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Corporate Preparedness Training and Response Exercise Management Tips

Posted on Thu, Dec 01, 2016

A company with multiple locations is often challenged with confirming and managing compliant preparedness practices and effective response planning programs under continuously evolving conditions. Each facility under the corporate umbrella typically has distinguishing operational structures, inherent hazards, and varying regulatory compliance guidelines. In short, maintaining preparedness and efficient response plans across an enterprise is a complex venture.

The preparedness components of each facility within a corporate enterprise must address site-specific operations, appropriate response processes, standardized company-wide best practices, and maintain location-specific regulatory compliance. Whether a facility is domestically located or abroad, ensuring compliance, employee safety, and an effective response requires a comprehensive preparedness training and exercise program. By utilizing available technology to manage these enterprise-wide programs, companies can verify compliance and ensure response readiness through a cohesive, yet site-specific standardization of best practices.

With proper maintenance and utilization of a training and exercise portal, individuals can be positioned to achieve and maintain peak optimal response capabilities. Preparedness training combined with tested response plan exercises can result in:

  • Response plan familiarization
  • Understanding individual roles and responsibilities
  • Improved response plans

Most companies, especially medium to large ones should implement a preparedness and response training and exercise management system with the ability to identify and sort specialized data.  This enables company managers to focus their efforts on operations and profitability. A centralized interactive, database-drive interface of scheduled, lapsed, and completed training requirements enables approved corporate personnel, facility managers, emergency managers, and health, safety, and environmental departments to:

  1. Simplify training reviews
  2. Easily identify training inception and expiration dates
  3. Verify responder knowledge and ensure employee accountability
  4. Identify regulatory compliance training gaps
  5. Account for preparedness endeavors and associated costs
  6. Ease maintenance and administrative efforts

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An enterprise-wide system is critical to enable systematic management of the training and exercise program for all company  locations. Managing several disparate systems and various paper files is cumbersome, time consuming and increases the potential for error. Web-based training and exercise management systems can provide authorized users with secure access from a variety of locations, simplifying the ability to update and document information as necessary. Additionally, as facilities are added or modified, operations are revised, or employees are re-assigned, training and exercise records can be conveniently added, accessed, transferred, or updated for accuracy and compliance. A comprehensive, web-based training and exercise management system will:

  • Reduce multiple site management and documentation formats
  • Streamline company protocols
  • Minimize administrative costs across the company
  • Minimize training discrepancies across an enterprise
  • Provide a historical record of training certifications and facility exercises
  • Engage company management in prioritizing preparedness efforts
  • Enhance reporting functionality and compliance
  • Reveal regulatory compliance training and exercise gaps
  • Track and report training completion or status by discipline, skill, position, individual, location, or over a specific time period
  • Generate summary reports that provide a snapshot of various mandated training and exercises versus completed and scheduled events
  • Print automated certifications and wallet cards
  • Serve as a legal instrument, if necessary

Advanced web-based technologies can also facilitate online training and provide classroom resources. While it is not required by regulations to implementing a web-based preparedness tool, it can reduce the ongoing corporate costs associated with classroom instruction and company-wide exercise management. Implementing a customized training and exercise management system in highly regulated environments is a proactive, cost-savings measure that can reduce the overall costs associated with incidents, training maintenance, and non-compliance.

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises

New Preparedness Guidelines for Medicare & Medicaid Facilities

Posted on Thu, Nov 17, 2016

The previous Medicare/Medicaid emergency preparedness regulations lacked the necessary comprehensive approach to account for the complexities of emergency preparedness. In particular, the previous regulations did not address the need for:

  1. Communication to coordinate with other systems of care within cities or states
  2. Contingency planning
  3. Training of personnel

As a condition of participation in Medicare and Medicaid, these health care providers must comply and implement all regulations within one year of the effective date, most likely by the end of 2017. Participating providers and suppliers must meet the following four common and well known industry best practice standards.

1. Risk Assessment and Emergency Planning: Based on a risk assessment, facilities must develop an emergency plan using an all-hazards approach, focusing on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters specific to the location of a provider or supplier. A risk assessment and subsequent response procedures may include, but are not limited to:

  • Hazards likely in geographic area
  • Care-related emergencies
  • Equipment and Power failures
  • Interruption in Communications, including cyberattacks
  • Loss of all/portion of facility
  • Loss of all/portion of supplies
  • Plan is to be reviewed and updated at least annually

medical_facility_preparedness.jpg2. Communication Plan: Facilities must develop and maintain a communication plan that complies with both Federal and State law. Patient care must be well-coordinated within the facility, across health care providers, and with State and local public health departments and emergency systems. The communication plan must:

  • Comply with Federal and State laws
  • Include a systematic process to contact staff, including patients’ physicians, and other necessary persons.
  • Provide a well-coordinated communication plan within the facility, across health care providers, and with state and local public health departments and emergency management agencies.

