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Chemical Incident Report

ISSN 1364-4106

Produced by the Chemical Incident Response Service of the


Medical Toxicology Unit, Guys and St Thomas Hospital Trust
Number 17 Editorial
Dr Virginia Murray, Director, Chemical Incident Response Service
July 2000

In this Chemical Incident Report the Chemical Incident Response Service (CIRS) targets the following for
public health professionals and staff working in accident and emergency departments:
Issues relating to decisions about sheltering and evacuation recur for Health Authorities practically
every time a major chemical incident occurs. Although some information has been published in the
Chemical Incident Management for Public Health Physicians it is timely to review this advice in the
light of Health Authority experience from recent incidents published in this Chemical Incident Report.
Several additional checklists have been included to facilitate the decision making process and a draft
information leaflet on important information for people being evacuated. As always comments would
be very welcome so that these can be finalised by October 2000 and made available in the CIRS section
of the Medical Toxicology Unit website (www.medtox.org.uk) for you to use as needed.
A paper on the implications of COMAH and the Human Rights legislation for Health Authorities is included. Health Authorities will need to be aware of the implications of these as additional responsibilities will mean additional planning which may need to included in current and future work programmes.
A draft checklist of the areas needing consideration is includedagain please comment on its appropriateness and completeness.
Many Health Authorities are developing excellent plans for response to all major events including
chemical incidents. However CIRS has become increasing concerned about the problems of making
these plans dovetail with Accident and Emergency Departments and other health and non-health organisations. The APELL approach is commended to you for offering you a system which could be implemented. Please discuss this with your Health Emergency Planning Advisers (HEPAs). If you feel it
would be helpful CIRS and your HEPAs could seek advice from the Department of Healths Emergency
Planning Co-ordination Unit on trying to take this approach or others forward.
Incinerators will also impact on Health AuthoritiesCIRS is in discussion with the Environment
Agency to try and clarify what your roles and responsibilities may be in providing advice.

Contents

Page

Sheltering versus evacuation

Sheltering to manage acute chemical releases

Shelter advice protects against adverse health effects of a hydrogen chloride gas plume

A fire at a chemicals warehouse in St Helens

Evacuation/relocation from persistent environmental contamination

Weston Quarries chemical incidents

Evacuation from persistent environmental contamination following a sewage spill

Incidents resulting in part evacuation and part sheltering

12

Chemical incidents in Devon

12

Health decisions and information taken without involving the Health Authority

14

Fire incident at textile dye factory, Macclesfield on Saturday 13 May 2000

14

If Evacuation is to occur ...

15

COMAH and the Human Rights Act 1998

16

Draft Checklist for COMAH information requirements for Health Authorities

17

APELL: Awareness and Preparedness for Emergencies at Local Level

18

Incinerators and Municipal Waste Incineration

21

Training days reports

23

CIRS Training programme Autumn 2000

24

Medical Toxicology Unit, Guy's and St Thomas Hospital Trust, Avonley Road, London SE14 5ER
National Poisons Information Service, London: 24 hour emergency Tel no. 0207-635-9191
Chemical Incident Response Service routine telephone enquiries: 0207-771-5383 Fax: 0207-771-5382
24 hour CIRS confidential number available to CIRS contract holders 2000

Chemical Incident Report from the Chemical Incident Response Service


Sheltering versus evacuation

July 2000

Effective sheltering entails :

Virginia Murray, CIRS

Go in, Stay in, Tune in (figure 1)


Commentary
As a result of problems arising in several incidents about
the difficulty in making correct decisions on the appropriateness of sheltering versus evacuation, this Chemical
Incident Report will review how some decisions are
made and implemented during incidents.
Many of these issues have been considered already and
published in the Chemical Incident Management for
Public Health Physicians chapter on public safety
sheltering versus evacuation (Irwin et al. 1999). This
chapter was initially developed by Dr Susan Shonfield
for the 1995 handbook. The summary provided here reviews the pro and cons in a checklist form which seems
to be particularly helpful for Health Authorities.
In particular it is essential that Health Authorities should
be party to the decision making process and therefore
must not only collaborate closely with the emergency
services in planning but also in debriefing on incidents
to develop better local links and planning strategies.

Sheltering
A considerable degree of protection is afforded by sheltering in a house. Buildings dampen fluctuations in atmospheric turbulence, reducing infiltration by gases.
Even in a poorly sealed house infiltration may be reduced by a factor of 10; when windows and doors are
sealed (with wet towels or newspapers) this increases by
30 or 50 fold.

Closing windows and doors


Minimising draughts by sealing windows and doors
with paper/tape or damp towels
Turning off central heating
Turning off mechanical ventilation including air
conditioning (dont forget to give this advice to hospitals downwind of the plume)
Going to an upper floor, if possible to an interior
room where ventilation is less
Avoiding bathrooms and kitchens, which tend to
have higher ventilation rates
Keeping children and pets indoors
Breathing through a wet cloth over the face if the
atmosphere inside becomes uncomfortable
Having access to a radio to tune into the local radio
station for further information and advice

The public also need to be advised not to use the telephone unless absolutely vital to prevent unnecessary
jamming of lines. Providing a help-line number is essentialconsider providing a service with the help of your
local NHS Directwhich will have nationwide coverage by the end of 2000.
Effective communication systems must be in place to
ensure that all those sheltered go outside to fresh air as
soon as the hazard is safely pastif they stay sheltered
too long people may end up being exposed to a higher

Figure 1: In Case of Emergency leaflet, page 23.

Cheshire Fire Brigade


Page 2

Chemical Incident Report from the Chemical Incident Response Service

July 2000

The decision to evacuate is also affected by:


The population profilenumbers of elderly, handicapped and immobile, whether there are any residential homes/nursing homes in the affected area, any
people on dialysis machines, or others at special risk
The extent of the road network
Transport availabilityprivate and public
Blockage of roadse.g. flooding or snow
Hazardous travel conditionse.g. fog, snow, sleet, ice
Consideration of the effect on evacuees of
Outside temperature
Psychological trauma/medical risks
Risk of damage and looting of property
Cost
How large a zone is to be evacuated
Possible health risks to the police cordon

cumulative dose than they would receive if outside.


Those who are severely incapacitated will need assistance from their homes. Prompt medical attention may
be needed after sheltering to triage those who may be at
potential risk from hazards such as irritant gases.
The Public Education Group of the National Steering
Committee on Warning and Informing the Public During Emergencies has developed a seven minute video to
make members of the public more aware of the actions
they should take to safeguard themselves in the unlikely
event of a major outdoor accident or emergency. For
more information please contact Evan Morris at Cheshire Fire Brigade on 01606-868785 emorris@cheshire.
co.uk or David Moses on 01992-555960 david.
moses@hertscc.gov.uk

Evacuation

Checklist of questions to facilitate


the sheltering / evacuation decision

Evacuation should only be used as a measure of last


resort when the public would be in serious danger if
they stayed. Specific instances could include:

1. Is the substance harmful to the public?


Highly toxic/ toxic/irritant/ non-irritant
Short-term / long-term effects
Explosive / non-explosive
2. Will the public be exposed?
Substance contained
Potential for release
Capable of dispersal via wind, rain, etc
Public in path of projected route
Distance, height of plume, meteorological conditions, stability of weather conditions
3. Will dilution factors minimise risk?
4. When will the public be exposed (time of day)?
Already exposed
Imminently
Not for a few hours
5. How long will the exposure last
Few minutes
Hours
Days
Months
Years

Before an incident (precautionary)

Risk of imminent explosion ( e.g. defusing a second


World War bomb or making safe a potentially explosive jar of picric acid)

Small leak likely to escalate sharply

Release / threatened release of radioactive materials


During an incident

Spread of fire to members of the public

Continuing release of a hazard over a prolonged period of time


After an incident

Gross environmental contamination


The decision to effect an evacuation to minimise the risk
to the publics health should always be taken in conjunction with the Health Authority. Evacuation is feasible only
if it can be confidently predicted that there is sufficient
time to evacuate people before the incident escalates.
Therefore the time available to effect evacuation will depend on:
The time required to make the decision to evacuate
the emergency services, and if applicable the Health
Authoritys, response time
The time required to co-ordinate the public
depending on the method chosen e.g. door-to-door, via
loudhailers, radio/TV networks, any language barriers,
whether translators are needed
The time of dayit is more difficult to warn people
effectively at 4 a.m. than at 8 p.m.
The time necessary for the public to prepare to
move to collect e.g. clothes, medication, baby supplies, pets, cheque books, credit cards, and to secure
their homes.
the time required for the public to move
Evacuation of homes may not be appropriate in, for
eaxmple, a short term release of a potentially toxic cloud.

Reference: Irwin DJ, Cromie DT, Murray V. Chemical Incident


Management for Public Health Physicians. London: The Stationery Office; 1999.p. 4-14.

Introduction
The chemical incidents reported on pages 3 to 14 reflect
issues raised by public health and concern experiences
gained during :

Sheltering: pages 4 6

Evacuation/relocation: pages 7-11

Part sheltering part evacuation pages 12-13

Decision made without involving the Health Authority: page 14


CIRS is very grateful to the many public health colleagues
who have contributed incident reports to illustrate some of
the problems surrounding these decisions.

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Chemical Incident Report from the Chemical Incident Response Service

July 2000

Sheltering to manage acute chemical


releases
Shelter advice protects against adverse health
effects of a hydrogen chloride gas plume
Dr Sarah Woodhouse, Specialist Registrar in Public
Health Medicine, Communicable Disease Unit covering
North and South Cheshire and the Wirral Health Authorities
On 8 March this year an incident occurred at the European Vinyls Corporation (EVC) in Runcorn, Cheshire,
resulting in a large release of hydrogen chloride (HCl)
gas. "Cloudburst" was declared and shelter advice issued
to residents and people travelling through the area. After
three hours the leak was contained, the shelter advice
lifted and the incident was stood down. Only a small
number of casualties resulted.

Figure 1: Bellows failure

Sequence of events
06.57 hours there was a bellows failure on site initiating a shut down (figure 1)
07.02 hours police received the first telephone calls
from the public, reporting a large white cloud over
the nearby expressway
07.07 hours the investigation on site detected escaping HCl gas.
07.10 hours the incident was progressing and
"Cloudburst" was declared. Cheshire Fire Brigade
was notified. (Figure 2 shows the location of EVC

Figure 2: Location with arrow showing prevailing wind


Page 4

and the prevailing wind direction). The site siren


was sounded, giving the first public warning of an
incident. First aid and decontamination was available for workers
07.15 hours Cheshire Police were notified and cascaded information to other agencies, who began implementing their emergency plans. Local incident
command and control bases were established. The
emergency services worked with local media to inform and advise the public. Environmental monitoring detected levels of 1ppm of HCl at two nearby
locations

Chemical Incident Report from the Chemical Incident Response Service

At 07.25 hours the leak was halted. Nearby roads


were now closed and causing traffic jams
By 07.30 hours local radio reported the incident, including possible health effects and advice to stay in,
with windows closed and await further advice.
Those with severe symptoms were advised to attend
A&E
At 07.55 hours the duty public health physician for
North Cheshire Health Authority was informed and
contacted the Chemical Incident Response Service
(CIRS). Toxicological information was received and
the risk to the public considered.

