CBRN versus HazMat: One of these things is not like the other
Warrant Officer Christopher Dawson, 9th Chemical Company, gathers simulation samples during training from a site set up as a suspected chemical weapons lab. Operation Rolling Thunder, Oct. 15-17, provided the 110th Chemical Battalion an experience for soldiers trained in tech escort missions to put their sample-gathering skills to the test. Photo by SGT Mark Miranda, 5th Mobile Public Affairs Detachment. Public Domain.
So far my posts have been very "big picture." This week, I'd like to get down in the weeds and talk about something more hands on. In particular, I'd like to address some common misconceptions about the nature of CBRN operations, which go well beyond incident response, beginning with the differences between CBRN operations and HazMat incident response.
CBRN operations are fundamentally different from Hazardous Materials incident response. While the two share some commonalities - they both deal with dangerous stuff that requires personal protection - their missions and focus are divergent. Some of those differences:
- CBRN missions can include Sensitive Site Exploitation (SSE) and intelligence operations where the hazardous material is of secondary concern - a laptop may be more important than a chemical sample taken at a site.
- CBRN missions often occur under battlefield conditions or during special operations where dynamic entry and "snatch and grab" is the norm. The goal is to get a sample, even if it is quick and dirty. The niceties of environmental sampling do not always apply.
- HazMat teams don't usually deal with weaponized material, which mix hazardous substances with a delivery mechanisms, many of which pose their own, very different threats.
- Many CBRN missions deal primarily in unknown risks, often multiple unknowns, which can remain unknowns throughout the entire mission. HazMat often deals with single hazards readily identified from placards or markings.
- The priority for CBRN missions is frequently identification (in the case of chemical or biological) of both the agent and the actor. This places the focus on sampling and intelligence collection, rather than the mitigation of spills or leaks, the focus of most HazMat response.
- Hazmat places a priority on safety and over thinking a situation. Their mantra: "Better safe than sorry." CBRN Operations are mission focused and accept greater risk by their nature. They attempt to limit risk, but accept it as part of the mission.
Despite these differences, a significant part of the CBRN community suffers from a “hazardous materials” mindset among operators. This approach places personnel safety and risk management in the fore and is widely used in both military and civilian hazardous materials teams. Teams like the 20th Support Command’s Technical Escort Battalions and members of the National Guard’s Civil Support Team – Weapons of Mass Destruction program train according to this approach.[1] Likewise, fire departments, hazardous materials contractors, and environmental agencies all utilize the "safety first" approach that encourages HazMat operators to ask a lot of "what ifs" and assume worst case before they make entry into a hotzone.
At its most basic, the hazardous materials training requirements that personnel receive under the Occupational Safety and Health Administration requirements known as HAZWOPER define this approach [2]. The National Fire Protection Association (NFPA) sets the standards for this approach in NFPA 472: Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents, defining training programs and operational standards. The NFPA has adopted, and the CBRN community widely utilizes, the NFPA standards of competence and training definitions for training their personnel. This approach has three levels of competence: Awareness, Operations, and Technician. Collectors and sample teams in the CBRN community usually train to the Technician level. The U.S. Army Chemical School has also begun to incorporate such civilian standards and training into their training for all military CBRN personnel.
Further, according to both law and executive order, most safety offices in the federal government, to include the military, would generally advise compliance with the requirements of 29 CFR 1910.120 despite "military unique" exemptions. The traditional approach in this regard is to meet the training requirements under OSHA and NFPA standards, and adopt appropriate Personal Protective Posture for personnel engaged in operations involving hazardous materials, to include a growing number of CBRN missions. Yet the training, and the HazMat approach, focuses on the emergency responder community, and that approach is ill suited to many of the unique CBRN mission parameters identified at the beginning of this post, even if the training has significant underlying value as a base from which to learn.
With that I'd like to examine the traditional HazMat approach, and suggest an alternate approach (in this post) that offers significantly more utility for a broader range of CBRN operations.
The Hazardous Materials Approach
The traditional hazardous materials emergency response approach views all hazardous materials responses, to include CBRN, through the same lens. The requirements of 29 CFR 1910.120 and NFPA 472, driven by health and safety concerns, forms the basis of this approach. Key components include:
- Situation “size up” – (Preliminary Evaluation) this is an initial assessment of hazard used to drive personnel protection measures.
- Hazard Identification – The preliminary evaluation makes a preliminary identification of the site hazards. These include physical hazards and chemical hazards. In the case of most transportation accidents for instance, the hazard identification observation occurs via vehicle or container hazardous materials placards or other markings.