3. Policies and Procedures: Facilities must develop and implement policies and procedures based on the plan and risk assessment to comply with Federal and State laws.

4. Training and Testing: Facilities must develop and maintain training and exercises that comply with both Federal and State law. Patient care must be well-coordinated within the facility, across health care providers, and with State and local public health departments and emergency systems.
In order for health care facilities to remain compliant and evaluate and elevate preparedness levels, response plans must be tested for response readiness. A web-based exercise management system provides authorized users with secure access from a variety of locations. As facilities are added or modified, operations are revised, or employees are re-assigned, records can be conveniently added, accessed, transferred, or updated for accuracy and compliance. A comprehensive, web-based exercise management system will:

  • Reduce the need for multiple site training management and documentation
  • Minimize administrative costs
  • Minimize training discrepancies across an enterprise
  • Provide a historical record of training certifications
  • Streamline training directives from one source
  • Serve as a legal instrument, if necessary
  • Engage management in prioritizing preparedness efforts
  • Enhance reporting functionality
  • Identify regulatory compliance training gaps

The path to preparedness and recovery is often complicated by abundant information, overlooked linked processes, and static plan formats. Managing several disparate systems and multiple paper files is cumbersome and time consuming, especially in the midst of an emergency situation. When health care companies with multiple sites utilize web-based tools and streamlined methods, preparedness and response planning management can be streamlined.

Corporate Crisis Management

Tags: Event Preparedness

"Top 10" Guide for Response Plan Exercises

Posted on Thu, Nov 03, 2016

Corporate preparedness exercises should be designed to test response plan components and practice response management practices, including team roles, response strategies and tactics. Yet, corporate culture and their concerns about public perceptions often reject the ideology of growth through failure. An exercise should support a positive response team synergy by validating successes, yet create a path to increased response capabilities and improve targeted training efforts. Exercises should be utilized and perceived as tools for continuous improvement.

Response Plan Exercise Guidelines

Key guidelines for an effective Response Plan Exercise include, but are not limited to:

  1. Select exercise objectives based on the specific audience in attendance, and their level of experience.
  2. Discuss exercise objectives with participants so that everyone is focused and understands the intent and purpose.
    • Detailed scenario information, ICS forms, and position specific events should be prepared in advance to guide all participants through the execution of their roles and responsibilities. These tools should be included in a participation package and distributed to all participants prior to the exercise.
  3. Design scenarios to be realistic, with a level of detail consistent with objectives, and time allotted to conduct the exercises.
    • In order to exercise the emergency scenario, the exercise must progress in a condensed time-frame (not real-time). Events should move rapidly through some phases of the exercised response. However, it should be clearly understood that under real conditions the same events or actions would require much more time to complete.
  4. The objectives of the exercise may vary depending on the participants’ key functions, and may include, but not be limited to testing public affairs procedures, equipment deployment, response procedures, emergency notifications, communications processes, among others.prepdrill-resized-600.jpg
  5. Exercise participants should initially be limited to company personnel, until they have sufficient experience to respond effectively. Once the team is trained in this process, and perhaps have received additional ICS or NIMS training, participation by outside parties (including LEPC, fire and police department, state and federal response agencies, corporate team representatives, and response contractors) can be extremely valuable.
  6. Determine the most appropriate type of exercise to best suit objectives and budget: tabletop, command post, or training.
  7. Interject situations during the exercise to ensure that all participants are engaged and challenged. An Inject describes an event or circumstance that requires a response or action from the participant.
    • Depending on the scenario, and how much a factor weather is, either real or simulated weather conditions may be utilized during the exercise.
  8. Ensure that exercise participants maintain documentation throughout the event, and utilize this information for debriefing and final report.
    • “This is a Drill” Exercise Communications: All radio, telephone, fax and written communications must begin and end with the statement "This Is A Drill". Include this statement in all verbal communications, and in a prominent location on all written correspondence, including report forms, fax communications, and press releases.
    • "This Is A Drill" Communications with Non-Participating Parties: Communications with external agencies, contractors, medical responders, or other parties not participating directly in an exercise must begin and end with the statement ,"This Is A Drill". This may involve state or federal regulatory notifications or contact with suppliers or vendors to source simulated logistical needs. In all cases, exercise
  9. Ensure that timely final reports are completed, with lessons learned and action items documented.
    • 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.
  10. Determine action items and update response plan with lessons learned. Exercises 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 completed in a timely manner.

