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The Corporate Incident Response Process and Action Plan

Posted on Thu, Oct 08, 2015

From the moment an incident is discovered, the response process begins. Effective corporate preparedness campaigns and exercised response plans lay the procedural foundation of information gathering, initial assessment, response coordination, and documentation management. Short-term responses, small in scope and/or duration, can often be coordinated using only ICS Form 201 documentation, the Incident Briefing form. However, longer-term, more complex responses, will likely require use of the entire planning cycle, many of the ICS Forms, and multiple operational periods.

It is critical that companies test small and large scale incident responses to ensure employees are familiar with their roles, responsibilities, and the overall response process. Planning efforts also must identify incident priorities, align resources, and assure proper communications to ensure an effective and timely response. The standard response planning cycle is as follows:

The Response Process 

1. Initial Response Actions, including notifications
2. Activation and staffing the Emergency Response Organization
3. Incident Planning/Documentation; Meeting Cycle includes:

  • Assessment
    • State incident objectives and policy issues.
    • Identify the situation and subsequent critical and sensitive areas, weather/sea forecast, resource status/availability.
  • Planning
    • Identify primary and alternative strategies to meet objectives.
    • Specify tactics for each Division, note limitations.
    • Specify resources needed by Divisions/Groups.
    • Specify operations facilities and reporting locations (plot on map)
    • Develop resources, support, and overhead order(s).
    • Consider support issues and agree on plans: communications, safety, medical, security, etc.
  • Incident Action Plan (IAP)
    • Develop draft IAP
    • Finalize, and approve IAP for next operational period.
  • Operational briefings

4. Demobilization/Post Incident Review

In the event of a prolonged and a potentially multi-disciplinary response, Incident Commanders can utilize an IAP to develop updated and pertinent objectives, priorities, and strategies for each operational period. IAPs contain general tactics to achieve goals and objectives within the overall strategy, while providing important documented information on event and response parameters. Because incidents evolve, IAPs must be revised on a regular basis (at least once per operational period)

The following should be considered in an Incident Action Plan:

Operational Period Goals and Objectives:

  • Must address any open agenda items from previous or initial operational period.
  • Must be attainable given the people, equipment, and supplies available during that operations shift.
  • Must be broad and flexible enough for the Incident Management Team to adapt to an evolving situation.

Response Strategy:

  • Develop primary and alternative strategies, specific response methods, and pertinent procedures to achieve the goals and objectives.
  • Establish priorities of tactics in order to accomplish goals and objectives.
  • Prepare an ICS 215 to identify required resources.
  • Identify primary roles, responsibilities and assign specific tasks


  • Critical situational updates
  • Detail resource status updates
  • Equipment status updates

Depending on the specifics of the incident, the following ICS forms may be used to document operational details, objectives, priorities, or strategies for each operational period.

INCIDENT ACTION PLAN (IAP) COVER SHEET: Provides initial response information, signature approval, and table of contents of the IAP.
INCIDENT OBJECTIVES: ICS 202: Provides weather and tide information, as well as basic incident strategy, control objectives, and safety considerations.
ORGANIZATION ASSIGNMENT LIST: ICS 203: Provides information on the units activated, and the names of personnel staffing each position/unit.
ASSIGNMENT LIST: ICS 204: Identifies Division and Group assignments.
COMMUNICATIONS PLAN: ICS 205: Provides radio frequency assignments..
MEDICAL PLAN: ICS 206Provides details on how medical services will be provided, including medical aid stations, transportation services, hospitals, and medical emergency procedures.
INCIDENT STATUS SUMMARY - ICS 209: Provides response status information. It is typically not included in within the IAP.

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Incident Action Plan, Response Plans

El Nino, Extreme Weather, and Corporate Emergency Preparedness

Posted on Thu, Oct 01, 2015

Recently, Los Angeles County Mayor Michael D. Antonovich requested county departments to report their state of preparedness, response planning, and recovery capabilities for the potential impacts of El Niño. In early September, NOAA released its monthly El Niño forecast, which indicated that this year’s El Niño could be one of the top three on record. “The news is that we now have a strong El Niño with a 95 percent chance El Niño will last through the winter,” said Mike Halpert, deputy director of NOAA’s Climate Prediction Center in College Park, Maryland.

Based on historical records, a strong El Niño has different impacts on various regions. Certain regions, such as southern California, typically receive excess rain and storms, while others will see less. While the forecast of more rain is good for the drought-ridden counties, any excess weather phenomenon can create natural disasters. Companies must ensure emergency preparedness and response measures are up-to-date and effective.

