The Number-One Response Priority

The 2017 hurricane season produced devastating storms that swept across Puerto Rico, the Virgin Islands, Texas, and Florida. Hurricane Maria knocked out power to over 90 percent of Puerto Rico; one month later, only 8 percent of Puerto Rico’s roads were open, according to The Weather Channel. Much of southern Florida was affected by Hurricane Irma, prompting the state to seek federal assistance under the Stafford Act. Recent emergencies haven’t been limited to hurricanes. In 2017 and 2018, the West Coast of the United States experienced severe wildfires. The Camp Fire of 2018 was the deadliest and most destructive wildfire in California history, destroying the town of Paradise. Other massive wildfires included the Carr Fire in Shasta and Trinity counties, which was the seventh-largest wildfire in California history; the Tubbs Fire in 2017, California’s second-largest wildfire; the Mendocino complex fire; and the Wine County fires. Disasters like hurricanes and wildfires present a plethora of hazards to those tasked with responding to them. As discussed in Part 1 of this article, “The Road to Reconstitution,” which appeared in the December 2017 Synergist, we OEHS professionals have the mindset necessary to improve the safety of the response and the skills and instruments necessary to become directly involved on the ground. In this article, the roles and deliverables, particularly within the Incident Command System structure, will be explored in further detail. THE SAFETY OFFICER How would you, as a safety or IH specialist, get involved in a response, and what would that response look like? The huge number of variables and dizzying array of outcomes makes answering this question virtually impossible on an individual level. That said, this article shares nuggets of information gleaned from years of experience responding to emergencies and disasters. The top priority for every response is the safety of responders and the public. This priority dominates every aspect of a response, from the overall strategic direction laid out by a Unified Command to tactical decisions made in the field. With such an emphasis on safety, the position of Safety Officer, or SOFR, plays a vital role within the ICS framework. As a member of the Command Staff, the SOFR wields extensive authority, second only to the Incident Commander or—in large responses with multiple Incident Commanders—the Unified Command.

RESOURCES

AIHA: Incident Safety and Health Management Handbook, 2nd ed.

Federal Emergency Management Agency: “ICS Forms.” The Synergist: “The Road to Reconstitution: Responsibilities for OEHS Professionals in an Incident Command System” (December 2017). U.S. Coast Guard: “Incident Command System Forms.”

“The Road to Reconstitution” examined the general roles and responsibilities that IHs may play in responses. This article explores the roles of SOFR and assistant safety officer, or ASO, in more detail. It explains how the SOFR and ASO interact with the response and highlights the critical components of the deliverables they’re responsible for. DELIVERABLES Safety officers and incident commanders can use the ICS forms available from the Federal Emergency Management Agency and the U.S. Coast Guard or modify them to meet the needs of specific responses. Table 1 lists the main forms discussed in this article; these are the forms that the SOFR traditionally focuses on. Note that other forms or deliverables may be of particular interest for the SOFR for a given response.

Emergency Safety and Response Plan. Those familiar with ICS know the importance of the “Planning P.” Touted by nearly every ICS reference, the “Planning P” is a flow chart of an effective response (see Figure 1). The response begins at the bottom of the P’s stem, which can be referred to as the emergency phase—before a source has been controlled and prior to the creation of the Incident Action Plan, or IAP. During the emergency phase, the SOFR might need to create an emergency safety and response plan, also known as the emergency safety plan (ESP) or the Coast Guard’s form 208A (for responses led by the Coast Guard). This plan provides a quick set of safety-related references to help responders by noting hazards, displaying a site map, listing required PPE, and outlining a decontamination plan. The emphasis on this part of a SOFR’s job is readiness. The SOFR’s responsibility is to provide concise, understandable content that can help responders navigate their duties safely in a chaotic or dynamic situation. Speed is never a substitute for accuracy, however, and all information found in form 208A or equivalent document needs to be correct and encompass the scope of tasks within the initial response.

Table 1. Select ICS Forms

Tap on the table to open a larger version in your browser.

Figure 1. The operational planning cycle, showing the “Planning P” and the “Operations O.” Adapted from FEMA’s National Incident Management System, 3rd ed., October 2017.

Tap on the figure to open a larger version in your browser.

