I agree to Idea Sharing Chemical Safety Information with Medical Facilities
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I disagree to Idea Sharing Chemical Safety Information with Medical Facilities


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Sharing Chemical Safety Information with Medical Facilities

Current federal law requires facilities with significant inventories of hazardous chemicals on site to notify the local fire department of the existence and location of those chemicals. Similarly, local medical facilities should be notified of the storage of significant amounts of toxic chemicals so that they may plan for mass casualty events involving those chemicals.

Submitted by in Jun 2013

Comments (15)

  1. Local fire departments should coordinate this information transfer with county health officials rather than requiring duplicate filings. Fire attack plans and Hazardous Materials Business Emergency Plans include a section with the Material Safety Data Sheets for all hazardous materials, inventories and locations. Business Emergency Plans also include a section that identifies the closest Hospital Emergency room and industrial clinic.
    in Jul 2013
  2. Patrick I like your suggestion but can see the difficulties of implementation. Who would hold the responsibility for notifying the medical facilities and when? A major incident might have up to 6 or 7 transporting agencies, hospitals might divert ambulances when they get overwhelmed with no guarantees that the other hospitals have the information. Perhaps the best solution would be a compromise, create regional data-bases online that the hospitals can tap into. Require the first responders no matter they be fire-EMS-Law Enforcement, to notify all area hospitals who might be expected to accept patients of the incident location and the hospitals can than access the data base before transports begin. Dispatch centers can be the focal point if staffing allows.
    in Jul 2013
    1. pjcoyle Idea Submitter
      JPF1301 - Acatully I was suggesting that local facilities submit MSDS to hospitals/medical authorities before an incident took place. That way the medical community could do some contingency planning for toxic release related mass casualty events.
      in Jul 2013
  3. If a local hospital is interested in the location of facilities with sq of hazmats and what kinds of hazmats are contained in facilities in their area they can request this information from their LEPC. Facilities should already be reporting this information to their LEPC (which local hospitals should be a member of). If a local hospital isn't already involved in their LEPC then it probably has bigger issues to tackle than this.
    in Jul 2013
  4. Here is a wild idea: Read SARA Title III

