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New PREP Guidelines Go Into Effect: June 2016

Posted on Thu, Apr 28, 2016

In April 2016, the EPA released its most recent revision to the Preparedness for Response Exercise Program (PREP). The updated guidelines go into effect June 2016 and incorporate various lessons learned and industry input.

PREP was initially developed to establish an economically feasible exercise program to meet the intent of section 4202(a) of the Oil Pollution Act of 1990 (OPA 90). Completion of the exercises described in the new guidelines is one option for maintaining compliance with OPA 90 response exercise requirements.

Exercise programs provide a mechanism to test participants’ knowledge and understanding of how to mobilize an appropriate response, execute communications and decision-making processes, and effectively manage a worst-case spill response. Effectively planned and executed exercises typically result in improved communication and multi-agency response capabilities in the event of an actual spill.

In order to satisfy PREP guidelines, all of the core components must be exercised once every three years, at a minimum. Today, a unified effort comprised of the following agencies make up the PREP Compliance, Coordination, and Consistency Committee (PREP 4C):

  • U.S. Coast Guard (USCG)
  • Environmental Protection Agency (EPA)
  • Pipeline and Hazardous Materials Safety Administration (PHMSA)
  • Bureau of Safety and Environmental Enforcement (BSEE)

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According to the April 5, 2016 Marine Safety Information Bulletin, “This revision modernizes the NPREP Guidelines to better align policy with the existing regulations and improve interagency consistency.”  The revisions, which are the first in over a decade, align certain PREP terminology with the Homeland Security Exercise and Evaluation Program (HSEEP), expand spill countermeasure topics, and incorporate salvage, marine firefighting, non-tank vessel exercise requirements.

PREP Terminology: The guidelines stipulate that new terminology does not imply new or different requirements than what is contained in regulations. These new terms should be viewed and treated as “synonyms” that have been adopted to ensure that the PREP program is consistent and easily compared to nationwide exercise terminology used in most other current programs. Updated terminology includes, but is not limited to:

  • Spill Management Team: Replaced by the term “Incident Management Team (IMT)
  • Containment: Wherever the word containment is used in the context of containing oil under the water's surface, the word “subsea” will precede the word “containment”. Where the word “containment” is used by itself, it is presumed to be associated with efforts to contain oil on the water's surface.
  • Oil Spill Removal Organization (OSRO): The definition of an OSRO has been updated to include, and better describe, a broader range of response resources and services, including source control, all spill countermeasures, and supporting services that an OSRO may provide in order to adequately contain, secure, recover, or mitigate a discharge of oil.

Spill Countermeasure topics:  The following updates were incorporated into the new exercise guidelines:

  • The “Recovery” Core Component in Appendix A was retitled “Mitigation,” and the supporting language was broadened to clarify that mitigation may include the use of various spill countermeasures, including, but not limited to, dispersants, in-situ burning, and bioremediation, in addition to mechanical oil recovery.
  • Plan holders will only be required to exercise Subsea Dispersant Injection (SSDI) equipment upon receiving direction from the Chief of Oil Spill Preparedness Division, or the Chief's designated representative. However, plan holders should carefully describe how SSDI capabilities will be used in their OSRPs.

Salvage, Marine Fire Fighting, Non‐tank Vessel Exercise Requirements: Requirement updates include:

  • Credit for equipment deployment exercises for salvage and marine firefighting services may be claimed for real world operations, when documented as outlined in Chapter 3 of the guidelines. This also applies to traditional oil spill recovery and storage equipment.
  • The committee determined that the best way to provide clarity on the issue of Dispersant-Related Objectives during PREP Exercises was to broaden the definition of OSRO to include all providers that offer any and all spill response resources designed to contain and secure a discharge, and recover or mitigate the impacts of the spilled oil through various countermeasures and supporting services, including mechanical recovery, in-situ burning, dispersants, bioremediation, salvage, source control, and other response services directly supporting the incident such as aerial surveillance and remote sensing.
  • A vessel that has successfully completed a Government-Initiated Unannounced Exercise (GIUE) will not be required to participate in another GIUE in any COTP zone for 36 months. Other vessels under that same plan will not be required to complete another GIUE in that same COTP zone for 36 months. Other vessels in the same plan may be subject to a GIUE in another COTP zone at any time.
  • The frequency of remote assessment and consultation exercises is significantly reduced, from quarterly to annually per vessel when the vessel operates in U.S. waters. The economic burden of this exercise on vessel stakeholders is correspondingly reduced. Annual per vessel credit is appropriate for remote assessment and consultation exercises to ensure that each vessel in the fleet would have the opportunity to simulate initiation of a remote assessment and consultation assessment each year.

A full list of updated 2016 PREP Guidelines can be found on the Federal Register Website.