The public health response


risk assessment to estimate the public health risk
and decide action: the risk assessment took into account that the leak was contained and the plume dispersing. No severe casualties were reported. The
effects would probably be eye and throat irritation
from mild exposures. The shelter advice was reinforced.
use of geographical information system to identify
vulnerable groups within 2 mile radius
dissemination of information to relevant people
liaison with major incident co-ordinator at hospital
trust
letter to GPs within 5 mile radius.
10.15 hours the incident was stood down, roads reopened and shelter advice lifted.
The health impact
The full health impact can only be estimated. Two workers were given first aid and taken to A&E where they
were treated and allowed home. An incident team member sustained a back injury. Seven people attended A&E
with minor symptoms and were allowed home. A GP
reported seeing two patients with symptoms. A few telephone calls for advice were taken by A&E and ICI's occupational health department. Traffic jams could have
caused problems for the public health response as key
people were stranded.
From the de-briefing there were learning points for each
agency, but it was felt that the incident had been managed well.
The plant has been shut down pending investigation and
the failed equipment sent away for evaluation.
Because of the high profile of the incident it is surprising
that so few people sought medical help. There was a
visible gas plume in a residential area, causing traffic
chaos at rush hour. It occurred where the population has
been sensitised to the health risks of chemical plants by
an incident at ICI that has received national media coverage (see Dr Staples report, page 7).
Lesson learnt
Prompt advice to shelter may have minimised the adverse health effects.

July 2000

A fire in a chemicals warehouse in St Helens


Dr. Basil Wiratunga, Consultant in Communicable Disease Control, Dr. Christine Whiteside, Specialist Registrar
in Public Health, St Helens & Knowsley Health Authority
Incident summary
At 11.15 hours on Sunday 30 April 2000 the duty Consultant in Public Health for St Helens & Knowsley was informed by the Merseyside Ambulance Service of a fire at a
warehouse on an industrial estate 4 miles south of St Helens town centre, near junction 7 of the M62 motorway.
The warehouse was thought to contain several hundred
different chemicals used in the manufacture of rubber
products, the list of which was contained in a fire-proof
safe within the warehouse itself. The warehouse was not
subject to COMAH regulations. The fire was difficult to
control, requiring the attention of 150 fire brigade personnel. The plume of smoke reached 700 feet into the air, being thick and dark at first (figure 4), and later becoming
thin and wispy. Police closed off the roads in the vicinity,
and advised local residents to remain indoors and close
windows. This information was broadcast over a helicopter loudspeaker and on the local radio. The smoke plume
was blowing in a north westerly direction over residential
areas, farmlands, and Knowsley Safari Park.
Effects of the fire
The fire gave off a pungent smoke which could be
smelt and seen for several miles in its path. In Huyton, a few miles west of the incident, a yellow dust
was reported to have settled on cars
Some of the water runoff at the site entered local water courses, and it is estimated that approximately
10,000 small fish were killed in two local dam sites
Symptoms which could be attributed to the smoke
from the fire were noted, reported from information
collected by GPs, and by a questionnaire sent to A&E
staff at Whiston Hospital.
Actions taken by emergency services & other agencies
The Police co-ordinated the emergency response, and
operated a Silver Command. Roads were closed off
in the vicinity of the fire, and radio warnings were issued to stay indoors and close all windows. A video
was made, filmed from a police helicopter.
Although quickly on the scene, the Fire Service found
the fire difficult to control, and it took several days to
extinguish completely. It was necessary to turn over
the remains of the fire, and this had to be performed in
a controlled manner to avoid further environmental
contamination.
North West Water took samples of drinking water
from a reservoir near Knowsley Safari Park, which
was found to contain particulate matter, but no contamination with chemicals.
Samples of water were taken for analysis by the Environment Agency from Sutton Mill dam where the fish
had been killed. Phenolic compounds were identified.
The water in the dam was subsequently aerated.
The Environmental Health department looked at air
samples taken in St Helens, and found no significant
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Chemical Incident Report from the Chemical Incident Response Service

Figure 1: Fire plume reached 700 feet into air

M Talbot

change from usual. The yellow dust was sent for


analysis, but was not sampled in sufficient quantities
for a chemical analysis to be performed. It was unfortunately not possible to take samples of smoke, as the
appropriate equipment was not available.
The Merseyside Emergency Planning Unit (MEPU)
carried out smoke plume modelling.
The Ministry of Agriculture, Fisheries and Food issued advice on washing and peeling of vegetables, but
no crop samples were taken.
The company who owned the warehouse subsequently
produced a list of stored chemicals. They were also
responsible for the disposal of the run-off water used
by the Fire Service.

The Public Health response


At 11.35 hours the duty Public Health Consultant contacted CIRS, for further advice.
A meeting was convened on 2 May at the Health Authority for all agencies involved.
A questionnaire was faxed out to all GPs in the district
asking them to report any person presenting with
symptoms that could be attributed to the fire.
Staff on duty at the local Accident & Emergency department at Whiston Hospital, which was in the path
of the smoke, were sent another questionnaire, asking
about specific symptoms experienced by staff on duty.
A press release was issued by the Health Authority.
Results of questionnaire sent to A&E staff at Whiston
Hospital:
28 questionnaires were sent out to all doctors and nurses
on duty the day of the fire, and 10 were returned. 6 of
Table 1: Result of questionnaire survey to A&E staff
Symptom
Itchy eyes
Throat discomfort
Tight chest
Nausea
Headache
Skin rashes
Other symptoms

Number of complaints
5
3
2 (both asthmatics)
5
-

July 2000

these reported symptoms. All of these staff were on daytime duty (table 1).
Lessons learned
Although this particular fire did not have any far-reaching
consequences, several issues should be mentioned regarding the response to the incident.
Communication needs to be effective. In this case, the
MEPU were not informed until 2 hours after the start
of the fire.
It may be difficult to encourage the local residents to
stay indoors for their own protection. It was a warm
sunny day, and despite radio warnings from the police
to stay indoors and close windows, these were unheeded by many people.
The police also used a helicopter to make announcements to the public. However this was counterproductive as people had to come outside to hear a
message telling them to stay indoors and close their
doors and windows.
Sampling tubes and equipment should be immediately
available, as samples of smoke or particulate matter
may need to be taken soon after the incident.
The combination of chemicals involved in a fire may
be as important as the amounts or presence of specific
chemicals as laid out in the COMAH regulations. The
high temperatures involved in a fire may cause reactions between the chemicals producing different and
potentially more or less toxic substances.
The company who owned the warehouse was particularly helpful, both in the clean-up operation after the
fire, and later in producing the list of stored chemicals.
This co-operation made it easier for all agencies to
deal with the tasks in hand.
Responsibility for the clean-up operation needed to be
clearer. Delays were experienced by the Fire Service,
who were waiting for advice from the Environment
Agency on turning over the fire.
Sampling reports from the Environment Agency need
to be quickly available when any decisions are to be
made on the results, e.g. the safety of people using the
area of the dam site which was contaminated.

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Chemical Incident Report from the Chemical Incident Response Service


July 2000
Evacuation or relocation for persistent reduce their exposure. Over two hundred properties, in
Weston Village, have now been tested for HCBD using a
environmental contamination
method which only has a sensitivity of measuring down
Weston Quarries chemical incident.
Dr Brian Staples, Consultant in Public Health Medicine,
North Cheshire Health Authority
Interim incident summary
Weston Quarries are located in Runcorn, Cheshire.
overlooking the Mersey Estuary (figure 1). Runcorn was
the birthplace of the petrochemical industry, and the area
continues to rely heavily on this source of employment.
Up to the 1970s two former stone quarries were used as
a chemical dump. The quarries are now covered with a
thin layer of ash and soil, and used for grazing horses. A
small number of houses have been built directly by the
quarry, and a larger number are within a few yards of the
perimeter.

to 2 ppb. HCBD has been detected in twenty one households, affecting more than seventy adults and children.
Most have relocated to alternative accommodation to
reduce exposure, but a few continue to reside in their
properties.
The health authoritys response to this situation has been
two fold. Firstly it has had to care for those people who
are concerned about their health after being advised they
have been exposed to this chemical. It has done this by
arranging both physical health checks and psychological
support. Secondly it has commenced epidemiological
investigations to look for evidence of health effects in
the vicinity of the quarries.
Health checks were offered to residents who were in permanent residence at the time HCBD was detected. The
results of these investigations will be reviewed by an
expert panel which
will
determine
whether further action needs to be
taken.

Several years ago the


company which owns
the quarries started a
programme of investigations, called Project
Pathway, the aim of
which was to ascertain
A review of hospital
the extent of spread of
activity data has
chemicals from the
shown that the rate
quarry. This project inof kidney disease in
volves drilling bore
the area is elevated.
holes to a depth of 5m
However, it tranaround the boundaries of
spired that the incithe old Weston Quarry
dence of renal disto investigate whether
ease is also elevated
there is any leakage of
through out RunFigure 1: Weston Quarries overlooks Mersey Estuary CIRS
its contents. These incorn. It is therefore
vestigations revealed the presence of many substances,
unclear what the cause of this observation may be, but it
but in particular a chemical called hexachlorobutadiene
is unlikely that chemical contamination from Weston
(HCBD). Initially it was felt that there was very little
Quarries could be solely responsible.
chance that this substance could pass, as a vapour, into
peoples homes. However, indoor air quality measureThe health authority has also been asked to set a safe
ment has now revealed the presence of this substance at
exposure level for HCBD. We therefore asked the Deconcentrations ranging from 2 to 8 parts per billion
partment of Health for their assistance. The matter was
(ppb), with one house having an exceedingly high conreferred to the Committee on Toxicity (COT) and the
centration of 1000ppb.
Committee on Mutagenicity. Their guidance was published on the 21 June 2000. Although the committees
Hexachlorobutadiene is toxic. A literature review rewere unable to set a reference level for carcinogenic efvealed that its pathological effects in animals are mainly
fects, they did recommend a level of 0.6 ppb for all other
restricted to the renal system, including causing cancer.
health concerns.
The chemical has also been linked to liver disease and
retarded foetal development in animals, although the eviIn response to this the company will be commencing
dence is less clear in these respects. The effects on humore sensitive air quality monitoring in July 2000.
man populations, at low levels of exposure via inhalaWhile it is expected that most results should be below
tion, are unknown. We do not know whether the concenthe reference level set by the COT, a few may well extration of this substance, detected in the area, represents
ceed this limit. This chemical incident therefore contina significant risk to peoples health. In view of the uncerues to be an evolving situation, and as a consequence we
tainty surrounding the health effects of this substance,
are currently preparing to respond to this development.
the health authority decided that the only prudent course
of action was to advise that where HCBD was detected
Reference COT report on hexachlorobutadiene http://
in peoples homes they should consider taking action to
www.doh.gov.uk/hcbd.htm
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Chemical Incident Report from the Chemical Incident Response Service


