Emergency Response Planning Blog

On-Site and Online Emergency Response Training

Posted on Thu, Dec 11, 2014

General emergency response training should be conducted for all site workers with industrial facilities. This preparedness training should provide employees with basic response knowledge so that they can perform defensive actions in the event of an emergency. Unless employees are specifically trained and qualified in more advanced hazardous spill response techniques, the typical employee’s trained response or function is to contain a release from a safe distance, keep it from spreading, and prevent exposures.

This general training should familiarize employees with site-specific emergency procedures, equipment, and systems. Covered topics should include, but are not limited to:

  • Incident reporting
  • Instruction and procedures for using personal protective and emergency equipment.
  • Evacuation and alarm procedures.
  • Specific roles and responsibilities in response to fires and explosions.
  • An understanding of the role of the first responder in an emergency.
  • Safe use of engineering controls and equipment.

Advanced specialized training programs typically include detailed course instruction and regulatory agency certifications.  An operational hazard or site-specific coordinated program often consist of classroom or online instruction, drills, and exercises. Specialized training may include, but is not limited to:

  • Basic hazard and risk assessment techniques.
  • Selection and use of proper personal protective equipment.
  • Basic control, containment and/or confinement operations within the capabilities of the resources available.
  • Relevant standard operating procedures and termination procedures.
  • Principles of the Incident Command System.
  • First Responder Operations Level.
  • Hazardous Materials Incident Commander.

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Retraining, or refresher courses, should be conducted for both general and specialized training requirements at a minimum of every 12 months or when certification requirements state. At a minimum, annual refresher training should cover current industry and in-house emergency operating experience, as well as changes in emergency operations plans, policies, procedures, and equipment. Additionally, annual training can highlight weaknesses identified through employee feedback and review of the program, drills, and exercises.

Federal OSHA HAZWOPER training requirements apply to “General site workers (such as equipment operators, general laborers and supervisory personnel) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards” (per 29 CFR 1910.120(e)(3)(i) for general industry and 29 CFR 1926.65(e)(3)(i) for construction).  These individuals must receive a minimum of 40 hours of instruction, either in a classroom or online, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor.

According to OSHA, trainees must become familiar with standard and site specific safety processes and applicable response equipment in a non-hazardous setting. To ensure compliance, companies should verify that appropriate and thorough hands-on training is being conducted in conjunction with any online or classroom instruction.

As web-based technologies become more accessible and mobile, different options for online training programs have evolved. These flexible training portals can be used as an intricate tool in the context of an overall training program. Online training is often in conjunction with additional site training. However, it is critical that trainees have the opportunity and mechanism to clarify unfamiliar information in order to become proficient. A computer-based training program should include access to a telephone hotline or an e-mail contact at the time the training is being conducted so that trainees will have direct access to a qualified trainer at the time their questions are raised.

To ensure online training programs are accomplishing its goals, companies should develop methods of training evaluations. OSHA recommends the following:

  • Questionnaires or informal discussions with employees can help employers determine the relevance and appropriateness of the training program.
  • Supervisors' observations. Supervisors are in good positions to observe an employee's performance both before and after the training and note improvements or changes. Drills and exercises should be routinely conducted to confirm response proficiency and specific training knowledge
  • Workplace improvements. The ultimate success of a training program may be changes in processes, procedures, or equipment that result in reduced injury or accident rates.

For free tips on conducting an effective exercise, click here or the image below:

 

Tags: Training and Exercises, Emergency Management Program, Emergency Response Planning

Key EPA Required Elements of a Facility Response Plan

Posted on Thu, Dec 04, 2014

As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, certain facilities that store and transport oil are required to develop, maintain, and submit a  Facility Response Plan (FRP). Maintaining regulatory compliance and an up-to-date FRP is an ongoing process.  As company operations evolve, and equipment and employees change, adjustments need to be incorporated into the FRP to ensure accuracy, compliance, and effective response capabilities.

Facility Response Plan: A detailed plan which must be prepared in accordance with 40 CFR 112.20 by facilities which may cause "substantial harm" to the environment or exclusive economic zone. The plan must contain an emergency response action plan (ERAP) and demonstrate that a facility has the resources to respond to a worst-case scenario discharge.- Oil Pollution Prevention Glossary

FRP development enables an owner or facility operator to develop a response organization capable of responding to an oil spill. The plan development and assessment process initiates the evaluation of:

  • Potential hazards
  • Response resources (i.e., response equipment, trained personnel)
  • Mitigation opportunities and discharge prevention measures
  • Response processes and procedures
  • Local and regional response capabilities

A regulatory compliant FRP should demonstrate that the appropriated response resources are available in a timely manner, thereby reducing impact and severity of an oil spill.

