the public should be advised to cover their mouth and nose with “available filtering material” when particulate activity may be present. This advice is not given in the UK.

It is also suggested that where particulate activity is present but below the PAG level the public are advised to “stay indoors to the extent practical” to reduce their dose but make a judgement if they need to go out for any reason. Such advice is apparently given on days when air pollution is forecast to be bad. Again, this is not something I’ve heard mentioned in the UK.

A discussion about the relative merits of shelter in place and evacuation concludes that “Sheltering-in-place should be preferred to evacuation whenever it provides equal or greater protection. Sheltering-in-place followed by informed evacuation may be most protective”. It reports that populations that are aware of the evacuation alerting mechanisms and plans are more likely to successfully evacuate than unprepared populations and further reports that many areas are improving their communications processes and public training. The need to have special plans for needy groups such as schools, institutions and those without their own transport is noted.

On iodine tablets the report suggests that minimum doses for each age (weight) group is ideal but that, if this is too challenging logistically and in terms of communication, then a full dose can be given to all without great risk.

Interestingly it suggests that adults over 40 years old would only benefit from stable iodine if their projected thyroid dose is of the order of 5 Sv where it can be used to prevent hypothyroidism.

Stable iodine given to pregnant women also protects the foetus but repeat doses should be avoided if possible to prevent foetal thyroid complications. (In the UK it is expected that a single dose of stable iodine will be adequate because either the release will have stopped or the affected members of the public should be evacuated within the 24 hours that the first dose provides protection for).

Breast feeding mothers can reduce the radioiodine in their milk by taking the usual dose of stable iodine. This is useful for reducing the baby’s dose but does not protect them from directly inhaled radioiodine for which a small dose of stable iodine can be administered.

Section 2.3 discusses the process of estimating dose projections based on source terms, atmospheric dispersion and release prognosis. Section 2.4 discusses contamination and environmental monitoring.

Subsequent sections discuss the control and limitation of dose to responders and recovery workers and doses in the later phases of the event, including from food and water, once the release has stopped. Of interest is table 4-2 which summarises a discussion about the circumstances under which people can be allowed back into an area, either for remedial work, use of critical infrastructure, to access business and homes to recover property.

On the whole the advice given in this report is similar to that given in the NRPB’s ERL documents that are used in the UK. It contains some interesting and useful discussion.

Heatwave plan for England

PHE and NHS England have issued new advice on planning for heatwaves (here).

The purpose of this heatwave plan is to reduce summer deaths and illness by raising public awareness and triggering actions in the NHS, public health, social care and other community and voluntary organisations to support people who have health, housing or economic circumstances that increase their vulnerability to heat.

It states a concern that periods of hot weather will become more common in the UK as climate change kicks in leading to increased deaths among several identified vulnerable groups and some infrastructure issues.

The Met. Office has a mechanism for promulgating alerts about forecasts of dangerous weather conditions and this is explained in the context of heatwaves and is linked to five levels of heatwave readiness.

We should be trying to make our public spaces, buildings and homes cooler by design, including tree planting and open water features. Cooling homes by appropriate shading and ventilation but also by choice of colours for curtains and roofs.

On the day we should be avoiding exercise in the midday sun, drinking plenty of water but less caffeine, wearing cool clothing and looking out for our neighbours.

It is a bit light on what employers can do to protect their workforce without sacrificing more productivity than required but, if they read the report, they’ll pick up some useful tips.