Evacuation from persistent contamination following a sewage spill
Karen MacArthur, Public Health Epidemiologist, Dr
Juliet Gubbins, Specialist Registrar, Dr Nimal Premaratne, Consultant in Communicable Disease Control,
Bexley and Greenwich Health Authority, Clive Caine,
Head of Environmental Health Commercial Services,
Alex Henderson, Head of Environmental Services Bexley
Council, Rico Euripidou, Environmental Epidemiologist,
and Faith Goodfellow, Environmental Research EngineerWater, Chemical Incident Response Service
Incident summary
A low lying residential area was flooded by sewage (a
mixture of domestic and trade effluent) in three waves
between midnight and 03:30 hours on Thursday 26 November 1998. The sewage which was at a maximal depth
of one and a half feet led to an ingress of effluent through
ventilation bricks of 9 houses. These houses were located
in a dip and the effluent, reported with a strong chemical
odour, entered the homes and collected underneath
floorboards. A site visit by the Health Authority, Local
Authority, CIRS and others was conducted on 26 November (figure 1).
Forty residents were estimated to be exposed by the
ingress of effluent into their homes and 37 of these were
evacuated on 26 November and re-housed as they were
considered at significant risk. Residents who did not have
effluent in their houses were not evacuated as they were
not in direct contact with the liquid chemical effluent.
On Friday 27 November CIRS advised the Health Authority on the basis of preliminary sewage analysis from the

July 2000

local water company, that it was not safe for the residents
to return to their homes until the risks were fully established. Residents thus remained in hotel accommodation.
Extensive environmental monitoring was undertaken. This
included effluent samples that were taken at the incident
site at 03.00 hrs on 26 November and at a nearby pumping
station on 27 November. Extensive soil samples were also
taken at the incident site. However no indoor air samples
were taken on the day of the incident although samples
were taken later . This made it difficult to assess effects of
exposure on residents whose homes were not directly affected. Table 5 provides an example of some of the analytical results obtained from the monitoring.
Bagged air samples were taken from 3 houses on 2 December and from all affected houses on 10 December
(table 5). Chemicals were detected on both occasions.
However, the concentrations were much lower in the second sample indicating a decreasing level of exposure. Soil
samples were also taken from all but one house.
All residents considered exposed within the previous 24
hours and who experienced exposure symptoms were offered biological samples which were taken on 28 November. None of the results showed any trace of the contamination.
Subsequent to this incident a questionnaire survey was
undertaken with the following objectives:
to obtain descriptive information of levels of ill health at
the time of the chemical incident and immediately afterwards.
to determine whether any significant association be-

Figure 1: CIRS site visit on day of incident

CIRS
Page 8

Chemical Incident Report from the Chemical Incident Response Service

Information on length of exposure was collected by assessing the number of time periods spent in the affected
area for evacuated residents and personnel from other
agencies in the first week including and immediately following the incident. Very few not-evacuated residents
completed this section of the questionnaire which makes it
difficult to use as a proxy for exposure in their case. For
the purposes of analysis they

0-10yrs 11-20yrs 21-30yrs 31-40yrs 41-50yrs 51-75yrs

Total

14
7
10
27
18
12
88
(15.9%) (8.0%) (11.4%) (30.7%) (20.5%) (13.6 %) (100%)

tribution of all respondents in table 1.


Within the 0-20 age band there were 11 (32.4%), 0-10 year

16 47.1%

13

38.2%

14.7%

34

100%

5 27.8%

27.8%

44.4%

18

100%

19

52.8% 17 47.2%

36

100%

0%

Total

Self Reported Health Status


79 respondents (91.9%) rated their health status over the
last year as good. 7 respondents (8.1%) rated their health
status as fair. No respondents (0.0%) rated their health
status as bad.
Smoking
19 respondents (22.6%) stated that they smoked compared
to 65 (77.4%) who did not smoke.
Chronic diseases
7 (8.6%) respondents stated they suffered from chronic
health complaints compared to 74 (91.4%) who didnt suffer from any complaints.
Duration of symptoms following exposure
Of those people (n=46) who responded to this questionnaire Figure 2 shows the duration of symptoms following
exposure. 5 (11%) people included in the above analysis
Figure 2: Duration of symptoms experienced by
Duration
of relevant and possible symptoms
respondents
14
12
No of people

For the purposes of analysis the data set was divided into
these three groups (table 2):
Group 1 = residents evacuated due to presence of effluent in the house (Exposed).
Group 2 = residents not evacuated (Unexposed).
Group 3 = workers from various agencies involved in
clean-up on site.

Table 1: Age distribution of respondents

41-75 yrs

olds in group 1, compared with only three (17.6%) in


group 2 (table 2). Children generally have increased vulnerability to infection or disease.

were analysed as unexposed to effluent for the whole period of time but could also be considered as exposed to
some of the gases and odour.

Descriptive data set


88 questionnaires were available for analysis. The age dis-

21-40 yrs

10
8
6
4
2
0-2
days

0
12-14
days

Workers from various agencies were analysed as a separate group. Initially not all were wearing personal protective equipment at the time of the spill. With further occupational health assessment they were all advised to wear
protective clothing and to spend no longer than 2 hours at
the site.

0-20 yrs

9-11
days

Definition of exposure
Residents were classified into non-evacuated and evacuated groups as defining differing levels of exposure. However, the non-evacuated group may have also been subjected to the gases and odour from the effluent. No air
samples were taken from any of their houses and it is difficult to define what the levels of exposure were in these
households.

Groups

6-8
days

The survey was designed as a descriptive cross-sectional


study/case control to provide information about individuals who had been exposed to chemical effluent. This included residents and personnel from other agencies working at the site of the incident. Data was collected by questionnaire designed with the assistance of CIRS. These
were distributed to residents and workers to be returned by
post 96 questionnaires were returned, 59 from residents
(61%) and 37 from workers involved in cleanup (39%).

Table 2 Age distribution by exposure category

3-5
days

tween levels of exposure to the chemical effluent and


symptoms existed.

July 2000

Frequency

Time period of symptoms

reported their symptoms as ongoing.


Results and symptom prevalence
Analysis of association between exposure and symptoms
was undertaken. A table of possible symptoms was presented in the questionnaire. For the purposes of analysis
these were classified as either: relevant, possible and irrelevant on the basis of whether they were likely to be
caused by the exposure. Each of these symptom groups
were then compared with exposure groups to show any
significant variations.

Page 9

Chemical Incident Report from the Chemical Incident Response Service

July 2000

Table 3: Frequency of relevant symptoms by exposure category


Relevant Symptoms
Eye irritation
Facial flushing/burning
Nose burning
Skin burning
Skin irritation
Sore mouth/tongue
Sore throat

Group 1
No.
9
8
1
2
6
5
24

%
(27.3%)
(24.2%)
(2.9%)
(6.1%)
(18.2%)
(15.2%)
(72.7%)

Group2
No.
2
0
0
0
1
3
11

Table 3 shows the frequency of relevant symptoms by


each exposure category:
No odds ratios for comparison of groups 1 and 2 were
found to be statistically significant. This could be partly
due to the small numbers and the difficulty of calculating
odds ratios where there were zero values. However chi
squared test on facial flushing /burning gave the result
equal to 4. 36 (P value = 0.04)
Observation of the data does show that all percentages in
group 2 are smaller than those in group 1 which may be

%
(13%)
(0%)
(0%)
(0%)
(6.7%)
(20%)
(73.3%)

Group 3
No.
4
3
1
1
1
1
7

%
(11.4%)
(8.6%)
(2.9%)
(2.9%)
(2.9%)
(2.9%)
(16.7%)

Total
No.
15
11
2
3
8
9
42

%
(18%)
(13%)
(2%)
(3.6%)
(9.6%)
(10.8%)
(50.6%)

Discussion
Looking at the results the following discussion points can
tentatively be made:
There appears to be a significant difference between
evacuated residents who were exposed to the effluent
and workers from various agencies working on the site
with respect to having one or more relevant or one or
more relevant and possible symptoms. Specific symptoms show no statistically significant differences between sore throat, abdominal pain, cough, diarrhoea,
headache, nausea and / or loss of appetite. The self limiting clinical effects of nausea, mucous membrane irri-

Table 4 Frequency of possible symptoms by exposure category


Possible Symptoms
Abdominal pain
Cough
Diarrhoea
Dizziness
Drowsiness
Headache
Nausea
Shortness of breath
Vomiting
Loss of appetite
Other

Group 1
No.
9
12
14
3
1
24
12
2
5
10
6

%
27..3%
36.4%
42.4%
9.1%
3%
72.7%
36.4%
6.1%
15..2%
30.3%
16.2%

Group 2
No.
4
6
2
0
3
5
4
1
0
0
1

accounted for by the lesser exposure.