According to NOAA, El Niño typically present the following scenarios:

  • Wetter weather to southern California
  • Cooler and wetter weather to the southern United States
  • Warmer weather to western Canada and southern Alaska
  • Drier weather to the Pacific Northwest
  • Cooler weather to northern Canada

The Los Angeles County preparedness report will include the status of capacity at the County's flood-control facilities and a plan for maximizing storm water capture and retention. “With a forecasted El Niño season approaching, we will be directing county departments to take every precaution necessary to protect life and property,” Antonovich said.

Countries around the globe are mimicking L.A. County’s lead in preparing for potential El Niño impacts. Individual companies should also follow suit. While the severity of impacts will vary depending on location, emergency management and response protocols should be an ongoing effort.

Severe weather situations, such as those produced by an El Niño phenomenon, can result in the loss or temporary disruption of one or more of the following necessary key business resources:

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

Severe weather emergency response plans

Weather-specific planning should be implemented for historically high-risk areas. However, the following general severe weather preparedness measures should be included in an overall emergency management program to prepare or respond to affected operations.

  • Establish, verify, and exercise communication plans
  • Verify contact details and identify communication procedures with employees, emergency personnel, critical business unit leaders, and contractors
  • Establish widely-accessible, yet secure response plans
  • Verify availability and viability of communication equipment
  • Verify Stormwater drainage compliance, if applicable
  • Monitor and determine applicable response procedures based on radio, television, and/or weather reports
  • Establish, verify, and exercise resource management and supply chain measures
  • Coordinate exercise activities with local and state response agencies
  • Evaluate equipment needs and verify availability
  • Identify alternate resources and ensure availability for incidents
  • Pre-select alternate delivery of critical needs in the event primary suppliers are not able to provide required services such as:
    • Electrical power
    • Water
    • Fuel
    • Telecommunications
    • Transportation
    • Staffing
    • Waste Management
    • Operations-specific equipment
  • Conduct site-specific awareness training, including facility evacuation routes and shelter-in-place procedures
  • Establish, verify, and exercise response personnel’s roles and responsibilities
  • Identify employees that should remain on-site (if deemed safe), and their responsibilities
  • Identify necessary minimum staffing levels and assignments necessary for recovery operations
  • Ensure staff, contractors, and suppliers understand their responsibilities and recovery time objectives
  • Train employees to recognize, report, and avoid hazardous chemicals impacted by severe weather
  • Ensure that key safety and maintenance personnel are thoroughly familiar with all infrastructure systems, such as alarms, utility shutoffs, elevators, etc.

Unfortunately, some natural disasters provide little or no warning. In these instances, prior planning and training is of the utmost importance. While often suppressed in favor of short-term profits, budgets for pertinent emergency management initiatives should be prioritized for long-term corporate sustainability. Companies that prioritize preparedness and planning, especially in severe weather prone areas, are better equipped to minimize impacts on personnel, infrastructure, and the environment.

Preparedness and Emergency Management - TRP Corp












Tags: Extreme Weather

Deficient Stormwater Pollution Prevention Plan Results in Fines

Posted on Thu, Sep 24, 2015

Whether organizational changes are the result of the construction of a new industrial facility or the acquisition of additional sites, ensuring preparedness, regulatory compliance, and employee safety requires a fundamental emergency management program with streamlined, compliant, coordinated, and exercised response plans.

An Iowa fertilizer company recently settled an $80,689 civil penalty for violation of the Clean Water Act during the construction of a new fertilizer plant. The Clean Water Act requires construction sites, such as the fertilizer plant, to establish controls to limit pollution from being discharged via stormwater into nearby waterways. The Environmental Protection Agency (EPA) Region 7 inspector who evaluated to plant identified violations that resulted in sediment-laden stormwater leaving the site and entering a tributary of the Mississippi River. Specific violations included:

  • Failure to update or amend the Stormwater Pollution Prevention Plan (SWPPP)
  • Failure to perform adequate stormwater self-inspections

The EPA issues “General Permits” for stormwater discharges associated with industrial activity, under the National Pollutant Discharge Elimination System (NPDES) program (as defined in 40 CFR 122.21 and 40 CFR 122.26). Runoff that contacts industrial materials can transport pollutants into nearby water sources. As a result, the development and implementation of a SWPPP is required in order to obtain a general permit.


The purpose of a SWPPP is to identify potential stormwater pollution sources and reduce the potential for pollutants reaching nearby waterways. Establishing procedures and controls is necessary to accomplish the following SWPPP objectives:

  • Identify pollutants that may come in contact with stormwater.
  • Establish measures to prevent pollutants from coming in contact with stormwater.
  • Establish controls to reduce or eliminate the potential for release of contaminated storm water to the environment.

