Challenges Faced During the Environmental Protection Agency's Response to Anthrax and Recommendations for Enhancing Response Capabilities A Lessons Learned Report U.S. Environmental Protection Agency September 2002 ------- Table of Contents Pa«o I executive Summary ii Acronym I .ist , .. ix Chapter 1: Introduction 1 1 Chapter 2: Lessons Learned and Recommendations ,, . 2-1 Chapter 3: Conclusions and Cross-Cutting Recommendations 3-1 Appendix A: Report N'1elliod«>lo.u> A-1 Appendix B: Sample Inien iew Quorums ................ , B-I September 2002 ------- Executive Summary Background This report describes lessons learned and priority recommendations for improvement regarding emergency response to anthrax-related incidents. based on the associated activities conducted by the Environmental Protection Agency (EPA) from October 2001 through February 2002. It reflects the retrospective observations and recommendations of EPA personnel involved in this effort, including front line responders, technical and support personnel, and both headquarters and regional management. In no way should this report be represented as critical of the outstanding performance of many individuals, or the demonstrated effectiveness and capacity of EPA as an organization. The report is intended as constructive feedback to the Agency, from the Agency, on its multifaceted anthrax response, to maximize learning from this unfamiliar challenge in the event of a future, similar attack. During September and October 2001, at least four letters containing a powdered form of anthrax were mailed through the United States Postal Service (USPS), resulting in the presence of anthrax spores at various Congressional office buildings on Capitol Hill in Washington, DC; USPS facilities; and other government and private facilities in several locations nationwide. Beginning in October 2001. EPA responded to the environmental threats created by confirmed and suspected cases of anthrax contamination. EPA personnel demonstrated the ability to develop site management and cleanup plans for an entirely new response scenario involving a biological contaminant. EPA's capabilities and efforts were central to the ultimate success of this unprecedented cleanup. The Agency's resources were mobiti/cd and coordinated using national and regional support, EPA's responses included the three-month anthrax response on Capitol Hill, as well as responses at other federal facilities. Approximately 128 EPA personnel and 54 On-Scene Coordinators fOSCs) came from all 10 EPA regional offices to respond to the anthrax cleanup. In addition to the application of professional emergency response knowledge and skill to unfamiliar challenges, EPA personnel devoted extraordinarily long hours to difficult and stressful work. From October 2001 through February 2002, EPA responders worked with other agencies and organizations to ensure the protection of public health and the environment, as well as the continued operations of the U.S. Government. This report captures lessons learned and cross-cutting recommendations in the following area categories: Authorities; Operations; Communications and Coordination; Health and Safety; and Resources, -ii- September 2002 ------- Executive Summary (continued) Study initiation EPA Administrator Christine Todd Whitman charged Assistant Administrator Marianne Lament Horinko. Office of Solid Waste and Emergency Response (OSWER). to chair an effort to draw out lessons learned from the wide- ranging activities m which EPA was engaged following the terrorist attacks oi September 1 I, 2001. Due in part to the relevance of an initial report. Lessons Learned in the Aftermath of September J1. 2001. developed by EP.-Vs Office of Emergency and Remedial Response (OERR), this lessons learned report. Challenges Faced During the Environmental Protection Agency 's Response to A nth rax and Recommendations for Enhancing Response Capabilities, was commissioned on March 6, 2002. Goals for the studv In any response of this magnitude, lessons learned will assist EPA in responding to future incidents. EPA views this report as an opportunity to learn from the experiences of its personnel. The goals of this report are as follows: 1. Document the major actions taken by EPA; 2. Identify the key accomplishments as related to significant advancement of the science and technology of detecting and remediating anthrax, as well as define areas where enhanced capabilities are most desirable; and 3. Develop lessons learned and present recommendations for meeting the challenges ahead in the areas of emergency preparedness and counter- terrorism response. A focused study based on extensive interviews of (i7 individuals was conducted between March 6, 2002. and April 30, 2002. Interviewees were representative of headquarters arid regional management, OSC's, other respondcrs. and personnel at ail levels who were involved with all aspects of EPA s anthrax-related activities between October 2001 and Fcbruarv 2002, Interviewees were asked to describe and assess their organization's anthrax response activities and capabilities, arid to answer questions with respect to HPA's authorities; operations; internal and external communications; health and safely; and resources during the response. Lessons learned jjlc information and assessments provided through interviews were examined to document actions, establish patterns and themes across different perspectives, identify lessons learned, develop specific recommendations, and "hi- September 2002 ------- Executive Summary (continued) finally formulate overarching "cross-cutting" recommendations Lessons learned are grouped in the following five area categories: Authorities; Operations; Communications and Coordination; Health and Safety; and Resources, f ross-cuttin« Alter evaluating the lessons learned, she most .significant and broad-reading recommend a- issues were identified as overarching challenges that span the previously ,ons identified area categories, and used to develop cross-cutting recommendations that encompass the lessons described in Chapter 2, Key steps in implementing the cross-cutting recommendations are further specified m Chapter 3, Although the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) provide authority to respond to biological incidents, the NCP does not include a response plan for such incidents, and the Federal Response Plan (FRP) was not activated to coordinate the agencies involved in the response to anthrax on Capitol Hill. A number of jurisdictional issues were raised during EPA's responses to the anthrax incidents regarding constitutional; statutory and regulator}-; contractual, and non-CEKCLA authorities. Lessons learned in this area include: Questions about lines of authority could potentially complicate or delay a response to an incident on property under the control of the legislative or judicial branches of the federal government. In the absence of FRP activation, there is no clear structure defining the interaction of the various federal agencies that may be involved in a large-scale response The non-traditional response structure under which EPA was operating at Capitol Hill did not make the best use of EPA's experience and established procedures, resulting in defining roles and responsibilities "on the fly." Cross-cutting recommendation: Revisit and revise, as needed, EPA's existing internal emergent*) response coordination authority, plans, and structures. Operation*. The anthrax incidents occurred while EPA's response at the World Trade Center and the Pentagon were ongoing. There were thousands of anthrax incidents, scares, and hoaxes nationwide. EPA regions responded to many -iv- September 2002 ------- Executive Summary (continued) incidents, most of which were false alarms. The operating environment wa>, in the opinion of responders. "unlike any previous operating environment" that EPA had faced. Although response personnel effectively solved the problems they faced, EPA was not fuilv prepared to scale up its efforts to the magnitude required for the anthrax cleanup, and did not have sufficient technical information or procedural guidelines at hand. Lessons learned in this area include: Use of a clearly defined and fully implemented command structure would have enabled more efficient management of a complex, national-scale response involving multiple agencies. Obtaining adequate expertise in the operational technicalities associated with responding to anthrax contamination or other biological agents would enhance planning efficiencies and the timeliness of response. Finding and testing the most efficient response methods, and their costs, for dealing with anthrax contamination would enable expeditious selection of disinfection approaches. Cross-cutting recommendations: Enhance capability to scale up emergency response efficiently, and develop specialized response skills for unfamiliar threats. Develop, with the Office of Homeland Security, a response coordination structure to be followed in a multi-federal agency response for which the FRP is not activated. Communications Coordination between organizations and creating a structure for sharing and coordination information is critical, as is ensuring interagency familiarity with each others' roles, responsibilities and capabilities. Many of the communication processes worked well, such as the use of cellular phones between OSCs and other key responders; daily conference calls; wntten daily updates of site activities; community outreach; and frequent press conferences and updates to Congress. However, a more ^>stematic approach to on-site communications was needed. Although a central planning and support section was in operation for interagency coordination, greater familiarity with its existence and functions would improve coordination among responders. -v September 2002 ------- Executive Summary (continued) Lessons learned in this area include: A more centralized process for tracking sue personnel, activities, and progress toward completion at the Capitol Hill response would enhance coordination among EPA staff, and thereby improve the efficiency of the response. Implementing a traditional Incident Command System-Unified Command (lCS-'L'C) structure would include a Joint Information Center for future responses of this magnitude. Using EPA's established systems for inter-office coordination, such as the National Incident Coordination Team and the Regional Incident Coordination Team (RICT), would help plan for emergency response situations. Deployment of hPA's Emergency Communications and Outreach Team (ECC)T) can provide additional support to the regional community involvement staff. Cross-cutting recommendation Elevate the priority of emergency communications structures and capacity, and implement existing communications programs developed for emergency responses. Health and At the time of the response. EPA had no standard mode or protocols for safety addressing the special health and safety concerns associated with the release of a biological agent such as anthrax. As a result. EPA relied on expertise and information from other organizations, and the approaches to health and safety changed and evolved during this response. While a Health and Safety Plan was available and accessible to all responders on site, some responders observed that more information should have been available in the plan to specifically address reconnaissance safety. The availability of useful, accurate scientific information for a response to anthrax in a civilian environment was limited and anthrax-related information front other health agencies was not initially as useful as EPA had anticipated. In the initial days of the response, the lack of scientific data about anthrax limited EPA's decision-making abilities regarding operational issues such as personal protective equipment (PPE). On-site medical support is another health and safety issue reviewed in this report. EPA should examine medical policies, regulations, and laws that to ensure that EPA will have adequate and continuous medical support at the beginning of a future large-scale response. September 2002 ------- Executive Summary (continued) Lessons learned in this area include: There is a need lor faster and greater access to better interagency (both civilian and military) information on potential biological weapons of mass destruction (WMD), and for providing a clear understanding of exposure risks and correct prophylactic treatments available to protect responders from exposure. CPA's traditional approach to health and safety must be revisited when responding to biological agents such as anthrax. Clear guidance on PPE levels for biohazard responses must be established. Special care must be taken to address sudden changes in field procedures while operations are underway, including re-training, to avoid the potential for human error affecting safety and health. Cross-cutting recommendation: Enhance safeguards to ensure that responder health and safety is given precedence among competing priorities, especially in a multi-agency led response. The anthrax response was unprecedented in terms of the amount of resources needed by EPA to accomplish its mission safely and effectively, EPA was well prepared and trained for an emergency