Order Code RL33191
CRS Report for Congress
Received through the CRS Web
Anthrax-Contaminated Facilities:
Preparations and a Standard for Remediation
December 16, 2005
Michael M. Simpson
Specialist in Life Sciences
Resources, Science, and Industry Division
Congressional Research Service ˜
The Library of Congress
Anthrax-Contaminated Facilities:
Preparations and a Standard for Remediation
Summary
Bacillus anthracis, the cause of the anthrax disease, was released into the
United States postal system in autumn 2001, resulting in five deaths and
contaminating several public and private facilities. Remediation costs were
significant. Subsequently, extant federal procedures and policies were clarified and
augmented, and new procedures and policies were created to fill identified gaps.
A number of additional emergency preparedness recommendations have been
made by stakeholders, researchers, and others, including the following:
! Facility owners and managers should keep and maintain ownership
records of valuable and important items; they should have detailed
and current floor plans and information about air flow patterns,
under routine and nonroutine conditions.
! Research and regulatory entities should consider having standardized
sampling and analysis protocols and consensus procedures for
developing protocols when needed; having standardized risk
assessment procedures; and conducting further research on human
dose-responses to bioagents, including anthrax, and developing
nonthreshold dose-response models.
! Governmental entities should develop more extensive plans and
procedures to maximize involvement of all stakeholders; conduct
further training and drills, especially for sampling, analysis, and
coordination procedures; determine the appropriate number and
locations of devices to detect leaked remediation chemicals, and the
conditions under which the devices would be needed; and determine
the appropriate number, size, and locations of chlorine dioxide
generators, given that EPA has concluded that chlorine dioxide gas
shows the most promise for remediating contaminated facilities.
The criterion (not the standard) for determining a successful remediation has
been and remains zero growth of anthrax surrogates from all postremediation
samples. In conjunction with the recommendations above, and given remediation
experience since 2001, it may not be necessary to develop a remediation standard
because consistently achieving the zero-growth remediation criterion appears
possible and would likely be demanded by stakeholders. This report will be updated
as warranted.
Contents
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Remediating Anthrax-Contaminated Facilities in 2001 . . . . . . . . . . . . . . . . . . . . 2
On-Site Issues in 2001 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
On-Site Remediation Details . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Cross-Organization Issues in 2001 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Managing the Situations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Determining a Successful Remediation in 2001 . . . . . . . . . . . . . . . . . . 5
Remediating Anthrax-Contaminated Facilities Today . . . . . . . . . . . . . . . . . . . . . . 6
On-Site Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
On-Site Remediation Details . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Cross-Organization Issues Today . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Managing the Situations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Determining a Successful Remediation Today . . . . . . . . . . . . . . . . . . . 8
National Research Council Remediation Recommendations . . . . . . . . . . . . . . . . 9
American National Standards Institute: 9/11 Commission Recommendations . . 10
Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Recommendations for On-Site Preparations . . . . . . . . . . . . . . . . . . . . . . . . 11
Recommendations for Cross-Organization Preparations . . . . . . . . . . . . . . . 11
Remaining Policy Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Appendix A: NRC’s Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Anthrax-Contaminated Facilities:
Preparations and a Standard for
Remediation
Introduction
When anthrax1 bacteria were released into the United States postal system in
autumn 2001, several public and private facilities were contaminated. In addition to
the five deaths that resulted, the cost of remediation — in dollars, time, and effort —
was significant.2 One private facility, four years after the bioterrorist incident,
remains closed. The incidents in 2001 led to experience and knowledge that may help
reduce the cost of future anthrax remediations. However, a few concerns remain.
This report provides background information on the 2001 anthrax incidents and
federal preparedness plans, but it focuses primarily on preparations for future
remediations and considerations for setting a remediation standard. Such a standard
would define the level of remediation needed to permit safe reuse and reoccupancy
of a facility contaminated with anthrax. Although such a standard does not exist, an
anthrax remediation criterion (zero growth of anthrax surrogates from all
postremediation samples) is commonly used to determine a successful remediation.
Policy questions exist regarding what preparations should precede the next bioagent
incident3 and whether to establish a remediation standard.
Background
Three releases of anthrax occurred in the United States in autumn 2001. In the
first release, letters containing anthrax spores were mailed from New Jersey to media
offices in New York City; the letters passed through the Hamilton Processing and
Distribution Center (P&DC) in Trenton, New Jersey on September 18. The second
release involved a package or letter sent in late September to American Media
Incorporated (AMI) in Boca Raton, Florida. In the third release, letters addressed to
1 The disease anthrax is caused by the bacterium
Bacillus anthracis. The term
anthrax will
be used in this report to mean both the disease and its cause.