Annual site evaluations are also required by the general permit and must be conducted by a qualified or SWPPP trained personnel. Completed site compliance evaluation checklists must be retained for one year after expiration of the General Permit. Evaluations must include the following:

  1. Inspect storm water drainage areas for evidence of pollutants entering the drainage system.
  2. Evaluate the effectiveness of Best Management Practices (i.e. good housekeeping measures, preventive maintenance, spill prevention and response, etc.).
  3. Observe structural measures, sediment controls, and other stormwater best management practices to ensure proper operation.
  4. Revise the plan as necessary within two weeks of the inspection, and implement any necessary changes within 12 weeks of the inspection.
  5. Prepare a report summarizing inspection results and actions items, identifying the date of inspection and personnel who conducted the inspection.
  6. Sign the report and keep it with the plan.
  7. If the annual review does not identify any action items, it will certify that the facility is in compliance with the Permit.

Costly non-compliance fines, such as the $80,689 fine experienced by the fertilizer company, continually result from the lack of implemented, thorough, or effective regulatory compliance programs. An SWPPP and required site evaluations should be incorporated, as necessary, into a company’s enterprise-wide emergency management program. Companies must prioritize emergency management programs and regulatory components to ensure company preservation, operational sustainability, and financial optimization.

By systematically aligning emergency management programs and associated plans with corresponding regulations, companies can identify and amend deficiencies that may result in fines and potential government mandated operation shutdowns. An effective compliance management process that includes regularly scheduled plan audits can result in an efficient, integrated and optimized program. Companies that operate many facilities should consider utilizing web-based technology and a regulatory compliance tracking module to ensure enterprise-wide compliance on multiple government agency fronts.

Regulatory Compliance with TRP Corp


Campus Safety Must Include Real-Time Incident Management System

Posted on Thu, Sep 17, 2015

The process of developing a campus incident management plan can be overwhelming for administrations. However, the increase in severe weather events highlight the urgency for swift, effective, and systematic, real-time response plans that can be utilized to protect campuses, students, and staff.

Real-time incident management is becoming more of an expected standard in today’s highly technical, social-streaming world. Current societal norms among college aged students dictate the necessity for immediate access to crucial and timely information, especially during an incident response.
A real-time incident management system allows for real-time transmission of incident details, including location, severity, impact, and status. Because of the instantaneous advantage, decisions and coordinated efforts can be tailored to a campus safety event as it evolves. A real-time incident management system can:

  • Reduce exponential impact of incidents through timely response
  • Increase effectiveness of response
  • Track status of the incident and all aspects of the response, based on each organization/departments assignment(s) and operational levels
  • Clarify necessary deployment of resources in order to prevent duplication of efforts
  • Provide a means to aggregate data into a format that enables real-time analysis and decision making to ensure the most efficient and effective emergency response
  • Provide an instantaneous method of emergency situational awareness

However, response actions must not fall victim to exaggerated miscalculations, rumors, and inaccuracies. The Incident Commander must ensure rapid responses and decisive actions are relevant and best suited for the site-specific scenario. Responders must understand applicable emergency procedures, status updates that need to be communicated, and time frame for documenting communications. An incident should be managed through clearly identified and communicated objectives. These objectives should include:

  • Establishing specific incident objectives
  • Developing strategies based on incident objectives
  • Developing and issuing assignments, plans, procedures, and protocols.
  • Establishing specific, measurable tactics or tasks for various incident management functional activities, and directing efforts to accomplish them in support of defined strategies.
  • Documenting results to measure performance and facilitate corrective actions

Just as timely communication methodology is important, commonly understood terminology is essential. If an incident requires a multi-agency response, the incident should dictate simple and parallel language. Rapidly communicating through unfamiliar radio codes, agency specific codes, perplexing acronyms, unanticipated text messages, or specialized jargon will disconnect and confuse responders, and/or stakeholders, possibly prolonging a response.


In order for a real-time incident management system to be effective, specific situational preparedness communication initiatives should be implemented.

