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Managing The Key Resources of Industrial Business Continuity Plans

  
  
  

Emergency management is continually evolving. The changing threat environment, including acts of nature, accidents, infrastructure weaknesses, cyber security attacks, and terrorist related incidents, coupled with tightly intertwined supply chains, has increased the urgency to revamp emergency management and business continuity efforts.

Building business continuity and emergency response plans to maintain personnel safety, and protect and restore operations is vital. Companies continue to develop and improve upon existing processes to seamlessly aid in managing risk and the rapid restoration of operational processes. However, with ever-changing threats, multiple sites, and human resource variables across an enterprise, most companies find it challenging to develop and maintain accurate and realistic business continuity plans (BCPs).

While the planning process may be executed with in-house staff, some companies prefer to use seasoned consultants for impartial critical process evaluations and experienced guidance. Consultants should have hands-on experience in business continuity and disaster preparedness. Specialized consultants may offer web-based, database driven platforms that incorporate site-specific business continuity information while streamlining company formats across an enterprise. The web-base option eases maintenance efforts and reduces administrative costs associated with managing BCPs. However, consultants must be able to comprehend core business needs and clearly communicate recommendations in order to successfully develop a customized, site specific, and functional BCP.

According to FEMA, the ability to perform essential functions lies within four key resources.

  • Leadership
  • Staff
  • Communications and Technology
  • Facilities

Site-specific information must be applied to the key resources. It is necessary for continued operation to evaluate and identify alternate site-specific resources that may be utilized during an incident.  If one or more of the key resources are lost, critical business processes may be affected. Keep in mind that any new business operations that may have developed also need to be included in these evaluations.

Leadership

Business Continuity Coordinators (BCCs) are typically responsible for the development and maintenance of business continuity plans. They must work closely with critical business units to understand their processes, identify risks, and provide solutions to help manage and minimize those risks. However, once an incident occurs, the BCCs must communicate, manage, and control activities associated with damage assessments and the recovery of critical business functions. Depending on the enterprise, a BCC may be assigned to an individual facility or a specific geographic location that encompasses numerous facilities with like-operations.

The BCC, in conjunction with the Incident Commander, may be tasked with activating and coordinating organization elements in accordance with an incident action plan.  By working with the appropriate business unit leaders assigned to business continuity/recovery plans, the BCC can also provide guidance for compliance with Incident Action Plan (IAP) components.

Business Continuity Leadership - TRP

Staff

The BCP should systematically guide specifically assigned personnel to restore operations that are affected by abnormal conditions. It is critical to identify the implications of a sudden loss for each business unit or necessary resource by performing a business impact analysis. While critical process evaluations can determine operational dependencies that are required to maintain normal operations, staff must be trained to carry out the BCP objectives. BCP training and exercises should occur (at a minimum) on an annual basis, or as required by regulations or company policy.

A BCP should identify the minimum staffing levels necessary to remain operational. As recovery advances, staffing levels may require adjustments. Depending on the scenario, the least critical process participants might have to vacate the facility while leaving critical players in motion to maintain or restore necessary functions. Companies should ensure staff, contractors, and suppliers understand their initial and adjusted responsibilities, and recovery time objectives.

Communications and Technology

Clear and effective communication channels and critical technologies must be available in order to disseminate information to employees, assess and relay incident updates, and implement necessary recovery strategies. As part of the business continuity mitigation process, companies should evaluate available communication equipment, mass notification systems, and technology storage and backup processes to ensure accessibility and functionality in multiple business continuity scenarios. All critical communication and technology should be included in a BCP with detailed recovery procedures and recovery time objectives.

Facilities

Facility management should be a crucial aspect of a business continuity plan. If an area or facility cannot sustain minimum service or operational levels, companies should mobilize resources, and/or relocate equipment and personnel to alternate areas, facilities, or redundant sites. If deemed acceptable, this may include  “working from home” strategies. In order to respond quickly and effectively to facility damage, BCPs should include predetermined suppliers/contractors (tree services, plumbers, electricians, restoration companies, and/or necessary skilled trades and suppliers).

For a free download on Designing a Crisis Management Program, click the image below:

TRP Corp - Emergency Response Planning Crisis Management

 

Expert Insight on Incident Response Drills and Tabletop Exercises

  
  
  

There are various types of types of emergency response drills and exercises that target specific goals. They can range from small group discussions to complex, multi-faceted exercises. But each drill or exercise presents the opportunity to improve site-specific response plans, rendering the potential for a more effective response.

