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Posted on Thu, Nov 26, 2015

OSHA's Top 10 Affirms Need for Regulatory Compliance Tracking System

Posted on Thu, Nov 19, 2015

In mid-October, six people were injured when seven stories of scaffolding collapsed at an apartment construction site in busy downtown Houston. The cause of the collapse is currently being investigated by Occupational Safety and Health Administration (OSHA) inspectors. Unfortunately, scenes like the one that occurred in downtown Houston continue to occur across the United States in staggering numbers.

OSHA recently announced its preliminary Top 10 most frequently cited workplace safety violations for 2015. These preliminary ranking were based on figures through September 8, 2015. Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs, presented the Top 10 at the 2015 National Safety Council Congress & Expo held in Atlanta, GA. As with years past, fall protection and scaffolding incidents continually rank in the Top 10 violations. The list incorporates worksite inspection findings of Federal OSHA inspectors from across the country.

Every month, audits and enforcement mandates are issued from various federal and state agencies. Costly non-compliance fines continually result from the lack of an implemented, thorough, or effective regulatory compliance program. Ideally, companies should utilize this list to conduct assessments, identify potential site-specific compliance lapses, and mitigate these highly recognized hazards. When companies deliberately protect lives, prevent hazardous environmental impacts, limit property damage, and eliminate regulatory fines, prioritizing an EHS program becomes an investment in the sustainability of a company.

OSHA Top 10 Safety Violations

The Top 10 for FY 2015 violations include:

  1. Fall Protection (1926.501) – 6,721
  2. Hazard Communication (1910.1200) – 5,192
  3. Scaffolding (1926.451) – 4,295
  4. Respiratory Protection (1910.134) – 3,305
  5. Lockout/Tagout (1910.147) – 3,002
  6. Powered Industrial Trucks (1910.178) – 2,760
  7. Ladders (1926.1053) – 2,489
  8. Electrical – Wiring Methods (1910.305) – 2,404
  9. Machine Guarding (1910.212) – 2,295
  10. Electrical – General Requirements (1910.303) – 1,973

It is often impractical for companies to spend relentlessly on emergency management mitigation efforts. However, regulatory compliance, required safety processes, and response planning should not be compromised for expedited operations and profitability. Prevention, mitigation, and planning costs should be analyzed against the financial impacts and potential stigma of non-compliance and emergency scenarios. These costs may include, but are not limited to:

  • Human life
  • Short term or long term business interruption
  • Lawsuit(s)
  • Infrastructure damage
  • Equipment failure
  • Inventory/stock losses
  • Fines
  • Reputation
  • Environmental destruction

"Far too many people are still killed on the job - 13 workers every day taken from their families tragically and unnecessarily.” said Thomas E. Perez, U.S. Secretary of Labor. “These numbers underscore the urgent need for employers to provide a safe workplace for their employees as the law requires.”

Regulatory non-compliance continually proves to be expensive, time consuming, and potentially dangerous to employees, surrounding communities, and the long term viability of companies. An effective compliance management system, mitigation efforts, and employee training can result in an efficient and integrated program that optimizes safety and regulatory compliance while minimizing potential costs and downtime.

Regulatory Compliance with TRP Corp

Tags: OSHA, Regulatory Compliance

Combat Complacency: 12 Cost/Benefit Emergency Management Objectives

Posted on Thu, Nov 12, 2015

Companies that experience extended periods of incident-free, operational continuity, often develop a dulled sense of vulnerability that impedes response planning and preparedness. EHS managers must continually address complacency and fluctuating real-world potential issues, site-specific risks, and regulatory compliance within set budgets. Securing the status-quo when daily operations and external influences can provoke everything from critical incidents to catastrophic disasters presents a continuous balancing act for EHS managers.

The challenge of sustaining effective safety and preparedness levels is often met with budget justifications for intervention, prevention, and response planning. However, the cost of complacency and stagnation is typically higher than the cost of advancing and implementing safety, preparedness, and response planning initiatives.

EHS budget justifications are often plagued by challenging internal and external factors. Internal challenges often include profitability, shareholder value, and cost control measures. These factors often propel management to question the likelihood of profit/loss scenarios. Additionally, regulatory compliance mitigation opportunities and response planning initiatives are often sacrificed during this process. However, one ineffectively handled emergency or crisis situation can cost a company many times the cost of implementing and maintaining an effective program.

External factors such as regulatory compliance, high-risk locations, shifting labor markets, and emerging competitors can increase the complexity and cost of overall operations. However, these external factors also introduce the potential for additional costs related to fines, emergencies, crises, and business continuity issues. Without a proactive approach to preparedness and response planning, reactionary costs will eventually overtake the cost savings of an effective program.

