The National Incident Management System (NIMS) is the consistent emergency management structure that has been adopted by countless companies to create a more effective, coordinated emergency response. According to FEMA, NIMS provides “a consistent nationwide template to enable Federal, State, tribal, and local governments, the private sector, and nongovernmental organizations to work together to prepare for, prevent, respond to, and recover from domestic incidents, regardless of cause, size, or complexity, including acts of catastrophic terrorism.”
With properly trained employees, many emergency situations can be handled on-site without external responders. However, if an emergency has the potential to exceed the scope of employee training, a unified incident management approach enables multiple entities to respond with one accepted management system. Adopting NIMS facilitates the ability for internal and external responders to collaborate through common operating principles, terminology, and organizational processes to improve response interoperability. The goal, and typical result of NIMS, is a coordinated, faster, and more effective resolution.
Company emergency preparedness personnel, as well as any emergency responders or teams (fire brigade/EMS), can adopt NIMS training programs. The Department of Homeland Security has developed Frequently Asked Questions regarding NIMS. Below is a sampling of those questions in quiz form to determine your NIMS proficiency.
1. Which is NOT a component of NIMS?
b. Communications and Information Management
c. Response Plan
d. Command and Management
2. Without ICS in place, which of the following often exists?
a. A lack of accountability
b. Poor communication
c. Neither a nor b
d. Both a and b
3. Which factor encourages jurisdictions to implement NIMS:
a. Federal funding eligibility
b. Pension eligibility
c. Tax exemptions
d. Training exemptions
4. Which of the following is NOT one of the three primary components of national incident response?
5. Which of the following describes NIMS?
a. A set of preparedness concepts and principles for all hazards
b. A response plan
c. Specific to certain emergency management/incident response personnel
d. Reserved for large-scale emergencies
6. Which is NOT one of the three primary implications of the evolving nature of the NIMS, implementation, and compliance?
a. Dedicated resources must for NIMS implementation must be retained on an ongoing basis
b. A new incident commander must be named at the beginning of each fiscal year
c. Compliance demands implementation on prior activities even when new regulations are put forth
d. From year to year, structures and processes that jurisdictions have implemented may change, or even be eliminated
7. Which of the following FEMA directors was the first to have had prior emergency management experience?
a. John Macy
b. Louis Guiffrida
c. General Julius Becton
d. James Lee Witt
8. ICS is designed to
a. Meet the needs of incidents of any kind or size.
b. Provide a site-specific response plan
c. Provide logistical and administrative support to operational staff
d. Both A and C
e. Both A and B
9. True or False - Private industry must comply with NIMS requirements in order to receive federal tax incentives.
10. Which of the following is an ICS concept states that personnel report to only one supervisor, and maintain formal communication relationships only with that supervisor.
a. Unity of Command
b. Unified Command System
c. Singular Command Structure
11. State governments also maintain mutual aid contracts with other states, called:
a. Emergency Management Assistance Compacts (EMACs)
b. Collaborative Support Systems (CSSs)
c. Intrastate Emergency Management Contracts (IEMCs)
d. None of the above
12. According to NIMS, all functions of response and recovery are dependent upon ____________ and ___________.
a. Logistics and budget
b. Public perception and reputation
c. Communication and coordination
d. Stakeholder input and stock valuation
13. Transfer of Command occurs when:
a. A more qualified person assumes command
b. There is normal turnover of personnel on extended incidents
c. The incident response is concluded and responsibility can be transferred to the home agency, company or, facility
d. All of the above
14. The Secretary of Homeland Security, through the ________________, publishes the standards, guidelines, and compliance protocols for determining whether a Federal, State, tribal, or local government has implemented NIMS.
a. National Intelligence Council (NIC)
b. National Integration Center (NIC)
c. Incident Command System (ICS)
d. Implementation Coordination System (ICS)
15. Which is NOT one of the seven strategies for emergency operations
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Corporate emergency preparedness can be defined as the preemptive activities that establish a state of readiness to effectively respond to events that could affect the health and safety of employees, facilities, the environment, and/or the community. These actions, which ideally consist of planning, training, equipping, exercising, evaluating, and mitigating, are required to sustain operational capabilities, despite a range of incident management scenarios. It is the goal of corporate preparedness to protect individuals, the integrity and functionality of infrastructures, and viability while minimizing the adverse operational impacts of events.
