In preparedness and emergency management, the concept of risk and hazard identification is fundamental. However, the potential inability to access important documents, particularly during an emergency scenario, is often overlooked. If you experienced a catastrophic loss and could not access these important documents, would you be able to conduct an effective response?
In order to manage risks and build resilience, companies must account for the interdependencies between risks by supplementing traditional risk-management tools with new concepts. Companies should mitigate the risk that an incident may incapacitate access to response plans. Cloud and web-based technology offer enterprise-wide, up-to-date redundancies that traditional record keeping methods cannot provide. With more people owning multiple computing devices such as laptops, tablets and smart phones, the idea of data being restricted to a single desktop computer or binder without adequate redundancies seems antiquated.
To counteract potential incidents, fallout vulnerabilities, and regulatory noncompliance, response plans should be shared with and accessible to regulators, auditors, inspectors, and responders. Having up-to-date information readily available to trained responders has been proven to limit the duration of the emergency. The faster responders can locate, assess, access, and mitigate the emergency, the sooner an incident can be contained. However, in order to minimize additional vulnerabilities, applicable data and confidential information should be secured.
A recent survey conducted by IT industry association CompTIA, found that more than 90% of companies use or have transitioned to some form of cloud technology in order to increase flexibility and reduce costs. However, the report revealed that only 48% of those surveyed utilize cloud-based methodology for business continuity/disaster recovery processes. When authorized users can access response plans information from any location, response expertise can be maximized and maintenance efforts can be shared.
In the event of an emergency, up-to-date paper plans may not be available from other locations. Although some companies post electronic plans to their intranet that can be accessed remotely, the process of updating these plans is time-consuming and inefficient. In addition, if a catastrophic event occurs, there is the possibility that the main data source or server will be inaccessible.
When an incident is isolated to a particular location, cloud or web-based response plans can enable response measures on a company-wide scale. Cloud or web-based plans can also provide hyperlinks, forms libraries, simplified interfaces, and other tools designed to improve functionality for plan users.
But with any data system, redundancy and back up efforts are essential. In the event Internet connectivity is terminated or inaccessible, emergency managers must have alternative means to access plans. Redundant data centers, scheduled download, and security measures must be a part of any web or cloud based emergency management program
Just as fire extinguishers and inclusive fire drills can maximize safety in a fire emergency, response plan accessibility and exercises a fundamental to the success of a response. From industrial facilities to multi-story office buildings, enabling first responders to have a working knowledge of site-specific responses and available equipment prior to an actual emergency is critical to the safety of the occupants.
When first responders can exercise approved response processes and procedures, responses can become second nature. Plan accessibility allows appointed responders to clarify critical contact information and responses to altered site circumstances, operations, or materials. Inaccessible response plan can facilitate confusion, inconsistency, and potentially accelerate impacts and financial loss.
As technology dependencies become more ingrained in company operations and emergency management programs, it is essential to institute company-wide best practices for computer security, downloads, and backups in order to secure necessary technologies and communications networks. Cyber exercises allow stakeholders to simulate real-world situations, to improve communications and coordination, and to increase the effectiveness of broad-based critical infrastructure protection capabilities without the consequences of real cyber event. These specific exercises educate employees on technological policies and provide a means to evaluate cyber incident preparedness, mitigation, response, and recovery capabilities.
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Regulatory non-compliance has proven to be expensive, time-consuming, and potentially dangerous to company employees and the surrounding communities. As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, companies may be required to develop, maintain, and submit an approved Facility Response Plan (FRP) and/or a Spill prevention, Control, and Countermeasures Plan (SPCC).
If government regulations are applicable to operations, companies need to prioritize response plan compliance in order to minimize fines, negative public perceptions, and potential government mandated shutdown of operations. A compliant and exercised response plan can be the foundation to an efficient preparedness program.
By systematically aligning emergency plans and their components with corresponding regulations, companies can identify and amend plan deficiencies. Response plan compliance can be improved by the following:
- Evaluate regulatory applicability across all company operations
- Perform audits or gap analysis of response plans against regulatory requirements
- Identify new planning requirements as regulations evolve
- Maintain up-to-date plans that reflect facility, personnel, or operational changes
- Exercise plans to ensure plan accuracy
- Confirm regulatory response plan submittal requirements
Determining response plan requirements for each facility will determine the site-specific information required by the corresponding regulatory agency. A “substantial harm” facility is a facility that, because of its location, could reasonably be expected to cause substantial harm to the environment by discharging oil into or on navigable waters or adjoining shorelines. These facilities are required to develop, maintain, and submit a facility response plan.
