Your Solution for SMART Response Plans

Drought, Wildfire, and Corporate Fire PrePlanning

Posted on Thu, May 19, 2016

According to the U.S. Federal Government, more than 39 million people, or about one-eighth of the U.S. population, is living with drought.  “About 12.5 percent of the continental U.S. was experiencing drought as of mid-March” said Alice Hill, ‎Special Assistant to the President and Senior Director for Resilience Policy in the White House National Security Council. As warmer temperatures prevail, the probability of wildfires in drought prone areas increases, threatening every community and company facility in its path.

Although the west coast has been affected by a long term severe drought, other areas of the country are experiencing impacts, as well. In early March, before peak wildfire season, Kansas experienced the largest wildfires in state history. The fire burned nearly 620 square miles in southern Kansas and Oklahoma. The National Interagency Fire Center predicted above normal significant fire potential from the southern plains, expanding to the mid-Mississippi Valley and lower Ohio Valleys, and eventually to the Great Lakes as drier and warmer trends continue through the spring months.

Wildfires can have significant impacts on industry. Any situation that hinders a company's ability to access key infrastructure and perform critical operations requires thoughtful and effective response planning initiatives. Scenario specific plan evaluations that enable personnel to identify, prioritize, and respond to natural disasters, such as wildfires, is critical for minimizing losses and financial damages.

An initial fire pre-plan assessment should be conducted to identify the likelihood of wildfires in your area. If one or more of a company’s facilities has the potential to be in the path of a wildfire, management should ensure fire pre-plans are up-to date and effective, and take the following preventative measures to minimize risk.

  1. Cut back brush or vegetation that may be impeding on any structures on your property.
  2. Remove dead wood and combustible litter from the site.
  3. If possible, enclose the underside of eaves and decks with fire-resistant materials to keep out flying embers.
  4. Cover exterior vents with fire retardant mesh screens to prevent embers from entering building
  5. Develop, review, and share fire pre plans with local fire departments
  6. Train employees of fire prevention, evacuation procedures, and fire safety measures
  7. Identify on-site and external equipment resources, procuring contracts if necessary (fire trucks, Backhoe/Front end loader for cutting fire breaks)
  8. Check functionality of sprinkler systems and fire extinguishers
  9. Evaluate and maintain irrigation system
  10. If applicable, establish response team and train as necessary

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The foundation of an effective fire pre-plan is based on site-specific details and up-to-date information. This pertinent information greatly assists responders in determining response methods and optimal equipment needs. Internal response teams and external fire departments should have knowledge of potential hazards and associated facility details prior to arriving at an incident. Shared fire pre plans can promote a coordinated, expedient, and safer response in the event of a wildfire.

Fire pre plans generally include information that will be used by decision makers at the incident. Below are a few insightful fire pre plan helpful hints to consider when developing your site-specific plans:

  • Emergency procedures should include tactical consideration and personnel accountability measures.
  • Update and share plans with external responders and fire departments, as necessary. It is critical to include updated contact information for key staff, as well as status updates of new construction and renovations.
  • Implement a securely accessible means for pre plan storage, retrieval, and sharing.
  • Ensure plans are intuitive and easy to read. . Fire responses may occur when light and/or visibility is limited. The easier the plan is to read, the better it is for all responders.
  • Utilize plot plans to separate large complexes into response sections. It may be optimal to divide complex into color-coded quadrants. Response strategies can be developed for each quadrant, making it much easier to respond to fires in large complexes.
  • Accurately identify alarm panel locations, key box locations, and hydrants.
  • Specify location and details of stored hazardous materials
  • Coordinate response exercises with fire departments
  • Implement lessons learned and new firefighting tactics into response plans

 

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Fire Pre Plans, Fire Preparedness

Utilizing Technology to Improve Regulatory Compliance and Preparedness

Posted on Thu, May 12, 2016

Workforce Reductions and Petroleum Inventories

Industry volatility associated with plunging commodity pricing is pressing many energy companies to operate at minimal staffing levels, challenging them to “do more with less” while sustaining current enterprise-wide preparedness capabilities and regulatory compliance.

Workforce reductions in the energy sector have resulted in a loss of nearly 118,000 jobs in the U.S. since the beginning of 20151, and more than 320,000 positions globally since the downturn began2. Even with reduced staffing, safety expectations, environmental protection standards, and regulatory compliance requirements remain constant - providing justification for utilizing tools that increase efficiencies and further reduce labor costs.