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises, Regulatory Compliance

HSE Managers: What is Your Superpower for Regulatory Compliance?

Posted on Thu, Apr 21, 2016

Effective tools are often the superpower that managers need to help reduce HSE department workloads. Declining oil prices, industry volatility, and resulting budget cuts are pressing some oil and gas companies to operate at minimal staffing levels. Yet regulatory compliance requirements, maintaining high safety standards, and environmental protection efforts remain constant. 

As a result, HSE managers are being asked to “do more with less”, stretching their capabilities and creating enterprise-wide preparedness and plan maintenance challenges. HSE managers must seek out available tools to help leverage their time, while ensuring preparedness measures are maintained, multiple response plans are managed, and regulatory compliance is maintained.

For pipeline and terminal operations, and others with numerous facilities requiring multiple plan types, advanced web-based systems offer advantageous plan management opportunities. These advanced systems are ideal for companies with facilities that must comply with the Oil Pollution Act of 1990 (OPA 90) requirements.

OPA 90 was created to instill comprehensive prevention, response, liability, and compensation policies for facilities that could cause oil pollution to U.S. navigable waters. The law requires that certain facilities submit Facility Response Plans (FRPs) that provide detailed site specific procedures to respond to a worse-case discharge.

FRPs require information and response details from each applicable facility including, but not limited to:

  • Emergency Response Action Plans, which serves as both a planning and action document
  • Facility information, including name, type, location, owner, and operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and analysis of potential spill hazards and spill history
  • Discussion of small, medium, and worst-case discharge scenarios and response actions
  • Description of discharge detection procedures and equipment
  • Detailed implementation plan for response, containment, and disposal
  • Description and records of self-inspections, drills and exercises, and response training
  • Diagrams of facility site plan, drainage, and evacuation plan
  • Security (e.g., fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)
  • Response team organization, roles, activation procedures, and personnel assignments

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When dedicated HSE staffing is limited, maintaining the many site-specific details required for OPA 90 compliance stretches available human resources. By creating all-inclusive emergency response plans through a system that accounts for OPA 90 requirements and other emergency planning regulations, HSE managers can leverage their time more effectively.   

The key superpower of advanced planning systems that utilize a centralized database is that this tool can incorporate multiple required emergency planning requirements from various agencies including, but not limited to:

  • EPA
    • Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements), 40 CFR, part 112.7(d) and 112.20-.21
    • Resource Conservation and Recovery Act Contingency Planning Requirements, 40 CFR, part 264, Subpart D, 40 CFR, part 265, Subpart D, and 40 CFR 279.52.
    • Risk Management Programs Regulation, 40 CFR, part 68
  • Department of Transportation
    • Pipeline and Hazardous Materials Safety Administration, 49 CFR, part 194
    • S. Coast Guard, Facility Response Plan Regulation, 33 CFR, part 154, Subpart F
  • Occupation Safety and Health Administration (OSHA)
    • Emergency Action Plan Regulation, 29 CFR 1910.38(a)
    • OSHA's Process Safety Standard, 29 CFR 1910.119
    • OSHA's HAZWOPER Regulation, 29 CFR 1910.120

Facilities may also be subject to site-specific, state planning requirements that are not typically contained in the general emergency response plan. HSE managers should coordinate the development of their plans with relevant state agencies to ensure compliance with any additional regulatory requirements.

Regulatory compliance and response planning initiatives are sometimes sacrificed in cost control activities. However, noncompliance fines or one ineffective response to an emergency situation can result in many times the cost of implementing and maintaining an effective program.

Preparedness and Emergency Management - TRP Corp

Tags: Regulatory Compliance

What's Your Plan? Emergency Action Plan or Emergency Response Plan?

Posted on Thu, Apr 14, 2016

Whether your company manufactures consumer products or provides hotel accommodations for thousands of guests across the globe, response planning is a crucial preparedness element that must be implemented in order to minimize the impact of emergencies. For most sites, the foundational response planning tool mandated by government agencies is either the Emergency Action Plan (EAP) or the Emergency Response Plan (ERP). However, while the two plan types sound similar, they have key differences and applicability.

Emergency Action Plan: An EAP can be utilized by a “non-responding” facility where only defensive responses are in play. Generally, these responses equate to evacuation and communication with responders. The EPA has adopted a policy for non-responding facilities similar to that adopted by OSHA in its Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard (29 CFR 1910.120), which allows certain facilities to develop an emergency action plan to ensure employee safety, rather than a full-fledged emergency response plan.