“Certain facilities that store and use oil are required to prepare and submit facility response plans to respond to a worst case discharge of oil and to a substantial threat of such a discharge.” - EPA
In addition to maintaining a site-specific plan, an FRP mandated facility must keep a log of response training drills and exercises, along with plan updates reflecting material changes. Records of inspections of response equipment must be kept for five years. If response-planning requirements under 40 CFR 112.20 are not applicable, a facility must complete the certification form in 40 CFR Part 112 Appendix C Attachment C-II.
According to EPA, key elements of an FRP should include:
- A stand alone Emergency Response Action Plan
- Facility name, type, location, owner and operator information
- Emergency notification, equipment, personnel, and evacuation information
- Identification and evaluation of potential spill hazards and precious spills
- Identification of small, medium and worst case discharge scenarios and response actions.
- Description of discharge detection procedures and equipment
- Detailed implementation plan for containment and disposal
- Facility and response self-inspection, training, exercises and drills, and meeting logs
- Diagrams of facility and surrounding layout, topography, and evacuation paths
- Description of site-security and security equipment
In addition to an FRP, facilities such as oil production facilities, bulk storage terminals, power plants, automotive plants, chemical plants, power plants, transportation centers, laboratories, and compressor stations may be required to submit SPCC plans. SPCC Plans identify prevention practices related to the storage of oil and management of tanks and other storage equipment. SPCC plans can often be confused with oil spill contingency plans, which typically address response measures after a spill has occurred.
Under the Federal Rule 40 CFR 112, facilities that store more than 1,320 gallons of oil or petroleum-based liquids aboveground or more than 42,000 gallons of oil underground s are required to have a SPCC (Spill Prevention, Control, and Countermeasure Plan). - EPA
Development of a unique SPCC Plan requires detailed knowledge of the facility and the potential effects of any oil spill. While each SPCC plan must be unique to the facility it covers, certain standard elements must be included to ensure regulatory compliance.
Typical elements of an SPCC Plan include:
- Professional Engineer Certification
- Discussion of conformance with federal regulations
- Facility description, plot plan, and contacts
- Potential spill volume and flow rates
- Inspections, tests and record keeping processes
- Personnel training requirements
- Loading/Unloading and transfer details
- Discharge prevention measures
- Security Measures
- Recovered material drainage and disposal methods
- Bulk Storage tanks details
- Secondary containment locations and volumes
- Discharge notification information and procedures
Response plan standardization across a company enterprise allows for a familiar format, a synchronized response, and is the best option for ensuring regulatory compliance across multiple response plans.
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From every event, whether a planned exercise or an actual emergency, lessons can be learned to improve the outcome of the next response. Emergency managers should not camouflage preparedness, response, or communication failures. Instead, they should draw from the scenario experience to improve the overall emergency management program.
Immediately after an exercise or incident, it is critical to:
- Conduct post incident reviews
- Gather conclusions from interviews
- Identify necessary changes for program implementation
- Apply lessons to targeted area(s)
Actual recovery times can be evaluated and any obstacles that led to perpetuating the response should be mitigated. Emergency managers should incorporate lessons learned into response plans, highlight any additional training measures, and inject new responses procedures into exercise simulations.
The post-incident review is an evaluation of incident response used to identify and correct weaknesses, as well as determine strengths. Timing of a post-incident review is critical. An effective review requires that response and preparedness discussions take place while a disaster fresh in the minds of decision makers, responders, and the public. From this review, lessons learned can be identified and the task of preparedness and response improvement can begin.
The post-incident review process is intended to identify which response procedures, equipment, and techniques were effective or ineffective, and the reason(s) why. The question “How can our emergency response process be improved?” should be asked for each subject under the post-incident critique.
Post-incident reviews should include, but is not limited to:
- Name and typical duties of personnel being debriefed
- Date, time and whereabouts of employee during incident
- Specific actions performed during the incident
- Documentation of the positive aspects of the response and areas for improvements
- Recovery time and possible mitigation measures for improvement
- Potential lessons learned
- Necessary program and plan revisions
- Condition of equipment used, both prior to and after the incident
- Overall post-incident perception
Key areas of consideration that should be analyzed by a review team can include, but not limited to:
- Was the emergency detected promptly?
- How was it detected?
- Could it have been detected earlier? How?
- Are any instruments or procedures available to consider, which might aid in earlier detection of the incident?
- Were proper procedures followed in notifying government agencies?
- Were notifications prompt?
- Was management notified promptly?
- Were personnel notified promptly? If so, why, how and who? If not, why not?
- Were contact numbers up to date?