response, but not well trained or prepared to handle the unfamiliar and unique aspects of a biohazard, or specifically, anthrax response. As observed by the front-line responders. resource availability proved to be multidimensional, affecting the conduct of operations, communications, and health and safety issues. In addition, the mechanisms typically used by EPA to obtain resources had to be exercised and interpreted in ways not previously used by EPA in an emergency response Lessons learned in this area include: There is a need for having a mechanism, procedure, or source of funding in place to provide financial support for the magnitude of an emergency response when the FRP had not been activated. A more traditional command structure, such as the ICS. can manage resources more effectively. vii- September 2002 ------- Executive Summary (continued) EPA's standard response contracts did not provide for the staffing needs for biological emergencies. There were times when there were no! enough qualified contractors available to conduct specialized work. EPA does not have an inventory of equipment needed to sample microbial agents or to perform disinfection. It also does not have a database of possible sources of equipment as it does for chemical responses. Adequate supplies of PPE must be provided for the OSCs. Cross-cutting recommendations Acquire equipment. lab capacity, funding and trained personnel sufficient to support EPA's role in responding to biological agents and other WMD. Improve response capability and develop in-house expertise in biological agents and other WMD. EPA considers the anthrax cleanup a success. Using the Agency's well-tested problem so I vim: approach to emergencies. EPA met and resolved the following challenges, Cleaned up the anthrax on Capitol Hill efficiently and safely, while having to adapt and operate within a command structure that used new approaches to organizing an emergency response. EPA worked within the established command structure facilitating the management of its response activities and personnel while also communicating and coordinating effectively with the other agencies and organizations. EPA responders had only limited technical information and experience for cleaning up biological contaminants. Despite these challenges. EPA was able to implement a plan of action based on sound science. * EPA, along with others, worked to access the technical and medical expertise necessary to identify appropriate health and safety procedures, and implement safeguards for the biological response. - V111- Scptember 2002 ------- Acronym List AA Assistant Administrator AMI .American Media, inc. BCR Biological, Chemical, or Radiological CDC Centers for Disease Control and Prevention CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CID Criminal Investigation Division ClOC Community Involvement and Outreach Center DA Deputy Administrator DoD U.S. Department of Defense ECOT Emergency Communications and Outreach Team hoc Emergency Operations Center EPA U.S. Environmental Protection Agency ERT Environmental Response Team FBI Federal Bureau of Investigation 1" FMA Federal Linereeney Management Agency PR? Federal Response Plan GSA General Services Administration HASP Health and Safety Plan HHS U.S. Department of Health and Human Services IC Incident Commander Incident Command ICS Incident Command System JiC Joint Information Center NCP National Oil and Hazardous Substances Pollution Comtngene\ flan NICT National Incident Coordination Team NIIMS National Interagency Incident Management System NIOSH National Institute of Occupational Safety and Health N'RS National Response System NRT National Response Team OERR Office of Emergency anil Remedial Response September 2002 ------- Acronym List (continued) OGC Office of General Counsel OPA Office of Public Affairs OPC Oil Program Center OPPTS Office of Pollution Prevention unci Toxic Substances OSC On-Scene Coordinator OSWER Office of Solid Waste and Emergency Response FDD Presidential Decision Directive PPE Personal Protective Equipment RA Regional Administrator RICT Regional Incident Coordination Team RPM Remedial Project Manager UC Unified Command USAMRUD United States Army Medical Research Institute of Infectious Diseases USCG United States Coast Guard USFHS United Slates Public Health Service USPS United States Postal Service WML) Weapons of Mass Destruction -X- September 2002 ------- Chapter 1 Introduction Overview The Challenge, For more than 30 years, the Environmental Protection Agency's (EPA) The Response, emergency response actions have reduced risks to public health and the A Program of environment. EPA stands ready 24 hours a day to respond quiekiy whenever hazardous substances are released. Action Every day across the country, a dedicated staff of On-Scene Coordinators (OSCs) conduct and direct emergency responses. During the anthrax cleanup on Capitol Hill, dozens of OSCs came together to apply their expertise to an unknown situation involving a biological contaminant. As a result, human health was protected. This historical response demonstrated the ability of OSCs to adapt to uncertain situations and apply their knowledge of science in meeting the challenges of anthrax. Within days of the response to Capitol Hill. OSCs worked m partnership with other agencies and organizations to manage site activities. They also worked on designing a plan for sampling and cleaning up the anthrax. The unprecedented level of coordination, communication and teamwork was the key to the success of the response. Additionally, OSCs provided daily briefings to Congress while ensuring that the surrounding community was kept informed of the cleanup activities, and for the next three months, OSCs worked to ensure a safe and expeditious cleanup. In orchestrating a response of this magnitude. EPA effectively used its problem-solving skills and applied sound science to the cleanup. This report records a program in action and reflects EPA's commitment to conducting effective responses and meeting our mission of protecting human health and the environment, Need for this Although EPA's response to anthrax is considered an overall success, it is rePorl important 10 draw lessons learned from the Agency's technical and oversight activities following the detection of anthrax contamination at several locations across the United Slates. Although efforts to strengthen counter-terrorism and disaster preparedness have been ongoing for several years within the parameters of available resources, all responding programs and regions were challenged by the extensive demands of responding lo the first large-scale incident of anthrax contamination in the United States. Res ponders faced an intense and mounting workload and new technical demands, in addition to ihe 1-1 September 2002 ------- Overview (continued) emotional and physical stress related to the extreme hazards and the realization that several civilian fatalities were associated with the anthrax exposure. The challenge was compounded by ongoing criminal hoaxes and false alarms involving anthrax contamination. This report follows an initial lessons learned report, completed on Februan I. 2002, Lessons Learned in the Aftermath of September 1 /. 200!. The Cross- Cutting Issues identified in Chapter 3 of this report may share similarities with those identified tn the initial report. The first anthrax incidents took place in the weeks following the attacks on the World Trade Center and the PemagoTi, where EPA was still involved m response activities. There was no time lapse between trie two phenomenally large responses in which lessons could be drawn from one response and effectively applied to the next. Similarities in findings should, therefore, not be seen as representative of an inabiiitv to implement recommendations, but rather reinforce their relevance as overarching issues to be addressed by EPA in preparation for future large- scale response activities. l-r«cncy for this The nation remains m a heightened state of alert, with an immediate need to rePort apply these lessons learned. FPA is committed to responding to emergency situations with increased quality, speed, and comprehensive action. The more quickly lessons can be gathered and learned after such events, the more quickly HPA can apply them both to an ongoing response and to the Agency's long-term counter-terrorism strategy. The unprecedented nature of the anthrax incidents has raised the nation's awareness of the potential for terrorism using chemical or biological weapons. This awareness highlights the need for EPA to be well prepared for new and unusual chemical or biological threats, and to be able to respond during national-scale emergencies. While this report focuses on actions taken in response to the threat of anthrax, it also notes EPA's more general need to strengthen capabilities to address the consequences of biological, chemical, or radiological (BCR) threats, and to enhance preparedness for potential terrorist attacks using weapons of mass destruction (WMDs). This report focuses on the actions taken by EPA in response to confirmed or suspected cases of anthrax contamination at various Congressional office buildings on Capitol Hill, U.S. Postal Sendee (USPS) facilities, and other government and private facilities since October 2001. However, lessons learned from these responses that are applicable to other types of BCR incidents are mentioned. 1-2 September 2002 ------- Overview (continued) what does this This chapter includes die following information: chapter u'ntjin- Report Purpose Report Methodology Events Pnor to EPA Involvement EPA's Role in Responding to Anthrax Contamination Activities and Conditions at Major Response Sices Content Overview 1-3 September 2002 ------- Report Purpose Intent in any response of this magnitude, lessons learned will assist EPA in responding to future incidents. However, the purpose of this report is not to undermine or question the effectiveness of the Agency's response lo the anthrax incidents. I:PA is proud of the efforts of its personnel, and views thi^ report as an opportunity to learn from their experience. Goals for the The goals of the study efforts culminating in this report are as follows: study » Document the major actions taken by I:PA; » Identify the kev accomplishments as related to significant advancement oi the science and technology of detecting and remediating anthrax, as well as define areas where enhanced capabilities are most desirable; and Develop lessons learned and presem recommendations for meeting the challenges ahead in the areas of emergency preparedness and counter- terrorism response. 1-4 September 2002 ------- Report Methodology Gathering the A focused study based on extensive interviews ol"67 indn iduaK wa> information conducted between March 6, 2002, and April 30, 2002, Interviewees involved in various facets of EPA's anthrax response were selected from across I.PA. from both headquarters and regional organizations. Respondents were asked to describe and assess their organization's anthrax response activities and capabilities, and to answer questions with respect to EPA\s authorities; operations: internal and external communications; health and safety: and resources during the response. Stuch initiation I-PA Administrator Christine Todd Whitman charged Assistant Administrator Marianne Lament Horinko, Office of Solid Waste and Emergency Response lOSWER}, to chair an effort to draw lessons learned from EPA activities following the events of September 11, 2001. Due in part to the relevance of an initial report, 1.assorts Learned in the Aftermath of September 11, 2001, developed by Office of Emergency and Remedial Response (OERR). this lessons learned report. Challenges Faced During the Environmental protection Agencv's Response to Anthrax and Recommendation- for Enhancing Response Capabilities, was commissioned on March 6, 2(102 Information EPA offices were asked to identify a cross-section of individuals involved collection and with all aspects of EPA "s anthrax-related activ ities between October 2001 and analysis February 2002. Individuals were representative of headquarters and regional management, OSC's. other responders, and personnel at all levels. The process for this effort, based on information collected from these respondents, is shown in the diagram below. Development of Recommendations Recommendations Conclusions ana 7 Ctsss-Cur-ig Re5e-t7wr>;lsr,o»*j 6? Inter/tews wtn Tia^agenen! ar.i !(&>!-'ne wsoine: Iran 10 Regions and HQ 1-5 September 2002 ------- Report Methodology (continued) The information and assessments provided through interviews were examined to document actions, establish patterns and themes across different perspectives, identify lessons learned, and develop overarching "cross- cutting" recommendations. A more detailed description of the methodology is presented in Appendix A. Data collected During the course of the interviews, managers and personnel from EPA offices and regions described the following: Actions taken Authorities activated Organizational decision-making Operational environments Preparedness levels Communication successes and challenges Coordination with outside entities Methods of information exchange Health and safety measures Available resources Tools used for maintaining essential operations Overall successes and challenges of the response Based on their firsthand know ledge, interviewees rated their satisfaction with bPA's ability to respond to the anthrax incidents in terms of five major areas: Authority Operations Communications and coordination Health and safety Resources Finally, respondents listed up to five of the greatest challenges they felt the Agency faced in responding to anthrax contamination. See Appendix B for example questionnaires. 