# Presentation: 124160

## The National Response System and the Incident Command System/Unified Command

**Notes:**
[NOTE TO SPEAKER:  The first four slides of this presentation provide a brief introduction to the National Response System and the role of the federal government during a response to an oil discharge or hazardous substance release.  If your audience is familiar with these concepts, you may skip this introduction and proceed to slide five for an introduction to ICS/UC.
Speaker Notes:  The purpose of this presentation is to:
Introduce the concepts of the Incident Command System/Unified Command (ICS/UC); 
Outline the assistance that can be provided by the Federal On-Scene Coordinator (OSC); and
Provide an outreach tool to discuss multi-jurisdictional responses with responders and the public.  You may want to use this tool to discuss area planning and regional contingency planning with your appropriate state representatives.]
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR part 300) establishes the National Response System (NRS) as the federal government’s response management system for emergency response to releases of hazardous substances into the environment or discharges of oil into navigable waters of the United States.  This system functions through a network of interagency and intergovernmental relationships and provides for coordinating response actions by all levels of government to a real or potential oil or hazardous substances incident.  A primary mission of the federal system is to provide support to state and local response activities.  Oil and hazardous substances response under the NRS is divided into three organizational levels:  the National Response Team (NRT), Regional Response Teams (RRTs), and OSCs. 
At the National level, the NRT is comprised of 16 federal agencies with interests and expertise in various aspects of emergency preparedness and response to pollution incidents.  The NRT provides national planning and policy guidance prior to incidents, and assistance as requested during an incident.  Like the NRT, the RRTs are planning, policy, and coordinating bodies, and usually do not respond directly to the scene; rather they provide support, advice, and assistance to the Federal OSCs.  All NRT member departments and agencies, as well as state and local participants, are represented on RRTs.  

## Federal On-Scene Coordinator

- Responsible for providing access to federal resources and technical assistance
- Coordinates all federal containment, removal, and disposal efforts and resources during an oil or hazmat incident
- Serves as the** **point of contact for coordination of federal efforts with the local response community
- Coordinates, monitors, or directs response actions
- Agency providing OSC might differ depending on the incident (EPA, USCG, DOD, DOE, or other federal agency)

**Notes:**
Federal OSCs are the federal officials predesignated by EPA and the USCG to coordinate response resources.  The OSC, either directly or through his or her staff, monitors, provides technical assistance, and/or directs federal and potentially responsible party (PRP) resources.  As the state and local responder’s gateway to the resources of the NRS, it is the OSC’s responsibility to provide access to resources and technical assistance that may not otherwise be available to a community.  Under the NCP, if federal involvement is necessary because state and local resources have been exceeded, the OSC is obligated to coordinate the use of these resources to protect public health and the environment.  (Note:  An example of the OSC’s direction of PRP resources could be through participation in the Unified Command or issuance of an administrative order.)
During an oil or hazmat incident, EPA will usually provide OSCs in the inland zone, and the USCG will generally provide OSCs in the coastal zone.  The OSC coordinates all federal containment, removal, and disposal efforts and resources during an incident under the NCP or the Federal Response Plan (FRP).  The OSC is the point of contact for the coordination of federal efforts with those of the local response community.  EPA has approximately 200 OSCs at 17 locations nation-wide; USCG has 46 Marine Safety Offices (MSOs), spread among the nine USCG Districts, each of which is headed by a Captain of the Port (COTP), who acts as an OSC.
Agencies other than EPA or USCG might provide the OSC depending on the incident.  While EPA and USCG have primary responsibility under federal laws and regulations, under CERCLA, DOD, DOE, and other federal agencies provide OSCs for incidents for which they have responsibility for releases of hazardous substances.  If a federal agency – other than EPA, USCG, DOD, or DOE – has responsibility for an incident, they only provide the OSC if the incident involves non-emergency removal actions.  Each of the agencies in the NRS provides resources and technical expertise and has access to a wide range of federal assets, such as equipment and special expertise, through the RRT.

## National Response System Concept of Response

**Notes:**
During an emergency, or for other response support needs, the NRS can be accessed 24-hours a day by calling the National Response Center (NRC) at 1-800-424-8802.  Located in the USCG headquarters command center and operating 24-hours a day, the NRC immediately relays reports to the cognizant, predesignated OSC.   
The NRC receives reports of all chemical, radiological, etiological (causes of a disease or abnormal condition), and biological releases regulated by various federal statutes.  (However, the only statutory requirements for reporting to the NRC are the Clean Water Act [CWA] for oil discharges, the Comprehensive Environmental Response, Compensation, and Liability Act [CERCLA] for hazardous substance releases, and the Hazardous Materials Transportation Act [HMTA] for hazardous materials releases.  Additionally, the inherent reporting limitations within each of these statutes prevent the NRC from receiving reports of all incidents.)
In every area of the country, OSCs are on-call and ready to respond to an oil discharge or a hazardous substance release 24-hours a day.  When a discharge or release is discovered or reported, the predesignated OSC is responsible for immediately collecting pertinent facts about the discharge or release to evaluate the situation.  Based on the evaluation, if the OSC decides a federal emergency response action is necessary, he or she works with state and local emergency response teams, local police and firefighters, and/or other federal agencies to eliminate the danger.  
While all significant oil discharges or hazardous substance releases must be reported to the NRC, many inland responses are effectively handled without any direct involvement by the federal government.  Others require federal assistance when the incident exceeds state and local capabilities.  In other words, the federal government acts as a “safety net” for state, local, tribal, and private party responders.  Notification occurs so that federal assistance will be there if needed to ensure that the polluter cleans up the spill or, if necessary, to provide federal assets.

## OSC Response Assets

- Enforcement authorities to ensure that the responsible party (RP) cleans up the spill or release
- Immediate access to technical assistance and cleanup contractors if the response is beyond the RP’s capabilities
- Immediate access to Superfund and the OSLTF
- Reimbursement of extraordinary oil or hazmat response costs incurred by state or local responders
- Regional Response Teams (during major incidents)
- Technical expertise from special federal teams
- Special equipment

**Notes:**
The OSC can provide valuable assets to assist state and local agencies during an incident, such as:
Enforcement authorities to ensure that the responsible party (RP) cleans up the discharge or release; 
Immediate access to technical assistance and cleanup contractors if the response is beyond the RP’s capabilities; 
Immediate access to Superfund and the Oil Spill Liability Trust Fund (OSLTF) to pay for responses (EPA OSCs are individually authorized through approval of emergency response action to activate up to $200,000 immediately and may obligate up to $250,000 under their contracting officer authority.  Most removal actions led by EPA cost $600,000 to $700,000; however, EPA OSCs may spend as little as $10,000 or into the millions on cleanup support.)  Federal trust funds and federal response equipment are managed by the OSC;
OSCs can reimburse state or local responders who have incurred extraordinary oil or hazmat response costs;
As explained in more detail later in the presentation, RRTs can provide assistance to the OSC during an incident;  
Technical expertise from special federal teams, such as the USCG’s National Strike Force, EPA’s Environmental Response Team, EPA’s Radiological Emergency Response Team, Scientific Support Coordinators, and USN/SUPSALV, for air monitoring, health effects advisories, radiation response, public affairs, oil slick tracking, multimedia sampling and analysis, etc.; and 
Special equipment.