- Was the magnitude of the problem assessed correctly at the start?
- What means were used for this assessment?
- Are any guides or aids needed to assist emergency evaluation?
- What sources of information were available on winds, on water currents and other variables?
- Is our information adequate?
- What steps were taken to mobilize countermeasures to the emergency?
- What resources were used?
- Was mobilization prompt? Could the response time improve? How?
- What about mobilization of labor resources?
- Was it appropriate to mobilize company resources and was this promptly initiated?
- What other company resources are available and have they been identified and used adequately?
- Was there a Response Plan available for reference?
- Was it flexible enough to cope with unexpected events?
- Does the plan include clear understanding of local environmental, political or human sensitivities?
- What was the initial strategy for response to this emergency?
- Is this strategy defined in the Response Plan?
- How did the strategy evolve and change during the emergency and how were these changes implemented?
- What resources were mobilized?
- How were they mobilized?
- How did resource utilization change with time? Why?
- Were resources used effectively?
- What changes would have been useful?
- Do we have adequate knowledge of resource availability?
- Who was initially in charge of responding to the emergency?
- How did this change with time? Why?
- What changes would have been useful?
- Was there adequate monitoring of the incident?
- Were communications adequate?
- Was support from financial services adequate? Prompt?
- Should financial procedures be developed to handle such incidents?
Upon conclusion of the post-incident interviews, the following lesson learned concepts should be examined, mitigated if possible, and incorporated for an improved emergency management program:
- Unidentified potential risk or hazard: A hazard and vulnerability analysis should be performed, and processes and procedures should be developed and added to the plans.
- Management gaps and weaknesses: If the post incident reviews revealed weaknesses or gaps in the emergency management organization, the structure and/or roles should be modified and emergency plans revised.
- Ineffective policies and procedures: If the policies and procedures fail to address key issues during the incident, policies and procedures would need to be modified to address inadequacies.
- Lack of response proficiency: If response was faulty due to deficient training, exercising, or planning, these efforts should be amplified and personnel should be familiarized with these modifications
- Planning deviations: If participants successfully diverged from existing processes, procedures, or plans theses areas should be modified to reflect the reality of the performance.
Applying lessons learned to an emergency management program enables the ability to use experiences as a means to improve to better prepare for future emergency scenarios. By analyzing the past, executing enhancements, and reinforcing strengths companies and municipalities will be better prepared to not repeat history.
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On March 22, 2014, a barge carrying nearly 900,000 gallons of marine fuel oil collided with a ship in the Houston Ship Channel. The collision led to the spill of an estimated 168,000 gallons of the heavy oil into the channel. The spill closed a critical area marine hub, impacted the local migrating wildlife, and spread nearly 12 miles into the Gulf of Mexico.
The event highlights the importance of minimizing impacts through immediate, effective, and decisive communications and response actions. As the duration of an incident increases, it is likely that impacts will broaden. Real-time incident management is becoming more of an expected standard in today’s industrial settings. Current societal norms dictate the necessity for immediate access to crucial and timely information, especially during an emergency response.
A real-time incident management system allows for real-time transmission of incident details, including location, severity, impact, and status. Because of the real time advantage, decisions and coordinated efforts can be tailored to the event as it evolves. A real-time incident management system can:
- Reduce exponential impact of incidents through timely response
- Increase effectiveness of response
- Track status of the incident and all aspects of the response based on each organization/departments assignment(s) and operational levels
- Clarify necessary deployment of resources in order to prevent duplication of efforts
- Provides a means to aggregate data into a format that enables real-time analysis and decision making to ensure the most efficient and effective emergency response
- Provide an instantaneous method of emergency situational awareness
However, response actions must not fall victim to exaggerated miscalculations, rumors, and inaccuracies. The incident commander must ensure rapid responses and decisive actions are relevant and best suited for the site-specific scenario. In order for a real-time incident management system to be effective, specific situational checklists should be created. Responders must understand applicable emergency procedures, status updates that need to be communicated, and in what time frame communications need to be documented. An incident should be managed through clearly identified and communicated objectives. These objectives should include:
- Establishing specific incident objectives
- Developing strategies based on incident objectives
- Developing and issuing assignments, plans, procedures, and protocols.
- Establishing specific, measurable tactics or tasks for various incident management functional activities, and directing efforts to accomplish them in support of defined strategies.
- Documenting results to measure performance and facilitate corrective actions
Just as timely communication methodology is important, commonly understood terminology is essential. A multi-agency incident response requires simple and parallel language. Rapidly communicating through unfamiliar company radio codes, agency specific codes, perplexing acronyms, unanticipated text messages, or specialized jargon will disconnect and confuse responders, and/or stakeholders, possibly prolonging a response.
