Your Solution for SMART Response Plans

Expert Response Planning Advice for Manufacturing Plants

Posted on Thu, Oct 20, 2016

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

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

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

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

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


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

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

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

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


TRP Corp - Emergency Response Planning Crisis Management


Tags: manufacturing

Record Oklahoma Earthquake Highlights Need for Earthquake Preparedness

Posted on Thu, Oct 06, 2016

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

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

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

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


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

Inside a building:

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

Outside a building:

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

Post-Quake Response Actions:

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

Preparedness and Emergency Management - TRP Corp  

Tags: Earthquake Preparedness

Expert Tips on Addressing Corporate EOP Challenges?

Posted on Thu, Sep 29, 2016

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

Company-Wide EOP Audit

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

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

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



Review Historical EOP Oversights

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

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


Initiate Safety and Response Best Practices

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

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

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


Streamline Emergency Communications

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

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Preparedness, corporate preparedness

Rail Safety Regulations Implementation, Mitigation and Preparedness

Posted on Thu, Sep 22, 2016

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

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

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

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

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

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

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


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

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

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

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

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

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Corporate Crisis Management

Tags: Crude by Rail

Corporate Crisis Management Plans - Stabilizing the Chaos

Posted on Thu, Sep 15, 2016

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

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

Crisis Management Team Activation

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

Crisis Communications

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

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

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


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

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

Crisis Recovery Guidelines

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

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

TRP Corp - Emergency Response Planning Crisis Management

Tags: Crisis Management

Spill Response: HAZWOPER or Hazard Communication Standard Training?

Posted on Thu, Sep 08, 2016

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

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

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

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

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

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


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

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

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

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

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

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises

3 Critical Pre-Planning Elements for Effective Crisis Management Plans

Posted on Thu, Sep 01, 2016

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

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

Crisis Communication Planning

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

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

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

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

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

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

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

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

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

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

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

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

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

Corporate Crisis Management

Tags: Crisis Management, Communication Plan

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

Posted on Thu, Aug 25, 2016

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

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

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

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

The regulation (29 CFR 1910.38), states that employers with 10 or fewer employees do not have to create a written emergency action plan. However, employers are still required by OSHA to communicate an EAP to staff. An EAP must communicate the following minimum requirements:

  • Means of reporting fires or other emergencies
  • Evacuation procedures, including exit route assignment
  • Procedures to be followed by employees who remain to operate critical operations before they evacuate
  • Procedures to account for all employees after evacuation (29 CFR 1910.38(c)(4))
  • Procedures to be followed by employees performing rescue or medical duties
  • The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.

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

Human-caused threats

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

Building and infrastructure incidents

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

Location-specific natural disasters

  • Earthquakes
  • Hurricanes
  • Tornadoes
  • Tsunamis


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

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

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

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

Preparedness and Emergency Management - TRP Corp


Tags: Response Plans, Emergency Action Plan, Office Building

Fines, Compliance Tracking, and the PIPES Act of 2016

Posted on Thu, Aug 18, 2016

The Cost of Non-Compliance

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

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

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

Regulatory Compliance Tracking System

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

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


New Pipeline Regulations on the Horizon

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

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

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

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

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

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

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

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

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



Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance, fines

Budget Conscious Response Plan Testing and the Tabletop Exercise

Posted on Thu, Aug 11, 2016

Why Test Response Plans?

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

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

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

  • Communication
  • Training
  • Resource management
  • Command Post effectiveness

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


The Tabletop Exercise

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

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

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

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

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

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

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

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

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

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

TRP Corp Emergency Response Planning Exercises

Tags: Testing, Tabletop Exercise