Are Your Plans Smart Enough?

Common Response Plan Mistakes in Corporate Preparedness Programs

Posted on Thu, Mar 05, 2015

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 As companies reorganize and/or grow, response plans can quickly become outdated and non-compliant.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

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

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

  • Personnel listed in plans are no longer employed with the company
  • Emergency response duties and responsibilities are not assigned to appropriate personnel
  • Inaccurate contact information for company personnel and external resources
  • Lack of detailed oil or hazardous material spill response procedures regarding
  • Lack of specific tank fire pre-plans and foam calculations
  • Training deficiencies
  • Inefficient documentation of training records
  • Inconsistencies with Area Contingency Plans and/or local regulations
  • Differing plan formats and versions resulting in varied information and disjointed composition
  • No efficient process for implementing lessons learned, changes in policies, or regulatory requirements

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

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

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

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

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

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, Response Plans

Disaster Mitigation Measures and Preparedness Elements

Posted on Thu, Feb 26, 2015

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

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

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

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

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

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

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

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

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

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

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

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

Mitigating the response planning process should incorporate the following:

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

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

Regulatory Compliance with TRP Corp

Tags: Emergency Preparedness, Mitigation

Common Response Planning Mistakes in Industrial Fire Pre-Plans

Posted on Thu, Feb 19, 2015

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

For a free whitepaper on Fire Pre-Plans, click here or on the image below:

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Fire Pre Plans, Fire Preparedness

Enterprise-Wide OPA 90 Plans: Standardize and Comply

Posted on Thu, Feb 12, 2015

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

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

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

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

oilspill

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

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

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

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

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

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

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

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

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

2015 Emergency Management Conferences to Consider

Posted on Thu, Feb 05, 2015

Since the 1990s, incidents, disasters, education, and technology have continued to alter emergency management at an increasing rate. Professionals who may have begun their careers in one of the three sub-disciplines of environment, health or safety (EHS), have been required to broaden their expertise beyond singular objectives and implement new systems, processes, training, and/or equipment to drive improvements across all operations.

Today, these professional are continually challenged to improve processes based on lessons learned, experiences, and industry advancements while balancing the profit/loss scale with sustainability. Because of these challenges, the opportunity for ongoing communication, collaboration, and education is a valuable tool.

These informative conferences can aid in fostering a culture of safety and preparedness. While many are industry specific, below is a list of 2015 conferences that can inspire EHS professionals and enhance their company programs. (The list reflects statements from the conference presenters and should not be considered a TRP Corp endorsement. Cost identified is the general registration fee for full conference access. Early registration discounts and other pricing may be available).

International Disaster Conference and Expo: February 10-12, 2015 (New Orleans, LA) -  This conference unites public and private sector professionals from around the world for discussions regarding policy, lessons learned, best practices, and forward thinking, resulting in the mitigation of loss of life and property when catastrophic events occur. $450 (private sector), $150 (public sector)

Society of Petroleum Engineers E&P Health, Safety, Security, and Environmental Conference-America: March 16-18, 2015 (Denver, CO) - Since 1993, this conference has provided a setting for HSE professionals and experts to exchange knowledge, learn, and network. The event brings together industry, government, and academia to share best practices and innovative solutions.  Cost varies from $75 to $925

Disaster Recovery Journal Spring World: March 22-25, 2015 (Orlando, FL) - Industry leaders gather to explore topics that address some of today’s most challenging and pressing business continuity and disaster response issues. Break-out sessions are scheduled to address strategic, managerial, technical, information, advanced, and emergency response. $1295

Preparedness, Emergency Response and Recovery Consortium and Exposition: March 24-26, 2015 (Orlando, FL) - This focus of this conference is placed on coordination and collaboration between the various organizations and stakeholders, contributing to disaster preparedness, healthcare response, rescue and evacuation, sheltering in place, and recovery operations. The setting brings together healthcare, medical, public health, and volunteer emergency management personnel involved in disaster recovery and response efforts. Individuals representing governmental, public, and private sectors come together to discuss shared practices in preparedness, mitigation, response and recovery. $500

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IEEE Symposium on Technologies for Homeland Security: April 14-16, 2015 (Waltham, MA) - Brings together innovators from leading academic, industry, business, Homeland Security Centers of Excellence, and government programs to provide a forum to discuss ideas, concepts, and experimental results. Showcases emerging technologies in cyber-security; attack and disaster preparation, recovery, and response; land and maritime border security; and biometrics and forensics. $265-$535