1-6 September 2002 ------- Events Prior to EPA Involvement Background Bacillus anthrcicis, commonly known as anthrax, is a naturally occurring spore-forming bacterium that causes acute infectious disease that is potentially fatal m humans. Occasionally, anthrax is found in some hooted mammals and. in rare cases, infects people working closely with such animals or animal products. Prior to September 200], anthrax had not been released in this country as a terrorist weapon, and much is still unknown about the properties of lab-produced anthrax spores. No anthrax cleanup of this scale had ever been attempted, and no registered antimicrobial agents were approved for civilian use against anthrax prior to October 2001. The logistics and engineering of decontaminating large areas within buildings had to be developed quickly, with limited knowledge about anthrax risk levels or the effectiveness of anthrax detection, cleanup, and disposal methods. Anthrax-laced Dunne September and October 2001, at least tour letters containing a letters caused powdered form of anthrax were mailed through the USPS. The first such contamination letter wa> received bv American Media, inc. < AMI) in Boca Raton, Florida on or around September 25, 2001. The contamination was discovered after one employee died of inhalation anthrax on October 5, 2001. and another was sickened.. ami outbreak Other anthrax-contaminated letters were received in October at NBC News in New York, and at U.S. Senator Torn Daschle's office in the Hart Senate Office Building in Washington, DC. Contamination of the Brentwood Post Office in Washington, DC was discovered after two workers died of inhalation anthrax, and several others were .sickened. New cases of inhalation and cutaneous anthrax emerged in October and November 2001, in New York. New Jersey, and Connecticut. Another contaminated letter, addressed to Senator Patrick Leahy, was later found m an off-site government mail facility. The presence of anthrax spores was discovered at various other locations, including a maiiroom at ABC News in New York; in New York .Mayor Giuliani's office; in New York Governor Pataki's offices; in New York City Hall, the New York Post; and in various postal facilities in New York. Washington DC. New Jersey. Connecticut. Florida. North Carolina, Indiana, and Missouri. In the greater Washington, DC area, anthrax spores were identified at a number of federal government facilities, predominantly m mail areas, including at the Department of State, the Department of Justice, the Supreme Court, the Department of Health and Human Services (I IMS), the Department of Defense iDoDl. the Department of Treasury, and other departments. Additional anthrax contamination was detected at the ford and 1-7 Sc-ptembei 2002 ------- Events Prior to EPA Involvement (continued) Longworth House Office Buildings and in a warehouse on P Street NW, on Capitol Hill, The scientific and medical information available to rcsponders at the time I ncrramttieij when the contaminated letters were initially heim: identified indicated that and unknown worker* in the poslxil facilities where the letters were proceed were not a: risk of infection. When postal workers at several facilities became ill, and two from the Brentwood Post Office subsequently died of inhalation anthrax, the limitations of existing knowledge to calculate the risks associated with this anthrax tragically became evident. risks A number of postal workers and other mail handlers at various locations became infected, and it is still unconfirmed how two individuals, who died of inhalation anthrax (a hospital worker in New York and an elderly woman in Connecticut), were exposed. National impact Five individuals died of inhalation anthrax in Florida, New York. Washington, of anthrax DC. and Connecticut m the first known cases in the United States in over 20 contamination years. In total, 22 actual eases of the inhalation or cutaneous forms ol anthrax were diagnosed, in addition to numerous confirmed exposures. Approximately 10,000 potentially exposed people were tested and treated with prophylactic regimens of antibiotics. Widespread alarm over the fatalities and concent about the safety of the mail resulted in many thousands of reports nationwide of suspicious substances requiring investigation. False alarms and hoaxes nationwide placed a significant dram on resources needed to conduct emergency response. Cross-contamination of mail now appears to have caused the spread of anthrax spores to some postal facilities that did not process the actuu; spore- con taming envelopes, increasing the geographic scope of the incidents and heightening uncertainties about the magnitude of the responses that would be required. 1-8 September 2002 ------- EPA's Role in Responding to Anthrax Contamination Protection of health and environment EPA is one of the chief guardians of public health and the environment in the United Slates. In any large-scale environmental emergency, EPA coordinates with local and state first responders. In the ease of anthrax contamination, EPA provided technical expertise and oversight in detection and ensured that the cleanup was fully protective of public health and the environment at both government and privately owned facilities, EPA's Technology Innovation Office led efforts to collect and disseminate information to appropriate entities on technologies that detect and kill anthrax. Currently, EPA is pursuing the development of additional procedures to handle bioterrorism, including procedures for decontamination and disposal, and improved coordinating mechanisms. EPA responded to the recent anthrax incidents as part of a larger National Response System (NRS) that has been in place for nearly 30 years to effectively deal with a wide range of environmental emergencies. EPA is the lead agency for Hazardous Materials Response under Emergency Support function ¦? 10 of the Federal Response Plan (FRP), and is also assigned to assist the Federal Emergency Management Agency tFEMA) during consequence management, with environmental monitoring, decontamination, and long-term site cleanup. Under the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). National Response Team (NRTi member agencies engage in response efforts to environmental threats, as set forth in the FRP. The NRT was activated on October 2lJ, 2001. Generally, in planning efforts for responses to terrorism, the FRP provides the coordinating mechanism for a NRT response. However, there was never a Presidential declaration of a national disaster; therefore, the FRP was not activated. Nevertheless, most NRT agencies were involved in some wa\ m the response to anthrax as a pollutant or contaminant under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLAl. The following NRT member agencies were involved in anthrax response activities* Environmental Protection Agency « Federal Emergency Management Agency United States Coast Guard Department of State Department of Health and Human Services » Department of Justice General Services Administration Department of Defense 1-9 September 2002 ------- EPA's Role in Responding to Anthrax Contamination (continued) Because certain anthrax-contaminated sites were determined to be crime scenes, it was important for EPA to coordinate with the Federal Bureau of Investigation (PBI). DoD was involved in providing expertise ;n hio-\\capons analysis, for human health advice. EPA sought support from HHS, in addition to National institute of Occupational Safetv and Health (NlOSiit. Centers lor Disease Control and Prevention (CDC ], U.S. Public Health Service s (LSPHS) Division ofl-edcral Occupational Health, and Agcncv for Toxic Substances and Disease Registry. Because the maii was used as the method ol anthrax delivery, USPS was another prtmarv response agenc\ w:ih which EPA coordinated. Technical ]-p,\ provided technical consultation and advice if requested bv a federal expertise and agency conducting an anthrax remo\ul action, oversight EPA response activities ai anthrax sites included the following. Sampling to confirm and determine the extent of contamination; Evaluating sampling results; Isolating areas to prevent the spread of contamination; Removing critical objects for special decontamination procedures; Working with the USPS and other agencies to evaluate the effectiveness of potential disinfectants and cleanup technologies; and Cleaning up areas of contamination. In a short time, EPA significantly advanced the science and technology of detecting and remediating anthrax. Prior to October 2001, no antimicrobial pesticides had been approved for use against anthrax. Several different chemicals and devices were initially tested and used under carefully controlled conditions. Chlorine dioxide Ethylene oxide Bleach Paraformaldehyde Development of new methods and technologies 1-10 September 2002 ------- EPA's Role in Responding to Anthrax Contamination (continued) Additional chemicals tested later included hydrogen peroxide, pcroxyacetie acid, and methyl bromide. Anthrax decontamination is a rapidly evolving field, and new technologies are now being tested and advanced continually. The EPA Office of Pollution Prevention and Toxic Substances (OPPTS) is responsible for ensuring that antimicrobial pesticides used in anthrax decontamination plans meet all federal requirements for safety and effectiveness. In developing decontamination strategies. EPA consulted a variety of experts, including the following: I-PA's Environmental Response Team (ERT) ¦ EPA research laboratories NIOSH CDC U.S. Armv Medical Research Institute of Infectious Diseases (USAMRHD) « Defense Advance Research Projects Agency State and local environmental and health officials » National experts in universities and private industry Counter- Several Presidential Decision Directives (PDIX) under the NRS specif) a role terrorism role for EPA m counter-terrorism activities. PDD 39 assigned EPA the task of assisting the FBI during crisis management in threat assessments and determining the type of hazards associated with releases or potential releases of materials in a terrorist incident. In addition to the activity generated by testing and cleaning, the anthrax-contaminated sites were also treated as crime scenes EPA's Criminal Investigation Division ICID) worked closely with the FBI and local and state law enforcement agencies. CID assisted the FBI in gathering evidence for use in identifying the criminals responsible for the terrorist attacks. PDD 62 reinforces EPA's mission to enhance the nation's capabilities to respond to terrorist events, and gives EPA responsibility for cleaning up buildings and other sites contaminated by chemical or biological agents as a result of a terrorist act. The primary response agencies for incidents resulting from a terrorist event under PDDs 39 and 62 are the following: September 2002 ------- EPA's Role in Responding to Anthrax Contamination (continued) Environmental Protection Agency * Federal Bureau of Investigation/ Department of Justice Federal Emergency Management Agency Department of I.i tie ray Department of Defense Department of Health and Human Services 1-12 September 2002 ------- Activities and Conditions at Major Response Sites Overall EPA j j»a responded io both ;ictual and potential releases of anthrax !ndi\ hIuli; response to departments, agencies, and private companies performed sampling and anthrax ^ cleanup to the extent of their capabilities, with EPA providing assistance as emergencies appropriate. If initial sampling results by local authorities, CDC, or others indicated the presence of anthrax, more comprehensive sampling was undertaken with assistance from EPA to assess the extent and severity of contamination. EPA provided expert technical advice to facility managers throughout the country on sampling plans, worker safety, and actual site cleanup methods. In general, most situations were relatively simple to stabilize. If it was an emergency response, the situation was quickly stabilized to a non-emergency response. Steps were taken to isolate the contaminated area, and potentially exposed people were placed on prophylactic antibiotics. (W ashington. DC) Capitol Hill I: PA provided massive technical support and assistance as part of a nmlti- facilities agency effort in response to anthrax contamination discovered in Congressional buildings in the Capitol Complex. Using CERCLA authority, EPA was able to write action memos to authorize EPA funds for the cleanup.. EPA responders reported to an Incident Commander (IO under the Capitol Police Board, working in conjunction with the Congressional Offices of the Architect of the Capitol, and of the Senate and House Sergeants at Arms. The U.S. Coast Guard fUSCCi) Atlantic Strike Team Commander supported the IC as Deput\ Incident Commander Strike Team personnel established and staffed an Incident Command structure and provided logistical assistance to EPA.. After anthrax spores were detected in the letter opened m Senator Daschle's office in the Hart Senate Office Building, several areas of the building were immediately evacuated and closed. Two days later, the entire Hart Building and the House of Representatives were closed because of health and safety concerns. The immediate threat to the United States government's Legislative Branch resulted in extensive sampling of Capitol Hill buildings and testing of staff for exposure, EPA emergency responders took thousands of samples to determine the presence of anthrax, and to design and carry out site-specific cleanup strategics where contamination was found, Positive results indicating the presence of anthrax spores were found at the Ford and Long worth House Office Buildings, the Hart and Dirksen Senate Office Buildings, and the P Street Mail Warehouse cm Capitol Hill. Once a decision was made to decontaminate a building, EPA advised the IC about the extern to which a building must be cleaned to make it safe. 1-13 September 2002 ------- Activities and Conditions at Major Response Sites (continued) By far, ihe cieanup of the Hart Building posed the largesi and most extensive anthrax cleanup challenge ever undertaken in a building The Hart Binidmg is a 10,000,000 cubic foot building that houses the offices and staffs of 50 senators. Pol lowing the initial discover,', further contamination was detected on the J1", 5:\ 6:\ and floors of the building, as well as m fillers w ithin a regional heating, ventilation, air conditioning, and cooling system. Fumigation with chlorine dioxide gas was conducted on December I and on December 30. 