From table 3, comparison between group 1 and group 3
shows that the difference between groups for having a sore
throat is statistically significant (OR = 10.67 (3.02 < OR
<39.88)) No other difference in relevant symptoms between these two groups is statistically significant.
Again from table 3, comparison between group 2 and
group 3 shows that the difference between groups for having a sore throat is statistically significant (OR=11.00
(2.22<OR<60.36*), Chi-squared 12.96, P value = 0.001
Yates corrected No other difference in relevant symptoms
between the two groups is statistically significant.
From table 4, no statistically significant difference between groups 1 and 2 was found for any of the possible
symptoms except in the case of headache (OR = 5.33 (1.19
<OR < 25.36* P value = 0.009), for loss of appetite in
which group 1 has a higher prevalence (chi squared 5.74
Fisher exact P value = 0.02)
*Epi-info shows that the upper confidence interval may be
inaccurate

%
26.7%
40%
13.3%
0.0%
20%
33.3%
26.7%
6.7%
0%
0%
7.1%

Group 3
No.
1
4
1
1
1
9
3
0
0
0
1

%
2.9%
11.4%
2.9%
2.9%
2.9%
25.7%
8.6%
0%
0%
0%
2.9%

Total
No.
14
22
17
4
5
38
19
3
5
10
8

%
16..9%
26.5%
20.5%
4.8%
6%
45.8%
22.9%
3.6%
6.1%
12%
9.9%

tation and headache are known to be compatible with


acute exposure to a number of agents identified in the
effluent including acrylonitriles and phenols.
No gross statistically significant difference was found
between evacuated and not-evacuated residents with
respect to having one or more relevant or relevant and
possible symptoms or for any particular symptoms except facial flushing/burning, headache and loss of appetite. It may be that not-evacuated residents were also
adversely affected by the fumes from the effluent. It is
also likely that a bias was introduced at this point as a
smaller proportion of households in this category returned questionnaires. It may be that residents experiencing symptoms were far more likely to return questionnaires. If this was the case this would have affected
the odds ratio considerably.
Possible Sources of Bias
Exact levels and duration of exposure were difficult to
ascertain. Large numbers of chemicals in the effluent
and the absence of air samples taken immediately
makes it difficult to comment on the likely effects to
health from these exposures exposure. All groups con-

Page 10

Chemical Incident Report from the Chemical Incident Response Service


sidered in this analysis had some exposure levels so
there is no control. Analysis was therefore restricted to
comparing differing levels of exposure against symptoms. It would have been helpful to have had a clearly
defined control group which was separate from the affected group and living in the same area.
The finding that there were more non-responders in the
unexposed group may affect the results.
Misclassification bias may have occurred as it was not
always clear whether missing values were genuinely
missing. There are 14 missing values for all categories
of symptoms in the data set. Given the small numbers
this could have had a significant effect and would significantly change the odds ratios.
Some misclassification bias may occur with children
having not filled in some categories on the form correctly, sometimes in a contradictory manner.
Design flaws and learning points
More time for preparing an interviewer administered
questionnaire might have been appropriate given the
sample size. This would have ensured greater completeness of data with more weight to the analysis.
Air samples of contamination levels were not taken in
the houses of all residents until a significant time period
had elapsed.
Inevitably householders wished to return to their homes
to collect things. Therefore length of exposure was not
measured accurately which made it difficult to compare
levels of exposure to levels of disease in any meaningful
sense. It may thus have been more helpful to design the
questionnaire to give more specific time periods of ex-

July 2000

posure.
It was also not possible to calculate a response rate accurately because of the way the questionnaire was administered. Residents should be given one questionnaire
per person and not a limited number of questionnaires
per household.
Conclusions
Evacuation is generally a very difficult and disrupting exercise and should not be undertaken unless clearly necessary. In this incident this decision was made easier as a
cocktail of chemicals had clearly entered peoples homes
leading to residents developing acute adverse symptoms.
Therefore this environmental contamination posed a risk
to their health.
The value of epidemiological surveillance in assessing adverse health effects from chemical incidents and management to minimise harm can be considerable and is highlighted in this study. However in this incident the comparison of symptoms of the evacuated residents group with
those not evacuated (where effluent did not enter their
homes) is difficult. In particular it shows that both groups
suffered similar symptoms, although, the small number of
respondents, the absence of a control group and null values
made interpretation of the data set difficult.
This could imply that the evacuated and the not-evacuated
groups may have been equally exposed and at risk or that
the action of evacuation was timely and effectively minimised exposure and therefore continuing harm to those
most at risk.

Table 5: Results of airbag sampling from inside houses and background levels, quantitative AEA air analysis, 10 December 1998
Air bag samples, g/m3
Substance

toluene
nonane
pentamethyl heptane
tetramethyl octane
trimethyl decane
ethenyl ethyl benzene
bis dimethyl cyclohexadiene dione
ethyl hexanol
limonene
decamethyl cyclopentasiloxane
benzoic acid
acetone
acetonitrile
hexane
ethyl acetate
methyl cyclopentane
unknown
DCM/CS2
fluoralkane 1
fluoralkane 2
fluoralkane 3
fluoralkane 4
fluoralkane 5

No. 1 No. 2 No. 3 No. 4 No. 5 No. 6 No. 7 No. 8 No. 9 No. 10
125 100
110 140
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
3770 4020
585 570
570 610
110
240 275
4355 4205
-

45
55
<5
<5
<5
110
110
2630
460
455
105
150
4105
-

90
90
<5
<5
<5
15
30
3455
565
535
105
210
4275
-

Page 11

15
145
10
5
<5
10
20
20
-

10
60
5
<5
5
10
10
15
-

30
40
<5
<5
<5
<5
<5
2435
385
390
95
105
4000
-

80
15
<5
<5
<5
10
<5
<5
-

40
60
<5
<5
<5
<5
<5
2370
415
405
115
125
3990
-

20
410
155
45
315
155

Background 1

Background 2

55
55
45
70
25
25
<5
2755
500
470
105
155
4250
-

50
25
<5
<5
<5
<5
<5
2785
500
460
105
145
4140
-

Chemical Incident Report from the Chemical Incident Response Service

July 2000

Incidents resulting in part evacuation


and part sheltering

Chemical incidents in Devon

Commentary
Virginia Murray, CIRS

The first incident occurred in Kingsbridge on Thursday, 25


November 1999 and involved the release of phosphine
gas. Stored rat poison (aluminium phosphide) had become
wet in the rain leading to production of phosphine gas.
Some residents were evacuated immediately at the onset of
the event and later some more were evacuated at the time
of clean up of the chemical. A total of 80 residents were
evacuated (table 1 provides a summary of the sequence of
events)

Two major chemical incidents occurred in Devon


within the short space of two weeks. Both required
intense public health activity to minimise the impact
on the health of the local community. CIRS was asked
to provide information and advice for the response in
both incidents. Common features are listed below:

both incidents were interesting since sheltering


and evacuation played a role in the incident response

to some extent these sheltering and evacuation


decisions were made without Health Authority
influence which posed a more complex problem

both incidents involved multi-agency debriefs to


which the Health Authority was invited to participate; they invited CIRS to attend which provided valuable sharing of roles and responsibilities

in both incidents questionnaires were used to assess the response and incident management process. Details of these will be published in a future
paper.

Dr Sanjay Kinra, Specialist Registrar in Public Health


Medicine, South West Devon Health Authority

The other incident happened in Paignton, on Thursday, 9


December 1999. A fire in a plastics factory resulted in the
thick black acrid smoke blowing over the nearby residential estate. Nearly 480 residents were evacuated from the
thick of the plume soon after onset of the incident (table 2
provides a summary of the sequence of events)
Summary and lessons learned
The public health department was represented in gold and
silver commands in both incidents and provided health
advice. The overall impression at the post-incident debriefs organised by the Police was that the incidents had
been managed well. The lessons that were learnt from
these incidents included delayed involvement of public
health and poor communications support, lack of under-

Table 1. Chronology of events on 25-26 November 1999, Kingsbridge


Time

Event/Action

Thursday 25 November 1999


13:30 hours.
13:46 hours

14:02 hours.
14:45 hours
17:00 hours
18:36 hours

Call from a resident regarding rubbish fire in the neighbour's backyard; Fire Service arrive quickly
and apply water but soon stop because the smoke worsens
Owner of the house tells Fire Service that the smoking black sack contained rat poison (aluminium
phosphide) for disposal; Fire Service search their chemical database and discover that aluminium
phosphide, on getting wet, releases phosphine gas; presume chemical reaction due to rain and fire
water
Police arrive on the scene; evacuate nearby 20 residences exposed to the plume and cordon off the
area (100m radius); others asked to shelter indoors
Fire service receive details about the gas and its effects by fax from head office; sand applied to the
chemical while officers use breathing apparatus
Public Health contacted who contact CIRS for expert advice; CIRS fax further information about
the health effects of phosphine
12 emergency services personnel attend the local hospital; 4 of them symptomatic

19:24 hours

Major Incident declared; Silver and Gold Commands set up; meetings through the night; no further
evacuation decisions considered possible in the absence of air sampling information
Friday 26 November 1999
04:31 hours

14:00 hours

Air sampling commenced; only traces of phosphine in the thick of the plume; decision taken to
evacuate more residences to allow the clean-up of the chemical as the process expected to release
more fumes
Evacuation leaflets distributed which had been produced overnight; evacuation of another 100 residences; only 25 people came out (some empty, some refused); taken to nearby leisure centre
Chemical removed from site by specialist company

17:40 hours

Residents returned to their homes; incident declared closed

06:00 hours

Page 12

Chemical Incident Report from the Chemical Incident Response Service

July 2000

Table 2. Chronology of events on 9-12 December 1999, Paignton


Time

Event/Action

Thursday 9 December 1999


10:59 hours

Fire Service, following a 999 call, arrive at a plastics factory in an industrial estate; find the building
well alight and releasing thick acrid smoke; commence fire fighting; no casualties as the workers
had just finished their shift who also inform the Fire Service the factory makes plastic jelly shoes
and toys
Friday 10 December 1999
00:40 hours
01:28 hours
02:43 hours
04:05 hours
04:21 hours
04:47 hours

Fire difficult to control; thick smoke over nearby residences; residents asked to stay indoors and shut
doors and windows
Building roof collapses; thick smoke continues to blow over the nearby residences; Emergency Services review the residential area and decide to evacuate group of houses considered most exposed
(480 people); evacuees taken to the nearby leisure centre
Major incident declared by Police; Gold and Silver Commands established
Chief Environmental Health Officer (CEHO) joins Silver Command; advises on likely constituents
of smoke and attempts to set up available air monitoring equipment
Several personnel from the emergency services taken to hospital for cough and breathing difficulties

06:30 hours

CIRS contacted who advise regarding possible smoke constituents and their side effects, problems
found in contacting Public Health
Change of wind direction leads to plume over additional houses; meeting to discuss further evacuation; disagreement on best option - Emergency Services support evacuation, Chief EHO opposed;
decision taken not to evacuate
Public Health informed following some problems in contacting, discuss with CIRS for advice. Public Health join Silver Command soon afterwards
2 evacuees taken to the hospital; one for an acute attack of bronchial asthma and other for suspected
angina
Evacuation complete

07:00 hours

EHO fails to calibrate local monitoring equipment and starts making alternative arrangements

09.40 hours

CIRS requested to attend site and Silver Command by Public Health

12:00 hours

14:54 hours

Air sampling finally begins; small amounts of hydrochloric acid (HCl) detected in the thick of the
plume; sampling continued for next 48 hours
CIRS director arrives at the site; finds many residents in the sheltering zone outside their homes;
finds asbestos cement in the factory; following visit around site and discussion with Silver Command advises Public Health not to expand the evacuation zone further and to consider exposure to
asbestos
Asbestos sampling shows only asbestos cement; asbestos fibre counts in air samples insignificant

16:58 hours

Fire fighting continues; air sampling for several gases does not detect any significant levels

05:00 hours
05:20 hours
05:24 hours

13:35 hours

Saturday 11 December 1999


11:22 hours

Air monitoring consistently negative; samples for asbestos and dioxins collected from several sites

16:05 hours

Steady progress with fire; plume clearer and air sampling consistently negative; evacuated residents
allowed back to their homes after 2 days away; advice leaflet given
Incident declared closed

17:25 hours

Sunday 12 December 1999 : Fire declared out by Fire Brigade


standing of each other's roles and inadequate air monitoring facilities to guide advice.

begun) and where the exposure in not expected to persist


for several days.

