Are Your Plans Smart Enough?

High Petroleum Supplies Advocate Oil Spill Response Plan Reviews

Posted on Thu, Apr 16, 2015

According to the March 27th U.S. Energy Information Administration's weekly status report, the petroleum supply continued to rise in the first quarter of 2015. Bloomberg Energy suggested that oil inventory is approximately 25% above its 5-year average. Many petroleum storage facilities are handling near capacity volumes and should evaluate preparedness measures and oil spill response plans to ensure the hazards associated with increased oil storage volumes are accurately and effectively addressed.

Operators of oil storage facilities should review their oil spill response plans to ensure that response procedures are consistent with local topography, sensitivities, and other site-specific details. This is especially critical when tank volumes and potential spill impacts are increasing. If properly planned, exercised, and executed, plans can protect lives, communities, and the environment, and reduce the financial impact associated with an oil spill.

The primary objectives of oil spill response plans are to:

  • Allow response personnel to prepare for and safely respond to spills
  • Ensure an effective and efficient response despite geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response
  • Outline response procedures and techniques for combating the spill at a specific location
  • Improve regulatory compliance efforts

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Through facility assessments, best practices, and responder input, effective plans should incorporate a variety of aspects and perspectives of a response. As inventories increase, it is imperative that risks and threats be re-evaluated. The following 30 questions can be used as planning discussion points to develop or review oil spill plans:

  1. Have high-risk activities been identified, assessed and, if possible, mitigated?
  2. Have sensitive areas been identified and potential consequences been assessed for the current tank volumes?
  3. How would a potential spill with current tank volumes affect external resources?
  4. Did previous risk assessments utilize realistic scenarios, current oil volumes, and potential release locations?
  5. Have trajectory estimates been completed for a variety of tank volumes, and do they include potential weather scenarios?
  6. Do trajectory maps mimic local observations and historical tendencies?
  7. Have trajectory-timing estimates and recovery location points been included in oil spill planning process?
  8. Have Safety Data Sheets been updated per OSHA regulations, and are hazardous material properties been included in the planning process?
  9. Have processes been established for updating planning information, tank volumes, and required response resources?
  10. Have plot plans and area mapping been integrated with GIS data and knowledge?
  11. Are sensitive sites prioritized for protection?
  12. Have response times and limitations been set?
  13. Have alternate strategies and response procedures been identified because of increased potential spill volumes?
  14. Is there an agreement over response strategies and priorities between personnel and responders?
  15. Does the planning process incorporate best practices ecological risk assessment principles?
  16. Have response equipment needs been re-evaluated and defined?
  17. Is appropriate external spill response support available and are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
  18. Are staff roles and responsibilities specified and communicated?
  19. Are personnel appropriately trained for allocated roles?
  20. Do plans include specific criteria for provisional tiered responses?
  21. Have the plans be thoroughly exercised with realistic scenarios?
  22. Is the response management team structure clear and able to be communicated?
  23. Is there an internal and external communication method established?
  24. Is exercise feedback incorporated into plan revisions?
  25. Are clear procedures in place to notify, assess, and initiate a response?
  26. Are communications backup systems available and described in the plan?
  27. How is information accessed during a response to determine size, shape, type, location, and movement of the oil?
  28. Are procedures in place for monitoring spill size, shape, type, location, movement, and impact
  29. Are waste management and demobilization processes in place and communicated?
  30. Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?
As oil storage volumes fluctuate, companies must utilize collaborative efforts in developing, evaluating, and exercising oil spill response plans. Worst case discharge collaborative planning among companies, responders, and the community provides opportunities for all entities to develop the teamwork and interpersonal relationships that can result in an effective, functional, and timely oil spill response.

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Response Plans, Oil Spill, Disaster Response

Oil Spill and Contingency Planning in an Industry Downturn

Posted on Thu, Apr 09, 2015

In March 2015, Brent crude oil prices hovered around $50 per barrel, while West Texas Intermediate (WTI) crude fell to nearly $40 per barrel. The drastic price decline continues to pressure oil-related companies to re-evaluate operating expenses, administer headcount reductions, and rationalize budget cuts. The combination of pricing, demand, and production levels has inventory levels at their highest levels since May 1985 (US Energy Information Administration). With infrastructures at capacity and potential budget cuts aimed at stretching operating costs, EHS departments, safety managers, and response experts cannot afford to sacrifice oil spill contingency planning and preparedness elements that address a worst case spill scenario.

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The benefits of oil spill contingency planning, preparedness, and response process optimization far outweigh the risks and costs associated with non-compliance or a worst case discharge. EHS departments must prioritize planning and response exercises, as they are necessary to satisfy applicable regulatory requirements, protect the environment, and ensure the best possible safety scenario for responders and employees.