 

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Tags: Training and Exercises

Expert Response Planning Advice for Manufacturing Plants

Posted on Thu, Oct 20, 2016

There are many possible hazards associated with manufacturing plant operations. Heavy machinery, various corrosive and combustible chemicals, and possible confined spaces are just a few of the potential safety issues associated with production or manufacturing facilities. When incidents or emergencies occur, improvising and implementing unplanned response actions is often inadequate, potentially life-threatening for employees, and typically damaging to a company’s reputation.

Preparing for every possible known and unknown site-specific contingency may be unrealistic. However, every effort should be made to include processes and procedures for the most likely and applicable emergency scenarios relevant to your facility. By analyzing potential hazards, reducing risks, and investing in mitigation and preparedness, companies with manufacturing operations can secure the foundation for long-term risk management, sustainability and social responsibility.

Insufficient EHS budgeting often results in overwhelmed personnel responsible for developing new emergency response plans, or even updating existing ones. However, without proactive mitigation and inclusive response planning efforts, reactionary costs often outpace the expenditures associated with effective emergency management programs. Factors such as regulatory compliance, high-risk locations, shifting labor markets, and emerging competitors can increase the complexity and cost of overall operations. However, these external factors should not deflect attention from crucial response planning efforts. 

The potential for additional costs related to fines, emergencies, crises, and business continuity issues is prevalent when preparedness measures are neglected. Incident recovery costs often include, but are not limited to:

  • Impacts on employees
  • Short term or long term business interruption
  • Regulatory fines or mandated shutdown for non-compliance
  • Infrastructure damage
  • Equipment failure
  • Inventory/stock losses
  • Reputation
  • Environmental damage

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Each manufacturing site must analyze their potential hazards and applicable responses. The analysis should identify and evaluate low, medium, and high impact likely scenarios, associated response expenditures, and total estimated recovery costs. Every section of the response plans needs to serve a specific purpose and meet explicit site-specific planning objectives. Below is a list of planning objectives that may be relevant to your facility:

  1. Establish site specific emergency response procedures for scenarios including:
    • Medical emergencies
    • Chemical releases
    • Fires
    • Severe weather
    • Security issues
    • Confined space rescue, if applicable
  2. Establish mitigation procedures and protective actions, such as evacuation or shelter-in-place, to safeguard the health and safety of on-site non-emergency personnel and nearby communities.
  3. Design an incident management team organization and assign personnel to fill primary and alternate roles.
  4. Ensure incident management team personnel receive applicable training for their roles.
  5. Define notification and response team activation procedures.
  6. Establish response communication procedures and identify necessary communication equipment.
  7. Identify internal and external resources necessary to ensure availability of applicable responders and equipment.
  8. Identify primary and alternate Emergency Operations Center location.
  9. Maintain compliance with all applicable local, state, and federal requirements for emergency response plans, training and exercise requirements, and hazardous materials, if applicable.
  10. Integrate industry-specific best practices, as well as lessons learned from past training, exercises, and actual emergencies.

Violating government regulations and disregarding employees’ safety can tarnish a company’s reputation, impact shareholders’ worth, and alter customer relations. As a result, manufacturing plants may require multiple plan types to account for varying regulatory and operational factors. These plan types may include, but are not limited to:

  • Emergency Response Plans
  • Business Continuity Plans
  • Crisis Management Plans
  • Spill Prevention Plans (SPCCs)
  • Fire Pre-Plans
  • Emergency Action Plans
  • Severe Weather or Hurricane Plans
  • Pandemic Plans

 

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Tags: manufacturing

Record Oklahoma Earthquake Highlights Need for Earthquake Preparedness

Posted on Thu, Oct 06, 2016

On September 3rd, a 5.8 magnitude earthquake jolted Pawnee, Oklahoma, making it the state’s largest recorded earthquake. The shallow quake occurred approximately 55 miles WNW of Tulsa, yet could be felt across six neighboring states.