A detailed emergency management program cost-benefit analysis can highlight the potential cost savings of an effective program and communicate the various threats to operational continuity and longevity. Prevention, mitigation, and planning costs should be compared with the financial impact of situational recovery processes and the overall costs of an incident. The analysis should identify and evaluate low, medium, and high impact likely scenarios, associated response expenditures, and total estimated recovery costs including, but are not limited to:

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

Emergency Management Cost benefit analysis

A thorough emergency management program review and response plan audits can reveal specific deficiencies and identify areas for program improvement. These deficiencies should be prioritized, quantified for mitigation, and included in a long-term budget plan. In addition to fulfilling a moral responsibility to protect employees, the community, and the environment, an effective and exercised emergency management program should meet certain key strategic and tactical objectives in order to be cost beneficial. Objectives should include, but are not limited to:

  1. Enhancing employee safety to minimize harm
  2. Facilitating compliance with Federal, State, and Local regulatory requirements, eliminating the threat of potential fines.
  3. Reducing the potential for infrastructure and property damage
  4. Enhancing the ability to recover from business interruption and loss
  5. Reducing indirect business interruption loss (ex. supply chain “ripple” effects)
  6. Reducing environmental damage
  7. Enhancing a company’s image and credibility with employees, customers, suppliers and the community.
  8. Reducing community damage and impacts (ex. historic sites, schools, neighborhoods)
  9. Minimizing societal losses (ex. casualties, injuries, layoffs)
  10. Reducing need for costly emergency response
  11. Reducing exposure to civil or criminal liability in the event of an incident.
  12. Potentially reducing insurance premiums (check with individual insurance providers for associated savings).

Over the long term, emergency management complacency becomes expensive and has a negative effect on corporate preparedness and response planning. By properly budgeting and continuously evaluating incident mitigation opportunities, improving response capabilities and quantifying regulatory compliance, EHS managers can reduce the costs associated with incidents and contribute to the longevity of a company.

Regulatory Compliance with TRP Corp


Tags: Resiliency, Workplace Safety, corporate preparedness

Sustaining Corporate Preparedness: Expert Administration Tips

Posted on Thu, Nov 05, 2015

There are a wide range of administrative actions associated with achieving a state of corporate preparedness, preserving regulatory compliance, and maintaining effective response plans. Neglectful emergency management practices can result in failed inspections, fines, infrastructure damage, negative public perceptions, and a possible government-mandated shutdown of operations. The administrative workload and task list can be daunting and time consuming, yet the effects of inactivity can negatively impact a company’s safety culture and financial bottom line.

Emergency planning and associated administrative duties must be an ongoing process. Company operations, equipment, and employees are continuously changing. Modifications, expansions, and adjustments need to be incorporated into preparedness initiatives and response planning to ensure compliance and effective responses in the event of an emergency. As a result, a methodological administrative process should be incorporated into every emergency management program.

One of the most important aspects of maintaining accurate and compliant plans is to update information in a timely manner. Cyclical response planning reviews and updates maximize efficiency and compliance of emergency management programs. The size and scope of administrative duties depends on operations, requirements, and resources. As a result, cyclical duties and actions may include, but are not limited to the following:

  • Documenting hazards
  • Regulatory compliance
  • Documenting plan gap analysis and audit evaluations
  • Communicating and documenting mitigation efforts Verification of emergency contacts
  • Updating plans
  • Documenting and updating training records
  • Communicating with emergency response organizations
  • Documenting and updating exercises and associated critiques
  • Distributing plan revisions

corporate preparedness

Corporate emergency preparedness programs and applicable plans need to be reviewed annually, at a minimum. However, plan reviews and potential updates requiring administrative actions should be conducted under the following situations:

  • Regulations deem changes are mandatory
  • An incident has occurred that highlights new best practices
  • A change in the status of current operations
  • A change in internal/external response capabilities
  • Changes to contact information
  • Company merger or acquisition
  • Site alterations/renovations
  • A vulnerability analysis reveals new risks/threats
  • A change in response resources/equipment

Companies must also maintain awareness of the various regulatory agencies’ plan submission requirements regarding response plan revisions. While a regulatory compliance tracking systems can itemize applicable federal, state, and local regulations, plan administrators must ensure regulatory components are documented, updated, and maintained for site-specific accuracy and compliance.