2 “Remediation of United States Postal Service facilities alone cost more than $200 million,”
as reported in
Reopening Public Facilities After a Biological Attack: A Decision Making
Framework. The National Research Council. Washington, D.C. July 2005.
3 Although this report focuses on anthrax, preparedness procedures for anthrax may be
useful for other bioagents as well.
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Senators Tom Daschle and Patrick Leahy in the Hart Senate Office Building entered
the Hamilton P&DC on October 9.
Numerous sites, including the Hart Senate Office Building, postal facilities,
media offices, and residences, were contaminated directly or through secondary
contamination. The contaminated postal facilities included physically large P&DCs
such as the Hamilton P&DC, the Morgan P&DC in New York City (which processes
all mail into and out of Manhattan), and the Curseen-Morris facility4 (which handles
all mail to and from the federal government in the D.C. metropolitan area).
Numerous smaller postal facilities also were contaminated, as were a number of
federal government mail facilities downstream of the Curseen-Morris facility.
The releases caused 23 cases of anthrax;12 were cutaneous, 11 inhalational.5
Five of the inhalational cases resulted in fatalities. Of the people who died, two
worked at the Washington, D.C., postal facility; one worked at AMI; one worked in
a New York City hospital; and one was an elderly woman who lived in Oxford,
Connecticut. No route of exposure has been established for the last two of these
deaths.6
Remediating Anthrax-Contaminated
Facilities in 2001
The term “anthrax-contaminated facility remediation” refers to the
decontamination of a large physical building or enclosed space, as opposed to the
decontamination of people or open areas exposed to anthrax.
In autumn 2001, most experience with anthrax contamination involved civilian
and military facilities, primarily facilities conducting anthrax research.7 However,
4 The name of this facility was changed from the Brentwood P&DC, to the Curseen-Morris
P&DC, in memory of the two postal workers who died as a result of contracting anthrax
there.
5 Cutaneous anthrax is the most common naturally occurring type of anthrax infection,
usually occurring after skin contact with contaminated meat, wool, or leather from infected
animals and sometimes resulting in a visible papule or ulcer on the skin. Deaths from
cutaneous anthrax are rare (fatality rates of 20% without antibiotic treatment, less than 1%
with it). Inhalational anthrax is the most lethal form of anthrax (the fatality rate for
inhalational anthrax is estimated at 75%, even with antibiotics and all possible supportive
care). Initial symptoms resemble a viral respiratory illness with a sore throat and mild fever;
symptoms may progress to respiratory failure. Gastrointestinal anthrax usually follows
consumption of raw or undercooked contaminated meat; symptoms include severe
abdominal distress. The fatality rate for this form of anthrax is estimated to be between 25%
and 60%.
6 “Investigation of Bioterrorism-Related Anthrax.”
Morbidity and Mortality Weekly. United
States Centers for Disease Control and Prevention. December 7, 2001.
[http://www.cdc.gov/od/oc/media/mmwrnews/n011207.htm#mmwr1].
7 “Section VII - A Agent Summary Statements.”
Biosafety in Biomedical and
Microbiological Laboratories. United States Department of Health and Human Services.
(continued...)
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little was known about addressing a simultaneous anthrax contamination in several
geographically dispersed facilities, with members of the general public in close
proximity to the anthrax and in various states of health (e.g., in the 2001 incidents,
some were young, healthy workers, whereas others were elderly and not
occupationally exposed). The facility remediation challenges that arose involved two
main foci: challenges involving on-site issues and challenges involving issues that
cut across organizations.
On-Site Issues in 2001
In autumn 2001, most remediation experience was based on civilian and military
involvement with anthrax research facilities. Drawing on then-current common
facility decontamination procedures, the on-site process to remediate public facilities
involved as many as nine steps:8 (1) assessing the site, including environmental
sampling to characterize the contamination; (2) isolating contaminated areas; (3)
removing items for off-site treatment; (4) reducing the sources of contamination; (5)
developing and designating risk zones and levels of required personal protection
equipment, such as Tyvek coveralls and full-face air-purifying respirators; (6)
cleaning and remediating contaminated areas; (7) sampling the environment
following remediation (often called
postremediation environmental sampling); (8)
additional remediation and sampling, if the initial postremediation sampling showed
areas that were still contaminated; (9) and disposal of decontamination wastes.
Removing items for off-site treatment and reducing sources of contamination were
complicated by a lack of records and, hence, questions regarding the ownership of
items in a contaminated facility.9
On-Site Remediation Details. During the 2001 anthrax releases, important
decisions had to be made on-site, on a case-by-case basis. For example
! Whether to remediate the entire facility at one time (e.g., the
Curseen-Morris site) or to remediate the facility in subsections (e.g.,
the Hart Senate Office Building). This decision depended, to some
extent, on the degree to which parallel facilities existed (i.e., other
7 (...continued)
Available at [http://bmbl.od.nih.gov/sect7a2.htm].