According to the EPA, an FRP must be:

  • Be consistent with the National Contingency Plan and applicable Area Contingency Plans
  • Identify a qualified individual having full authority to implement removal actions, and require immediate communication between that person and the appropriate federal authorities and responders
  • Identify and ensure availability of resources to remove, to the maximum extent practicable, a worst-case discharge
  • Describe training, testing, unannounced drills, and response actions of persons on the vessel or at the facility
  • Be updated periodically
  • Be resubmitted for approval for each significant change

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The Environmental Protection Agency EPA’s 33 CFR part 112, Oil Pollution Prevention, describes response procedure requirements for oil discharges of all types, whether the cause is accidental, man-made, natural, or deliberate. While Part 112.21 of the 40 CFR regulation contains requirements for the development and implementation of a facility training program and drill/exercise program, Part 112.20 addresses the FRP requirements, which include, but are not limited to:

  • Notifications: The emergency response action plan portion of the FRP must include an accurate emergency phone list with information for the Qualified Individual, facility response personnel, response organizations, and local responders.
  • Evacuation: The FRP requires detailed evacuation plans for the facility, including primary and secondary evacuation routes, centralized check-in area, and references to community evacuation plans.
  • Vulnerability assessment: The FRP must include a detailed site diagram, hazard evaluation, and vulnerability assessment. The assessment in the FRP examines outcomes and potential effects of an oil spill, such as the shutdown of downstream water intakes.
  • Discharge Planning Scenarios: Site-specific scenarios and response resources must be addressed for small, medium, and worst-case spills. Most spill scenarios would likely be contained in specified areas or by specialized equipment, unlikely to travel off site. However, if the scenario created could potentially result in oil traveling off site, its migration pattern, potential traveling distance, and specifically identified locations should be detailed. A smaller facility may only need to plan for two scenarios or a single scenario if its worst-case discharge falls within one of the specified ranges for small or medium discharges.  The worst case planning quantity shall be the larger of the amounts calculated for each component of the facility. Discharges are categorized by the following volumes:
    • Small discharge: up to 2,100 gallons spilled
    • Medium: 2,100 to 36,000 gallons spilled, or 10% of the largest tank (whichever is less)
    • Worst Case Discharge: Volume of the largest tank over 36,000 gallons

Appendix F of the Oil Pollution Prevention regulation (40 CFR 112) includes a model Facility Response Plan. Key elements include:

  • Emergency Response Action Plan, which serves as both a planning and action document and should be maintained as an easily accessible, stand-alone section of the overall plan
  • Facility information, including its name, type, location, owner, operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and analysis of potential spill hazards and previous spills
  • 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

For a free download on preparing for your next incident, click here or the image below:

 

Tags: Facility Response Plan, EPA, Regulatory Compliance

Response Plan Tip: Ensure Processes and Communications Equipment Align

Posted on Thu, Nov 27, 2014

The fastest way to turn an incident, crisis, or emergency into a prolonged disaster is to experience a communications breakdown.  In order to minimize impacts and rapidly respond to circumstances, companies must ensure communication processes and procedures are clearly defined and understood, and associated equipment is functional.

While every effort should be made to train employees on response processes and procedures for probable emergency scenarios relevant to your operations, training employees on initial site-specific responses included in your response plan is fundamental to your emergency management program. The need to swiftly communicate accurate and pertinent information is common to all emergency scenarios, despite operational function. Information, at a minimum should include:

  • Contact number to initiate report and response needs
  • Location of incident
  • Type of incident (medical, fire, oil spill, etc.)
  • Casualties or injured parties

The initial responder, or first person on-scene, will be the first initiator of emergency communications. While this individual may have extensive training and response knowledge, most likely, the initial responder is not specifically trained for response. As a result, all employees should be trained in initial response processes, procedures, and communication expectations.  Individuals who demonstrate a clear understanding of the communication plan, emergency procedures, and assigned responsibilities are better prepared to implement effective communication and initiate a streamlined response. Detailed information should be readily available to facility personnel to ensure all emergency managers, response personnel, and applicable agencies (ex. National Response Center) are quickly notified in the event of an incident.

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Once initial response processes and procedures are established, ongoing communication is critical in order to assess, direct, and respond to the incident. Facilities must have standardized and exercised modes of communicating.  The Federal Emergency Management Association (FEMA) describes standard communications response equipment options that may be used during an incident, emergency, or disaster. The following options range from basic to state-or the art technology:

Runners: Individuals carrying written messages from one location to another. 

LIMITATIONS:

  • Distance and time
  • Requires written information for accuracy
  • Availability
  • Requires familiarity with the area

Landline telephones: Analog and digital phones connected by physical lines. (Note: Some telephone service providers utilize modems for connecting landlines. Check with your individual service provider)

LIMITATIONS
  • Not mobile
  • System overloads easily
  • Network susceptible to physical damage
  • May be affected by power failure

Cellular/Smart phones: Mobile digital phones connected by signals transmitted by cellular towers. Capable of transmitting short messaging service (SMS). In many cases text messages will go through when your call may not.