2001. Approximately 100,000 cubic feet of the Hart Building were sealed prior to i'umigation. Further fumigation was performed in the air handling system that serves that area. Several other suites and common areas in the Hart Building and in other buildings in the Capitol Complex were cleaned using chlorine dioxide liquid, Sandia foam, and high efficiency particulate air filter vacuuming. Post-cleanup sampling showed no remaining viable anthrax, and on January 22, 2002. the Hart Building was cleared for reoccupancy. liPA has pro\ided USPS with technical expertise and advice in the cleanup of contaminated USPS facilities. EPA was requested by USPS to provide full- time OSC presence at the USPS command center, which was established at USPS headquarters at L'Enfant Plaza in Washington, DC, for consolidation of information and coordination. Postal facilities in HPA Regions 1. 2. 3. 4, 5, and 7 were altected, including the following facilities: l.S. Postal Service facilities Boca Raton main postal facility, Boca Raton, PL Green Acres postal facility. Lake Worth, PL Lucerne Station postal facility. Lake Worth. FI Lake Worth main postal facility. Lake Worth, FL West Palm Beach postal * facility. West Palm Beach, FL Blue Lakes postal facility, Boca Raton, PL Morgan postal facility. New York, NY Brentwood mail processing facility, Washington, DC Hamilton postal facility, Hamilton, NJ West Trenton postal facility, Trenton. NJ USPS Westgate Processing and Distribution Center. Raleigh, NC USPS Postal Distribution Center. Wallingford. CT DDD Building (USPS Contractor), Indianapolis, IN USPS Stamp Fulfillment Center. Kansas City, MO 1-14 September 2002 ------- Activities and Conditions at Major Response Sites (continued) The deaths of two workers at the Brentwood Post Office, and the serious illnesses of two others, alerted authorities to the presence of anthrax spores at the Washington, DC facility where two anthrax contaminated letters were processed. The facility was closed on October 2L 2001, and remains closed at this time. Decontamination of the facility using chlorine dioxide fumigation will require sealing 17.5 million cubic feet. The successful decontamination of the Hart Building is being used as a blueprint, although the much larger scale of the Brentwood facility will require logistical adjustments. An EPA OSC has remained on site at the Brentwood postal facility since October 2001. providing technical assistance, and serving as a technical liaison with the USPS Command Center, EPA GSCs have provided consultation during the various USPS sampling operations, and cleanups conducted during the past months, and EPA continues to assist IJ8PS in ongoing anthrax cleanup efforts. I'PA has facilitated the creation of a National Coordination Council, a working group composed of NRT member agencies and USPS, to involve USPS with NRT and its creation of the Technical Assistance Document on Anthrax Response. EPA is preparing a Memorandum of Understanding with USPS that will formalize the relationship between USPS and EPA for anthrax response*, and will provide a model for future interagency cooperation. P.PA provided technical support and assistance to a number of other federal agencies with anthrax-contaminated facilities. For federal agencies f other than the Department of Energy and Dot)). EPA collaborated with the Government Services Administration (GSA) to develop a list of environmental contractors who were awarded GSA indefinite quantity contracts tu sample for anthrax and perform remediation, A Region 3 OSC was assigned to monitor the progress of the removal and remediation operations being conducted by federal agencies other than USPS in the greater Washington, DC area. EPA collected data from each response, including: health and safety standards and procedures; sampling and analysis methods; remediation and treatment methods and technologies: and waste disposal procedures. In an emergency situation. EPA ma\ conduct removal operations if the affected agency i> incapable of performing the necessary actions. The following federal agencies continued positive anthrax hits at one tit more of their facilities: I-utilities of oilier ft*fk-r;s! aycncit". September 2002 ------- Activities and Conditions at Major Response Sites (continued) Department of Justice * « Department oi''Slate Bureau of Alcohol, Tobacco and Firearms I) l* pa rtme n t o f A gri cult u re « Veterans Administration * Central Intelligence Agency Corporation of National Service* Federal Bureau of Prisons National Aeronautics and Space Administration Defense Intelligence Agency Federal Aviation Administration (Dulles Airport) General Services Administration AMI and On or around September 25, 2001, a letter containing a powdery substance private facilities was received and handled by several employees at the Sun offices of the AMI building tn Boca Raton. Florida. The serious health and safety implications to the employees in the building were not realized until October 5, 2001, when one employee died of inhalation anthrax. Initially considered a health issue by CDC, the site was quickly declared an FBI crime scene. The FBI released control of AMI to EPA on October 20, 2001. FBI provided data analyzed by CDC, and the information was used by EPA ERT and operations team personnel to develop a site specific sampling plan. EPA and the Florida Health Department secured laboratory resources of the L SAMRIID. Of 278 samples collected from the AMI building, 32 samples indicated positive results. EPA also oversees private-sector sampling and clean-up efforts when requested by local, state, or other federal agencies, such as the FBI. EPA provided assistance in varying capacities to several privately-owned facilities in Florida and New York, and to privately owned facilities of USP'S contractors in Missouri and Indiana. Hoaxes and Responding to false alarms and hoaxes with all necessary precautions diverted false alarms valuable resources from other responses, Of the many thousands of reports of suspected anthrax contamination received nationwide during the months of the ongoing responses, the vast majority were false alarms, including a number of pranks and criminal hoaxes. Most false alarms, however, were due to public fear (of white powders) rather than intentional hoaxes. The number of calls declined as response activities progressed, in part because dispatch centers became more adept at screening calls, and in pan due to a better educated public as additional guidance was released. 1-16 September 2002 ------- Activities and Conditions at Major Response Sites (continued) False alarms occurred in all EPA regions, and the regions worked with state arid local authorities to ensure the protection of public health and the environment Because of the extreme hazards associated with anthrax contamination, reports were treated seriously and investigated by state and local authorities, with EPA consultation and assistance where appropriate. 1-17 September 2002 ------- Content Overview Time period This report is inclusive of EPA anthrax response activities conducted from October 2001 through February 2002. No major new anthrax contamination lias occurred since November 2001. However, several sites remain contaminated and sealed to date, and scattered hoaxes and false alarms continue nationwide. Report The report is organized as follows: structure « Executive Summary Acronym List Chapter L Introduction Chapter 2: Lessons Learned and Recommendations Chapter 3: Conclusions and Cross-Cutting Recommendations » Appendix A: Report Methodology Appendix B; Sample Interview Questions Lessons learned Lessons learned are grouped in the following five categories: Authorities Operations Communications and coordination Health and safety- Resources To enhance clarity, lessons are framed in the following format: Lessons learned Recommendations Cross-cutting After evaluating the above lessons, the most significant and broad-reaching rccommcnda- issues were identified as overarching challenges that span the previously described area categories. These issues are intended to encompass the more specific icsM_>n> addressed in Chapter 2. tioris Conclusions and action items The report concludes that EPA is at a crossroads in the scope of its mission. Lessons learned indicate that to effectively respond to environmental hazards associated with large-scale biological or terrorist emergencies, commensurate resources and organizational support must be available to EPA. 1-18 September 2002 ------- Chapter 2 Lessons Learned and Recommendations Overview Chapter 2 presents the lessons learned that were drawn from the observations of the interviewees. Corresponding recommendations were either taken directly from the responses of interviewees or developed from their observations. In this chapter Topic See Page Authority Mul si-Branch of Federal Government Issue Multi-Agency Interaction CF.RCLA and the NCP Contractual Authority EPA Non-CERCLA Aulhority 2-3 Operations Command Structure Technical Issues Preparedness Intra- and Interagency Support 2-6 Communications and Coordination -¦ Internal EPA On-site Communications Communication among Regions, Headquarters, and Sites 2-9 Communications and Coordination ¦- External Interagency Coordination with the Incident Command Structure Public Information Dissemination and Community Involvement 11 Health and Safety External Factors Evolving Internal Procedures 2-13 2-1 September 2002 ------- Overview (continued) Topic Sec Page Resources 2-16 funding Resources Personnel Resources Training Resources Equipment Resources September 2D02 ------- Authority A number of jurisdictional issues were raised during EPA's responses to anthrax releases and suspected releases concerning EPA's constitutional, statutory and regulator}', and contractual authorities, Muii j-Br anch of Federal Government Although the response on Capitol Hill may itself have been a unique situation, questions about lines of authority could potentially complicate or delay a response if an incident were to occur on property under the control of the other branches of the federal government, legislative or judicial, such as the Supreme Court, issue: Lesson learned Recommenda- tion OSWER, in conjunction with executive branch respcmders and appropriate representatives of the legislative and judicial branches, should reach agreement on future responses at legislative and judicial branch sites. Legal and regulatory issues should be addressed en route to this agreement. .Multi-;i»enc> interaction: Lessons learned Tile FRP was not activated to respond to Capitol Hill and did not provide the structure for a response involving all the various federal agencies The N'CP is available in the absence of an FRP activation. At the anthrax response in Florida, the NCP was used to guide the response EPA was not operating under a traditional response structure and the structure thai was chosen did not make best use of EPA's experience and established procedures, resulting in defining roles and responsibilities "on the fly." Recommend Recommend using already established response structures available turns during a muln-agency response when the FRP is not activated, including defined roles and responsibilities. Determine who will be accountable for the cleanup m non-1 HP imiltt- ageney responses. 