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OSHA's Emergency Action Plan: Commercial Property and Building Owners

Posted on Thu, Aug 25, 2016

As of August 2, 2016, fines and penalties for OSHA violations have increased. Commercial property and building owners must comply with relevant Occupational Health and Safety Administration (OSHA) regulations in order to avoid the increasing non-compliance expenses. Many owners see the cost to initiate, upgrade, and/or maintain a preparedness program as a superfluous expenditure. However, proactive budgeting in comparison to the cost of lives, hazardous impacts, property damage, and regulatory fines, is minimal.

According to the 2016 OSHA Field Operations Manual, any employer who willfully or repeatedly violates regulations may be assessed a civil penalty of not more than $124,709 for each violation, but not less than $8,908 for each willful violation. For a company with multiple sites, the exponential violation cost could be staggering and financially crippling.

In order to minimize non-compliance, commercial property and building owners should identify potential emergency scenarios and necessary site-specific safety measures, including those required in OSHA’s Emergency Action Plan (EAP). An EAP should be part of an overall emergency management program, elevate the state of response awareness, and create an atmosphere of response readiness. Each plan should identify site-specific actions by employers, employees, or other building occupants to ensure safety from fire emergencies and other potentially devastating scenarios.

In order to minimize life threatening impacts, OSHA has identified requirements for the development of site-specific EAPsfor certain employers and their work sites. OSHA requires a verbal or written EAP based on the number of employees that are physically present in a facility at any time of the working day.

The 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 EAP must communicate the following minimum requirements:

  • Means of reporting fires or other emergencies
  • Evacuation procedures, including exit route assignment
  • Procedures to be followed by employees who remain to operate critical operations before they evacuate
  • 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
  • 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.

Building owners should not limit response planning to fire emergencies, but consider an all-hazard approach when developing EAPs. Any scenarios that could impact the safety of building occupants should be planned and documented in advance. These scenarios may include, but are not limited to:

Human-caused threats

  • Bombs and bomb threats
  • Weapons of mass destruction
    • Chemical
    • Biological
    • Radiological/nuclear
  • Workplace violence

Building and infrastructure incidents

  • Building system failures
  • Elevators
  • Emergency power systems
  • Flooded areas
  • Medical emergency
  • Utility disruptions
  • Adjacent building fire

Location-specific natural disasters

  • Earthquakes
  • Hurricanes
  • Tornadoes
  • Tsunamis

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Building owners, tenants, and response personnel should coordinate and ensure efficient evacuation procedures are in place for all occupants, including those with disabilities. The EAP should account for:

  • Mobility impairments
  • Wheelchair users
  • Ambulatory mobility disabilities
  • Respiratory impairments
  • Visual impairments
  • Hearing impairments
  • Speech impairments
  • Cognitive impairments

Depending on the characteristics of the building and inherent functions of the occupants, building owners’ preparedness programs may consist of the required Emergency Action Plans, as well as additional plan types such as a Fire Pre Plans, and/or Hazardous Waste Operations plans. Any building response plan should be shared with local responders and include the following site-specific information:

  • Building description
  • Owner/Manager contact information
  • Emergency Assembly Point details
  • Internal and/or external emergency personnel information and contact details
  • Specific hazard details and associated safety data sheets
  • Utility shut-off locations and descriptions
  • Alarm(s) description
  • Emergency equipment inventory and locations
  • Plot plan(s) and floor plan(s)
  • Risk, site and task identified situational checklists and job specific procedures

Preparedness and Emergency Management - TRP Corp

 

Tags: Response Plans, Emergency Action Plan, Office Building

Fines, Compliance Tracking, and the PIPES Act of 2016

Posted on Thu, Aug 18, 2016

The Cost of Non-Compliance

Every month, audits and enforcement mandates are issued from various federal and state agencies that oversee industrial facilities. According to the Pipeline and Hazardous Material Safety Administration’s (PHMSA) summary of cases involving civil penalties, the first half of 2016 has resulted in 16 open cases with a proposed $3,070,200 in civil penalty fines. These cases were accompanied by a proposed compliance order (identifying actions the operator is required to take) and/or proposed civil penalties for these alleged violations.

As evident from the revolving door of compliance orders and penalty assessments, companies often take a non-compliance reactionary role rather than implementing proactive compliance measures. Preemptive compliance efforts and regulatory compliance tracking software programs are beneficial and often less expensive than agency fines.

According to the Ponemon Institute’s “True Cost of Compliance” 2011 report1, non-compliance is expensive. According to the study, the cost of compliance for 46 organizations averaged $3.5 million or $222 per employee. The extrapolated average cost of non-compliance for 46 organizations was significantly higher: nearly $9.4 million and $820 per employee.