LIMITATIONS
  • Towers may fail due to power outage or damage
  • System overloads easily
  • Requires knowledge of responder phone numbers
  • May be dependent on landlines

Satellite Phone: Mobile phones that use signals transmitted by satellites.  If other phone systems are down, can only communicate locally with other satellite phones  

LIMITATIONS

  • Expensive
  • Requires visibility to sky or building with compatible antenna
  • Potential diminished voice quality or latency

Two-way radios: Handheld, mobile, or base-station radios used for communicating on radio frequencies; many require licensure by the FCC. Below are a few examples of the different two-way radio types as described by FEMA:

RELIABILITY:

  • Family Radio Service (FRS): Have a very limited range; useful only for intra-team communications
  • General Mobile Radio Service (GMRS): Have a greater range than FRS radios and signals can be improved with antennas and repeaters
  • Multiple-Use Radio Service (MURS): Only 5 channels available for use
  • Citizen Band (CB): Have 40 channels and affordabl

LIMITATIONS:

  • Family Radio Service (FRS): Cannot alter radio (no antennas) = limited range
  • General Mobile Radio Service (GMRS):
    • Requires a license (one per family)
    • Intended for family use
    • Some business licenses are grandfathered
  • Multiple-Use Radio Service (MURS): More expensive than FRS/GMRS radio
  • Citizen Band (CB):  Limited range

Computer-based communications: Information may be transmitted over the Internet or with runners via USB drives

LIMITATIONS:
  • May require internet connectivity
  • Requires specific hardware
  • Requires power source for long use although solar power options are becoming increasingly available and affordable.

In the event Internet connectivity is terminated or inaccessible, emergency managers must have alternative means to access plans. Redundant data-centers, scheduled downloads, and ancillary security measures must be a part of any emergency management program based on an intranet or cloud.

Internet availability enables additional emergency communications through social media. From communicating facility closures in the event of bad weather or evacuation orders as a result of a hazardous spill, greater Internet accessibility allows for companies to streamline emergency communications to a wider audience with minimal administrative effort.

NOTE: The National Response Center (NRC) is the sole federal point of contact for spills of hazardous materials. NRC, which is staffed on a 24-hour basis, was given the responsibility of receiving incident reports involving hazardous materials regulated under the Hazardous Materials Transportation Act for the transportation of hazardous materials (49 CFR 171), for natural gas and other gases transported by pipeline (49 CFR 191), and for liquids transported by pipeline (49 CFR 195). All facilities involved in these activities should include the National Response Center reporting number, (800) 424-8802, in the notification section of an emergency response plan.

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Tags: Power Failure, Resiliency, Communication Plan, Social Media, Disaster Response, Notification Systems

SMART Response Planning in an Era of Advanced Communications

Posted on Thu, Nov 20, 2014

Within the past few years, technology has allowed for an increasing number of companies to automate emergency preparedness and response processes. However, in an era of instantaneous information, effective communications is still one of the greatest logistical problems during an emergency.

Without clear and effective communications, first responders may:

  • respond to the wrong location
  • be unable to effectively coordinate resources  
  • misunderstand the severity of a situation
  • be ill-equipped for the actual situation
  • find themselves in danger for which they are unprepared  

Advanced technology for emergency preparedness and response has included everything from gas-leak sensors and drones, to social media integration and sophisticated emergency management software. The ability to automate a myriad of emergency response activities, including expediting communications with local first responders, safety officials, and those affected by an incident enables companies to potentially minimize the impacts of an emergency on individuals, facilities, and the community.

Through pre-planning, a communication plan can be fully integrated into the overall response plan. Companies must be certain that response plans are accessible in a variety of formats in order for necessary process and procedures to be implemented. If the plan is not accessible, prepared information cannot be conveyed and responses may be inadequate. Best practices should be continual reviewed in order to improve optimal communication methods for each scenario. Communication pre-planning should include, but is not limited to, the following:

1. Notification and Activation methods: Meet with employees and responders to discuss notification and activation methods.  Do not assume that responders identify with current company communication policies, context of emergencies communications, or the crisis communication plan. Ensure employees are aware of applicable alarms, muster requirements, implications of various situations, and response expectations. Through communication, employees can comprehend the safety measures necessary to limit exposures and prevent unnecessary harm. With company-approved protocols in place, engaging in social media for emergency communications can allow for:  

  • Speed: Direct communication between informants and those who need information enables responders to react faster, minimizing the duration of the emergency.
  • Relevance: Disseminate the right message to the right audience
  • Accuracy: Ensure information is correct, confirmed by company sources, and backed up by facts or direct observation. Multiple informants can confirm accuracy or inaccuracies.