Although early detection systems are under development, it is difficult to target when an earthquake will occur or where the epicenter will be located. According to a March US Geological Survey report, “Seismic activity is on the rise in certain energy-intensive states after a relatively stable period of about 30 years.” The report showed that approximately 7 million people live and work in areas of the central and eastern U.S. with potential for damages caused by induced seismicity. 

Response planning for unpredictable events is a core element of corporate preparedness. Without a robust early detection system in place, companies must rely on reinforced construction methods and structural mitigation opportunities to minimize potential infrastructure damage. However, earthquake preparedness and response planning can limit the effects of an earthquake.

The actual ground movement created by earthquake is seldom the direct cause of death or injury.  However, earthquakes can severely damage sensitive infrastructure and generate vibrations that can shake, damage, or demolish buildings, each of which can cause great damage. As a result, most earthquake casualties result from falling objects and debris.

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Upon immediately sensing seismic action or aftershocks, it is prudent to take protective measures. The following procedures should be implemented in the immediate aftermath of an earthquake:

Inside a building:

  • Remain calm and clear-headed. Major earthquakes generally last less than 60 seconds.
  • Move quickly away from windows, tall fire cabinets, and other things that could fall. Watch for falling plaster, light fixtures, and other objects.
  • Shelter yourself by getting under a table or desk.
  • Protect yourself, kneel down, or squat to protect your head.
  • If you are able to shield yourself under a desk, do not try to relocate to a doorway. Heavy industrial doors can cause damage when they swing during an earthquake and trying to maneuver through falling debris can cause more injury.
  • Do not attempt to leave the building. You are much safer to remain still inside the building until the shaking stops.
  • If necessary or directed, exit the building after the shaking stops.

Outside a building:

  • Seek protection away from buildings. Falling glass, power lines, and debris can be very hazardous.
  • Once it is safe to do so, contact Supervisory personnel

Post-Quake Response Actions:

  • If hazardous conditions are present, initiate or follow emergency response procedures.
  • Be prepared for additional aftershocks. Although most aftershocks are smaller than the initial earthquake, some may be large enough to cause additional damage.
  • Do not attempt to move seriously injured persons unless they are in immediate danger of further injury.
  • Inform management of your location, damage and injuries.
  • If safe to do so, inspect facilities for signs of damage.
  • Check for fire or fire hazards from broken electrical lines or short circuits. Initiate fire response procedures if a fire is discovered or can reasonably be expected.
  • Relocate company vehicles out of garages and structures, if applicable.
  • Secure any shelving, and inspect on-site stock.
  • If damage is found, report findings to management.
  • If available, listen to media coverage to determine the earthquake location, strength and area infrastructure damage.

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Tags: Earthquake Preparedness

Expert Tips on Addressing Corporate EOP Challenges?

Posted on Thu, Sep 29, 2016

One of the most important, yet challenging, aspects of maintaining up-to-date and compliant emergency operations plans (EOPs) is to initiate updates in a timely manner. These challenges are often intensified by changes in organizational structures. Corporate downsizing, mergers, acquisitions or reorganizations in additional to typical employee turnover can render required EOPs inaccurate, obsolete, and non-compliant. As corporate frameworks expand and contract, processes must in place to verify EOP details for each location and certify site-specific regulatory compliance.

Company-Wide EOP Audit

Cyclical EOP audits enable continuous reviews and potential revision opportunities. But as company facilities, operations, equipment, and employees change, it is critical that each site’s EOP be audited by EHS department or plan administrator(s) to determine potential discrepancies, format disparities, and regulatory deficiencies. The following preparedness concepts and EOP particulars should be reviewed for each company facility for the accuracy and effectiveness:

  • Safety and health procedures
  • Evacuation plan
  • Fire protection plan
  • Environmental policies
  • Security procedures
  • Supply chain purchasing and response procedures
  • Closing and communication policy
  • Employee manuals
  • Hazardous materials plan, if applicable
  • Business Continuity plan
  • Risk management plan
  • Hurricane/Tornado/Flood Plans
  • Mutual aid agreements

If discrepancies and deficiencies are identified, adjustments must be incorporated to ensure compliance, efficiency, and effectiveness. If multiple updates are needed, it is beneficial to utilize a web-based, database driven planning system that can eliminate duplication of tasks and planning responsibilities, minimizing costs of dedicated administrative hours.