## Slide 5

## Overview

- Purpose of the ICS/UC *Technical Assistance Document*
- Background and authorities for NCP and ICS/UC
- ICS/UC
- Relationship between UC and ICS
- Relationship between the RRT and UC
- ICS/UC:  A response management tool
- Responsibilities under ICS/UC
- Advantages of ICS/UC
- Participants in the UC under the NCP

**Notes:**
The following is an overview of the topics that we will be discussing today:
The purpose of the ICS/UC Technical Assistance Document and this presentation.
The background and authorities of the National Contingency Plan and ICS/UC.
A brief description of what ICS/UC is and why it is used, including:
The relationship between UC and ICS and the relationship between the RRT and UC;
Using ICS/UC as a response management tool;
Responsibilities of participants under ICS/UC; and
The advantages of ICS/UC.
An overview of the participants and their roles in the UC under the NCP.  (Participants in the UC typically include the Federal and State OSCs, the local emergency response incident commander, and the Incident Commander for the RP.)

(Continued on next slide.) 

## Overview (cont’d)

- OSC and RRT Planning Roles and Responsibilities
- Reimbursement programs
- Potential liability
- UC implementation
- Essential planning elements and ACPs
- Initial UC meeting activities
- ICS/UC at work:  Professional Food Systems case study
- Moving Forward
- Sources of ICS information

**Notes:**

A discussion of the OSC and RRT planning roles and responsibilities.
A discussion of the Superfund and Oil Spill Liability Trust Fund (OSLTF) reimbursement programs.
A discussion of the potential liability of responders.
A discussion of implementing a UC through:
Contingency planning and area contingency plan (ACP) development; and
Convening an initial unified command meeting to discuss:  (1) setting priorities and objectives, (2) presenting considerations, (3) developing a collective set of incident objectives, (4) adopting an overall strategy, and (5) selecting a Unified Command spokesperson; and
The Professional Food Systems incident that occurred in Bedford, Virginia will be discussed as an example of ICS/UC at work and effective ICS/UC action, and 
We will conclude with a discussion of next steps for ensuring effective implementation of the ICS with a UC.
We also provide a list of additional ICS information sources.

## Purpose of ICS/UC Technical Assistance Document

- Increase awareness of ICS/UC
- Improve coordination among responders during responses and exercises
- Encourage interagency training programs
- Encourage development of a common language and response culture
- Help achieve consistent, effective, and efficient response among members of the NRS

**Notes:**
The NRT and RRTs hope that the ICS/UC Technical Assistance Document and this corresponding PowerPoint presentation will help:
Increase awareness of ICS/UC;
Improve coordination among responders during response and exercises;
Encourage interagency training programs;
Encourage development of a common language and response culture; and 
Help achieve consistent, effective, and efficient response among members of the NRS.

## Background and Authorities for NCP and ICS/UC

- NCP developed to provide federal agency expertise to responses of oil spills and hazardous substance releases
- Establishes the mechanism for the NRS
- OPA enacted after *Exxon Valdez* to strengthen the NRS and provide better contingency planning coordination
- NIIMS-based ICS first designed to respond to forest fires
- Under the NCP, the NRS functions as an ICS

**Notes:**
In the late 1960s, a major oil spill in Europe made the U.S. Federal Government question its ability to respond to such spills.  As a result, several U.S. federal agencies developed a National Contingency Plan, or NCP.  The Plan was developed to bring federal agency expertise to bear during responses to oil spills and releases of hazardous substances.  The NCP establishes the mechanisms for an NRS.  The two primary legal authorities for the NCP are the Clean Water Act (CWA) (33 U.S.C. 1251 et seq.), which establishes a fund for federal responses to oil spills, and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (42 U.S.C. 9601 et seq.), which establishes the Superfund for federal responses to releases of hazardous substances. 
The Oil Pollution Act (OPA) of 1990, which amended the CWA, was signed by the President after both houses of Congress passed the Act unanimously.  After several similar proposals had been unsuccessful over the previous 15 years, Congress enacted this legislation partly in response to the Exxon Valdez spill and several other incidents.  The OPA of 1990 was enacted to strengthen the NRS and provide for better coordination of spill contingency planning among federal, state, and local authorities.  To do this, the OPA required revision of the NCP to expand federal removal authority, add responsibilities for Federal OSCs, and broaden preparedness planning and requirements.  
The National Inter-agency Incident Management System (NIIMS) was originally designed by a group of local, state, and federal agencies with wild-land fire protection responsibilities, to improve the ability of fire forces to respond to any type of emergency.  The NIIMS-based ICS is most commonly used and endorsed by the USCG as the response management system for oil spills in the coastal zone.
The NCP states that the NRS functions as an ICS under the direction of the OSC, with the basic framework for the response management structure being a system (e.g., a unified command system) that brings together the functions of the Federal Government, the state government, and the responsible party to achieve an effective and efficient response, where the OSC maintains authority.  Therefore, the NRT endorses the use of the ICS/UC and hopes that this presentation will provide an understanding of the basic concepts of ICS/UC. 

## Background and Authorities for NCP and ICS/UC cont.

- 1989 EXXON VALDEZ Report to the President
- 1994 Revisions to the NCP
- 1996 and 2002 NRT Technical Assistance Documents

**Notes:**
The concept for coordinated federal, state, and local response management was recommended in the 1989 National Response Team report to the President of the United States on the Exxon Valdez incident. 
The Incident Command System/Unified Command is included in the revisions to the 1994 version of the National Contingency Plan. The document on the slide #5 updates the document first published in 1996. It highlights the issues and lessons learned identified by NRT member agencies that have arisen through responses to major incidents throughout the U.S. It also provides guidance that should lead to more effective and efficient responses under the NRS. The NRT plans to update this technical assistance document periodically to reflect the evolving use of an ICS led by a UC. 

## Background and Authorities for NCP and ICS/UC cont.

- The NRT recommended that NIIMS-based ICS/UC be used for on-site response management during terrorist incidents
- A recommendation from the NRT to the Department of Justice after TOPOFF 2000, the largest domestic terrorism exercise in the US to date
- ICS/UC is an important element of the Homeland Security Presidential Directive #5 that addresses terrorist incidents

**Notes:**
The use of National Interagency Incident Management System-based Incident Command System/Unified Command for on-site response management during terrorist incidents was a recommendation from the NRT to the Department of Justice after TOPOFF 2000, the largest domestic terrorism exercise in the US to date.
The Department of Homeland Security is expected to include the Incident Command System/Unified Command as an important element in their response management plan for addressing terrorist incidents. 