Regulatory Compliance Tracking System

Adopting a regulatory compliance tracking system can streamline the process of compliance without increasing your employees’ workload. Regulatory compliance tracking software should:

  • Enhance company-wide regulatory compliance
  • Establish an effective means of corporate oversight
  • Provide systemic consistency for compliance tasks
  • Simplify documentation of compliance action items
  • Reduced the likelihood of non-compliance and associated penalties

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New Pipeline Regulations on the Horizon

Companies with pipeline operations often face multiple compliance mandates that require frequent monitoring and audits. As a result, compliance can be a significant cost. Recently, the “Protecting our Infrastructure of Pipelines and Enhancing Safety” (PIPES) Act of 2016 was signed into law. The act reauthorizes the PHMSA and related Department of Transportation programs through 2019 and enables the continuation of emergency response grants, one-call notification programs, state damage prevention programs, community pipeline safety information grants, and the pipeline integrity program. The PIPES Act of 2016 also reauthorizes the PHMSA to complete the remaining 15 Congressional mandates proposed with the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 20112. PHSMA has established a progress chart detailing the status of the initial 42 mandates.

Companies with applicable pipeline operations should be aware and monitor the following outstanding mandates in order to verify or align compliance initiatives (Note: For a full list, please refer to the PHMSA chart):

Automatic and Remote-Controlled Shut-Off Valves: Requires the use of automatic or remote-controlled shut-off valves on gas and liquid transmission pipelines constructed or entirely replaced after the date of the approved rule. The “Pipeline Safety: Amendments to Parts 192 and 195 to require Valve installation and Minimum Rupture Detection Standards” is projected to publish September 2016. The intent is to improve overall incident response.

Integrity Management Program Expansion and Class Location Replacement: PHMSA may extend a gas pipeline operator's 7-year reassessment interval by 6 months if the operator submits written notice with sufficient justification of the need for an extension. PHMSA should publish guidance on what constitutes sufficient justification. The "Pipeline Safety: Safety of Hazardous Liquid Pipelines" will be published October 2016 and the Pipeline Safety: Safety of Gas Transmission Pipelines proposed rule is still under evaluation.

Leak Detection: Final rules relating to leak detection on hazardous liquid pipelines and establishing leak detection standards set projected to be published October 2016.

Accident and Incident Notification: Reporting time should not be more than one hour after confirmed discovery. Notification requiring revision or confirmation of initial notification should be within 48 hours. Final rule projected to publish October 2016

Cost Recovery for Design Reviews: Setting up a cost recovery fee structure for design review of new gas and hazardous liquid pipelines with either overall design and construction costs totaling at least $2,500,000,000 or that contain new and novel technologies.  Final rule, "Operator Qualification, Cost Recovery and Accident Notification", is projected to publish October 2016.

Excess Flow Valves: Issue regulations requiring the use of excess flow valves on new or entirely replaced distribution branch services, multi-family facilities, and small commercial facilities, if appropriate.

Maximum Allowable Operating Pressure (MAOP) Verification: Require tests to confirm the material strength of previously untested gas transmission pipelines in HCAs. Require operators to report any exceedance of MAOP within 5 days, and regulations to ensure safety of pipelines without records to confirm MAOP. The proposed rule "Pipeline Safety: Safety of Gas Transmission Pipelines" is currently under review.

References:
2).http://www.phmsa.dot.gov/pipeline/psa/overview-and-progress

 

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance, fines

Budget Conscious Response Plan Testing and the Tabletop Exercise

Posted on Thu, Aug 11, 2016

Why Test Response Plans?

Budget restrictions and staffing limitations are continually on the minds of many corporate leaders. Yet response planning and preparedness continue to be an essential aspect of company operations. In order to be effective, response plans must be interactive, and continually updated and improved upon in order to provide actionable information, processes, and procedures that help manage incidents, infrastructure, and critical business processes. As a result, response plans must be tested.

Periodical response plan testing requires a dedicated budget, even in times of economic strain. Testing responses can identify detrimental training gaps and non-compliance issues that may compromise the effectiveness of a response plan and cripple operational continuity. This critical preparedness level feedback is essential in stabilizing readiness, response competency, and corporate sustainability.

There are various types of emergency response drills and exercises that test response plans. Depending on operations, potential risks, and budgets, these drills and exercises can range from small group discussions to complex, multi-faceted exercises. To fully execute a response plan, synergistic exercises should be developed to assess the following:

  • Communication
  • Training
  • Resource management
  • Command Post effectiveness

Managers should set exercise goals and budget before settling on a particular method. When budgets are restrained, a well-prepared tabletop exercise may be an acceptable method for a response plan assessment.