Maintaining an accurate and up-to-date picture of resource utilization is a critical component of incident management and emergency response. Each real-time incident management status update should identify the following in order to clearly communicate to those in the Incident Command System:
- Time of update (timestamp)
- Incident or event name
- Elapsed time of incident from initiation
- Name/position of responder making status updates
- Current planning phase and/or specific status update
- Tasks assigned, both internally and externally, and resources used or required
- Emergency Operations Center location and contact information
Companies that are required to maintain emergency response plans for regulatory purposes should consider the use of web-based response plans that integrated real-time incident management systems. Minimizing the consequences at the site, the environment, and the responders offsets the cost of implementing a new incident management system. Improving reactive decision management, timeliness of an ongoing response, and swift implementation of recovery strategies can limit resulting effects of any emergency situation.
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Emergency managers are increasingly asked to “do more with less”. Reduced staffing levels and heightened personnel responsibilities due to budget constraints create enterprise-wide challenges for environment, health and safety professionals. The mandate of managing and maintaining multiple emergency response plans and ensuring regulatory compliance and site specific accuracy can be a continual uphill battle. An enterprise-wide response planning system can remove the uncertainties and challenges associated with managing multiple response plans, streamline the update process, and simplify plan reviews, ensuring a consistent path toward compliance.
An enterprise-wide response plan system can address regulatory compliance and consistency in company-wide planning standards. For companies with numerous facilities, advanced systems offer advantageous response plan management opportunities while improving the overall planning system framework and the accuracy of site-specific emergency response plans.
Defining planning objectives, budget limits, and information technology (IT) system criteria will assist in determining which enterprise-wide planning system aligns with company requirements. Below are key questions that may help determine if an enterprise-wide planning system is right for your company:
- Do you have more than one facility that is governed by regulatory requirements?
- Are your facilities required to comply with multiple agency requirements?
- Is there repetitive information in multiple plans at multiple facilities?
- Does your employee turnover rate create inaccuracies in your response plan?
- How effectively do you handle contact information updates and verification? How often does this occur?
- How often do you print updated plan copies for distribution, and what costs are involved?
- Do you have multiple versions of plans, leading to “version confusion”?
- Are your existing plans user-friendly or cumbersome?
- Do your personnel need better access to your existing plans?
- Do local responders have access to your most up-to-date emergency response plan?
- Are your plans updated quarterly or annually, and how do you integrate new regulatory requirements?
- Have you recently gone through a merger or acquisition?
- How much time is dedicated to maintaining, updating, and distributing your plans?
- How often are you audited and would you be ready if an auditor appeared tomorrow?
- Do audits result in fines or violations?
- Can you use your existing plan to expedite training?
- Do you have an accurate record of changes and revisions?
- Are you able to comply with frequently evolving regulatory requirements across your various facilities?
Corporate-level managers may have substantial input regarding long-term environmental, health and safety goals and associated budgeting. However, EHS personnel and those who manage site-specific response plans often determine the success or failure of the program and are responsible for regulatory compliance. A company-wide response planning system should ease the day-to-day challenges associated with managing and maintaining multiple response plans and site-specific regulatory audits, yet seamlessly integrate and interface with established company policies and cultures.
In addition to simplifying the administrative duties of managing multiple response plans, an enterprise-wide response planning system should:
- Support the ability to execute company approved response strategies across multiple locations/facilities
- Easily incorporate company growth and facility acquisitions
- Enable site-specific details while not compromising company directives
- Facilitate the ability to update corporate planning elements across multiple locations, without compromising site-specific details and response challenges
- Be easily updated with minimal dedicated staff
- Become an easily accessible, yet secured, shared tool for internal and external responders
- Allow for streamlined regulatory compliance audits
- Automate and optimize response planning training and exercise activities
- Reduce non-compliance issues on a company-wide scale
- Automate regulatory governance with electronic submissions
An enterprise-wide response planning system enables EHS departments to spend more time on preparedness planning and maximizing response efforts versus plan maintenance, documentation, compliance, and reporting. The result is a more streamlined company emergency management program that reduces administrative efforts, non-compliance fines, and ineffective responses.
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Improving the effectiveness of emergency response programs should be an ongoing event. From technological advancements to best practices implementation, continually evolving planning programs can reduce unexpected impacts on individuals, infrastructures, and the environment.