Another common feature was the evacuation of the resiDespite this advice, a large number of evacuations still
dents in both the incidents. The standard guidance for pubtake place every year in the UK, which have risks associlic health protection in chemical incidents, under most cirated with them. Early involvement of Public Health and
cumstances, is to shelter rather than evacuate. This is espeincreased awareness amongst Emergency Services may
cially true for aftermath evacuations (after exposure has
help to reduce unnecessary evacuations in the future.
Page 13

Chemical Incident Report from the Chemical Incident Response Service


Health decisions and information takenwithout involving the Health Authority
Fire incident at textile dye factory,
Macclesfield, on Saturday 13 May 2000
Dr Evdokia Dardamissis Specialist Registrar in Public Health Medicine; Dr Paula McDonald Consultant
in Communicable Disease Control , Communicable
Disease Unit covering North and South Cheshire
and the Wirral Health Authorities
Incident Summary
On Saturday 13 May at 14.00 hours a fire occurred
within the premises of a textile dye factory at
Fence Avenue Macclesfield leading to the release
of cement asbestos and fabric dyes into the environment.
Macclesfield Local Authority commissioned a
clean up operation of the adjoining streets. This
was carried out by an outside agency on 14 May
and again on 15 May. Fragments of asbestos were
handpicked.
Fire fighting water was contaminated with small
amounts of acid based dyes and entered the River
Bollin via surface drains. One of the dyes was
nyolamine Red C-2B, which has a fish toxicity of
0.1-1.0 mg/l. The Environment Agency concluded
Assuming the quantities released were not significant, the dilution effect of the extinguishing water
and the watercourse itself may be sufficient to
avoid adverse [environmental] effects. Checks
with North West Water established that the river is
not used as a water source.
No air or water samples were taken.
The on call public health doctor at the Communicable Disease Unit was informed on Monday 15
May 2000 by Cheshire Civil Protection Unit
Following review by the Health Authority the public health risk to local residents was considered
small.
The Local Authority issued a press release about
the incident on Tuesday 16 May 2000. This included advice to residents in the neighbouring
streets not to touch asbestos pieces. The release
was approved by Communicable Disease Unit
No casualties or symptomatic people were reported.
Issues
The Communicable Disease Unit was not informed until two days after the incident occurred.
Therefore public health advice was not timely, for
example , we were not able to contribute to decisions about evacuation or sheltering. The normal
route of notification of the Communicable Disease Unit during a chemical incident is via the
Ambulance Service. However, the Ambulance
service may not be involved in incidents if there
are no casualties and the site concerned is not a

July 2000

CIMAH or COMAH site. The Communicable


Disease Unit and the Fire Service have recently
set up a system whereby the Fire Service notifies
the Communicable Disease Unit of significant
incidents where there are no casualties. The criteria for notification include an asbestos roof in a
commercial premise, as was the case in this incident. However, the system did not work in this
case. The Fire service has identified that this is
training issue for staff, and is arranging training in
operating the protocol.
Information about the chemical substances contained in the fabric dye was requested from the
manufacturer by the Communicable Disease Unit
on Monday, but not received until Tuesday afternoon.
No air or water samples were taken. Therefore it
was difficult to be certain if the clean-up was
complete.
The Local Authority took initial health advice on
the incident from the Health and Safety Executive, rather than the Health Authority.
Consideration was given on Tuesday to issuing a
leaflet to local households about asbestos, but it
was decided that it was inappropriate at that stage.

Lessons learned
In a spirit of learning from the incident, the Local
Authority and Communicable Disease Unit have
had further discussions about:
1. Health advice for off-site incidents. This should
normally come from the Health Authority
2. Whether the Local Authority could act as a failsafe to help ensure that the Communicable Disease Unit is informed of significant incidents
3. When environmental sampling is appropriate, and
whether Local Authorities have the capacity to
collect, analyse and interpret them.
4. Pro-actively developing an asbestos public information leaflet for people living close to fires involving asbestos
5. Developing criteria for commissioning clean-up
operations involving asbestos
Commentary
Virginia Murray
Many chemical incidents have bypassed advice from
Health Authorities. It is only by persistence and
sharing of information with the relevant agencies
about the roles and responsibilities of public health
in response to chemical incidents that systems can
be developed locally to improve local structures and
communications. Consider reviewing again the information from NHSE on PLANNING FOR MAJOR INCIDENTS THE NHS GUIDANCE, which
can be found on the following web site
http://www.doh.gov.uk/epcu/epcu/index1.htm

Page
Page1414

Chemical Incident Report from the Chemical Incident Response Service


If Evacuation is to occur ...
As a result of the two Devon incidents the following have
been prepared to assist other public health departments
who are faced with evacuation. These are:
A checklist for medical aspects of evacuation
A leaflet to be distributed to those being evacuated
A checklist with the criteria to return those evacuated
home safely
These Checklists have been prepared for comment by Dr
Sanjay Kinra, Specialist Registrar in Public Health Medicine, South West Devon Health Authority with the CIRS
team.
Checklist for medical aspects of evacuation
Availability of a suitable shelter for evacuees unaffected by the incident
Confirmation from Local Authority and other emergency services that the shelter is not likely to be
downwind of any contamination
Arrangements for first aid and medical care for the
evacuees
Residents should be reminded to take their regular

July 2000

medications and spectacles, hearing aids, walking


frame or stick, if any
Residents should be reminded to close their doors and
windows, secure their homes before leaving, turn heating to minimum in winter and off in summer and turn
off mechanical ventilation, if any

Criteria for returning home


Incident under control and not expected to escalate
The residential premises considered safe for residents
Where necessary, environmental sampling and analyses to provide risk assessment information in residential premises
Where necessary discuss results with a medical toxicologist from a Chemical Incident Provider Unit
Evacuation leaflet provided explaining the situation
and actions on returning such as opening all windows
and doors to vent premises for appropriate period of
time
Advice about whom to contact if any ill health develops, such as NHS Direct, general practitioner or local
Accident and Emergency Department
Any comments on these checklists please send by email to virginia.murray@gstt.sthames.nhs.uk

Draft Information Leaflet

IMPORTANT INFORMATION FOR PEOPLE BEING EVACUATED


YOU ARE BEING EVACUATED TO AN EMERGENCY REST CENTRE
ESTABLISHED BY THE LOCAL COUNCIL
The basic facilities you can expect at the emergency rest centre are:
Safe shelter
Refreshments
Accommodation for domestic pets
Reliable information about the incidents and when it is safe to return home
First aid

Please consider bringing with you the following


All regular medication, if any
Spectacles, hearing aid, walking frame or stick, if any
Address book and your mobile telephone, etc, if any
Things for daily living such as tooth brush, towel, change of underwear
Things you may need for your baby such as warm clothing and milk powder
Your family and pets, if any
Your cheque books, credit cards and/or money

Before you leave your home remember to


Close all your windows and doors
Turn heating to minimum for winter, off for summer
Turn off any mechanical ventilation
Secure your home

Thank you for your co-operation


Page 15

Chemical Incident Report from the Chemical Incident Response Service


COMAH AND THE HUMAN
RIGHTS ACT 1998
Adrian Cooper, Barrister
COMAH
The Control of Major Accident Hazards Regulations
1999 (COMAH) came into force on the 1st April
1999. They apply to establishments where specified
dangerous substances are kept in specified quantities
(regulation 3).
The operator of every such establishment has a number
of obligations including to notify and keep informed
the competent authority which in England and Wales
is the Health & Safety Executive and the Environment
Agency acting jointly. Each operator must have an onsite emergency plan (regulation 9). Each local authority
must have an off-site emergency plan for each relevant
establishment in its area (regulation 10). In preparing
the on-site plan the operator must consult the health
authority for the area. In preparing the off-site emergency plan the local authority must consult the health
authority for the area. Emergency plans must be reviewed and tested from time to time (regulation 11).
Any review must take into account changes.within
the emergency services concerned, new technical
knowledge and knowledge concerning the response to
major accidents. An emergency plan whether on- or
off-site must be put into effect when a major accident
occurs or an uncontrolled event occurs which could
reasonably be expected to lead to a major accident
(regulation 12).
In summary although the major obligations under COMAH are on the operator, the HSE, the EA and the local authority, health authorities have an important role
which appears to be reactive i.e. responding to the consultation. However the effect of the Human Rights
Act 1998 (HRA) may be to require health authorities
to be more proactive.
The Human Rights Act
The HRA comes into effect on the 2nd October 2000. It
gives direct effect to the European Convention on Human Rights (ECHR). Its primary application will be
between individuals and public authorities including
health authorities and hospital trusts as well as local
authorities. Section 6(1) states that:
It is unlawful for a public authority to act in a way
which is incompatible with a Convention right.
Section 6(6) provides that:
An act includes a failure to act..
Section 7 provides that an individual who claims that a
public authority has acted or proposes to act in a way
which is incompatible with his or her Convention right
may bring proceedings in court.
Therefore an individual or a company may bring pro-

July 2000

ceedings against a health authority claiming that it


has acted or failed to act or is about to do so in a way
which is incompatible with his or her Convention
rights.
Convention rights
How might this affect health authorities in relation to
their role under COMAH and more generally? The two
Convention rights most relevant will be those in Articles 2 and 8. Article 2 states that:
Everyones right to life shall be protected by law.
Article 8.1 states that:
Everyone has the right to respect for his private
and family life [and] his home.
Article 2: the right to life
Article 2 places on public authorities a positive duty to
protect life by taking appropriate steps to safeguard it.
In Osman v United Kingdom, decided by the European Court of Human Rights on the 28th October 1998,
the Court decided in relation to the positive obligation
to protect the right to life, in the context of the prevention and detection of crime, that:
..it must be established [by an applicant for
legal redress] that the authorities knew or
ought to have known at the time of the existence of a real and immediate risk to..life.
and that they failed to take measures within the
scope of their powers which, judged reasonably, might have been expected to avoid that
risk.
This principle could apply to health authorities in the
area of public health. The Court stated more generally:
..it is sufficient for an applicant to show
that the authorities did not do all that could be
reasonably expected of them to avoid a real
and immediate risk to life of which they have
or ought to have knowledge.
Health authorities functions under COMAH should be
understood in that light.
Article 8: the right to home and family life
Under Article 8 two decisions of the European Court
of Human Rights have shown the obligation of regulatory public authorities to take positive steps to protect
individuals rights to respect for their private and family life and home.
In Lopez-Ostra v Spain (1994) 20 EHRR 277 the
applicant lived in a town with a heavy concentration
of leather industries. A waste treatment plant was
built 12 metres from the home where she lived with
her family. In 1988 the plant began operating without a licence and caused fumes, smells and contamination which caused local inhabitants including the
applicants daughter to become seriously ill. The
Page 16