Response plan testing can begin with simple exercises intended to validate general response plan comprehension or incorporate an all-inclusive, full-scale, realistic, multi-scenario exercise. Managers should determine the goals of the exercise before settling on a particular method. To fully execute a response plan, synergistic drills or exercises should be developed to assess the following critical response skills:

  • Communication
  • Training
  • Resource management
  • Teamwork

An exercise should prepared employees and responders to minimize the impacts of an incident. Below are three of the most basic exercises.

1. Orientations: The purpose of an orientation is to familiarize participants with roles, responsibilities, plans, procedures, and equipment. Orientations can resolve questions of coordination and assignment of responsibilities. The inclusion of first responders and facility staff promotes the development of an effective plan.

2. Drills: The goal of a drill is to practice aspects of the response plan and prepare teams and participants for more extensive exercises in the future. A drill can test a specific operation or function of the response plan.  Facilities should conduct evacuations, shelter in place, and lockdown drills to demonstrate emergency response actions. Drills can be altered to incorporate various scenario situations. The procedures, individual responsibilities, and public safety coordination may be addressed depending on the presented scenario or outcome of the drill.

emergency response drill - TRP CORP

3. Tabletop Exercises: A tabletop exercise simulates an emergency situation in an informal, stress-free environment.  The participants, usually comprised of decision-making level staff and responders, gather to discuss simulated procedures and general problems/solutions in the context of an emergency scenario.  The focus is on training and familiarization with roles, procedures, and responsibilities relative to the emergency synopsis and potential injects.

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 timeframe (not real-time). Events should move rapidly through the phases of the exercised response. However, it should be clearly understood that under real conditions the same events or actions might require additional time to complete. Conversely, real world scenarios can quickly change and transition from a basic emergency to a full scale crisis within a short time frame that require rapid decision making and expeditious responses.

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. A web-based drill and exercise management tool can streamline the distribution of these tools.

Weather Conditions: Depending on the scenario and if the weather is a critical factor, either real or simulated weather conditions may be utilized during the exercise.

“This is a Drill” Exercise Communications: All radio, telephone, fax 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, including report forms, fax communications, and press releases. It may be helpful to add the date to any written documentation for organizational and regulatory compliance purposes.

Communications with external agencies, contractors, medical responders, or other parties not participating directly in an exercise must begin and end with the statement, "This is a Drill". This may involve state or federal regulatory notifications or contact with suppliers or vendors to source simulated logistical needs. In all cases, exercise participants must ensure that the all involved parties clearly understand that no actual emergency exists, and no resources or equipment should be mobilized or dispatched.

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

Injects: Injects may be provided to some participants or as a component of the exercise. An inject describes an additional event or circumstance that requires a 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. Feedback should be evaluated for potential response plan mitigation opportunities.

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

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

 

Tips for Facility Security Planning and Training

  
  
  

Managing the Facility Security Plan (FSP) related administrative duties and associated training requirements can be time-consuming and complex, particularly for large companies. With multiple, dynamic, and security-related response planning variables, many large companies implement a response planning system with a training and exercises management component. Advanced web-based systems can ease the burdens of training documentation, scheduling, and maintenance while verifying regulatory compliance. Managing an enterprise-wide security training program can be complicated by:

  • Multiple fluctuating certification/expiration dates
  • Diverse and varying scope of responder/employee responsibilities
  • Site-specific operations and response objectives
  • Maintaining company standards and best practice priorities
  • Regulatory compliance measures
  • Multiple facilities across several locations
  • Employee turnover

A FSP and those facilities required to comply with U.S. Coast Guard’s (USCG) 40 CFR 105 regulation should include site-specific details on the following components:

Notification: The Facility Security Officer must have a means to effectively notify facility personnel of changes in security conditions at a facility. Transportation security incidents are reported to the National Response Center and to appropriate emergency responders. At each active facility access point, a system must be in place to allow communication with authorities with security responsibilities, including the police, security control, and the emergency operations center.

Fencing and monitoring: The FSP must describe security measures to prevent unauthorized access to cargo storage areas, including continuous monitoring through a combination of lighting, security guards, and other methods.

Evacuation: The owner or operator must identify the location of escape and evacuation routes and assembly stations to ensure that personnel are able to evacuate during security threats.