  • Establish a central conference call phone line. This enables the campus incident management team to communicate collectively during a crisis.
  • Develop contact lists. Ensure that the list includes contact information for key stakeholders, with multiple points of contacts, including work phone, cell phone, home phone, and e-mail. Update the list on a semi-annual basis.
  • Acquire a mass notification system to communicate with students, staff, and parents. During a crisis, regularly update information through this system. System can consist of phone calls and/or text messages.
  • Conduct semi-annual mass notification tests to ensure accurate contact information.
  • Share plan with key staff, local law enforcement, and local emergency management agencies. A web-based incident management system should enable secured access.
  • Develop Incident Management Chain of Command so that all decision-makers can begin communicating with one another as soon as a crisis begins.
  • Always have amateur radio units in your Emergency Operations Center. Amateur radios may be outdated, but they are also the last type of communication to fail.
  • After an incident, remember to debrief and identify lessons learned in the incident management plan.
  • Revise and exercise the adjusted plan. Just because the crisis is over does not mean the incident management process has ended.

Maintaining accurate and up-to-date picture of resource utilization is a critical component of a real-time incident management system. Each incident management status update should identify the following in order to clearly communicate to those in the Incident Command System:

  • Time of update (timestamp)
  • Incident or event name
  • Elapsed time of incident from initiation
  • Name/position of responder making status updates
  • Current phase and/or specific status update
  • Tasks assigned, both internally and externally, and resources used or required
  • Emergency Operations Center location and contact information

Preparedness and Emergency Management - TRP Corp

Tips for Merging Response Plan Templates and ICS

Posted on Thu, Sep 10, 2015

Response planning is a multi-faceted entity, composed of critical information, procedural comprehension, and response process awareness. Two contributors to effective preparedness comes from the site-specific information within the plans and a standardized response management process by which procedures are carried out. The two concepts, site-specific and standardization, may appear to contradict each other. However when merged properly, companies can strengthen preparedness initiatives and enable a flexible, effective, efficient, and all-hazards incident management response.

By integrating up-to-date, site-specific response plans, company EHS protocols, and Incident Command System (ICS) components, response operations can be streamlined and coherent without being hindered by jurisdictional boundaries. Utilizing ICS in conjunction with site-specific plans can also consolidate an effective response that includes multiple combinations of facilities, equipment, personnel, procedures, and communication methods.

However, when companies implement or utilize a basic template approach without consideration of site-specific details, the result is often an incomplete, ineffective, and non-regulatory compliant plan. In addition, implementing an incident command approach without site-specific information often results in inadequate and prolonged responses.

By utilizing a template as an outline, companies can begin the process of creating response plans. Companies may consider web-based technology to streamline template formats across an enterprise. A generic plan template may not address every regulatory and/or site specification, so it is essential to evaluate site-specific variables and applicable regulatory requirements. If templates are tied to a web-based database, site-specific information can often be cross references with regulatory requirements. As facilities are added or renovated, operations are revised, or employees revolve, each web-based plan can be conveniently accessed and updated for accuracy and compliance.

Below are twelve basic template topics that should be evaluated for site specific applicability and implementation.

  1. Laws and regulating authorities
  2. Hazard identification and risk assessment
  3. Hazard mitigation procedures
  4. Resource management
  5. Response direction, control, and coordination
  6. Notifications and warning systems
  7. Operations and safety procedures
  8. Logistics and facilities infrastructure specifics
  9. Training
  10. Exercises, evaluations, and corrective actions
  11. Crisis communications
  12. Finance and administrative duties


Once site specifications and regulatory requirements are identified, plans should be formatted within a common and unified incident planning organizational structure. The structure is based on a set of essential features that apply to the management of any incident or all-hazards events. Features included in ICS are:

  1. Common terminology - use of similar terms and definitions for resource descriptions, organizational functions, and incident facilities across disciplines
  2. Modular organization - response resources are organized according to their responsibilities. Assets within each functional unit may be expanded or contracted based on the requirements of the event.
  3. Management by objectives - specific, measurable objectives for various incident management functional activities and direct efforts to attain them. Planning should allow for a timely response, documentation of the results, and a way to facilitate corrective actions.
  4. Incident action planning - Incident Action Plans (IAPs) guide response activities, and provide a concise means of capturing and communicating a company’s incident priorities, objectives, strategies, protocol, and tactics in the contexts of both operational and support activities.
  5. Manageable span of control - response organization is structured so that each supervisory level oversees an appropriate number of assets (varies based on size and complexity of the event) so it can maintain effective supervision.
  6. Pre-designated incident facilities - assignment of locations where expected incident-related functions will occur.
  7. Comprehensive resource management - systems in place to describe, maintain, identify, request, and track resources.
  8. Integrated communications - ability to send and receive information within an organization, as well as externally to other disciplines.
  9. Consolidated action plans - a single, formal documentation of incident goals, objectives, and strategies defined by unified incident command.
  10. Establishment and transfer of command - Clearly identify and establish the command function from the beginning of incident operations. If command is transferred during an incident response, a comprehensive briefing should capture essential information for continuing safe and effective operations.
  11. Chain of command and unity of command - Identify clear responsible parties and reporting relationships
  12. Unified command structure - multiple disciplines work through their designated managers to establish common objectives and strategies to prevent conflict or duplication of effort.
  13. Accountability - Develop process and procedures to ensure resource accountability including: check-in/check-out, Incident Action Planning, unity of command, personal responsibility, span of control, and resource tracking.
  14. Dispatch/deployment - Limit overloading response resources by enforcing a “response only when requested or dispatched” process in established resource management systems.
  15. Information and intelligence management - The incident management organization must establish a process for gathering, analyzing, assessing, sharing, and managing incident-related information and intelligence.