Chemical Incident Report from the Chemical Incident Response Service


European Court for Human Rights found a breach of
Article 8 on the basis that the local authority had permitted construction of the plant and may have failed
to prevent the dangerous emissions from it. In the
opinion of the Court the question was whether the
relevant public authorities had adequately protected
the applicants right to respect for her home and for
her private and family life. In the Courts view they
had not. The regulatory authority had resisted judicial
decisions by appealing two separate orders to close
the plant.
In Guerra v Italy (1998) 26 EHRR 357 the applicants lived 1 kilometre away from a fertiliser factory
in which an explosion took place causing 150 people
to be hospitalised for acute arsenic poisoning. The
applicants focused on the regulators failure to implement the
Seveso Directive on major accident hazards
and in particular the obligation to inform local
inhabitants of the details of the hazard posed,
safety measures and plans for emergencies
and procedures including evacuation in the
event of an accident.
The Court found a breach of Article 8. The Court
concluded that the direct effect of toxic emissions
on the applicants right to respect for their private
and family lives means that Article 8 is applicable.
Although the public authority did not directly interfere with this right it failed to take steps to ensure
effective protection. The Court further stated:
The applicants had waitedfor essential information that would have enabled them to
assess the risks they and their families might
run in the event of an accident at the factory.
Conclusion
These cases have a clear relevance to the functions of
public authorities with responsibilities under COMAH including health authorities. They seem to suggest that under the HRA a pro-active rather than reactive role will be required.
References
The authoritative version is the Queen's Printer copy
published by The Stationery Office Limited as the
Human Rights Act 1998, ISBN 0 10 544298 4,
4.85 sterling. For details of how to obtain a printed
copy see How to obtain The Stationery Office Limited titles.
http://www.hmso.gov.uk/acts/acts1998/19980042.
htm
The authoritative version is the Queen's Printer copy
published by The Stationery Office Limited as the
The Control of Major Accident Hazards Regulations 1999, ISBN 0 11 082192 0, 5.80 sterling. For
details of how to obtain an official copy see How to
obtain The Stationery Office Limited titles.
http://www.hmso.gov.uk/si/si1999/19990743.htm

July 2000

Draft Checklist for COMAH information


requirements for Health Authorities
Dr Terry Mathews, Consultant in Communicable Disease
Control, South Humber Health Authority
In collaboration with other organisations concerned with
COMAH plans, the following list are the main headings
for a Health Authority to consider:
SITE
main business and processes undertaken
neighbouring sites/pipelines
building construction especially asbestos content
personnel employed: numbers day/night/weekend
contact phone numbers including Occupational Health
Service contact names and numbers
CHEMICALS
type and volume of agents used/stored, UN, CAS numbers, etc
intermediate products of processes
effects of exposure (include ingestion) to each agent
(and intermediate products - intended and
"accidental"), likely combinations, products of combustion/explosion if available; occupational exposure
limits etc
decontamination, first aid, and treatment recommendations for each agent
Personal Protective Equipment recommendations
any antidotes applicable and where to obtain (on site or
elsewhere)
potential for long term contamination
LOCAL AREA/ POPULATION AT RISK
area profile ? industrial/residential/mixed;
population density
high risk groups e.g. nursing/residential home; schools.
nurseries, health care facilities
advance advice given to local population (form of
alarm, action to take)
water sources and courses, including private supplies
land use ?agriculture ?what
road/rail/water communications with preferred routes
used for transport on and of site
potential evacuation centres
OTHER
likely receiving hospital and decontamination facilities,
etc
list of GPs serving locality
?prevailing winds (of any value?)
local topography (e.g. hollows where heavy agents can
collect)
Other issues e.g. notification, information cascade, media handling etc would be part of a generic plan as for
other chemical incidents
Any comments on this checklists please send by e-mail to
terry.matthews@shumber-ha.trent.nhs.uk or to virginia.
murray@gstt.sthames.nhs.uk
Page 17

Chemical Incident Report from the Chemical Incident Response Service


APELL:

Awareness and Preparedness for


Emergencies at Local Level
Dr Ernst Goldschmitt, United Nations Environment Programme, Tour Mirabeau, 39-43 Quai Andr-Citroen,
75739 Paris Cedex 15, France.
E-mail address, ernst.goldschmitt@unep.fr
Abstract
Awareness and Preparedness for Emergencies at Local
Level (APELL) is a tool developed by the United Nations
Environment Programme's Division of Technology, Industry and Economics ( UNEP DTIE ) in conjunction with
governments and industry. Its purpose is to minimize the
occurrence and harmful effects of technological accidents
and emergencies, particularly, though not exclusively, in
developing countries.
APELL was launched in 1988 following various industrial
accidents affecting adversely human health and the environment. The program addresses all emergencies related
to any industrial or commercial operation that have a potential for fire, explosion, spills, or releases of hazardous
materials. Such technological emergencies can result from
human activity or as consequences of natural disasters
such as earthquakes and flooding.
APELL consists of two parts:
providing information to the community; and
formulating a plan to protect people, property, and the
environment, referred to as "Emergency Response".
This article describes the APELL ten-step process for effective disaster-prevention planning and some of the tools
that have been developed to implement it, in particular the
APELL Handbook.
1. What is APELL ?
Awareness and Preparedness for Emergencies at Local
Level (APELL) is a tool developed by the United Nations
Environment Programme's Division of Technology, Industry and Economics office (UNEP DTIE), in conjunction
with governments and industry. Its purpose is to minimize
the occurrence and harmful effects of technological accidents and emergencies, particularly, though not exclusively, in developing countries. APELL provides a well
structured, detailed description of how to develop a coordinated, integrated, and well functioning emergency response plan for local communities. The strategy of the
APELL approach is to identify and create awareness of
risks in an industrialized community, to initiate measures
for risk reduction and mitigation, and to develop preparedness for emergencies in industries, the local governments,
and the population.
APELL was launched in 1988, following various industrial accidents that had adverse impacts on health and the
environment. Some well-known examples of such accidents include Bhopal in 1984 and the Sandoz warehouse
fire near Basel in 1986, which resulted in extensive contamination of the Rhine.

July 2000

APELL can be useful in any situation that requires joint


planning for disasters by several parties, eg. government,
industry, and local communities. Being aware and prepared means having workable, realistic plans if an accident
occurs. It also means creating a better understanding of
local hazards, which in turn should lead to action designed
to prevent accidents from happening at all.
It is now universally acknowledged that every disaster,
whatever the cause, may have an environmental impact.
While some major industrial accidents can be contained
within the boundaries of the plant, in other cases, there are
impacts on the surrounding neighbourhood, with adverse
short- or long-term consequences affecting life, lifesupport systems, society, or property. This is even more
so for accidents arising from transport of dangerous goods,
e.g. by road, rail, or pipeline, through or close to populated
areas, since by definition there is no boundary fence in
these cases. The extent of the losses from these accidents
depends largely on the actions of the first responders to an
emergency, both at the scene of the accident and within
the surrounding community.
Clearly, adequate response to such situations calls for cooperation between various institutions and individuals.
This can be achieved only if there is awareness within the
community of possible risks and of the need for joint preparedness to cope with the consequences of these risks.
2. The Objectives of the APELL Handbook
The APELL Handbook describes a process for improving
community awareness and emergency preparedness and
achieving co-operation between the various parties involved.
The APELL Handbook is a detailed guide to a process that
trains the reader to:
develop and practise a community emergency response
plan for any type of accident or disaster;
consider all kinds of risks, i.e., hazardous installations,
identify and initiate measures to reduce risks (refer Figure 1 for probability and seriousness of risks);
combine all technical resources and expertise available
in an industrialized community for responding to emergencies;
Provide information to the community, thus creating
"Community Awareness.
Any member of the following involved groups may initiate the APELL process: industry managers, local authorities, or community leaders. However, there must then be
direct and close interaction between the representatives of
the three partners. A "bridge" is created by means of the
"APELL Co-ordinating Group". The Co-ordinating Group
is the critical management team that develops and oversees
the APELL Process at the local level. Their job is to
gather facts and opinions, assess risks, initiate measures
for risk reduction, evaluate approaches and generally organize the personnel and the resources available in the
community to produce an emergency response plan.

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Chemical Incident Report from the Chemical Incident Response Service

July 2000

of the most common observations are:


lack of awareness of actual risks, mainly within the
population living adjacent to such risks;
inadequate preparedness of emergency responders and
the entire organisation responsible for response, mitigation, and relief particularly concerning technological
risks (i.e., risk-specific training and suitability of available equipment, co-ordination between the acting agencies, practising of emergency plans, provision of medical services);
inadequate capacity for handling emergencies at the
local level. Any kind of emergency requires the most
competent, efficient, and immediate response capacity
in the community. Emergency response strategies have
to focus on strengthening these capabilities at the local
level as the main key for effective mitigation.
Figure 1: The key to awareness and preparedness is the
identification and evaluation of risks, the probability of an
incident, and the potential storage facilities and transport
of hazardous goods, earthquakes and flooding
APELL addresses all emergencies with potential for fire,
explosion, spills, or releases of hazardous materials. The
possibility of "combination accidents" should be noted at
this point, for example, an earthquake that triggers an
emergency in a refinery or chemical factory. The determination of which potential hazards should be covered by
the APELL process is in principle the result of a risk assessment. In most cases, however, common sense will be
sufficient to identify the facilities or areas that present a
risk of a major accident. The criteria of accidents (lists of
substances and threshold levels) given in international or
national regulations or recommendations may also provide
guidance.
APELL is flexible. Countries differ in culture, value systems, legal and regulatory requirements, community infrastructure, and response capabilities and resources. Their
industries present different potential dangers. However,
they have one common need - the need to cope with a major technological accident affecting a local community.
The APELL Handbook provides the basic concepts for the
development of action plans, which can be adapted to local conditions. No legislation or regulations are needed.
Since the lessening of health and environmental impacts
depends on the speed and scope of the initial local response, local participation is emphasized. It is recognized,
however, that national governments and the chief executive officers of industries have a fundamental role in promoting and supporting these local efforts. Industry associations also have an important part to play in encouraging
industry participation.

