September, 2005

International Association of Fire Fighters – Canadian Office

Submission to federal Emergency Preparedness Act Review

Comment 1

The International Association of Fire Fighters submits that the scope of the Emergency Preparedness Act should be revised to formally and specifically recognize that Canadian cities are potential targets for Chemical, Biological, Radiological, or Nuclear (CBRN) attack, and also that municipal fire fighters and other first responders are a critically important element in ensuring the survivability of Canadians in the aftermath of a CBRN attack or any other kind of major disaster.

Military-based teams are hours, if not days from deployment to the scene of a CBRN attack or any other kind of emergency. Fire fighters, however, will be on the scene in minutes and are Canadians’ first line of defense against the aftermath of a CBRN attack.

The federal government informally acknowledges that first responders have a critical role to play in emergency preparedness, but historically has assumed that front-line fire fighters are properly trained and equipped to safely and effectively protect citizens. This is a serious flaw in Canada’s emergency preparedness plans that puts the lives of fire fighters and Canadian citizens at risk.

Until the critical role of first responders is formally acknowledged and resourced by the federal government and CBRN and hazardous materials response training is delivered to a significant number of front-line, rank-and-file fire fighters in cities in towns all across Canada, millions of Canadians will remain vulnerable to the aftermath of a terrorist attack of a CBRN nature. Continuing to bolster military-based CBRN or other teams will do nothing whatsoever to protect Canadians from the immediate aftermath of a CBRN attack or other major disaster.

A survey of Canada’s professional fire fighters conducted by the IAFF in early 2005 revealed the shocking truth: not only is CBRN response training non-existent in a vast majority of Canadian cities, but many professional fire fighters also lack the ability to respond safely and effectively to even the most basic hazardous materials incidents.

The IAFF survey indicated that only 19 per cent of Canadian affiliates have the training and equipment necessary to respond to a CBRN incident in their city. A shocking 75 per cent have little or in fact no CBRN response training at all. And that means millions of Canadians remain vulnerable to the potentially-devastating aftermath of these kinds of attacks.

The federal government has acknowledged its responsibility to protect Canadians from the aftermath of terrorist attacks by creating a federal Ministry of Public Safety and Emergency Preparedness, and allocating billions toward initiatives designed to improve disaster mitigation and emergency response. Yet it has failed miserably in terms of delivering widespread CBRN response training to front-line first responders such as fire fighters.

The need for first responder CBRN training in Canada is immediate, and it is real, as illustrated by at least two frightening incidents: in March 2005, a van transporting anthrax and other viral agents to a research centre was involved in a serious traffic accident in downtown Winnipeg, causing serious alarm in the city until emergency crews were able to verify that the deadly packages had not ruptured. This incident mirrored a May, 2003 situation in Guelph, Ont., where a van carrying six cases of radioactive materials was involved in a traffic accident at an intersection and overturned.

These incidents demonstrated that biological and radiological materials are being transported on our city streets, and that accidents involving these materials do in fact happen, anytime and anywhere. In the case of the Guelph accident, none of the fire fighters who rushed to the scene had received any radiological or other CBRN response training at all. Fortunately, none of the materials leaked, otherwise the situation could have been deadly for fire fighters and members of the public. What is just as shocking is that in 2005, two years after this incident, Guelph fire fighters have still not receive any radiological or other CBRN training.

What is more disturbing is that a 2004 request from the Guelph Fire Department for federal CBRN response training was denied. The department was told that existing teams have priority for federal training and that it would be years before any space would be available.

The Winnipeg and Guelph incidents also serve to illustrate that incidents of a CBRN nature can and will happen anywhere, and not just in Ottawa, Toronto or another of the small number of other Canadian cities that have CBRN response teams in place.

Comment 2

In December 2001, the federal government allocated $7.7 billion for national security. Canadians expect and deserve to know exactly what their investment has yielded in terms of protecting their safety and infrastructure. Accordingly, the Emergency Preparedness Act should be revised to indeed include an accountability requirement for annually reporting on the progress made in the areas targeted by this investment.