- Site Safety Plan – Hazardous materials response requires the designation of a “safety officer” responsible for developing a site safety plan based on the preliminary evaluation of the incident/site. These plans are usually very detailed, and change as additional information develops. Their primary focus is to mitigate potential hazards through “engineering controls” and ensure compliance with appropriate PPE requirements and decontamination procedures.
- Personal Protective Equipment Selection – the criteria for determining PPE is a well-established process. At its most basic, it consists of four levels of protection. Level A consists of Self Contained Breathing Apparatus (SCBA) and completely encapsulating protective suit and gloves. Level B maintains the SCBA and splash suit/gloves, but is not completely encapsulating. Level C drops the SCBA for a protective mask with appropriate filter, with or without Powered Air Purifying Respirator (PAPR), and maintains the splash suit and gloves. Level D is normal attire, basic protective clothing (helmet, boots, gloves, overalls, etc.) with no airway protection, though it may include basic splash protection or chemically resistant gloves. The process for selection assumes Level B as the minimum level for all personnel where the hazardous material is unknown and then adjusts protective posture based on the likelihood of contact with material and the material itself, once identified.[3] The military uses a different system for its personnel. These Mission Oriented Protective Posture (MOPP) levels are postures adopted by personnel based on the assessed likelihood of chemical attack and speed the ability of personnel to achieve a protected status. MOPP levels run 0 through 4. MOPP Level 4, full protective posture, is equivalent to an OSHA Level C. Levels 0 through 3 have no direct OSHA equivalent falling between Level D and Level C. Special military and civilian CBRN teams equipped with SCBA use the Level B and Level A terms when describing protective posture above MOPP 4. These teams may utilize specially designed suits and SCBAs different from those found in the civilian sector, which may offer different levels of protection. They may also use specialized SCBA/PAPR combinations that allow users to switch between Level C and Level B at the flip of a switch without requiring a change of equipment.[4]
- Operations plan – Based on the preliminary evaluation and site safety plan, operations to contain and mitigate the hazard, or carry out cleanup activities in waste operations, are developed. These may be detailed or more general depending on the circumstance. At a minimum, operations plans incorporate downrange operations, “hotzone” designation, air and hazard monitoring, decontamination procedures, and PPE selection criteria for decontamination and downrange personnel (based on the site safety plan). Frequently these plans refer to Standard Operating Procedures for the bulk of their content.
- Decontamination – Decontamination plans are part of the Site Safety plan and are driven by the hazard and the PPE utilized by personnel entering the “hotzone.” The OSHA standard decontamination process for a Level A entry, the highest level of PPE protection is a nineteen-step process (OSHA 2013).
There are additional steps and requirements under OSHA and NFPA guidelines, but the point should be clear that these operations are highly detailed, resource intensive, and focused on responder and public safety, and rightly so. The advantages of this approach include a high degree of risk management and risk mitigation, a measure of caution designed to prevent “expanding” the problem, and a focus on safety that eschews time as a constraint. The obvious downsides for CBRN operations are these very advantages. CBRN operations are frequently very time-limited. By their nature, CRBN operations in military operations, intelligence collection, and other missions, must assume a higher level of risk than would be acceptable in civilian or emergency response situations.
The use of PPE is constrained in many circumstances and CBRN operations frequently require alternative, shortened approaches to decontamination due to CBRN operationally unique circumstances like significant resource and time constraints, kinetic threats (i.e. armed men trying to kill you), or covert or low-footprint actions. You can't quietly enter and exploit a lab behind enemy lines if you set up a nineteen stage decon process and bring in the water trucks to do it. Unlike the traditional emergency response idea of “start high, and then adjust down,” when it comes to personnel protection CBRN operations (like MOPP Levels) often “start low, and adjust up if needed," and use decision based decon alongside go/no-go criteria.
CBRN operations also occur in ways fundamentally different to HazMat operations. A CBRN SSE mission or a technical escort operation will be planned in detail, long before anyone arrives at the scene, if the operation is carried out in a hostile environment. HazMat planning typically occurs on-site, after the 911 call. HazMat gathers information at the scene and it is usually readily available. All it requires is a pair of binoculars to read a number placard or a look at shipping papers. CBRN missions can require complex procedures prior to arriving at a site, i.e. passage of lines, insertion into enemy airspace, secure convoy movement, etc. Entry into a critical facility or suspected CBRN site might require covert or clandestine entry, or even overt, forced entry. HazMat teams don't have to fight their way into a site, killing the enemy as they go. Even the terminology is different: CBRN operations typically have targets while HazMat teams have incidents. CBRN operations often focus on "collects," whereas HazMat focuses on mitigation.