    Problem solved.
    in Jul 2013
  5. pjcoyle Idea Submitter
    The incident in West, TX demonstrates that the LEPC system has it's own problems. In some communities it works very well, in most not so much, and in way too many there is no LEPC. IHMO in an ideal world the facilities would communicate this information to the local medical treatment community as a matter of self-interest. But this is demonstrably not a perfect world, so a mandate to push this information to the local hospitals is almost certainly the only way that this will happen in most communities.
    in Jul 2013
  6. All parties identified in the planning process used in a jurisdiction’s emergency operations plan need to have agreements in place to ensure that the elements within plans and procedures will be in effect at the time of an incident. The agreements should specify all of the communications systems and platforms through which the parties agree to use or share information. National preparedness is the shared responsibility of our whole community. Every member contributes, including individuals, communities, the private and nonprofit sectors, faith-based organizations, and Federal, State, and local governments. It is not just a problem wioth the LEPC but it takes two parties to an agreement.
    in Jul 2013
  7. If an LEPC either doesn't exist or is dysfunctional in a jurisdiction then it might behoove local hospitals to take the lead and begin building the relationships necessary to move their region forward. That can take a lot of time and if stakeholders don't generally play well together then making it happen may take getting creative. Its necessary however as it takes more stakeholders than just hospitals to respond to a mass casualty incident.
    in Jul 2013
  8. The responsibility for responding to incidents, both natural and manmade, begins at the local level – with individuals and public officials in the county, city, or town affected by the incident. Local leaders and emergency managers prepare their communities to manage incidents locally.Chief Elected or Appointed Official. A mayor, city manager, or county manager, as a jurisdiction’s chief executive officer, is responsible for ensuring the public safety and welfare of the people of that jurisdiction. Specifically, this official provides strategic guidance and resources during preparedness, response, and recovery efforts. Emergency management, including preparation and training for effective response, is a core obligation of local leaders.Chief elected or appointed officials must have a clear understanding of their roles and responsibilities for successful emergency management and response.Emergency Manager. The local emergency manager has the day-to-day authority and responsibility for overseeing emergency management programs and activities. He or she works with chief elected and appointed officials to ensure that there are unified objectives with regard to the jurisdiction’s emergency plans and activities. This role entails coordinating all aspects of a jurisdiction’s capabilities. These issues are controlled by State law and local ordinance.
    in Jul 2013
  9. IDEA INITIAL IMPRESSION: I agreed with the idea (with many caveats), ideally, contingencies and preparation to handle contamination can be very useful, but safety and preparedness activities always involve ”a process” at multiple coordinated levels, and with multiple caveats listed below…COST OF MAINTAINING STOCK IS USUALLY A DETERMINANT FACTOR FOR HOSPITAL CFO’S (federal grants are not discussed herein).
    Example items in stock at a hospital are as per:
    1. A standard list of supplies and equipment,
    2. Contingent upon the programs the hospital can sustain
    3. Items interpreted to be necessary and contingent upon them being cost effective with a viable shelf-life and also (prioritized via regional epidemiology studies).
    4. Public Health consultants make recommendations on the matter, which plays a role in program development and available resources.
    5. Hazards such as those gleaned from the CDC weekly morbidity and mortality reports are usually one of the basis’s for which Emergency Physicians make adjustments to their capabilities (e.g. vaccinations) see: http://www.cdc.gov/mmwr/
    Also, the hospitals would receive their “important MSDS information” late in the development process => and it would be directly from “specialists” or public health experts delegated by the City Emergency Management team, (and not directly from the businesses MSDS).
    BARRIERS: The sheer number of chemical patients and/or materials to consider is going to present a major challenge (if hospitals were to attempt to perfectly mirror chemical danger vectors in the community with remedies). Capabilities, geography, plausibility, feasibility, logistics, and division of labor will need to be assessed prior to hospitals preemptively increasing their inventories to handle potential contamination scenarios (with vectors being items reflective of a businesses MSDS).
    Yes, I believe it is POSSIBLE and PLAUSIBLE for hospitals to compensate for some potential MSDS business MSDS chemical vectors. It would be nice for hospitals to be “in-tune” with businesses that contain chemical/material vectors, =>(that may produce victims) => whom would be sent to their hospital facility.
    However, FEASIBILITY in a large city like (e.g. New Jersey with many factories), this could be challenging to tabulate and maintain the (changing and rotating) inventories such that the Hospital’s “preparation” perfectly mirrors the changing chemical/material inventories of all local manufacturers.
    => Therefore to achieve your goal, your hypothetically (VERY SIMPLIFIED AND IDEALIZED PROGRAM MAJOR LOGISTICAL COMPONENTS) might include:
    1. A “specialist liaison” or Public Health Expert (sent from the city Emergency Manager) who would delegate a team to collect chemical/material information from all businesses within their jurisdiction, then…
    2. “Planners” would consider the city map, hospital, and business (geographic location, proximity, products, resources, capabilities, and programs etc.), then…
    3. A geographic grid would be created and used to allocate potential contamination events to hospitals that are closest and/or can handle a given incident, then…
    4. At some point an initial program is designed (based upon the grid) and an initial Plan would include a final list of who does what and how, with yearly updates (that would approximate changes accordingly), then…