Partners in Emergency Preparedness Conference: April 14-16, 2015 (Tacoma, WA) -  The Partners in Emergency Preparedness Conference (a non-profit 501(c)3 charitable organization) is the largest and most successful regional emergency preparedness conference in the Pacific Northwest. Partners in Emergency Preparedness annually hosts nearly 700 people representing business, schools, government, the nonprofit sector, emergency management professionals, and volunteer organizations. $425

Continuity Insights Management Conference:  April 20-22, 2015 (Scottsdale, AZ) - This conference provides the opportunity for strategic business continuity discussions, where professionals can learn from and network with those responsible for the integrity, availability, resilience, and security of their organizations. The conference includes a review of the latest technologies and practices, and the ability to earn additional certification with post-conference workshops. $1295-$1495

World Conference on Disaster Management: June 8-11, (Toronto, ON Canada) - Celebrating its 25th anniversary, this conference delivers a global perspective on current and emerging issues. Presentations cover practice, research, and innovation in emergency management, business continuity and crisis communications. $350

Volunteer Protection Programs Participants’ Association: (VPPPA): August 24-27, 2015 (Grapevine, TX) - Encourages and provides opportunities for EHS professionals to network, learn, and advance as leaders in occupational safety and health issues. Participants range from safety and health managers, employee safety team members, industrial hygienists, union representatives, consultants, environmental health specialists, and human resource managers Government agency representatives from the Occupational Safety and Health Administration (OSHA) and Department of Energy (DOE) are also available for networking and education. (Cost not release by publication date.)

IAEM-USA 60th Annual Conference & EMEX 2012: November 13-18, 2015 (Las Vegas, NV) - Partnering conference of the International Association of Emergency Managers (IAEM) and Emergency Management and Homeland Security (EMEX) that provides a forum for current trends and topics, information about the latest tools and technology, and advances IAEM-USA committee work. Sessions encourage stakeholders at all levels of government, the private sector, public health, and related professions to exchange ideas on collaborating to protect lives and property from disaster.  More than 2,500 participants are expected to attend this 63rd conference. (Cost not release by publication date.)

Clean Gulf: November 10-12, 2015 (New Orleans, LA) - Opportunity for companies, regulatory agencies, and associations involved in exploration, production, shipping, transportation or storage of petroleum, petrochemicals or hazardous materials to view the latest products, services and technologies, as well as hear about the latest trends and developments in the oil spill response industry. This event is co-located with the Deepwater Prevention & Response Conference. (Cost not released by publication date.)

For a free response planning guide, click the image below:

Preparedness and Emergency Management - TRP Corp

Tags: Choosing a Consultant, Conference, Emergency Management, Training and Exercises, Disaster Response

Requirements for Effective Incident Management

Posted on Thu, Jan 29, 2015

Some of the greatest challenges in emergency management comes with the unpredictability of an ongoing situation and the shortfalls of systems, processes, and individuals.  Efforts to prepare for, manage, or mitigate risks are often unexecuted or shelved by constrained resources, profit margins, politics, or alternative goals. In order to minimize response challenges, potential situations have to be identified and preparedness initiatives must be prioritized, implemented, and exercised. When a solid preparedness foundation in place, incident management and response activities can be optimized, minimizing incident duration and associated costs.

Streamlined incident management systems and processes need to be established and tested by assigned individuals who, in an emergency scenario, will be relied upon to carry out assigned response tasks. Systems and processes should include a means to provide the following:

  • Initial response information, data, and statistics - Assigned employees should be able to intuitively obtain essential information to determine optimal responses.  This allows responders to provide swift and appropriate resolutions as established by designated response planning initiatives. The infrastructure of an intuitive, streamlined, and customizable system enables companies to implement site-specific processes while retaining company-wide response planning consistency. (A web-based, enterprise-wide response planning system can remove the uncertainties and challenges associated with managing multiple response plans, streamline the update process, and simplify plan reviews, ensuring a consistent path toward compliance and effective emergency response.)

  • Accurate reporting - To improve targeted response processes in an ongoing scenario, the incident commander or designated person-in-charge, needs the ability to measure current conditions and quantify appropriate processes. The process of providing and receiving current information and communicating necessary focused tasks is the essence of incident management.

