There appears to be come confusion regarding the exact role environmental health practitioners play in chemical incident management. Emma Waterworth and Robyn Fairman investigate.

Accidents involving chemicals do not happen very frequently, but can have serious repercussions for environmental and human health. Chemical incidents arise when chemicals having the potential to cause harm to the environment or to human health are released into the environment.(4) The most common types of chemical incident are leaks and spills from chemicals(2) and chemicals liberated by fire.(4, 9)

WHAT ROLE FOR EHPs?
Environmental Health Practitioners (EHPs) may become involved in managing chemical incidents due to complaints from the public about the effects of an incident, for example an odour related to a chemical leak from a tank. The emergency services may also request environmental health assistance in managing an incident, while an NHS consultant in communicable disease control (CCDC) may seek practical help on a public health issue related to a chemical incident. From discussions with the chemical incident response service (CIRS) at Guys and St Thomas's Hospital, a specialist unit providing toxicological and environmental advice to public health physicians in the NHS, it appears that the response of local authority EHPs varies greatly.(2)

The UK National Environmental Health Action Plan (NEHAP) identifies the necessity for EHP involvement in major chemical incident management. One objective of NEHAP is to limit the consequences of major industrial accidents and ensure effective arrangement for emergency preparedness. It also identifies the need to improve the public health response to chemical incidents.(3) The main areas that require further work are thought to be the assessment of risks, the speed with which expert advice can be sought and the need for follow-up action.

EHPs working within local government are not the only group carrying out environmental health work. The Health and Safety Executive, Food Standards Agency and the Environment Agency are all involved in regulating environmental health, while many other disparate groups, such as health educators and public health medics, are involved in improving environmental health.

The NHS has a significant role in chemical incident management which involves both primary care and public health. Guidance published by the NHS places responsibility for the surveillance and handling of health aspects of non-communicable environmental hazards with health authorities.(5) In light of this it is strongly recommended that health authorities have contracts with regional service provider units (RSPUs), of which there are five across the country. RSPUs aim to provide public health physicians with background toxiciological and environmental health advice in order for them to better manage chemical incidents.

The NHS guidance concerning planning for major incidents identifies the essential elements needed to ensure an effective response.(6) This guidance states that in the event of a major incident the role of local authorities often includes the co-ordination of an emergency planning liaison group. It envisages that this role will be performed by both emergency planning officers and EHPs. The environmental health involvement in chemical incidents is often laid down in a peace-time emergency plan8 and some authorities have specific chemical incident plans.(1,10)

The DETR publication Environmental sampling after a chemical accident provides guidance on the sampling procedures essential to gauge the nature and extent of contamination resulting from a chemical incident.(4) This report suggests that EHPs may be ideally placed to play an initial investigative role after a chemical incident, be involved in a response team attending the site of an incident and carry out environmental sampling. However, it also states that this does not necessarily mean that EHPs will be involved.

A health and safety/local authority enforcement liaison committee (HELA) circular advises local authority officers on major incident response procedures.(7) It states that local authorities should be involved in the event of a major incident and have emergency procedures and arrangements in place, through their role in emergency planning.

Although such guidance mentions the involvement of EHPs in chemical incidents, questions still arise as to their role in chemical incident response, their perception of that role, and the preparedness of local authorities to carry out chemical incident work. This article summarises the results of a survey undertaken early this year on the role of EHPs in chemical incident management.

SURVEY METHOD
A self-completion questionnaire was sent to all the district councils, unitary authorities, and metropolitan authorities in England, Wales and Northern Ireland, with the purpose:

• to examine the experience that local authorities have of chemical incidents;
• to discover the attitudes and perceptions of EHPs towards their role in response to chemical incidents; and
• to ascertain the preparedness of local authorities to carry out chemical incident work.

RESULTS
Overall, 202 responses were received (50.4 per cent) and figure 1 shows the response rate for the various authorities surveyed. Respondents were asked if they had had any involvement in chemical incidents over the past 12 months. If so, they were then asked how many incidents and which environmental media were affected (ie land, water or air). 98 (48.5 per cent) of the respondents had been involved in chemical incidents in the previous year. The total number of incidents in these 98 authorities was 271, giving an average of 2.8 incidents per authority in those authorities in which incidents occurred, and an average of 1.3 incidents per authority in all of the authorities that responded.

