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42 This chapter discusses remediating shortfalls such as those identified in Chapter 8 through (1) improving the capabilities of existing resources or adding more resources, (2) reallocating existing resources to improve response times, (3) considering agreements with additional response resources (including private entities), and (4) exploring the use of hazmat route restrictions (coordinating with the state routing agency and following the process prescribed in the Federal Motor Carrier Safety Regulations, or FMCSRs). Of course, more than one of these approaches may be implemented. In a broad sense, the improvement of emergency response capability will offset the risk metric used in this Guide. However, this factor applies only to improvements that directly affect the tier assessment for existing response resources or teams, or that reduce the response time for qualified responders to reach the location of one or more scenarios in the risk portfolio. Improving Emergency Response Capabilities As the capability of each response team or unit is assessed, it will become apparent which specific elements of the requirements outlined in Chapter 4 are needed for the team to be assigned to the next-highest level. Those specific elements may include additional training or equipment for existing personnel, or the addition of new personnel. The costs of these elements can be estimated or will already be known and can be compared to the benefits of having that improved capability in the jurisdiction. Each scenario in the risk profile can be reevaluated and the ERC term adjusted as necessary to account for the new capability. Each adjustment will reduce the risk metric for that scenario. Material solutions must always be fielded judiciously with close examination of long-term total costs of ownership. These costs include staffing, training, life cycle management, transportation, and exercise requirements associated with employing and maintaining material capabilities, such as increased protective equipment, detection capabilities, and decontamination systems. If costs to obtain the desired reduction in the risk metric are too high, then other alternatives should be considered. Reallocating Resources Reassigning personnel or equipment to different locations or even relocating entire response teams can have implications on the risk metric for each scenario, because the RTF term will reflect the new response time from the appropriate response teams to the location of each scenario. Care must be taken to account for any changes in actual capability of responders based on reassignment of personnel or equipment among teams. C H A P T E R 9 Approaches for Addressing Identified Shortfalls
Mutual-Aid Agreements Mutual-aid agreements with other jurisdictions, facilities with response capabilities, private response organizations, and other entities can augment jurisdictional hazmat response capa- bilities. To include these in the risk portfolio, each new response capability will need to be rated and its response time to each scenario examined to determine whether it can favorably adjust the RTF term. Hazardous Materials Route Restrictions Where allowed by law and subject to federal preemption authority, jurisdictions can perform route risk assessments for transportation of hazmat. For highways, the governor-designated state routing agency has the authority and responsibility to oversee any such restrictions, even if they are implemented at the local level. The analysis approach is prescribed in the FMCSRs. As long as reasonable alternatives for the movement of commerce through the jurisdiction are identified, a jurisdiction may be able to justify a route restriction that requires certain hazmat shipments to avoid areas of high transportation risk. Approaches for Addressing Identified Shortfalls 43