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The ability to maintain transparent communication and a seamless exchange of information during the incident management process improves safety, reduces response costs, and improves continuity of operations. Real-time 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. Utilizing an instantaneous method of situational awareness provides a means to:

  • Determine the deployment of resources in order to prevent duplication of efforts

  • Integrate incident response plan contacts and assigned tasks

  • Aggregate data into a format that enables real-time analysis and decision making to ensure the most efficient and effective emergency response

  • Minimize miscommunications that can delay time sensitive responses

  • Document stakeholder and agency directives to be used as a reference or learning tool.

Even when state-of-the-art systems and best practice processes are in place, incident management 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 are better prepared to implement a precise, streamlined, and effective response.

The Incident Command System (ICS) command staff or incident management team is made up of management level personnel who are self-directed in support of the response effort. It is critical that the ICS assigned individuals are trained in their responsibilities and have demonstrated understanding through realistic exercises. In additional to the incident commander, the ICS supervisory personnel may include but is not limited to Safety Officer, Information Officer, Risk Management, Legal, Security, and Liaison Officer. (FEMA’s ICS Resource Center has full list of positions and checklists that may be applicable to your facilities.)

Individual responsibilities vary by role and the site-specific scenario. However, general supervisory responsibilities may include, but are not limited to the following:

  • Initial response actions

  • Prioritize the health and safety of staff members through evacuation or shelter-in-place

  • 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

For a free paper on the "Top 3 Benefits of a Web-based Response Planning System", click the image below:

Web based response planning - TRP CORP

Tags: Incident Management

The Importance of Response Plan Training for the First Responder

Posted on Thu, Jan 22, 2015

Any employee has the potential to be put in a first responder role in the event of an emergency at the office, jobsite, or facility.  As a result, all employees should be trained in response measures appropriate for site-specific vulnerabilities and identified risks. The rapid mobilization and proficiency of initial actions, as well as response procedure familiarity is essential in order to minimize potential chaos, scenario consequences, and plausible chain-reaction events.

In order to avoid the onset of panic or prolong emergency circumstances, necessary and effective reactive measures should become second nature to any potential initial responder. Familiarity through training and exercises can combat the natural effects of stress in tense situations. Having a well-rehearsed emergency plan enables efficient and effective response coordination, reduces losses, and can limit the impact to employees, the environment, and surrounding community.

Efforts must be made to train non-response team members in initial response actions and the appropriate initiation procedures. Any employee or contractor, upon discovering a significant event or condition that requires urgent response from outside trained personnel, should be trained to take the suggested initial response actions listed below:

Initial Response Actions:

  1. Warn others in the immediate area through verbal communication and/or activate local alarms.

  2. Take immediate personal protective measures (PPE, move to safe location, etc.).

  3. Report the emergency to Security or 9-1-1, depending on company policy.

  4. Implement local response actions (process shutdowns, activate fire protection systems, etc.) if safe to do so, and consistent with level of training and area specific procedures.

Industrial facility employees often encounter unique, site-specific hazards, and potential threats, unlike those in other fields. Specialized training must complement response team roles and responsibilities in order to address these specific vulnerabilities and risks. But despite an industrial setting, not all employees will be assigned to a formal response team.

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Employees who may be exposed to hazardous substances are required to be HAZWOPER certified. HAZWOPER, an acronym for the Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Standard, communicates the required training that addresses hazardous operations and potential spills or releases. The intent of the HAZWOPER standard is to protect workers engaged in "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v)).  However, this does not mean that all HAZWOPER certified employees are responsible for terminating a release. According to the standard, the following first responder levels are not trained to terminate a hazardous incident.

The Awareness Level:  According to OSHA, the first responders at the “awareness level” must demonstrate competency in areas such as recognizing the presence of hazardous materials in an emergency, the risks involved, and the role they play in their employer’s plan.

Who should be trained? This level is applicable for persons who, in the course of their normal duties, could be the first on the scene of an emergency involving hazardous material. Responders at the awareness level are expected to recognize the presence of hazardous materials, protect themselves, call for trained personnel, and secure the area without engagement.

Individual companies can set their own hourly training requirements; however, employees must be capable of demonstrating the following:

  • What hazardous substances are, and associated risks during an incident

  • The potential outcomes associated with an emergency when hazardous substances are present

  • Ability to recognize the presence of hazardous substances in an emergency

  • Ability to identify the hazardous substances, if possible

  • The role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook

  • Ability to realize the need to make appropriate notifications for additional resources

The Operations Level: Operations level responders meet and exceed the competency level of the awareness responder. 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.