Assessment: The Facility Security Assessment requires description of the layout of the facility, and response procedures for emergency conditions, threat assessment, and vulnerabilities, with a focus on areas at the facility that may be vulnerable to a security threat, such as utility equipment and services vital to operations.

facility security plan - TRP CORP

Training: A security plan should describe the training, drills, and security actions of persons at the facility. These actions should deter, to the maximum extent practicable, a transportation security incident, or a substantial security threat. If a facility is required to comply with §105.210, facility personnel with security duties must be trained in the following: (Note: These guidelines are also beneficial to facilities not required to comply with the USCG’s 40 CFR part 105 requirement)

  • Knowledge of current security threats and patterns
  • Recognition and detection of dangerous substances and devices
  • Recognition of characteristics and behavioral patterns of persons who are likely to threaten security
  • Techniques used to circumvent security measures
  • Crowd management and control techniques
  • Security related communications
  • Knowledge of emergency procedures and contingency plans
  • Operation of security equipment and systems
  • Testing, calibration, and maintenance of security equipment and systems
  • Inspection, control, and monitoring techniques
  • Relevant provisions of the FSP

Proper documentation is a critical aspect of any emergency management program. If a facility is required to comply with the USCG’s 40 CFR part 105 regulations, certain documentation is required to be available at the facility and made available to the USCG upon request. A web-based planning system can ensure plan documentation is available from various locations and can expedite plan distribution. The USCG’s 40 CFR 105 requires the following documentation:  

  1. The approved FSP, as well as any approved revisions or amendments thereto, and a letter of approval from the COTP dated within the last 5 years.
  2. The FSP submitted for approval and an acknowledgement letter from the COTP stating that the USCG is currently reviewing the FSP submitted for approval, and that the facility may continue to operate so long as the facility remains in compliance with the submitted FSP.
  3. For facilities operating under a USCG-approved Alternative Security Program as provided in §105.140, a copy of the Alternative Security Program the facility is using, including a facility specific security assessment report generated under the Alternative Security Program, as specified in §101.120(b)(3), and a letter signed by the facility owner or operator, stating which Alternative Security Program the facility is using and certifying that the facility is in full compliance with that program.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

 

How to Manage Preparedness Training for Multiple Downstream Facilties

  
  
  

Luck runs out, but safety is good for life.  ~Author Unknown

Whether an industrial facility is domestically located or abroad, ensuring compliance, employee safety, and an effective response requires a comprehensive training and exercise program. All training and exercise components within a corporate enterprise should address site-specific operations, appropriate response processes, standardized company-wide best practices, and maintain location-specific regulatory compliance.

The challenge of managing and ensuring compliant training programs for multiple facilities and various regulatory agencies is complex. Certification efforts, enforcement mandates, and costly non-compliance fines may result from the lack of implemented, thorough, or effective programs. By utilizing available technology to manage an enterprise-wide training approach, companies can verify compliance and response readiness through a cohesive, yet site-specific standardization of best practices.

Through proper maintenance of a training portal, individuals will remain at peak optimal response capabilities. Training should include, but not be limited to:

  • Response plan familiarization
  • Individual roles and responsibilities
  • Plan review training whenever a substantial change or revision is made to the plan that affects organization, procedures, roles and responsibilities, or response capability.
  • Refresher courses, as necessary

Mid to large size companies should implement a preparedness and response training management system with the ability to identify and sort specialized data. When a company has multiple facilities, a centralized web-based database of scheduled, lapsed, and completed training enable facility managers to focus their efforts on operations and profitability. With a comprehensive, web-based, database-driven training management system, emergency managers and health, safety, and environmental departments can:

  1. Simplify training reviews
  2. Easily identify training inception and expiration dates
  3. Verify responder knowledge and ensure employee accountability
  4. Identify regulatory compliance training gaps
  5. Account for preparedness endeavors and associated costs
  6. Ease maintenance and administrative efforts

Training management System - TRP CORP

For companies looking to systematically manage the training and development of their staff, an enterprise-wide training management system is critical. Managing several disparate systems and multiple paper files is cumbersome and time consuming. Maintaining training information in a single, consolidated system provides significant benefits. A web-based training management system provides authorized users with secured access from a variety of locations. As facilities are added or modified, operations are revised, or employees are re-assigned, training records can be conveniently added, accessed, transferred, or updated for accuracy and compliance. A comprehensive, web-based training management system will:

  • Reduce the need for multiple site training management and documentation
  • Minimize administrative costs
  • Minimize training discrepancies across an enterprise
  • Provide a historical record of training certifications
  • Streamline training directives from one source
  • Serve as a legal instrument, if necessary
  • Engage management in prioritizing preparedness efforts
  • Enhance reporting functionality
  • Identify regulatory compliance training gaps

Training administration can be time-consuming and difficult, particularly in medium to large companies with staff employed in different roles across a variety of physical locations. A customized training management system can streamline this administrative effort, making it easy to ensure staff members receive the appropriate training, and instructors are supported with the necessary resources. A comprehensive system can

  • Track and report training completion or status by discipline, skill, position, individual, location, or over a specific time period
  • Generate summary reports that provide a snapshot of various mandated training versus completed and scheduled events
  • Print automated certifications and wallet cards

Advanced web-based technologies can also facilitate online training and provide classroom resources. While it is not essential to implementing web-based training, it can reduce costs associated with classroom instruction.  Some web-based training solutions include tools to share critical training information and lesson plans with students, reducing the time required to duplicate and distribute training materials across an enterprise.

While optimizing training is critical for regulatory compliance and safety, cost is always a deciding factor. Implementing a customized training management system in highly regulated environments is a proactive, cost-savings measure that can reduce the overall costs associated with incidents, training maintenance, and non-compliance.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

 

Documenting Oil and Gas Emergency Response Drills and Exercises

  
  
  

Amidst the business of sustaining profitable operations, oil and gas companies must ensure that work conditions are safe. Oil and gas operations have innate risks, hazards, and, in the event of a release or spill, potential detrimental impacts. As a result, regulatory agencies require response drills and exercises that adequately reflect the current operations and emergency response capabilities.

The National Preparedness for Response Exercise Program (PREP) is designed to facilitate the periodic testing of oil spill response plans for certain vessels and facilities, and provide companies an economically feasible mechanism for exercise compliance. This unified federal effort provides a consistent set of guidelines that satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline Hazardous Material Safety Administration (PHMSA), and the Bureau of Safety and Environmental Enforcement (BSSE). Completion and documentation of the PREP exercises satisfies all OPA 90 mandated federal oil pollution response exercise requirements.

Drill frequency and specific requirements vary depending on operations, vulnerabilities, facility location, and site hazards. However, documentation of oil and gas emergency preparedness drills and exercises is mandated by various regulatory agencies. Thorough documentation also:

  • Identifies deficiencies and mitigation opportunities
  • Provides a historical record of the event
  • Engages management in preparedness efforts
  • Serves as a legal instrument, if necessary
  • Ensures training accountability
  • Accounts for preparedness efforts and plan maintenance cost

Oil and Gas Emergency Response Planning - TRP

In order to satisfy the PREP requirement, oil and gas companies must be able to document all operational and support aspects of a response, and provide detailed records of decisions and actions taken. An exercise tracking system that is integrated into an overall response planning system can minimize the documentation efforts associated with drills and exercises. A tracking system should:

  • Improve regulatory compliance with thorough documentation·
  • Provide a tool for scheduling exercises, and documenting PREP objectives, exercise objectives, lessons learned, scenarios, and action items.
  • Provide a tool for developing exercise final reports and a method of assigning and tracking outstanding action items to improve follow-up.
  • Provide a reporting mechanism to track PREP objectives completed during any 3 year cycle, outstanding action items, and a summary report by facility that indicates progress in meeting PREP exercise requirements.
  • Provide a “snapshot” of exercises completed for the year for every facility via a summary report.

To ensure employees and identified essential response personnel are prepared to respond to an incident in an efficient and effective manner, oil and gas companies should establish minimum exercise guideline requirements. Management should ensure that:

  • All aspects of response plans are exercised at least once per year with the appropriate response, incident management, and support teams taking part.
  • Notification exercises for Qualified Individuals are conducted on a quarterly basis. This exercise should involve unannounced checks of the communication processes, and systems.
  • National and local training and exercise requirements should be used to assess the overall integrated preparedness of a response with the authorities.