    5. At this point, the “Plan” may advance to the next testing phase and is put into a pilot project, (all stakeholders are informed and will initiate their planning, acquisition, and training). Hospitals and stakeholders will report their progress and be audited to ensure that the allocated hospitals are effective and able to fulfill (the assumed capability) including sustaining all resources and personnel, then…
    6. The “Plan optimization” process begins with drills or exercises, (e.g. Emergency Room staff, fire department and first responder readiness) that will correct all errors and irregularities that may occur within the pilot phase, then…
    7. The program continues to evolve into a semi-permanent final drafted Plan, and Ambulance routes and capacity numbers become factored in.
    8. A mature Finalized Plan is precipitated through many years of trials and exercises that ensure uniform execution and standardized results.
    NOTE: Radioactive contamination and leak contingencies are planned in advance of any facilities becoming operational (this is handled by specialist U.S. Nuclear Regulatory Commissions and potentially DOE entities) who coordinate with Emergency Management and lead the planning process (see links at the end of this comment for details).
    ABOUT THE MSDS INCLUSION TEST: Also, another note about “The specialist liaisons” who would collect MSDS information for Emergency Managers
    =>they would probably have many criteria they use for their decision to include the (chemical MSDS and/or the business) within the potential list of actionable vectors (used to prepare and plan contingencies at local hospitals). Therefore, I could speculate that the “list inclusion criteria” for a chemical/material to be eventually “Planned for” at a hospital, might include: (here are a few examples or caveat’s):
    The MSDS material is included on the list (IF):
    1. (IF) it is a very dangerous chemical (e.g. Nerve gas)
    2. and/or (IF) it is stored in mass quantities (e.g. a breach in the containment unit could result in a massive amount of material exiting the facility and reaching the public)
    3. and/or (IF) the chemical compound did contaminate the public domain, it would overwhelm or delay the typical management systems. (e.g. radioactive materials, whereby, contamination by the item requires pre-planned contingencies and resources are necessary in advance to ensure incidence are managed with special technologies that must be available and functioning prior to an incident).
    4. and/or (IF) an antidote or highly effective treatment exists (and is available for purchase) then it must be ordered in advance, and kept on hand in advance of an incident. (e.g. Bulk Atropine)
    5. Also, obviously, some chemical manufacturing is classified, therefore, the MSDS information can not be made public (at a hospital or otherwise).
    OTHER IMPRESSIONS: We are doing great America! We have come a long way since WW-II, and there is still progress to be made. Here are a few fun lists of items kept on hand on by facilities:
    =>Merchant ships during WW-II:
    =>Modern list of standard equipment available at a couple of (foreign hospitals):
    =>Finally, here is an attempted standard supply list created as an international standard (2001) only one like it I’ve found thus far:
    BASIC CONCLUSIONS: As you can see, from the links above, hospitals may not have specialized treatments for all chemicals, but there are multiple players included in the capabilities decision process. Yes, contingencies need to be made above and beyond standard items as per regional or endemic dangers, and these contingencies may include chemicals at a local business. There is a process (hypothetically demonstrated above) that would need to take place to perfect your IDEA whereby hospitals more accurately can handle chemical contamination (mirroring treatments for chemicals found in local businesses MSDS inventory). CURRENTLY, MANY CONTINGENCIES ARE AVAILABLE AND ON HAND AT REGIONAL HOSPITALS (e.g. snake venom antidote, and individuals trained to handle nuclear contamination, multiple poisoning antidotes and chemical exposure treatments, Et. Al.) Epidemiologists and Public Health officials are carefully studying, updating reports, and meeting with Emergency Managers all over the U.S. to discuss changes as they need to be planned into programs and executed. This is an ongoing process.
    Thank “pjcoyle” you for bringing preparedness for chemical vectors back to my awareness and thought processes!
    P.S. n4aof wrote: “Here is a wild idea: Read SARA Title III Problem solved.”
    I read my own Michigan SARA Title-III for the first time today
    thank you for posting your comment “n4aof”
    FEMA Hazard category called “Technology Hazards Division”
    => http://www.fema.gov/technological-hazards-division-0
    Sub-category “Radiological Emergency Preparedness Program”
    => http://www.fema.gov/radiological-emergency-preparedness-program
    The content of this website contains policy, regulations, coordination, and some other processes that were not included in this thread, but may be of interest to the reader. If you or your organization has in-depth Radiological Emergency Preparedness needs, please see
    1. The 2013 Radiologic Emergency Preparedness Program Manual here => http://www.fema.gov/media-library-data/20130726-1917-25045-9774/2013_rep_program_manual__final2_.pdf
    2. For individuals or groups that live near a nuclear power plant, there is an in-depth information within this guide => http://www.fema.gov/pdf/about/divisions/thd/FEMA-REP-1%20Rev-1%20Supp-4%20Oct%202011.pdf
    3. An Offsite Response Organization for Radiological Emergency Plans and Procedures addressing Hostile Action Based (HAB) events, Tool Kit here => http://www.fema.gov/media-library-data/fb1bbb2f3cd75c7d18da46f2dd2083e4/HAB_REPP_Tool_Kit%20-%20secure.pdf
    4. HHS Radiation Response Plan=> http://www.remm.nlm.gov/responseplan.htm
    5. Improvised Nuclear Device Response and Recovery2013 => http://www.fema.gov/media-library-data/20130726-1919-25045-0618/communicating_in_the_immediate_aftermath__final_june_2013_508_ok.pdf
    6. The CDC Radiation Emergencies Education website => http://www.bt.cdc.gov/radiation/
    in Mar 2014
  10. The basic suggestion of the original poster is that we should have a system in place to do exactly what we already have a system in place to do:

    Under the Emergency Planning and Community Right-to-Know Act (EPCRA), Local Emergency Planning Committees (LEPCs) must develop an emergency response plan, review the plan at least annually, and provide information about chemicals in the community to citizens. Plans are developed by LEPCs with stakeholder participation. There is one LEPC for each of the more than 3,000 designated local emergency planning districts. The LEPC membership must include (at a minimum):
    •Elected state and local officials
    •Police, fire, civil defense, and public health professionals
    •Environment, transportation, and hospital officials
    •Facility representatives
    •Representatives from community groups and the media

    So, we already maintain a list of hazardous chemicals, we already provide that list to hospital personnel, and those hospital personnel are already required by law to work with other stakeholders in the community to plan an appropriate response.

    If the problem is that the people involved are incompetent, I doubt that any new program is going to change that. Likewise, if the problem is that the people involved refuse to follow the law, again I don't see much way to change that.
    in Mar 2014
    1. Thank you "n4aof" for your re-clarification, it is well received and understood (you have stated that the Idea is already in functional use). FYI, your numbers, stats, and lists have been useful to me, and I have taken note.
      My last question would then be=> what is the scale of implementation (e.g. is it every business at every local level reflecting all inventory changes annually)?
      STIPULATION-1 (New acquisition): perhaps, changes should be reflected IMMEDIATELY (rather than annually) in certain new acquisition circumstances =>if a new chemical is brought into a facility that is unlike anything available locally, and meets the hazard reporting criteria. (e.g. if the new chemical is acquired by a factory in January but the annual report is made in December then we are unprotected for ~a year).
      STIPULATION-2 (Transportation Alert Dissemination): With the variety of chemicals being transported across the U.S. (via trucks & tankers) the stakeholders may need to be updated with each new hazardous chemical passing through an area, unless the container meets an exclusion rule (e.g. the truck is equipped with containers that are rated to withstand massive impacts).
      INITIAL IMPRESSION: It will be challenging to keep up-to-date, in reporting, planning, and practicing contingencies.
      Your thoughts?
      in Apr 2014

    To keep the first post short, I did not detail the chemical hazard Stakeholders, but decided to mention a few specifications that relate to the implementation of SARA Title-III:

    => A Facility that handles hazardous chemicals should have an emergency response plan. The National Response Team's Integrated Contingency Plan (ICP) Guidance provides a format for a comprehensive emergency response plan. The stakeholders include national, state, and local entities listed below.

    1. SARA-Title-III establishes requirements regarding emergency planning and "Community Right-to-Know" reporting on hazardous and toxic chemicals. Benefits: These laws are intended to improve chemical safety and protect public health and the environment. Workers, then Police Officers, or Fire fighters could be among the first exposed to a given chemical in the event of a fire, or other event, and therefore benefit from SARA Title-III.

    2. FEDERAL ENTITIES impacting implementation of SARA Title-III:
    =>The U.S. Environmental Protection Agency (EPA): enforces SARA Title III
    => The U.S. Department of Transportation: Road regulations, and other services
    => The U.S. Department of the Interior: Hazard mapping and other services
    => The U.S. Department of Labor: (OSHA), Right to Know, and other services

    3. STATE ENTITIES impacting implementation of SARA Title-III:
    => State Emergency Planning and Community Right-To-Know Commission
    => State Department of State Police
    => State Department of Environmental Quality
    => State Department of Agriculture & Rural Development
    => State Department of Licensing & Regulatory Affairs
    =>COMMISSIONER SPECIFICS: Emergency Planning and Community Right-to-Know Commission (sometimes known as the State Emergency Response Commission - SERC), manage SARA-Title-III implementation in their state.