At the local level, there are three very important partners


who must be involved if APELL is to succeed (refer Figure 2):
Local authorities. These may include provincial, district, and city or town officials, either elected or appointed, who are responsible for safety, public health,
and environmental protection in their area.
Industry. Industrial plant managers from either stateowned or private companies are responsible for safety
and accident prevention in their operations. They prepare specific emergency measures within the plant and
review their application. But their responsibilities do
not stop at the boundary fence. As leaders of industrial
growth and development, they are in the best position to
interact with leaders of local authorities and community
groups in order to create awareness of how the industrial facility operates and how it could affect the environment and to help prepare appropriate community
response plans in the event of an emergency. The involvement and active participation of the plants workforce is also very important.
Local community and interest groups. These include
environmental, health, social, and religious organisations and leaders in the educational and business sectors, and the media, who represent the concerns and
views of their members or constituents in the community.

3. The APELL Partners and Their Responsibilities


When analysing past disasters that have caused traumatic
loss of lives, serious health problems, environmental damages, or property losses, it becomes obvious that these
damages could have been avoided to a large extent. Some

Figure 2 The Basic Principles of the APELL Process:


Communication and Co-operation
Page 19

Chemical Incident Report from the Chemical Incident Response Service


There are other partners, e.g. non-governmental organisations (NGOs). The APELL process is designed to
work with other initiatives to reduce risks and their consequences, not to replace them.
4. The APELL process
The actual process itself in action is the mainspring of
the emergency response plan.
The APELL Coordinating Group, in which all stakeholders should have
a representation, itself does not have any operational role
during an emergency but exists to prepare the various
partners for their tasks if an accident does occur. Members must be able to command the respect of their various constituencies and be willing to work together in the
interests of local safety, well-being, and property security. In particular, local plant managers need to be active
participants and local authority and community leaders
need to know that they are acting with the blessing and
full authority of the most senior managers in their companies. The leader of the Co-ordinating Group should
ideally be able to motivate all sections of local society,
regardless of cultural, economic, educational, and other
dissimilarities, and to ensure their co-operation. This
needs to be kept in mind when choosing the leader.

July 2000

local plan. There may be national government emergency plans in place but there is always the need for an
effective structure at the local level. Industrial facilities
should already have on-site emergency plans. Local authorities and rescue services should have plans to deal
with the consequences of major emergencies. Local hospitals should certainly have their own "major accident
plans" for dealing with large numbers of seriously injured people. The APELL process ensures that all existing plans contribute to the overall integrated, cooperative plan.
5. Community Awareness
Citizens have the right to know if potentially hazardous
materials are being produced, stored, used, or transported
in their communities. There is nothing mysterious about
a community awareness programme. A fenced-in industrial plant can look threatening to the public but much of
the threat disappears when people know what the plant
uses and manufactures and that it has a good safety record and an effective emergency plan. People need to be
informed about potential risks in order to understand
why an emergency plan has been established, how it
works, and what action they are expected to take in an
emergency.

The APELL process consists of ten steps.


6. APELL Worldwide
1. Identify the emergency response participants and esestablish their roles, resources, and concerns.
2

Evaluate the hazards and risks that may result in


emer
emergency situations in the community.

3 Have participants review their own emergency reresponse plans to ensure a coco-ordinated response.
4 Identify the required response tasks not covered by
existing plans.
5 Match
Match these tasks to the resources of the identified
participants.
6

Make the changes necessary to improve existing


plans, integrate
integrate them into an overall community
plan, and gain agreement.

7 Commit the integrated community plan to writing and


obtain approval
approval from local governments.
8 Educate participating groups about the integrated plan
and ensure that all emergency responders
responders are
trained.

Industries all over the world, particularly the chemical


and gas industry, have co-operated with UNEP DTIE in
supporting the application of APELL.
The APELL concept has been successfully introduced in
more than 30 countries and in over 80 industrialised
communities world wide: in Latin America (i.e., Brazil,
Colombia, Chile, Argentina), in Asia (i.e., China, India,
Thailand, Indonesia, and Korea) and in Russia. The
guiding principles of the APELL process for emergency
planning are also practised in the United States and Canada.
Remarkable changes have occurred in many of the communities that have implemented APELL, such as a general safety consciousness and an increased concern for
environmental issues.
APELL is part of a broad cleaner and safer production
programme that UNEP DTIE has launched with the objective of promoting world wide sustainable production
and consumption patterns.
7. The APELL Handbook and Newsletter

9 Establish procedures for periodic testing, review, and


updating of the plan.
10 Educate the community about the integrated plan.
The APELL process is designed to build on any and all
existing emergency plans to create a single co-ordinated

More than 10,000 copies of the Apell Handbook have


been distributed throughout the world. The APELL
Newsletter is published twice a year as a supplement to
UNEP DTIE's quarterly publication Industry and Environment Review.

Page 20

Chemical Incident Report from the Chemical Incident Response Service

July 2000

8. UNEP DTIE Technical Reports (related to APELL


and technological accidents):

Incinerators

TR 3, Storage of Hazardous Materials

Commentary
Virginia Murray, CIRS

TR 8, International Directory of Emergency Response Centres (in co-operation with OECD, 2nd
edition in preparation)

TR 12, Hazard Identification and Evaluation in a


Local Community (prepared with help from Sweden)

Recently on the ccdc-uk e-mail discussion group incinerator anxiety was apparent. CIRS therefore asked for the Environment Agency to provide a comment on current proposals and where Health Authority comment will be required. CIRS is grateful for the information provided but
remains concerned about the precise activity required of
the Health Authority in the consultation process.

TR 19, Health Aspects of Chemical Accidents

Municipal waste incineration

TR 21, APELL Annotated Bibliography (prepared


with help from Canada)

TR 28, Safety, Health and Environmental Management Systems (in preparation)

TR 35, TransAPELL - APELL for accidents arising


from dangerous goods transport

APELL for Port Areas, prepared in conjunction


with the International Maritime Organisation
(IMO) and published by IMO

APELL World-wide, national accounts of the development of APELL in twelve countries

Management of Industrial Accident Prevention


and Preparedness, a training resource kit for use
in universities and colleges

LP Gas Safety, Guidelines for Good Safety Practice


in the LP Gas Industry, prepared together with the
World LPG Association.

Martin Whitworth, Environment Agency

For copies of these publications, or more information


about UNEP, contact: www.uneptie.org
Forthcoming publications:

APELL in the Mining Industry, with special focus


on tailings dam failures.

APELL for Natural Disasters Part I: Flooding

United Nations Environment Programme


Division of Technology, Industry and Economics
39-43, quai Andr Citron
75739 Paris Cedex 15, France
Fax: (33-1) 44 37 14 74
www.uneptie.org
www.uneptie.org/apell/e training day

Introduction
The UK generates around 30 million tonnes of municipal
waste (MSW) every year the majority of which is landfilled. Some 5 million tonnes are diverted from landfill,
mainly through composting of green waste, incineration
and recycling. In the UK an average of 9% of the MSW
is recycled or composted whilst 8% is incinerated.
Currently there are eleven municipal solid waste incinerators (MSWIs) in England and Wales with a total capacity of around 2.7 million tonnes per annum, and new
capacity of around 1.5 million tonnes, although much of
this still requires planning permission, has been authorised by the Environment Agency. In addition, the
Agency is aware of around a further twenty potential
MSWIs.
Regulatory framework and emissions standards
Within the UK incineration processes are regulated under part 1 of the Environmental Protection Act 1990 by
the Environment Agency, the Scottish Environment Protection Agency, the Environment and Heritage Service
Northern Ireland and local authorities. In England and
Wales the Environment Agency is responsible for regulating waste incineration processes under the Integrated
Pollution Control regime by means of an authorisation.
The conditions included in the authorisations require operators to use the Best Available Techniques Not Entailing Excessive Costs (BATNEEC) to prevent the release
of the most polluting substances and, where that is not
possible, to minimise the releases and render them harmless.
MSWIs were the first incineration processes to be subject to EU Directives. In June 1989 the Municipal Waste
Incineration Directive (MWID) was adopted which set
strict emission standards for all existing MWIs which
had to be achieved by 30 November 1996. Many existing
MSWIs ceased operation by this date, as their owners
were unwilling or unable to upgrade to achieve the
tighter standards. All new MWIs built since this date
have to comply with a second sister MWID. Table 1summarises the MWIDs requirements and the existing emission limit values applied by the Agency. In addition, the

Page 21

Chemical Incident Report from the Chemical Incident Response Service


Agency sets limits for oxides of nitrogen and for dioxins
despite these not being required by the MWID. Most
MSWIs achieve or are authorised at 0.1ng/m3 of dioxins.
In order to demonstrate compliance with limits, either continuous emission monitoring systems or extractive monitoring is employed.
Health Issues
Health impacts from waste incineration are not well understood. Published studies generally refer to incinerator
types that have not operated in the UK for some time. International studies too have focused on older units for
which there is no read-across to current plant. The only
recognised guidance on health impacts was prepared by
the Department of Healths (DH) expert committee on the
medical effects of air pollution (COMEAP) who reviewed
the literature and developed a series of coefficients relating
pollutant mass release to morbidity rate which they believed could be applied in some cases. The Agency is
working with DH and the Department of the Environment.
Transport and the Regions to develop national protocols
and standards to assess the impact of emissions on human
health, the food chain and the environment. The new Pollution Prevention and Control (PPC) Regulations will also
require the Agency to consult local Health Authorities on
the impact of new processes so that their advice can be
incorporated into the Agencys decision-making.
The future
Legislation to implement the EUs Landfill Directive (LFD)
has to be introduced into UK law by mid 2001. It will fundamentally change the way waste is managed in the UK, the
most significant requirement being the progressive reduction in the amount of biodegradable municipal solid waste
(MSW) permitted in landfill. For example, by 2020 no more
than 35% of the amount of biodegradable MSW produced in
1995 can be landfilled. In its Waste Strategy, the Government presented a number of scenarios for managing the consequences of the LFD based on mixes of materials recy-