The OSHA regulation (29 CFR 1910.38), states that employers with 10 or fewer employees do not have to create a written emergency action plan. However, employers are still required by OSHA to communicate an EAP to staff. An emergency action plan must communicate the following minimum requirements:

  • Procedures for emergency evacuation, including type of evacuation and exit route assignments (29 CFR 1910.38(c)(2))
  • Procedures to be followed by employees who remain to operate critical operations before they evacuate (29 CFR 1910.38(c)(3))
  • Procedures to account for all employees after evacuation (29 CFR 1910.38(c)(4))
  • Procedures to be followed by employees performing rescue or medical duties (29 CFR 1910.38(c)(5))
  • Means of reporting fires or other emergencies (29 CFR 1910.38(c)(1))
    The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.(29 CFR 1910.38(c)(6))

A facility that is not bound by ERP regulations may utilize the EAP if they are located in an area with access to municipal responders and emergency response resources that can facilitate an effective response.

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Emergency Response Plan: Depending on industry, operations, and site hazards, sites may be required to submit specialized response plans to one or a variety of federal regulatory agencies. When an ERP is in place, the facility has established first responding capabilities with the intent to initiate offensive actions. (Note: The purpose of the first responder at the operations level, is to protect life, property, or the environment from the effects of the release, not stop the release.)

OSHA regulations (29 CRF 1910.120(q)) state that “an emergency response plan shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations. The plan shall be in writing and available for inspection and copying by employees, their representatives and OSHA personnel.” According to the Employers who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, are exempt from the requirements of this paragraph if they provide an emergency action plan in accordance with 29 CFR 1910.38.

Emergency response plans need to serve a specific response purpose and meet explicit planning objectives. Every response plan should include site-specific details that are unique to your facility. Below is a list of some basic planning objectives that may be relevant to your facility:

  1. Establish site specific emergency response procedures for each potential threat, risk or emergency scenario. These may include, but are not limited to:
    a. Medical emergencies
    b. Hazardous releases
    c. Fire
    d. Severe weather
    e. Security issues
  2. Design an emergency response team framework and assign personnel to fill primary and alternate roles.
  3. Define notification and emergency response team activation procedures.
  4. Establish communication procedures and a primary and alternate Emergency Operations Center location.
  5. Identify and quantify necessary response equipment
  6. Ensure emergency response team personnel receive applicable and required training
  7. Establish mitigation procedures and protective actions to safeguard the health and safety of on-site personnel and nearby communities.
  8. Identify and ensure availability of responders and supply chain resources
  9. Maintain compliance with all applicable local, state, and federal requirements for environmental hazards, response plans, and training requirements.
  10. Integrate best practices and lessons learned from past training and exercises, actual emergencies, and incident reviews.

In order to be fully integrated with external resources, the Emergency Response Plan structure should be consistent with the National Incident Management System and integrated with Incident Command System concepts.

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Tags: Emergency Response Planning, Emergency Action Plan

The New Age of Fire Pre-Planning

Posted on Thu, Apr 07, 2016

Technology has greatly improved how firefighters and emergency response teams approach and respond to emergencies. Responders no longer need to rely on potentially outdated fire pre-plans stored in binders. The age of data mobility combined with a fire pre-plan system enables responders to gather real-time scenarios details, facility photos, floor plans, and critical, on-site hazardous material information within seconds from any location. A timely response, in conjunction with accurate and relevant site-specific information, will have an enormous effect on the outcome of an emergency scenario and potentially minimize impacts to responders and employees, infrastructure, and the environment.

Although some may resist the concept of web based fire pre-plans, paper-based and document style plans present the antiquated challenge of outdated information, “version confusion”, and cumbersome accessibility. Combining database technology and fire pre-planning enables emergency managers to optimize response capabilities and efficiency, as well as maximize budgets and regulatory compliance.

The purpose of pre-fire plans is to ensure a coordinated, expedient, and safe response in the event of a fire. A web-based format elevates the implementation these principles and provides the following benefits to responders and firefighters.

Accessibility of plans:  Systems with 24/7 web-based access offer immediate critical details that can be extremely beneficial to decision makers. The commonality web-based devices enables emergency managers, on-site responders, as well as approved stakeholders at any location to evaluate the scenario and real-time pre-plan information in order to stage an effective and timely response.

In the event of a fire emergency, updated paper plans and binders may not available from all company locations. Additionally, accessing plans housed on a company intranet may be dubious if an incident renders company servers inaccessible.  Although the intranet approach has improved overall plan accessibility, a number of significant time-consuming challenges remain including plan maintenance, version control, and consistency across multiple plans.

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Efficiency:  The most advanced web-based fire pre-planning software utilizes a database, allowing for specific repetitive information to be duplicated and streamlined across multiple plans and plan types.  As a result, maintaining up-to-date and actionable response plans amongst changing personnel, fluctuating external response contacts, and revolving equipment availability minimizes administrative efforts and dedicated time. Required changes and repetitive, identical edits are more likely to be transferred into the system if administrative tasks are minimized, optimizing the accuracy of the plans and improving the likelihood of an effective response if an incident were to occur.