## Incident Command System

- Provides organizational structure for response to any single incident or multiple incidents without being hindered by jurisdictional boundaries
- Integrates communication and planning by establishing a manageable span of control
- Divides emergency response into five functions:  Command, Operations, Planning, Logistics, and Finance/Administration

**Notes:**
An ICS provides an organizational structure for all emergencies, including response to oil spills and discharges and hazardous substance emergencies.  In the inland zone, the ICS is typically implemented at the local level by first responders (e.g., fire, police, emergency management agencies).  ICS integrates communication and planning by establishing a manageable span of control. While ICS is an optional, but strongly endorsed, tool for use by EPA, USCG has formally adopted the use of ICS USCG-wide under Commandant Instruction 3120.14.  USDA also has adopted ICS – the U.S. Forest Service originally established ICS for fighting forest fires.  FEMA and other federal agencies also endorse ICS. 
The ICS divides an emergency response into five manageable functions that are essential for emergency response operations:  
Command;
Operations;
Planning;
Logistics; and 
Finance and Administration.
The following is a list of the duties generally associated with each ICS function:  Command staff is responsible for public affairs, health and safety, and liaison activities within the incident command structure; the Operations staff undertake operations directly applicable to the primary mission of the response, the Planning staff collect, evaluate and disseminate the tactical information related to the incident, and prepare Incident Action Plans, the Logistics staff provide equipment and services, and the Finance and Administrative staff manage finances and administrative support.  The Command includes the Incident Commander, as well as his or her “Command Staff,” as included in the Safety, Information, and Liaison positions.  Each of the other sections (Operations, Planning, Logistics, and Finance) are managed by a section chief and supported by other functional units.  
Depending on the magnitude and impact of the discharge or release, the Congressional liaison position will be handled by the liaison officer.  Similarly, any legal issues will be handled by a legal technical specialist.  Technical specialists are under the direction of the “Planning” function, but can be assigned anywhere in the ICS organization.

## Unified Command

- Component of an ICS
- Responsible for overall management of incident
- Directs incident activities and approves ordering and releasing of resources
- Used whenever multiple jurisdictions are involved in a response effort

-  OSC

- STATEa

- RP

- aThis usually includes local authorities as well.

**UNIFIED COMMAND**

- LOCAL

- OSC

- RP

- STATE

**Notes:**
Often the command function is handled by a single Incident Commander (supported by the command staff), who directs the efforts and receives input from the four supporting areas.  An ICS may be expanded to include a Unified Command for complex responses, which often require multi-agency resources and involve multiple jurisdictions on the federal, state, and local levels.  The ICS/UC brings together the “Incident Commanders” of all major organizations involved in the response.  
Under the NCP, the Unified Command typically consists of the Federal OSC, the State OSC, the Incident Commander of the RP, and usually the local emergency response Incident Commander. The UC directs activities and approves ordering and releasing of resources.
As illustrated in the graphic on this slide, the alteration of the triangular-depicted UC to the circular-depicted UC more accurately represents the presence of  local responders.  As the local response community continues to receive more training on UC, new issues regarding roles and responsibilities are being raised.  For example, if a UC has been established by the local responders when the OSC arrives at the incident scene, who should serve as the Incident Commander?  The local community should be included in discussions that address issues regarding the roles and responsibilities of those included in the UC. 
In addition, the membership of the UC will also be determined by:  (1) the specifics of the incident; (2) planning discussions held before the response; or (3) at a minimum, decisions reached during the initial meeting of the UC.

## When should a UC be used? 

- The UC may be used whenever multiple jurisdictions are involved in a response effort.  These jurisdictions could be represented by:
- Geographic boundaries
- Governmental levels
- Functional responsibilities
- Statutory responsibilities
- Some combination of the above.

**Notes:**
The UC may be used whenever multiple jurisdictions are involved in a response effort.  These jurisdictions could be represented by:
Geographic boundaries  (e.g., two states, Indian Tribal Land);
Governmental levels (e.g., local, state, federal);
Functional responsibilities (e.g., fire fighting, oil spill, Emergency Medical Services (EMS));
Statutory responsibilities (e.g., federal land or resource managers, responsible party under OPA or CERCLA); or
Some combination of the above.

## Participants in the Unified Command under the NCP

**Under the NCP, the UC may consist of the pre-designated Federal OSC, State OSC, Incident Commander for the RP, the local emergency response Incident Commander, and/or other parties as appropriate**
**Local fire and police are frequently first responders to arrive on-scene**
**May establish an initial ICS**
**Relationships can vary depending on state laws and/or practices**
**Makeup of the UC is determined by:**
**Specifics of the incident**
**Determinations outlined in existing response plans**
**Decisions reached during the initial meeting of the UC**
**Makeup of UC may change over time. **

**Notes:**
The NRT and RRTs recognize local government as a key emergency response participant to protect public health and the environment for most emergencies under the jurisdiction of the NRS. Frequently, the first responders to arrive at the scene of an incident will be emergency response personnel from local fire and police departments.  
The majority of local responders are familiar with the ICS in the inland zone, and are likely to immediately establish an ICS.  As federal, state, and private party responders arrive on-scene, they would be integrated into the ICS organization and a UC would be established to direct the expanded organization in response to the multi-jurisdictional incident.  
Although the role of state and local responders can vary depending on state laws and/or practices, it is always expected that local responders will be part of the ICS/UC.
The makeup of the UC is determined by 1) the specifics of the incident; 2) determinations outlined in existing
response plans; and 3) decisions reached during the initial meeting of the UC. 

## Participants in the Unified Command (cont’d)

- Number of personnel should be kept at a minimum
- Decision to include RP in the UC depends on its relationship with members of the ICS

**Notes:**
The UC is a team effort, but to be effective, the number of personnel should be kept as small as possible. The decision to include the Responsible Party in the UC depends on its relationship with members of the ICS.

## Who is in the Unified Command?

- Member organizations in the UC:
- Must have jurisdictional authority or functional responsibility under a law or ordinance for the incident
- Must have an area of responsibility that is affected by the incident or response operations
- Must be specifically charged with commanding, coordinating, or managing a major aspect of the response
- Must have the resources to support participation in the response organization

**Notes:**
Members in the UC have decision-making authority for the response. To be considered for inclusion as a representative, the representative’s organization must: 
Have jurisdictional authority or functional responsibility under a law or ordinance for the incident;
Have an area or responsibility that is affected by the incident or response operations; 
Be specifically charged with commanding, coordinating, or managing a major aspect of the response; and 
Have the resources to support participation in the response organization.
All four criteria must be met by member organizations in the Unified Command. 