In the event of an emergency, administrative duties are crucial to response documentation. Emergency actions must be documented as soon as practical during or immediately after an emergency incident. This includes compiling notes and applicable documentation from all employees and members of the response team. The following are recommended documentation guidelines:

  • Record only facts, not speculation.
  • If participant does not know a particular fact, do not allow speculation or elaboration. 
  • Do not criticize other people's efforts and/or methods. 
  • Do not speculate on the cause of the emergency. 
  • Do not relate unqualified opinions.

Depending on assigned roles and responsibilities, administrative actions during and after an emergency may include, but are not limited to:

  • Maintaining telephone logs
  • Keeping a detailed record of events
  • Maintaining a record of injuries and follow-up actions
  • Accounting for personnel
  • Coordinating notification of family members
  • Issuing press releases
  • Maintaining sampling records
  • Tracking incident costs
  • Coordinating personnel services
  • Documenting incident investigations and recovery operations
  • Updating response plans
  • Submitting revised plans and to agencies

Web based response planning - TRP CORP

Respond Under Pressure: Emergency Management Communications

Posted on Thu, Oct 29, 2015

In order to effectively respond to emergencies, emergency management teams must establish the ability to receive and transmit information, maintain situational awareness, and communicate within a coordinated emergency response framework. Streamlined communication components are essential to ensure effective emergency management. Communicating timely and accurate information to facility managers, critical decision makers, emergency response teams, stakeholders, contractors, and the public is an important aspect of nearly every emergency management function.


The execution of a solid communication plan should begin in the planning phase, not on the verge of, during, or in the aftermath of a disaster. Through planning, a communication plan can be fully integrated into the overall disaster or emergency response plan. Companies must:

  • Develop processes to assess incoming/outgoing information to/from multiple sources
  • Organize information systematically
  • Display and relay applicable information
  • Communicate essential information to appropriate parties
  • Document response data in the event it is necessary for further communications

Communications planning may include verification of emergency contacts, training, exercises, activation procedures, response notifications, public relations, and other site-specific needs. These company efforts must be accurate and conclusive to bolster the overall strategic and tactical preparedness objectives.

Management, employees, and responders should be familiar with emergency communication processes, especially notification and activation procedures. Do not assume that responders identify with current company policies or the context of emergencies communications. Exercises play a crucial role in preparedness, providing opportunities for employees, emergency responders and officials to practice, assess and refine their collective communications capabilities and response expectations. These exercises encourage awareness of alarms, muster requirements, implications of various situations, and response expectations.


The notification process begins upon discovery of an emergency situation and notification of appropriate personnel. The initial notifications should be communicated by a company approved method (telephone, alarm, radio, etc.), and all known information should be provided at that time, including, but not limited to:

  • Location
  • Type of event (fire, explosion, etc.)
  • Casualties or injured parties
  • Hazardous material involved, if applicable

Companies must establish a strategic framework with checklists and response criteria that will guide the communications decision-making process to allow for an effective response. All pertinent facts and necessary information should be maintained to ensure all emergency management, response personnel, and agencies are quickly notified.


Effective communications is the bridge to stabilizing an emergency situation. Stabilization includes such communication actions as initiating proper notifications, alarms and PA announcements, personnel evacuation, shutdown of systems, obtaining medical assistance, and conferring with appropriate personnel to develop and implement a course of action.

Stabilization also may include media/public relations. 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 defuse rumors.


Recovery begins once the affected area is stabilized, personnel are evacuated and/or accounted for, and the situation is under control or stable. Recovery communications includes damage assessment reporting, interactions with response personnel, removal and disposal of an explosive device or hazardous material, and verifying the safety of an area prior to reentry. The lines of communications need to remain open to return to a “business as usual” level.


After a declared emergency has been terminated, an oral and written critique of the response should be conducted among the key responders involved.

A post-incident summary of any problems and corrective actions planned or taken to resolve the problem should be included in incident reports. Lines of communication should remain open and action items should be documented and tracked to ensure that corrective actions are completed.

As technology and communication methods evolve, companies must make an effort to incorporate accepted systematic formats, mainstream methodology, and digital response tactics into EHS programs. Implementing best practice communications methods that relate to satellite radios, social media, smartphones, and/or cloud-based technologies will enable companies to carry out a solid communication plan.

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

Tags: Emergency Management, Communication Plan

Why Test Preparedness and Response Plans with Tabletop Exercises?

Posted on Thu, Oct 22, 2015

Exercises must be conducted in order to ensure response plans are effective, and personnel are prepared to respond to an incident. Minimum exercise requirements should be established within an emergency preparedness program to ensure response plans are properly tested for use during a disaster, emergency, or crisis.

A tabletop exercise is often the simplest form of exercise to prepare for, coordinate, and conduct. A tabletop exercise utilizes a simulated scenario that enable participants to react to events as they unfold. This exercise format should facilitate analysis of an emergency situation, elicit constructive response from participants, and identify gaps or inaccuracies in response plans and personnel knowledge. The goal of a tabletop exercise program should be to improve the overall readiness and capabilities of emergency response program that encourages:

  • Realistic scenarios
  • Proper training validation
  • Effective emergency response plans
  • Identification of action items
  • Response team relationships
  • Operational response capabilities
  • Personnel preparedness, regardless of the threat or hazard

The tabletop exercise also provides an environment to:

1. Apply National Incident Management System (NIMS) and the Incident Command System (ICS): The Incident Management Team (IMT) should demonstrate a proficiency in utilizing the forms, processes, and terminology of the ICS.

2. Demonstrate understanding of the Emergency Response Team (ERT) and Incident Management Team (IMT) organizations: The ERT and the IMT should have a functional understanding of their specific roles and responsibilities. Gaps in training should be identified, and follow-up action taken to ensure that these gaps are addressed.

3. Unify common organizations, general responsibilities, and company expectations: The ERT and IMT should have a clear understanding of the capabilities of each responding organization. Communication processes, response methods, roles and responsibilities, and available equipment should be identified and confirmed for the applicable scenario.

4. Demonstrate the ability to document communication, actions, management decisions, and track resources: Participants should utilize ICS forms to record processes and implemented procedures per regulatory requirement and company standards. Documentation can be used for post-exercise assessments and team reviews, and to create action items to improve follow-up and emergency response plans.


Below is a list of common tabletop exercise planning considerations:

Condensed Exercise Time-Frame: In order to exercise the emergency scenario, the exercise must progress in a condensed time-frame (not real-time). Events should move rapidly through some phases of the exercised response. However, it should be clearly understood that under real conditions the same events or actions would require much more time to complete.

Scenario Information and Position-Specific Tools: Detailed scenario information, ICS forms, and position specific events should be prepared to guide all participants through the execution of their roles and responsibilities. These tools should be included in a participation package and distributed to all participants prior to the exercise.

Weather Conditions: Depending on the scenario, either real or simulated weather conditions may be utilized during the exercise.

“This is a Drill” Exercise Communications: All radio, telephone, electronic, and written communications must begin and end with the statement "This is a Drill". Include this statement in all verbal communications, and in a prominent location on all written correspondence.

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

Injects: An Inject describes an event or circumstance that requires an additional response or action from the participant.

Exercise Termination and Debriefing: Following termination of the exercise, a debriefing of all exercise participants should be conducted. All participants should have the opportunity to provide feedback on the exercise and complete an exercise evaluation form.

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


TRP Corp Emergency Response Planning Exercises

Tags: Tabletop Exercise

Severe Weather Projections Require Energy Sector Response Planning

Posted on Thu, Oct 15, 2015

According to an October 2015 report by the Department of Energy, the US energy infrastructure may not be able to withstand projected extreme weather changes associated with temperatures, precipitation, hurricanes, wildfire, and sea-level rise. Infrastructures were designed to perform across a known range of historical conditions. However, record breaking climate conditions that fall outside historical parameters have the potential to expose new vulnerabilities and stress the US energy infrastructure. As a result, it is imperative that companies ensure preparedness and response planning initiatives that reflect a new range of potential risks and climatological threats.

The private sector, which owns and operates the majority of energy assets in the US, holds central responsibility for identifying and implementing appropriate measures to ensure infrastructure resilience, continuity, and response. “In recent years, record temperatures, droughts, and floods have damaged energy infrastructure and disrupted energy systems, affecting American families and businesses across the country,” said Energy Secretary Ernest Moniz. The report highlighted the following major energy systems and susceptible locations that have the potential to be affected by regional climate impacts:

  • Oil and gas upstream operations are most vulnerable in the Southeast, Southern Great Plains, and Alaska, particularly to decreasing water availability, and increasing temperatures and frequency of intense storms, hurricanes and storm surge.
  • Fuel transport in every region is vulnerable to a variety of climate impacts, including increasing heavy precipitation, heat waves, drought, hurricanes, and sea level rise-enhanced storm surge.
  • Thermoelectric power generation is vulnerable to increasing temperatures and reduced water availability in most regions, particularly in the Midwest, Great Plains, and southern regions.
  • Hydropower is vulnerable to reduced snowpack, earlier melting, and changes to precipitation and runoff patterns, mainly in western regions.
  • Bioenergy crops in the Midwest and Northern Great Plains may be harmed by higher temperatures and more frequent droughts and floods.
  • Electric grid operations and infrastructure in every region is vulnerable to a variety of climate impacts, including increasing temperatures, heavy rainfall events, wildfire, hurricanes, and storm surge.
  • Electricity demand is affected by increasing temperatures and is a key vulnerability in nearly every region.

Projected Climate Impacts on US Energy Sector by Region

Source: U.S. Department of Energy, Office of Energy Policy and System Analysis 

With the potential for more frequent and severe disruptions, preparedness and response planning measures should be reviewed. At a minimum, the following severe weather measures should be included in a site-specific preparedness program:


Establish, verify, and exercise communication plans:
  • Verify contact details and identify communication procedures with employees, emergency personnel, critical business unit leaders, and contractors in the event of an emergency
  • Establish response plans in a portable format that can accessed through a variety of methods
  • Verify availability and viability of communication equipment
  • Monitor and determine applicable response procedures based on radio, television, and/or weather reports

Establish, verify, and exercise resource management and supply chain measures:

  • Coordinate activities with local and state response agencies
  • Evaluate equipment needs
  • Pre-select alternate resources to ensure necessary response equipment is available when needed
  • Pre-select alternate delivery of critical needs in the event primary suppliers are not able to provide required services such as:
    • Electrical power
    • Water
    • Fuel
    • Telecommunications
    • Transportation
    • Staffing
    • Waste Management
    • Operations-specific equipment

Establish, verify, and exercise personnel roles and responsibilities:

  • Conduct site specific awareness training, including facility evacuation routes and shelter in place procedures
  • Identify employees that should remain on-site (if deemed safe), and their responsibilities.
  • Identify necessary minimum staffing levels and assignments necessary for recovery operations.
  • As the storm passes, ensure staff, contractors, and suppliers understand their individual responsibilities and recovery time objectives.
  • Train employees to recognize, report, and avoid hazardous chemicals discovered during debris clean up.
  • Ensure that key safety and maintenance personnel are thoroughly familiar with all building systems, such as alarms, utility shutoffs, elevators, etc.

Infrastructure-related RESPONSE MEASURES

  • Evaluate building structures, roadways, surfaces, trenches and excavations for damage, stability and safety
  • Inspect the worksite before allowing employees to enter
  • Report hazards such as downed power lines, frayed electrical wires, or gas leaks to the appropriate authorities
  • Assume all wires and power lines are energized
  • Beware of overhead and underground lines, especially when moving ladders or equipment near them
  • Utilize a site plan for collection of debris
  • Inform employees where debris is being collected and deposited of any special hazards they may encounter during recovery efforts
  • Be aware of possible biological hazards
  • Use flaggers, traffic cones and highway channeling devices to steer traffic away from hazards and employees working along roadways
  • Provide traffic flow details and train employees to stay clear of all motorized equipment.
  • Provide radio equipment and extra batteries to all spotters and equipment operators, so warnings can be communicated
  • Utilize point of contact for employees check in procedures
  • Freeze all computer system updates so that systems will not be damaged by electrical surges
  • Ensure employee safety
    • Before engaging in strenuous tasks in extreme temperatures, consider employee's physical condition, weather factors, and the nature of the task.
    • Wear long pants, a long-sleeved shirt and sturdy shoes when examining walls, doors, staircases and windows for damage
    • If applicable, provide all employees with personal protective equipment (PPEs), including hard hats, safety glasses, work boots, and gloves
Preparedness and Emergency Management - TRP Corp

Tags: Facility Response Plan, Extreme Weather

The Corporate Incident Response Process and Action Plan

Posted on Thu, Oct 08, 2015

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

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

The Response Process 

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

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

4. Demobilization/Post Incident Review

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

The following should be considered in an Incident Action Plan:

Operational Period Goals and Objectives:

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

Response Strategy:

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


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

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

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

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Incident Action Plan, Response Plans

El Nino, Extreme Weather, and Corporate Emergency Preparedness

Posted on Thu, Oct 01, 2015

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

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

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

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

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

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

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

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

Severe weather emergency response plans

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

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

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

Preparedness and Emergency Management - TRP Corp












Tags: Extreme Weather

Deficient Stormwater Pollution Prevention Plan Results in Fines

Posted on Thu, Sep 24, 2015

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

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

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

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


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

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

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

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

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

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

Regulatory Compliance with TRP Corp