ALAN LEIBOWITZ, CIH, CSP, FAIHA, is the president of EHS Systems Solutions LLC, chair of the Joint Industrial Hygiene Ethics Education Committee, past chair of the Board for Global EHS Credentialing, and a past Board member of AIHA.
Perfection vs. Practicality in Disaster Response
Editor’s note: The case study in this article is fictitious and is intended to highlight ethical issues in the practice of industrial hygiene. Any resemblance to real people or organizations is coincidental. The opinions expressed in this article are those of the authors and do not necessarily reflect the opinions of AIHA, The Synergist, the JIHEEC or its members.
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By their very nature, disasters are unpredictable and require an agile and flexible response to address issues both large and small. While failure of a specific operational capability or resource can itself be considered a disaster, more often, disaster events include compromises of multiple systems. These failures can cause extreme property damage, utility interruptions, supply chain disruptions, civil unrest, and abrupt changes in regulatory or customer requirements.
After a long career as the OEHS lead for a major corporation, with global responsibility for business continuity and disaster response, I recently had an unwelcome opportunity to experience the personal impacts of living in the eye of a major catastrophe and its aftermath.
In late September, my coastal Florida home was directly hit by the peak winds and tidal surge of Hurricane Ian, including almost six feet of water flooding into my home. For more than a day my home was part of the Gulf of Mexico. At a community level, the impact from Ian’s surge, flying debris, and winds has been one of the most significant in U.S. history with over 125 deaths, more than any other Florida hurricane since 1935, and tens of billions of dollars in property damage.
While I had significant experience leading a corporation’s business continuity efforts, including addressing many catastrophes such as tsunamis, wildfires, armed conflicts, terrorism, pandemics, storms, and nuclear incidents, the experience of being one of the impacted was very different from my familiar managerial role. In both circumstances, implementation of controls to protect community members and response workers was a priority while recognizing that ideal protective measures would not always be possible given the limitations of available resources.
Several of my personal observations of Hurricane Ian align with my corporate experience: 1. Response time is critical to minimizing long-term impacts. In this instance, addressing potential mold growth and debris hazards were priorities. 2. Each affected party will compete for limited resources. Only a lucky few will have access to the most capable and best-prepared contractors and equipment. With community-wide power outages, alternative housing and stores capable of providing essential supplies were difficult to find. 3. Regardless of preparation, unforeseen issues will arise. For us, one example was that our standby generator, which was elevated to meet building codes, failed. All local replacement supplies were exhausted, leaving us with no power for several weeks. In this high-humidity environment, mold growth was a particular concern due to limited availability of power for dehumidifiers and air conditioners. 4. Local resources will vary, but in general, disasters bring neighbors and broader communities together for mutual aid and support. 5. The most capable governmental emergency response resources will appropriately be deployed where impacts are the greatest. Those with lesser impacts must be more self-sufficient. 6. Often there will be confusion as to who is in charge, and conflicting requirements may be communicated. One example we experienced was confusing and inconsistent guidance from electric utilities and government officials regarding how and when it was safe to restore power.
On the ground, adherence to good OEHS practice can be a challenge when resources such as water, power, or appropriate protective equipment may not be readily available. In the case of local response to Ian, large numbers of newly trained response personnel were immediately enlisted to assist with removing sand, mud, debris, and affected structures from impacted buildings. While these teams brought some of the equipment required for the response, the tools they used were often salvaged from the debris. Workers generally wore gloves and basic, sturdy garments; respirators, eye protection, and air-handling equipment were used less often.
Adherence to good OEHS practice can be a challenge when resources such as water, power, or appropriate protective equipment may not be readily available.
Demolition and “mucking” teams were generally receptive to safety and industrial hygiene recommendations to minimize their potential exposures. However, immediate response goals often led to work in potentially hazardous conditions. With homes and businesses inundated with contaminated and biologically active muck, speed of removal was an immediate priority. The criticality of that rapid response was confirmed by observation of the consequences of the delayed response in several homes where debris and muck removal were not performed for more than a week. In those instances, decay of contaminants along with mold growth or other structural contamination led to a much greater risk to workers as well as ruin of adjacent contents and the buildings themselves.
Resources for sampling and evaluating potentially hazardous working conditions or airflow were not generally available. Risk evaluations, where they took place, were most often performed by observation of the nature of the debris and damage. Many injuries occurred during response and recovery operations, including several deaths from bacterial infections.
The following hypothetical scenario is based on observations and anecdotal reports from community members affected by Hurricane Ian and workers who participated in the response.
UNACCEPTABLE RISK? After a long career as an OEHS professional, Heather retired to a coastal community in Florida. Shortly after she settled in, the community was struck by a significant hurricane. In addition to the typical effects of high winds, this hurricane included a tidal surge that inundated Heather’s home and left several inches of mud from a local bay throughout her living space.
Based on her training and experience, Heather knew that prompt removal of this mud and potentially contaminated structural elements was her priority. Heather had several contacts with nationally recognized remediation firms and immediately contacted them for assistance. Unfortunately, the firms that had crews available indicated that it could take up to a week for them to respond. That delay seemed unacceptable, and Heather frantically explored local alternatives. She observed that several neighbors had crews actively addressing the contamination in their homes. Most of the workers appeared to be from various local building trades that, in a show of community support and appreciation for potentially higher profits, set aside their regular work to assist in the cleanup. Heather approached several of the crews before identifying one that appeared capable and able to help her.
When they arrived at her home, Heather discussed with the supervisors the scope of their efforts and her concerns regarding potential hazards the team might encounter. The team primarily consisted of laborers with construction experience, but few were familiar with the unique concerns potentially associated with this event. Supervisors were experienced in disaster response and monitored worker activities. Heather explained her background and suggested to the supervisors that they warn the workers to watch for wildlife and any leaking containers or other signs of contaminants of concern, and to be particularly careful to address any injuries that resulted in open wounds, along with other safety suggestions. While she knew the importance of a prompt cleanup, she made it clear that she did not want anyone to get hurt.
Heather was impressed and appreciative with how diligently the crew worked. Eye protection was a particular concern with so many hand tools being used for demolition. All work was performed with doors and windows open to the outside environment.
The work was completed without any observed or reported injuries. While Heather did not see any situations that clearly presented critical OEHS risks, in some instances she might have asked supervisors to pause activities for further evaluation if she had observed them in a professional capacity. But in this instance, she knew that if work stopped for any extended period the team would just move on to their next task or to the next home on their list.
FOR DISCUSSION Is there any acceptable difference in the OEHS controls employed in disaster response versus those used in standard work? Can professional judgment be used to establish protective procedures in the absence of sampling data during an emergency? Should Heather have waited until a fully trained and equipped team was available? Should Heather have insisted that all possible protective equipment be used where potential risks were present? Should Heather have personally informed each of the workers about the hazards associated with their work?
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