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

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3. Strategic Considerations: Emergency managers should establish a strategic response planning framework, with checklists and response criteria that will guide the communications decision-making process to allow for an effective response. Communications should:

  • Identify internal and external methods and procedures
  • Confirm emergency contact information
  • Identify multiple forms of communication methods (text, e-mail, cell phones)

4. Stabilization: Effective communications is the bridge to stabilizing an emergency situation. The stabilization phase may include media/public relations and a crisis communication plan. In this 24/7 information age, a communications plan should include informational jurisdiction decisions about what to release, by whom, and when. Information MUST be accurate and timely in order to diffuse rumors.

Unfortunately, during the height of an incident, bleak realities and raw emotion may alter communication agreements and promote misinformation. Avoid public power struggles and confusion by establishing a clear and exercised understanding of communication responsibilities before a situation occurs.

5. Recovery: The lines of communications need to remain open to return to a “business as usual” level. In order for a full recovery, communication should include:

  • Accurate damage assessment reports
  • Response personnel reports
  • Demobilization techniques
  • Employee reentry procedures
  • Lessons learned debriefings

Be prepared for your next incident, download TRP Corp's free white paper, "A Step-by-Step Guide: Be Prepared for Your Next Incident".

Tags: Response Plans, Communication Plan, Disaster Response

Be Ready with Hats, Gloves, and Business Continuity Plans

Posted on Mon, Nov 17, 2014

Winter is rushing in with a vengeance this November. But it wasn't too long ago that the meteorological term “Polar Vortex” was indoctrinated in the minds of millions across the United States. In January 2014, arctic temperature plummeted unusually south and two-thirds of the nation was paralyzed by record breaking cold. Will we have another Polar Vortex-filled winter that impacts businesses across the country?

According to Evan Gold, Senior Vice President at Planalytics, a business weather intelligence company, January’s polar vortex resulted in a $50 billion economic disruption, the most delivered by a weather phenomenon since Superstorm Sandy in 2012.

Severe weather habitually effects routine business operations and profitability. Weather can be the culprit of power outages, dangerous temperatures, supply disruptions, safety hazards, and potentially impair access to key infrastructures. The January 2014 events, which impacted nearly 200 million people, is one of the many examples of how severe weather affects operational continuity.

As we begin another winter season, companies should perform a business impact analysis (BIA), a precursor to a business continuity plan. The process of a BIA allows for targeted recovery strategies to be developed in the event of an emergency. A BIA should be utilized to identify likely consequences of critical business process disruptions.

After each critical business process is identified, the potential impacts resulting from loss of facilities and/or necessary infrastructure, personnel, or supply chain can be examined for each process. Key minimum recovery components along with incremental recovery time objectives should be detailed for each critical area identified. The following components should be evaluated for each critical business process.

  1. Recovery Time: Identify how long it would take to recover a specific critical process under scenario specific circumstances.
  2. IT requirements: If electronic data must be available to recover specific processes to a minimum service level, identify the necessary requirements.
  3. Data Backup History: Indicate how old the data can be to satisfy recovery (i.e. last weekly backup, last monthly backup, last quarterly backup, etc.) and review recovery methods.
  4. Review alternate location options: Identify needs and review options for off-site backup processes.
  5. Staffing minimums: Identify needs throughout recovery time objectives to optimize recovery.
  6. Impact Level: Indicate how severely the process would be impacted considering current/existing mitigation measures (ex. minimal, somewhat severe, severe).
  7. Likelihood Level: Indicating how likely each specific threat could occur considering current/ existing capabilities, mitigation measures, and history.

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Timely recovery also depends on specific preparedness and planning initiatives. Establishing processes, training employees, and restocking necessary equipment can drastically reduce the overall potential damage to operations and the financial bottom line. In order to minimize the effects of severe winter weather on continuity, preparedness protocols should be established. Depending on location and specific operations, these protocols should include, but are not limited to the following:

  • Monitor news and weather reports on television or the radio (with battery backup)
  • Alert employees or others on-site that severe weather is approaching and communicate expectations
  • Be aware of the dangers posed extreme temperatures, and ice and snow falling from equipment and buildings; mediate if possible
  • Identify infrastructure dangers posed by cold weather on exposed piping (hazardous releases, flooding, etc)
  • Prepare and insulate exposed piping
  • Winterize and shut off landscaping sprinkler systems
  • Contract snow removal services or obtain the necessary equipment (snow shovels, ice scrapers, rock salt, tire chains, etc.)
  • Ensure that company vehicles have a full tank of gas and are functioning properly (heater, deicing fluid, antifreeze levels, windshield wipers)
  • Ensure flashlights are in proper working order and have additional batteries on site.
  • Monitor ice and snow accumulation on any on site tanks, sheds, or buildings and identify non-hazardous procedures for mitigation.
  • If necessary, obtain generators to re-power facilities or necessary equipment
  • If appropriate, leave water taps slightly open so they drip continuously to prevent pipes from freezing.
  • Understand and implement cold weather response techniques when responding to product spills as released product may flow under ice or snow.
  • Establish and maintain communication with personnel
  • Consider limiting vehicle traffic
  • Maintain building temperature at acceptable levels and understand safety measures if using space heaters.
  • Notify supervisors if facility(s) loses power or is otherwise unable to operate