Responding to a worst case spill is a dynamic scenario with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. Yet, all plans related to oil spills, regardless of the volume, have one common thread: to minimize impact. As profits margins are stressed, companies must ensure that risks and hazards remain mitigated through compliance, preparedness, and effective response planning.

Local, state and federal regulatory agencies often require varied site information depending on particular oil-related operations and locations. This information may be required in the form of a site-specific oil spill contingency plan. Contingency planning looks at all the possibilities of what could go wrong and, “contingent” upon actual events, has the contacts, resource lists, and strategies to assist in the response to the spill. Contingency planning should provide procedural details, or a “game plan” that addresses various spill scenarios and situations.

Despite complexity and varied nature, a well-designed contingency plan should be easy to follow. Facilities must ensure that their spill contingency plan outlines the necessary procedures for before, during, and after an emergency. Although the plans can be vastly different, they typically have four major elements in common:

  1. Hazard identification
  2. Vulnerability analysis
  3. Risk assessment
  4. Response actions

Hazard Identification: Numerous varied criteria, such as location, climate, severe weather potential, operations, logistics, equipment, spill trajectory, or facility dynamics, can create situations that can affect the ability of response personnel to contain and clean up a spill. These hazards should be identified and processes put in place to counteract challenges caused by each specific situation.  It may be possible for certain identified hazards to be mitigated, essentially eliminating the hazard altogether.

Vulnerability Analysis: It is critical to identify and provide detailed information regarding area social, natural, and economic resources that may be compromised or destroyed if a spill were to occur.  This information regarding these non-facility related entities in the path of a spill or response, should guide response personnel to make reasonable, well-informed response actions to protect public health and the environment. Vulnerability analysis information should include the following:

  • List of socio-economically sensitivities such as schools, nursing homes, hospitals, etc. and individual point of contact for each facility
  • Lists of public safety agencies/officials in adjacent and nearby communities
  • Lists of large gathering or recreational areas, such as campgrounds, parks, malls, etc.
  • Calendar lists of special events and point of contact
  • Identification of parts of the environment that are particularly susceptible to oil or water pollution such as water sources, beaches, farms

Risk Assessment: This assessment quantifies the hazards and the vulnerabilities to address the potential impact of a spill on its surroundings. The contingency plan should address best possible spill containment measures, how to prevent certain populations or environments from exposure to oil, and what can be done to repair the damage done by the spill.

Response Actions: Employees and responders should train for and exercise their assigned spill response actions in order to minimize the hazards to human health and the environment. Stakeholders and applicable levels of government and industry should be consulted and incorporated in spill response and contingency planning. Without the full participation of personnel, responders, contractors, and government entities, a plan may lack validity, credibility, and effectiveness.

TRP Corp Emergency Response Planning Exercises

Tags: Tactical Response Planning, Response Plans, Oil Spill, Regulatory Compliance

MITIGATION: The Ever-Present Emergency Management Tool

Posted on Thu, Apr 02, 2015

Effective mitigation can often prevent emergencies or minimize their impacts. Mitigation requires a thorough understanding of the potential risks, procedures, regulatory compliance, lessons learned, and operational goals. It is often difficult to quantify and financially justify preparedness mitigation initiatives, however, taking action in the present can often reduce human, environments, and financial consequences in the future.

It is often impractical for companies to spend relentlessly on emergency management mitigation efforts. Operations must remain profitable and margins maintained for corporate viability. Despite that a disaster can strike at any time, potential human, environmental, and financial impacts are often difficult to predict. For optimal financial benefit, mitigation efforts should meet certain key operational and response objectives. Ideally, mitigation efforts should eliminate or lessen the strategic cost of an incident, and reduce the tactical effort of regulatory compliance. Mitigation efforts should, at a minimum:

  • Reduce the likelihood of incidents
  • Improve the ability to respond to incidents
  • Improve the casualty and harm conditions through faster rescues and accident avoidance
  • Strengthen infrastructure against failure
  • Improve corporate reputation through intent and safety investment
  • Reduce projected downtime
  • Improve asset utilization
  • Solidify supply chain availability

Disaster preparedness mitigation measures should also be integrated into corporate and site-specific response planning and corporate preparedness initiatives.  Incorporating upgraded communication methods, technologies, response procedures, and lessons learned can improve the overall functionality of response plans. Response planning mitigation measures may include, but are not limited to:

  • Automating response planning through tracking, updating, and management
  • Facilitating the ability to update plans across locations, sites, rigs, geographies through updated technology
  • Automating regulatory compliance components and response planning activities
  • Reducing the compliance and safety resource consumption
  • Enabling HSE departments, emergency managers, and compliance specialists to spend less time on administrative duties, maintaining plans, reviewing compliance, and reporting
  • Automating governance and controls
  • Optimizing and coordinating drills, testing, and actual emergency responses

toolboxIdentifying and prioritizing mitigation efforts can be challenging. Below are a series of discussion provoking questions that can assist in mitigation assessments. Although not industry specific, these points may identify which areas of preparedness should be mitigated in order to ensure best emergency management practices are in place (NOTE: These suggested discussion points do not address all mandated planning requirements. Please refer to your operations-specific requirements to ensure regulatory compliance.)