Data-base-response-planning.jpg

 

Review Historical EOP Oversights

Typical EOP errors include, but are not limited to the following:

  • Personnel listed in response plans are no longer employed with the company or at specific facility
  • Emergency response duties and responsibilities are not assigned to appropriate personnel
  • Inaccurate contact information for company personnel and external resources
  • Lack of detailed hazardous material spill response procedures
  • Lack of site-specific fire pre-plans
  • Training deficiencies
  • Inefficient documentation
  • Inconsistencies or missing information required for current local, state and/or federal regulations
  • Differing plan formats and versions resulting in varied information and disjointed composition
  • No efficient process for implementing lessons learned, changes in policies, or regulatory requirements

 

Initiate Safety and Response Best Practices

When specific site, operational, response, or regulatory components change, facilities need to confirm that best practices apply to their site-specific situation. Deliberating on and implementing applicable best practices and lessons learned can positively impact company preparedness and response readiness. While companies may not need to “reinvent the wheel” when it comes to safety and response procedures, each facet of a company’s operations should be broken down to examine specific best practices for a particular action, material, scenario, and/or site circumstance.  For example, safety and response best practices exist in the following areas:

  • Pre-incident planning
  • PPE and response equipment
  • Security
  • Fire brigades
  • Rescue
  • Hazardous materials handling/response
  • Fire planning and prevention
  • Shelter-in-place and evacuation
  • Training
  • Exercises

Incorporating site-specific and current human resource information into a plan allows for the plan to go from stagnant process and procedures, to an actionable response. Accurate internal and external contact information must be verified and documented in order for assigned response roles and responsibilities to be carried out.

 

Streamline Emergency Communications

The ability to communicate among internal and external responders, as well as adopting the Incident Command System (ICS) is an important element. ICS provides “structure across multi-jurisdictional or multi agency incident management activities to enable agencies with different legal, jurisdictional, and functional responsibilities to coordinate, plan, and interact effectively on scene.” This open communication can increase the potential that enterprise-wide EOP response procedures are carried out in accordance with best practices and company protocols. When company components and/or organizational structures change, collaborative planning and exercise efforts can often validate participants’ positions, align priorities and common interests, and motivate participants to seek compromise for the good of corporate preparedness and effective response.

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Preparedness, corporate preparedness

Rail Safety Regulations Implementation, Mitigation and Preparedness

Posted on Thu, Sep 22, 2016

The first officially recorded U.S. railroad accident occurred in 1832 when four people were thrown off a vacant car on the Granite Railway near Quincy, Massachusetts. The victims had been invited to view the freight process of transporting loads of stone when a cable snapped on the return trip. As a result, the observers were thrown off the train and over a 34-foot cliff. One man was killed and the others were seriously injured.

Rail technology, applicable safety regulations and compliance initiatives have significantly changed since 1832. In early 2016, the Federal Railroad Administration (FRA) announced that its heighten enforcement of railroad safety regulations in 2015 led to the highest civil penalty collection rate in the agency’s 50-year history. “Safety must be the number one priority for every railroad, and the Department of Transportation will continue to take aggressive action against railroads who fail to follow safety rules,” said U.S Transportation Secretary Anthony Foxx. “A strong safety enforcement program is critical to prevent accidents, save lives and move our country forward.”

According to the Association of American Railcars, freight railroads operate over a network of nearly 140,000 miles and serve nearly every industry sector of the economy. Two significant safety measures affecting the state of rail safety include the ‘Implementing the Positive Train Control Enforcement and Implementation Act of 2015”, and “FAST Act Requirements for Flammable Liquids and Rail Tank Cars”.

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The FRA has been monitoring the progress of the “Implementing the Positive Train Control Enforcement and Implementation Act of 2015”. Positive Train Control (PTC) provides a capable system that prevents train-to-train collisions, over speed derailments, incursions into established work zone limits, and the movement of a train through a main line switch in the wrong position. When active, the PTC can mitigate multiple vulnerabilities and eliminate the need for an emergency response.

The initial December 31, 2015 deadline for Positive Train Control (PTC) enforcements was extended to December 31, 2018 to allow for railroads to achieve full PTC integration. However, rail companies are slow to make the expensive transition.