Below are eight tips to consider in the continual effort to improve a response-planning program:
1. Data Accuracy: Establishing readily available up-to-date information has been proven to limit the duration of the emergency. The faster responders can locate, assess, access and implement accurate response actions to mitigate the emergency, the sooner an incident can be contained, and operations can be restored to “business as usual”.
The specific information regarding company operations, on-site equipment, and employees are continuously changing. Accurate details of these modifications, expansions, and adjustments must be incorporated into the emergency response-planning program. If the information contained within the plan is missing or out-of-date, the response will be hindered. Additionally, necessary compliance data relevant to ever-changing regulatory requirements must be accurately applied in order to eliminate the potential for fines.
2. Training: Training programs that include properly trained personnel, guidance, documentation, and oversight help ensure compliance with agency regulations. These regulatory requirements are designed to prevent harm and ensure adequate responses to protect the public. However, companies should not rely on regulatory training requirements and agency inspections to ensure training programs are sufficient.
Companies need to perform cyclical internal training program audits to create corporate assurance, add EHS program value, improve operational safety, and ideally prevent harmful incidents from occurring. Objective internal auditing emphasizes corporate responsibility to employees, the environment, and the surrounding communities and can often reveal inadequacies and mitigation opportunities. Training audits can bring a systematic, disciplined approach to evaluating and improving the effectiveness of risk management, control, and corporate governance processes.
3. Exercises: Real world exercise scenarios can often highlight potential deficiencies in the response plan and procedures, comprehension of individual roles and responsibilities, and partnership coordination. However, it is through identified deficiencies that mitigation opportunities are revealed and valuable response knowledge and experiences can be attained.
Exercises provide a setting for operational response procedures to be tested. In preparation for these exercises, companies should develop exercise-planning documents, including participant 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.
4. Accessibility: Web-based response plans offer the greatest secured accessibility option for stakeholders, auditors, and inspectors while bolstering an entire emergency management program. With web-based technology and an Internet connection, response planning program information embedded with database driven software can be immediately and securely available without the “version confusion” typically found in other formats. Both paper-based plans and those housed on a company intranet are often out of date with multiple versions in various locations, potentially misinforming the response team.
5. Collaboration: Response planning program effectiveness can be optimized through effective interoperability: the ability for diverse organizations to work together for a greater good. Broadening the scope of response expertise can greatly benefit a facility by limiting the timeline of potentially escalating emergencies. Coordinating planning, training, drills, and resource availability with local agencies and responders is an important aspect of an effective environmental, health and safety program.
Local agencies may provide additional response knowledge based on particular research, experiences, or occupational training in a particular area of study. Emergency managers should continually meet with government agencies, community organizations, and utility companies throughout the entire planning cycle to discuss likely emergencies and the available resources to minimize the effects on the community.
6. Auditing: Audits, whether conducted by in-house professionals or experienced consultants, can often reveal the same inadequacies and mitigation opportunities as regulatory agencies. Regrettably, most companies address response plan gaps only after an incident or agency inspection occurs. With an objective eye, a gap analysis generated by an audit can bolster a response-planning program and minimize the chance of impeding incidents or budget-crippling regulatory fines.
7. Mitigation: Adverse conditions, unsafe activities, or ineffective responses pose risks to occupants, facilities, the environment, and/or communities. By eliminating or mitigating risks, companies can reduce the potential for emergency situations. The risk assessment process can be used to identify situations that may lead to incidents or prolong a response.
While all risks cannot be averted, a facility can become better prepared for disasters if the procedural risk mitigation measures are implemented. Mitigation measures may include a variety of tactics including, but not limited to training for employees, updating safety processes and procedures, or purchasing updated equipment.
8. Best Practices Implementation: Applying best practices to an response planning program enables emergency managers to leverage past experiences as a means to improve planning efforts for future emergency response scenarios. By analyzing past incidents and responses, executing enhancements, and reinforcing lessons learned, companies and municipalities will be better prepared than their historical counterparts.
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In emergency management, response time is critical. The faster an effective response can be initiated, the less chance of an incident escalating and adversely impacting the facility, employees, the environment, and a company’s reputation. Rapid incident response requires accurate communication, training, and exercises.
An accurate plan must be in place for optimal response times. Verification of contact information for company personnel, emergency responders, and agencies should be done on a periodic basis. Any delay in communication will increase response times, delay response actions, and exacerbate the potential impacts.
In order to react quickly, companies need to prepare response plans with flexible, yet pre-identified response strategies. It is critical that the emergency management framework, response measures, and communication strategies be tested and exercised before an incident occurs.