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The Tabletop Exercise

A tabletop exercise is the simplest form of exercise to conduct in terms of planning, preparation, and coordination. In order to garner a heightened awareness of preparedness, response competency and plan effectiveness, the following tabletop components should be considered when planning exercises:

Scenario Information and Position-Specific Tools: Detailed scenario information, ICS forms, and position specific events should be prepared to guide all participants through the execution of their roles and responsibilities.

Exercise Time Frame: The facilitator should determine how much time is allotted for the exercise in order to test response processes and procedures. Exercise responses are typically accelerated through each phase of the exercise. However, it should be clearly understood that the same events or actions under emergency conditions might require additional time to complete. Participants must be prepared for actual scenarios that can quickly transition from a basic emergency to a full scale crisis within a short time frame, requiring rapid decision making and expeditious responses.

Exercise Notification Communications: In all cases, exercise participants must ensure that all involved parties clearly understand that no actual emergency exists, and no resources or equipment should be mobilized or dispatched. The statement "This is a Drill" should be included on with all verbal communications and written correspondences, including report forms, fax communications, and press releases. It may be helpful to add the date to any written documentation for organizational and regulatory compliance purposes.

Communications with external agencies, contractors, medical responders, or other parties not participating directly in an exercise should also be informed as to not inadvertently initiate responses.

Response Equipment Deployment: Emergency equipment and vehicles should be simulated for tabletop exercises. Staging area locations should be identified.

Injects: An inject describes an additional event or circumstance that requires a response or action from the participant. Injects may be provided to specific participants or as a component of the entire exercise.

Weather Conditions: Adverse weather conditions may be simulated during an exercise. In an actual emergency, weather conditions may hinder response processes and procedures.

Exercise Termination and Debriefing: Following termination of the exercise, a debriefing of all exercise participants should be conducted. All participants should have the opportunity to provide feedback on the exercise and complete an exercise evaluation form. Feedback should be evaluated for potential response plan mitigation opportunities.

Follow-up on Action Items: Exercises may provide insight into the deficiencies in an emergency response plan. In order to take response efforts to the next level, action items resulting from the exercises should be prioritized and completed in a timely manner.

TRP Corp Emergency Response Planning Exercises

Tags: Testing, Tabletop Exercise

Business Continuity Scenarios to Review for Effective Preparedness

Posted on Thu, Aug 04, 2016

Many companies are looking for greater assurance that their business could withstand an unprecedented operational disruption. Yet, as potential influences continue to evolve, companies must ensure effective and applicable Business Continuity Plans (BCPs) are in place and are well-maintained. Mitigating business continuity response processes, procedures, and personnel responsibilities must be adaptive enough to account for current instigating conditions.

In order to effectively implement a relevant and applicable BCP, company leadership should:

  • Support budget allocations for the BCP program
  • Appoint key personnel to lead the program
  • Ensure the BCP team is staffed and fully trained to implement the plan
  • Provide the resources necessary to maintain an up-to date program that accounts for any site-specific changes to facilities, personnel, or processes
  • Provide support and resources to implement the BCP process and recovery strategies

 

Business Continuity Vulnerabilities

At any time, unforeseen circumstances beyond a company’s control can influence the operational status of a business unit. Managers should regularly monitor incidents that may cause a business disruption and/or have a serious impact to operations. Companies should continually evaluate the following scenarios to identify any vulnerabilities that may affect operational continuity. (Note: The list of vulnerabilities is not all-inclusive. Additional vulnerabilities may be applicable to your company.) 

  • Human errors or failures
    • Lack of training or policy guidance
    • Inadequate supervision
    • Intentional or unintentional disruptive practices
  • Human resource limitations
    • Strike
    • Inaccessibility to site
    • Pandemic outbreak
    • Aging population
  • Supply chain dependencies
  • Equipment damage
    • Vehicles
    • Critical industrial mechanisms
  • Technology-related failures
    • Cyber-attacks
    • Data fraud/theft
    • Critical system or network failures
    • Communication network failure
  • Infrastructure failures
    • Power failure
    • Water damage
    • Improper maintenance
    • Water supply crisis
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  • Failure of regulatory compliance
    • Fines
    • Mandated shutdowns
    • Reporting obligations
  • Natural disasters
    • Fires
    • Earthquake
    • Severe flooding
    • Hurricane/typhoon
    • Tornado
    • Volcanic eruption
    • Tsunami
    • Landslides
  • Regional and civil disturbances
    • Urbanization
    • Terrorism
    • Corruption
    • Religious fanaticism
    • Protests
  • Economic
    • Price fluctuations in critical commodities and/or natural resources
    • Dependence on central and/or commercial banks
    • Political influences
While many companies have BCPs in place, oftentimes they are untested or ill-suited for evolving conditions and potential threats. The BC program manager should ensure BCPs are applicable to relevant, realistic risks, and threats to their critical operations. A BC manager should:
  • Comprehend basic BC principles and methods
  • Ensure consistency in business impact analysis to identify critical business functions
  • Understand the correlation between operations, business continuity, IT disaster recovery, and emergency planning
  • Ensure that the BCP reflects the current hazard risk analysis, mitigation processes, business impact analysis, response management, and recovery strategies
  • Encourage coordination between all company staff while implementing a BCP
  • Identify and initiate appropriate, cost-effective strategies and procedures to recover critical business functions and information assets
  • Formally assign BC responsibilities to appropriate department managers and ensure each receives proper training to implement the BCP
  • Ensure that necessary contractual agreements exist for recovery of critical business functions and information resources
  • Review, update, and communicate BCP content changes
  • Continual improve the BCP as required