8 Compiled from numerous reports of the time and from “Lessons Learned: Remediation of
Anthrax Contamination,” Dorothy A. Canter, Ph.D. U.S. Environmental Protection
Agency. Presented at the 2003 Eighth International Kilmer Memorial Conference in Osaka,
Japan. Polyscience Publications, Inc. Laval, Canada. 2004.
9 Personal communication with Sabre Technical Services, September 2005. Sabre is the
firm that remediated the former-AMI building. In 2001, AMI published newspapers from
that building, which contained large numbers of photographs and other valuable documents
when the building was contaminated. AMI sold the building, which remains closed, and the
items included in the building, mainly due to a dispute over ownership. The issue of
maintaining precrisis records of ownership is described later in this report.
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locations where the functions of the contaminated facility could be
accomplished without excessive difficulty).10
! To determine which chemical should be used to remediate the
contaminated facilities. In 2001, no chemicals or pesticides were
registered by the United States Environmental Protection Agency
(EPA) for remediating anthrax sites. This remains the case today.
Prior to 2001, different chemicals and physical agents had been used
against anthrax. The process of choosing the appropriate chemical
for each facility slowed the pace of remediation.
! To determine which bacterium should be used to indicate the
effectiveness of remediation actions. For example, when the
decision is made to fumigate, biological indicators are placed
throughout the facility prior to fumigating. (The biological
indicators are species that are not pathogenic to humans but are
similar to anthrax in terms of genetics and resistance to the
fumigation chemicals.) Typically, a million spores of surrogate
indicator species are placed on a carrier, such as a paper strip or disk.
A species that is more resistant than anthrax to the fumigation
chemicals could be used to add a margin of safety to the remediation
efforts (i.e., if a species more resistant to the chemicals is killed by
the treatment, then there is a greater likelihood that the anthrax will
be killed by that treatment).
! To determine the number and placement of spore strips used to
indicate the effectiveness of the remediation. Typically, at least one
spore strip is used for every 100 square feet fumigated; however, a
different number could be used. In fact, the space in the Hart Senate
Office Building was tested with one spore strip for each square foot
fumigated.11
In addition, decisions were made for each site concerning the quality of the test
strips, the handling of biological and other samples, and the methods used to analyze
the data.12
Cross-Organization Issues in 2001
Managing the Situations. Managing the anthrax contamination situations
involved more than on-site efforts. Several other decisions and actions, involving
10 “Fumigating Buildings Containing Anthrax.” Center for Infectious Disease Research and
Policy. University of Minnesota. December 2003.
11 EPA reported that 3,000 test strips were used in the 3,000 square foot Daschle suite in the
Hart Senate Office Building. “Senate Hart Building Decontamination Progressing” United
States Environmental Protection Agency. December 2, 2001.
[http://yosemite.epa.gov/opa/admpress.nsf/0/f93e59a8346b3cf985256b1700590dcb?Ope
nDocument].
12 Canter, op. cit.
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various off-site organizations, were discussed and made in concert: establishing a
unified command, an incident command system (including a federal on-scene
coordinator, the Federal Bureau of Investigation, the facility manger or owner, and
local incident commanders, such as local public health officials), and a command
post; identifying funding sources for the response; assessing occupational and public
hazards; developing and implementing prophylaxis and monitoring plans for exposed
workers and members of the general public (e.g., administration of antibiotics such
as Cipro); and developing and implementing long-term remediation plans, including
procedures to certify that the site was safe to reoccupy. These cross-organization
decisions and actions related to, and generally complied with, plans and procedures
contained in the interagency Federal Response Plan, which was issued in 1992 and
updated and reissued in April 1999.
Determining a Successful Remediation in 2001. In 2001, there was no
established, acceptable limit for exposure to anthrax, either in workplace or public
settings. Trying to set such a limit posed several difficulties: microorganisms such
as anthrax live, thrive, or die at different rates in different hosts; some hosts may have
or may develop immunity; different strains of the same bacterial species may show
significantly different degrees of infectivity;13 the virulence of the microorganism
may differ significantly among laboratory animals and humans, making it difficult
or impossible to extrapolate safe limits from laboratory animal findings to humans;
possible interventions of vaccines and antibiotics could complicate efforts to set an
occupational or public anthrax exposure limit; and differences exist between the
lethality of anthrax found in nature and anthrax that has been deliberately altered, or
weaponized, to increase infectivity and virulence. Moreover, it was not known how
few anthrax spores, natural or altered, a person would have to inhale to get sick or
die. 14
Given the variabilities and difficulties in trying to set an exposure limit and
remediation endpoint15 for anthrax, the criterion used in 2001 to judge the
effectiveness of site remediation efforts was zero growth of anthrax surrogates from
all postremediation environmental samples. This criterion did not ensure that all
13 Infectivity is the proportion of persons exposed to an infectious agent who become
infected by it. Virulence is the ability of an infectious agent to produce disease.