Tags: Business Continuity, Event Preparedness, Extreme Weather

The SPCC Plan Template and Compliance Components

Posted on Thu, Nov 13, 2014

According to a February 2012 EPA report, approximately 55% of 3,700 facilities inspected from 2007-2010, were not in compliance with existing Spill Prevention, Control, and Countermeasure (SPCC) guidelines. If these regulations are applicable to operations, companies need to prioritize plan compliance with facility management in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations. New production facilities have 6 months to prepare and submit their site-specific SPCC plan in order to be in compliance with the regulation.

According to the EPA, most SPCC enforcement actions are due to incorrect or missing required documentation or nonexistent plans. If a facility does not have a documented plan, it will not be entitled to “informal enforcement” (verbal feedback and check sheet documenting potential violations). By utilizing a template as an outline, companies can begin the process of creating a compliant plan.

In order for a standardized template to be a compliant document, it is essential to evaluate and incorporate site-specific variables and applicable requirements.  Development of an effective plan requires detailed knowledge of the facility and the potential effects of an oil spill. While each plan must be unique to the facility it covers, certain standard elements must be included to ensure regulatory compliance.

Typical elements of an SPCC plan include:

  • Professional Engineer Certification
  • Conformance declaration
  • Certification of the Applicability of the Substantial Harm Criteria
  • Facility description, plot plan, and contacts
  • Potential spill volume and flow rates
  • Inspections, tests and record keeping processes
  • Personnel training requirements
  • Loading/Unloading and transfer details
  • Discharge prevention measures
  • Security Measures
  • Recovered material drainage and disposal methods
  • Bulk Storage tanks details
  • Secondary containment locations and volumes
  • Discharge notification information and procedures
SPCC - TRP Corp

An SPCC plan template should be supplemented with the following site-specific information:

Description of Facility Infrastructure and Physical Attributes: 

Plans should include site-specific details of the designated facility. This includes:

  • Facility Name
  • Address
  • Latitude/Longitude
  • Contact Number
  • Contact Person (and/or facility manager)/contact number(s)
  • Site operations
  • Products handled
  • Number of employees
  • Identification of waterways in the vicinity
  • Summary of site drainage properties
  • Site topography
  • Details of tanks, pipelines, utilities, etc.
  • Site security features, including fencing, visitor access, and lighting

Plan distribution list: Include the names and addresses of those that maintain paper plan copies.

Key contacts: Identify all primary and secondary key contacts that may be included in a response. It is crucial to routinely verify contact information for accuracy. Response equipment and alternate response equipment suppliers should be identified. (Key contacts may include 911, National Response Center, and internal and external response teams.)

Alarm Identification and Notification Process:  Specific alarm signals that may signal an emergency, evacuation, or shelter in place. It is imperative to perform exercises with alarms to confirm they are in proper working condition and employees react accordingly. Ensure employees are trained in immediate notification response actions per roles and responsibilities.

Pertinent and updated contact numbers should be listed in the plan and verified. Plan administrators must be certain that all applicable contacts listed in notifications are accurate and/or phone numbers, especially in case of an evacuation. Verification of contact information for both personnel and external responders should be done on a periodic basis.

If maintaining accurate contact information is challenging, consider opting for an e-mail notification verification system that enables individuals to verify their own information.

Response Actions:  Checklists and procedures detailing specific key response actions should be listed in the plan. In addition to these requirements, task teams should be formed, at a minimum, to cover each process. It is crucial to train employees on each site-specific component of the plan. Companies often provide extended training in case primary emergency management team members are not available.

Hazardous Waste Storage and Disposal: Applicable contact information for external suppliers should be reviewed and verified. The consequences of a supply chain failure on response components can exacerbate an emergency scenario. Transportation delays could affect necessary equipment delivery times. As a result, facilities should plan and mitigate accordingly.

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Tags: SPCC, Regulatory Compliance, Facility Management

The Role of Communications Planning in Business Continuity

Posted on Thu, Nov 06, 2014

The primary goal of business continuity planning is to efficiently restore operations through predetermined, systematic processes and procedures. However, in order to minimize the impacts and rapidly respond to operational hindrances, companies must ensure business continuity communication methods and procedures are clearly defined and functional.

Communication planning is an intricate part of preparedness and any continuity process. Clear and effective communication channels must remain available in order to disseminate information to employees, assess and relay damage, and coordinate a recovery strategy. Failed communication often results in failed business continuity efforts. Thoroughly planning, testing, and exercising communication procedures within the following four phases is essential to ensure effective business continuity and viability of critical business operations.