Preparedness and Emergency Management - TRP Corp

Tags: Business Continuity Plan

Business Continuity Planning Doesn't Have to Be Complicated!

Posted on Thu, Jul 28, 2016

Some incidents, regardless of size, can escalate rapidly, impact employees, disrupt typical operations, and affect your company’s financial stability. To prevent and reverse impacts from spreading to multiple departments and critical business processes, companies should prepare a thorough Business Continuity Plan (BCP). However, the path to sustainability and recovery is often complicated by ambiguous information, overlooked linked business processes, and static  plan formats. Business continuity planning does not have to be a complicated process. When companies utilize systematic methods to identify objectives and implement potential response in conjunction with intuitive formats, the process of recovery, continuity, and sustainability can be streamlined.

Business Continuity Plan Objectives

At a minimum, a BCP should provide the following:

  • Key operations and critical activities
  • Critical processes and strategies for recovery
  • Resources necessary to assess, declare, and recover from disruption
  • Evacuation and relocation information and policies
  • Key response personnel

However, identifying the potential implications of a sudden loss can be a daunting process. Determining business function inter-dependencies required to maintain operations is a significant step in effective response planning. Managers should not exaggerate the importance of departmental business functions, critical priorities, or recovery expectations. This can lead to further failures and prolonged recovery. A workflow analysis may assist managers in prioritizing each function and the necessary process to be recovered. At a minimum, managers should examine the following applicability and their critical function within their business unit:

  • Information Technology
  • Environmental, Health, and Safety
  • Personnel
  • Supply and Trading
  • Contracts
  • Accounts Payable and Benefits
  • Finance and Payroll

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Key Business Continuity Information

Once each department’s key functions and critical processes are identified, mitigated and tested, details can be implemented into the plan. Continuity processes should be aligned with company protocols, site-specific personnel details, and specialized training and exercise programs. At a minimum, the BCP should include

  • Notifications and activation details
  • Team roles and responsibilities
  • Facilities
  • Detailed Response Strategies
    •  Communications
    • Accountability
    • Evacuation
    • Relocation
    • Employee policies
    • Damage assessment processes
  • Critical Process Recovery Information
  • Termination and Demobilization
  • Documentation
  • Training and Exercises

 

Web-Based Business Continuity Formats

Effective BCPs should contain detailed and site-specific information for each operational facility. Because of the dynamic nature of operations and incidents, managing and communicating evolving counteractive process can be complicated by a static BCP format. Dynamic BCP formats and modern communication techniques can streamline evolutionary business process countermeasures. By transitioning from paper-based BCPs to a web-based approach, companies have the ability to integrate data into a standardized, enterprise-wide business continuity template with site-specific details for each particular site. Web-based BCP formats simplify business continuity planning by enabling:

  1. Efficiency: Maintaining up-to-date and actionable BCPs can be administratively time consuming. The most advanced web-based software programs utilize a database, allowing for specific repetitive information to be duplicated in the various necessary plan types across an entire enterprise. By minimizing administratively tasking duties, accuracy of the plans are optimized.
  1. Accessibility of plans: In the event of a business disruption, web-based plans are typically available from all company locations. However, web-based BCP software should offer every option of instant accessibility: via the Internet, downloaded, or printed to ensure accessibility in a variety of forms. Increasing accessibility options can bolster the entire business continuity program.
  1. Instantaneous Updates: Multiple versions of paper-based and intranet-based plans can potentially confuse and misinform the response team(s), prolonging a response and the business disruption. Web based software eliminates “version confusion” and allows the business continuity team to apply the most up-to-date and tested processes.
  1. Superior functionality: Simplifying documentation during an incident enables prompt response progress and faster return to “business as usual”. Web-based plans can provide hyperlinks, forms libraries, and simplified interfaces to improve streamlined functionality for plan users.
  1. Multi-purpose data: BCPs often share common data. Web-based, database driven plans utilize one database to manage this information, effectively leveraging plan content and revision efforts to all plans and locations that utilize that data.