For example, Canadians in every city deserve to know what they would endure in terms of initial response to a CBRN attack or another kind of major disaster. They deserve to know how long they will wait before the arrival of emergency personnel who are trained to a recognized level of CBRN or hazardous materials response. This is a key element in ensuring a consistent level of preparedness in provinces and cities across Canada. It would allow the government to identify those cities and citizens who are at risk and quickly and specifically target first responder training in those areas.

Comment 3

It is surprising to see such a casual acknowledgement in this question about the need for the federal government to work with “Canadian emergency management communities” on a complementary framework for dealing with emergencies. The only thing that can be said is that the federal government has failed miserably at this in the past, if we are to give any credence whatsoever to the March, 2004 report of the Senate Committee on National; Security.

The Committee’s report reads like a recipe for disaster – federal agencies ignoring the needs of municipalities and first responders, local caches of emergency supplies unknown to local authorities and provincial governments gobbling up emergency preparedness funds intended for municipalities. Time and time again, the report details jurisdictional squabbles and communication breakdowns at the federal level when it comes to national security. And in the meantime, more than four years after the events of 9-11, the federal government still does not have an effective plan to protect Canadians from the aftermath of a terrorist attack of a CBRN nature.

The discussion on this issue proposes revising the Emergency Preparedness Act to ensure there is harmonization within federal government departments, and secondarily with provincial and territorial governments. Again, with no provision contemplated for coordination with local authorities and first responder activities, there is therefore no provision for harmonizing action or even information on the critically-important point protecting Canadians from the immediate aftermath of a CBRN attack or another kind of major disaster. The federal government has no idea which municipal first responders have CBRN or haz-mat training; neither does the provincial government.

An individual CBRN attack, for example would not happen in a single jurisdiction. It would happen in a municipality, which is also in a province or territory, which is also in Canada. Regardless of where it happens, it is automatically in three jurisdictions simultaneously.

We recommend the Emergency Preparedness Act be revised to formally and specifically recognize the role of fire fighters and other municipally-based first responders as a first line of defense in the event of a terrorist attack. We further recommend that the act be revised to contemplate some mechanism for formally tying the element of initial response (i.e. first minutes) into the overall idea of the federal government’s acknowledged role in national security and emergency preparedness.

Comment 4 (Effective Partnerships)

For four years, the International Association of Fire Fighters has proposed an example of a partnership to the federal government, one that could have significantly boosted the number of first responders trained in CBRN response in an extremely cost effective manner. Every MP is aware of our proposal, and so is the Minister of Public Safety and Emergency preparedness. Yet our proposal has never been acted upon by any federal government department or agency.

The IAFF Hazardous Materials Training for First Responders Program and Emergency Response to Terrorism Operations Programs have successfully trained tens of thousands of first responders in the U.S. to a recognized level of response.

But because the funding for these programs comes from the U.S. government, Canadian first responders are prevented from receiving this urgently-needed training. IAFF analysis shows that annual funding of just $500,000 would reach approximately 1,667 first responders a year. Because they are train-the-trainer programs, the effects of the training are multiplied as participants deliver the course to first responders in their home community.

The $500,000 funding proposal represents a tiny fraction of the $7.7 billion that was allocated over a five-year period by the federal government in December, 2001 for enhancing national security. And because the curriculum administration for these IAFF programs are already in place, virtually 100 per cent of federal funding would go directly toward instruction.

The IAFF has been told again and again, by sources inside and outside of government, that our proposal, at a cost of $500,000, is simply too small to be noticed; in other words it’s “flying under the radar.” We are told that if we tack on a zero at the end of our cost projection, we’ll get more attention from the federal government. But we refuse to upwardly revise the estimated cost of our proposal for this or any other reason. It is simply not necessary.