There are differences in the proportion of types of incidents (contaminated land, air or water) affecting the local authorities. For instance, in the London and Metropolitan Boroughs land incidents are relatively more common than in District Councils and Unitary Authorities. Many of the local authorities that had been notified of a chemical incident took specific action to respond. Despite the fact that EHPs often become involved in the response to chemical incidents, there is a distinct lack of clarity about what their role actually is.

Respondents were asked whether they had any additional information that might provide insights into the involvement of EHPs in response to chemical incidents. This question was useful in providing rich qualitative data on the perception of EHPs regarding their role in incidents and insights as to the major difficulties in managing or being involved in an incident. A number of themes arose from this question.

The lack of clarity within environmental health services as to their role in chemical incidents: Some authorities tackle incidents with enforcement of legislation as the primary objective, and if they have no regulatory role do not involve themselves in the incident. Other authorities take a wider role in protecting the health of the local community and involve themselves in incident management. This can mean that emergency services may be unclear as to the exact role of environmental health. It can also mean that unless chemical incident plans and emergency responses have been discussed prior to an incident, individual staff members may be unclear as to their exact role.

The perceptions of emergency services as to the role of environmental health: The emergency services often view EHPs on site as a representative of the local authority and all its departments. Distinctions between housing or highways, for example, are not always made. EHPs may be seen as experts in handling chemical incidents and their consequences to human health and the environment.

The lack of resources to deal with incidents: The question of adequate resources for sampling, monitoring and analysis, and clean-up costs nearly always arises when local authorities become involved in incidents, which may explain their reticence. Monitoring equipment is simply not available in many local authorities, which means that the assessment of incidents is difficult for EHPs. The need for an immediate response to incidents is also problematic for most local authorities as 24-hour availability of skilled staff is difficult to achieve. Even where local authorities have 24-hour cover, for instance for noise nuisance, staff may not have the expertise to deal with an incident.

DISCUSSION
Nearly half of the respondents had experience of a chemical incident in the year before the survey took place. It is recognised that this may be biased, as those who experience an incident may be more likely to respond. The survey shows that incidents reported to local authorities, although apparently infrequent, do occur.

The most common response by EHPs is to refer the incident to another enforcement authority. The choice of response on this question was not mutually exclusive, and in 50 per cent of the incidents EHPs were involved in the emergency response team. The inference is that although in 80 per cent of cases enforcement responsibility lay with another body, in 50 per cent of the cases the local authority emergency plan resulted in environmental health involvement. Interestingly, sampling only occurred in 29 per cent of incidents. A stark contrast exists between the current situation regarding the extent to which sampling is carried out and the DETR publication that identifies sampling as a major role for local authorities in incident management.(9) Preparedness, resources and time issues may all be important in this failure to gather quantitative evidence. Other enforcement agencies may also be involved in sampling.

The involvement of EHPs in chemical incidents may be either due to enforcement duties or as part of the emergency response team, where their role is to actively help manage the incident and give advice on environmental health issues. Managing the incident and enforcing legislation leads to different actions by EHPs. This disparity can cause confusion to the emergency services and in the minds of EHPs themselves. During an incident, members of the emergency services will look to EHPs and CCDCs for practical advice in reducing or preventing health effects in the local community. The environmental health enforcement role will not concern them.

One issue which arose from the survey was that the emergency services expected EHPs to carry out tasks they were neither equipped for, or felt was their function, such as environmental sampling. If an EHP, on site to examine whether there is an enforcement role, is asked questions by the emergency services relating to the immediate management of the incident, it is clear that confusion and misunderstanding may result.

The clarity of some local authority environmental health services as to their role appears to be linked to where emergency plans which define roles and responsibilities in relation to incidents and organisational arrangements have been made. Confusion appears to arise where emergency plans either do not exist or are not specific, or with smaller incidents that may be outside an emergency plan. The following comment highlights that even when protocols are agreed between emergency services and local authorities they may not be clear: "An arrangement has been made between the fire service and local authorities. This does not specify what role EHOs have in issues such as sampling."

Some of the comments made also revealed that there is a lack of communication between different bodies, which allows for misunderstandings to occur. A good working relationship between all parties involved is essential for the effective resolution of a chemical incident.