Real-time updates:  Web-based software allows responders to apply the most up-to-date information and tested processes while eliminating antiquated information and “version confusion” of the past.  Both paper-based plans and those housed on a company intranet are often out of date with multiple versions in various locations, potentially misinforming response teams.

Superior functionality: Web-based fire pre-plans can provide simplified interfaces and tools such as webcam access, hyperlinks, forms libraries designed to improve functionality for plan users. Simplifying the user interfaces and documentation process during an incident enables prompt response progress, improved regulatory compliance, and a more accurate account of the response.

Multi-purpose data: Specific firefighting information, such as construction details, hydrant, and utility valve locations may be useful to responders when highlighted in a stand-alone format. However, the information listed in a fire pre-plan, such as floor plan(s) and details of on-site hazardous material(s), may also be required by multiple agencies (OSHA, DOT, EPA, USCG) as part of an overall emergency response plan. Web-based, database driven fire pre-plan information can be streamlined and shared with additional plan types under the same umbrella system including emergency or facility response plans, business continuity, hurricane plans, and others.

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Fire Pre Plans

Does Your Company Incorporate the 12 Key NIMS Components?

Posted on Thu, Mar 31, 2016

As part of the response to the 9/11 attacks, the Department of Homeland Security (DHS) initialized the National Incident Management System (NIMS) in February 2003. The comprehensive system provides a consistent approach to prepare for, respond to, and recover from any domestic incident regardless of the cause, size or complexity.

“NIMS is a systematic, proactive approach to guide departments and agencies at all levels of government, nongovernmental organizations (NGO), and the private sector in working together seamlessly and managing incidents involving all threats and hazards—regardless of cause, size, location, or complexity—in order to reduce loss of life, loss of property, and harm to the environment.” - FEMA

Over the years, additions and changes have been implemented, yet the basic function, scope, and principles remain unchanged. Effective and consistent NIMS integration among the private sector can also result in a strengthened preparedness, response, and recovery capabilities, minimizing the duration and effects of incidents. In order to integrate NIMS into private sector companies, FEMA suggest the following 12 core concepts.

  1. Communicate intention: Local fire and rescue, law enforcement, hospitals and healthcare systems, transportation systems, public works, voluntary agencies, private industry and any other entity that may be responding to an incident should be informed that your company/facility will be adopting NIMS.
  2. Identify Points of Contact: Ensure you have up-to-date contact information for local response authorities and the facility/company personnel.
  3. Support an integrated multiagency coordination: Pre planning coordination efforts among the different emergency management entities offers the opportunity for a more cohesive response. The Unified Command and the Liaison Officer may be able to provide the needed multiagency coordination at the scene. However, as an incident grows in size and complexity, off-site support and coordination may be required.
  4. Establish a public information system: During an incident, gather, verify, coordinate, and disseminate information both internally and externally as directed by the communication plan or public relations designee.
  5. Revise Plans: Response plans and standard operating procedures should incorporate NIMS components, principles and policies, to include planning, training, response, exercises, equipment, evaluation, and corrective actions.
  6. Promote Mutual Aid: Establish a memorandum of understanding/agreement with the government agencies and other private sector organizations to share resources and personnel.teamwork.jpg
  7. Maintain NIMS Training: Company emergency preparedness personnel, as well as any emergency responders or teams (fire brigade/EMS), should adopt NIMS training programs.
  8. Coordinated Exercises: Conduct both small and large-scale onsite exercises with internal and external responders. The facility/company should also participate in State, regional, tribal, and/or local NIMS-based exercises when possible.
  9. Inventory Response Assets: An inventory of internal and external response assets should be conducted in conjunction with identified threats and risks. These assets should be inclusive enough to counteract any potential incident. The availability of inventory should be shared with local emergency management authorities.
  10. Coordinate Mutual Aid Requests: Exercise your response asset inventory during exercises and training opportunities.
  11. Use Common Language and Communication Platforms: Apply standardized and consistent terminology, including the establishment common communications technology and practices. These platforms and practices should be shared within the company, other private sector partners, and local emergency response groups.
  12. Implement the Incident Command System (ICS): ICS is the recognized, standardized, organizational structure designed to enable an integrated response, despite its complexity, response demands, or jurisdictional boundaries. The application the Incident Command System (ICS) is critical to ensure the long-term viability and sustainability of the organization. By instituting these best practices into a site-specific response structure, a company is more likely to effectively manage and mitigate the consequences of an emergency.

Note: Non-governmental organizations and private sector entities entitled to receive Federal preparedness funding or grants are required to coordinate NIMS implementation with their respective State Administrative Agency in order to be eligible for funding.