14 It has been estimated and reported in different studies that half the population of primates
exposed to as few as 2,500 inhaled anthrax spores would die from that exposure, but large
uncertainties accompany extrapolations to lower exposures, making lower dose-response
estimates highly speculative. Mark Keim et al., “Principles for Emergency Response to
Bioterrorism,”
Annals of Emergency Medicine, August 1999, volume 34, number 2, pp. 177-
182. John Jernigan et al., “Bioterrorism-Related Inhalational Anthrax: The First 10 Cases
Reported in the United States,”
Emerging Infectious Diseases, Nov-Dec 2001, volume 7,
number 6, [http://www.cdc.gov.ncidod/EID/vol7/no6/jernigan.htm ]. Lydia Barakat et al.,
“Fatal Inhalational Anthrax in a 94-Year-Old Connecticut Woman,”
Journal of the
American Medical Association, February 20, 2002, volume 287, number 7, [http://jama.ama-
assn.org/cgi/content/full/287/7/863]. Matthew Meselson et al., “The Sverdlovsk Anthrax
Outbreak of 1979,”
Science, November 18, 1994, volume 266, pp. 202-208.
15 A remediation endpoint is the point at which remediation efforts would be aimed and the
point at which, when reached, remediation efforts could stop.
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anthrax spores had been killed by the remediation efforts, nor that there was zero risk
of disease, but that the level of risk of developing disease was acceptably small.16
There was no science-based minimum number of spores known to cause disease in
a person; however, two women in 2001 died from inhalational anthrax without any
identified sources of exposure, supporting the idea that a very low number of anthrax
spores could be enough to cause disease and even death.17
Remediating Anthrax-Contaminated Facilities Today
Remediation experiences since the autumn 2001 anthrax releases have led to
higher levels of knowledge about, and preparedness for, decontaminating facilities.
On-Site Issues
In general, current steps to remediate a facility are refinements of steps that
evolved during the 2001 incidents. The steps today are practiced in drills to increase
the likelihood of successful remediation of another anthrax situation. However, a
few remaining on-site issues exist.
For example, determining ownership of items in a contaminated facility, such
as valuable documents, remains an issue. Remediation and other recovery efforts
could be facilitated if facility owners, managers, and insurers maintained ownership
records of important items within a facility (note the situation involving the former-
AMI building, described earlier in this report).
Another issues involves limiting public exposure to chemicals being used in a
facility undergoing remediation, and determining the analytic method used to
measure levels of chemicals outside the facility. In the past, EPA has deployed its
Trace Atmospheric Gas Analyzer (TAGA) to check for inadvertent releases of
remediation fumigant. TAGA is a self-contained mobile laboratory, resembling a
bus, capable of real-time sampling and analysis in the low parts per billion range for
various chemicals in the air. Other means of analyzing for trace gases exist, but they
do not use a single unit like a TAGA and do not necessarily work in real-time or with
concentrations so small. EPA now has two TAGAs, one based in Las Vegas,
Nevada, and one in Edison, New Jersey.18 It is important to consider the appropriate
level of protection for people living and working near a remediation site, and the
appropriate methods for providing such protection, especially for simultaneous
events involving several contaminated facilities in separate locations.
16 Canter, op. cit.
17 Barakat, op. cit., and Jernigan, op. cit.
18 It may be useful to note that both TAGAs were deployed to check for air contaminants in
areas affected by hurricanes Katrina and Rita, which raises questions about the appropriate
numbers and prepositioning of TAGAs, and the mix of public versus private monitoring,
especially given monitoring demands in terror and nonterror incidents. Further information
about EPA’s TAGAs can be found at [http://www.epa.gov/earth1r6/6lab/taga.htm].
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On-Site Remediation Details. Important site-specific details include the
following:
! On-site decisions whether to remediate an entire facility, or to
remediate in subsections, must continue to be based on site-specific
conditions. One factor that slowed remediation activities in 2001
was the lack of information about ventilation in the contaminated
structures. Remediation could be facilitated if building owners,
managers, and insurers maintained information about air flow in a
facility.
! On-site decisions regarding the best remediation chemicals or
physical agents to use must continue to be based on site-specific
conditions, including the types of important items (e.g., books,
photographs, or computer equipment) and ventilation in the facility.