July 2000

cling facilities, composting plants and incinerators. These


estimated that between 21 and 166 new incinerators of
250ktpa would be needed. However, this range is highly
dependent upon the size, type and location of incineration
capacity, and the rate of growth in MSW generation.
The EU is close to reaching an agreed Common Position on
a new Waste Incineration Directive (WID) which will set
even tighter limits than the MWID. It will also set limits for
the first time for oxides of nitrogen and for releases into the
aqueous environment. Potential developers of incinerators
are being informed by the Agency of the likely implications
of the WID at the earliest possible opportunity to allow the
expected standards to be incorporated into the design and
any application for a PCC permit. For most incinerator applications, the standards set out in the WID are achievable
without incurring excessive cost.
Abbreviations for Environment Agency article
BATNEEC: Best Available Technique Not Entailing
Excessive Costs
COMEAP Committee On the Medical Effects of Air
Pollution
EU
European Union
Ktpa
Kilo tonnes per annum
LFD
Landfill Directive
MSW Municipal solid waste
MSWIs Municipal solid waste incinerator
MWID Municipal Waste Incineration Directive
PCC
Pollution Prevention and Control Regulations
WID
Waste Incineration Directive
Key to table
SO2
NOX
HCL
HF
VOC
CO
3tph

sulphur dioxide
oxides of Nitrogen
hydrogen chloride
hydrogen fluoride
volatile organic compounds
carbon monoxide
three tonnes per hour

Table 1: Municipal Waste Incinerator Directive and existing emission limit values applied by the Environment
Agency
mg/m3
Dust

SO2

NOX

HCL

HF

VOC

CO

Coventry and Solihull Waste Disposal Co Ltd

30

300

350

30

20

100

WasteNotts (Reclamation) Ltd

25

100

350

30

20

100

MES Environmental Ltd

20

100

350

30

10

100

MES Environmental Ltd

20

100

350

30

10

100

MES Environmental Ltd

30

100

350

30

10

100

Tyseley Waste Disposal Ltd

30

300

350

30

10

100

Cleveland Waste Management

10

300

350

30

20

100

Sheffield City Council

30

100

350

30

20

100

London Waste Ltd

20

300

350

30

20

100

SELCHP

30

80

350

30

20

80

GM Waste Ltd

30

100

200

30

20

100

MWID (new plant >3tph)

30

300

No limit

50

20

100

Operator

Page 22

Chemical Incident Report from the Chemical Incident Response Service


CIRS TRAINING DAY REPORTS
PESTICIDE CHEMICAL INCIDENTS - An appreciation of a CIRS Training Day
Thursday 8 June 2000
Dr. Paul Bingham Consultant in Public Health Medicine,
Isle of Wight Health Authority
The first CIRS training day on pesticides held on 8 June
2000 at St Thomas' Hospital, London was well attended
and well received.
A stimulating, audience friendly introduction to the toxicology of the most important pesticides was given by a
series of speakers and illuminating table-top exercises ensured delegate participation and exchange of experience.
In particular, the importance of involving the police in an
acute incident was underlined.
Guest speakers from the Health and Safety Executive and
Environmental Agency spoke on specific aspects of their
work (Pesticide Incident Appraisal Panel and modelling
and mapping of environmental pesticide levels) and while
this was informative it also underlined the complex tangle
of government responsibility for regulating and enforcing
pesticide control. Perhaps the tangle is unsurprising when
it is much easier to identify those who benefit from pesticides (commerce, consumers) from those suffering disbenefits (the environment etc).
A welcome feature of the day was the inclusion of two
representatives from the Pesticide Action Network that is
pressing for minimal use of pesticides. They also provide
support to individuals who consider that they have been
affected by pesticides. While health economies/local authorities are hopefully getting better at responding to acute
pesticide incidents, it is apparent that long term surveillance/support, where a medical model is not always helpful, is less good. Delegates were encouraged to consider
the Report on Organophosphates Sheep Dip, 1998
Reference
Royal College of Physicians and the Royal College of
Psychiatrists. Organophosphate Sheep Dip: Clinical aspects of long-term low-dose exposure. London: Royal
College of Physicians; 1998.

If other public health professionals would like


CIRS to run the training day again please contact
Virginia Murray by phone 020 7771 5383 or by email on virginia.murray@gstt.sthames.nhs.uk
CIRS UPDATE FOR CsCDC
Report from the Thursday 15 June 2000.
Dr Charles Irish. Consultant in Communicable Disease
Control, Dorset Health Authority.

July 2000

by Dr. Ernst Goldschmitt, from the United Nations Environment Programme (UNEP) Paris, who described the use
of Awareness and Preparedness for Emergencies at a Local Level (APELL), a process to minimise the harmful effects of technological accidents. Chemical incident exercises included the possible consequences of bromate testing of drinking water, for which there is no precedent in
the UK.
The European Human Rights Act 1998 will incorporate
the European Convention on Human Rights into UK legislation on 2nd October 2000. Articles 2 and 8 of the Convention will be of most likely relevance to Health Authority emergency planning. Article 2 upholds the right to life.
Article 8 upholds the right to respect for private and family
life. Section 6 of the human rights act will allow any person to bring a direct action against a public authority, such
as a health authority, acting in a way which is incompatible with that individuals convention rights. Most importantly, under Convention Articles 2 & 8 this could also
include failure to act (see pages 16-17)
It will be the legal responsibility of the health authority to
ensure that, as part of the emergency planning process, it is
adequately consulted by the operator in the formation of
the on-site plan and informs the public about risks. Similarly, for the off-site plan, the health authority will be legally required to ensure that it is properly consulted by the
local authority to provide appropriate health advice.
Dr. Ernst Goldschmitt described APELL, a process
developed by UNEP with governments and industry, to
minimise the occurrence and harmful effects of
technological accidents and emergencies. APELL was
launched in 1988 in response to industrial accidents such
as Bhopal in 1984 and the Sandoz warehouse fire near
Basel in 1986, which produced extensive contamination of
the Rhine. So far APELL has been applied mainly in
developing countries. However, incidents such as the
firework factory explosion at Enschede (Netherlands) on
13th May 2000 have illustrated a lack of awareness of risk
by local residents even in the developed world (see pages
18-21)
APELL is a two part process, aiming to provide information to the community and develop an emergency response plan to protect people, property and the environment. A co-ordinating group of all interested parties is
brought together to produce co-operation between the local community, local government and industry and prepare
the members for their roles should an accident occur.
Similar principles to those of APELL are already applied
in developed countries such as the USA and Canada. It
remains to be seen whether APELL would provide a useful framework for the UK, where emergency planning is
already advanced. However, APELL could provide a
means of strengthening the health input into local emergency planning and improving risk communication to the
public, in line with the requirements of the European Human Rights Act 1998.

The day began with a presentation by Adrian Cooper, Barrister, about the implications for emergency planning of
the European Human Rights Act 1998. He was followed
Page 23

Chemical Incident Report from the Chemical Incident Response Service

July 2000

Air Contamination Incidents


Tuesday 17 October 2000

CIRS
TRAINING Programme
AUTUMN 2000

(for CsCDC, CsPHM and Specialist Registrars and


Local Authority Environmental Health Practitioners).

How to Respond to Chemical Incidents


Friday 22 September 2000

Course will be held at Sherman Education


Centre, Thomas Guy House, Guys Hospital, next to London Bridge
This specialist training day will cover a selection of
issues focused on the management of acute and
chronic air contamination incidents. The day will be of
most benefit to those who have already attended a
general training day on how to respond to chemical
incidents, or have been involved in the management of
air related chemical incidents.
A maximum of thirty places are available for this
course. These days are charged at 50 for those in
Health Authorities or Local Authorities holding contracts with CIRS and for others at 70 per person.
Bookings will be confirmed upon receipt of the fee.
Those attending the day will receive a Certificate of
Attendance and CPD/CME information.

(for Public Health Consultants, Specialist Registrars,


Control of Infection Nurses and other Public Health
staff on call and Local Authority Environmental
Health Practitioners).

Course will be held at Sherman Education


Centre, Thomas Guy House, Guys Hospital, next to London Bridge
This one day course is an introduction to chemical incident response. Topics covered will include a review
of recent chemical incidents, how to respond to chemical incidents and lessons learnt, decontamination, exercises and information available from CIRS and the
Medical Toxicology Unit.
Two free places per Health Authority holding a Service Level Agreement with CIRS are available for this
introductory course and these will be allocated on a
first come first served basis. A maximum of 80 places
are available. Bookings will be confirmed upon receipt of a refundable 20 deposit. The deposit will be
returned to those attending the day along with their
Certificate of Attendance and CPD/CME information.

Update for CsCDC on Clusters


Friday 8 December 2000
(for CsCDC and CsPHM who have responsibility for
chemical incidents and who have attended previous
courses).

Course will be held at Sherman Education


Centre, Thomas Guy House, Guys Hospital, next to London Bridge
The updating course is designed for CsCDC and
CsPHM who have previously attended a CIRS training
day and who have specific responsibility for their
Health Authority response to acute and chronic chemical incidents. It is expected that participants will have
had some experience of dealing with chemical incidents. The day will consist of acute and chronic incident exercises, lessons learnt, and will concentrate on
issues related to clusters. The training pack will include exercises for you to run within your Health Authority.
One free place per Health Authority holding a Service
Level Agreement with CIRS is available for this
course and these places will be allocated on a first
come first served basis. A maximum of twenty five
places are available on this course. Bookings will be
confirmed upon receipt of a refundable 20 deposit.
The deposit will be returned to those attending the day
along with their Certificates of Attendance and CPD/
CME information.

Water Contamination Incidents


Thursday 23 November 2000
(for CsCDC, CsPHM and Specialist Registrars and
Local Authority Environmental Health Practitioners).

Course will be held at Sherman Education Centre, Thomas Guy House, Guys
Hospital, next to London Bridge
This specialist training day will cover a selection of
issues focused on the management of water contamination incidents. The day will be of most benefit to
those who have already attended a general training
day on how to respond to chemical incidents, or have
been involved in the management of water related
chemical incidents.
A maximum of thirty places are available for this
course. These days are charged at 50 for those in
Health Authorities or Local Authorities holding contracts with CIRS and for others at 70 per person.
Bookings will be confirmed upon receipt of the fee.
Those attending the day will receive a Certificate of
Attendance and CPD/CME information.
Chemical Incident Report
Edited by Dr Virginia Murray, prepared and distributed in
collaboration with Rico Euripidou, Joan Bennett, Ivan
House and the staff of the Chemical Incident Response Service.
The data remains the copyright of the Chemical Incident
Response Service, Medical Toxicology Unit, London and
as such should not be reproduced without permission. It is
not permissible to offer the entire document, or selections,
in what ever format (hard copy, electronic or other media)
for sale, exchange or gift without written permission of the
Director, Chemical Incident Response Service. Use of the
data for publications and reports should include an acknowledgement to the Chemical Incident Response Service, London as the source of the data.

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