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

Tags: NIMS

Optimize Industrial Chemical Safety with Post Incident Reviews

Posted on Thu, Mar 24, 2016

Chemical plants and other industrial facilities have site-specific, innate hazards that present unique preparedness and incident response challenges. Immediately after a planned exercise or an unforeseen emergency response, it is critical to conduct post incident reviews, gather insights from participants and witnesses, and identify lessons learned. Incidents and flawed response processes should be utilized to catapult new findings into emergency plans, incorporate new response measures into exercise simulations, and alter training needs as necessary. As a result, lessons learned can be implemented and preparedness improvement work can begin.

Timing of a post-incident review is critical. Response and preparedness discussions should take place while the incident, emergency, or exercise is fresh in the minds of decision makers, responders, regulators, and the public. The following five post incident/emergency management concepts should be presented and thoroughly examined for lesson learned preparedness opportunities.

  1. Unidentified potential risk or hazard: A hazard and vulnerability analysis should be performed, and processes and procedures should be developed and added to the plans.
  2. Management gaps and weaknesses: If the post incident reviews revealed weaknesses or gaps in the organization, the emergency response management structure should be modified and emergency plans revised.
  3. Ineffective policies and procedures: If the policies and procedures fail to address key issues during the incident, policies and procedures need to be modified to address inadequacies.
  4. Lack of response proficiency: If response was faulty due to deficient training, exercising, or planning, these efforts should be amplified and personnel should be familiarized with these modifications.
  5. Planning deviations: If participants successfully diverged from existing processes, procedures, or plans, these areas should be modified to reflect the reality of the performance.

By conducting a post incident critique with employees and responders, managers can evaluate the effectiveness of the response and identify areas that need improvement. Ideally, the incident critique should be moderated by personnel who are:

  • Experienced and knowledgeable in emergency response.
  • Not directly involved in the actual incident.

The following general guideline questions can be used as a starting point for conducting a post incident critique with employees and responders. Specific questioning should be determined by site-specific parameters.

Incident Detection

  • Was the incident detected promptly?
  • How was it detected?
  • By whom?
  • Could it have been detected earlier? How?
  • Were there any additional circumstances that inhibited detection (ex. time of day, noise, severe weather)?
  • Are any instruments or procedures available which may aid in earlier detection?

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Notifications

  • Were notifications performed in a predictable time frame?
  • Were personnel notified promptly?
  • Do additional individuals need to be notified? How, and why?
  • Were contacts and contact numbers up to date?
  • Were management notification procedures effective and timely enough to promote effective and actionable responses?
  • Were proper procedures in place and followed in notifying government agencies?

Assessment/Evaluation

  • Was the magnitude of the incident assessed correctly from the start?
  • What means were used for this assessment?
  • What references were used to assist in incident evaluations and statuses?
  • Were environments sources available regarding severe weather, winds, water currents, and/or other variables?
Response Mobilization
  • Was the response plan utilized in effectively mobilizing countermeasures to the incident?
  • If the response plan was not used, what steps were taken to mobilize countermeasures?
  • Were response plans accessible?
  • Was mobilization prompt?
  • Could the response time improve? How?
  • How were resources mobilization and were they effective?
  • Were additional resources were used outside those listed the response plan? Why?
  • Was it appropriate to mobilize company resources and was this promptly initiated?
  • What other company resources are available and have they been identified and used adequately?

Response Strategy

  • Was the initial strategy for response to this incident effective? If not, what needed to be adjusted?
  • Was the response strategy flexible enough to cope with unexpected events?
  • Was there a response plan available to key individuals for reference?
  • Does the plan include clear directions regarding local environmental, economical, or human sensitivities? Do updates need to be addressed?
  • How did changes in strategy evolve during the emergency and how were these changes implemented?

TRP Corp Emergency Response Planning Exercises

Tags: Chemical Industry

Facility Response Team Supervisory Responsibilities

Posted on Thu, Mar 17, 2016

Whether your facility is an office building or a chemical plant, every employee should be trained in basic emergency responses in order to minimize personal risk and exposure to hazardous situations. The better a company can prepare its employees for emergency situations, the more effective and timely the response. However, facilities that empower employees to command and lead response team missions have the unique responsibility to ensure advanced training and appropriate safety measures are understood.