If not physically present during a drill and/or exercise, the final documentation from the events can be submitted to local responders or fire marshals for review. If a web-based planning system is utilized, drill and exercise documentation can be securely shared and accessed by approved stakeholders. In the event of an actual incident, the lessons learned from these drills and exercises can minimize impacts and prevent further consequences.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

 

Expert Insight on Emergency Response Tabletop Exercises and Scenarios

  
  
  

Emergency response training simulations are an integral part of a sound emergency management program. Exercises offer training opportunities for responders to strengthen their capacity for responding to various site-specific emergencies. By facilitating different types of drills and exercises, facilities can identify the appropriate methods for preventing, preparing for, responding to, and recovering from crises.

Real world exercise scenarios can often highlight potential deficiencies in response plans, individual comprehension of response roles and responsibilities, and partnership coordination efforts. Deficiencies often reveal mitigation opportunities and valuable response knowledge that can be applied to response plans and an actual emergency response situations.

There are various types of emergency drills and exercises for response training and planning validation. Companies can test response plans with simple orientations and drills, and work their way toward full-scale exercises, inclusive of multiple components and coordinated efforts.

A tabletop exercise is one of the simplest type of comprehensive exercises to conduct in terms of planning, preparation, and coordination. It should facilitate analyses of an emergency situation and the most effective processes to respond and recover. The informal, stress-free environment should be designed to prompt constructive discussions about existing emergency response plans as participants identify, investigate and resolve issues. The success of the exercise is mainly determined by the identification of problem areas, and applying applicable corrections.

These exercises should replicate realistic and site-specific emergency scenarios that allow participants to increase their awareness of roles and responsibilities required to respond, stabilize, terminate, and recover from emergencies. In preparation for these exercises, companies should develop exercise planning documents, including participant's and controller’s packages that contain exercise objectives, scenarios, ground rules, and simulation scripts. These guidelines, at a minimum, should be provided to all participants prior to the exercise to allow for a thorough examination of exercise expectations. A training and exercise management system can streamline and simplify the documentation and administrative duties associated with exercises planning.

tabletop exercise - TRP Corp

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 plans
  • Action item identification
  • Operational response capabilities
  • Personnel preparedness to respond to incidents, regardless of the threat or hazard

The Department of Homeland Security addresses four types of exercise scenarios used in risk management and emergency planning:

1. Basic Scenario:  Provides basic information about one specific variable or risk, such as internal or external hazard, attack type, or potential target. Scenarios can be used to establish response parameters and instructions based on a singular applicable variable (Ex: tank 101 fire or leak at a loading dock).

2. Narrative Scenario: Story-like, highly detailed scenarios with many fixed factors. Narrative drills are typically used for planning purposes rather than risk analysis. Narratives identify characteristics of a scenario, detailed background information, and each components of the scenario.

3. Visual Modeling:  Highly structured scenarios that display multiple potential variables of an emergency situation. Depending on the level of detail, visual models can become highly comprehensive and complex. The Department of Homeland Security identifies three methods of visual planning: attack paths, fault trees and event trees.

Attack paths: A systematic method that examines the sequence of events that occurred prior to the incident.

Fault trees: A detailed, deductive tool is used to assess the ill-fated sequence of events that led to the incident. A fault tree highlights potential hazards and ineffective processes.

Event trees: Assess the components it takes to respond and recover from an incident. Event trees highlight the necessary planning initiatives required to counteract the incident.

4. Future Scenario: Speculative narratives that consider how trends, such as social media usage or global warming, will impact future risks. This scenario can to identify “future-state” planning strategies against a range of alternative risk possibilities.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

 

 

Compliance Tips for Industrial Emergency Management Exercise Programs

  
  
  

The National Preparedness for Response Exercise Program (PREP) is a unified federal effort established to provide a consistent set of guidelines that satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline and Hazardous Materials Safety Administration, and the Bureau of Safety and Environmental Enforcement in an economically feasible manner.

The intent is to create a workable exercise program which meets section 4202(a) of the Oil Pollution Act of 1990 amending section 311(j) of the Federal Water Pollution 6 Control Act, by adding a new subsection for spill response preparedness (33 USC 1321(j)(7)). Facilities and vessels required to adhere to these regulations must establish a compliant exercise program to ensure an adequate response to an oil spill.