TRP Corp - Emergency Response Planning Crisis Management

Tags: Business Continuity

Tips for a Company-Wide Response Planning Review

Posted on Thu, Jul 21, 2016

Terrorism, cyber-attacks, and natural disasters continue to impact companies around the globe at seemingly extraordinary rates. As these threats become increasingly complex and company profiles include intricate networks of technology, human resources, and global influences, corporate preparedness programs and applicable response plans need to be reviewed and tested for effectiveness and accuracy.

A thorough review should include information gathering regarding potential risks and threats to operations, as well as the status of current response plans, response competencies, and applicable regulatory requirements. It is critical to analyze various risks, threats, and on-site emergency response capabilities, as they are essential for responsible preparedness and core components of response plans.

 

Preparedness Documentation Review

While each facility has unique response planning needs and capabilities, the following general preparedness documentation, if applicable, should be reviewed and tested in relation to the identified site-specific threats:

  • Safety and health procedures
  • Environmental policies
  • Security procedures
  • Finance and purchasing procedures
  • Mutual aid agreements
  • Communication policy
  • Employee training manuals
  • Hazardous materials information
  • Business Continuity Plan
  • Risk management Plan
  • Hurricane/Tornado/Flood Plans
  • Evacuation Plan
  • Fire Pre-Plan

 

Collaborative Response Review

The review of company response plans should include debriefings with collaborative response entities. Meetings with these outside responders should confirm specific plan and response procedures details that can be carried out in accordance with collective best practices and company protocols. Groups to consider in planning reviews include, but are not limited to:

  • Local responders (fire, police, emergency medical services, etc.)
  • Government agencies (LEPC, Emergency Management Offices, etc.)
  • Community organizations (Red Cross, weather services, etc.)
  • Utility Company(s) (gas, electric, public works, telephone, etc.)
  • Contracted Emergency Responders
  • Neighboring Businesses

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Response Plan Review

Response plans must serve site-specific preparedness measures and meet precise planning objectives in order to be relevant and effective. Below is a list of basic response planning components that should be included in the preparedness review. These planning components should must be reviewed, confirmed, and updated as necessary in order for each facility to meet response objectives associated with each potential threat, risk or emergency scenario:

  • Site-specific response procedures
  • Response team frameworks and assigned personnel to fill primary and alternate roles
  • Effectiveness of notification and emergency response team activation procedures.
  • Communication procedures
  • Primary and alternate Emergency Operations Center location
  • Necessary response equipment
  • Response team and personnel response training
  • Mitigation procedures and protective actions to safeguard the health and safety of on-site personnel and nearby communities
  • Availability of responders and supply chain resources
  • Regulatory compliance with all applicable local, state, and federal requirements for environmental hazards, response plans, and training
  • Best practices and lessons learned integration from past training and exercises, actual emergencies, and incident reviews

 

Crisis Management Plan Review

As new vulnerabilities evolve and risk potentials unfold, every effort should be made to include crisis management response processes and procedures to the most likely emergency scenarios relevant to your site. A Crisis Management Plan (CMP) can minimize the escalation effect; such as a company’s short and long-term reputation, adverse financial performance, and overall impingement of company longevity. The associated level of preparedness may mean the difference between a crisis averted and an exhaustive corporate disaster.

The following concepts should be utilized when developing CMP:

PREDICT: Identify all potential threats to “business as usual” operations.
PREVENT: Take preventive measures to avert emergency situations and establish necessary communications platforms. This also includes generating effective response procedures and recovery processes for a variety of potential threats in order to minimize the extent of impacts.
PLAN: Prepare a plan for responding to all internal and external aspects of the crisis. This may include identifying and communicating with media and all audiences that may be affected by each crisis situation.
PERSEVERE: Follow your tested plan and be flexible if circumstances require additional support. Be sure to communicate ongoing activities to inform employees, stakeholders, and the public. Proactive efforts, honesty, empathy, and preparedness will assist in maintaining company viability and reputation.

TRP Corp - Emergency Response Planning Crisis Management

Tags: Response Plans, Crisis Management

The Evolution of Response Planning - The TRP Story

Posted on Thu, Jul 14, 2016

Technical Response Planning Corporation (TRP) staff recently sat down with its Founder and President, Steve Bassine, to discuss the company’s origins, its evolution, and the response to the ever changing demands of corporate preparedness and response planning.