Who should be trained? These responders are part of the initial response for the purpose of protecting nearby persons, the environment, and/or property from the effects of the release.   Operations may receive additional training in HAZMAT/CBRNE defensive techniques of absorption, damming and diking, diverting, retention, vapor dispersion and suppression. They may also be trained in basic decontamination procedures and PPE.

First responders at the operational level should complete the 8-hour HAZWOPER training course or have had sufficient experience to objectively demonstrate competency in the following areas:

  • Basic hazard and risk assessment techniques

  • How to select and use proper personal protective equipment

  • Basic hazardous materials terms

  • How to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit

  • How to implement basic decontamination procedures

  • The relevant standard operating procedures and termination procedures

For a free download on conducting an effective exercise, click here or the image below.

TRP Corp Emergency Response Planning Exercises

Tags: OSHA HAZWOPER, Facility Response Plan, Response Plans, Facility Management, Disaster Response, Workplace Safety, Chemical Industry, HSE Program

Falling Oil Prices Should Not Compromise Compliance and Response Planning

Posted on Thu, Jan 15, 2015

After nearly five years of stability, crude oil prices have dropped over 50% in recent weeks.  According to the “Global 2015 E&P Spending Outlook”, exploration and production spending by North American Oil and Gas companies could drop 30% in 2015, affecting budgets across the industry.1 However, despite potential budget restructuring, oil and gas companies should not sacrifice regulatory compliance and safety for profitability.  Environmental, health, and safety programs must be viewed as an investment in the sustainability of a company, rather than as a subordinate expense.

Profitability, shareholder value, and cost control measures may initiate management to implement cost control measures. Regulatory compliance and response planning initiatives are often sacrificed during this process. However, the reality is that one emergency or crisis situation occurring because of noncompliance, or prolonged due to ineffective responses can cost a company many times the cost of implementing and maintaining an effective program.

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In order for the oil and gas industry to continue to be one of the safest operating industrial sectors in the United States, the industry must continue to audit, test, and update preparedness endeavors and response capabilities. In the face of decreasing profits, many HSE programs involved in oil and gas, refining, petrochemical, manufacturing, and others, will encounter challenging operational environments and cost cutting initiatives. But in addition to fulfilling a moral responsibility to protect employees, the community, and the environment, an effective and exercised emergency management program must be prioritized in order to meet certain key strategic and tactical objectives. These include, but are not limited to:

  • Facilitating compliance with Federal, State, and Local regulatory requirements, eliminating the threat of potential fines.
  • Reducing property damage (ex. buildings, contents, pipelines)
  • Enhancing the ability to recover from business interruption and loss (ex. damaged industrial, commercial, and retail facilities)
  • Reducing indirect business interruption loss (ex. supply chain “ripple” effects)
  • Reducing environmental damage (ex. wetlands, parks, wildlife)
  • Enhancing a company’s image and credibility with employees, customers, suppliers and the community.
  • Reducing other nonmarket damage (ex. historic sites, schools, neighborhoods)
  • Minimizing societal losses (ex. casualties, injuries, layoffs)
  • Reducing need for emergency response (ex. ambulance service, fire protection).
  • Reducing exposure to civil or criminal liability in the event of an incident.
  • Potentially reducing insurance premiums (check with individual insurance providers for associated savings).

The emergency response and crisis management planning investment becomes much more strategic when considering of the total cost of actual emergencies and incidents. In business, these terms and financial impacts are not discussed often, but emergency response and incidents have some of the gravest and most serious moral consequences regarding humanity and the environment. When an emergency can be prevented from escalation and/or affecting the lives of employees, communities, or the environment, a company must make every effort to prevent harm.

If government regulations are applicable to operations, companies must prioritize regulatory compliance in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations. The increasing number of stringent regulatory compliance standards compounds the complexity of sliding oil prices and cost-cutting operations. Most companies believe they have the regulatory compliance component of their business under control. However, agencies such as OSHA, EPA, and DOT, continue to inspect and fine companies for non-compliance for a variety of infractions. 

Companies can reduce overall costs associated with HSE programs by easing day-to day administrative processes, ensuring regulatory compliance, and implementing and maintaining effective response capabilities. Streamlining these efforts with enterprise-wide, web-based response planning technology and best practices formats can reduce overall costs associated with variegated plans and processes across multiple locations.