Response plan audits ensure detailed accuracy, plan applicability, and regulatory compliance. Throughout the audit process, a variety of aspects can be tested to ensure optimal response times. Certain elements to test include, but are not limited to:
- Viability of communications systems (monthly)
- Alerts, notifications, and activation procedures (quarterly) for all response personnel
- Response equipment (monthly)
- Accessibility of response plan
- Primary and backup infrastructure systems and services
- Plans for recovering vital records, critical information systems, services, and data
Most successful and timely responses result from a prepared strategy, with a cooperative understanding of response roles and responsibilities. Having a “real-time” incident management system in place may alleviate some of the shortfalls in response measures. However, employees and responders must be trained in response procedures in order to carry out expected actions. In order to limit response times, the following training and exercise concepts should be implemented:
- Train employees on response roles and responsibilities
- Conduct incident response orientations and briefings for the entire workforce
- Train company leadership on response team organization and applicable functions
- Train personnel on response plans and procedures
- Allow opportunities for response personnel to demonstrate familiarity with the plans and procedures
- Report documented training to applicable regulatory agencies
- Exercise physical security attributes at the site
- Test internal and external interdependencies, with respect to performance of critical response functions
- Conduct exercises that incorporate deliberate response actions and measure overall response time
- Conduct exercises using scenarios that involve evacuation, shelter in place, or virtual office accessibility
- Demonstrate coordinated communications capability
- Allow opportunity for continuity personnel to demonstrate their familiarity with the recovery and restoration procedures to transition from a continuity environment to normal activities
Coordinating planning, training, drills, and resource availability with local agencies and responders is an important aspect of an effective environmental, health and safety program. Broadening the scope of response expertise can minimize response time. Local agencies may provide additional response knowledge based on particular research, experiences, or training. Not only can response time be reduced, but also the overall duration of the incident.
Emergency managers should continually meet with potential response partners such as government agencies, community organizations, neighboring companies, and utilities companies. Communicating with external alliances throughout the entire planning cycle can drastically reduce response time. Sources of local collaborative response efforts and plan management information may include:
- Community Emergency Management office
- Mayor or Community Administrator’s office
- Local Emergency Planning Committee (LEPC)
- Fire Department
- Police Department
- Emergency Medical Services organizations
- American Red Cross
- National Weather Service
- Public Works Department
- Telephone companies
- Electric companies
- Neighboring businesses
Companies that are required to maintain emergency response plans for regulatory purposes should consider the use of web-based response plans that integrate with real-time incident management systems in order to maximize their emergency response efforts.
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As companies merge, acquire facilities, or expand operations, applicable location-specific threats, risks, and regulations must be incorporated into response plans. Emergency preparedness programs and facility response plans need to be reviewed, at a minimum, on an annual basis to adequately reflect expanding operations. However, if an acquisition or merger occurs, it is essential to evaluate and align facilities and processes with corporate standards and applicable regulatory requirements.
Enterprise expansion requires environmental, health, and safety (EHS) managers to sharpen their location-based understanding of regulations, security needs, and associated response plan components specific to each location. As part of a company’s asset management program, engaging experienced personnel in response plan data review, safety and response audits, and response plan validation can highlight areas where the local knowledge is imperative.
The new response planning documents should include updates from various stakeholders and collaborating response groups. Open communications with internal and external responders will ensure plan and response procedures are current, and carried out in accordance with company protocols. Groups to consider in planning reviews include, but are not limited to:
- Local responders (fire, police, emergency medical services, etc.)
- Government agencies (LEPC, Emergency Management Offices, etc)
- Community organizations (Red Cross, weather services, etc)
- Utility Companies (Gas, Electric, Public Works, Telephone, etc.)
- Contracted Emergency Responders
- Neighboring Businesses
Whether a facility is domestically located or abroad, ensuring enterprise-wide compliance and employee safety requires streamlined, coordinated, and exercised response plans. A poorly managed and inadequate response can negatively affect a company’s reputation, operations, business interests, and relationship with key regulators, partners, and local entities.
Internal or external experts, as well as independent consultants can assist in response plan audits to ensure compliance, accuracy, and effectiveness. All response plans within the corporate enterprise should address site-specific facility details, appropriate response processes, standardized company-wide best practices, and maintain location-specific regulatory compliance.
The response plan audit process, followed by exercises, can minimize the “lessons learned” transfer process knowledge gap among incoming personnel. Important threat identification, operational site specifics, and response process and procedural details may have gone unnoticed in the transition, potentially compromising safety and emergency response.
After an audit, new or unidentified risks should be slated for possible mitigation measures and regulatory gaps should be documented. However, if the risks cannot be eliminated, new countermeasure processes and procedures must be implemented and response plans adjusted accordingly. Important threat identification, operational site specifics, and response process and procedural details may have gone unnoticed in the transition, potentially compromising safety and emergency response.