Those results of the study relating to the preparedness of local authorities to deal with chemical incidents identified areas where significant improvements in environmental health service response could be made. However, clarification of the role of EHPs has to come first.

CONCLUSION
The responses of different local authorities to chemical incidents vary, as do their attitudes. Some local authority environmental health services function solely according to their responsibilities as prescribed by legislation. Others take a more proactive approach, which involves undertaking non-regulatory initiatives.

The confusion over the role of EHPs in chemical incidents may stem from the fact that there is no specific duty on local authorities to train and plan to be able to provide an effective response in the event of an accident (except for the most hazardous COMAH sites).

Dealing with chemical incidents effectively requires environmental health services that are prepared. To prepare fully, environmental health services have to identify and clarify their role in chemical incidents. In widening the responsibility of the director of public health (DPH) in the health authority to include non-infectious environmental hazards, the NHS is taking up that part of the public health function. EHPs in local authorities need to play a part in the management of incidents. DPHs have specific public health medical training whilst EHPs are trained in assessing exposure and risks. They have local knowledge of hazards and local services. Within the local authority they are the only group of staff capable of dealing with the health effects of incidents.

To reduce confusion, there needs to be a strategic policy and specific guidance relating to the way in which chemical incidents are dealt with. This could be laid down in local chemical incident plans, or part of a wider peace-time emergency plan, and could identify the responsibilities of the different organisations and agencies concerned.

EHPs may have an important role to play in response to chemical incidents. As they are often early on the scene, they are ideally placed to carry out initial investigative work. However, in certain situations, given the nature of the incident, it may be more appropriate for another organisation or agency to play the lead role. Each organisation, agency or service must be made aware of what their own role is and the roles of others. It is also important that there is communication between organisations and agencies as response action to chemical incidents is often shared between different bodies.

Currently, the CIEH is producing policy and practice guidelines on emergency planning and the CIRS is producing a guide to the environmental health functions in chemical incidents. These are in part a recognition of the lack of clarity regarding co-operative responsibility for, and co-ordinated response to, chemical incident management. This study has highlighted the need for local authorities and EHPs to communicate with other agencies involved in incident management. Hopefully it will promote discussion on the measures that are required at a local level to improve chemical incident management in terms of public health.

Acknowledgements
The authors would like to thank Virginia Murray, Chemical Incident Response Service, London; Jody Foster, The National Focus, Wales; and Alan Higgins, Portsmouth City Council, for their useful and constructive comments on an earlier draft of this article.

References
1. BESMIC and HESMIC, 1997, "Local Authority Environmental Health Toolkit For Handling Chemical Incidents", Environmental Health and Emergency Planning Services of Bedfordshire and Hertfordshire Local Authorities.
2. Chemical Incident Response Unit, 2000, "Chemical Incidents in 1999", Chemical Incident Report, Chemical Incident Response Unit, London.
3. Department of the Environment/Department of Health, 1996, United Kingdom Environmental Health Action Plan, Cm 3323, The Stationary Office, London.
4. Department of the Environment, Transport and the Regions, 1999, Environmental Sampling After a Chemical Accident, The Stationary Office, London.
5. Department of Health, 1993, "Arrangements to Deal with Health Aspects of Chemical Incidents", National Health Service Management Executive Health Service Guidance NSG (93) 38, Department of Health, London.
6. Department of Health, 1998, "Planning for Major Incidents", National Health Service Management Executive Health Service Guidance, Department of Health, London.
7. Health and Safety Executive/Local Authority Enforcement Liaison Committee, 2000, Circular 20/2: Major Incident Response Procedures, HMSO, London.
8. Home Office, 1997, Dealing with Disasters, Brodie Publishing, Liverpool.
9. National Focus, 2000, National Surveillance of Chemical Incidents, National Focus, Wales.
10. Lancaster County Council, 1999, Chemical Incident Management Plan.

A CIEH guide, the principles of COSHH, aims to promote awareness of the full range of substances hazardous to health covered by the Control of Substances Hazardous to Health (COSHH) regulations 1999. For further information, please contact the Centre Support department on 020 7928 6006/e-mail: centresupport@chgl.com or visit the web site www.cieh.org