## What if you are not a member of the UC?

- Being in the UC does not mean that you are the only member of your agency on the response
- There must be support staff on lower levels
- Being a member in the UC is not the only place one can make a difference
- Much of the “real work” occurs within the sections of the ICS organization
- That is where you should be involved!

**Notes:**
Being in the UC does not mean that you are the only member of your agency on the response as there must be support staff on lower levels. Being a member in the UC is not the only place one can make a difference because the majority of the “real work” occurs within the sections of the ICS organization.

## Duties of UC Representatives

- Establish response objectives and priorities
- Sustain a 24-hour-a-day, 7-day-a-week commitment to the incident
- Ability to commit resources
- Authority to spend funds
- Agree on an incident response organization
- Agree on the appropriate Command and General Staff position assignments
- Commit to speak with one voice through the Information Officer or JIC
- Agree on logistical support procedures
- Agree on cost-sharing procedures

**Notes:**
UC representatives must also be able to: 
Agree on common incident objectives and priorities; 
Have the capability to sustain a 24-hour-a-day, 7-day-a-week commitment to the incident;
Have the authority to commit agency or company resources to the incident;
Have the authority to spend agency or company funds;
Agree on an incident response organization;
Agree on the appropriate Command and General Staff position assignments to ensure clear direction for on-scene tactical resources;
Commit to speak with one voice through the Information Officer or Joint Information Center, if established;
Agree on logistical support procedures; and
Agree on cost-sharing procedures, as appropriate

## Relationship between ICS and UC

**Notes:**
As a component of an ICS, the UC provides the organizational management tool to facilitate and coordinate the effective involvement of the various agencies.  It creates the link between the organizations responding to the incident and provides a forum for these agencies to make decisions that all responders can agree with.  Under this single UC, the various jurisdictions and/or agencies are blended together throughout the Incident Command System to create an integrated response team.
It is important to recognize that the key players in the response management system maintain a separate internal management infrastructure during a response; they do not relinquish agency authority, responsibility, or accountability.  Modification of the ICS into a UC enables responders to carry out their own responsibilities, while working cooperatively within one  response management system.  Depending on the needs of the incident, it may be appropriate to modify the ICS with a UC, while in other circumstances it may not.  This decision will be based in large part upon the level of the response and the need for additional resources.
With the evolution of UC, when an incident escalates and more than one agency or jurisdiction becomes involved, the ICS can be expanded to manage the increasing demands of the incident, utilizing personnel and facilities as dictated by the incident.  
The roles of the various ICS participants will vary depending on the incident and may even vary during the same incident.  Based on a consensus decision by members of the UC, one agency may fulfill the duties of the Operations function, whereas several state agencies may be needed to the fulfill the duties of the Planning function during an incident.  In addition, these two functions may be responsible for their own logistics and finance support.  The key to successful implementation of an ICS/UC is planning and exercising at the regional and area levels to help all participants understand their roles and responsibilities.

## Relationship Between the RRT and UC 

-    National Response System Concept of Response

**Notes:**
As outlined in Section 300.115 of the NCP, regional planning and coordination of preparedness and response actions is accomplished through the RRT.  The RRT agency membership parallels that of the NRT, but also includes state representation.  
When needed during an incident, the RRT provides coordination of assistance and advice to the OSC during response actions.  The basic function of the RRT is to provide support to the OSC by acting as a sounding board, a means to access resources, a support mechanism, etc.
During response actions, the members of the RRT seek to make available the resources of their agencies to the OSC as specified in the RCP and ACP.
During an incident, the RRT may be convened either by telephone or in person.  RRTs can convene on scene, at the request of the OSC, in the form of an incident-specific RRT.  Incident-specific teams are formed from the standing team when the RRT is activated for a response.  On incident-specific teams, participation by the RRT member agencies will relate to the technical nature of the incident and its geographic location.  The role of the incident-specific team is determined by the operational requirements of the response to a specific discharge or release.  Key responsibilities of the incident-specific RRT are monitoring the response, providing communications support, making recommendations to the OSC consistent with the RRT’s expertise, and mobilizing resources available in the region, as requested by the OSC in specific response situations.  In areas where use of chemical countermeasures (CCMs) is not preauthorized, the NCP requires concurrence from EPA and state RRT representatives and recommends consultation with DOI and DOC RRT representatives.  However, in areas where CCM use is preauthorized, the RRT does not need to be involved.  ACPs should be used as the means for documenting – and for informing responders  about – the areas for which CCM use is preauthorized.
If the assistance requested by an OSC exceeds an RRT’s capability, the RRT may request assistance from the NRT.

## ICS/UC:  A Response Management Tool

- Assists the OSC in directing, monitoring, and coordinating response efforts
- Responding organizations retain their authorities and responsibilities
- Facilitates and coordinates the effective involvement of the various agencies
- Creates link between the organizations responding to the incident

**Notes:**
The use of ICS/UC as a management tool does not relieve the OSC of her or his obligation to direct, monitor, and coordinate response actions.  Rather, the ICS/UC is a useful mechanism in obtaining input from other responders to help the OSC in directing and coordinating response efforts.  Under the NCP, each responding organization has a role to play.  The UC allows all parties with jurisdictional or functional responsibility for the incident to work together to develop a common set of incident objectives and strategies.  At the same time, the UC allows each responding organization to maintain its authorities and responsibilities.  The RP is expected to conduct the response under the oversight and/or direction of the OSC.  State and local responders are responsible for protecting public safety and thus, for responding to threats to the public safety.
As we saw in the UC triangle on the previous slide, the UC provides a place for the decision-makers from each of the responding organizations to come together.  Finally, the ICS/UC also allows for information sharing both horizontally and vertically throughout the response organization, allowing a multi-jurisdictional response to be conducted effectively.  A Joint Information Center (JIC) may also be associated with the ICS/UC, under the direction of the UC.

## ICS/UC: A Response Management Tool (cont’d)

- Provides an avenue for response  organizations to establish input in the decision-making process
- Allows for information sharing both horizontally and vertically throughout the response organization
- All parties must be integrated throughout the response

**Notes:**
As outlined in the preamble to the 1993 NCP proposed rule, the emphasis during oil spill response is on coordination and cooperation, rather than on a more rigid system of command and control.  The OSC, the state/local government representatives, and the RP all are involved with varying degrees of responsibility, regardless of the size or severity of the incident.  The OSC in every case retains the authority to direct the spill response, and must direct responses to spills that pose a substantial threat to the public health or welfare of the U.S.  In many situations, however, the OSC will choose to monitor the actions of the RP and/or state/local governments and provide support and advice where appropriate.  The response management structure does not attempt to prescribe a specific item-by-item functional description of where particular organizations or individuals fit within a single response structure for a given response.  Developing, adapting, and implementing a response management system, such as an ICS/UC, is the responsibility of the OSC and the Area Committee through the ACP.