2-3 September 2002 ------- Authority (continued) CERCLA and the NCP: Lesson learned Although CERCLA provides authority to respond to biological incidents, the NCP is not specific about cleanup methods for such incidents. Recommtn lu tion Contractual Authority: Lessons learned Revise the NCP to address specific cleanup methods for biological agents, such as anthrax. FPA's current authority to indemnity response contractors could delay cleanup in future responses where the agency may need flexibility to implement innovative cleanup methods using contract resources. lo be effective in carrying out their responsibilities, non-lead region OSCs involved in a large-scale response must be able, at least on an ernergenev basis, to direct contractors. Recommenda- tions EPA Non- CERCLA Authority: L ess oris learned Work to acquire expanded indemnification authority, similar to that of PL MA and DoD, to implement existing federal law that would enable the EPA to more readily provide contractor indemnification when necessarv during unique emergency circumstances. Develop a contractual mechanism that gives non-lead region OSCs deliver.' order project officer authority to direct contractors Remediation oi contamination that requires the use of unusual substances or methods may require emergency exemptions from other EPA program areas. However, it is important to note that federal OSCs leading a response do not have to get permits for on-site work, per CERCLA. Responders need knowledge of, and access to, the expertise and rcsoua all EPA program offices. Recommenda- tions To the extent possible, anticipate and develop a process for acquiring other emergency exemptions thai ma\ he required for biological. chemical, radiological, and nuclear response activities, and work with the appropriate offices to implement these processes. 2-4 September 2002 ------- Authority (continued) Ensure that the capabilities, authorities, and resources of all EPA program offices are known and available to resporiders. 2-5 September 2002 ------- Operations The anthrax incidents occurred while EPA's response at the World Trade Center was ongoing. There were thousands of anthrax incidents, scares, and hoaxes nationwide. EPA regions responded to many incidents, most of which were false alarms The operating environment was, in the opinion of responders, "unlike any previous operating environment" that EPA had faced. Command Structure: Lesson learned Complex, national-scale responses involving multiple agencies are not managed most effectively in the absence of a clearly defined and fully implemented command structure. Some responders observed that the command structure at Capitol Hill was unfamiliar with federal response authorities. In other, similar responses, the 1C would be a Federal OSC. In this ease, the 1C was a private consultant hired by the Capitol Hill Police- Board and was not initially familiar with the role of the Federal OSC under the NCP. Recommenda- tions Implement a clearly defined and scalable command structure, such as the Incident Command System (ICS), based on the National Interagency Incident Management System (NIIMS). All EPA OSCs will be trained in the ICS by December 200?. Evaluate using a separate ICS for each site in a multi-site response. Ensure that training includes exercises in which OSCs from across the regions participate together to strengthen teamwork. Shared operational responsibilities among OSCs worked well on Capitol Hill. The lead OSC was effective in responding to the press and Congress, while managing overall site activities. Some responders observed that more resources should be available to help support the OSCs in this area. For future nationally significant responses, use a more formal ICS with Unified Command (UC). Technical Issues: Lessons learned Adequate expertise was not available in the operational technicalities associated with responding to anthrax contamination, or other biological agents. Because there were no established protocols for responding let anthrax contamination or other biological agents, extensive time and resources were devoted to the processes of searching for candidate methods, coordinating logistics, implementing untried procedures, and assessing the efficacy of candidate methods 2-6 September 2002 ------- Operations (continued) Without a comprehensive comparison of candidate methods for dealing with the anthrax contamination and their costs, EPA and contractors may not be able to use the most efficient response methods. turns Rcvommenda- . Develop response teams trained for specific incident types, for example. three to four people specialized in biological agents. To facilitate inter- regional cooperation and support, develop cross-regional consistency and evaluation of skill sets, similar to the USCG Strike Team's qualification process. A standby list of qualified OSCs and responders (and state resources) should be available for crisis situations. Identity and conduct research on potential contaminants for which vulnerabilities exist, and develop processes for characterizing site contamination. Develop biostatisueal or other models for demonstrating when cleanup levels have been achieved. Conduct interagency research to evaluate potential decontamination technologies, their scientific bases, and cost effectiveness, Evaluate processes for decontamination of personal property. Document and record the information developed to respond to anthrax incidents, including best practices, protocols, technologies used at the various sites, and identify the pros and cons of using them. Ensure that future responders can access this information, and evaluate plans for an electronic "field book." to be expanded to address other potential incident types. PrrpartiJuvs.s: Lesson learned Although the response personnel did a good job of .solving the problems they faced. EPA was not fully prepared to scale up its efforts to the magnitude required of the anthrax cleanup, and did no! have sufficient technical information or procedural guidelines at hand. Rei-ommcntia- Develop tools, protocols, and procedures required to respond to releases l'ons of biological agents based on EPA's experience responding to anthrax Develop and conduct response exercises geared toward other potential terrorist scenarios in cooperation with other EPA program offices and appropriate outside agencies, 2-7 September 2002 ------- Operations (continued) Intra-and Interagency Support: Lesson learned Review the regional preparedness resources to determine whether they can he shared with, or expanded across EPA regions. Support provided to responders from other EPA entities and external agencies and departments varied in quality and consistency. Recommenda- tion Work with counterparts in other agencies to define roles, assess capabilities, and develop the necessary technical resources and knowledge to respond to biological or unconventional contaminants. 2-8 September 2002 ------- Communications and Coordination - Internal EPA Because of the politically sensitive environment and strong pressure for a fast response to the Capitol Hill cleanup, internal and external communications were critical to implementing an effective response. Many of the communication processes worked well, such as the use of cellular phono between OSCs and other key responders; daily conference calls: written daily updates of site activities; and frequent press conferences and updates to Congress, In other responses of this magnitude. EPA would also consider implementing a traditional ICS UC structure that would include a Joint Information Center (JIC). On-Site Co mm link a- ti°ns: A more systematic approach to internal on-site communication* was needed. A more centralized process for tracking site personnel activities, and progress Lessons learned toward completion at the Capitol Hill sites would have enhanced coordination among EPA staff, and thereby improved the efficiency of the response. To maintain up-to-date information across all components of the response operation. EPA should look into securing more telecommunications equipment for on-site responders. Implement the communications and coordination processes of the ICS for large-scale responses, and ensure that all responders are fully trained in ICS. Clear protocols should be established for standard operating procedures in responses that require coordination with federal legislative authorities, or tn politically sensitive situations. Work with the EPA Office of Congressional and Intergovernmental Relations to help develop protocols. Some responders observed that security concerns, such as reporting confidential information critical to a criminal investigation, prohibited normal documentation of site activities. A recommendation was made to develop appropriate reporting alternatives to satisfy both the need tu share information, and to preserve sensitive information Ra ommenda- lions 2-9 September 2002 ------- Communications and Coordination - Internal EPA (continued) Communication amon« Regions, Headquarters, and Sites: Lesson learned Use of EPA "s established systems for inter-office coordination, such as the National Incident Coordination Team (N1CT). and the Regions! Incident Coordination Team (RICT), would have made better use of EPA's prior planning efforts for emergency response situations and coordination within the Agency. Recommenda- tions Maintain a formal, written communications plan that details the processes tor internal coordination among various offices that may be called upon to support responses of political sensitivity and national .security. Revitalize and ensure the use of EPA's existing communications and coordination structures such as NIC'T and RICT. Assume that the NRT and Regional Response Team functions under the NCP are prepared to facilitate national and regional intcr-agencv coordination respectively, through enhanced planning, training, and exercising. 2-10 September 2002 ------- Communications and Coordination - External Keeping the press and public updated throughout the anthrax cleanup on Capitol Hill and at other facilities was a key priority for EPA. At Capitol Hill the U.S. Capitol Police Board elected a spokesperson who held regular press conferences. The lead OSC participated in the press conferences and kept members of Congress updated on progress. An effort was also made to implement CPA's normal community involvement activities for emergency responses. Lessons learned reflect the need to implement a more formal communication structure, such as a JIC. typically used tor responses of this magnitude. Lessons learned also reflect a need to have proper on-site communications equipment and resources. Inter agency Conrdinatjun w Although a central planning and support station was in operation, greater familiarity with its existence, roles, and functions, would improve coordination amonu respondent and thereby increase the efficiency of Structure: ,, - * response el I oris. Lesions learned Coordination between organizations is critical. Knowing each others* roles, responsibilities, and capabilities in addressing environmental contaminants, and creating a structure for sharing information is critical Rt'( iirnntenda- liurts Work with partner agencies 10 clearly define functional and organizational roles, and improve understanding between agencies potentially involved in coordinated response actn ities, Elevate the priority of emergency communication1; *>t rue Hires and capacities, and ensure fall training m, and implementation of. existing programs developed for emergency response. Public Information Dissemination and Commw nm Invohiment. /.ovw Icurui'd In most responses of this size, a JIC is a standard communications structure within a I'C and is used by EPA lo coordinate information, and to ensure that public information was disseminated to all interested parties. In multi-junsdictional responses, EPA would normally work with all organizations to implement emergency communications and implement existing outreach programs developed for emergency responses. 2-11 September 2002 ------- Communications and Coordination - External (continued) Recommenda- . Work with key agencies and organizations to ensure the establishment of lions a JiC. Implement Superfund's standard external communications programs for emergency responses. Continue to deploy the Fmergeney Communications and Outreach Team (ECOT) m support of regions during long-term responses Provide communicators with appropriate communications resources, such as mobile telephones, communications-ready laptop^, printers, and fax machines. 