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

Posted on Thu, Mar 26, 2015

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance, Deadline Approaching

Incident Management and Business Continuity Go Hand-In-Hand

Posted on Thu, Mar 19, 2015

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

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

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

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

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

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

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

Web based response planning - TRP CORP

Tags: Business Continuity, Incident Management

The Basics of Business Continuity Planning

Posted on Thu, Mar 12, 2015

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Preparedness and Emergency Management - TRP Corp

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

Common Response Plan Mistakes in Corporate Preparedness Programs

Posted on Thu, Mar 05, 2015

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

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

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

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

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

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

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

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

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

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, Response Plans

Disaster Mitigation Measures and Preparedness Elements

Posted on Thu, Feb 26, 2015

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

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

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

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

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

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

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

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

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

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

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

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

Mitigating the response planning process should incorporate the following:

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

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

Regulatory Compliance with TRP Corp

Tags: Emergency Preparedness, Mitigation

Common Response Planning Mistakes in Industrial Fire Pre-Plans

Posted on Thu, Feb 19, 2015

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Fire Pre Plans, Fire Preparedness

Enterprise-Wide OPA 90 Plans: Standardize and Comply

Posted on Thu, Feb 12, 2015

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

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

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

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

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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:

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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