Risk Assessment

  • What are the current high-risk activities at the location?
  • Can high-risk tasks or conditions be mitigated? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Have sensitive areas been identified and potential consequences been assessed?
  • Did risk assessment utilize realistic scenarios to define spill and release volumes and locations?
  • Are employees made aware of hazards associated with specific workplace process, materials, or location(s)?

Compliance

  • What agencies and specific regulations apply to my location(s)?
  • If applicable, have safety data sheets (SDSs) been updated per operations and properties included in the planning process?
  • Have inspections taken place or regulatory audits been performed? If so, have non-compliant issues been mitigated?
  • When will an internal compliance audit(s) be conducted and how will findings be prioritized for mitigation?
  • Is personnel training up-to-date and compliant with site-specific requirements?

Response Elements

  • Are clear procedures in place to notify, assess, and initiate a response?
  • Are individual responders and their contact information verified for accuracy?
  • Can approved stakeholders easily access response plans?
  • Have response times and limitations been identified?
  • Do response elements address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been identified in the plan, and are they accurate?
  • Are communications backup systems available and described in the plan?
  • Are staff roles and responsibilities current, specific, and communicated?
  • Have “best practice” strategies and response procedures been identified and implemented?
  • Are processes and procedures identified in the plan to assess and monitor size, shape, type, location, and movement of a spill or release?
  • If applicable, have tactical response details been included and verified for incidents that expand beyond the confines of the facility?
  • If applicable, do spill trajectory estimates and maps mimic current local observations, potential weather scenarios, and historical tendencies?
  • Have sensitive areas been identified and prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes accurate and communicated?

Documentation

  • Have processes been established for updating planning information?
  • Have updated plot plans and area mapping been integrated with accurate GIS data?
  • Are contracts, memorandums of understanding (MOUs), and other appropriate agreements and documentation in place?
  • Has exercise feedback/lessons learned been incorporated into plan revisions?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible?
  • Are necessary Incident Command (ICS) forms and company paperwork readily available for response documentation?

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Management, Emergency Management Program, Mitigation

OSHA's Safety Data Sheets Regulatory Compliance Deadline: June 1, 2015

Posted on Thu, Mar 26, 2015

As of June 1, 2015, the Hazard Communication Standard (HCS) will require all Safety Data Sheets (SDSs) to be in the standardized format set forth by 29 CFR 1910.1200(g). A SDS, (formerly known as Material Safety Data Sheet or MSDS) was constructed to conform to the Globally Harmonized System, a globally accepted classification of health, physical and environmental hazards. After the deadline of June 1st, OSHA compliance will require that SDSs be in the designated format.

HCS regulatory compliance mandates chemical manufacturers, distributors, or importers of hazardous materials to provide SDSs (formerly known as Material Safety Data Sheets or MSDSs) to downstream users for each chemical hazard. The format includes 16 standardized sections arranged in a strict order. The information contained within the SDS is similar to its MSDS predecessor. However, SDSs will be required to comply with the standardized visual layout, allowing workers who handle hazardous chemicals to have a comprehensive familiarity and understanding of the required data.

The safety compliance SDS format includes section numbers, headings, and associated information under the headings below:

Section 1, Identification includes product identifier; manufacturer or distributor, address, phone number; emergency phone number; recommended use; restrictions on use.

Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.

Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.

Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.

Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.

Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.

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Section 8, Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).

Section 9, Physical and chemical properties lists the chemical's characteristics.

Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.

Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

Section 12, Ecological information* provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment.

Section 13, Disposal considerations* provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS.

Section 14, Transport information* provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea.

Section 15, Regulatory information* identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS. The information may include: 

  • Any national and/or regional regulatory information of the chemical or mixtures (including any OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product Safety Commission regulations)

Section 16, Other information, includes the date of preparation or last revision. This section may also state where the changes have been made to the previous version. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be included here.

Employers must also ensure that SDSs are readily accessible to employees for all hazardous chemicals in their workplace. Although the requirement does not dictate a specified communication method, employees have immediate access to the information without leaving their work area.  In the event of a power outage or other emergency, a backup SDS must be available for rapid access. From an emergency management standpoint, it may be advantageous to house SDSs within a web-based, database driven framework to ensure accessibility from multiple locations in the event a catastrophic event renders paper copies or company servers inaccessible.