2-12 Septe nber 2002 ------- Health and Safety In an emergency response, EPA's paramount responsibility is the protection of health and safety of humans and the environment, EPA's health and safety experience primarily involves responses to hazardous materials. EPA has no standard mode or protocols for addressing the special health and safety concerns associated with the release of a biological agent, such as anthrax. As a result. EPA re bed on expertise and information from other organizations, and the approaches to health and safety changed and evolved during this response. Although the U.S. government has sponsored anthrax research for several decades, the av ailability of useful, accurate scientific information for a response to anthrax in a civilian environment is limited. Anthrax-related information from other health agencies was not initially as useful as EPA had anticipated. In the initial phases, there was no organized system that EPA responders could use to locate the available technologies, capabilities, and facilities in either civilian or government agencies that ma> have been useful in the anthrax response. This lack of access to all of the available, relevant scientific data limited EPA's decision-making regarding operational issues such as personal protective equipment (PPE). For example, in the first few days of the response, information such as spore size data was not yet available to EPA. Once the 1C was set up, and EPA began coordinating with other agencies who had better information about anthrax and spore si/e, the necessary data became available and was shared with the responders. Medical support on site is another key health and safety issue reviewed m this report. EPA should examine the medical policies, regulations, and laws that played a roie in providing adequate medical support at the site. This may involve working with the DoD Directorate of \1iiit3ry Support office, the USPHS as well as other agencies, and EPA's Office of Administration and Resources Management, to ensure that E'PA will have the ability to access adequate and continuous medical support at the beginning of a future large- scale response. External I-";u-K»rs. EPA responders need access to all available information related to the health Lessons learned and safety aspects of an anthrax response. EPA needs faster and greater access to better interagency (both civilian and military) information on potential biological WMD EPA's traditional Hazardous Waste Operations and Emergency Response approach to health and safety {based on chemical hazards j needs to be 2-13 September 2002 ------- Health and Safety (continued) Recommenda- tion Kvolving Internal Procedures: Lessons learned revisited when responding to biological agents such as anthrax. Additionally, clear guides on PPE levels for biohazard responses need to be established. Work with health authorities, such as IMS. to produce medical and responder guidance on all potential biological threats. A health and safety plan was available and accessible to all responders on- site. All responders were directed to review the plan as soon as they entered the command post. Some responders observed that more information should be available in the plan that specifically addresses reconnaissance safetv. Because there were no clearly established protocols for anthrax, there was some concern among the responders. especially during the first month of the response, Responders need a clear understanding of exposure, correct prophylactics, and location of contamination when they report to duty on site. Responders from Region 5, where more extensive counter-terrorism training and drills had occurred, were very helpful in using their training experience to assist Region 3 in responding to biological agents. Responders need to be in good health and fitness, and need confidence sn the adequacy of their medical monitoring. ERT and some (but not all) regions have special arrangements facilitating gym memberships for exercise. Responders need sufficient levels of PPE to protect them without hampering the response. Mid-course changes in field procedures without sufficient clarification and re- training were a concern among some responders because of the potential for human error, safety, and health issues. Recommendm- "om * Establish and maintain proper health and safety precautions. EPA should have sound health and safety protocols for biological contaminants that have been reviewed by experts in the medical field. Test and assess effectiveness of PPE against biological agents to determine level of protection offered by existing Pl'H. Response 2-14 September 2002 ------- Health and Safety (continued) personnel must be protected and prepared with the appropriate equipment and medication (i.e.. prophylactic antibiotics). Resolve any liability issues involved with the prescription of medical drugs Tor uses considered to be investigative. Speciflcaliv. the CDC" offered site workers an anthrax vaccine that had not yet been tested for the accelerated regimen sue workers would have to take. For site workers to accept the accelerated vaccine regimen. C'DC required them to sign a liability waiver. Develop medical protocols for determining the risk to human health posed by biological contaminants. Support the convening of a Health and Safety Advisorv committee to address pertinent issues, and plan for future events and possible scenarios. Develop a medical surveillance monitoring and provision program for OSts subject to bio.-counter-ierrorism activities; the current program is proven only for chemicals. Develop in each region a team that deals with health and safetv with available doctors to .support the Site Satetv Otiicer ior WMD incidents, and other issues as they arise. LPA should develop in-house medical expertise, and establish a medical monitoring team for biohazards. Unsure proper training of personnel lo deal with anthrax and other bioiogicals; regions may need to have a response team readv for these types of incidents. Re-evaluate long-standing shortfalls in the Core l;mergenc\ Response program regarding responder health and fitness for duty, and support responders in maintaining their physical fitness 2-15 September 2002 ------- Resources The anthrax response was unprecedented in terms of the amount of resource?, needed by EPA to accomplish its mission safely and e fleet i vet v. As observed by the iront-lme responders. availability of resources proved to be multidimensional, overlapping with operations, communications, and health and safety issues. In addition, the mechanisms typicallv used bv EPA to obtain resources had to be exercised and interpreted in wavs not previously used by EPA in an emergency response. Without established protocols for a biohazard response or a cost comparison of candidate methods. EPA and contractors repeatedly consumed valuable resources in scare hum for methods, coordinating logistics, implementing untried procedures, assessing the eificacy of candidate methods, and at times repeating the process, if the methodology did not work. This section specifically addresses resource issues dealing with funding. personnel, training, and equipment. Funding Resources: EPA did not have a mechanism, procedure, or source of funding in place to Lesson learned fmancialk support this magnitude of an emergency response for winch the FRP had not been activated. Be able to respond and obtain resources quickly to alleviate the restrictions on funding and contracts, and depletion of mission funds. Explore with others how funds could be made available in a non-declared disaster. Maintain someone with authority to be on call to answer questions, make funding decisions, and obtain resources quickly. Appropriate administrative support to supplement the OSC's 5250K response spending ceiling and limited contract officer authority is needed on site. Use resources obtained by EPA to fill gaps in equipment, personnel, and contractor support. Personnel Rt'soiircts: L ^ Because of the unfamiliar command structure, and the unique circumstances earne of a response of the magnitude, EPA was not always in control of its resources, personnel workload, response schedule, or working conditions. A more traditional command structure, such as the ICS. would have helped manage resources more formally. 2-16 September 2002 ------- Resources (continued) Valuable information for response continuity f shift-to-shift and day-to-day) was lost because the command structure did not establish a clear procedure for transferring information through the use of log books, rotation reports, ami pollution reports that would normally be used in other, similar responses EPA's standard response contracts did not provide for the staffing needs fur biological emergencies, There were times when there were not enough qualified contractors available to conduct specialized work. Insufficient contractor staff with accepted security clearance hindered the response effort. Recommenda- tions Maintain Agency control over its work load planning so that resources can be appropriately scheduled. Determine way*. for regions to support their ongoing programs while sustaining a long-term response effort. Similar to the USPHS, EPA may consider the use of a volunteer service as backup, to respond to concurrent regional emergency events when regular personnel may be on- scene at a nationally significant response. Review EPA's process for acquiring qualified contract personnel to access contractors that match the specifications of jobs EPA needs to have done. This must include technical and medical experts m the area of bioierrorism who can be on-site as needed. Work with other response agencies to ensure, ahead of time, that IIP A security clearances for contract personnel are recognized in order for EPA response contractors to gain access to critical response information. Depbv adequate medical staff on-site to monitor the health of responders. Resources: Lesson learned EPA was well prepared and trained for an emergency response, but not well trained or prepared to handle the unfamiliar and unique aspects of a btohazard, or specifically, anthrax response. 2-17 September 2002 ------- Resources (continued) Provide more training for responding to a biological incident to OSCs, and ERT. While it may be unrealistic to focus the training on all possible biological agents, training should address responses to the most probable agents and the range of threat characteristics. Before training can occur, however, adequate protocols for dealing with biohazard remediation must be developed and implemented. Coordinate interagency training to ensure broad familiarity with KPA's capabilities in emergency response. Provide OSCs with ICS training and certification. Tram teams of OSCs intensively in specialized response efforts, and enable them to act as technical advisors when the response is larger than the team can handle. Tram remedial project managers (RPMs) and site assessment managers as back-up for OSCs so they can temporarily maintain continuity of ongoing removal actions on-eall if OSCs are responding to national emergency situations. Provide additional staff exercises for emergency operations, specifically regarding emergencies of a biological nature Lquipnivnt Kovntirircs: f,csM>/is learned The lack of real-lime analyses, compounded by the lack ol cleanup levels, hindered response. EPA docs not have an inventory of the equipment needed lo sample microbial agents or to perform disinfection. It also does not have a database of possible sources of equipment as it does for chemical responses- Planning of health and safety resources had not included mechanisms to procure antibiotics or prophylactics for responders or the appropriate PPE needed during the disinfection stage of the operation. OSCs should have access to their own PPE: they should not have to "dram up" PPl: at the beginning of each shift ot borrow it from other agencies, Responders need adequate, reliable communications resources, September 2002 ------- Resources (continued) Recommenda- . Provide responders with access to an on-site lab for the testing and tinns analysis of samples for "real time" emergency response. A nationwide network of laboratory capacity for microbial testing, including adequate in-house capabilities, needs to be provided. Establish an emergency inventor)' of the equipment and protocols needed to respond to bioterronsrn, including state resources, or at least a database of sources of the needed equipment and protocols. Provide responder with access to a sufficient amount of equipment to minimize reuse and to address all activities that would compromise worker health and safety regardless of the PPE level chosen. Maintain a minimum communications infrastructure for example, two- way radio capability cell phones and full-time network computers are tools that can he implemented quickly. The use of remote television capability should be explored. 2-19 September 2002 ------- Chapter 3 Conclusions and Cross-Cutting Recommendations Conclusions Using nioiv lhan 3d years of experience in responding to hazardous subMance releases. EPA planned, tested, and implemented the first ever cleanup of several large, anthrax-contaminated buildings in a mailer of three months, while responding to other anihrax incidents and hoaxes, and continuing activities at the World Trade Center. j |owevcri f-.PA's current challenge is evident. Managing adequate reMHirccs in terms of personnel, funding, equipment, and training, to meet the evolving requirements of its counter-terrorism role are all issues that must be addressed to maintain the level of commitment EPA has in protecting human health and the environment. If EPA is to continue responding to large-scale incidents requiring muhi- agencv involvement, it must take actions to surmount these challenges before another incident occurs. The cross-cutting recommendations and supporting steps identified in Chapter 3 of this report were designed to meet these challenges, EPA considers the anthrax cleanup a success. Using the Agency's well-tested problem solving approach to emergencies, EPA met and resolved the following challenges: EPA was able to clean up the anthrax on Capitol Hill efficiently and safely, while having to adapt and operate within a command structure that used new approaches to organizing an emergency response. Because of the circumstances and location of the anthrax response on Capitol Hill, EFA worked within the established command structure facilitating the management of its response activities and personnel, while also communicating and coordinating effectively with the other agencies and organizations. Although highly trained and experienced in bazatdous substance responses. EPA respondcrs had only limited technical information and experience for cleaning up biological contaminants. Despite these challenges. EPA was able to implement a plan of action based on sound science. 