In the ever-changing environment of homeland security policy and strategy, a discipline that has yet to fully mature is highlighted in the National Strategy for Chemical, Biological, Radiological, Nuclear, Explosives (CBRNE) Standards issued in May 2011. That document – an evolution of disparate federal agency regulations and procurement guides – and the interagency program it led to, aims to simplify the complex process of ensuring that state and local first responders possess effective and robust CBRNE preparedness capabilities.
The strategy, as proposed, has two major goals: (a) to coordinate the development and promulgation of public safety CBRNE standards; and (b) to ensure the proper certification of burgeoning technologies. What remains to be seen, however, is how this new interagency approach will be any different from past efforts, including those carried out by the current Inter-Agency Board (IAB) for Equipment Standardization and Interoperability and the U.S. Department of Homeland Security’s SAVER (Systems Assessment and Validation for Emergency Responders) program.
The DHS Approach In 2004, the Department of Homeland Security (DHS) adopted the first set of CBRNE personal protective equipment (PPE) standards – governing such gear as personal respirators, escape masks, and protective garments – for state and local first responders. These National Fire Protection Administration (NFPA) and National Institute for Occupational Health and Safety (NIOSH) standards were used as procurement guidelines for the millions of dollars offered annually to state and local governments through various DHS grant programs. In 2007, a review of the 2004 policy resulted in the adoption of three NFPA standards that had not been addressed by the 2004 policy.
Established in 2004, the SAVER program, which operates out of the DHS’s Science and Technology Directorate, uses already established DHS standards – including but not limited to those in the CBRNE field – to assist first responder agencies in making procurement decisions. SAVER provides commercial product evaluations and distributes publications in print and via the DHS Responder Knowledge Base website. This program aims to reduce the time it takes for an agency to properly investigate equipment solicitations by producing a comprehensive DHS Authorized Equipment List.
Interagency Cooperation To foster an integrated approach to CBRNE equipment procurement decisions, the National Institute for Standards and Technology (NIST) spearheaded a coordinated effort to ensure a common standardization – or at least a better coordinated approach to the elements of CBRNE equipment standardization – through the IAB. The IAB brought together law enforcement, fire, and homeland security officials to: (a) discuss common elements of CBRNE standardization policy – including areas where standardization could not be achieved across disciplines due to the unique nature of certain missions; and (b) evaluate equipment performance standards for use in federal equipment grants. The result of the IAB’s seven sub-working groups is a much more comprehensive Standardized Equipment List (SEL).
With both DHS and interagency standardized equipment lists to choose from, the Federal Emergency Management Agency (FEMA) Responder Knowledge Base program developed an integrated list to “simplify” responder agencies attempting to navigate through the extensive equipment list.
New-Old Approach The 2011 National Strategy designates the National Science and Technology Council to lead the effort to “establish and coordinate the implementation of an integrated standards development approach.” This approach rests on the execution of five strategic goals:
Goal 1: Establish an interagency group for CBRNE standards to promote the coordination of these standards among federal, state, local, and tribal communities;
Goal 2: Coordinate and facilitate the development of CBRNE equipment performance standards and promote the use of standards for federal, state, local, and tribal communities;
Goal 3: Coordinate and facilitate the development and adoption of interoperability standards for CBRNE equipment;
Goal 4: Promote enduring CBRNE standard operating procedures for federal, state, local, and tribal use to improve national preparedness and response; and
Goal 5: Establish voluntary CBRNE training and certification standards for the federal, state, local, and tribal communities and promote policies that foster their adoption.
However, although the 2011 National Strategy highlights the need for interagency cooperation, as stated in Goal 1, very little mention is given to the work of NIST, and no reference at all is made to the IAB as the current mechanism for the interagency coordination of the Board’s seven member agencies. The IAB’s website presents a Strategic Plan for the Board. Nonetheless, it still is not clear as to whether the Plan will remain the mechanism for coordination under the new approach. Similarly, no mention is made in the National Strategy of the existing SAVER and IAB equipment lists that first responder agencies have become accustomed to use as they make their procurement decisions. As a result, it is possible that at least some of these commercial products, already thoroughly examined, may have to be re-evaluated using a new set of standards and testing protocols.
The first Annual Report of the IAB, issued in 1999, emphasized that this issue should be “addressed now, through nationally recognized standards, before the advent of multi-agency, multi-jurisdictional WMD [Weapons of Mass Destruction] incidents.” As of late last year, though, the necessity of developing a National Strategy to address, and resolve, this largely bureaucratic issue shows how little has been achieved in the arena of interagency cooperation – specifically including the failure to reach universal agreement on the standardization of CBRNE equipment.
The Current Grant Cycle As state and local first responders review their annual budget and grant program requests, they must determine which technical resource they will leverage toentify capable, tested, and approved replacement – or new – CBRNE protective equipment. However, until and unless the interagency approach can coalesce around one standardization body for both fire and law enforcement disciplines, it seems likely that the various agencies involved will still have two choices: SAVER or IAB.
Today, U.S. homeland security agencies, at all levels of government, and private-sector industries are obviously concerned about current and probable future budget cuts affecting CBRNE incident preparedness. Moreover, in the age of cyber-disruption, WMDs may be losing focus as the primary non-conventional homeland security threat. However, the importance of protecting the nation’s first responders is no less important than it has been over the past decade. The 2011 National Strategy for CBRNE Standards re-affirms the federal government’s commitment to preparing for the CBRNE contingencies – but only time will tell if it can ease the complexity of equipment procurement for local police and fire departments.
For additional information on: May 2011 National Strategy for Chemical, Biological, Radiological, Nuclear, Explosives (CBRNE) Standards, visit http://www.whitehouse.gov/sites/default/files/microsites/ostp/chns_cbrne_standards_final_24_aug_11.pdf
________________________ Jordan Nelms is a Homeland Security specialist at Witt Associates, a public safety and crisis management consulting firm. He was on the Witt Associates planning team that assisted a major community police department in conducting an independent assessment of Weapons of Mass Destruction (WMD) response capabilities. Jordan is currently supporting the Presidential Policy Directive 8 (PPD-8) Program Executive Office at FEMA. He is also a published researcher with Johns Hopkins University’s Department of Homeland Security Center of Excellence: National Center for Preparedness and Catastrophic Event Response Center (PACER).