Once the initial response plan is completed, plan audits, exercises, expert assistance, and/or consultation services may be required to confirm plan compliance and effectiveness.

Preparedness and Emergency Management - TRP Corp

Tags: Response Plans, Incident Management, ICS, Emergency Response Planning

The Necessary Details for Pipeline Tactical Response Planning

Posted on Thu, Sep 03, 2015

Pipelines play a key role in the sustainability of our economy. Pipelines deliver millions of gallons of crude oil and petroleum products across every state so that communities can commute and travel, maintain homes and businesses, utilize modern communications systems, and manufacture thousands of products that are used in daily life.

In 2013, 192,396 miles of pipelines transported nearly 15 billion barrels of crude oil and petroleum products. Controversies develop because these vast pipelines often share common acreage with waterways, residential neighborhoods, businesses, schools, and municipalities. Despite strict regulations, pipeline incidents do occur. Because these common geographic boundaries exist, it is imperative that tactical spill response plans contain site specific details that are unique to the location and landscape.

Pipelines present a distinct risk since it is not practical for them to utilize secondary containment. When a spill occurs, impacts can be costly to the environment, surrounding communities, and the pipeline company. If a worst-case discharge were to occur, the impacts can be devastating on multiple fronts. However, the faster the spill can be contained, the less impacts it creates.

Spill prevention should be the primary objective. However, by creating location-specific tactical response plans, pipeline companies and operators can identify and compensate for key geographical challenges that may delay responding to and managing a pipeline emergency. The planning process should involve a detailed site examination and anticipated response analysis, as well as an understanding of the characteristics of the pipeline contents.

The primary objectives of tactical 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
  • Minimize impact zones


Tactical spill plans should include location-specific details that include, but are not limited to:

  1. Photographs of response locations
  2. Maps
  3. Latitude and Longitude
  4. Property owner information
  5. Driving directions to the site from main roads
  6. Description of potential staging area(s)
  7. Specific response tactics for the site location
  8. Description of site and applicable waterways
  9. Site access specifications
  10. Security requirements
  11. Waterway flow rates
  12. Any critical response information that may be informative to responders
  13. Recommended equipment and personnel to implement response strategy
  14. Sensitive environments

Pipeline spills within waterways increase the complexity of a response. They require a higher level of coordination and communication in effort to minimize impending impacts. As a result, companies must maintain optimal pipeline spill response standards to address challenges. Those challenges include, but are not limited to:

  • Response time must be minimal due to spill flow rate and travel distances
  • Potential substantial equipment deployment
  • Waterway access points
  • Coordination and cooperation efforts with private landowners
  • May require extensive geographic surveys
  • Associated increased costs of deployment
  • Consequential costs associated with long-term cleanup activities 
  • Extensive damage to marine and wildlife habitats, fishing, and/or tourism industries
  • Potential lawsuits

Analyzing possible spill trajectories through topographical features, wind speeds, and water flow rates allows planners to identify which areas are most likely to be impacted by a spill. Once these resources have been identified, proper response techniques and procedures specific to the sensitive areas must be incorporated into the response plan. Types of sensitive areas to evaluate during the planning phase include, but are not limited to:

Ecological: Examples of sensitive species include shore birds and other water fowl, marine life, commercially important wildlife, and species with limited distribution or populations. Sensitive habitats range from protected bays with marshes and tidal flats to open coast areas used as marine mammal or bird breeding sites.

Cultural: Areas of direct importance to humans including, but not limited to native lands, historical landmarks, waterfront parks, and recreational areas.

Economical: Populated areas that are highly valued because of their ability to generate income. Areas include tourist sites, real estate developments, urban developments, marinas, parks, and other locations.

Specific sensitive resources: Specific resources that are only available at that particular location, such as specialized suppliers, water sources, transportation systems, food sources.


Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

Tags: Tactical Response Planning, Pipeline, Oil Spill

FRP Compliance for Crude Oil Storage Facilities

Posted on Thu, Aug 27, 2015

According to an August 11th report by the U.S. Energy Information Administration, crude oil storage fell slightly from 1,150.4 million barrels on July 31, 2015 to 1,148.7 million barrels on August 7, 2015. Although crude levels continue to vary, facilities that are bound by the EPA Facility Response Plan (FRP) requirement must ensure compliance. This is especially true during mergers, acquisitions, and when new storage facilities come online. In response to the potential growth opportunities, numerous U.S. companies are expanding storage capabilities.

  • Magellan Midstream Partners and LBC Tank Terminals have a $95 million crude oil storage and transportation project along Houston’s Gulf Coast. The two companies said they will build about 700,000 barrels of new crude oil storage and distribution infrastructure near Seabrook, Texas, about 30 miles southeast of Houston. The new storage will be connected into the area’s existing oil transportation infrastructure by a planned 18-inch diameter pipeline.
  • The Louisiana Offshore Oil Port is adding three new above-ground oil tanks and 1.1 million barrels of storage capacity to its Clovelly Hub, one of the nation's largest oil trading and distribution centers. It is expected to be completed by late summer 2016.
  • Florida Fuel Connection is investing $75 million to build a petroleum terminal and rail transportation facility near the Mississippi River.


Because a single oil spill can have a significant or catastrophic impact, it is imperative for emergency managers to evaluate response processes for best practices and maintain the most current FRP possible. Storage facilities that meet EPA capacity thresholds and could reasonably cause "substantial harm" to the environment by discharging oil into or on navigable waters, must prepare and submit FRPs. Facilities that could cause "significant and substantial harm" are required to have their plans approved by an EPA Regional Administrator (RA).

Substantial Harm
According to the FRP rule, a facility may pose "substantial harm" if:

  1. The site has a total oil storage capacity greater than or equal to 42,000 gallons and it transfers oil over water to/from vessels; or
  2. The site has a total oil storage capacity greater than or equal to 1 million gallons and meets one of the following conditions:
  • Does not have sufficient secondary containment for each aboveground storage area.
  • Is located at a distance such that a discharge from the facility could cause "injury" to fish, wildlife, and sensitive environments.
  • Is located at a distance such that a discharge from the facility would shut down a public drinking water intake.
  • Has had a reportable discharge greater than or equal to 10,000 gallons within the past five years.

If the facility meets the criteria, an FRP is required to be prepared and submitted to the regional EPA office. Once the FRP is submitted to the EPA, the regional administrator (RA) will review and determine if the facility should be classified as a significant and substantial harm facility. If the regional administrator determines that the facility could cause significant and substantial harm, the FRP requires approval by the RA.

Significant and Substantial Harm
An RA determines if a facility could cause significant and substantial harm to the environment by discharging oil into or on the navigable waters and adjoining shorelines. This is determined by factors similar to the substantial harm criteria, as well as:

  • The age of tanks;
  • Type of transfer operations;
  • Oil storage capacity;
  • Lack of secondary containment;
  • Proximity to fish, wildlife, and sensitive environments or drinking-water intakes;
  • Spill history and frequency of past discharges; or
  • Other information, including local impacts on public health.

The landscape of growth opportunities may be changing as the Department of Commerce recently announced a partial lift to the 1975 Energy Policy and Conservation Act ban allowing U.S. companies to export domestically produced crude oil to Mexico. However, despite the change or volatility of the oil industry, companies must ensure regulatory compliance remains across their enterprise.

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

Tags: Facility Response Plan, Oil Spill

Improvised Planning Is Costly: 7 Regulatory Compliance Tracking Factors

Posted on Thu, Aug 20, 2015

"It's not what happens to you, but how you react to it that matters." - Epictetus

Despite best mitigation efforts, emergencies and disasters occur. Although emergency managers can relate to Epictetus’s antidote, it has been proven by the abundance of regulatory fines and fees that responses should not be improvised. Numerous government agencies require that responses be planned for, exercised, and compliant across multiple fronts.

While organizations may see compliance efforts as challenging, the purpose of regulations is to shape practices to limit harm and protect communities and the surrounding environment. However, every month, companies across the nation receive regulatory enforcement mandates.

Regulatory non-compliance is expensive, time consuming, and potentially dangerous to company employees and the surrounding communities. For example, a Seattle area marine terminal that transfers large quantities of ethanol fuel and grain from rail cars to tanker trucks was fined more than $420,000 by Washington’s Department of Labor and Industries for numerous non-compliance issues. Additionally, the agency placed an immediate order to restrain the company’s ethanol transfer operation because of inadequate emergency response planning. Compliance costs are typically lower than the expenditures associated with non-compliance fines, litigation, reputational risk, and government mandated shutdown of operations.