3-1 September 2002 ------- Conclusions (continued) * Betore cleanup activities could begin. EPA, along with others, worked to access the technical and medical expertise necessary to identic appropriate health and safety procedures, and implement safeguards for the biological response. Alter evaluating the lessons learned and interviewees' recommendations, the most significant issues were identilied as overarching challenges that "cut across at least lour of the iive area categories of focus: authorities, operations, communications, health and safety, and resources. Sev en recommendations addressing these challenges encompass the more specific recommendations described m Chapter 2. hnhance capability to efficiently scale up emergency response, and develop specialized response skills for unfamiliar threats. Steps to enhance scale up capabilities include (he fallowing: F.nsure that EPA responders are familiar with and well trained m a standardized ICS as an internal response management structure (such as the ICS MUMS). Define the scope of EPA's and other agencies' roles, responsibilities, capabilities, and authorities prior to the initiation of major response activities, and ensure that each is understood clearly by HP A respond ^ contractors, and personnel from partner agencies. Establish a J1C to help lead OSCs with the public/external relations and political interaction Junctions in a large-scale response in order to protect the response management role of the lead OSC. Develop and implement an agency-wide coordination plan lo best use support staff and resources from across the regions when needed. Provide a coordination structure for staff rotation in a large-scale response, and minimize impact on ongoing programs. Develop a database that includes available EPA. contractor, and local/state expertise m order to match the best available resources So specialized response needs. In this chapter Recommenda- tion #1 3-2 September 2002 ------- Conclusions (continued) Recommenda- Develop, with the Office of Homeland Security, a response coordination twn structure to be followed in a multi-federal agency response to a terrorist incident for which the FRP is not activated. Such an interagency coordination structure must: » involve liPA leadership working with counterparts in other agencies or departments to clearly define roles and responsibilities in a non-FRP multi-federal agency response. Institute periodic interagency emergency response training and exercises to ensure preparedness and mutual familiarity with EPA and other agencies' roles, responsibilities, and capabilities, Plan with the FBI and other law enforcement agencies for scenarios involving concurrent crisis and consequence management. Hnsure appropriate interagency cooperation on evidence gathering and health and safety protocols ior cases in which investigation and emergency response must occur simultaneously. Resolve funding and cost recovery issues m the absence of the declaration of a national emergency under the FRP. Recommenda- Improve response capability and develop in-house expertise on biological tum M agents and other WMD. Steps to improve response capabilities for biological agents and WhiD include the following: Coordinate closely with other federal agencies. Research biological agents for which potential threat of terrorist or criminal contamination exists, and identify and develop a database for technologies and methods for detection, sampling, and cleanup. Identify nationwide resources and a capacity for sampling and analysis of biological and new or unconventional agents, including the development of interagency and public-private networks (e.g., with CDC. FBI. DoD, universities and/or commercial labs, etc.), to facilitate sharing of best available science and laboratory resources in emergency responses. Document all relevant data developed m responding to anthrax incidents for use in developing protocols for responding to biological agents or 3-3 September 2002 ------- Conclusions (continued) WMD, including appropriate procedures for site characterization and risk assessment. Develop and train response teams for specific emergency scenarios (e.g.. 3-4 people specialized in biological agents). Training should involve an evaluation of skill sets thai is consistent across regions (similar to USCG Strike Teams' qualification process) 10 facilitate cross-regional cooperation. Knhunce safeguards to L-uiurt that responder health and safety is jjivon precedence among competing priorities, especially in niul{i-a»enc> led responses. Steps to safeguard respander health and safety include the following: Support the efforts of a recently convened Health and Safety Advisory Committee to address unfamiliar health and safety issues associated with responding to biological or unconventional agents, « Establish and enforce clear limits on hours spent by on-site personnel in high stress or high risk capacities. Take steps to safeguard the ability of EPA personnel to make hazard level determinations and appropriate health and safety decisions independently of external pressures or deadlines. Examine current response contracts to resolve funding to cover the costs of contractor medical monitoring and health needs, including physicals, blood work and other lab tests, vaccines, antibiotics, etc. Ensure timely reimbursement of contractor's out-of-pocket medical expenses where appropriate, Monitor research on efficacy and long term effects of prophylactic antibiotics against biological agents. Monitor and, where appropriate, conduct followup studies, especially on responders treated with prophylactic antibiotics for extended periods of tune. Expand the routine Medical Monitoring Program to address health issues specific to biological agents, and ensure that responders undergo pre- entry and post-exposure medical testing for pathogens or biotoxinv Rt'ctnumcnda - tion *r4 3-4 September 2002 ------- Conclusions (continued) Reaimmenda- Revisit, and revise as needed, F.PA's existing internal emergency response li'mi coordination authority, plans, and structures. A it ions to update existing plans and structures include the following- Revitalize and then ensure the use of EPA's existing intern;)! communications and coordination structures, specifically the N'ICT and RJCT. which reflect prior planning efforts for inter-office coordination during emergency response.-, Clarify the role of ERT personnel as Science Support Coordinators to OSCs, to make best tree of ERT expertise. Ensure that the special capabilities. authorities, and resources of all EPA program offices are known and available to responders. Clarify jurisdictional issues with regard to EPA's emergency response authority at a site under the control of the legislative or judicial branches. Recommeiula- Hievate priori!) of emergency communications structures am! capacity, uon fib atKj implement existing communications programs developed for emergency responses. Steps to strengthen the effectiveness of emergency communications include the following: Implement the Superfund's required community involvement activities and best practices for emergency response communications. Required activities include implementation of a robust community involvement program; establishment of a JIC; development of a communications strategy; and deployment of the ECOT. Work with key agencies and organizations to recommend establishing a JIC for all major responses to coordinate external communications, and ensure that information is available and communicated to the press and the public. Ensure that OSCs and Community Involvement Managers are aware of and able to deploy ECOT when long term communications support ts needed throughout a response. 3-5 September 2002 ------- Conclusions (continued) Work with EPA's Office of Public Affairs fOPA) to develop national guidance on media policies during emergency responses of national significance. The guidance would be used to help OERR develop the appropriate information needed for OP A to disseminate information to the public from a national forum. Acquire equipment, lab capacity, funding and trained personnel sufficient to support tPA's role in responding to biological agent1. uiui other WMD. Steps to secure adequate response resources include the following: Identify and seek dedicated funding for advancing counter-terrorism efforts, commensurate with EPA's counter-terrorism role Invest in enhanced field and lab analytical capacity for sampling and analysis of new agents, equipment needed to perform appropriate decontamination, and specialized PPE. Develop interagency and public private networks to maximize available resources. Develop and provide training m emergency response to btohazards and other WMD. and in the operation of multi-agency responses. Provide training to OSl's in management skills needed for large-scale responses as well as for working effectively as part of a team. Review existing contracts to determine how- best to acquire expertise for biobazard and WMD responses. Establish contract mechanisms to adequately indemnify contractors and to provide non-lead region OSCs emergency authority to direct contractors. Acquire and maintain adequate emergency communications infrastructure and electronic equipment, including fully equipped laptop computers, two-way radio cell phones, fax machines, and remote closed-circuit television capacity. Recommenda- tion H ~ 3-6 September 2002 ------- Appendix A Report Methodology A-l ------- Appendix A Report Methodology Introduction EPA Administrator Christine Todd Whitman charged Assistant Administrator, Marianne Lament Horinko. OSWER, to chair an effort to draw lessons learned from the wide-ranging EPA activities following the events of September 1J. The resulting report. Lessons Learned in the Aftermath of September 11, 2001, developed by OERK, was released on February 1. 2002, Due in part to the relevance of the initial report, this second lessons learned report was commissioned on March 6, 2002, to address challenges faced during EPA's activities in responding to nationwide anthrax from October 2001 to February 2002, and to propose recommendations for enhancing response capabilities in the future. Process The process for this effort involved the following steps: Request names of EPA personnel representing a cross-section of individuals involved with all aspects of EPA's anthrax related activities from EPA offices. Conduct interviews, of identified EPA personnel regarding key aspects of actions taken and experience responding to anthrax, Synthesize raw data from interviews and identify common themes, perspectives, and patterns. Develop lessons learned for major response aspects; operations, authorities, health and safety, communications, and resources. Collaborate to identify cross-cutting issues and overarching recommendations which encompass several, or all of the major response categories. Develop first draft of lessons learned report. Circulate first draft to Assistant Administrators (AAs), Regional Administrators (RAst. and contributing interviewees for feedback. Review comments from AAs, RAs. and contributing interviewees, and incorporate additions or edits where appropriate. Present final Anthrax, Lessons Learned to EPA Administrator, A-2 September 2002 ------- Report Methodology (continued) Data collection tor this study was designed to solicit input tor the time period following the initial identification of anthrax contamination at the AMI Building in Boca Raton, Florida on September 25. 2001, to include anthrax response activities through February. 