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NEW Hazardous Waste Generator Regulations: Effective May 30, 2017

Posted on Thu, Jan 12, 2017

On November 28, 2016, the EPA published its final ruling that revised Resource Conservation and Recovery Act's (RCRA) hazardous waste generator regulatory program. According to the EPA, “the new ruling is intended to provide greater flexibility in how hazardous waste is managed to better fit today's business operations, enhance the safety of facilities that create hazardous waste and improve the response capabilities of emergency responders by improving risk communication.” The final rule goes into effect on May 30, 2017.

Highlights of New RCRA Rule 

  1. Reorganized hazardous waste generator regulations to make them more user-friendly, and thus improve their usability by the regulated community.
  2. Provide a better understanding of how the RCRA hazardous waste generator regulatory program works.
  3. Address gaps in the existing regulations to strengthen environmental protection.
  4. Provide greater flexibility for hazardous waste generators to manage their hazardous waste in a cost-effective and protective manner.
  5. Make technical corrections and conforming changes to address inadvertent errors and remove obsolete references to programs that no longer exist.

This final rule includes over 60 changes to the hazardous waste generator regulations that clarify existing requirements, increase flexibility, and improve environmental protection. These changes also reorganize the regulations to make them easier to follow and make certain technical corrections. The new ruling is aimed at the following:

User-Friendly and Flexibility

  • Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed.
  • Allowing a very small quantity generator (VSQG) to send its hazardous waste to a large quantity generator under control of the same person.

Improved Environmental Protection

  • Updating the emergency response and contingency planning provisions for small quantity generators (SQGs) and large quantity generators (LQGs) to include Local Emergency Planning Committees (LEPC).
  • Requiring periodic re-notification for SQGs every four years (SQGs only notify once under the current system).
  • Improved labeling and marking that clearly indicate the hazards of the hazardous waste contained inside of containers and tanks.

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Improve Generator Compliance

  • Clarification on generator categories and applicable guidelines regarding acute and non-acute hazardous waste.
  • Revises RCRA biennial reporting inconsistencies.
  • Replaces the phrase “conditionally exempt small quantity generator” with the phrase “very small quantity generator” to be consistent with the LQGs and SQGs generator categories.

Reorganization Regulations and Technical Corrections

  • VSQG regulations are moved to 40 CFR part 262, where the regulations for SQGs and LQGs are located.
  • Consolidates various generator regulations from other parts of the hazardous waste standards into 40 CFR part 262 to replace the current lists of cross references.
  • Corrects inadvertent errors in the regulations, obsolete programs, and unclear citations.

For a complete synopsis of the new Hazardous Waste Generator Improvements Rule, read the entire rule in the Federal Register.

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance

Top TRP Corporate Preparedness Blogs of 2016

Posted on Thu, Dec 29, 2016

As 2016 dwindles and our readers anticipate the New Year, TRP is looking forward to its 22nd year of innovation and service.  In addition to providing resourceful, informative articles that guide professionals in developing effective, compliant, cohesive, and world-class response plans, our response planning experts and in-house software development staff continue to introduce evolutionary technological improvements, upgrades, and state-of-the-art response planning tools and services.

Yet, before we move on to 2017, TRP would like to share our “Top Ten” blogs from 2016.  While the topics vary, we hope corporate and facility emergency managers, first responders, and industrial safety professionals can utilize these blogs to advance emergency management, preparedness initiatives, and safety efforts in 2017. 

Our “Top Ten” 2016 blog articles include:

10) The Evolution of Response Planning - The TRP Story: (July 14, 2016) TRP President, Steve Bassine, discusses TRP's origins, its evolution, and the company’s response to the changing demands of corporate preparedness, response planning, and regulatory compliance.

9) 3 Critical Pre-Planning Elements for Effective Crisis Management Plans: (September 1, 2016) The modern pathways of communication are so quick that companies must have solid communication and crisis management plans. Pre-planning communications details, methods, and response strategies for crisis management plan is essential for minimizing the impact a crisis situation.

8) Corporate Crisis Management Plans - Stabilizing the Chaos: (September 15, 2016) Every crisis has the potential to negatively impact a company’s reputation, daily operations, and financial performance. Learn how a strategic crisis management response plan framework with management, communications & recovery checklists and criteria is essential to have in place prior to any crisis scenario in order to guide the decision-making process.

7) Spill Response: HAZWOPER or Hazard Communication Standard Training? (September 8, 2016) Discover how spill response training levels distinguish between incidental spills and emergency spills that require evacuation and Hazmat team assistance.

6) “Top 10" Guide for Response Plan Exercises: (November 3, 2016) Learn the “Top 10” corporate preparedness exercise guidelines for effectively testing response plans and coordinating disaster responses to crises and emergencies.

5)  Business Continuity Scenarios to Review for Effective Preparedness: (August 4, 2016) The list of potential threats, risks and interruptions that can influence the operational status of a business unit is continuously evolving. TRP highlights potential scenarios that should be considered when developing business continuity plans and ensuring corporate preparedness.