## Responsibilities of Command/General Staff under ICS/UC

- Provide response direction
- Coordinate effective communication and resources
- Establish incident priorities
- Develop mutually agreed-upon incident objectives and approve response strategies
- Assign objectives to response structure
- Review and approve incident action plans

**Notes:**
The following is a list of Command Staff and General Staff responsibilities that must be performed or assigned by the Incident Commander of any response to ensure that all participating agencies are kept properly informed:
 Provide overall response direction;
 Coordinate effective communication;
 Coordinate resources;
 Establish incident priorities;
 Develop mutually agreed-upon incident objectives and strategies;
 Assign objectives to response structure;
 Review and approve incident action plans;
 Ensure integration of response organization; 
 Establish protocols;
Ensure worker and public health and safety; and
Inform the media.

## Responsibilities of Command/General Staff under ICS/UC (cont’d)

- Ensure integration of response organizations
- Establish protocols
- Ensure worker and public health and safety
- Inform the media

## Advantages of ICS/UC

- Uses a common language and response culture
- Optimizes combined efforts
- Eliminates duplicative efforts
- Establishes a single command post
- Allows for collective approval of operations, logistics, planning, and finance activities
- Encourages a cooperative response environment
- Allows for shared facilities, reduced response costs, *increased* efficiency and *fewer* communication breakdowns
- Permits responders to develop and implement one consolidated Incident Action Plan

**Notes:**
Advantages to using the ICS/UC include: 
Use of a common language and response culture;
Optimization of combined efforts;
Elimination of duplicative efforts;
Establishment of a single command post;
Development of collective approval of operations, logistics, planning, and finance activities;
Encouragement of cooperative response environment;
Allowance for shared facilities, which not only reduces costs for those responding, but also increases efficiency and leads to fewer communication breakdowns; and 
Development and implementation of one consolidated Incident Action Plan.

## How do responders prepare for ICS/UC implementation? 

- Planning and exercising at the regional and area levels using the ACP process.
- Practice using an ICS/UC to help responders understand their roles and responsibilities and prepare them to work together in the ICS.
- The OSC and the Area Committee are responsible for developing, adopting, and implementing a response management system, such as ICS/UC, through the Area Contingency Plan (ACP).
- Using a NIIMS-based ICS/UC as the model for response management in the ACP to ensure an effective response

**Notes:**
The key to successful implementation of an ICS/UC is planning and exercising at the regional and area levels.  Practice using an ICS/UC prior to an incident will help responders understand their roles and responsibilities and prepared them to work together in the ICS.  According to the NCP, the area contingency planning process, which brings together appropriate representatives from local, state, and federal agencies to enhance contingency planning, is the forum for working out the details of how the ICS will be applied in each area.  When responders understand each other’s roles and responsibilities and have a plan for working together, they are more likely to be able to reach consensus on response strategies and tactics.  The OSC and the Area Committee are responsible for developing, adopting, and implementing a response management system, such as ICS/UC, through the Area Contingency Plan (ACP). Use of a NIIMS-based ICS/UC as the model for response management in the ACP can be helpful in ensuring an effective response.

## Essential Planning Elementsfor Implementing ICS/UC

- Formalized structure accepted by all parties
- Well-defined functions and responsibilities
- Designated individuals for each function
- Defined and accepted reporting mechanisms
- Established methodology for developing IAP and Site Safety Plan

- Participant commitment to respond as a team
- Training and familiarity with ICS/UC addressed in plans
- Defined relationships to entities outside ICS but relevant to the NRS

**Notes:**
According to the NCP, the area contingency planning process, which brings together appropriate representatives from federal, state, and local agencies to enhance contingency planning, is the forum for working out the details of how the ICS will be applied in each area.  To ensure that ICS/UC is effectively implemented, discussions must occur at the Area Committee level and in the Area Contingency Planning process.  When responders understand each other’s roles and responsibilities and have a plan for working together, they are more likely to be able to reach consensus on response strategies and tactics.
For the ICS/UC to be effective, the following elements should be in place and documented in relevant plans well before an incident occurs:
The structure must be formalized and accepted by all parties concerned;
Specific functions and responsibilities must be well defined; 
Individuals must be designated for each function and the reporting mechanisms defined and accepted;
A methodology for developing an Incident Action Plan and Site Safety Plan should be established;
The participating organizations must make a committed effort to respond as a team; 
Contingency plans (including ACPs, facility and vessel response plans, and LEPC plans) must address training and ensure familiarity with ICS utilizing a UC; and
Relationships and interactions with entities outside the ICS but relevant to the NRS (e.g., RRT, Natural Resource Trustees) must be defined.

## Area Contingency Plans and ICS/UC 

**Area Contingency Plans should consider:**
- Jurisdictional responsibilities
- Roles of all levels of government in the Unified Command (i.e., federal, state, and local)
- Financial agreements
- Information dissemination
- Communications
- Training and exercising
- Logistics
- NRS organizational components
- Lessons learned

**Notes:**
The NCP does not prescribe specifically how a particular organization or individual fits within a given response structure.  The OSC and the Area Committee are responsible for developing, adopting, and implementing a response management system, through the ACP.  An ICS/UC based on the National Inter-agency Incident Management System (NIIMS) can be used as the model for response management in the ACP to ensure an effective response.  Included in this model, each ACP should fully address and describe key organizational components of the NRS, such as the role of the RRT.  Because key players differ from area to area, however, Area Committees must have flexibility to adapt the ICS/UC to be effective in each specific area.  

## OSC’s Planning Roles and Responsibilities

- Oversee development of the area contingency plan (ACP)
- Coordinate, direct, and review work of other agencies, Area committees, RP’s and contractors
- Coordinate with state and local response agencies
- Periodically conduct drills of spill removal capability
- Monitor the actions of the RP and state and local governments

**Notes:**
Under the NCP, OSCs have the responsibility to oversee development of the ACP in the area of the OSCs responsibility. The NCP states that the development of ACPs should be accomplished in cooperation with the RRT, and designated local and state representatives, as appropriate. In both contingency planning and spill response, the OSC is responsible for coordinating, directing, and reviewing the work of other agencies, Area committees, RPs and contractors to ensure compliance with the NCP and other plans applicable to the response. 
In developing the ACP, the OSC must coordinate with state and local response organizations, including those represented on the State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs). In addition, the OSC must periodically conduct drills of spill removal capability, including fish and wildlife response capability, without prior notice, in areas for which ACPs are required and under relevant tank vessel and facility response plans. 