After graduating from the University of Florida with a Bachelor of Science Degree in Engineering, Bassine began his career as a Project Engineer for Exxon’s South Texas Production Division in Corpus Christi, TX. It was in this first job that Bassine learned the importance of effective communication. “My role was ten percent engineering and 90 percent written and verbal communications.” While college prepared Bassine with a deep understanding of engineering concepts and principles, and provided the foundation to broaden his knowledge of oil and gas production, equipment and processing, regulatory compliance, and onshore and offshore operations, he discovered that fine-tuning his written, verbal, and decision-making skills were needed in order to be an effective project manager and future entrepreneur.

After the oil slump of the late 1980’s halted Bassine’s initial entrepreneurial aspirations, he accepted a job with a consulting firm that specialized in oil spill response planning. His immersive corporate and field experience with Exxon coupled with a practical expertise in response planning prompted Bassine to explore simplified preparedness processes.  “I knew there were better ways of doing things, and I needed the freedom to try them,” said Bassine.

In 1995, Bassine founded TRP in an effort to provide innovative response planning practices that simplified preparedness complexities for companies with large operations. “We were working hard to meet Client expectations, and stretching ourselves to find a better way to deliver response plans.” Two years later, the company pioneered industry’s first "electronic plan”, as well as graphical one-page response plans for fire pre-plans, oil spill tactical plans, and spill prevention plans. Bassine proved that these new techniques could be utilized to streamline complex preparedness and response planning processes, a great improvement to the static, paper-based response planning methods of the past.

Bassine continued to push the envelope of response planning innovation with the development of TRP’s first web-based response plans in 2001. “The availability of the Internet, reliance on and better understanding of computers and software, and the emergence of a tech-savvy workforce accelerated the understanding and acceptance of TRP’s approach.” At the time, web-based response plans were a new and unfamiliar concept. “Many companies were reluctant to be the first to commit,” said Bassine, “But today an overwhelming majority of companies are eager to embrace technology in order to help them solve their problems.”

Since 2001, the rapid acceptance of technology has continued to raise expectations for more robust, yet user-friendly functionality. Bassine made it a priority to align emerging technologies, societal behaviors, and client feedback with groundbreaking response planning platforms. The result was a proprietary response planning technology that eliminated redundant planning efforts while reducing errors, version confusion, and regulatory non-compliance. “We are always looking for better, more efficient ways of doing things, and for more user-friendly functionality. This, coupled with frequent feedback from clients and new prospects helps us keep abreast of new technology.”

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But after more than 20 years in the industry, Bassine says many companies are still challenged with preparedness, response planning, and enterprise-wide regulatory compliance issues. “The cyclical nature of the oil and gas industry and the difficulties of managing response plans for large operations are still relevant.” The TRP founder believes that the challenges have continued to increase over the years due to elevated scrutiny from regulatory agencies and the public, heightened profit/loss pressures, and the constant change of company structure, ownership, and staffing.

In a continual effort to simplify company-wide response planning, TRP released its SMARTPLAN™ software in 2015, which enables companies to do more with less resources. Companies utilizing this latest system can now revise content for multiple plans quickly, track revisions, print plans, manage contacts, and so much more. “Our latest technology reduces administrative efforts, eliminates the need to manage mountains of paper-based response plans and hundreds of Microsoft Word files, and provides a platform that facilitates more rapid and cost-effective upgrades. This leaves more time for our Clients to focus on strategic initiatives and provides assurances that our technology will continue to evolve.”

Incorporating technology for the sake of upgrading can often be costly, time consuming, and counterproductive. However, technology that provides innovative solutions to the challenges associated with preparedness, response planning, and regulatory compliance is highly advantageous in the emergency management realm. As TRP continues to fine-tune technologies and adapt systems to the needs of the consumer, they are setting a new standard for “Best Practices” in response planning software. With new response planning challenges continually arising, TRP solutions will continue to evolve to provide solutions to the ever-changing demands of preparedness and response planning.

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Management, Emergency Preparedness, Response Plans

10 Questions Executives Should Ask about Response Plans and Compliance

Posted on Thu, Jul 07, 2016

Corporate leadership teams must prioritize compliance with environmental, health, and safety regulations by financially supporting, authorizing, and directing management to initiate and sustain best practice emergency management measures. The intent of these regulations is to protect employees, communities, and the surrounding environments and reduce impacts in the event of an incident. Through consistent and dedicated support, executives can create a culture that prioritizes regulatory compliance, proactively prepares for threats, risks, and potential disaster, and has the ability to effectively respond if an incident were to occur.