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4) New PREP Guidelines Go Into Effect: June 2016: (April 26, 2016) Identify new PREP guidelines that went into effect in June that aligns terms, expands spill countermeasure topics, and includes salvage, marine firefighting, non-tank vessel exercise requirements.

3) What's Your Plan? Emergency Action Plan or Emergency Response Plan? (April 14, 2016) A brief description of the differences between Emergency Action Plans (EAP) and Emergency Response Plans (ERP) and how they each impact the specifics and details that must be included in corporate response plans.

2) U.S. Coast Guard Updates OSRO Classification Guidelines for 2016 (June 16, 2016) In March 2016, the US Coast Guard’s National Strike Force Coordination Center released the new 2016 Oil Spill Removal Organization (OSRO) Guidelines. Companies that contract OSROs to control a worst case discharge spill scenario must be aware of new USCG OSRO classification guidelines.

1) 10 Questions Executives Should Ask about Response Plans and Compliance: (July 7, 2016) 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. TRP highlights ten questions that executives should initiate to company managers to ensure effective and compliant response planning programs are in place.

TRP’s industry-proven technology has resulted in many large-scale enterprise-wide implementations across highly regulated industries. The TRP SMARTPLANTM platform has enabled these companies to transition from static mismatched formats and non-functional binder-based response plans to an all-inclusive, user-friendly, web-based preparedness program.

Preparedness and Emergency Management - TRP Corp

Tags: corporate preparedness

Response Plan Compliance Tracking and Submission

Posted on Thu, Dec 15, 2016

Regulatory Compliance is Not Optional

Month after month, companies are reminded through assessed fines and mandated enforcements that regulatory compliance is not optional. In August 2016, the U.S. Environmental Protection Agency (EPA) settled with an oil and gas equipment company for hazardous waste violations at five Texas facilities. The company was assessed a penalty of $237,980 for violations regarding improperly generating, transporting and disposing of hazardous waste.

These types of cases are not restricted to one industry. If regulations apply to operations, non-compliance fines can be assessed. The most widely applicable regulations to industrial companies are those under the realm of the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA).

 

Typical Industrial Requirements

Below are a sample of the EPA requirements that may be applicable to industrial operations:

  • National Pollutant Discharge Elimination System (NPDES) - Permitting program designed to control water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.
  • Facility Response Plan (FRP) - Requires an owner or operator of a facility that could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines to prepare and submit a facility response plan.
  • Resource Conservation and Recovery Act (RCRA) - The primary governing law that oversees the generation and containment of solid and hazardous waste.
  • Spill Prevention Control and Countermeasure Plans (SPCC) – Requires developing site specific plans for oil storage facilities that describe spill prevention and response procedures.
  • Emergency Planning and Community Right to Know (EPCRA) - Establishes requirements for federal, state and local governments, Indian tribes, and industry regarding emergency planning and "Community Right-to-Know" reporting on hazardous and toxic chemicals to enable a more effective emergency response planning process.

 

Response Plan Submissions

A simplified regulatory submission process is highly beneficial when companies have multiple facilities in various locations. Despite similar operations within the same industry, each site may need to comply with specific local, state, and/or federal regulatory mandates. Companies should have a systematic method to itemize these varied regulations and include categorical information that satisfies that regulation. Implementing a web-based planning system with a regulatory tracking element can eliminate redundancies across converging compliance requirements and minimize dedicated administrative time.

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Compliance Tracking System

Using database technology allows association of each regulatory requirement to applicable facilities. Additionally, updating evolving regulatory information can be effectively managed across multiple facilities with the use of a database. At a minimum, a web-based tracking system should contain the following components:

  • Operational Category: 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 subcategories may be utilized.
  • Applicable Regulation Level: Regulations should be further broken down to federal, state or local regulation categories. 
  • Update History: Date that each regulation was last updated.
  • Compliance Task: Tasks that needs to be completed for compliance.
  • Compliance Feedback: Applicable notes.
  • Industry Standard: Industry standards or best practices that apply to the specific -regulatory requirement.
  • Cross-reference: Itemized list of additional regulations that may be applicable to the information provided.
  • Facility Compliance Responsibility: Person(s) responsible to maintain compliance for each regulatory requirement.
  • Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and persons assigned. Reports should have filters to customize queries as required by the users.

The ability to track company-wide compliance and streamline the regulatory submission process is administratively advantageous for the individual company, as well as the multiple regulatory agencies. With required response plans in an easy to use electronic format, companies can ensure compliance and easily adhere to new, and future regulatory submission policies.

To receive your free white paper on Response Planning for Large Organizatiojns, click the image below:

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Tags: Response Plans, Regulatory Compliance

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.

 

Receive TRP's free guide: Tips on HOW to Conduct an Effective Exercise.

TRP Corp Emergency Response Planning Exercises

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

 

TRP Corp - Emergency Response Planning Crisis Management

 

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.

Preparedness and Emergency Management - TRP Corp  

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.

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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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Tags: Crude by Rail