The PTC integration status update as of the June 30, 2016 is as follows:

PTC Implementation Freight Rail Passenger Rail
Radio Towers Installed 73% 46%
Locomotive Equipped 34% 29%
Training Completed 43% 41%
Route Miles in PTC Operation 9% 22%
Track Segments Completed 11% 12%

 

The law also authorizes up to a two-year additional extension on a case-by-case basis if the railroad can demonstrate that it has fulfilled statutory prerequisites including, but not limited to:

  • Installed all PTC hardware by December 31, 2018
  • Acquired all spectrum necessary for implementation of the PTC system by December 31, 2018
  • Completed employee training required under FRA’s PTC regulations
  • Included in its revised PTC implementation plan an alternative schedule and sequence for implementing PTC as soon as practicable
  • Certified in writing that it will be in full compliance with the requirements of 49 U.S.C. § 20157 on or before the date in the alternative schedule and sequence, subject to FRA approval.

On August 15, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the FRA issued a final rule modifying regulations governing trains hauling crude oil and other flammable materials. The potential impacts of a hazardous material incident can be significant.

  • The rule mandates that all new tank cars (specifically, each tank car built to meet the DOT-117 specification, and each non-jacketed tank car retrofit to meet the DOT-117R specification) be equipped with a thermal, insulating protection blanket that has been approved by PHMSA pursuant to 49 C.F.R. 179.18(c).
  • These new tank car requirements are expanded to all trains hauling flammable liquids, regardless of the length of the train.
  • Older tank cars retrofitted to the new design standard (the DOT-117R specification) must be equipped with certain minimum top fittings protections.
  • The rule also requires a faster phase-out of older model tank cars used to transport unrefined petroleum products (e.g., petroleum crude oil), ethanol, and other Class 3 flammable liquids, irrespective of train composition.

As of January 1, 2016, there were 4,613 DOT-117 style tank cars in the manufacturing backlog.

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Corporate Crisis Management

Tags: Crude by Rail

Corporate Crisis Management Plans - Stabilizing the Chaos

Posted on Thu, Sep 15, 2016

As Southwest Airlines experienced over the 2016 summer, unforeseen circumstances can land companies in precarious situations. The airline experienced technology failures in the height of the summer travel season, yet met the crisis scenario with swift implementation of their crisis management plan. Although nearly 2,000 flights were cancelled and an estimated 250,000 passengers were stranded, Southwest Airlines’ multichannel crisis communication approach upheld the company’s reputation as a customer-focused airline.

Regardless of the circumstances, every crisis has the potential to negatively impact a company’s reputation, daily operations, and financial performance. Companies must have a clear understanding of their impacted audience, whether it be their employees, customers, or a community, and tailor a crisis management plan accordingly.

Crisis Management Team Activation

Activating a response team that can deliver swift and effective responses is the bridge to stabilizing a crisis situation. In order for a crisis management plan to be properly initiated, employees and responders should understand established response policies and intended context of emergencies communications. A strategic response framework with checklists and criteria that can guide the decision-making process must be developed and tested prior to a crisis in order for the scenario to be stabilized.

Crisis Communications

A tested crisis communications plan is instrumental in minimizing chaos. Communication policies and procedures should be developed as part of the planning phase, not on the verge of, during, or in the aftermath of a disaster. Through pre-planning, a communication plan can be fully integrated into the overall crisis management plan.

Response communications must be timely, transparent, and dynamic in order to defuse incident escalations and potential rumors. Unfortunately, during the height of a crisis, bleak realities and raw emotion often alter communication agreements and promote misinformation. In this 24/7 information age highlighted by real-time social media connections, an exercised communications plan should include informational jurisdiction decisions about what to release, by whom, and when.

Southwest Airlines utilized multiple social media channels in order to address the technical failure and subsequent customer complaints. The company’s multiple live Facebook video feeds kept customers up-to-date on the current state of the technology challenges. In total, the feeds received over one million views. This targeted approach minimized the potential perceived incompetence that could have resulted from a lack of communication and should be a lessons learned for other companies.

Crisis_Management_Plans.jpg

Engaging with media outlets and the exponential number of layperson journalists can be an unnerving element of a response. Through crisis management planning, specialized training, and all-inclusive exercises, companies can stabilize potential chaotic public relations scenarios. The more detailed the information, the less room for interpretation. In order to regulate inaccurate perceptions, initial communications should contain the following elements:

  • A brief, focused, and factual description of the situation and initial response actions
  • Processes established to minimize and counteract the emergency
  • An expression of empathy and apologies to impacted parties
  • Access to subject matter experts to answer media inquiries
  • Timing for media follow-up but only promise what can be delivered
  • A statement of commitment to return to “business as usual”