*Note: Since other Agencies regulate Sections 12 through 15, OSHA will not be enforcing these sections.

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance, Deadline Approaching

Incident Management and Business Continuity Go Hand-In-Hand

Posted on Thu, Mar 19, 2015

Some of the greatest challenges in incident management stem from the unpredictability of an ongoing situation and concurrent communication shortfalls. The ability to establish a quick and effective response through a real-time, transparent management process improves response time, reduces impacts, and provides the best opportunity for the implementation of a Business Continuity Plan (BCP).

An incident or emergency scenario that activates an Incident Management Plan can also spur the activation of a BCP. Both incident commanders and BCP team leaders need timely, yet accurate information to assess necessary response requirements. When incidental impacts and response scenarios are effectively communicated, the outcome can greatly support both incident management efforts and continuity of operations initiatives.

A BCP that is guided by a functional incident management process can provide the information to enact necessary continuity processes.  In order to be effective to business continuity leaders, Incident Management Systems need to include a means to provide the following:

  • Initial Response Statistics - Employees should be able to obtain essential information in real-time.  This allows responders to provide swift and appropriate resolutions to the current or escalating scenario(s). Having the ability to establish an intuitive, customizable system is a key component of incident management.
  • Reporting - To improve responses to an ongoing process, incident commanders must be able to quantify the response based on accurately reported information. In incident management, this means the process of providing and receiving current, real-time information and customizing an appropriate response. Necessary information that can assist in an effective response includes:
    • Actual response times
    • Initial response actions and resolutions
    • Incident command position roles and responsibilities
    • Incident planning /follow up assignments
    • Action status (Assigned, Delayed, Overdue, Complete)
    • Sustained response actions
    • Demobilization
    • Review proceedings (Examine overall performances and processes.)
  • Feedback - After an incident has been resolved, the company should solicit honest feedback from responders, regulators, and employees. This may highlight areas for improvement in your incident management process.

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When multiple plans are concurrently enacted, communication failures, rumors, and speculation can escalate, affecting the functionality and effectiveness of the response. Real-time system mechanisms with automated dynamic workflows can greatly improve incident response, continuity opportunities, and corporate viability. Incident management information, considering existing incident response capabilities, response measures, and history can assist business continuity leaders in determining the best path towards continuity or restoration. This specific information includes, but is not limited to the following criteria:

  • Incident Timing - If an interrupting incident occurs during high-output timeframes, continuity priorities and process implementation should be amplified in order to limit operational and financial impacts.
  • Likelihood Level - Based on accurate and timely incident impact information, the business continuity team can decipher how likely the incident will affect each critical business unit, suppliers’ availability, or set deliverables.
  • Duration and recovery time - Determine if the incident duration and demobilization efforts will impact and/or impair critical operational processes. Based on this information, processes and alternate facilities may be necessary to account for maximum allowable downtimes. This will allow for recovery time of specific critical processes under existing capabilities and, if possible, potentially altered conditions.
  • Staffing minimums - Identify available staffing levels and whether the number meet minimum requirements to meet typical daily productivity goals, as well as recovery time objectives.
  • Operational Impacts -Determine how the incident affects and will affect operations Functions that may be affected include, but are not limited to:
    • Lost sales and income
    • Negative cash flow resulting from delayed sales or income
    • Increased expenses due to overtime, outsourcing or other operations that increase costs
    • Regulatory fines and legal implications
    • Contractual penalties or loss of contractual bonuses
    • Customer dissatisfaction or withdrawal
    • Delay of business plan execution or strategic initiative

Interoperable communication and coordination among incident commanders and business continuity leaders should be exercised for a swift recovery. If an incident has the potential to impact two or more business processes, it is critical that an effective BCP be enacted. An incident can become a multi-tiered business continuity event that extends beyond the facility borders, affecting personnel, multiple critical business processes, vendors or suppliers, and customers.

Web based response planning - TRP CORP

Tags: Business Continuity, Incident Management

The Basics of Business Continuity Planning

Posted on Thu, Mar 12, 2015

The primary purpose of a Business Continuity Plan (BCP) is to minimize the negative impacts of a business interruption by accelerating the return to “business as usual”.  A BCP should be applied to every business, small or large, to provide a framework to ensure operational resilience in the event of business disruption. Industries including manufacturing, healthcare, education, financial, energy, and retail can benefit from business continuity planning, but each organization must create a detailed and specific plan for each of their locations, business units, or functional groups.