Site Safety and Health Plan. Once a response moves out of the emergency phase, it enters the traditional ICS Planning P schedule. As the response evolves over multiple operational periods, the Planning P becomes the “Operations O.” In this phase, the central document the SOFR is responsible for is the Coast Guard’s ICS form 208, also known as the Site Safety and Health Plan. This robust document is like an ESP but delves into much greater detail. The FEMA version of form 208 is called the Safety Message-Plan. FEMA’s form 208HM is used for a hazardous materials response when an exclusion zone is established for an all-hazards event. While the ESP is intended to be easily and quickly understood, the 208 covers all safety- related aspects of a response. The 208 is the SOFR’s tool for communicating safety knowledge and wisdom gleaned from experience to all responders, including safety-related contact information, an exhaustive list of hazards, required personal protective equipment, an air monitoring plan, and applicable safety thresholds for exposure. Keep in mind that massive responses spanning large geographical areas might require on-the-fly creation of site-specific safety plans that hone in on possible hazards present in one area of responsibility but not others. Assignment List. The SOFR works with the Operations Section Chief, or OSC, to complete a hazard and risk analysis of work assignments (ICS form 204) identified in the IAP. This critical form identifies goals and objectives for the next operational period, as well as strategies and tasks that will be undertaken by field personnel. Operational Planning Worksheet. Work assignments and resources needed are identified on the Operational Planning Worksheet (ICS form 215). Incident Action Plan Safety Analysis. The safety analysis is documented on form 215A, the Hazard/Risk Analysis Worksheet. Similar to a Job Hazard Analysis, or JHA, the 215A reviews each task for hazards and risks, and identifies mitigations for each hazard. The 215A is not usually included in the IAP. However, a 204 is provided to each division or group for which a task is assigned. The SOFR should transfer the information identified for each task assignment from the 215A onto the appropriate 204 (in the box for “special instructions”). By ensuring that safety information is included on the 204, the SOFR can relay task-specific safety analysis and information on controls directly to all members of the division or group performing work in the field. Wildland firefighters use a variation of form 215A that includes a risk ranking score for identified hazards before and after mitigation. AIHA has also developed a 215A that looks very similar to a JHA. AIHA’s 215A is published in the second edition of the Incident Safety and Health Management Handbook. General Message. Another important component and communication tool is ICS form 213, the General Message. This simple form is useful for topics that the SOFR wishes to highlight to the greater response community. Some examples of topics appropriate for a form 213 are specific OSHA guidance on accident avoidance and mitigation for important or commonly used tools and equipment, information on how to work around or deal with dangerous wildlife in the area, and hazard characteristics for chemicals found in the work area. Medical Plan. The SOFR must also sign off on the medical plan, ICS form 206. This plan indicates which medical care facilities are in the area and whether they have special capabilities like burn or chemical units in case such care is needed for responders. In general, the Medical Unit Leader or MEDL is responsible for form 206, but if the MEDL position is not filled, the SOFR is typically responsible for ensuring the form is completed and maintained. If medical monitoring is required as part of the response, the SOFR must work with the MEDL to ensure that it is incorporated into form 206. One example of medical monitoring includes exams to determine workers’ fitness to wear respirators. Other exams might be required if an exposure has occurred. OTHER DUTIES While ICS forms offer a glimpse of the SOFR’s main functions, there are other critical responsibilities that the SOFR must fulfill. One of the SOFR’s most crucial decisions is determining how many assistant safety officers are needed. ASOs can reduce the SOFR’s workload by managing forms and messages, by serving as the SOFR’s eyes, ears, and voice in the field, and by running point with accident investigations. When the SOFR is stuck in meetings, an ASO can staff the phones and manage ongoing events in the SOFR’s stead. The SOFR also works with the IC/UC to determine how they will execute stop-work authority. Who will this authority be granted to? The easy answer tends to be that everyone in a response has stop-work authority—that is, anyone has the authority to stop whatever work is going on if an unsafe situation is unfolding or a near miss or accident has occurred. Sometimes, particularly when the response directly affects the safety of the public, stop-work authority may be reserved for personnel in higher positions within the response (such as a Division/Group supervisor). Another related and important decision that needs to be addressed as soon as possible once a response has begun concerns the process and authority for canceling a stop-work call and resuming operations. I usually recommend this authority be granted to an ASO or the SOFR along with an OSC or Deputy OSC and the IC/UC. It is surprisingly common for safety issues to become marginalized during a response or explained away as flukes without corrective actions being taken. Pressure to lift a stop-work call can be strong; it is the SOFR’s and ASOs’ responsibility to ensure that reengaging in work won’t result in future injuries or worse. Decisions about the lifting of stop-work orders can be contentious within the Incident Command, but the SOFR must stand his or her ground. THE GREATEST HOPE A response action isn’t going to wait for the SOFR or an ASO to complete all the deliverables described in this article. This is just one reason why the SOFR position is challenging, requiring both a specific skill set and underlying knowledge base. That said, comparing the characteristics of a successful SOFR/ASO with those of many IHs shows that we do indeed provide the greatest hope that the IC/UC will be able to meet their number-one response priority—and everyone will be safer for it. LCDR. AARON L. RIUTTA, MS, is the response department head at Coast Guard Marine Safety Unit, Valdez, Alaska, and a DHS-FEMA Type 1 ICS Safety Officer. DANA STAHL, MS, CIH, is an instructor and content manager at the Pacific Northwest OSHA Training Center (osha.washington.edu) and lead instructor for the Center’s Emergency Safety Officer Course. BRIAN HAYNACK, MS, CIH, CSP, is global director of EHSRA Continuous Improvement and Integration at The Sherwin-Williams Company in Cleveland, Ohio. Send feedback to The Synergist.

IPGGutenbergUKLtd/Getty Images

Responsibilities for OEHS Professionals in an Incident Command System, Part 2

BY AARON L. RIUTTA, DANA STAHL, AND BRIAN HAYNACK

The Number-One Response Priority

the Synergist