Individual supervisory responsibilities are as unique as the site, specific response expectations, and particular role. However, general supervisory responsibilities may include, but are not limited to the following:

  • Initiate initial response actions if first person on-scene
  • Request medical assistance, if necessary
  • Verify substance released and obtain Safety Data Sheets (formerly known as Material Safety Data Sheets), as necessary
  • Communicate response actions to assigned specialized team members
  • Identify and evaluate safety and health hazards that may impact the response workers, employees, and the public
  • Identify and isolate source to minimize product loss and potential harm
  • Restrict access to the incident scene and surrounding area as the situation demands and designate exclusion zone boundaries
  • Determine levels of personal protective equipment required
  • Identify key government representatives from each agency, if applicable
  • Maintain Records and Individual Logs
  • Coordinate further response actions with Incident Commander and local responders
  • Re-evaluate situation as response unfold to determine if adjustment are necessary

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Priorities of response team leaders should include, but are not limited to the following:

Early evaluation and continual incident updates: With early evaluation, communication, and continual progress assessments, team leaders can utilize current conditions to establish the necessary responses to counteract the circumstances. The consideration of responder safety should be incorporated into every evaluation and response measure.

Effective communications:  The ability to receive and transmit information, maintain situational awareness, and communicate with all components within the incident organization is essential to ensure effective supervision, directives, and response controls.

Strategic decisions:  The response team’s risk level may be driven by the extent of the incident and response strategy. 

Offensive strategies places members in interior positions where they are likely to have direct contact with the incident or hazard.  While an offensive strategy may result in a more timely response, team leaders must ensure the team’s training level coincides with this type of approach.

Defensive strategies remove members from interior positions and high-risk activities. The defensive approach may minimize incident escalations until properly trained responders arrive at the scene. In conjunction with the response plan, the Incident Commander may assign basic positioning and functions of the internal and external responders and allocate necessary response resources.

The number of employees on a Facility Response Team will depend on site and operational hazards, the number of on-site employees, training budgets, and the likelihood of a hazardous incident. To ensure employees and identified essential response personnel are prepared to respond to an incident in an efficient and effective manner, minimum training and exercise guidelines should be established as minimum requirements within an emergency management program.

Management should ensure that:

  • All facility response team members are trained in accordance to their designated responsibilities
  • All aspects of response plans are exercised individually at least once per year with the appropriate response, incident management, and support teams taking part.
  • Separate functions or components within response plans should be exercised at more frequent intervals, as appropriate, in preparation for the main annual exercise.
  • Notification exercises for each team and response components (both internal and external) should be verified and practiced at least twice per year. This exercise should involve unannounced checks of the communication processes, equipment, and systems.
  • National and local training and exercise requirements should be used to assess the overall integrated preparedness of a response with the authorities.

TRP Corp - Emergency Response Planning Crisis Management

 

Tags: response team

Streamlining Response Planning in the Midst of Slashed Oil & Gas Budgets

Posted on Thu, Mar 10, 2016

In the face of decreasing profits, many oil and gas HSE departments will encounter challenging operational environments and cost cutting initiatives.  However, these departments can minimize or eliminate noncompliance fines and reduce the costs of a disaster. Effective and exercised preparedness and response planning satisfies regulatory compliance requirements, decreases response costs, and fulfills a moral responsibility to protect employees, the community, and the environment.

As oil and gas companies’ budgets shrink and business protocols continue to require preparedness and response planning financial justification, the need to demonstrate the economic benefit of risk reduction costs to decision makers is increasing. However, while historical occurrences can present a general understanding of potential costs of disasters, unique circumstances continually change the landscape of the cost-benefit analysis of preparedness and response planning. Forward thinking risk analyses and associated costs justifications are often minimized and sidelined by profitable operational priorities. The uncertainty of circumstances surrounding an emergency or disaster including human error, equipment failure, climatology, population growth, and/or other external influences, coupled with a “it won’t happen to us” mentality lead to a notion of unjustifiable cost/benefit implementation.

However, the costs associated with regulatory noncompliance fines are often the catalyst for companies to prioritize preparedness and response planning. Fortunately, technological advancements have provided a simplified framework for addressing the administrative costs associated with maintaining compliant response plans. Confirming and updating regulatory compliance is simplified with an enterprise-wide, universally accessible response planning system. As a result, administration costs associated with mandated preparedness and response planning upkeep are reduced, justifying the cost of this new technology.

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Implementing advanced software that enables companies to maintain the same or higher levels of compliance with less staff (such as TRP's SMARTPLANis critical when budgets are reduced. Corporate emergency management and HSE budgets can be stretched if response planning software:

  • Facilitates a reduction of dedicated staff
  • Facilitates the ability to update corporate planning elements across locations, sites, geographies, without compromising site-specific details and response challenges
  • Incorporates a simplified foundation to address plan related employee changes and facility acquisitions
  • Allows for streamlined regulatory compliance audits and reduces non-compliance issues on a company-wide scale
  • Automates regulatory governance with electronic submissions

In addition, an effectively exercised and accessible emergency response plan minimizes the duration of the incident and in turn minimizes associated costs and the impacts of an emergency on employees, the environment, and infrastructure.