Prioritizing compliance, preparedness, and response not only facilitates a unified culture of safety, but heightens a company’s ability to fulfill their moral responsibility to protect employees, the community, and the environment. Establishing an effective preparedness and response program enhances a company’s ability to:

  • Recover from financial losses
  • Limit or eliminate regulatory fines
  • Limit damages to equipment or products
  • Reduce the potential or duration of business interruption which could impact market share
  • Reduce exposure to civil or criminal liability and lawsuits in the event of an incident.
  • Enhance its image and credibility
  • Reduce insurance premiums

Executives must maintain profitable operations, yet ensure compliance with a complex array of federal, state, and local regulations. The consequences of being out of compliance can be damaging to the company, personnel, community, and professional reputations.

A compliant preparedness and response program includes multiple safety processes and procedures, as well as training, drills, equipment testing, and interoperability coordination. From a budgetary standpoint, emergencies, disasters, and incidents are expensive. Fortunately, compliance and mitigation costs are typically much lower than the expenditures associated with non-compliance fines, litigation, reputational risk, and government mandated shutdown of operations. 

True_cost_of_incidents.jpgTo ensure effective and compliant preparedness and response planning programs are in place, executives should propose the following questions to company managers:

  1. What activity presents the highest risk to our people and facilities, and how can these risks be minimized?
  2. Are there any newly identified threats and risks that require additional resources for mitigation?
  3. Are the individuals accountable for safety, preparedness, and response planning compliance receiving adequate training?
  4. What additional support is needed to improve safety, preparedness, and response planning compliance?
  5. Are company and contractor safety, preparedness, and response planning training programs being verified, and are the outcomes documented efficiently?
  6. When was the last time response plans had been verified and updated?
  7. Is employee input and/or feedback being utilized to improve safety, preparedness, and response planning processes? Do we have any recent examples?
  8. What were the top three high priority results of the last exercise?
  9. What lessons learned can be utilized for improvement to our process and procedures?
  10. Can our compliance verification continue to be handled internally, or do we need to seek external expertise to validate compliance?

Improving preparedness and response capabilities requires coordination across all levels of an organization. Collaborative pre-planning and exercising interoperable responses can minimize regulatory surprises and result in a more effective and timely response. When applicable, executives should encourage collaborative planning and exercises to validate response team positions, align priorities and common interests, and motivate participants to seek compromise for the good of an effective response.

Internal resources or outsourced compliance expertise can often enable a company to leverage regulatory knowledge across the entire company. In order to reduce managerial and administrative efforts required to manage compliance, companies often utilize external experts or consultants to ensure appropriate response planning and compliance measures.

Regulatory Compliance with TRP Corp

Tags: Emergency Management, Regulatory Compliance

Database Technology Implementation Eases Response Planning Compliance

Posted on Thu, Jun 30, 2016

According to the U.S. Government Accountability Office, antiquated technology utilized by various government departments is costing nearly $60 billion a year to maintain. In order for companies to remain competitive and sustain viable operations over the long-term, response planning technologies and compliance verification processes must be periodically evaluated and upgraded.

Preparedness, emergency management, and regulatory compliance is a dynamic endeavor. The increasing number of stringent regulatory requirements compounds the complexity of industrial operations. Many companies may believe they have the compliance component of their business under control. Others take a reactionary role rather than a proactive approach. Without a targeted response planning and preparedness approach, fines and devastating incidents can negatively impact company profitability.

As with rapidly advancing technology, company-wide preparedness efforts and emergency management priorities are inherently dynamic, creating a challenging atmosphere for complying with an array of regulations. Costly fines continually result from the lack of an implemented, thorough, or effective response planning and regulatory compliance programs. Advanced response planning systems that utilize database technologies can provide customization, providing the ability for companies to adapt their preparedness and emergency management to specific conditions and regulations. This cost-saving technology, at a minimum, enables companies to:

  1. Document critical data necessary for site-specific responses
  2. Easily incorporate new locations during growth
  3. Validate continually evolving regulatory requirements

Response planning systems with database technologies can include regulatory tracking benefits, easing the duties associated with maintaining compliance. Unlike spreadsheets or word processing programs, these advanced systems can easily leverage duplicate regulatory data across an enterprise. The ability to eliminate the need for administrative redundancies across converging compliance requirements is financially beneficial for organizations that have multiple applicable regulatory requirements. Utilizing a database limits the duplication of tasks generated when multiple agencies have regulations that are related to the same subject matter.