Since the 2001 anthrax releases, EPA has approved seven chemicals
for use against anthrax, which may be used only by authorized
personnel following the specific requirements of the crisis
exemption, and only with approved decontamination plans.19 In
addition to these chemicals, other ways to remediate anthrax
facilities are now more widely known.20 However, available
remediation technologies remains an issue. Following its
examination of myriad approaches to remediation, EPA reported that
“chlorine dioxide has shown the most promise for use as a fumigant
for biologically contaminated buildings.”21 For remediating large
facilities, chlorine dioxide is produced by a machine on-site. It may
be useful to consider how many, and how large, chlorine dioxide
generators, private and public, are appropriate nationwide, and
where they should be prepositioned to facilitate future remediations.
! Decisions about which indicator species to use, the number and
placement of indicator strips, the quality of the strips, and the
methods for handling and analysis, continue to be made based on
site-specific conditions. One could argue, however, that given the
greater level of experience and expertise now available, these
19 EPA evaluates pesticides to ensure that they meet federal safety standards, before they can
be marketed and used domestically. The agency can issue exemptions for various reasons,
including public health emergencies. See CRS Report RL31921,
Pesticide Law: A Summary
of the Statutes, by Linda-Jo Schierow. The seven chemicals approved by EPA for use
against anthrax, to be used by authorized personnel following the specific requirements of
the crisis exemption (which includes having approved decontamination plans), are vaporized
hydrogen peroxide, chlorine dioxide, sodium hypochlorite (bleach), paraformaldehyde,
methyl bromide, peroxyacetic acid with hydrogen peroxide, and ethylene oxide.
20
Compilation of Available Data on Building Decontamination Alternatives. United States
Environmental Protection Agency. EPA/600/R-05/036. March 2005.
21
Decontamination and Consequence Management Synopsis Report. United States
Environmental Protection Agency. EPA/R-05/031. April 2005. This information is
available at [http://www.epa.gov/NHSRC/news/news041205.htm].
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decisions could be incorporated into a remediation standard and not
left to site-by-site determinations, which may slow remediations and
increase costs.
Cross-Organization Issues Today
Managing the Situations. There have been many cross-organization policy
and procedure changes since 2001. The National Response Plan (NRP) has
superseded the Federal Response Plan. The NRP is now accompanied by six other
national priorities, which are part of the National Preparedness System (NPS).22 The
NRP “establishes a comprehensive all-hazards approach to enhance the ability of the
United States to manage domestic incidents,” according to the United States
Department of Homeland Security (DHS).23
In addition to the NRP, the NPS includes the National Incident Management
System (NIMS), which identifies standard operating procedures to ensure that
emergency responders communicate and cooperate to achieve the best response to
disasters. One important element of NIMS is the Incident Command System (ICS).
ICS operates in the framework of five functional areas: command, operations,
planning, logistics, and finance. ICS requires the identification of responsible
officers and staff prior to a disaster to ensure that functions and assignments are
carried out during the response.
It is beyond the scope of this report to discuss in detail ways to improve the
NRP or NPS, but it may be useful to note that all the cross-organization procedures
and policies continue to evolve, sometimes driven by incidents that illuminate
possible areas for improvement.24
Determining a Successful Remediation Today. Today, no public or
occupational exposure limit for anthrax exists, for the same reasons that existed in
2001. The criterion used to define a successful remediation in 2001 (i.e., zero
growth of anthrax surrogates in all postremediation samples) continues to be used.
Despite the similarity between 2001 and today with regard to exposure limit and a
successful remediation criterion, several recommendations have been made by
various organizations for ways to improve remediation efforts.
22 “A Common Approach to Preparedness.” United States Department of Homeland
Security. Available at [http://www.ojp.usdoj.gov/odp/docs/Goal_041305.pdf]. See CRS
Report RL32803,
The National Preparedness System: Issues in the 109th Congress, by Keith
Bea.
23 “Emergencies and Disasters.” United States Department of Homeland Security.
Available at [http://www.dhs.gov/dhspublic/interapp/editorial/editorial_0566.xml].
24 The United States Government Accountability Office has reported on cross-organization
improvements for handling anthrax situations, including
Agencies Need to Validate
Sampling Activities in Order to Increase Confidence in Negative Results, GAO-05-493T;
Better Guidance Is Needed to Ensure an Appropriate Response to Anthrax Contamination,
GAO-04-239; and
Public Health Response to Anthrax Incidents of 2001, GAO-04-152.
