Freedom of Information Act Publication Scheme Protective Marking Not Protectively Marked Publication Scheme Y/N Yes Title Chemical, Biological, Radiological and Nuclear Policy Version 1.0 Summary Policy regarding the policy response to CBRN incidents (B)OCU or Unit, Directorate Specialist Operations Author Counter Terrorism Command Review Date September 2016 Date Issued September 2020
Freedom of Information Publication Scheme Protective Marking: Not Protectively Marked Publication (Y/N): Y Title: Chemical, Biological, Radiological and Nuclear (CBRN) Policy Summary: Policy regarding the policy response to CBRN incidents Branch / OCU: Specialist Operations (SO) Date created: 2 nd September 2016 Review date: September 2020 Version: 1.0 Author: SO15 Counter Terrorism Command Application When? This Policy applies with immediate effect. Who? All police officers and police staff, including the extended police family and those working voluntarily or under contract to the Mayor s Office for Policing and Crime (MOPAC) or the Commissioner must be aware of, and are required to comply with, all relevant Metropolitan Police Service (MPS) policy and associated procedures. This Policy applies in particular to officers and staff in the following roles: All operational staff employed on Borough/Operational Command Units; CBRN-trained staff from all Borough/Operational Command Units including officers in supervisory roles; CBRN Command CADRE; Counter Terrorism Command staff; Event planning staff; Emergency Planning Officers. What? This policy applies to all aspects of police involvement with Chemical, Biological, Radiological or Nuclear incidents. It does not include working in environments filled with smoke, police use of incapacitant spray/agent, or police operations in confined spaces. Policy Principles Within London, a range of incidents occur each year that involve Chemical, Biological or Radiological substances. Whilst some of these are of no direct concern to the MPS, being wholly dealt with by other agencies, a number of 1
these incidents, to varying degrees, involve some form of policing element. In addition, at the far end of the spectrum lies CBRN Terrorism which is, by definition, a policing matter. The MPS has a responsibility towards all CBRN incidents that involve some level of potential criminal allegation or investigation, with the MPS working closely with partner agencies in many cases. The MPS have a number of staff trained and equipped as CBRN responders to respond to an actual or suspected CBRN incident, within the Metropolitan Police Area and throughout the United Kingdom. The roles and duties of these staff include Command & Control, scene reconnaissance, casualty assistance, cordoning, suspect handling, agent sampling and identification, firearms operations, explosive ordnance disposal, criminal investigation, forensics, search, screening and maritime operations. A number of officers have been trained to provide the Strategic, Tactical and Operational levels of command of a suspected or actual CBRN incident, or contingency plan. MPS call-handling staff and all operational MPS staff are provided with training and information on the recognition of a CBRN incident and the initial tasks that should be undertaken to minimise risk and aid the response. At any time a number of CBRN responders are on duty to provide an immediate response to an incident. They cover several roles, including the ability to provide a proportionate immediate assessment of any suspect device, material or atmosphere - enabling incidents to either be escalated early to aid the response, or resolved rapidly to minimise disruption and restore normality. In addition, staff are able to provide assistance to event, security and contingency planning. These functions are conducted in a multi-agency environment, as appropriate to circumstances, with other Police Services in London, Emergency Service Partners, and other agencies. All CBRN responders have been trained to the specific level required for their role, and officers trained and equipped to enter contaminated environments must maintain specific levels of training, fitness and health screening in order to continue in their role. An annual training and exercising programme ensures all CBRN trained staff maintain their skills and are kept up to date with any changes in procedure. 2
Health and Safety Impact Statement This policy and associated toolkit have been developed with appropriate consultation with the MPS Safety and Health Risk Management Team to ensure that all significant Health and Safety risks have been quantified. There are no additional significant health and safety risks associated with this policy that are not the subject of existing risk assessments and controls. Purpose and Benefits The purpose of this policy is to set out the MPS procedures and standards for CBRN planning and the training and equipping of staff to respond to a CBRN incident. This policy provides reassurance and confidence to the public that: The MPS has procedures in place to recognise an actual or potential CBRN incident at the earliest opportunity and immediately task appropriate resources to deal in a proportionate manner, thereby minimising both risk to health and community disruption, aiming to restore normality at the earliest opportunity. MPS staff are appropriately trained, equipped and prepared to deal with any incident that involves, or is suspected to involve, a CBRN element. If an incident does occur, the MPS are able to fully investigate it. This policy ensures standards by mandating that only those members of staff who have been appropriately trained, equipped, and who have passed the appropriate fitness test and health screening, may be CBRN responders. This policy demonstrates that the MPS has effective working relationships with partner agencies, both in London and nationally, to enable the most effective management of a CBRN incident or contingency plan. Associated Documents and Policies CBRN Toolkit Terrorism Response CBRN Authorised Professional Practice CBRN Initial Operational Response Programme 3
London CBRN Response Framework Guidance on the Police Service Response to Operations & Incidents Involving Radiation Notices to be Cancelled / Amended Cancel Item 2 of Notices 9/01, of 28 February 2001 4
Equality Impact Assessment Research and consultation Review of research Internal consultation External Consultation Internal MPS briefing notes were used to inform and build this policy. The following were consulted in the development of this toolkit: Directorate of Legal Services, Safety and Health Risk Management Team (SHRMT), Finance Business Partner, Information Assurance Unit (IAU) and staff associations. In addition frontline officers and CBRN responders and specialists were consulted. External consultation was carried out with Police Federation and Superintendents Association. Protected Characteristics (Equality Act 2010) Summary of Equality Impact Assessment Age The CBRN policy impacts on CBRN police responders from specific protected characteristic groups. These have been clearly outlined below along with explanations and monitoring practices. No impact, negative or positive, has been identified on members of the public at this stage. However, policy monitoring process will capture and address any that may arise in the future. Within the MPS: CBRN responders are required to undergo regular eyesight, hearing and other medical tests. They are required to achieve and maintain a suitable level of fitness. These requirements may be considered to have a negative impact on an older person, however there is no evidence to support this assertion. These requirements have been developed by MPS Occupational Health and are designed to protect the long term health and well-being of the member of staff as well as the wider public. The results of CBRN medicals are monitored and analysed and are used to identify possible areas of improvement. Service delivery: There is no impact identified on people from this Protected Characteristic at this stage. 5
Deaf/ disability Within the MPS: This policy will impact officers and staff with physical and/or mental disabilities and those who are significantly visually or hearing impaired. CBRN responders are required to undergo regular eyesight, hearing and other medical tests. They are required to achieve and maintain a suitable level of fitness and undertake regular psychological screening. These criteria have been developed by MPS Occupational Health and are designed to protect the long term health and well being of the member of staff as well as the wider public. Such impact is justified in that being a CBRN responder requires a considerable degree of physical and mental capability, and needs to be undertaken in stressful, dynamic, situations where no support or reasonable accommodation will be available or possible. Service delivery to the Public: There is no impact identified on people from this Protected Characteristic at this stage. Gender reassignment Pregnancy and Maternity There is no impact identified on people from this Protected Characteristic at this stage. Within the MPS: MPS policy on pregnancy directs that a full risk assessment should be carried out by a member of staff s line manager as soon as an officer notifies the MPS that she is pregnant. There is an expectation that this risk assessment would lead to the officer being removed from CBRN duties, as the potential risks posed both to her own health and that of her unborn child would be too great for her to continue. There are no specific guidelines as to when a member of staff can return being a CBRN responder after giving birth or suffering a miscarriage, this would be determined on a case-by-case basis in consultation with Occupational Health. These guidelines are in place to protect the health and wellbeing of the member of staff. Service delivery to the Public: There is no impact identified on people from this Protected Characteristic at this stage. Race There is no impact identified on people from this Protected Characteristic at this stage 6
Religion or belief Within the MPS: Members of staff, who either i) wear turbans or ii) have a full beard, will be impacted by this policy. This is because it is not possible to wear protective headgear over the top of a turban and facial hair compromises the seal of the protective respiratory equipment worn. In respect of turbans, staff may have the option of wearing a patka (a smaller head covering), which may be worn underneath protective headgear as long as it does not impinge on any seal or the fit of the protective equipment. Sikh officers who cannot remove their turban would be unable to become CBRN responders. Any staff, including Sikh staff, with full beards would not be allowed to be CBRN responders. This policy is designed to protect the safety of the member of staff; it is necessary to ensure that staff are not put at unnecessary risk through compromise of the seal of their protective respiratory equipment. Any member of staff with a religious or cultural requirement to wear or carry any item would need to be able to demonstrate that the item did not interfere with the wearing, use or removal of CBRN Personal Protective Equipment, did not interfere with any tasks required to be conducted at a CBRN incident, and did not put the member of staff under any excessive physiological burden. Service delivery to the Public: There is no impact identified on people from this Protected Characteristic at this stage. Sex Within the MPS: Female members of staff are subject to limitations when working with radiation if they are pregnant or breastfeeding, being subject to a reduced operational radiation dose limit. This is to protect the unborn foetus or new-born. Aside from this, dose limits - both operational and emergency - are equivalent with male limits. Service delivery to the Public: There is no impact identified on people from this Protected Characteristic at this stage. Sexual Orientation There is no impact identified on people from this Protected Characteristic at this stage 7
Other issues for example: Low income groups, single parents, rough sleepers There is no impact identified on people from Protected Characteristic at this stage Monitoring 12 month implementation plan This policy will be implemented across the MPS with additional communication to officers and staff to ensure they are aware of the policy and corporate standards for handling CBRN related matters. Training compliance is monitored through the CBRN training team. And policy compliance is monitored through regular management meetings. Wider compliance is enforced through the network of SPOCs who meet periodically, with oversight available from the CBRN strategic group. MPS compliance is monitored via national CBRN responder requirements. 8