In order for the oil and gas industry to continue to be one of the safest operating industrial sectors in the United States, the industry must continue to audit, test, and update preparedness endeavors and response capabilities. Supplying emergency management programs with advanced response planning technology will enable companies to meet key strategic and tactical preparedness objectives within the confines of a reduced budget. These key objectives include, but are not limited to:

  • Facilitating compliance with Federal, State, and Local regulatory requirements, eliminating the threat of potential fines.
  • Reducing property damage through expedited responses
  • Enhancing the ability to recover from business interruption and loss (ex. damaged industrial, commercial, and retail facilities)
  • Reducing indirect business interruption loss (ex. supply chain “ripple” effects)
  • Reducing environmental damage (ex. wetlands, parks, wildlife)
  • Enhancing a company’s image and credibility with employees, customers, suppliers and the community.
  • Reducing other non-market damage (ex. historic sites, schools, neighborhoods)
  • Minimizing societal losses (ex. casualties, injuries)
  • Reducing need for emergency response (ex. ambulance service, fire protection).
  • Reducing exposure to civil or criminal liability in the event of an incident.
  • Potentially reducing insurance premiums (check with individual insurance providers for associated savings).

Regulatory compliance and response planning initiatives are often sacrificed in cost control activities. However, noncompliance fines or one ineffectively response to an emergency, disaster, or crisis situation can cost a company many times the cost of implementing and maintaining an effective program.

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

Tags: Regulatory Compliance, HSE Program

Business Continuity Plan Tips: Are Your Concerns Addressed?

Posted on Thu, Mar 03, 2016

Every corporate threat may result in the same consequence: the loss or temporary cessation of key business processes. In February 2016, the Business Continuity Institute released its fifth annual Horizon Scan report highlighting the level of concern to different risks and threats. The report tabulated survey results from 568 worldwide organizations from 74 countries.

According to the report, the following are the top 10 concerns for businesses:

  1. Cyber attack
  2. Data breach
  3. Unplanned IT and telecom outage
  4. Act of terrorism
  5. Security incident
  6. Interruption to utility supply
  7. Supply chain disruption
  8. Severe weather
  9. Availability of talent/key skills
  10. Health and safety incident

Threats to a company’s ability to conduct “business as usual” is a continual concern for large, multinational companies, as well as smaller, domestic operations. Regardless of size, establishing methods to preserve critical business processes during any of the adverse concerns listed in the Horizon Scan report can improve the probability of operational sustainability and minimize the potential of lost revenues. Failure to develop an effective business continuity plan that address these concerns can lead to costly and devastating impacts, often affecting the long-term growth of a company.

In order to combat concerns, the following must be identified for each operational site or location

  • Potential risks/threats
  • Trigger events
  • Impacted critical business processes/activities
  • Incident response structure
  • Warning and communication process
  • Recovery time objectives

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While reviewing a plan that addresses targeted risks and threats, key details and alternate provisional elements should be considered. The following basic Business Continuity Plan components should be reviewed to ensure concerns are addressed and processes are in place to minimize loss or the temporary cessation of key business processes.

  1. Key contacts: Identify and confirm all primary and secondary key contacts that must be made aware of a business interruption. Due to possible employee turnover or contact detail changes, it is important to routinely verify contact information for accuracy.
  1. Plan distribution list: Identify and confirm names, addresses, and contact information of those that retain access to one or more plans.
  1. Recovery plan:
  • Identify/develop parameters of business continuity strategies with regards to each identified risk/threat. This includes incremental processes and necessary procedures required to recover each critical business process.
  • Ensure communication methods and backup equipment will be adequate for each trigger event.
  • Response checklist time lines may include increments such as 1st hour, 24-hours, 48 hours, one week, one month, and long-term recovery.
  1. Key staff roles and responsibilities:
  • Develop job specific checklists and procedures detailing responsibilities, from business continuity implementation through recovery.
  • Identify Critical Staff, at a minimum, for each critical business process.
  • If necessary, provide cross team training, in the event that primary team members are not available.
  1. Off-site recovery location: Identify and include addresses, contact info, available on-site equipment, and any necessary external equipment for effective continuity and recovery operations.
  1. Key customers’ data: Effective customer relations and communication may be critical in retaining clients and maintaining positive relationships during a business interruption. Identify communication methods, platforms, and required contact information in order to inform customers of disruptions of deliverables.
  1. Key supplier contact list: Logistics and transportation delays could affect delivery times; therefore the plan should address this issue. Identify dependencies and interdependencies along with key contact information.
  1. Alternate suppliers list: The consequences of a supply chain failure on associated key business components can be crippling. Through the planning process, alternatives can be explored to reduce the impact of supply chain disruptions.
  1. Back up data details: Identify details of computer back-ups and recovery methods. Ensure that staff training is in place to ensure data accessibility, security, and recovery.
  1. Technology requirements: Identify necessary hardware and software, and the minimum recovery time requirements for each business unit. Ensure best practices are in place regarding backups and IT security.
  1. Equipment requirements: Identify equipment requirements for each business unit and recovery time goals.
  1. Implement improvements
  • Track and update key details and associated processes as deficiencies and inaccuracies are identified
  • Incorporate newly identified hazards and vulnerabilities into the business continuity plan.
  • Include necessary equipment used (requiring replacement or replenishment)
  • Incorporate lessons learned into the plans and necessary training
  • Periodically evaluate critical business processes to ensure that evolving businesses practices are captured.
  • Periodically evaluate risks and threats to ensure that concerns are addressed in the plan.