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National Research Council Remediation
Recommendations
The Department of Homeland Security funded the Restoration and Domestic
Demonstration and Application Program to study and develop, among other things,
the criteria that must be met for a remediation effort to be declared successful. The
National Research Council (NRC)25 convened a committee of experts, and their
findings and recommendations were reported in
Reopening Public Facilities After a
Biological Attack: A Decision Making Framework, released in summer 2005.26 The
committee did not recommend an actual standard for defining a successful anthrax
remediation. It did describe criteria that, if met, would facilitate the reoccupation and
reuse of the facility with minimal attendant risk. The committee’s 28
recommendations are condensed here and presented with more detail in
Appendix
A. NRC committee recommendations fell into four categories.
! Planning and preparing — including building managers having
detailed physical information about their facilities (e.g., air flow
patterns and floor plans); health department and law enforcement
authorities having predrawn agreements for information flow;
deployment of effective bioagent monitoring and health surveillance
systems; facility operators having training for prompt responses to
emergencies; and the NRP containing detailed technical information
about remediation and clear lines of responsibilities among
authorities.
! Basing future actions on experience rather than establishing new
procedures with each incident — including having a response plan
that can be tailored for a specific situation but not creating a new
response plan for every situation; using a standard method for
assessing risk; and using standardized sampling and analytical
techniques, so that results are comparable and consistent. All of
these will help reduce costs and increase confidence in the
estimation of the extensiveness of remediation needed.
! Involving representatives of all stakeholders, and independent
experts free of conflicts of interest, in all decisions and actions —
including creating precrisis agreements for using relevant sampling
protocols where they exist and agreements on how to develop
protocols where they don’t, and jointly developing risk assessment
and management procedures, which will increase acceptance of
remediation decisions and actions.
25 On its website, the National Academies says that it brings together scientific and
technological experts to advise the federal government and the public. The National
Academy of Sciences, the National Academy of Engineering, the Institute of Medicine, and
the National Research Council, compose the National Academies.
[http://www.nationalacademies.org/about].
26
Reopening Public Facilities After a Biological Attack, op. cit.
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! Conducting research to accelerate threat identification and improve
understanding of human responses to different doses of bioagents —
including developing a system that can inexpensively and quickly
identify threat agents; conducting research to clarify human dose-
responses to bioagents while further developing nonthreshold dose-
response models; and targeting research to improve the validity of
interspecies dose-response extrapolations. These actions will help
clarify the minimum remediation level needed to insure safe
reoccupany and reuse of facilities.
American National Standards Institute:
9/11 Commission Recommendations
Known generally as the 9-11 Commission, the National Commission on
Terrorist Attacks Upon the United States27 noted that the private sector, which
controls 85% of the critical infrastructure in the nation, remains largely unprepared
for a terrorist attack, with the principal contributing factor being the lack of a widely
embraced private sector preparedness standard. The Commission asked the
American National Standards Institute (ANSI)28 to develop a consensus on a
“National Standard for Preparedness” for the private sector. The proposed standard
would establish a common set of criteria and terminology for preparedness, disaster,
and emergency management and business continuity programs. Included in the
standard is consideration of risk assessment methodologies for anthrax and other
biological hazards, a recommendation also made in the NRC study. In its final
report, the Commission endorsed ANSI’s recommended standard for private
preparedness.29
Conclusions
The actions and recommendations following the 2001 anthrax incidents have
not resulted in the adoption of a specific, numeric remediation standard. The general
remediation criterion continues to be for zero growth of anthrax surrogates from all
postremediation environmental samples taken from a contaminated facility. What
has developed since 2001 is a set of recommendations, mostly relating to preparation
before a crisis, compiled from comments by public and private sector researchers,
remediators, facility managers, and others. The recommendations tend to fall into
27 On its website, the 9-11 Commission states that it is an independent, bipartisan
commission created by law in late 2002. [http://www.9-11commission.gov].
28 On its website, ANSI states that it is a nearly 90-year-old, “private, non-profit organization
that administers and coordinates the U.S. voluntary standardization and conformity
assessment system,” with a membership of approximately 1,000 company, organization,
governmental, institutional, and international members. [http://www.ansi.org].
29 The National Commission on Terrorist Attacks Upon the United States.
The 9/11
Commission Report. U.S. Government Printing Office. July 22, 2005. Pages 397-398.
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two categories: on-site preparations and cross-organization preparations. Congress,
in its EPA and DHS oversight responsibilities, may wish to consider the benefits and
costs of recommending, or not recommending, the implementation of these steps
preparing for future bioagent incidents.
Recommendations for On-Site Preparations
! Have and maintain records of ownership of valuable and important
items in facilities.
! Have detailed and current floor plans and information about air flow
patterns, under both routine and nonroutine conditions.
Recommendations for Cross-Organization Preparations
! Have standardized sampling and analysis protocols and consensus
procedures for developing protocols, when needed.
! Have standardized risk assessment procedures.
! Conduct more research on human dose-responses to bioagents,
including anthrax, and develop nonthreshold does-response models
more fully.