Modernizing compliance tracking efforts can improve overall preparedness levels. When operations and facilities expand beyond a few locations, a methodological tracking system can be utilized to itemize federal, state, and local regulations, and include categorical information that satisfies that regulation. A tracking system should, at a minimum contain the following components:

  • Operational categories: Categories can range from air quality and hazardous materials, to construction safety and general safety and health. Depending on the detail required by the regulations, further breakouts by subcategories may also be required.
  • Applicable Regulation Level: Regulations should be further broken down to federal, state, or local regulation categories.
  • Time/Date Stamping: The time and date that each regulation was last updated.
  • Compliance Feedback: Applicable notes regarding compliance or non-compliance.
  • Industry Standard: Apply best practices related to compliance with specific regulatory requirements, when practical to do so.
  • Cross-reference: Itemize list of additional regulations that may be applicable to the information provided.
  • Facility Compliance responsibility: Identify person responsible for compliance for each regulatory requirement.
  • Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and person(s) assigned. Reports should have filters to customize queries as required by the users.
  • Search Functionality: Create the ability to search database for keywords and phrases associated with regulations.

Adaptability is a crucial emergency management attribute. Companies should take the same approach when it comes to the tools utilized for their emergency management program. As new and innovative tools are developed, companies must not be left with antiquated, costly solutions to company-wide preparedness and regulatory compliance.

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance

Regulatory Compliance Fines are Increasing: Is Your Company Ready?

Posted on Thu, Jun 23, 2016

Since the 1990 Inflation Adjustment Act exemption, the set monetary penalties for violating OSHA’s health and safety standards have remained fixed. However, on November 2, 2015, Congress passed the Bipartisan Budget Act of 2015 which requires federal agencies, including OSHA, to adjust their civil money penalties based on inflation. Any penalty proposed or assessed after August 1, 2016, will reflect the increased fine.

According to a February 24, 2016 memorandum, executive departments and agencies are to adjust “the maximum civil monetary penalty or the range of minimum and maximum civil monetary penalties, as applicable, for each civil monetary penalty by the cost-of-living adjustment.” Per inflation, experts estimate that fines may rise as much as 80% compared to previous years’ rates. This estimation would result in the maximum penalty for a willful violation to be approximately $126,000, a significant increase from the current $70,000.

Agencies are required to publish initial penalty adjustment amounts by July 1, 2016, which must take effect no later than August 1, 2016. This timeline condenses the reactive mitigation period and minimizes the time for companies to confirm compliance across an enterprise. Encouraging regulatory compliance prioritization even further, agencies will be required to make annual inflationary adjustments based on the Office of Management and Budget guidance starting January 15, 2017. Companies must be proactive and confirm regulatory compliance or be ready to pay increased fines.

When company operations span across multiple locations, compliance verification can become increasingly complicated. In 2015, OSHA penalized Anheuser-Busch with safety violations at its New Jersey warehouse, resulted in a $150,000 fine. If the penalty was assessed after the upcoming August 1, 2016 adjustment, the company could have been fined nearly $270,000.

The cost to initiate, upgrade, and/or maintain a proactive EHS program may be seen as a superfluous expenditure. However, compliance efforts and compliance tracking software programs are often less expensive than agency fines. When companies can deliberately protect lives, prevent hazardous impacts, limit property damage, and eliminate increasing regulatory fines, EHS program prioritization becomes an investment in the long-term sustainability of a company.

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Site applicable regulations must be identified in order for processes, procedures, or response planning noncompliance to be discovered. Regulatory recognition can occur through routine inspections, job hazard analyses, and audits. Audits, whether done by in-house professionals or specialized contractors, can often reveal the same inadequacies and mitigation opportunities as identified by regulatory inspections, without the potential reputational and financial consequences of non-compliance. With an objective eye, an audit can bolster an overall emergency management program and minimize the potential for incidents or regulatory fines.

One of the most important aspects of maintaining compliant response plans is to update them in a timely manner. Cyclical response planning checks enable continuous reviews and potential revision opportunities, creating an optimal opportunity for regulatory compliance confirmation. Cyclical response plan reviews should include:

  • Safety and health procedures
  • Evacuation plan
  • Fire protection plan
  • Environmental policies
  • Security procedures
  • Response procedures
  • Communication Plans
  • Employee manuals
  • Business Continuity plan
  • Risk management plan
  • Hurricane/Tornado/Flood Plans
  • Mutual aid agreements

As agencies are redefining their monetary penalties, companies must not rely on the prospect of an inspection to ensure preparedness programs are sufficient. Regulatory deficiencies are most likely shared with others within the same industry, therefore, companies may identify potential solutions by researching applicable best practices. Often, the expertise and knowledge that drove the regulation into existence stems from the problems and experiences of others, and their efforts to address the inherent problem(s).

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance