Are Your Plans Smart Enough?

The Importance of Response Plan Training for the First Responder

Posted on Thu, Jan 22, 2015

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

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

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

Initial Response Actions:

  1. Warn others in the immediate area through verbal communication and/or activate local alarms.
  2. Take immediate personal protective measures (PPE, move to safe location, etc.).
  3. Report the emergency to Security or 9-1-1, depending on company policy.
  4. Implement local response actions (process shutdowns, activate fire protection systems, etc.) if safe to do so, and consistent with level of training and area specific procedures.

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

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

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

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

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

  • What hazardous substances are, and associated risks during an incident
  • The potential outcomes associated with an emergency when hazardous substances are present
  • Ability to recognize the presence of hazardous substances in an emergency
  • Ability to identify the hazardous substances, if possible
  • The role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook
  • Ability to realize the need to make appropriate notifications for additional resources

The Operations Level: Operations level responders meet and exceed the competency level of the awareness responder. Operational responders are trained to respond in a defensive fashion without actually trying to terminate the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.

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

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

  • Basic hazard and risk assessment techniques
  • How to select and use proper personal protective equipment
  • Basic hazardous materials terms
  • How to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit
  • How to implement basic decontamination procedures
  • The relevant standard operating procedures and termination procedures

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

TRP Corp Emergency Response Planning Exercises

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

Falling Oil Prices Should Not Compromise Compliance and Response Planning

Posted on Thu, Jan 15, 2015

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

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

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

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

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

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

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

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

Regulatory Compliance with TRP Corp

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

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

Posted on Thu, Jan 08, 2015

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

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

Compliance

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

Risk Assessment

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

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Supply Chain

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

Training

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

Response Elements

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

Documentation

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

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

 

Ensure preparedness and compliance! Download this free guide by clicking the image below:

Preparedness and Emergency Management - TRP Corp

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

TRP's Top 10 Preparedness Blogs of 2014

Posted on Tue, Dec 30, 2014

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

Our “Top Ten” 2014 blog articles Include:

10. Preparedness, Planning, and Pandemic Plans 

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

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

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

8. Incident Response Drills and Tabletop Exercises 

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

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

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

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

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

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

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

Response Planning to succeed

4. Corporate Emergency Preparedness and Risk Management 

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

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

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

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

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

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

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

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Tags: Emergency Management, Emergency Management Program

Corporate Crisis Management Plans and Team Roles

Posted on Thu, Dec 18, 2014

Corporate crises come in a variety of forms, ranging from social media glitches to mass casualty situations. Regardless of the circumstances, every crisis has the potential to negatively impact a company’s short and long-term reputation, daily operations, and financial performance. Resolutions require a prepared crisis management plan with flexible, yet pre-identified responses and actions. Informative communication and proactive, actionable procedures can minimize the impacts associated with corporate crises.

“It takes 20 years to build a reputation and five minutes to ruin it. If you think about that, you’ll do things differently”. -Warren Buffett

A properly developed and implemented crisis management plan can result in:

  • Crisis resolution
  • Continuation of business as usual
  • A preserved, or possibly enhanced corporate reputation
  • Financial sustainability

It is critical that a basic crisis management planning framework, response measures, and communication strategies be established and exercised before a crisis actually occurs. Most successful responses result from a prepared strategy, with a cooperative understanding of the incident, response roles, and assigned responsibilities. Since each crisis is unique and comes with varying degrees of impact, each crisis must be evaluated and resolved individually based on:

  • The potential impact on current and potential clients and customers
  • The potential impact to employees and the company
  • Stakeholders interested in the outcome of the incident
  • The level of control the company has over the situation
  • Complexity of the crisis and specialists required

A crisis management team (CMT) may be activated for any situation that involves a threat to people or property, a business interruption that could have a negative financial impact, or an incident that may result in damage to the company's reputation and/or financial well being. CMTs, often comprised of a small group of senior managers, typically respond, coordinate, and set necessary actions in play according to the specific crisis situations. The team members should be trained to manage an array of potential crises, additional risks and exposures, and management stakeholder interests.

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Depending on the crisis planning and crisis management requirements, the following CMT roles may provide a company with the essential functions necessary to manage crisis situations.

  • Crisis Manager: Approves the Crisis Management Plan and provide overall leadership
  • Security Manager: Reviews and revises the plan on necessary security related procedures
  • Public Affairs Advisor: Participates in all aspects of Crisis Communications
  • Medical Advisor: Assess and assists in human health impacts of crises
  • Human Resource Advisor: Maintains a current, accessible contact list of all employees, contract employees, and responders
  • Health, Safety, Security, and Environmental Advisor: Coordinates the implementation, training, and updating of Incident Response Plans
  • Legal Advisor: Ensures the availability of legal representative related to crises
  • Crisis Management Advisor: Supervises and coordinates necessary CMT support roles.  Individuals may be assigned to work directly under any core CMT position to fill a specific need. Support roles may include:
    • Aide(s): Administrative resource(s)
    • Business Unit Advisor(s): Anticipates Business Unit issues, develops strategic plans to proactively address these issues, and adjust staffing of Business Unit Group and to suit evolving needs
    • Subject Matter Expert(s): Be available to assist crisis manager on as “as needed” basis.

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

While the specific circumstances will define a crisis response strategy, basic communications processes typically remain consistent. Companies must be tuned into the vast digital network of social chatter. Viral rumors and antagonistic communications can often be inhibited with a timely, factual, and proactive crisis communications campaign.

For a free download on crisis management, click here or the image below:

TRP Corp - Emergency Response Planning Crisis Management

Tags: Resiliency, Crisis Management, Facility Management, Event Preparedness

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:

TRP Corp Emergency Response Planning Exercises

 

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:

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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.

For a free download on Best Pratices for Crisis Management, click the image below:

TRP Corp - Emergency Response Planning Crisis Management

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".

Preparedness and Emergency Management - TRP Corp

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

Preparedness and Emergency Management - TRP Corp

Tags: Business Continuity, Event Preparedness, Extreme Weather