Once at a target, CBRN operations typically act based on the intelligence or other reports that brought them there, until circumstances lead to a reassessment. A HazMat team responds, evaluates, and acts - it is a linear response with a clear beginning, middle, and end. CBRN operations are frequently in a constant state of re-evaluation, an OODA (Observe, Orient, Decide, Act) loop. Such operations can have no end, only new beginnings - discoveries at one target might lead to another target and the process starts all over, or a planned mission may be scrubbed when a no-go criteria is hit, requiring an evacuation and eventual planned return. For instance a team might arrive at a site with only military issued chemical suits and protective masks only to discover that the hazard requires an SCBA.
Further, in CBRN operations, unlike a HazMat incident, the target may not be clear as to its intent or its function. Is it a pharmaceutical plant or a chemical weapons production facility? Is that makeshift lab for making drugs, explosives, or chemical weapons? Are those aluminum tubes for pipes or centrifuges? Who was working here, where did they go, what is their target? Does this production of a dual use chemical feed a chemical weapons program or is it used industrially? HazMat responders don't deal in such questions on a routine basis, and when confronted with them, they are as equally unprepared as CBRN operators are for situations that traditional HazMat response organizations find run of the mill. HazMat is about mitigation and risk reduction. CBRN operations are about targets and identification. One deals in public safety in an immediate sense, the other is about building an intelligence and military operational picture and supporting national security operations.
In the grand scheme of things, the two worlds have a lot to learn from each other, but the entire problem has become muddled by a lack of mission focus in the CBRN community. In our next post, we will look at an alternative approach to CBRN operations that offers increased utility and presents an easily implemented model for CBRN operators that significantly reduces resources and operational footprints, while still mitigating risks and meeting mission goals.
Notes:
[1] Mask filters are not “all inclusive.” Specific filters protect against specific chemicals and only to concentrations below those “immediately dangerous to life and health (IDLH).” IDLH concentrations always require SCBA under OSHA rules. The rules governing filter and mask selection are complex and require a high level of training and knowledge. Military units relying on their protective masks and standard issue military filters do so at great risk, as those are certified to protect against specific known chemical warfare agents and certain other Volatile Organic Compounds (VOC’s) only to specific concentration levels expected to be encountered on the battlefield. Likewise, filter life is dependent on the chemical vapor, the filter used, and the individuals breathing rate. Filters can experience “burn through” in a matter of minutes to hours depending on the specific chemical and its concentration. It is a common misconception in military and intelligence units to view protective masks with standard NATO filters (MCU-2P filters for example) as “all inclusive.” The author has observed units attempting to utilize masks and military JSLIST (MOPP suits) in situations in which they offered no or little protection, including mitigating highly corrosive acids and in oxygen deficient environments. Fortunately, there were no casualties due to the intervention of more knowledgeable personnel.
[2] The Dräger Hybrid System 7000 is one such example. See Dräger Safety AG & Co. http://www.draeger.us/sites/assets/PublishingImages/Products/cre_dhs_hybrid/US/PI-DHS-7000-05-30-12.pdf (April 26, 2013).
[3] Both teams attend the Technical Escort School at Fort Leonard Wood, Missouri and the course includes certification at the NFPA 472 Hazardous Materials Technician level.
[4] HAZWOPER is an acronym for HAardous Waste OPerations and Emergency Response, the title of 29 CFR 1910.120. This is the federal statute that lays out the basic requirements required by federal law for hazardous materials operations and emergency response.
Sources:
103rd Civil Support Team – Weapons of Mass Destruction. 2003. “General Fact Sheet.” November 7. http://c21.maxwell.af.mil/wmd-cst/cst_factsheet_103rd.pdf (April 26, 2013).
Department of Defense. 1998. “DoD Instruction Number 6055.1 : DoD Safety and Occupational Health (SOH) Program.” August 19. www.dtic.mil/whs/directives/corres/pdf/05501p.pdf (April 25, 2013).
Drielak, Steven C. 2004. Hot Zone Forensics: Chemical, Biological, and Radiological Evidence Collection. Springfield, IL: Charles C. Thomas.
National Fire Protection Association. 2008. NFPA 472: Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents. Quincy, MA: National Fire Protection Association.
Noll, Gregory G., Michael S. Hildebrand, James G. Yvorra. 1995. Hazardous Materials: Managing the Incident. 2nd ed. Stillwater, OK: Fire Protection Publications, Oklahoma State University.
Occupational Safety and Health Administration. 2013. “Decontamination.” http://www.osha.gov /SLTC/hazardouswaste/training/decon.html (April 26, 2013).
Sidell, Frederick R., William C. Patrick III, Thomas R. Dashiell, Ken Alibek, Scott Layne. 2002. Jane’s Chem-Bio Handbook. 2nd ed. Alexandria, VA: Jane’s Information Group.