  1. Dittrick, Paula. Barclays Sees Likely Downside to North American E&P Budgets. Oil and Gas Journal. January 9, 2015.

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance, Emergency Management Program, Emergency Response Planning

Make 2015 "The Year of Response Planning and Preparedness"!

Posted on Thu, Jan 08, 2015

While it is more cost efficient and less complicated to learn from other's response experiences and emergency management mistakes, every emergency scenario, exercise, or training endeavor can be used to improve the outcome of the next response. As we begin 2015, facility and emergency managers should draw from personal experiences, staff knowledge, and industry-wide lessons learned to improve their preparedness and response program.

The following discussion points, while not all-inclusive, can be used to spur emergency management program improvements and response planning reformations for 2015:

Compliance

  • What agencies and new or impending regulations apply to my location(s)?
  • Have budgets been allocated for necessary compliance mitigation resolutions?
  • If applicable, have Globally Harmonized System (GHS) Safety Data Sheets (SDS) been updated and have their properties been included in the planning process?
  • Has an inspection taken place, and if so, have non-compliant issues been mitigated?
  • Will an internal compliance audit(s) be conducted?
  • Is personnel training up-to-date and compliant with site-specific requirements?
  • Are required exercises scheduled?

Risk Assessment

  • What are the new high-risk, medium-risk, and low risk-activities or circumstances, and are how will these scenarios relate to planning?
  • Can high-risk tasks or conditions be mitigated with the current budget? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Are there additional environmentally sensitive areas that need to be addressed in the response plan?
  • Does the risk assessment utilize realistic scenarios to define potential spill volumes and downstream locations?
  • How will employees be made aware of hazards associated with specific workplace process, materials, or location(s)?

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Supply Chain

  • When will response equipment needs be re-evaluated and defined?
  • Are there new technologies or equipment that will better suit your program's equipment needs?
  • Will current vendors have predefined supplies or equipment available in the event of an operational disruption or emergency scenario, or do new suppliers need to be evaluated?
  • Are processes in place to monitor internal and external supply chains and their response time?
  • Is additional or alternate external spill response support necessary and available?
  • How would a spill affect both internal and external resources?
  • Are back up suppliers identified, and when will their availability be confirmed?

Training

  • Are current personnel appropriately trained for their allocated roles?
  • Are new employees being trained effectively?
  • Do new training measures need to be implemented?
  • Will training comprehension be tested with realistic exercise scenarios?
  • Is the response management team structure clear and able to be communicated?
  • Will external responders included in plan preparations and exercises receive a copy of the current plan?
  • Have post exercise review mitigation measures been applied to current training and preparedness measures? If not, when will these tasks be completed?
  • Should training include any new resource tracking documentation methods, software, or amended response communication actions?

Response Elements

  • If an incident were to occur today, would your response plan minimize impacts and be a guide for an effective and coordinated response effort?
  • Is a process established for individual responders to verify their contact information to allow for timely responses? If not, can verification process improvements be made to ensure accuracy?
  • Are clear initial response action procedures in place to notify, assess, and initiate a response?
  • Can approved stakeholders easily access response plans? Have you researched innovative technology that allows for improved plan access?
  • Have response times and limitations been confirmed? Have they changed from the previous plan revision?
  • Does the current response plan address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been upgraded? If so, have these changes been addressed in the plan.
  • Are new or additional communications backup systems available and described in the plan?
  • Are there new staff roles, personnel, or modified internal or external responsibilities that need to be specified in the plan, and communicated to responders?
  • Are there alternate strategies and response procedures that need to be included in the plan?
  • Are updated processes and procedures identified in the plans to assess and monitor size, shape, type, location, and movement of a spill or release?
  • If applicable, have tactical response details been included in the planning process for incidents that expand beyond the confines of the facility? Are there any changes that need to be incorporated?
  • Do trajectory maps and estimates mimic local observations and historical tendencies?
  • Are sensitive sites prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes communicated?

Documentation

  • Are sufficient processes established for updating planning information prior to an emergency and during a response?
  • Have plot plans and area mapping been integrated with the latest GIS data and knowledge?
  • Are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), updated and in place? Are there new MOUs or contracts that need to be established or finalized?
  • Do stakeholders have a copy of your most up-to-date plans?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible to auditors?
  • Are necessary Incident Command (ICS) and company-specific forms readily available for documentation?

By analyzing the past, monitoring the present, and evaluating the “potentials” of 2015, companies can reinforce their commitment to emergency management while establishing a culture of preparedness. Executing plan enhancements and reinforcing preparedness across an enterprise strengthens a company’s resolve, ultimately creating a more resilient organization.

 

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Preparedness and Emergency Management - TRP Corp

Tags: Emergency Management, Response Plans, Oil Spill, Event Preparedness

TRP's Top 10 Preparedness Blogs of 2014

Posted on Tue, Dec 30, 2014

As TRP Corp. gets ready to begin its 20th anniversary year, we would like to share our subscribers’’ “Top Ten” blogs from 2014.  While the topics vary, the goal of each blog is to provide a resourceful, informative article that guides professionals in developing effective emergency, crisis, and business continuity plans. We hope emergency managers, first responders, and safety professionals can utilize these blogs to advance emergency management, preparedness initiatives, and business continuity efforts in 2015.

Our “Top Ten” 2014 blog articles Include:

10. Preparedness, Planning, and Pandemic Plans 

Published prior to the onset of the well-publicized Ebola outbreak, this blog highlights the evidence for the need of pandemic planning and the pandemic response plan.

9. The Business Impact Analysis: A Step Towards Business Continuity 

While the size and complexity of essential business elements required for sustainability varies among industries, companies, and specific facilities, the ability to quantify and prioritize critical work flow components is a key business continuity element. This blog highlights examples of which critical business functions to analyze, and the specific components of the Business Impact Analysis.

8. Incident Response Drills and Tabletop Exercises 

Every drill or exercise presents the opportunity to improve site-specific response plans, rendering the potential for a more effective response. This blog examines the three most popular types of response exercises and details tabletop exercise planning considerations that can aid in improving preparedness levels.

7. Consultants Combat Emergency Management Challenges: Oil and Gas Industry 

Despite safety statistics, the oil and gas industry’s public safety perception has been tested by highly publicized tragic incidents, increasing the pressures on emergency managers. This blog highlights some of the challenges felt by oil and gas emergency managers, and breaks down the strategic and tactical cost-benefits of hiring specialized, reputable consultants.

6. 7 Key Points for Industrial Business Continuity and Disaster Recovery 

Companies often lack adequate recovery planning and recuperative procedures to restore critical information, essential processes, and normal business operations within an acceptable recovery time frame. This popular blog identifies seven elements that can accelerate the business continuity recovery process.

 5. Ten Reasons for Companies to Invest in Incident Management Programs 

Implementing a technologically advanced, enterprise-wide incident management system offers opportunities to increase the effectiveness of preparedness efforts with “real-time” response advantages. This blog highlights ten “best practice” reasons why companies should prioritize these programs, and advance preparedness initiatives and associated response programs.

Response Planning to succeed

4. Corporate Emergency Preparedness and Risk Management 

Companies that prioritize risk management and integrated preparedness goals are better prepared to educate employees on potential incidents, and their role in prevention, mitigation, response, and recovery. This popular blog highlights four “best practice” processes and prevention measures that should be included in your risk management program.

With carefully planned tabletop exercises, mitigation opportunities and valuable response knowledge can be revealed. Realistic exercise scenarios can often highlight potential deficiencies in response plans, individual comprehension of response roles and responsibilities, and partnership coordination efforts. This blog highlights the various types of tabletop scenarios that can be utilized to strengthen preparedness efforts and bolster your emergency management or HSE program.

2. A Lesson in Emergency Preparedness: Learn from Past Incidents 

Emergency managers should not camouflage preparedness or response failures. On the contrary, they should draw from scenario experiences and response lapses to improve their emergency management program. This blog highlights the importance of the evolution process within response planning and emergency management, and offers a series of questions that may aid in identifying plan deficiencies and mitigation opportunities.

1. Fire Pre Plan Templates: How to Make Them Work for You! 

An enterprise-wide fire pre plan template can serve as an outline of required fire response related information, yet they must be populated with site-specific details. TRP’s top blog of 2014 highlights specific elements that should be included in a fire pre plan, despite the response situation or circumstance. The blog also provides insightful fire pre plan “helpful hints” from various first responders and fire departments.

For more information regarding web-based, database driven planning systems, contact TRP at (281) 955-9600, or click the image below to set up a personalized demonstration.

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Tags: Emergency Management, Emergency Management Program