2002. The greatest intensity of EPA activity over a duration of time, however, was from October ];>, 200] when anthrax contamination was confirmed in the Hart Senate Office Building, until January 22, 2002 when the building was cleared for reoccupancy. It was also during this period that other Congressional buildings were sampled and cleaned, and that the vast majority of anthrax cross-contamination was discovered in other federal and postal facilities, and mail rooms in several states. Time periods of interest Information information for this study was gathered from the following sources: sources » Sixty-seven interviews with EPA personnel, representing input from all EPA regions and headquarters, including responders and EPA management at all levels. (All regions responded to anthrax contamination either in the region, or by contributing rotational personnel in support ol the Region 3 Capitol Hill response.) Other resources such as internal reports, summaries of events, and documentation from the Emergency Operations Center (HOC), including the following: > Meeting and conference call summaries from Capitol Hill and Regional responses Press releases Situation, Incident, and Pollution Reports (where existing) ~ FPA regional offices' lessons learned * External groups' lesions learned reports A-3 September 2002 ------- Report Methodology (continued) ORGANIZATION TITLK, OR I-TNOTION SFRVKD IN ANTHRAX RESPONSE ACTIVITIES Upper Management 1. HQ Administrator 2. HQ Special Assistant for Homeland Security 3. HQ Deputy Administrator (DA) 4, HQ DA Chief of Staff 5. HQ - OSWER Assistant Administrator, Office of Solid Waste and Emergency Response 6. HQ Chief Adviser for Bioterrorism Issues 7. R3 Deputy Regional Administrator Middle Management X HQ - Oi-RK OPC Center Director 9. HQ - OERK CIOC Program Manager 10, HQ-OPA Public Affairs Specialist 11. HQ - OERR Senior Process Manager 12. HQ-OSWER EOC Regional Coordinator n. iiq-opp'is Program Manager 14. HQ-OGC General Counsel 15, HQ-USPHS Program Officer 16. ERT (R2) Center Director 17. R1 Removal Manager 18, R3 Technical Manager 19. R3 Chief, Removal Branch (Acting) 20. R3 Congressional Liaison 21. R3 Associate Regional Counsel 14. R3 Community Involvement Coordinator 15. R3 Removal Manager September 2002 ------- Report Methodology (continued) ORGANIZATION TITLE, OR FUNCTION S FRY FT) IN ANTHRAX RESPONSE ACT IYITILS 16. R3 Section Chief. Removal Branch 17, R3 Chief, Removal Branch 18, R3 Division Director 19. R4 Chief, Removal Branch 20. R4 Section Chief 21. R5 Public Affairs Specialist 22. R5 Chief. Remov al Branch Front Line Res ponders 23. R1 osc 24. RI osc 25, ERT Veterinary Medicine Officer 26, ERT OSC Technical Support 27. ERT (R2) Environmental Engineer 28. ERT (R2) Engineer 29. R2 OSC 30, R3 Federal Facilities Branch RPM Technical Specialist OSC 31. R3 Lead OSC 32, R3 Community' Involvement Coordinator 33, R3 OSC 34, R3 osc 35. R3 Regional Response Coordinate 36. R3 OSC 37. R3 osc 38, R3 osc 39. R3 Regional Counter-Terrorism Program Coordinator Ao September 2002 ------- Report Methodology (continued) ORGANIZATION TITLE. OR I- I NC'TION SERY'ED IN ANTHRAX RESPONSE ACTIVITIES 40. R3 osc 41. R3 osc 42, R3 osc 43, R4 osc 44 R4 osc 45. R4 osc 46, R4 osc 47. R4 osc 4X. R5 osc 49. R5 osc 50. R5 osc 51. R5 osc 52. R5 osc 5?. R6 osc 54. R7 osc 55. R7 osc 56. RS osc 57. R9 osc 58. RIO osc 5«. RIO osc 60. RIO osc \ September 2002 ------- Appendix B Sample Interview Questions B-l September 2002 ------- Appendix B Sample interview Questions Intervieweg Office 'Title Date Interviewer Questions for Anthrax Interviews with Headquarters ami Regional Management Personnel A. Authority {Laws/Regulations} 1, Under which laws and authorities did you respond0 2. Did you have authority appropriate for the response actions thai were required"? 3, Did von encounter any problems or issues related to your authority or the authority of other parties involved in the response'? If so, how were the problems or issues resolved? 4. What law regulations could be strengthened to provide the adequate authority1? B. Operations 1. What, specifically, was your role in the response'? What actions did you take to earn' out your responsibilities'? 2. Describe the operating environment. What were the issues that you faced? 3. What were the cleanup technologies, specific to your sue/facility, used in the anthrax response'? 4. What were some of the issues associated with the technicalities of remediating the anthrax? 5. Were there any technologies that would have been helpful to you if they were available during the response operation in terms of analytical methods, monitoring, etc.'' 6. Mow prepared was your organization to respond to the anthrax incident! s)'? 7. Hid you receive the support you required to carry out your responsibilities? B September 2002 ------- Sample Interview Questions (continued) C. Communications/Coordination /nternal Communication/Coordination 1. Describe the structure for ensuring that HQ, Regions, and EOC operations were kept updated on response progress. How well did this structure work? What could be improved? 2. Was a Joint Information Center (JIC) established*? If so, talk about how the J1C functioned. If not, describe the decision-making process for not having a JIC. Describe what was implemented in lieu of a JIC. 3. How were you notified of the anthrax incidents)? 4. Describe the process for information gathering. Was there an organized structure for obtaining information from key personnel responsible for the response? What worked and what could be improved? 5. Did you receive the information you required to carry out your responsibilities initially? As the response activities progressed? 6. What information requests, including reporting requirements, were made of you'' 7. What EPA groups did you communicate, coordinate with? What was the nature of the communication? Was it successful'' 8. Were there any significant challenges that kept you from communicating internally? Describe the challenges and offer suggestions for improving internal communications. lixtern al ( omntu nicution/Coordinution 9. Which organizations, outside offfPA, did you coordinate with'* 10. What was the nature of the coordination/communication with outside organizations? Was it successful? 11. How were crisis communication, public information, or media relations decisions made and communicated? 12. Were there any significant challenges that kept you from communicating externally? Describe the challenges and offer suggestions for improving external communications. September 2002 ------- Sample Interview Questions (continued) Community Involvement 13. Was there a formal communications strategy that outlined who the key audiences were and how the agency would involve them during the response'.' 14. What were some of the challenges of conducting community involvement activities during the response'.1 How could those challenges have been resolved0 D. Health and Safety L Was the health and safety planning sufficient to address the activities of your organization in response to the anthrax incidents)? 2. How were you involved in hazard and risk management decisions? 3. Was the level of training you and your organization had received sufficient to prepare vou to address the health and safety issues associated with the anthrax incidental? 4. Describe the challenges you faced and what specific recommendations you would give. E. Resources: Technical and Administrative 1. What resource issues did you face in carrying out your responsibilities? 2. I low did you handle resource (personnel, equipment, funding) shortfalls? 3. Did responding to the anthrax incident(s) require you to make adjustments in other program activities? F. Overall Significance and Impact 1. Please indicate your degree of satisfaction with llPA's abiluv to respond to the challenges presented in each of the areas previous!v discussed: Very Satisfied Reasonably Satisfied Satisfied Di satisfied Very Dissatisfied Authority 5 4 3 2 1 Operations 5 4 3 2 1 Interna] (EPA) Communications 5 4 3 -> 1 B-4 September 2002 ------- Sample Interview Questions (continued) Very Satisfied Reasonably Satisfied Satisfied Dissatisfied Very Dissatisfied External (other agencies) Communications 5 4 3 *> I Community Communications 5 4 3 2 1 Health and Safety 5 4 3 2 1 Resources s 4 3 2 1 2. What do you believe to be the most significant problems or challenges facing the Agency in the case of anthrax contamination .' (List no more than five.) Questions for Anthrax Interviews with OSCs and Other Response Personnel A, Autliorin 11 aus Regulations) 1, Under which laws'regulations did you respond? 2, Did you have authority appropriate for the response actions that were required? 3, Did other parties act under other authorities, laws or regulations'? If so, what were they? 4, Did you encounter any problems or issues related to your authority or the authority of other panics involved in the response? if so, how were the problems or issues resolved? 5, What law/regulations could be strengthened to provide the adequate authority'' B. Operations 1. What, specifically. was your role in the response? What actions did you take to cam out your responsibilities? 2. Describe the operating environment. What were the immediate issues thai you faced? 3. What were lite cleanup technologies, specific to your site/facility, used in the anthrax response? B-5 September 2002 ------- Sample Interview Questions (continued) 4. What were some of the issues associated with the technicalities of remediating the anthrax'.1 Were there any technologies that would have been helpful to you if the v were available during the response operation in terms of analytical methods, monitoring, etc.? 5. How prepared was your organization to respond to the anthrax incident!sT? 6. Did you receive the support you required to carry out your responsibilities? C. Communications/Coordination Internal Communication/Coordination 1. Describe the structure fur ensuring that HQ, Regions, and HOC operations were kept updated on response progress, iiow well did this structure work'.' What could he improved? 2. Was a Joint Information Center fJIC) established'.' If so, talk about how the J!C functioned. If not. describe the decision-making process for not having a J1C. Describe what was implemented in lieu of a JIC. 3. How were you notified of the anthrax incident! s) 4. Describe the process for information gathering. Was there an organized structure for obtaining information from key personnel responsible for the response? What worked and what could be improved? 5. Initially, did you receive the information >'011 required to carry out your responsibilities? As the response activities progressed? 6. What information requests, including reporting requirements, were made of you'.' 7. What EPA organizations did you communicate coordinate with'.' 8. What was the nature of the communication, coordination'.1 Was it successful? 9. Were there any significant challenges that kept you from communicating internally'1 Describe the challenges and offer suggestions for improving internal communications. External Communication/Coordination 10. Which organizations, outside of EPA. did you coordinate with? I L Was there a clear structure for keeping external audiences updated'.' 12. What was the nature of the coordination/communication? Was it successful? B-6 Septc Tiber 2002 ------- Sample Interview Questions (continued) 13. How were crisis communication, public information, or media relations decisions made and communicated'1 14. Were there any significant challenges that kept you from communicating externa!ly".' Describe the challenges and offer suggestions for improving external communications. Community Involvement 15. Was there a formal communication* strategy that outlined who the key audiences were and how the agency would involve them during the response'1 16. What were some of the challenges of conducting community involvement activities dunng the response? How could those challenges have been resolved? D. Health ;md Safcl> 1. Was there a written HASP for employees involved in the response? 2. Was the level of training you had received sufficient to prepare you to address the health and safety issues associated with the anthrax incident!s)'' 3. Was the site evaluated to identify specific site hazards and to determine the appropriate safety and health control procedures? 4. Were appropriate procedures implemented to control exposure to hazardous substances before clean-up work began? 5. Were you or are you covered under a medical surveillance program? 6. Did the site manager use engineering controls, work practices, and PPE appropriately to protect employees from exposure to hazardous substances and safety and health hazards? 7. Were decontamination procedures developed, communicated to employees and implemented before any employees or equipment entered areas on site where potential for exposure to hazardous substances exist? 8. Was a written site emergency response plan developed and implemented for the site, and made available to you? 9. Describe the challenges you faced and what specific recommendations you would give. E, Resources: technical and Administrative 1. What resource issues did you face in earning out your responsibilities? September 2002 ------- Sample interview Questions (continued) 2, How did you handle resource (personnel, equipment, funding) shortfalls? 3, Did your response activities require you to make adjustments in other program activities'.1 F, Overall Significance and Impact L Please indicate your degree of satisfaction with EPA's ability to respond to the challenges presented in each of the areas previously discussed: Very Satisfied Reasonably Satisfied Satisfied Dissatisfied Very Dissatisfied Authority 5 4 3 2 1 Operations 5 4 3 2 I Internal (EPA) Communications 5 4 3 2 1 External {other agencies) Communications 5 4 2 I Community Communications 5 4 3 *> 1 Health and Safety 5 4 3 2 1 Resources 5 4 3 1 2. What do you believe to be the most significant problems or challenges facing the Agency in the case of anthrax contamination? (List no more than five.) B-8 September 2002 ------- |