Other business units or divisions outside headquarters’ domain may present additional preparedness and response challenges. Audits should be inclusive of cultural differences, infrastructure challenges, or security priorities that may heighten preparedness priorities and planning efforts. As a result, an expanding company may be particularly vulnerable to crisis or emergency response situations.
Audits should verify that response plans have been effectively developed for each potential scenario. In additional to specific operational hazards and site specific regulations, response planning may incorporate, but is not limited to the following:
Natural Disasters: Each geographic location is saddled with specific potential natural threats. If historically applicable, plans should address
- Sand/wind storms
Security Breach: A security breach can affect multiple aspects of a company, from business continuity to the physical safety of employees. Plans may include response processes for:
- Computer hacking
- Catastrophic IT failure
- Facility security measures
- Civil unrest
- Personnel/employee security
Industry/Sector Issues: As industry specific equipment, regulatory requirements, and technologies evolve, preparedness efforts should adapt to include safety processes, continuity procedures, and best practices for.
- Supply disruptions
- Plan maintenance
- Plan accessibility
- Employee training
Though preparedness, companies can minimize the effects of costly crisis and emergency situations, as well are potential regulatory fines. Timely resolutions with limited impact to the facility, employees, the environment, reputation, and the financial bottom line will allow companies to better position themselves for growth, prosperity, and longevity.
Emergency response plan templates often include the basic fundamentals of response planning. They should be utilized as a general outline for developing emergency response plans and a guide for regulatory compliance. However, response plans must also reflect the unique nature of every company, facility, and operation. Consideration of site-specific details of each operation is important to ensure regulatory compliance.
In order for emergency response plan templates to be effective, specific facility information and operational hazards, as well as local, state and federal requirements must be addressed and included in plans. Industrial operations are required by law to institute site-specific emergency response plans and train employees in the appropriate level and method of response. Utilizing generic procedures from basic templates may result in ineffective plans that are not in compliance with regulatory requirements.
By utilizing a template as an outline, companies can begin the process of creating emergency response plans. A generic plan template may not address every regulatory and/or site specification, so it is essential to evaluate site-specific variables and applicable regulatory requirements. Below are twelve basic template topics that should be evaluated for site-specific applicability and implementation.
- Local, State and Federal regulations
- Hazard identification and risk assessment
- Hazard mitigation procedures
- Resource management
- Response direction, control, and coordination
- Notifications and warning systems
- Operations and safety procedures
- Logistics and facilities infrastructure specifics
- Exercises, evaluations, and corrective actions
- Crisis communications
- Finance and administrative duties
A plan template should be supplemented, at a minimum, with the following information:
Description of Facility Infrastructure and Summary of Physical Site Attributes: Emergency response plans should include the following site-specific details:
- Facility Name
- Contact Numbers
- Key contacts
- Site operations and equipment
- Products handled
- Number of employees
- Nearby waterways.
- Site drainage.
- Details of tanks, pipelines, utilities, and other major equipment
- Site security features, including fencing, visitor access, and lighting
Plan distribution list: Include the names and addresses of personnel who have plan copies
Key contacts: Identify all primary and secondary key contacts that may be included in a response. It is crucial to routinely verify contact information for accuracy. Key contacts may include 911, National Response Center, and internal and external response teams. Response equipment suppliers should be identified
Alarm Identification and Notification Process: Identification of alarms that may signal an emergency, evacuation, or shelter in place. It is imperative to perform exercises with alarms to confirm they are in proper working condition and employees react accordingly. Ensure employees are trained in and understand required notifications.
Key Staff Roles and Responsibilities: Job-specific checklists and procedures detailing responsibilities from initial response actions through demobilization. It is a good idea to provide training to at least two people per position in case primary team members are not available. It s helpful to:
- Create Emergency Response Team organizational chart
- Develop Emergency Management Team activation procedures
- Create Emergency Management Team roles and responsibilities checklists
Response Actions: Response action checklists for for each potential scenario. .
- Perform a detailed hazard and risk analysis
- Create response procedures for each identified threat
- Identify hazard control applicability and methods
- Detail external communications and public relations policies
Response Equipment: Major on-site and external response equipment should be itemized. Equipment availability and applicable contact information should be reviewed and verified. The consequences of a supply chain failure during a response can severely limit effectiveness. Transportation delays could affect response equipment delivery times. Plan and mitigate accordingly.