Many industrial facilities must comply with multiple regulations sanctioned by various government agencies. For example, one specific industrial facility in Louisiana has to meet as many as 700 individual requirements. In order to ensure optimal compliance capabilities, companies should have an effective compliance management process in place that can enhance efforts, and limit the potential for fines and operational downtime.

In recent years, advanced technology has allowed an increasing number of companies to automate emergency preparedness, response processes, as well as regulatory compliance. One of the most important aspects of maintaining compliance is ensuring that required response plan and associated revisions are submitted to the proper regulatory agencies in a timely manner. The various agencies have different submission requirements regarding initial and plan revision compliance.


A company must associate each regulatory requirement with applicable mandatory submission requirements and tasks for each facility. From a corporate standpoint, incorporating a regulatory requirements tracking system can ease the complicated exponential challenges associated with managing multiple regulatory requirements for numerous locations. A regulatory compliance tracking system can eliminate redundancies that typically occur across converging compliance specifications
A methodological tracking system should itemize applicable federal, state, and local regulations, and include categorical information that satisfies that regulation. A tracking system should, at a minimum, contain the following components:

  1. Operational categories: Categories can range from air quality and hazardous materials, to construction safety and general safety and health. Depending on the detail required by the regulations, further breakouts by subcategories may also be required.
  2. Applicable Regulation Level: Regulations should be further broken down to Federal, state or local regulation categories.
  3. Time/Date Stamping: The time and date that each regulation was last updated.
  4. Compliance Feedback: Applicable notes regarding compliance or non-compliance.
  5. Industry Standard: Apply best practices related to compliance with specific regulatory requirements, when practical to do so.
  6. Facility Compliance responsibility: Identify contact assigned to maintain compliance for each regulatory requirement.
  7. Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and person(s) assigned. Reports should have filters to customize queries as required by the users.
The results of an effective compliance tracking system is an efficient and integrated program that optimizes the efforts of all stakeholders and allows for optimum compliance.

Tags: Response Plans, Regulatory Compliance, Facility Management

EPA Fines Multiple Companies for SPCC Plan Violations

Posted on Thu, Aug 13, 2015

Multiple California companies are in non-compliance with the U.S. Environmental Protection Agency’s Spill Prevention, Control, and Countermeasure (SPCC) regulation. The agency recently announced a series of financial penalties totaling more than $140,000 from both large and small facilities.

The SPCC regulation was created under the Clean Water Act to prevent oil from reaching navigable waters and adjoining shorelines, and to contain and respond to discharges of oil. It requires onshore oil storage facilities with identified capacities to develop and implement SPCC plans, identifying established procedures, methods, and equipment requirements to prevent and effectively respond to spills.

Under EPA’s Clean Water Act, facilities with aboveground storage tank capacities exceeding 1,320 gallons or underground tanks with capacities above 42,000 gallons, are required to comply with SPCC regulations.

“All companies who store oil must comply with federal standards. Facilities are required to prevent spills and be prepared to respond to a worst case oil discharge emergency," said Jared Blumenfeld, EPA’s Regional Administrator for the Pacific Southwest. “Preventing spills and protecting our waterways from oil spills is essential.”

True_cost_of_incidentsWhile it is not possible for EPA to identify and inspect every SPCC facility, owners and operators need to be proactive in developing and maintaining accurate plans. Despite inspection probabilities, companies must prioritize regulatory compliance in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations. Recent California SPCC violations include:

  • A waste oil recycler facility in Newark, CA was ordered to pay a $90,000 penalty for failing to provide secondary containment around an oil storage area; failing to secure and control access to oil handling, processing and storage areas; failing to use safe containers and good engineering practices, including liquid level alarms to avoid discharges; and failing to develop a complete Facility Response Plan.
  • A vegetable oil terminal operator and packaging facility in Fullerton, CA, was fined $45,000 by failing to update and recertify its spill prevention plan; failing to provide adequate oil containment and drainage controls; failing to ensure that the secondary containment walls of a tank farm could contain spilled oil; and failing to remove accumulations of oil outside tanks and piping, transfer areas and process area collection trenches.
  • A building materials company in Pittsburg, CA was fined $2,775 for failure to provide a proper spill prevention plan, implement tank inspection and integrity testing programs, and provide documentation of employee training.
  • A grease service and disposal service facility in Riverside, CA was fined $2,400 for failure to provide a proper SPCC plan, for storing oil in improper storage containers, and for failing to implement a tank integrity testing program to prevent releases.
  • A food products facility in La Mirada, Calif. was fined $2,250 for failure to provide a proper SPCC plan and have adequate secondary containment for vegetable oil storage tanks.
  • A grease service and disposal facility in Riverside, CA was fined $1,900 for failing to provide a proper SPCC plan, and complete inspection records, The facility also lacked an adequate tank integrity testing program and proper oil drum secondary containment. 

