Since leaving USARNORTH and starting Watchtower Defense, it has become very aware I participated in a program designed to defeat threat at its foundation but hardly touched the reality HAZMAT Technicians are faced with in the field. In so many ways, through true terrorism-related responses we’ve conducted under Federal contract, I have learned the standards to which I held each WMD-CST simply do not exist.
Chain of Custody
I used to issue (what I thought were) well-earned No-Go’s to very hard working CST Survey Teams for “violating” chain-of-custody principles. During the aforementioned responses we extracted, overpacked, and submitted as evidence illicit materials worth tens of millions of dollars on the black market. The apprehended individuals were part of a US-recognized terror organization and each earned life sentences.
In each of these cases as the HAZMAT entry team, we never started a chain-of-custody. When we discussed this with the investigatory lead, he was adamant we didn’t need to provide any paperwork to support his case – and certainly not a chain-of-custody. I’m going to guess he was right being that each of the perpetrators will spend the remainder of their days in prison.
As a CST Evaluation Chief, I checked my watch against the 90 minutes it took for a WMD-CST to respond, occupy, and make entry. Being the HAZMAT Team Chief for Watchtower Defense while working the Ebola Crisis of 2014 and three extremely high profile illicit materials cases, I cannot begin to comprehend the complete irrelevance of time during a real-world HAZMAT event. Simply, other than to a Survey Team Leader establishing a step-off time hack, time does not matter.
One who has never had the pleasure of making Level A entries will never understand the importance of research, communication, and preparation required of every single member of a HAZMAT Team. Under no circumstances should a time restriction be placed on a CST working in an atmosphere that could very well present them with life-altering circumstances. To rob anyone of an ounce of preparation in the name of requiring an entry is extremely shortsighted and generates a system of failure where it simply does not exist.
In every response scenario, be it our role as the operational lead during the Ebola Crisis in 2014 or a confiscation of illicit materials being smuggled across the US Border, our ETA has always been the lead topic of discussion until we got boots on the ground. As a Division Chief at CSTA, I always required WMD-CSTs to push an ADVON out the door as soon as humanly possible. In many cases this push met significant resistance and – sometimes – with good reason. However, in our response experience for both our government and commercial clients, ‘when can you get here?’ has always been the very first question during an emergency.
Placing this requirement on WMD-CSTs deploying to one of our ARNORTH CLT or TPE evolutions was a reality that deserves attention. Further, it’s a reality we ask our WMD-CST customers to train for now even as a response training contractor. The requirement for a Rapid Response Force deploying within a few minutes is a reality and should certainly be addressed in a monthly or quarterly training event.
How? It’s as simple as having two of your junior NCOs deploy 2-3 hours ahead of the remainder of the team. Create information requirements not normally associated with their job descriptions and ensure the rest of the team (and perhaps the entirety of the CST community) receives those critical pieces of information. Operationally, ensure the ‘left behind’ portion of the team is managing the response from afar or while enroute. If nothing else, as a commander, you will certainly find both weaknesses and strengths in your team.
Time In = Time Out
The NFPA 472 is a great guideline but in no way does it dictate how any response organization manages HAZMAT Operations. The time-on-target is dictated by the CST Commander and absolutely no one else. For reference, please be sure to read the 29CFR1910.120 and the aforementioned NFPA guideline. There may be situations when an Incident Commander requires supporting response agencies to abide by the NFPA guideline, but to assume they would dictate to you the rest requirements of your team is completely arbitrary guesswork.
In July of 2014 we removed $1.6M of illicit contraband where the ambient air temperature was 108F and the temperature inside of the confined space was 123F. It took us seven (7) 90-minute entries to complete the operation and – during breaks – we rehydrated and had chow. Some of our breaks were 20 minutes while others lasted for an hour. Could you imagine us telling our customer we had to rest for 90 minutes or more during our entries? We would have been asked to leave. And the next training manager – be them ARNORTH or otherwise – that tells you Time In = Time Out should also be asked to leave. Simply, it isn’t in the same ballpark as reality.
On the flip side of that, between our last Ebola remediation entries, we rested long enough to have dinner and take a snooze. As a leader, get your survey folks what they need to rest and rehydrate. Trust your people, trust your leadership, and march onward.
Sifting Through the Minutiae
Lastly, I’d like to address the mole hills we put before the CST Command Staff. When we found a team was headed towards excellence, we often spent time addressing chock blocks on vehicles not being in place, marking communications lines as a trip hazard, and the dreaded man down emergency. While all are important and probably have their place in a TPE write-up, having them become showstoppers while presenting the CST with a scenario killing hundreds of civilians is revealing of the experience you’re receiving from your training/evaluation team.
I appreciate the time I spent as a CSTA Division Chief in Regions 7, 8, 9, and 10. We had some excellent venues and put on some fantastic training events with some awesome WMD-CSTs. Simply, I wish I knew then what I know now. We would have turned the WMD Response industry upside down!