! Further develop plans and procedures to maximize involvement of
all stakeholders.
! Conduct additional training and drills, especially for sampling,
analysis, and coordination procedures.
! Determine the appropriate number, capabilities, and locations of
private and public TAGAs or other leak detectors and the conditions
under which they would be necessary.
! Determine the appropriate number, size, and locations of chlorine
dioxide generators, given that EPA has concluded that chlorine
dioxide gas has shown the most promise for remediating
contaminated facilities.
Remaining Policy Questions
There remains a policy question that has relevance both on-site and across
organizations: Is there a need for a nonzero standard? Some researchers are
concerned that if several important facilities were simultaneously contaminated, and
if there were little or no parallel capability for those facilities, there might be
significant pressure to abandon the zero growth remediation criterion and remediate
to a less stringent level. Given lessons learned since 2001, it may now be possible
to use chlorine dioxide gas to remediate a large facility to the zero growth criterion,
at the cost of one week and $4 per square foot, compared with approximately 14
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weeks and $27 per square foot for the Hart Senate Office Building in 2001-2002.30
If this estimate can be reliably confirmed, in conjunction with the recommendations
described earlier, it may not be necessary to accept a remediation criterion less than
zero, nor to develop a remediation standard, because consistently achieving the zero
growth remediation criterion would appear to be reasonable and would likely be
demanded by stakeholders.
30 On the Hart Senate Office Building,
Capitol Hill Anthrax Incident: EPA’s Cleanup Was
Successful; Opportunities Exist to Enhance Contract Oversight. United States
Governmental Accountability Office. June 2003. GAO-03-686. On the current remediation
estimate, personal communication with Sabre Technical Services, in September 2005.
Insurance is a related concern; Sabre reports an insurance arrangement with American
International Group, Inc., which requires remediation to the zero growth criterion. It may
be helpful to note that continuity of operations is a segment of federal contingency planning,
linked to continuity of government. See CRS Report RL31594,
Congressional Continuity
of Operations (COOP): An Overview of Concepts and Challenges, by R. Eric Petersen and
Jeffrey W. Seifert; CRS Report RL31857,
Continuity of Operations (COOP) in the
Executive Branch: An Overview, by R. Eric Petersen; and CRS Report RL31978
Emergency
Preparedness and Continuity of Operations (COOP) Planning in the Federal Judiciary, by
R. Eric Petersen.
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Appendix A: NRC’s Recommendations
A summary of NRC’s twenty-eight recommendations, in preparation for reopening
public facilities, follow.31
1. Remediation decisions and plans should consider the infectivity and virulence of
the biological agent in the particular situation at hand. Infectivity and virulence
can vary between natural and weaponized forms of anthrax, and given that
uncertainty, it is impossible to set an acceptable threshold below which
exposure would pose zero risk.
2. In considering how to respond to new biological attacks, authorities should base
their plans on lessons learned from prior experiences, rather than try to develop
a new response plan for each new incident. Important considerations should
include the critical policy dimensions of the biological quality of the hazard, the
public nature of the building, the people’s perception of the attack, and the
national security implications of the event.
3. Representatives of affected parties, as well as independent experts who are free
of conflicts of interest, should be involved in risk management decision making.
Stakeholder involvement in risk assessment and management would contribute
to more widespread acceptance of the legitimacy of the results.
4. After a facility has been remediated, some type of medical monitoring is critical
to ensure confidence that a facility is safe. The purpose and outcome of the
monitoring must be transparent to affected parties. There should be a
centralized and sustained effort to track the health of those exposed to the
bioagent.
5. Risk managers should assume that any given contamination incident could be
worse than initially perceived. Information about remediation efforts should be
made available widely, which will facilitate broader participation in risk
management activities.
6. Agreements among health departments and law enforcement agencies should be
drawn up in advance of incidents to facilitate the flow of information during a
crisis. Efforts to get broader participation in, and acceptance of, remediation
efforts will be helped by the unobstructed and transparent flow of information
during a crisis.
7. A standard risk assessment approach, developed and validated over the past 20
years, should be used as one part of decision making to determine the adequacy
of remediation efforts. Use of a well-validated method for assessing risk will
increase acceptance of its results.
8. A practical, as opposed to theoretical, analysis of risk also will increase its
acceptance, but more sampling source and dose-response data are needed for
31
Reopening Public Facilities After a Biological Attack, op. cit.
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this. Gathering and validating as much data as possible should be done in
preparation for a crisis. Trying to gather and validate data during a crisis will
impede remediation efforts.
9. Research should be conducted to develop a system that can inexpensively and
quickly identify threat agents. Remediation efforts can be facilitated with sound
and detailed information about the threat agent.