## RRT Planning Roles and Responsibilities

- Develop and coordinate preparedness activities before a response is taken
- Coordinate assistance and advice to OSC during response actions
- Provide guidance to Area Committees to ensure inter-area consistency and consistency of individual ACPs with the Regional Contingency Plan and the NCP

**Notes:**
As outlined in Section 300.115 of the NCP, regional planning and coordination of preparedness and response actions are accomplished through the RRT. The RRT agency membership parallels that of the NRT, but also includes state and local representation. The RRT provides the appropriate regional mechanism for development and coordination of preparedness activities before a response action is taken and for coordination of assistance and advice to the OSC during response actions. 
The two principal components of the RRT mechanism are a standing team and incident-specific team. The standing team consists of designated representatives from each participating local and state government and federal agency. The role of the standing RRT includes providing regional access to communications systems and procedures, planning, coordination, training, and evaluation.

## OSC’s Response Roles and Duties 

- Direct, monitor and coordinate response actions
- Monitor the actions of the RP and/or local and state governments and provide support and advice where appropriate
- Explain the OSC’s authority at a response during both the planning and response phases
- Implement an ICS at the beginning of a response, OR be prepared to integrate into an existing, properly functioning, ICS during a response
- May establish any of the functions of an ICS by assigning responsibility to another individual
- Provide access to appropriate response trust funds

**Notes:**
The use of the ICS/UC as a management tool does not relieve the OSC of her or his obligation to direct, monitor, and coordinate response actions.  The OSC in every case retains the authority to direct the response, and must direct responses to discharges of oil that pose a substantial threat to the public health or welfare of the United States.  In most situations, however, the OSC will choose to monitor the actions of the RP and/or local and state governments and provide support and advice where appropriate.  It is the OSC’s responsibility to explain the OSC’s authority at a response during both the planning and response phases.  The ICS/UC also is a useful mechanism in obtaining input from other responders to help the OSC in directing and coordinating response efforts. 
The OSC should either implement an ICS at the beginning of a response, or be prepared to integrate into an existing, properly functioning, ICS during a response.  It is important to recognize that local and/or state responders may already have established an ICS when the OSC arrives on-scene.  In many cases, the OSC will fill multiple positions within the ICS organization.  An OSC also may elect to establish any of the functions of an ICS by assigning responsibility to another individual. 

## The Role of the Regional Response Teams

- National Response System Concept of Response

**Notes:**
Ideally, consensus will be achieved within the UC.  However, if consensus is not reached during the initial meeting of the UC, the RRT can be used as a forum for achieving consensus. The incident-specific RRT provides a mechanism for the Federal OSC to seek support and conflict resolution from the regional leadership of his or her own agency, other federal agencies, and state and local governments participating in the RRT. 

## Implementation During an Incident:  Initial Unified Command Meeting

- Initial meeting** **is an opportunity for open discussion to:
- Set priorities and objectives
- Present considerations
- Develop a collective set of incident objectives and priorities
- Adopt an overall strategy
- Select a Unified Command spokesperson
- Establish a JIC, as needed
- Decide on initial membership of UC

**Notes:**
When an incident does occur, and plans need to be implemented, open and early discussion between response commanders is critical to ensuring effective implementation of the NRS and use of ICS/UC.  The establishment of a UC must begin with an initial meeting to set priorities and objectives, present considerations, and develop a collective set of incident objectives.  This meeting should include only the Incident Commanders and their staffs from each of the involved jurisdictions.  During this meeting – which should be brief – the Incident Commanders must come to consensus on priorities and objectives, a collective set of incident objectives, an overall strategy, and a Unified Command spokesperson before they can effectively work together to carry out the response.  The initial meeting will also provide an opportunity for the Incident Commanders to establish a JIC as needed.  In addition, if not established in pre-planning activities, the Incident Commanders must use the initial meeting as an opportunity to determine the appropriate roles and responsibilities of all the players involved in the ICS (e.g., state and local governments, the RP).  As discussed earlier, this conversation will help establish the membership of the UC.
Although an initial meeting is critical for ensuring the effective integration of all responders, these steps may have to be revisited periodically as information on the incident or the demands of the incident change.
These meetings will provide a private opportunity for the Incident Commanders to speak openly and honestly about their priorities, considerations, and concerns.  However, once participants in the Unified Command leave this meeting, they must speak with one voice.  
These steps are addressed on the following slides. 

## Initial Unified Command Meeting Step 1:  Set Priorities and Objectives

- National Response Priorities specifically for oil response established by the NCP for the NRS**:**
- Preserve safety of human life
- Stabilize the situation to prevent the event from worsening
- Minimize adverse effects to the environment
- Address these three priorities concurrently
- Each responding entity will likely have other significant priorities

**Notes:**
For the Unified Command to work, each participant must be committed to working together to solve a common problem.  Each responding agency will have objectives to carry out.  Fortunately, the primary objectives of each responding agency during oil response are established under the NCP as “national response priorities” and include:
Preserving safety of human life;
Stabilizing the situation to prevent the event from worsening;
Using all necessary containment and removal tactics in a coordinated manner to ensure a timely, effective  response that minimizes adverse impacts to the environment; and
Addressing all three of these priorities concurrently (that is, not sequentially, but all at once). 
However, each responding agency will likely have other significant priorities during oil or HAZMAT response requiring consideration.  These might include such factors as:
Maintaining business survival;
Minimizing response costs, or keeping them within liability or insurance limits;
Maintaining or improving public image;
Minimizing economic or tourist impact (e.g., public use might be a key consideration for a state or local official as a result of an incident affecting beaches in a prime vacation area prior to spring break);
Minimizing natural resource restoration costs;
Evaluating prospects of criminal prosecution;
Obligating that the OSC meet the “direct” mandate per OPA 90 (OPA states that the OSC must “direct” the responses to certain incidents.  However, realistically, the OSC can only command other federal resources and those of the PRP.  As a result of this requirement, however, the OSC may need to document his or her role in “directing” the response through participation in the Unified Command); and
Meeting certain reasonable stakeholder expectations (public, agency, interest group, or political).
Understanding all the issues facing the participants is important in any negotiation – and the Unified Command must be viewed as a negotiation, because consensus must be reached for the Unified Command to be effective.

## Initial Unified Command Meeting Step 2:  Present Considerations

- UC members discuss their organization’s authorities, equipment, skills, experience, and response capabilities
- Constraints and capabilities must be shared openly

**Notes:**
At the onset of any initial meeting, UC members have an obligation to raise and discuss the limitations of their response capabilities.  All Incident Commanders must be free to speak openly with the other members of the UC about their constraints or limitations, whether practical or political in nature, because these other constraints may have very real impact on how the Unified Command’s objectives can best be achieved. This process will help to clarify what each response organization can provide in terms of authorities, equipment, skills, and experience.

## Initial Unified Command Meeting Step 3:  Develop a Collective Set of Incident Objectives

- Identify what the Unified Command *as a whole *needs to accomplish
- Develop a set of incident-specific objectives for the response
- Objectives should be measurable, assignable, reasonable, and time-related
- Helps to provide focus to the growing response organization
- Includes establishing and agreeing upon acceptable priorities

**Notes:**
The planning process for UC is similar to that used for a single jurisdiction or agency incident.  However, because each agency will bring its own set of objectives and considerations to the response, the UC must decide upon a collective set of incident objectives before an overall response strategy can be developed.  To be effective, these objectives should be specific, measurable, assignable, reasonable, and time-related (a.k.a. SMART objectives).  The UC must come to consensus on a set of general objectives that can then be documented to provide focus for the response organization.  This process includes establishing and agreeing upon acceptable priorities.

## Initial Unified Command Meeting Step 4:  Adopt an Overall Strategy

- Determine how to accomplish the objectives
- Request preferred strategies for later approval as necessary

**Notes:**
Strategy is the development of policies and plans to achieve the objectives for a response.  If the UC knows exactly how to accomplish an objective, it should specify the strategy.  However, because there are frequently multiple possible strategies that would accomplish the same objective, the UC will often ask the planning and operations section chiefs to recommend preferred strategies for later approval.  This allows for better input and discussion from the responders, and also reduces meeting time for the Incident Commanders.

## Initial Unified Command Meeting Step 5:  Select a Unified Command Spokesperson

- Establish a JIC
- A single spokesperson is typically needed to speak for the Unified Command
- One of the members of the Unified Command
- Point of contact and a single voice to the incident management team
- Spokesperson at internal and external briefings
- Final procedural check

**Notes:**
Frequently, the Unified Command will establish a JIC and designate a single spokesperson.  The spokesperson:
Is typically a member of the Unified Command;
Serves as a point of contact and a single voice of the members of the incident management team;
Is the actual spokesperson at external and internal briefings (e.g., although technical information will be released through the JIC, the spokesperson may assist the information officer by providing press conferences when needed by the JIC);
Does not make Unified Command decisions; and
Can also be used as a final procedural check before response actions are undertaken.  For instance, the spokesperson may be included in in situ burn plans as the person with whom the responders in the operations section will check before the burn is ignited.
The spokesperson may change during the course of an incident as the situation develops.  For example, a different agency may designate a spokesperson if it has more expertise in a particular area at a certain time.  In addition, different departments within the same agency could designate a spokesperson at different times during the same incident, as appropriate.

## ICS/UC at Work:Professional Food Systems Case Study

- Leak in accumulator assembly valve released anhydrous ammonia into the PFS building and the outside environment
- Approximately 4,000-5,000 pounds of anhydrous ammonia contained in the system was leaking at 4-5 pounds per hour
- Leak was slowed by initial responders, but not completely contained
- Ammonia gas accumulated in the building, presenting difficulties for the responders

**Notes:**
This is an example of how an ICS/UC was used at an actual response.  The emergency response to the Professional Food Systems release of anhydrous ammonia in the State of Virginia presents an example of successful use of the ICS/UC.  This example is included in an appendix to the NRT’s ICS/UC technical assistance document.
PFS, the potentially responsible party, is located in an industrial park that lies within a half mile of a residential area. The release of anhydrous ammonia at the PFS site was the result of a leak in the check valve on an accumulator assembly of an anhydrous ammonia-based refrigeration system at the meat storage and processing facility. Approximately 4,000 to 5,000 pounds of anhydrous ammonia contained in the refrigeration system were leaking at a rate of 4-5 pounds per hour. An unknown quantity of anhydrous ammonia was released from the valve into the  PFS building and outside environment.
The leak was initially identified by a mechanical contractor as PFS personnel were performing a repair operation on the refrigeration unit, however the contractor and personnel were unable to control the leak and thus contacted local responders. The leak was slowed by the initial responders, but was not completely contained due to difficulties presented by the configuration and limited space around the leaking valve, as well as significant concentrations of ammonia gas accumulating in the building. 

## ICS/UC at Work: Professional Food Systems Case Study (cont’d)

- Bedford Volunteer Fire Company and the Roanoke Valley Regional HAZMAT Response Team were first to respond
- Established an ICS
- Began response actions
- FOSC initiated response from off-site by deploying ERT
- FOSC merged into the existing ICS structure

**Notes:**
The Bedford Volunteer Fire Company and the Roanoke Valley Regional Hazardous Materials Response Team were the first to respond to the scene. In addition, the Bedford County Hazardous Materials Response Team responded to assist the fire company, and the Bedford County Director of Public Safety was on-scene. The Virginia Department of Emergency Services also responded to the incident, and the Virginia Emergency Operations Center (VA EOC) requested assistance from EPA Region II as the need for technical expertise was immediate and additional response resources were necessary. The federal OSC initiated response activities from off-site in Philadelphia by arranging for technical expertise from the EPA Environmental Response Team to be available for chemical and engineering advice. The federal OSC also contacted the United States Coast Guard Atlantic Strike Team and mobilized a Site Assessment and Technical Assistance response team capable of Level A entry and ammonia monitoring capability (Level A protection is required when the greatest potential for exposure to hazards exists, and when the greatest level of skin, respiratory, and eye protection is required.) Upon arrival at the scene, the federal OSC met with the Virginia Department of Emergency Services and the Bedford Volunteer Fire Company Incident Commander to establish the federal OSC’s role in the Unified Command. The ICS established in response to the Bedford incident was initiated by the local responders. When the federal OSC arrived on-scene, he merged into the existing structure, which was already functioning properly.

## Responding Organizations

- US EPA Region III Removal Response Section
- VA DES
- Bedford Volunteer Fire Company/Rescue Squad
- Forrest Volunteer Fire Company/Rescue Squad
- USCG Atlantic Strike Team
- Roanoke Valley Regional Hazardous Materials Response Team
- Bedford Police Department
- Professional Food Systems
- US EPA ERT
- USDA
- Roy F. Weston Inc. SATA
- City of Bedford, VA
- Webb Technologies

**Notes:**
As shown on this and the next slide, numerous federal, state, local, and RP responders can be expected at any significant incident.  A Unified Command is critical to ensuring that all responders work together in the most efficient and effective way.  The ICS/UC allowed the many incident commanders from various jurisdictions to manage and coordinate effectively an emergency response that included the participation of approximately 30 federal, state, and local agencies.

(Continued on next slide.)

## Responding Organizations (cont’d)

- Franklin County Fire Department
- Evington Fire Department
- Smith Mt. Lake Fire Department
- Lyn/Dan Heights Fire Department
- Stuartsville/Chamblissberg Fire Department
- Huddleston Fire Department/Rescue Squad
- Chamblissberg Fire Department
- Moneta Fire Department/Rescue Squad
- Boonesboro Fire Department/Rescue Squad
- Montvale Fire Department
- Saunders Fire Department
- Good Rescue Squad
- Campbell Rescue Squad

## Effective ICS/UC Actions to the Professional Food Systems Response

- OSC immediately able to identify and integrate roles and positions for USCG-AST and contractor resources
- Coordination between and presence of FOSC and state OSC allowed for seamless operations
- ICS/UC informally applied to allow UC to effectively manage diverse responding agencies

**Notes:**
The following is a list of actions taken by the Unified Command at the Bedford incident, which contributed to an effective and successful response: 
Working through the UC, the federal OSC was able to immediately identify roles and positions for the US Coast Guard Atlantic Strike Team and contractor resources that he brought to the response and integrated these federal resources into the response organization.
The federal OSC, the state Hazardous Materials Officer, the local IC, and representative of PFS functioned as the Unified Command. The members of the UC changed over time, but local, state, and federal officials always shared command responsibilities. Since local, state, and federal agencies each shared responsibilities in and provided assets to the response, each organization benefited from its presence in the Unified Command. Additionally, because the primary role of the site entry team shifted between state and federal assets during a 24-hour cycle, the coordination between and the presence of the federal OSC and state OSC in the UC was necessary to ensure seamless operations. The potentially responsible party representative provided the command with contactor support for site expertise and recovery operations.
The Bedford incident presented several difficulties that immediately identified it as a more than routine emergency response:  the ammonia release could not be stopped in a timely manner, and the response teams entering the plant to control the dangerous gas levels required Level A personal protective equipment.  These issues, coupled with the complexity of multi-agency involvement in the incident, suggested the need for ICS/UC structure.  However, the size and likely short-term duration of the Bedford incident suggested that ICS/UC would best be informally applied.  Few ICS forms or formalities were applied, but the basic concepts of ICS were used to allow the UC to effectively manage the diverse responding agencies and effectively implement their strategies.  The Incident Command recognized the value of the ICS/UC structure and allowed that structure to guide and facilitate the response.  Responders decided that they would use enough of the ICS/UC structure to assist them without allowing it to consume the response effort. 

(Continued on next slide.)

## Effective ICS/UC Actions to the Professional Food Systems Response (cont’d)

- Early and continued presence of the USCG-AST, the EPA ERT, and the SATA team provided continuity throughout the response
- Early coordination with local, state, and federal response teams
- Representatives from all appropriate levels of government in the UC expedited coordination efforts with other agencies
- Close and early coordination with the ERT and SATA team

**Notes:**
Early and continued presence of the US Coast Guard Atlantic Strike Team, the EPA Emergency Response Team, and the Site Assessment and Technical Assistance team provided continuity throughout the response.  The expertise, knowledge, and additional resources they made available were invaluable to the successful management of the response. 
Early coordination with local, state, and federal response teams played a key role in the success of mitigation efforts by giving the federal OSC rapid access to a large supporting team and assisting in the resolution of many problems. 
Having representatives from all appropriate levels of government in the Unified Command expedited coordination efforts with other agencies at all levels. 
Close and early coordination with the Emergency Response Team and Site Assessment and Technical Assistance Team ensured that efforts were not duplicated during air quality monitoring, and their knowledge assisted EPA enforcement officials when working with the potentially responsible party. Representatives from the Emergency Response Team and the Site Assessment and Technical Assistance team helped the UC achieve an integrated release response and risk assessment and effectively address the concerns of the public. 

## Moving Forward

- There are four keys to effective   implementation of the ICS/UC as a tool of the NRS:
- Learn the NRS and the ICS
- Plan – ACP process
- Start Early
- Practice - Federal, state, and local officials should plan and conduct exercises
- Develop a sense of team work and trust

**Notes:**
In conclusion, the importance of planning and preparedness in ensuring that the ICS/UC is fully effective should be stressed again.  The keys to successful implementation of an ICS as a tool of the NRS are planning, training and exercising long before an incident occurs.  There are three keys to effective implementation of the ICS with a UC:  
Learn the ICS.  The NRT encourages all responders to learn the NRS and the ICS.  The better it is understood, and the more familiar it is, the easier it will be to form a common structure when demanded by an incident.
Plan. How the ICS/UC will be implemented in varying situations should be decided in advance of an incident. The ACP process should be used to identify roles and responsibilities of the various participants during different response scenarios.
Start early in the game.  As soon as it is determined that two organizations have responsibility for, or in, a response, an ICS/UC should be implemented. 
Practice.  Periodic training/drills are crucial to providing training and role play opportunities in a non-threatening way.
The U.S. Occupational Safety and Health Administration (OSHA) and EPA have promulgated identical standards (at 29 CFR 1910.120 and 40 CFR part 311, respectively) to protect employees engaged in hazardous waste operations and emergency response.  These standards apply to all employees engaged in emergency response activities and principally cover emergency planning, employee training, and employee medical surveillance.
When plans and procedures are understood, agencies can support each other effectively.  However, each response results in new lessons learned, which necessitates continuing refinement of the procedures and processes, development of better methods, and meshing of agency needs and actions.  Planners and responders at all levels need to understand the authorities and resources each response organization brings to a specific incident.  ICS/UC is an important concept to practice as part of response exercises and include in local and area contingency plans.  Such exercising and planning will facilitate coordination and cooperation between federal, state, local, and private party responders when the ICS/UC is implemented at an incident, and make sure that all responders are able to work together effectively to protect human health and the environment.

## Sources of ICS Information

- NRT’s *Minimum Essential ICS Training Elements*
- NRT’s *Federal Natural Resource Trustees and the ICS/UC*
- Annex 3 of the NRT ICP Guidance
- USCG’s Incident Management Handbook
- USCG HQ ICS web site
- RRTs I and II ICS in Oil Spill Response web site
- NSFCC ICS web site
- FEMA’s and the U.S. Fire Administration’s Computer-assisted Instruction for ICS:  Self-study Course
- USCG’s OSC2 – On-scene Command and Control Prototype
*Setting Objectives in a Unified Command:  The “Cost” of Leadership*,1999 IOSC Proceedings
*Incident Command System*, Fire Protection Publications, Oklahoma State University
- NWCG ICS National Training Curriculum modules
- NOAA Electronic ICS Forms – ICSFORMS Solution
- Unified Command: The Mechanism for Ensuring a Comprehensive, Coordinated Response, 1995 IOSC Proceedings