1. Notification- The notification process begins upon the anticipation or discovery of a business continuity situation. Appropriate personnel and applicable business unit managers should be initially notified and updated on the current scenario. The initial notification format can be dictated by company policy, however all known information should be provided at that time, including:

  1. Location of impact or potential impact
  2. Scenario details (fire, explosion, etc.)
  3. Implementation timeline

The person responsible for each critical business process should begin documenting response actions.  Necessary continuity information should be maintained and updated as necessary to ensure all management and affected personnel can quickly initiate proper actions.

In the planning phase, initial communication procedures, available communications equipment, and alternative communication formats should be evaluated.  Initial and back up communication formats should be agreed upon during training and exercises to certify that managers, continuity personnel, external suppliers, and possibly the public receive pertinent messages.

Primary and alternate resources contact information should be included in the business continuity plan (BCP) to ensure consistent delivery and continued operations in the event suppliers are subjected to business continuity circumstances. Up-to-date contact information for internal and external responders should be verified for accuracy.

TRP Corp Business Continuity

2. Verification - Verification of contact information for personnel, continuity supervisors, and external responders should be done on a periodic basis. Business continuity planners must be certain that new employees are included in the plan, as necessary, and that notifications are being delivered to accurate e-mail addresses and/or contact numbers.

If maintaining accurate contact information is challenging, consider opting for an e-mail notification verification system that enables the contact to verify their information through hyperlinks. Companies can also offer incentives, such as drawings or prizes, to encourage all personnel to verify contact information as requested.

3. Stabilization - Stabilization is the result of the corrective actions initiated by the business continuity coordinator, business unit managers, and response personnel. Stabilization includes such actions as initiating proper notifications and implementing a procedural course of action. Planners should identify and procure necessary communication equipment and establish processes for continued operations and recovery. This will prevent unnecessary downtime and additional recovery efforts. Effective communications is the bridge to stabilization.

4. Recovery - Recovery begins once the affected area, personnel, equipment, and/or operations are accounted for and stabilized. Recovery communications includes actions such as damage assessment reporting, interactions with response personnel, removal and disposal of disruptive element, and safety verification prior to reentry or a return to operations. The lines of communications need to remain open in order to return to a “business as usual” level.

Developing relationships and common understandings of roles and responsibilities prior to a continuity event increases overall communication, post-disaster collaboration, and unified decision-making, streamlining the recovery process.

Upon termination of the incident and restoration of operations, an oral and written critique of the response should be conducted among personnel and the key business continuity members.  Communicating through evaluations and post-incident summaries can lead to the identification of continuity challenges and procedural obstacles. Items requiring action should be documented, communicated to involved parties, and tracked to ensure that potential corrective actions are identified and mitigation efforts are completed.

For a free informative download on Crisis Management Planning, click the image below:

 

Tags: Business Continuity key points, Business Continuity, Crisis Management, Communication Plan, Business Continuity Plan

Maintaining Regulatory Compliance in an Oil Industry Acquisition

Posted on Thu, Oct 30, 2014

Oil companies are not stagnant entities.  Every year, the industry experiences acquisitions, mergers, and systemic transformations. The dynamic nature of the energy sector requires environmental, health, and safety departments, as well as facility managers, to periodically review and adjust their approach to emergency management and regulatory compliance.

Whether a facility is located in the U.S. or abroad, ensuring compliance, employee safety, and an effective response requires a streamlined, coordinated, and exercised response plan. All response plans, including SPCC's and facility response plans, within the corporate enterprise should address site-specific facility details, applicable and tested response processes, and standardized company-wide best practices while maintaining location-specific regulatory compliance. A customizable response plan template can enable the development of a streamlined, site-specific preparedness program that consistently delivers company-standard guidelines and practices while providing a medium for rapid assimilation of merging or acquired facilities.

Industrial operations are required by law to institute site-specific emergency response plans, and train employees according to their response roles and pertinent response methods. Acquiring one or more new facilities typically presents challenges that generic or static response plan templates do not account for. Failure to incorporate site-specific details may result in incomplete, ineffective, and costly non-compliant plans.  Companies with multi-facility operations should utilize a customizable template with the ability to inject distinct facility information and hazards for each operation, pre-approved company best practices, as well as applicable local, state, and federal requirements.

Integrating response plans under one centralized format enables consolidated preparedness and response objectives. Acquired facilities must be absorbed into the company-wide emergency management program. If response plans exist, companies should perform a gap analysis or audit to identify any procedural, company policy, or compliance deficiencies that may be applicable to the new facilities. It is critical to define preparedness objectives, response roles, and responsibilities in order to eliminate ambiguity and confusion.  Responsible parties must apply new data, site assessments, and validated information into cohesive, compliant, and effective response plans for the new enterprise.

New or outlying facilities may present preparedness and response challenges. Cultural differences, infrastructure challenges, response equipment availability, minimal response knowledge and training, and security priorities may require heighten preparedness priorities and planning efforts. As a result, new locations may be particularly vulnerable to crisis or emergency response situations.