Crisis Recovery Guidelines

Specific recovery guidelines provide agreed-to procedures to help facilitate an expedited return to normal operating conditions. A detailed and collaborative planning effort can equate to a faster recovery time, minimizing the ongoing effects of the disaster. Potential risks and associated consequences must be identified and planned for prior to an emergency in order to react efficiently.
When developing crisis management plans, companies should consider the following questions:

  • Are clear and accurate internal notification and activation procedures in place to mitigate the crisis? Is all contact information up-to-date?
  • Are procedures specified to enable trained observers to confirm, characterize and quantify the impact of the crisis?
  • Can the incident be reported rapidly and reliably to the on-site staff to take action?
  • Who is able to provide responders with the necessary information to accurately respond?
  • Can further planning and response mobilization be implemented and communicated based on current and potential site specific conditions?
  • Is there a reliable model to provide timely prediction of immediate, intermediate and long-term impacts and how will this be relayed to your targeted audience?
  • Does the initial assessment indicate obstacles to mounting a response? Can these be mitigated based on a risk assessment?
  • Have procedures been tested with appropriate responders?
  • Are multi-channel communications and backup systems available and reliable?
  • How does social media and the various media outlets tie into the crisis management plan?

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Tags: Crisis Management

Spill Response: HAZWOPER or Hazard Communication Standard Training?

Posted on Thu, Sep 08, 2016

The costs associated with effective employee training, spill prevention, and spill response planning are often much less than the costs associated with fines, spill cleanup, and other civil liabilities. As a result, companies should not wait for a safety incident or regulatory inspections to ensure their emergency management programs are sufficient.

When hazardous materials are on site, employees must be trained to distinguish between incidental spills that can be handled in house and emergency spills that require evacuation and Hazmat team assistance. OSHA would prefer that all potentially exposed employees are trained to at least the awareness level. However, the properties of hazardous substances combined with the circumstances of a release  affects the applicable OSHA standards, the corresponding mandated employee training level, and the subsequent emergency procedures. 

Spills without emergency consequences are considered “Incidental Spills” and are covered by the Hazard Communication Standard (29 CFR 1910.1200). Under the specification of the Standard, employees who are trained on the hazards of the chemicals they are working with may safely clean up an incidental spill. An incidental spill can be described as:

  • Hazardous
  • Limited in quantity
  • Limited in exposure potential
  • Limited in Toxicity
  • NO or minor safety threat to employees or immediate vicinity
  • NO or minor health hazard to employees or immediate vicinity
  • NO or minor effects from cleanup process
  • NO potential to become an emergency within a short time frame.

“Emergency spills” are covered by the standard for Hazardous Waste Operations and Emergency Response (HAZWOPER). For the definition of "emergency response" to be satisfied under HAZWOPER, the release or situation must pose an emergency and may:

  • Cause high levels of exposures to toxic substances
  • Be life or injury threatening
  • Mandate personnel evacuation
  • Cause Immediately Dangerous To Life or Health (IDLH) conditions
  • Cause a fire and explosion hazard (exceeds or has potential to exceed 25% of the lower explosive limit (LEL)
  • Require immediate attention because of potential danger
  • Present an oxygen deficient condition

Hazardous_Spill_Response_Plan.jpg

Where applicable, all employees involved in an emergency response must be trained under 29 CFR 1910.120.  HAZWOPER training can include:

  • General site workers: Individuals, such as equipment operators, general laborers and supervisory personnel, who are engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health.
  • Operations crew: Individuals involved in hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with Environmental Protection Agency to implement RCRA regulations.
  • Emergency response operations team: Those directly involved in responding to the releases of, or substantial threats of releases of hazardous substances, regardless of the location of the hazard.

Numerous organizations have emergency response policies in place based on misinterpretation of the HAZWOPER regulations. The purpose of the initial responder (operations level) of an emergency is to protect life, property, or the environment from the effects of the release, not stop the release. Operational responders are trained to respond in a defensive fashion without actually trying to terminate the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.

There are various training levels within HAZWOPER. Training levels should reflect the type of work and the potential hazard involved in the work.

  • 24-hour HAZWOPER Training: Appropriate training for those who are less directly involved with uncontrolled hazardous waste sites (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying).
  • 40-hour HAZWOPER Training: Those individuals directly involved in the cleaning up of hazardous materials, its storage, or its transportation should take the 40-hour HAZWOPER course. The 40 hour course is required for the safety of workers at uncontrolled hazardous waste sites.
  • 8 hours HAZWOPER Training: Managers are required to attain the same level of training (either the 40-hour or 24-hour training) as those they supervise, and an additional 8 hours.

