Comment Submitted by George Blackmore, Austin Fire Department

Docket ID: DHS-2009-0091 Proposed Guidance for Protecting Responders’ Health During the First Week Following a Wide-Area Anthrax Attack The guidance articulates logical assumptions and offers common sense response strategies. The scenario, impact and assumptions are plausible and based on scientific findings. Proper response actions warrant deliberate consideration at multiple levels of government. However, the science-based scenario coupled with the identified knowledge gaps illustrates the truly disastrous potential of such an attack. Although this is proposed guidance targeting responders’ health following an attack, I would suggest it also highlights the need for a more comprehensive response strategy to include public actions. The guidance suggests the employment of a public safety shelter in place strategy, but that should be further defined to include communications strategies and impact to commerce considerations. In addition, the knowledge gaps that include lag time reducing the window of opportunity to begin Post Exposure Prophylaxis suggest the strategy of pre-event placement of antibiotics for emergency responders receive much stronger consideration. The St. Louis study of pre-event placement of antibiotics for the public also suggests this strategy as a viable alternative to mass dispensing with attendant logistical problems in a very compressed timeframe. Even though there are serious impediments and questions concerning pre-event placement of antibiotics in the home, given the catastrophic potential of a wide-area anthrax attack, the strategy deserves deliberate consideration. That such an attack is certainly in the realm of possibility, is it prudent to consider such a strategy with its inherent detriments? A certain segment of the population may be negatively impacted and that statistical significance must be quantified, but the known potential for a wide-area anthrax release is truly catastrophic.