Documentation Process: Accurate and detailed records of a response are imperative. Regulatory authorities may require specific response documentation. The burden of proof typically falls on the responsible party when making insurance claims.
- Create process for incident documentation
- Utilize appropriate ICS Forms
Emergency Operations Center Location(s): Include location, address, contact info, available equipment, and any necessary external equipment for effective response operations.
Visual Aids: Include plot plans, evacuation routes, maps, and any other graphic displays that may aid in a response.
- Identify multiple evacuation routes
- Identify shelter in place areas
- Identify the muster point(s)
Demobilization and Post-Incident Review: Specific demobilization guidelines provide organized and agreed-to procedures to help facilitate a more organized and expedited return to normal operating conditions, and help to minimize costs by standing-down response resources in a timely manner.
- Create a checklist to identify demobilize gudelinesPerform a post incident review and debriefing
- Document newly identified hazards and vulnerabilities
- Identify “lessons learned” and action items
- Update response plan accordingly
Templates should be populated with industry-specific, best practice response techniques. Once the initial emergency plan is completed, response plan audits, exercises, and consulting assistance may be required to confirm emergency plan compliance and effectiveness.
Interested in auditing response plans for effectiveness and compliance, download the "Audit Preparedness Guide for Industrial Regulatory Compliance".
According to the U.S. Department of Labor’s Bureau of Labor Statistics, the oil and gas extraction industry, as well as the petroleum and coal products manufacturing, accounted for the some of the lowest recordable occupational injury incident rates in private industry for 2011. But despite statistics, the industry’s public safety perception has been tested by highly publicized tragic incidents, increasing the pressures on emergency managers.
Preparedness planning and emergency management within the highly regulated energy industry requires expertise. Those who manage these programs face many challenges. Preparing for resilience requires planning, internal and external response coordination, training, and exercises. In addition to grappling with budget restraints, program managers are responsible for planning, regulatory compliance, and possibly responding to emergencies. Implementing this level of company and facility resilience often requires external expertise or the services of specialized consultants.
Oil and gas emergency management program challenges may include:
- Maintaining multiple and complex response plans
- A lack of detailed site-specific response strategies
- Frequent personnel changes
- Evolving compliance requirements
- Regulatory audits
- Emergency management personnel who have other full-time responsibilities
- Minimal time available for training
- Increased risk of regulatory penalties and fines
- Reduced budgets
- Gathering or verifying site-specific information for Oil Spill Response, Emergency Response, and SPCC Plans.
- Providing professional engineer certification for SPCC plans.
- Developing Oil Spill Tactical Plans for response strategies downstream of your facilities and pipelines.
- Developing response pre-plans for tanks, process units, and buildings, and high angle and confined space rescue plans.
- Conducting emergency response assessments of personnel, response equipment, plans, and response contractors.
The ramifications of non-compliance or a hazardous incident can be exceedingly detrimental to oil and gas companies. As a result, many oil and gas companies utilize consultants to ensure their preparedness program levels match regulatory compliance requirements and best practice implementation. These specialized experts recognize that proven best practices and strict compliance reduces the inherent hazards associated with oil and gas operations.
The costs associated with contracting consulting services are always in question. When hiring an external emergency management and preparedness consultant, oil and gas companies should evaluate the strategic cost of an incident and the tactical cost of safety compliance versus the consultant fee. The cost benefit of hiring a specialized, reputable consultant typically outweighs the financial impacts associated with non-compliance or a catastrophic incident.
A consultant can improve safety performance and reduce the strategic cost of an incident by:
- Reducing the overall number of incidents
- Improving the ability to respond effectively
- Improving the casualty and harm conditions through expedited responses and accident avoidance
- Proactively showing intent and safety investment through the media and public
- Helping reduce downtime
- Improving asset utilization
In addition, the tactical cost of compliance can be reduced if a competent and proven consultant is contracted. A consultant can improve the tactical cost of compliance by:
- Simplifying and automating tracking, updating, and management
- Facilitating a universal ability to update response management plans across all locations and facilities
- Automating core compliance and response planning activities
- Reducing the compliance and safety resource requirements
- Enabling EHS workers to spend time planning and performing vs. complying and reporting
- Optimizing and coordinating drills, exercises, and actual emergency responses
Consultants can also provide assistance in responding to incidents or non-compliance issues. With each occurrence, vital proactive measures, including procedural and preparedness efforts, can be implemented in order to safely minimize future mandates, fines, accidents, and/or catastrophes.
Learn why Audits can minimize non-compliance, what documents should be reviewed, how they can imprive HSE programs: Download your Audit Preparedness Guide for Industrial Regulatory Compliance (click the image below):