Regulatory compliance - TRP Corp

The following fundamental preparedness and response questions may assist companies in absorbing facilities into an established emergency management program. Determining site-specific information, possible mitigation efforts, and response capabilities can mobilize stakeholders to develop necessary and required response planning objectives. (Note: The questions below are meant to initialize conversations and should not be considered a thorough checklist for preparedness and response planning)

Who will be in charge of the response and how will it be organized?

  • Identify Incident Commander
  • Create Emergency Management Team organizational chart
  • Identify Emergency Management Team activation measures
  • Create Emergency Management Team roles and responsibilities checklists

Does the facility have a current response plan to draw from?

  • Update necessary contact information and notifications
  • Perform a gap analysis of the current plan(s) against new operations, equipment, company policies, industry best practices and applicable regulations
  • Review agency approval and submittal processes and comply as necessary

What threats affect the new facility and its employees?

  • Perform a detailed hazard and risk analysis
  • Verify or create response procedures for each identified threat
  • Identify process for incident documentation
  • Utilize appropriate ICS Forms
  • Identify current and necessary equipment necessary for response

What regulatory requirements apply to this facility?

  • Evaluate operations for compliance
  • Identify required training and confirm documentation
  • Review submitted response plan information
  • Perform a compliance audit

If necessary, what organization will conduct additional response duties?

  • Identify response capabilities and determine if additional resources are necessary
  • Initiate a Memorandum of Understanding or contract specific response needs
  • Confirm contact information, availability, and response times

How will the emergency be reported and response initiated?

  • Create site-specific notification procedures
  • Identify site-specific alarms that signal employee evacuation or shelter in place.
  • Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in alarm procedures and immediate response actions per designated roles and responsibilities
  • Implement company approved emergency classification levels to associated response procedures with emergency conditions to prevent the incident from escalating

What incidents or classification level require evacuation/shelter in place

  • Establish multiple evacuation routes.
  • Does the evacuation go beyond facility borders?
  • Identify the muster point(s) and head count procedures?

How are response actions sustained?

  • Establish command post location
  • Identify internal and external response resources and equipment for a sustained response
  • Share response plan with appropriate responders/stakeholders
For a free Audit Preparedness Guide, click the image below:
TRP offers a variety of free resources at http://www.emergency-response-planning.com/downloads/

Tags: Facility Response Plan, SPCC, Oil Spill, Emergency Management Program

Crude by Rail: Cooperative Preparedness Planning and Training

Posted on Thu, Oct 23, 2014

CSX, a North American leading supplier of rail-based freight transportation, recently hosted a crude-by-rail (CBR) incident response training session at the Security and Emergency Response Training Center (SERTC) in Pueblo, Colorado. The training consisted of 40 first responders representing 12 states.  According to CSX, “The three-day training session focused on preparation for and emergency response to railroad incidents involving crude oil, and included an overview of the history of crude oil extraction, chemical and physical properties of different types of crude oil currently being transported, incident site and damage assessment, and tank car design and construction. Participants also practiced specialized response techniques and incident command scenarios during mock derailments.”

According to the Association of American Railroads’ October 4, 2014 Weekly Report, petroleum and petroleum products shipped by rail was up 12.8% from the same time frame in 2013 (1). As CBR shipments continue to increase, companies must prioritize response and safety training, as well as coordinated planning and preparedness efforts. Because a single incident can have a significant or catastrophic impact, it is imperative that pre-planning and training be incorporated with coordinated response efforts.

In May 2014, the Department of Transportation (DOT) mandated initial coordination by instituting an emergency order for railroads to communicate specific information to each State Emergency Response Commission (SERC). The notifications must provide information regarding the estimated volumes and frequencies of train traffic implicated. Rail companies that transport 1,000,000 gallons or more of Bakken crude oil must adhere to the emergency order.

Specifically, the emergency order dictated that the notifications must: 

  1. Provide a reasonable estimate of the number of trains expected to travel, per week, through each county within the state
  2. Identify and describe the petroleum crude oil expected to be transported in accordance with 49 CFR part 172, subpart C
  3. Provide all applicable emergency response information required by 49 CFR part 172, subpart G
  4. Identify the routes over which the material will be transported.

Communication and cooperative pre-incident planning provides a tool for railroad companies and response agencies to begin the collaborative process of preparedness. This endeavor should be a coordination of overall response strategies that are made part of CBR response plans, training, drills, and exercises. A derailment that includes crude may require mutual aid efforts and a clear, yet robust Incident Management System.

crude by rail prearedness

In order for an incident management system to be effective, specific situational checklists should be created.  Rail employees, and local incident responders must be trained in applicable emergency procedures, communications cycles, and documentation requirements.  Rail incidents should be managed through clearly identified and communicated objectives. These objectives may include, but are not limited to:

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

Maintaining an accurate and up-to-date picture of resource utilization is a critical component of incident management and emergency response. This may be especially challenging on select high or low density rail routes.  Each real-time incident management status update should include the following information in order to clarify response status:

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

Improving rail car emergency response training, reactive decision management, timeliness of an ongoing response, and swift implementation of recovery strategies can limit resulting effects of any CBR emergency situation. As the shipments of CBRl continue to increase, it is imperative that companies, in conjunction with local responders prioritize well-coordinated preparedness initiatives.