Preparedness and Emergency Management - TRP Corp

Tags: Business Continuity

Pandemic Planning in a Global World

Posted on Thu, Feb 25, 2016

Since the World Health Organization has declared the mosquito-borne Zika virus an international public emergency, employers should ensure prevention and response procedures are in place to minimize its spread. With reports of Zika virus infections on the rise, corporations are grappling with how to handle jobs and projects in the growing number of affected regions.

As global epidemics continue to garner the attention of corporate emergency managers, well-developed Pandemic Response Plans (PRPs) should be established and implemented, as necessary. “Best practices” dictates that PRPs, like emergency plans, should be developed during normal conditions, prior to any threatened outbreak. However, companies with global operations or multinational interactions should re-evaluate and examine ongoing pandemic risks and vulnerability factors in order to provide employees with:

  • Critical knowledge
  • Proactive procedures
  • Necessary resources 

Companies doing business in affected pandemic areas should look to their PRP to establish a safe work environment, minimize the spread of the pandemic, and preserve business continuity. Specifically, the purpose of a PRP is to:

  • Identify how additional resources and personnel will be made available to support the organization.
  • Identify how internal and external communications will be maintained.
  • Identify how the reputation impact will be managed during and after the outbreak.
  • Identify how the technical and commercial implications of the outbreak will be managed, and where in the organization this support will be obtained.

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The PRPs should document procedures and methods to minimize exposures and sustain critical business functions with reduced staffing throughout different stages of the outbreak. When developing the plan, it is useful to define impact levels for the various stages.

Level 1 - Normal Operations

  • Establish contact verification and notification measures with employees and key stakeholders (both internal and external)
  • Determine if PRP implementation is necessary if normal management procedures can manage the incident
  • Conduct briefings, promote awareness, and educate employees on pandemic
  • Determine and validate current priority projects and processes to determine which to suspend, if necessary
  • Direct staff to maintain and backup all business information and working files (data and documents) so that content is accessible to alternates and other staff members as necessary
  • Acquire necessary equipment to enable key staff to work from home , if needed

Level 2 - Heightened risk and modified PRP activation

  • Notify staff members of PRP activation and revised operational procedures.
  • Staff may be directed to work from remote locations or minimize travel to impacted areas, if feasible
  • Maintain tracking of all staff, assess well-being of staff, and identify any additional needs for support and/or resources
  • Direct staff to maintain and backup all business information and working files (data and documents) so that content is accessible to alternates and other staff members

Level 3 - Business as usual with limited on-site staff

  • Only essential employees who cannot work remotely would report on-site
  • Determine and validate current priority projects and processes to determine which to suspend, if necessary
  • Review and establish guidelines for backfilling resources, including leadership
  • Confirm availability of local and/or remote alternates for critical roles
  • Maintain tracking of all staff, assess well-being of staff, and identify any needs for support and/or resources
  • Direct staff to maintain and backup all business information and working files (data and documents) so that content is accessible to alternates and other staff members

Level 4 - Emergency Service Level with normal levels of operation with minimized staffing

  • Notify internal and external entities with dependencies on critical business operations.
  • Re-evaluate current priority projects and processes to determine which to suspend, if necessary
  • Proactively notify corporate executives, team leads, and other contacts of availability and work location, and maintain out of office phone, e-mail notices, and calendars, as appropriate.
  • Distribute peripherals (e.g. external disk drives) for home use and distribute as needed
  • Direct all non-essential staff to work at home, if possible.

Level 5 - Suspend all non-critical operations examine critical business processes

  • Maintain tracking of all staff, assess well-being of staff, and identify any needs for support and/or resources
  • Implement modified operations schedule with critical staff. Excuse non-essential staff and place on standby.
  • Maintain critical staffing levels and engage emergency contractors
  • Secure facilities

Level 6 - Return to normal operations after situational assessment

  • Communicate resuming operations date with employees and key stakeholders
  • Review time records and pay overtime as required
  • Update and archive file directories, if necessary
  • Update Pandemic Response Plans, as necessary

TRP Corp - Emergency Response Planning Crisis Management

Tags: Pandemic Planning, Pandemic Plan