Numerous events, such as this winter’s perpetual snow storms, can cause business disruptions. Business interrupting events typically result in the loss or temporary disruption of key business resources including:

  • Facilities or Workspace
  • Infrastructure or IT Applications/Systems
  • People
  • Supply Chain

In order to protect a company’s viability, site-specific recovery strategies should be developed with the assumption that a disruption will occur during a peak business cycle, when the services or output are at the highest level and most critical point. A Business Impact Analysis (BIA) enables a company to identify and quantify which business unit that, when absent, would impact profitability and threaten its survival. While the size and complexity of essential business elements required for sustainability vary among companies, the ability to quantify and prioritize critical workflow components is a key business continuity element. Some departments to consider when conducting a BIA for peak cycles include, but are not limited to:

  • Finance and Treasury
  • Contracts
  • Supply and Trading
  • Financial Accounting
  • Emergency Response/Crisis Management Team
  • Payroll
  • Benefits
  • Accounts Payable
  • Environmental Health and Safety

Once critical components are identified, managers should review the following business continuity planning elements for each critical business function:

  • Determine what personnel, software, and vendors are required to continue these processes.
  • Identify the duration and point in time when an interruption would impair critical processes and develop recovery time objectives.
  • Estimate the maximum allowable downtime for each specific business function.
  • Identify alternate locations where these processes can be maintained in the event normal facilities are not accessible.
  • Identify how communications will be maintained
  • Provide training for BCP personnel that are assigned to support the continuity of operations.

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A BCP should include site-specific details that can direct process continuation or restoration. The following continuity plan components should be included in a site-specific BCP.

1. Plan distribution list: Names, addresses, and contact information of those that retain secured access to the BCP.

2. Key contacts and notification procedures: Identify all primary and secondary contacts that must be made aware of a business interruption. It is important to routinely verify contact information for accuracy, and train personnel in BCP activation and notification procedures.

3. Key staff roles and responsibilities: Develop position-specific checklists and procedures detailing responsibilities from business continuity implementation through recovery. Task teams should be formed, at a minimum, to cover each critical business process. Business Continuity Team structure, organization charts, and interfaces should be clearly communicated. It may be necessary to provide cross team training, in the event that primary team members are not available.

4. Off-site recovery location(s): Include address, contact information, available on-site equipment, and any necessary external equipment for effective operations.

5. Recovery action plan: Identify/develop incremental processes and procedures necessary to recover each critical business process.   Response checklist timelines may include time increments such as 1st hour, 24-hours, 48 hours, one week, one month, and long-term recovery.

6. Customer data:  Identify communication methods and necessary contact information in order to inform customers of disruptions of deliverables. Effective customer relations and communication may be critical in retaining clients and maintaining positive relationships during a business interruption.

7. Primary suppliers contact list: Identify contact information of supply dependencies and interdependencies. Transportation delays or events at suppliers’ locations could affect delivery times; therefore the plan should address this issue.

8. Alternate suppliers list: Primary supply chain failures can be crippling to key business components. Through the planning process, alternative suppliers should be explored, and contact information and materials should be documented in order to reduce the impact of primary suppliers’ disruption.

9. Documentation and Insurance details: Identify details of insurance coverage and accurate contact information. The burden of proof when making claims typically lies with the policyholder. Accurate and detailed records are imperative. Documentation forms should be made available to all critical business unit leaders for timely documentation.

10. Technology requirements: Identify necessary hardware and software, and the minimum recovery time requirements for each business unit.

11. Backup data details: Business continuity plans should identify details of data backups and recovery methods. If current backup procedures are questionable, mitigation measures should be evaluated prior to a business disrupting event.

12. Equipment requirements: Identify equipment requirements for each business unit, primary and alternate suppliers, and recovery time goals.

13. Review and revise:  On an annual basis or following an incident, incorporate newly identified hazards and vulnerabilities into the business continuity plan. Include necessary equipment used (requiring replacement or replenishment), altered processes, and lessons learned.

Preparedness and Emergency Management - TRP Corp

Tags: Business Continuity key points, Business Continuity, Business Continuity Plan

Common Response Plan Mistakes in Corporate Preparedness Programs

Posted on Thu, Mar 05, 2015

Response planning challenges are often exaggerated by corporate downsizing, reorganizations, mergers, or acquisitions. As companies reorganize and/or grow, response plans can quickly become outdated and non-compliant. Through internal audits, companies can identify regulatory compliance requirements and whether minimum corporate emergency preparedness criteria are met. However, audits also may reveal process or procedural inadequacies, contradictory plan formats, or inaccurate information.

Whether organizational changes are the result of new facilities or acquired through a merger or acquisition, ensuring preparedness, regulatory compliance, and employee safety requires a committed emergency management staff and a fundamental emergency management program with streamlined, coordinated, and exercised response plans. Although there are many complexities and costs associated with regulatory compliance, the regulations exist to protect public interest, the company, and surrounding sensitive environments. If staff, programs, and/or plans are insufficient for an effective response, the status quo of companies and communities may be compromised.