In conjunction with enormous staff reductions, petroleum inventories have increased to record levels. As of April 29, 2016, the U.S. Energy Information Agency listed the inventory of crude oil and petroleum stocks at 2,065,928 (thousand barrels), the highest amount in history3. Although facilities and response plans are designed for a worst case discharge, there is now less margin for error for a large spill, given that many facilities are operating at higher capacities.

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Complex Compliance Requirements

Oil storage operations are heavily regulated. Overlapping response plan requirements from multiple agencies are applicable to many facilities. Federal agencies that may require response plans include EPA, U.S. Coast Guard, PHMSA, and OSHA. As many as three different federal agencies regulate OPA 90 for some facilities, and certain states add more requirements. In addition to the complexities of developing and maintaining Facility Response Plans, many facilities are subject to planning requirements for Spill Prevention, Control, and Countermeasures, Dock Operations, Security, Risk Management, Process Safety Management, Emergency Response, and Fire Pre-Plans. Many of these regulations require similar site-specific details, further exemplifying the need for tools that are specifically designed to leverage and manage this content.

In order to maintain company-wide compliance and preparedness, every response plan must contain accurate site-specific details consistent with operations, personnel, topography, sensitivities, weather, and other factors. Maintaining this level of detail across multiple plan types for a large number of facilities is a challenge, especially when less personnel are available. TransMontaigne Partners and DCP Midstream, among others, have embraced cloud-based, database-driven systems specifically designed to improve flexibility, accessibility, efficiency, and consistency of their response plans. Intuitive response planning systems that streamline formats, and utilize database technology to leverage and manage information offer tremendous benefits in improving compliance and preparedness.

SMARTPLAN™ Response Planning Tools

For companies with multiple facilities and locations, cloud-based planning systems, such as Technical Response Planning’s (TRP) SMARTPLAN™ Software, provide a platform for site-specific response plans that integrate seamlessly with company-wide operations, procedures, and policies. DCP Midstream, which has been utilizing TRP’s technology for their Emergency Response Plans since 2001, operates 63 gas processing plants and over 64,000 miles of pipelines across 17 states. “With a footprint that large, we need to leverage technology to improve efficiencies,” says Brian McGuire, Director of Health, Safety and Security for DCP Midstream. TRP’s system enabled DCP Midstream to optimize plan maintenance processes, plan formats, and regulatory compliance at every location.

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In 2013, TRP demonstrated their new SMARTPLAN™ Software to DCP. “I quickly recognized the power of the new platform and improvements that would enable us to easily manage all of our plan types, including SPCC Plans, Business Continuity Plans, and Risk Management Plans, in addition to the Emergency Response and Crisis Management Plans that TRP had been managing since 2001,” says McGuire. “When integration of our current plans into the SMARTPLAN™ platform was completed in 2014, it was an easy decision to also add our NGL Pipeline County Emergency Response Plans and our more than 700 SPCC Plans. TRP’s quick turnaround in transitioning these additional plans exceeded our expectations.”

TransMontaigne Partners, which operates more than 50 refined product bulk storage terminals and pipeline systems, also saw the enterprise-wide benefits of the new system. “TRP recently upgraded our account to their new SMARTPLAN™ platform, which provides even more functionality, flexibility, and tools to help us manage regulatory requirements and plan maintenance for our large operation,” says Dudley Tarlton, Vice President of Environmental, Safety and Occupational Health with TransMontaigne Partners. “Their software allows TransMontaigne Partners to manage our plans much more effectively and with less manpower than could be done with traditional methods.” 

TRP’s SMARTPLAN™ software system and unique approach has been widely adopted by companies like DCP Midstream and TransMontaigne Partners. SMARTPLAN™ accomplishes these improvements in efficiency by providing the following:

Instant Accessibility: Ensures each approved stakeholder has access to the latest version of every response plan. Accessibility options include being able to access live from the Internet, download a static electronic version, or print paper copies. The electronic format also provides the ability for plans to be shared for regulator or auditor review. In addition, hyperlinks, reference libraries, simplified interfaces, and reporting tools improve functionality and further leverage available data for plan users.

Plan Management Tools: Database allows for information to be mapped to multiple locations in all plan types, across an entire company. By reducing time requirements, plan updates are more likely to be performed, thereby improving accuracy and compliance.

Instantaneous Revisions: Plan updates are immediately available to all stakeholders. This eliminates “version confusion” for plan users, which improves response plan accuracy. This functionality also provides the ability to quickly and cost effectively apply lessons learned, regulatory changes, and company reorganization issues across all response plans.