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises

3 Critical Pre-Planning Elements for Effective Crisis Management Plans

Posted on Thu, Sep 01, 2016

The first hours and days of a crisis situation are the most critical. High pressure environments and atypical events often breed additional chaos and public relations nightmares that can rapidly tarnish a company’s sterling reputation. Whether you're company has a few domestic locations or an extensive international network of offices and facilities, designing a comprehensive Crisis Management Program (CMP) with a means for effective communication is essential to the continued success of your company.

From the minute an incident occurs, a company’s response can be publicly scrutinized and analyzed by the masses. The modern pathways of communication are so quick, companies must have solid communication and crisis management plans. Any response plan should be tested for effectiveness in the planning phase, not on the verge of, during, or in the aftermath of a disaster. Through pre-planning, a communication plan can be fully integrated into the overall crisis management plan and be available at the onset of an incident.

Crisis Communication Planning

Communication pre-planning should include, but is not limited to, the following:

1. Notification methods: The standard "phone tree" has evolved to include a variety of dynamic communication formats. Do not assume that internal and external responders, stakeholders, and those impacts by the crisis scenario identify with current company communication policies, formats, or context of emergencies communications. Pre-planning efforts should include establishing and exercising coordinated notification processes, formats, and various content.

Most professionals have several phone numbers, multiple email addresses, and can receive SMS (text) messages and digital images. As a result, a clear crisis communication notification methodology must be established.

The primary notification of a crisis situation should be made by telephone or radio to ensure leadership has received the critical information to begin response procedures. All known information regarding the scenario should be provided, including but not limited to:

  1. Type of event (technology, fire, explosion, etc.)
  2. Immediate impact
  3. Location of incident
  4. Any casualties or injured parties

In an effort to minimize the communication gap between a company and the general public, companies should establish social media notifications as part of their crisis communication planning. According to a Pew Research Center October 2015 publication entitled “Social Media Usage: 2005-2015”, nearly 65% of American adults utilized at least one social media platform in 2015 compared to only 7% in 2005. As mobile technology is adopted by a greater percentage of society, those statistics should continue to grow.

Utilizing social media as a tool for Corporate Crisis Communications has numerous benefits including, but not limited to:

  • Opens up a dialogue to reduce miscommunication and rumors
  • Informs public of potential threats, impacts, and applicable countermeasures
  • Communicates mobilization of internal coordinating teams, staff, and/or volunteers
  • Improves externally communications with agencies and people affected by the crisis
  • Provides real-time updates and allows company personnel to have a first-person awareness of a situation.
  • Active communication demonstrates that the company values emergency preparedness and response and its implications to the community
  • Eliminates an information bottleneck
Crisis_Management_Plans.jpg

2. Contact Verifications: Primary and secondary contact information should be verified for personnel, responsible agencies, and contracted responders. Verification should be conducted on a periodic basis in order to maintain accurate and applicable information. Communication equipment, such as hand held radios and satellite phones, should be verified as functional and tested periodically to ensure they are available when necessary.

One of the greatest challenges in preparedness and response planning is the continual effort to maintain up-to-date contact database. Dedicated man-hours or an automated cycle of contact verification should be in place as part of the maintenance phase of planning.  A contact verification tool that integrates with a web-based, database driven response plan can save timely maintenance efforts and can eliminate a potential lapse in emergency response. Without valid phone numbers, even a call out system is voided if the contact’s information is inaccurate. Every effort should be made to regularly confirm contact information with partnering entities that are involved in a response.

3. Strategic Considerations: While the specific circumstances will define a crisis response strategy, basic communications processes typically remain consistent. Establishing a systematic framework with checklists and response criteria can guide crisis manager through the communications decision-making process to allow for an effective response.

If the crisis warrants, the pre-identified crisis management team would be responsible for developing media strategy, public statements, and key messaging, as well as identifying and briefing one or more spokespersons to deliver the pre-approved messages to media outlets. A specific individual or individuals should be assigned to media/public relations to ensure messaging consistency and information availability.

Emergencies and crisis scenarios do occur and companies must respond swiftly and effectively. There can be a multitude of communication and response details, variables, and eventualities that must be taken into consideration and planned for. Yet, timely responses and proactive communication in the early stages of a crisis can dramatically reduce the negative implications of an emergency scenario.

Corporate Crisis Management

Tags: Crisis Management, Communication Plan