With so many operational components, it is critical that plans be audited to determine potential discrepancies and regulatory deficiencies. Once discrepancies and deficiencies are identified, adjustments can be made for to ensure compliance, efficiency, and effectiveness. Response plan audits often identify the following:

  • Personnel listed in plans are no longer employed with the company
  • Emergency response duties and responsibilities are not assigned to appropriate personnel
  • Inaccurate contact information for company personnel and external resources
  • Lack of detailed oil or hazardous material spill response procedures regarding
  • Lack of specific tank fire pre-plans and foam calculations
  • Training deficiencies
  • Inefficient documentation of training records
  • Inconsistencies with Area Contingency Plans and/or local 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

A dedicated regulatory intelligence team or the EHS manager may be responsible for the daunting task of sifting through the mountains of location-specific regulations, mandates, and guidelines in order to modify determined deficiencies.  In some instances following an external regulatory compliance audit, authorized agencies may demand deficiencies be addressed within a certain time frame. Agencies can impose fines and ultimately shut down operations for missed deadlines or ignored requisitions.

world_wideThose responsible for the emergency management program must remain vigilant to ensure plans are up-to-date and compliant in order to minimize financial penalties. When regulatory fines are assessed, companies can encounter additional collateral damage. Negative media exposure and antagonistic public opinion can quickly escalate when companies mismanage personnel safety or disturb environments that result from regulatory compliance failures.  Ineffectively planning for or responding to an oil spill, fire, or other incidents can lead to a company’s demise. In order to prevent escalating effects, response plan audits and reviews should be scheduled, at a minimum, on an annual basis

While companies may not need to “reinvent the wheel” when it comes to safety and response procedures, facilities need to confirm that best practices apply to their site-specific situation. Each facet of a company’s operations should be broken down to examine specific best practices for a particular action, material, scenario, or site circumstance. For example, safety and response best practices exist in the following areas:

  • Pre-incident planning
  • Training
  • Exercises
  • National Incident Management System
  • Security
  • Fire brigades
  • Rescue
  • Hazardous materials handling/response
  • Fire loss prevention
  • Evacuation

An effective compliance management process that includes regularly scheduled plan audits can result in an efficient and integrated program that optimizes the efforts of all company stakeholders and limits operational downtime. Effective technology can aid in managing response planning administrative duties associated with continually evolving personnel, operations, and regulatory requirements. Multi-facility operations should consider utilizing web-based technology to ensure enterprise-wide compliance on multiple government agency fronts.

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, Response Plans

Disaster Mitigation Measures and Preparedness Elements

Posted on Thu, Feb 26, 2015

Emergency Management should be a continuous cycle of mitigating risk, response planning, training employees, and exercising plans. It is imperative to understand and address plausible scenarios and inherent employee actions, intentions, and perceptions surrounding a potential incident in order to plan effectively. Once every aspect of a potential scenario is defined, a mitigation process should be implemented with the intent to eliminate risk, minimize the potential for escalation, and reduce overall impacts.

As history has proven, not all risks can be averted. Many natural disasters, such as earthquakes, floods, tornadoes, or wildfires, can occur with little or no warning. If your facility experiences a natural disaster, the incident can alter the day-to-day operations for an extended period.  Natural disaster mitigation measures often stem from preparedness and response planning efforts, and site-specific business continuity plans. When mitigation opportunities and preparedness efforts merge, the impacts to employees, operations, and the environment can be minimized even in the case of a natural disaster.

Disasters and emergency incidents can also stem from Internet or power outages, intentional harm, security issues, human error, supply breakdowns, and on-site hazardous materials. Each facility has its own unique associated risks, therefore targeted, site-specific analyses must be conducted. Once every scenario has been identified for probability and likelihood, and dedicated risk mitigation measures and processes have been prioritized and implemented, implications and business disruptions can be minimized.

Companies should evaluate the following risk mitigation measures in order to heighten preparedness levels:

1. Identify potential arrangements and assets that can directly minimize the impact of the associated threat. Evaluate current arrangements and assets to determine if they are sufficient to eliminate incidents or assist in a more timely response.  Examples include: purchasing backup generator, identifying alternate critical suppliers, increasing computer security measures, purchase equipment and/or contract cleanup companies (such as tree, snow, and hazardous material removal), etc.

2. Identify effective facility procedures that may minimize risks. Response evaluations from employees, responders, and industry counterparts can identify “lessons learned”, revealing potential procedural mitigation opportunities. Examples include; routine data backups, shut-off or shut-down procedures, evacuation processes, training specifics, etc.

3. Estimate the cost for implementation of mitigation measures specific to each process and prioritize budgeting, as necessary. A corporate level commitment to preparedness in conjunction with a “lessons learned” mitigation approach can result in improved response capabilities and lessen the impacts of disasters.

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4. Identify and update the recovery point objectives to determine what minimum processes need to be “up and running” to conduct business. This includes a time frame breakdown of specifics that need to be recovered in order to minimize impacts. Examples include:  data backups, employees levels, supply chain requirements, etc.

5. Revise and update response and continuity plans if mitigation measures are fully implemented, tested, and successful.

6. Evaluate and update the “Likelihood Level” based on sound data and adjust mitigation efforts as necessary. Examples include impending hurricane, terrorist threats, computer security updates, and large scale local event.

Determine the duration of the mitigation and evaluate a review or audit calendar. Specific mitigated safety processes and response procedures that are currently effective may need adjustments or updates based on improved technology or lessons learned.

Once mitigation efforts have been optimized for implementation, there may be site-specific elements regarding location, operations, and response efforts that cannot be altered. In this case, specific safety processes and response procedures must be developed for each hazard and associated risks in order to minimize potential impacts.

Mitigating the response planning process should incorporate the following:

  • Form a collaborative team: Engage essential personnel in the planning process to identify and mitigate planning gaps, response capabilities, and necessary internal and external resources for an improved response.
    • A core planning team typically includes an emergency manager or security manager, a hazard mitigation expert, local jurisdictions, and any additional available planning experts.
  • Re-evaluate Hazards and Risks: Perform a vulnerability assessment for the purposes of determining priorities, and developing processes and procedures. Understanding the consequences of a potential incident can help prioritize resources and response efforts. It is helpful to assess local jurisdiction’s planning framework to highlight geographical threats.  Potential facility hazards and risks may include, but are not limited to:
    • Natural Hazards
    • Technological Hazards
    • Chemical Hazards
    • Infrastructure Hazards
    • Human Hazards

For a free Audit Preparedness Guide, click the image below:

Regulatory Compliance with TRP Corp

Tags: Emergency Preparedness, Mitigation

Common Response Planning Mistakes in Industrial Fire Pre-Plans

Posted on Thu, Feb 19, 2015

The US Chemical Safety Board (CSB) continually emphasizes that every industrial facility should have fire emergency plans, or fire pre-plans, to minimize the impacts of a fire. Industrial fire emergencies can create dynamic circumstances resulting in fluctuating and challenging responses. The CSB, an independent federal agency charged with investigating industrial chemical accidents, urges emergency response agencies, companies, and communities to work closely together to prepare for potential tragic chemical accidents.

However, many established fire pre-plans are inadequate for an effective response, out-of-date, or inaccessible to those that need the plans the most. These mistakes may stem from the lack of a coordinated development process, poor plan format, or no change management procedure. Below are expert evaluations of pre-planning mistakes and corrective measures that can enhance the overall functionality of these plans, consequently limiting the impacts of a fire.

1. Lack of a coordinated development process: Response planning coordination between private and public entities improves emergency management capabilities. Partnering with associated response participants will result in a more successful and streamlined implementation of the intended plan. Relationships and coordinated efforts should be reflected when establishing, updating, exercising, and responding to fire emergencies.

Coordinated fire pre-plans can result in an expedient and safer response. A coordinated effort should consist of a combination of agreed elements including:

  • Personnel
  • Procedures
  • Company protocols
  • Best practices
  • Communications systems and methods

Establishing and sharing up-to-date facility information and site specific potential hazards in a coordinated effort prior to a fire emergency can assist responders in:

  • Determining appropriate and proven response methods
  • Acquiring and locating necessary equipment
  • Removing site-specific obstacles
  • Identifying sensitive areas

The faster the first responders can locate, assess, access, and mitigate the emergency, the sooner the incident will be contained and facility operations restored to “business as usual”. Limiting liabilities in a fire emergency by informing first responders of key components is crucial to your company's livelihood.

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2. The fire pre-plan format:  As your organization evolves, grows, and changes over time, personnel, hazards, response equipment, and overall site layout may be altered. Each time a single component of the plan needs to be updated, the entire paper document needs to be redistributed. Site specific information, such as exposures, building hazards, foam calculations, and hydrant locations are plan details that create a thorough fire pre plan, and may need to be updated over time.

These plans should be in “easy-to-read” formats. It is important to remember that responders may have to refer to fire plans at night, in periods of limited light, and in inclement weather. The easier the information is to read, the better it is for all responders. When facilities are large, color-coded plot plans can be utilized for each segment of the facility. Response strategies can be developed for and associated to each area, making it much easier to respond to fires in large complexes.