Plan Consistency: Promotes the use of a consistent plan format across entire companies, yet it is still customized to account for company-specific processes and philosophies. This allows for improved familiarization with response plans for all company personnel.

Plan Types: Provides all types of response plans, including Facility Response Plans, Emergency Response Plans, SPCC Plans, Fire Pre-Plans, Business Continuity Plans, and others.

“TRP’s system has always done an amazing job of standardizing our many plans, and helping us manage all of our plan contacts,” says McGuire. “In addition, the new dike volume calculation tools in SMARTPLAN™ have greatly improved the accuracy and documentation of our SPCC plans and have significantly reduced time required to perform manual calculations.”

  1. http://www.houstonchronicle.com/business/energy/article/Fed-U-S-oil-job-cuts-reach-about-118-000-7237605.php
  2. http://fuelfix.com/blog/2016/04/07/chevron-cutting-655-houston-jobs-amid-oil-bust/#31744101=0
  3. https://www.eia.gov/dnav/pet/PET_STOC_WSTK_DCU_NUS_W.htm

TRP Corp - Emergency Response Planning Crisis Management

Tags: Emergency Preparedness, Regulatory Compliance, corporate preparedness

Corporate Response Planning and Response-Ability

Posted on Thu, May 05, 2016

Companies must proactively affirm their responsibility to ensure the safety of employees, the environment, and the surrounding communities by prioritizing a corporate emergency management program. Through targeted response planning, mitigation efforts, and overall preparedness initiatives, companies can validate their commitment to address impactful emergency situations, and set an example for staff, industrial counterparts, and the surrounding communities.

Collaboration and coordination are crucial elements of response planning and corporate responsibility. In order to fulfill these critical corporate emergency management elements, managers should:

  • Obtain and foster leadership commitment from all response disciplines (Incident Response Team, EMS, Fire, and Police Departments)
  • Ensure collaboration and coordination efforts are included in response plan processes and procedures
  • Interface with local leadership to ensure community awareness and resource support
    Establish relationship sustainability with all stakeholders through ongoing communications
  • Plan and budget for ongoing updates to emergency management systems, procedures, and documentation

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Whether response planning is mandated by corporate policy or regulatory agencies, advancing preparedness and fulfilling a responsibility to employees and the community must be a priority. As a result, companies should, at a minimum, examine the following emergency management planning elements to incorporate site-specific details:

Public and Private Services and Resources: Emergency managers should continually meet with government agencies, community organizations, and utility companies throughout the entire planning cycle to discuss likely emergencies and the available resources. During a response, these entities can provide services necessary to minimize the effects of the incident and allow for a more timely response.

Health, Safety, and Environmental Response: Personnel, contractors, and additional response team members must be aware of their predefined roles, responsibilities, and assignments. By identifying specific personnel training needs and responder capabilities, all potential hazards should be accounted for in order to support a cohesive and effective response.

Operational Communications: Communicating timely and accurate information to/among facility managers, critical decision makers, emergency response teams, stakeholders, vendors and contractors, and the public is an important element to any emergency management function. From notification to demobilization, steady correspondence in conjunction with commonly understood terminology is essential for clear communication. An effective response relies heavily on the ability to put forth effective communications.

Situational Assessments and Strategic Responses: Improving reactive decision management, timely communications, and swift implementation of response strategies can minimize the resulting effects of an emergency situation. Continual tactical discussions should reveal situational details that enable response strategies to be implemented or altered. Situational assessments are crucial to the decision-making process regarding lifesaving and life sustaining activities, as well as identifying resources necessary to procure incident stabilization and meet basic human needs.

Mass Health Care, Search Assistance, and Rescue Operations: Broadening the scope of response expertise can greatly benefit a facility. Local agencies, health care providers, and specialized contractors may provide additional response knowledge based on particular research, experiences, or occupational training in a particular area of study. Establishing relationships and memorandums of understanding with assisting entities allows all parties a comprehensive understanding of response capabilities and the potential needs of the community and response team.

Critical Transportation: Plot plans, evacuation maps, and tactical planning details allow for site specific information regarding transportation interests and directional awareness. Identifying adequate access and egress points at the facility and potential response location(s) allows responders to minimize response time.

On-scene Security and Protection: Due to increased public attention and on-site population created at disaster locations, preparing for and responding with additional security measures should be part of the emergency management processes. Response security protocols should be reviewed to educate security personnel on roles and responsibilities, and inform responders of potential security measures. Such exercises can strengthen security awareness and reduce the potential for added security-related incidents.

Regulatory Compliance with TRP Corp

Tags: Response Plans

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.

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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?

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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.

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Tags: response team