NOTE: SERTC was established in 1985 to train railroad officials to safely handle accidents involving tank cars carrying hazardous materials. Because the initial endeavors were so successful, hands-on training courses were extended to serves the public sector emergency response community, the chemical industry, government agencies, and emergency response contractors from all over the world.  

(1)   Association of American Rail Traffic Weekly Rail Traffic Report, Oct. 9, 2014.

For enterprise-wide response planning guidance, click here or the image below:

 

Tags: Response Plans, Oil Spill, Training and Exercises, Safety, Crude by Rail

SPCC Planning and Regulatory Compliance Inspections

Posted on Thu, Oct 16, 2014

The challenge of managing and ensuring compliance of Spill Prevention, Control and Countermeasure (SPCC) plans for multiple facilities can be complex. Detailed government inspections, enforcement mandates, costly non-compliance fines, and negative publicity may result from the lack of implemented, site-specific, and up-to-date plans. By utilizing available technology to manage multiple SPCC plans, companies can verify compliance through a cohesive, yet site-specific, standardization of best practices.

For facilities with aboveground storage tank capacities exceeding 1,320 gallons or underground tanks with capacities above 42,000 gallons, Environmental Protection Agency (EPA) compliance requires accurate and up-to-date SPCC plans. A professional engineer must certify SPCC plans if your facilities have more than 10,000 gallons of aboveground oil storage capacity.

Maintaining SPCC compliance requires preparing plans that outline facility-specific spill prevention procedures, associated equipment to prevent spills from occurring, and countermeasures to address the effects of potential oil spills on sensitive environments. For organizations that have many facilities, web-based response planning provides seamless integration of approved enterprise-wide procedures and policies with site-specific, SPCC required information. This optimizes the potential for every location to remain in compliance with SPCC regulations.

Since 1973, the EPA has conducted scheduled or unannounced facility inspections to ensure that facilities identify site-specific practices related to the storage and management of oil and oil tanks, and response procedures in the event of an oil spill. According to the EPA, the SPCC Inspections serve two primary functions:

  1. To ensure that oil storage facilities, refineries, electrical utilities and oil production fields, among other subject industries, are in compliance with 40 Code of Federal Regulations (CFR) part 112.
  2. To give U.S. Environmental Protection Agency representatives the opportunity to educate owners and operators about the regulations and ways to ensure compliance.

SPCC TRP Corp

In order to meet SPCC regulatory requirements, every applicable facility in your organization is required to regularly update and maintain SPCC plans per EPA regulation 40 CFR 112.20. The following is an abbreviated checklist of SPCC associated planning elements that EPA representatives may evaluate during facility inspections:

  • Storage tanks and other equipment containing oil
  • Storage tank integrity testing requirements
  • Truck loading/unloading areas
  • Transfer procedures and equipment (including piping)
  • Facility layout and diagram
  • Drainage patterns and oil discharge predictions
  • Secondary containment or diversionary structures and their ability to contain a release of oil
  • Site security measures
  • Operating procedures
  • Personnel training and oil discharge prevention briefings
  • Plan certification (by a Professional Engineer (PE) or in certain cases by the facility owner/operator)
  • Recordkeeping

Since the prevention and countermeasures identified in SPCC plans must be implemented throughout the facility in order to be in compliance with regulations, a copy of your SPCC plans must be available to inspectors for reference at all times. In addition, it is essential to provide inspectors with relevant documentation of all operating and inspection procedures, spill prevention measures, training records and other compliance verification information.

With a comprehensive, web-based, database-driven SPCC plan management system, emergency managers and health, environmental, and safety departments can:

  1. Simplify audits
  2. Easily identify required information
  3. Verify accuracy of plan contents through secured access
  4. Revise information in real-time, as necessary
  5. Identify regulatory compliance gaps
  6. Account for necessary mitigation endeavors
  7. Ease maintenance and administrative efforts
  8. Provide electronic copies of plans to government agencies

Proactive responsive, procedural, and preparedness measures, in conjunction with innovative planning system technologies can maximize compliance efforts and minimize accidents and catastrophes. Transitioning to a web-based system to maintain SPCC plans can enhance accessibility, portability, and redundancy, potentially easing communication barriers with responders and regulatory audits.

For a free download entitled, "The Facility Response Plan and the Spill Prevention, Control, and Countermeasure Plan", click here or the image below:

Tags: SPCC, EPA, Regulatory Compliance, Facility Management, Emergency Management Program