10. Characterizing the threat agent should be done before selecting the approach for
large scale remediation. The remediation approach chosen should be able to
destroy the amount of agent present at the start of the procedure (i.e., at its
highest concentration, prior to any dispersal).
11. Existing monitoring and surveillance systems need to be evaluated for their
abilities to detect and limit the spread of bioagents in a cost-effective manner.
Systems that prove effective could be deployed in public facilities that are likely
targets for attacks. Such systems could help better inform remediation
decisions.
12. Because bioagents can spread beyond their point of initial release through air-
handling systems, reaerosolization, foot traffic, air currents, and adhesion to
people and clothes, an extensive survey should be done to determine the extent
to which biological contamination has spread. This consideration can affect the
extensiveness of remediation required.
13. Building operators should, in preparation for a crisis, gain a thorough
understanding of how air flow occurs in their buildings, under both routine and
unusual conditions, such as during partial breakdowns or maintenance.
Remediation efforts can be impeded by needing to determine air flow, a process
made more difficult in a crisis by the presence of a bioagent.
14. The training and education of facility managers and building designers should
include information about vulnerabilities to weaponized agents, so they will be
better prepared to respond to bioterror attacks and subsequent remediation
efforts.
15. The concept of a threshold below which no risk to a population exists is not
supported by current data; dose-response data for most pathogens of concern are
incomplete. As such, nonthreshold dose-response models should be developed
further and used more extensively to reduce the possibility of remediating to an
arguable endpoint.
16. Targeted research should be conducted to help inform decision making based
on extrapolations of dose-response data between species for pathogens of
concern. Dose-response data from nonhuman species may be relevant and
useful to humans, if the proper mechanisms for extrapolation are discovered.
17. Samples of bioagents should be collected and handled by protocols that are
appropriate to the threat. Accepted protocols should be used where they exist,
and new protocols should be developed with the involvement of relevant public
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and private entities (e.g., the Centers for Disease Control and Prevention [CDC]
and the American Society for Microbiology).
18. Because surface sampling with dry wipes led to false negatives in one instance,
and to inconclusive results in another, wet surface-swipe techniques should be
used, with complementary vacuum surface-sampling.
19. Sampling and analyses should be standardized. Knowing that the sampling and
analyses are consistent and comparable will increase confidence in the estimate
of the initial extent of contamination and, therefore, the extensiveness of
remediation needed.
20. A general sampling plan, to guide more specific surface-, air-, and bulk-sampling
methods, should be a consensus document drawn up by stakeholders. This
would increase acceptance of sampling results, a step toward acceptance that
remediation was successful.
21. EPA precluded use of paraformaldehyde for remediation because of fears of its
possible carcinogenicity, despite its proven efficacy against bioagents. The
NRC committee recommended that the National Cancer Institute lead an
interagency task force to reevaluate the chemical’s possible carcinogenicity.
This could result in the addition of another available remediating agent.
22. Chlorine dioxide has been used successfully to remediate several buildings
contaminated by anthrax. The committee recommended that the chemical be
considered, at this time, the standard for remediation and that new methods and
processes should be expected to be at least as effective, safe, and cost-effective.
23. The committee recommended that EPA and CDC should establish standards for
remediation and validation of contaminated buildings, and for the training of
remediation teams.
24. A remediation technique that meets the current federal sterilization standard
could possibly leave a large number of viable anthrax spores in a contaminated
setting, possibly resulting in unacceptable residual risk. The committee
recommended that current and emerging remediation techniques should be
thoroughly evaluated to determine how efficiently they kill bioagents, including
anthrax.
25. Owners and managers of high-value facilities should plan and prepare for a
prompt and well-organized response, which will minimize the time that a
facility will be nonoperational due to remediation efforts. The committee
recommended that the NRP be augmented with more scientific and technical
information on bioweapons, remediation, sampling and surveying,
epidemiology, and forensics. There should be descriptions of how response and
recovery teams should operate, clear lines of responsibility for actions, from the
short through the long term.
26. Expanding on the previous recommendation, the committee recommended that
airport operators should assemble, adopt, and maintain detailed plans to
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identify, contact, and mobilize the diverse and specialized resources needed to
facilitate remediation and recovery. These plans and resources should be
updated periodically and stored in locations that would be accessible in a crisis.
27. Physical information about facilities, including floor plans, material
characteristics, air flow patterns, and air sampling data should be included in
preparation plans. Current contact information for individuals and
organizations that would be needed in a crisis also should be included in
preparation plans.
28. Planning should identify the interested parties, form them into working groups,
and have them interact regularly in anticipation of coming together to guide an
actual recovery effort. The committee recommended that actions be taken to
maximize trust among the participants and stakeholders.