Plan holders may develop a customized exercise program based on site operations or utilize the PREP exercise guidelines. The program must comply with the appropriate Federal oversight agency and regulatory exercise requirements. In order to maintain PREP compliance, all core components of a response plan must be exercised every three years. However, it is not required to conduct a major exercise every three years. PREP compliance can be obtained by exercising individual components within in a three-year cycle. The exercises must incorporate the following core PREP components:

  1. Notifications
  2. Staff mobilization
  3. Ability to operate within the response management system described in the Plan
  4. Discharge prevention/control
  5. Assessment of discharge
  6. Containment of discharge
  7. Recovery of spilled material
  8. Protection of sensitive areas
  9. Disposal of recovered material and contaminated debris
  10. Communications
  11. Transportation
  12. Personnel support
  13. Equipment maintenance and support
  14. Procurement
  15. Documentation

Exercise Management Program - TRP

Exercises should be designed to test the aforementioned response plan components for effectiveness and accuracy. In order to satisfy the PREP requirement, plan holders must be able to document all operational and support aspects of a response, and provide detailed records of decisions and actions taken. Exercise requirements vary depending on operations. Vessels, unmanned barges, and certain identified facilities each have specific exercise requirements. Generally, the types of exercises required include:

1. Qualified Individual (QI) notification exercises: The purpose of the QI notification exercise is to ensure that the QI (or designee) listed in the response plan will respond as expected and carry out his or her required duties in a spill response emergency. Contact by telephone or electronic messaging must be made with the QI, and confirmation must be received from him or her to satisfy the requirements of this exercise. At least once per year, the QI notification exercise should be conducted during non-business hours.

2. Emergency procedures exercises: The purpose of the emergency procedures exercises is to ensure that personnel are capable of conducting the initial actions necessary to mitigate the effects of a spill. Specific regulations apply to vessels and unmanned barges. USCG and EPA Marine Transportation-Related Facilities have the option of conducting emergency procedures exercises. For the purpose of the PREP, emergency procedures for facilities are the procedures established to mitigate or prevent any discharge or a substantial discharge threat resulting from facility operational activities associated with cargo transfers. An unannounced emergency procedures exercise would satisfy the facility's requirement for the annual unannounced exercise.

3. Equipment deployment exercises: The purpose of equipment deployment exercises is to ensure response equipment is appropriate for the operating environment and that operating personnel are trained in its deployment and operation. It is not necessary to deploy every piece and type of equipment as long as all equipment is included in a periodic inspection and maintenance program. The inspection and maintenance program should ensure that the equipment remains in good working order.

4. Spill Management Team (SMT) tabletop exercises: At least one SMT Tabletop Exercises in a triennial cycle should involve a worst-case discharge scenario. If a response plan lists different types of SMTs for varying spill sizes (ex, a local SMT for small spills, a regional team for larger spills, and a national team for major spills), each team identified should be required to conduct an annual SMT tabletop exercise.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

 

Tips for Managing Corporate Emergency Management Training Programs

  
  
  

The ability to schedule, communicate, develop, document, and deliver training is a critical aspect of your environmental, health, safety and emergency response program. Training familiarizes employees and responders with safety and emergency procedures, equipment, and systems, and can identify deficiencies and mitigation opportunities in emergency response planning programs.

Managing the administrative duties associated with training requirements can be time consuming and complex, particularly for large companies. With the multiple variables associated with training, many large companies implement a training and exercise management system. An emergency response planning system with a training component can ease the burdens of documentation, scheduling, and maintenance. Managing an enterprise-wide training program can be complicated by:

  • Multiple fluctuating certification/expiration dates
  • Diverse and varying scope of responder/employee responsibilities
  • Site-specific operations and response objectives
  • Maintaining company standards and best practice priorities
  • Regulatory compliance measures
  • Multiple facilities across several locations
  • Employee turnover

Accurate and verifiable training documentation enables response plans and procedures to be implemented as intended. Training topics and specialized training includes, but is not limited to:

  • Hazard and risk assessment techniques
  • Selection criteria of proper personal protective equipment
  • Incident reporting
  • Instruction and procedures for using personal protective and emergency equipment
  • Evacuation and alarm procedures
  • Specific roles and responsibilities in according to response scenarios (i.e. fire, explosion, severe weather)
  • An understanding of the role of the first responder in an emergency (i.e.  First Responder Operations Level)
  • 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

Training and exercise administrative requirements may be dictated by company policy, site operations, hazardous material response needs, or governmental agencies. In addition to yearly response plan reviews and scheduled updates; training documentation modifications may be required:

  • After each training drill or exercise
  • After each emergency
  • When personnel or response tasks change
  • When the layout or design of the facility changes
  • When policies or procedures change