Despite the response situation or circumstances, fire pre-plans should include, but are not limited to the following: 

  • Building/site layout information
  • Fire suppression information
  • Hazards locations
  • Utility information
  • Exposure information
  • Water supply
  • Evacuation needs
  • Occupancy information
  • Special procedures for handling, storage and control of major fire hazards items
  • Mutual aid resources
  • Strategies

With budgets restraints and increasing workloads, easing plan maintenance issues, improving communication methods, and minimizing preparedness disparities is critical in the emergency management realm. Dismissing the importance of maintaining this crucial response plan with the most up-to-date information is not only putting lives at risk, but could exacerbate the emergency and become a costly loss for a company.

Because of an increasingly technological-driven culture, the concept of utilizing technology for preparedness planning continues to expand. Establishing or converting your paper-based plans into web-based, database driven system allows for simple modifications, streamlined company formats, and easy distribution.

3. Accessibility: Industrial fires can escalate quickly and the potential danger to lives and the environment can exponentially increase. In the event of an emergency, up-to-date paper plans may not be available from other locations.  Although some companies utilize electronic plans housed on an intranet that can be accessed remotely, emergency events often create the possibility that the main data source or server is inaccessible.

When an incident is isolated to a particular location, web-based response plans can enable response measures on a company-wide scale. Web-based plans can also provide hyperlinks, forms libraries, simplified interfaces, and other tools designed to improve functionality for plan users and streamline company response elements.

But with any data system, redundancy and back up efforts are essential.  In the event Internet connectivity is terminated or inaccessible, emergency managers and responders must have alternative means to access plans. Redundant data centers, scheduled downloads, and security measures must be a part of any web-based emergency management program. This allows for multiple options for accessibility, ensuring the responders have the correct information at critical times.

For more information on Fire Pre-Plans, read our expert guide:

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Fire Pre Plans, Fire Preparedness

Enterprise-Wide OPA 90 Plans: Standardize and Comply

Posted on Thu, Feb 12, 2015

Amidst the challenges of sustaining profitable operations, oil and gas companies must ensure that employees and work conditions are compliant with various regulations in order to manage innate risks, operational hazards, and minimize potential detrimental impacts. As a result, regulatory agencies require response plans and response exercises that adequately reflect the current operations and emergency response capabilities.

In the wake of the Exxon Valdez oil spill, emergency preparedness requirements were reassessed and the Oil Pollution Act of 1990 (OPA 90) was created to instill comprehensive prevention, response, liability, and compensation policies for vessel and facilities that could cause oil pollution to U.S. navigable waters. The law requires that regulated facilities and vessels develop and submit oil spill plans for approval. For facilities adjacent or nearby shorelines, OPA 90 requires compliant site-specific Facility Response Plans (FRP).

Yet, because of the rapid decline in the price of oil, emergency managers are, once again, being asked to “do more with less”. Reduced staffing levels and heightened personnel responsibilities due to budget constraints create various enterprise-wide challenges for environment, health and safety professionals. The mandate of managing and maintaining multiple emergency response plans and ensuring regulatory compliance and site specific accuracy can be a continual uphill battle.

Oil spill responses can be challenging dynamic scenarios with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. FRPs must provide procedures to quickly, safely, and effectively respond to these potential spills to prevent further damaging effects. This is challenging for a company that has multiple facilities that fall under the OPA 90 compliance requirements.

oilspill

FRPs require site-specific information and response details including, but not limited to:

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

An enterprise-wide response planning system can remove the uncertainties and challenges associated with managing multiple, regulation-driven response plans. A single web-based system can streamline the update process and simplify plan reviews, ensuring a consistent path toward compliance.  For companies with various facilities, advanced systems offer budget-friendly, advantageous response plan management opportunities, improve the overall planning system framework, and provide greater  accuracy of site-specific emergency response plans.

In addition to simplifying the administrative duties of managing multiple response plans, an enterprise-wide response planning system should:

  • Support the ability to execute company approved response strategies across multiple locations/facilities
  • Easily incorporate company growth and facility acquisitions
  • Enable site-specific details while not compromising company directives
  • Facilitate the ability to update corporate planning elements across many locations,  without compromising site-specific details and response challenges
  • Be easily updated with minimal dedicated staff
  • Become an easily accessible, yet secured, shared tool for internal and external responders
  • Allow for streamlined regulatory compliance audits
  • Automate and optimize response planning, training, and exercise activities
  • Reduce non-compliance issues on a company-wide scale
  • Automate regulatory governance with electronic submissions

An enterprise-wide response planning system enables EHS departments to augment dwindling budgets, spend more time on preparedness planning, and maximize response efforts. The result is a more streamlined company emergency management program that reduces administrative efforts, non-compliance fines, and ineffective responses.

For a free white paper on standardizing response planning, click the image below:

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

Tags: Facility Response Plan, Emergency Preparedness, OPA 90, Oil Spill