In September 2003, after discussions with the IAFF, the Federation of Canadian Municipalities (FCM) endorsed the IAFF position on federal funding for hazardous materials and Weapons of Mass Destruction training for first responders. The FMC represents hundreds of Canadian municipalities, from the largest cities to the smallest townships and villages, in every province in Canada.

Years and years are passing while this cost-effective opportunity to significantly increase the number of first responders trained to safely and effectively protect Canadians from CBRN incidents goes untapped.

The IAFF has continuously called on the federal government to fully recognize its responsibility for national security and the protection of Canadians and immediately provide funding to enable Canadian first responders to participate in the IAFF Hazardous Training for First Responders Program and the IAFF Emergency Response to Terrorism Operations Program.

This funding could be provided by the federal government through existing budgetary allocations through the Ministry of Public Safety and Emergency Preparedness (PSEPC), or jointly between PSEPC and Health Canada, National Defence and Foreign Affairs.

The origin of the funding is not important. The need to implement widespread first responder CBRN training in Canada is extremely important.

In light of this example, we would certainly agree with the statement that “a coordinated approach – through collaboration, agreements, and arrangements with other Canadian jurisdictions, NGOs, the private sector and other countries is required for modern emergency management.”

The consultation paper for the Emergency Preparedness Act review states that “The national Security Policy recognizes that addressing many threats and emergencies requires a coordinated approach with provinces, territories, NGOs, the private sector and international partners. The policy sets out processes for engaging these partners in the development of coordinated plans to support the overall framework.” A study of the National Security Policy, however, indicates that it specifies no such process through which the IAFF or another non-governmental group could participate in the discussion about national security.

We further recommend that the Emergency Preparedness Act be revised to specify a formal mechanism through which stakeholders such as fire fighters can provide input and submit proposals on the subject of national security and emergency management.

Comment 5 – Information Sharing

The IAFF agrees that information collected for the purpose of enhancing national security should be protected from unauthorized use, and we recommend the Emergency Preparedness Act and any other related regulatory instrument be revised to prevent this from occurring.

The consultation paper for this Emergency Preparedness Act review states on this issue: “For first responders, incidents evolve rapidly and their impact can be widespread. Obtaining timely and accurate information from reliable sources would enable accurate situational awareness, assessment and remedial action during an emergency.”

This is an extremely curious statement in that it supposes that first responders should arrive on the scene of an emergency without any training or preparation and then wait for some unspecified authority to provide information about how to respond safely and effectively.

The reality of emergency response is that time is of the essence, and therefore the best way to protect the lives of Canadians and first responders themselves is to provide them with adequate CBRN training before an incident takes place, therefore fire fighters can safely and immediately perform their duty to rescue citizens as soon as they arrive on the scene without the need to wait. This is the purpose of first responder training and again we reiterate that it is a critical element in the ability of citizens to survive a CBRN event. The Emergency Preparedness Act should be revised to specify this point, if necessary.

Comment 6 – Reliable and resilient Critical Infrastructure

We agree that infrastructure is vulnerable and that the issue of infrastructure protection should be addressed within the scope of the Emergency Preparedness Act. The question in this consultation paper deals with the issue of improving infrastructure so that it is more resistant to damage; specifically whether standards for doing this should be voluntary or mandatory under any legislative regime.

This is a worthwhile discussion but we submit that infrastructure should also be considered in terms of emergency response after an incident occurs. Railways, roadways, universities, laboratories, power facilities, hospitals all handle or store materials that are chemical, biological, radiological or nuclear in nature and therefore present attractive targets to those who would seek to commit an act of terrorism on Canadian soil.

Again, the ability of first responders to deal safely and effectively with these kinds of incidents is related to the ability of Canadians to survive their aftermath. This also points to the need for widespread haz-mat and CBRN training across Canada.

We recommend that the discussion of infrastructure in the Emergency Preparedness Act extend beyond protection and include the issue of response and mitigation.