HSE training - TRP CORP

Continual administrative duties associated with personnel training documentation may be timely or inadequately performed, jeopardizing regulatory compliance or the sustainability of an optimal emergency management program. Maximizing efficiency through advancements in technology can minimize administrative maintenance time. An enterprise-wide training and exercise management system can:

  • Improve regulatory compliance by comparing actual training dates to required training frequencies
  • Reduces costs by incorporating all training and exercise records and documentation into an existing database already being utilized for your emergency planning system.
  • Provide reporting tools to identify personnel requiring training, generate lists of completed training per person, and  document all training completed.
  • Automatically generate training agenda and certificates  for each scheduled training session
  • Simplify communication to attendees by generating emails regarding training requirement reminders, class agendas,
  • Initiate scheduled training requirement reminders to each facility. A comprehensive system will allow for developing a customized email message that will be automatically sent to a list of personnel for a selected time period (example monthly).

Technology has bolstered the availability and popularity of online training. However, depending on the certification, trainees often must complete corresponding classroom training offered by a local government agency such as the emergency management agency, fire or police department. But regardless of the training format, employers must document certifications and verify site-specific response comprehension.

Companies should require annual site-specific training, and routinely implement unannounced emergency drills and scheduled response exercises. Annual refresher training should cover current industry and in-house emergency operating experience; changes in emergency operations plans, policies, procedures, and equipment; as well as, familiarize employees and responders with response procedures, equipment, and systems. Annual training events can be used as a trigger for discussions and feedback on the company’s emergency management program, drills, and exercises. These discussions often cultivate an environment of safety and preparedness, identify mitigation opportunities, and possibly, training deficiencies.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

 

Expert Tactical Response Plan Tips for Oil and Gas Companies

  
  
  

Maintaining accurate and effective response plans requires due diligence. In the oil and gas industry, response planning for a dynamic worst-case scenario with multiple moving parts and various potential trajectories is an ongoing, yet required challenge. However, utilizing web-based, database driven, standardized tactical plan template enables emergency managers to plan for numerous potential impact zones across vastly diverse terrains with multitudes response obstacles. The hazardous nature of the material spilled, the number of responders involved, and the probable impacts requires a pre-planned, coordinated, and swift response effort. A web-based template format allows secured access for various stakeholders, despite their location, maximizing the planning effort for an effective response.  

Tactical response plans contain numerous geographical fixed response actions for the various off-site tracts in the path of an oil spill. These planning tools assist in the implementation of an overall response strategy by minimizing the potential travel distance of a spill.  The tactical planning process identifies the “how” a downstream response will be implemented at a specific location. When spills migrate off site, it is essential to have plans in place that have been developed in cooperation with those in the potential path of a spill. Communication with downstream counterparts lessens spill response anxieties and promotes company/community partnerships.

Through the planning process, information necessary to achieve a successful response is gathered at each downstream response location. The primary objectives of tactical response plans are to:

  • Allow response personnel to prepare for and safely respond to spill incidents
  • Ensure an effective and efficient response despite geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response
  • Outline response procedures and techniques for combating the spill at a specific location
  • Improve regulatory compliance efforts

Tactical Plans - TRP COrp

Because a single oil spill can have a significant or catastrophic impact on downstream environments, it is imperative for emergency managers to cyclically evaluate response processes and maintain the most up-to-date plan possible. Off-site spill responses and containment efforts present unique challenges compared with those within the confines of a specific facility or secondary containment. Downstream spills require a higher level of coordination and communication in effort to minimize impending impacts. Those challenges include, but are not limited to:

  • Response time must be minimal due to spill flow rate and travel distances
  • Potential substantial equipment deployment
  • Waterway access points
  • Coordination and cooperation efforts with private landowners
  • Consequential costs associated with long-term cleanup activities
  • Extensive damage to marine and wildlife habitats, fishing, and/or tourism industries
  • Potential lawsuits

In the event of an emergency, updated paper plans are typically not available from all downstream locations. Web-based planning system software increases accessibility options while improving efficiency, functionality, and effectiveness. A standardized, enterprise-wide, yet customizable tactical plan template provides necessary data for each response site.  The systematic tactical response plan format should consist of customary response policies and procedures, as well as detailed, site-specific data necessary for an effective response.