Managing SPCC plans and associated compliance can be achieved through a cohesive, yet site-specific, standardization of best practices. The costs associated with effective emergency management, planning efforts, and overall spill prevention are often much less than the costs associated with fines, spill clean-up, and other civil liabilities. By utilizing available technology, companies can enhance accessibility, portability, and redundancy, and potentially ease communication barriers with responders and regulatory audits.


Tags: SPCC, EPA, Regulatory Compliance

Why Real-Time Incident Management Systems are Now EXPECTED!

Posted on Thu, Aug 06, 2015

Text messages, Facetime, Skype, live-streaming, and email are just a few of the communications technologies that offer current Environment, Health, and Safety (EHS) professionals and responders a unique advantage over their counterparts from years past. Because of the commonality of instantaneous access to communication and information, real-time technology should be incorporated into corporate Incident Management Systems (IMS). From the moment an incident is discovered, the response process of information gathering, assessments, response coordination, and documentation should not be halted by the communication barriers of the past.

The intent of an Incident Management Plan, which should be based on the Incident Command System (ICS), is to define, document, and provide tactical intelligence to those managing and responding to incidents. These plans should guide management, supervisors, employees and contract personnel as to their roles and necessary actions based on the current environment at the incident site. Timely, clear, and concise communication is pivotal. As a result, Incident Management Plans should incorporate:

  • Internal and external communication processes and procedures
  • Accurate contact information, highlighting the preferred method of communication
  • Methodology and protocols for two-way communication with all parties

A two-way information flow breakdown during the chaos of an incident commonly results in a diminished ability to quickly restore the site to “business as usual”. The IMS is the response communication tool that allows users to provide and receive current information enabling those with assigned response roles to carry out swift and appropriate resolutions. Compromised incident response communication often results in jeopardized safety, greater impacts, questionable company reputation, escalated costs, and diminished profits.

Incident Management Systems can be designed to expeditiously facilitate emergency management and coordinate responses through the use of interactive database-driven interfaces and real-time situational displays. Systems with 24/7 web-based access to the incident site information are extremely beneficial to decision makers. With a real-time system in play, emergency managers, on-site responders, as well as approved stakeholders at any location, are more likely to stage an effective and timely response. Providing an instantaneous method of situational awareness provides a means to:

  1. Monitor site response status/scenario
  2. Prioritize the health and safety of staff members and responders based on current information
  3. Aggregate data into a format that enables real-time analysis and decision making
  4. Determine the status and effectiveness of response actions
  5. Modify response strategies, tactics, and objectives based on the information received
  6. Determine the deployment of resources in order to prevent duplication of efforts
  7. Integrate incident response plan contacts and assigned tasks, as necessary
  8. Minimize miscommunications that can delay time sensitive responses
  9. Document stakeholder and agency directives to be used as a reference or learning tool

Despite a real-time communication, best practice processes, and state-of-the-art systems, the incident response will not be successful without a trained response team. Best practices have proven that individuals who demonstrate a clear understanding of their response role and responsibilities in exercised scenarios are better prepared to implement a precise, streamlined, and effective response.

Individual incident management responsibilities vary by role and the site-specific scenario. However, the lack of procedural and incident status communication can lead to the mishandling and mismanagement of a response. Real-time communication can benefit general supervisory responsibilities which may include, but are not limited to the following:

  • Initial response actions
  • If the situation demands, limit or restrict access to the incident scene and surrounding area
  • Determine or carry out directives regarding required personal protective equipment
  • Request medical assistance, if necessary
  • Identify representatives from each agency for associated responsibility, including communication links and location
  • Verify any substance released and obtain Safety Data Sheets, as necessary
  • If properly trained, identify and isolate source to minimize product loss and potential harm
  • Maintain records and individual logs, as necessary
  • Coordinate required response actions with Incident Commander and local responders
  • Communicate response actions to assigned specialized team members
  • Document all complaints and suspicious occurrences

Preparedness and Emergency Management - TRP Corp

Tags: Incident Management, Communication Plan