Compensatory Considerations for Radiological Emergency Response and Public Protective Actions during the COVID-19 Pandemic

Epidemiological evidence and models have demonstrated that the current COVID-19 pandemic introduces a significant public risk to implementing large-scale community evacuations in response to disasters. While guidance documented in the US Environmental Protection Agency Protective Action Guidance (PAG) Manual is widely accepted as the standard basis for public and emergency worker protective actions for a radiological emergency, it is based primarily on assessing the risks associated with the radiological factors alone. However, as demonstrated in response to the nuclear incident in Fukushima, these events seldom occur in isolation from other risk-inducing events. Today, the COVID-19 pandemic represents a significant public health risk that must also be considered alongside the radiation risks in determining appropriate public and emergency worker protection action decisions. In particular, the significant public health risks associated with community transmission and mortality of COVID-19 challenge our most familiar and rehearsed radiological response strategies. The 1992 and 2017 US Environmental Protection Agency PAG manuals allow for considerations in protective action decision making. Much of the radiation emergency response community has been conditioned through decades of structured training and exercises to focus public protection considerations on specific guidelines referenced numerically in tables within the manual. Discussion regarding adjustment of specific PAG values is provided in the footnotes and bases portions of the PAG manual but is often not included in jurisdictional plans or routinely considered in exercises. However, when properly applied, the protective action guidance provides the necessary flexibility for decision-makers to account for additional public health risks or impediments, and jurisdictions can use this guidance to build a more effective response strategy. The authors have applied the full guidance and flexibility provided in the 2017 US Environmental Protection Agency PAG Manual to develop more specific guidance for their respective jurisdictions' radiation emergency response plans and will outline a process for consideration of protective action decisions to maximize the protection of public health and safety.