Web-based tactical plans can provide a responder’s perspective of specific short-term actions and details that communicate best site access, assessment tools, and response measures. Tactical spill plans should include the following:

  • Various photographs of each segment (including ground and aerial views, if possible)
  • Maps
  • Latitude and Longitude
  • Land/property owner information
  • Driving directions to the site from main roads
  • Description of potential staging area(s)
  • Specific response tactics for the site location
  • Description of site and applicable waterways
  • Site access specifications
  • Necessary security requirements
  • Waterway flow rates and composition
  • Any critical response information that may be informative to responders
  • Recommended equipment and personnel to implement response strategy
  • Other site specific pertinent issues that may hinder a response

 

Challenged with managing preparedness amongst your various facilites? Download TRP's best practices guide on response planning for large organizations with multi-facility operations.

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

 

Managing Multiple Emergency Action Plans: The Template Approach

  
  
  

Enterprise-wide standardization breeds familiarity. Yet, each facility requires customization due to site-specific risks, threats, and emergency response challenges. This continually evolving component of preparedness, response planning, and regulatory compliance complicates the administrative duties associated with maintaining a company’s multiple Emergency Action Plans (EAPs).

Technology, such as a web-based planning system, provides companies with the tools to balance enterprise-wide standardization and site-specific regulatory criteria. Companies responsible for multiple buildings, possibly in various locations, should demonstrate a commitment to emergency management by creating a systematic template for incident response policies, procedures, and practices. Yet, these templates should enable users to incorporate the detailed, site-specific data necessary for an effective response.

While much of the information required in an EAP is site-specific, a template approach ensures regulatory requirements are communicated and pre-approved company protocols are identified. At a minimum, a template for EAPs should include:

  • Procedure(s) for reporting a fire or other emergency
  • Procedure(s) for emergency evacuation, including type of evacuation and exit route assignments
  • Procedure(s) to be followed by employees who remain to operate critical plant operations before they evacuate
  • Procedure(s) to account for all employees after evacuation
  • Procedure(s) to be followed by employees performing rescue or medical duties
  • Contact Information of company/building/site management
  • Alarm system details

The primary goal of an EAP is to protect lives. To establish effective EAPs capable of protecting employees or building occupants, companies should conduct analyses to identify necessary site-specific safety measures, including those required in OSHA’s 29 CFR 1910.38 regulation. Analyses should identify the following details:

1. Site Analysis

  • Identify existing and potential site hazards through employee feedback, audits, and detailed inspections.

2. Task Analysis

  • Determine job specific methods and procedures for each employee’s duty to reduce or eliminate associated hazards.
  • Review and update methods and procedure when an incident occurs, job responsibilities change, or if hazards are identified through analysis.

3. Risk Analysis

  • Establish risk evaluation criteria, probability of incident, and potential consequences.
  • Monitor and review procedures for continuous improvement, effectiveness, control measures and changed conditions.

Emergency Action Plans - TRP CORP

After initial analyses, site-specific EAPs should be developed and shared with building occupants.  Depending on the characteristics of the building, and inherent roles and responsibilities of the occupants, an EAP may be a component of a comprehensive emergency response-planning program.  This inclusive program may include Facility Response Plans and site-specific Fire Pre Plans. Building emergency response plans should include the following minimum information:

●       Building description

●       Owner/Manager contact information

●       Emergency Assembly Point details

●       Internal and/or external emergency personnel information and contact details

●       Specific hazard details and possible MSDS information, if applicable

●       Utility shut-off locations and descriptions

●       Alarm(s) description

●       Emergency equipment inventory and locations

●       Plot plan(s) and floor plan(s)

●       Risk, site and task identified situational checklists and job specific procedures

Emergency management programs, especially those inclusive of multiple buildings, should include health, safety and environmental training to communicate regulatory requirements, site response methods, and other applicable required safety training. EAPs require that companies designate and train employees to assist in the safe and orderly evacuation of other employees. Job and site specific training should be implemented for current employees, new hires, or supervisors that may need to carry out direct reports’ responsibilities.

Safety audits, inspections, task analyses, and incident investigations often identify a need for additional training and/or highlight necessary changes that may apply response plans.  EAPs must be reviewed when:

  • Initial plan is developed
  • A new employee is assigned to the EAP
  • Employee emergency response role or responsibilities change
  • Plan is revised

 

Challenged with managing preparedness amongst your various facilites? Download TRP's best practices guide on response planning for large organizations with multi-facility operations.

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

 

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