    NOTE-1: In general, a representative of the State Police Emergency Management Division, oversees the emergency planning requirements in SARA Title III, and is the Chair of the Commissioners who implement SARA-Title-III.

    NOTE-2: The state Department of Environmental Quality handles the major reporting aspects related to SARA Title-III: The vice chair of said commissioners is a representative of the Department of Environmental Quality (DEQ).

    NOTE-3: The Specialists and Liaisons I spoke of are given duties by Commissioners who are appointed by the State Governor.

    4. LOCAL ENTITIES impacting implementation of SARA Title-III: Each City or County has a Local Emergency Planning Committee (LEPC) who will consider how the various aspects of SARA-Title-III pertain to their City or County.

    =>LEPC ROLES: The (LEPC) develops response plans for accidental spills or releases of Extremely Hazardous Substances that threaten the community. In addition, the LEPC must keep information on hand about each site that manufactures, uses, or stores certain quantities of Extremely Hazardous Substances.

    =>REPRESENTATIVES WITHIN (LEPC): Constituents of the LEPC usually include: Elected Officials, Local Police Dept., Local Fire Dept., Local Emergency Management officials, Public Health, Environmental Health, Hospitals, Transportation, Regulated Facilities, various Community Groups, Media, Education, and Agriculture.

    =>FIRST RESPONDERS: First Responders have a "Right to Know" under CERCLA-SARA Title-III (EPCRA), and are important to the implementation process.

    =>HOSPITAL ENTITY SPECIFICS: Briefly stated, hospital representatives from (LEPC) may then discuss how their findings pertain to a given hospital. The given hospitals committees, executives, and chairmen can then ideally develop a plan to both implement SARA Title-III within their hospital chemical storage areas, and develop contingencies related to local businesses. The finalized protocols ideally make their way to directors and staff whose duties involve any aspect affected by chemicals or healthcare as per SARA Title-III.

    =>REPORTING: As Reports are created, this information must be made available to the public. The following are the main agencies who receive the reports:
    …EPCRA Section 302 Extremely Hazardous Substances
    …CERCLA Hazardous Substances
    ...EPCRA Section 313 Toxic Chemicals
    …CAA 112(r) Regulated Chemicals For Accidental Release Prevention

    5. TECHNOLOGY REQUIREMENTS: As we all know, technology platforms & systems make sharing of information easier. Thus, I was looking for a system that would be a win-win for all stakeholders regarding sharing Chemical Hazard information. Canada is utilizing the Workplace Hazardous Materials Information System (WHMIS) which could meet or exceed the capabilities desired. For details, please see:
    =>Information Resource: http://en.wikipedia.org/wiki/WHMIS
    =>Official site: http://www.hc-sc.gc.ca/ewh-semt/occup-travail/whmis-simdut/index-eng.php

    =>CFR SECTIONS: http://www.ecfr.gov/cgi-bin/text-idx?SID=5aaa2030e9733b3f7e1dcac969ed4611&c=ecfr&tpl=/ecfrbrowse/Title40/40cfrv29_02.tpl
    =>FEDERAL REGISTER REPORT: http://www.gpo.gov/fdsys/pkg/FR-2013-11-07/pdf/2013-26475.pdf
    *********Hope this clarification helps*************
    in Mar 2014
    CORRECTION: "A Facility that handles hazardous chemicals should have an emergency response plan". Correct to, A Facility that handles hazardous chemicals is required to have an emergency response plan.[SARA Title III]
    in Apr 2014
    1. Thank you "mjcyranwd6alm" Correction noted and my statement has been adjusted accordingly, (just in time too I intend to post similar information elsewhere soon).
      Also, thank you for posting multiple references throughout Idea Scale, I have been downloading your suggested reading, reviewing them, and utilizing the information to augment my knowledge, update and conform to current practices, and ensure my own posts are as accurate and valid as possible.
      in Apr 2014

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