Many aspects of preparedness rely on underlying administrative duties and associated response plans. According to the Department of Homeland Security (DHS), preparedness plans are meant to describe how personnel, equipment, and other governmental and nongovernmental resources will be used to support incident management requirements. These plans represent the operational core of preparedness and provide mechanisms for:
- Establishing priorities
- Implementing response functions
- Integrating multiple entities
- Establishing collaborative relationships
- Ensuring communications systems and procedures support incident management activities
There are a wide range of administrative actions associated with achieving a state of preparedness and attaining response goals. In particular, documents or response plans written prior to the emergency allow for comprehensive review of procedures that may result in improvements in plan and response to actual emergency scenarios. A variety of regulatory authorities govern most aspects of company preparedness administrative procedures and practices. These requirements may be dictated by company policy, local, state, and/or federal governmental agencies.
A typical response planning process requires ample time for the administrative duties. These duties may encompass details associated with hazard identification, review of plan drafts, exercising the plan, integration of mitigation efforts, training evaluations, and plan distribution. In addition to a yearly review, plan modifications may require administrative efforts:
- After each training drill or exercise
- After each emergency
- When personnel or their responsibilities change
- When the layout or design of the facility changes
- When policies or procedures change
Prior to an incident, required corporate preparedness administrative duties and actions may include, but are not limited to, the following:
- Establishing a written emergency management plan
- Maintaining training records
- Mitigation efforts communication and documentation
- Documenting training, exercises, and associated critiques
- Communicating with emergency response organizations during planning activities.
Administrative actions during and after an emergency
- Maintaining telephone logs
- Keeping a detailed record of events
- Maintaining a record of injuries and follow-up actions
- Accounting for personnel
- Coordinating notification of family members
- Issuing press releases
- Maintaining sampling records
- Managing finances
- Coordinating personnel services
- Documenting incident investigations and recovery operations
- Response plan maintenance
- Regulatory submittals
Preparedness administrative duties are often the responsibility of an environmental, health and safety (EHS) department. The size of the planning or incident management team will depend on a facility's operations, requirements, and resources. However, each position within the team has unique planning administrative duties specific to the nature of their responsibility. The responsibilities of the logistics section chief, as well as the planning section chief, rely heavily on organized administrative efforts. The potential complexity of site emergency response logistics should be analyzed, optimized, and communicated within the response plan. Logistical documentation of the expected and actual resource flow of an incident can minimize response time and maximize efficiency.
Before an emergency, logistical duties may include the following:
- Identify and acquire service and support requirements for planned and expected operations
- Supply allocation details
- Designating emergency facilities
- Establishing training facilities
- Establishing mutual aid agreements
- Preparing a resource inventory
- Provide input to and review the response plan(s)
During an emergency, logistics may entail:
- Participating in preparation of the Incident Action Plan (IAP)
- Providing utility maps to emergency responders
- Providing material safety data sheets to employees
- Coordinating and processing requests for additional resources
- Repairing equipment
- Arranging for medical support, food and transportation
- Arranging for shelter facilities
- Providing for backup power
- Providing for backup communications
- Recommend release of resources in conformity with Incident Demobilization Plan
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“Our greatest glory is NOT in never failing, but in rising up every time we fail." -Ralph Waldo Emerson
Corporate culture and associated public perceptions do not embrace the ideology of growth through failure. A recent LinkedIn discussion highlighted the issue of exercises being designed entirely for success. The exercises in questions were ones that were specifically designed to match response capabilities, not necessarily challenge participants and established preparedness efforts.
The discussion brings to light the multifaceted purpose of an exercise. While the action of conducting an exercise may validate regulatory requirements, exercises should be designed to test response plans and training effectiveness. The unique paradox of success through failures is the key to overall response plan improvement, especially within exercises.
Real world exercise scenarios can often highlight potential deficiencies (meaning failures) in response plans 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.
The discussion emphasized that designing exercises strictly to create stressful, non-attainable objectives, is counter-productive. It is imperative to balance current capabilities with realistic scenarios in an effort to strengthen the overall resolve of the emergency preparedness program. An exercise should present challenging situations in an effort to improve capabilities. A demanding exercise can clearly identify deficiencies. However, creating a bottom line, no-win exercise situation can negatively affect the overall preparedness program by diminishing and detracting from the goal of improved response. An exercise should support a positive response team synergy by validating successes, yet create a path to increased response capabilities and improve targeted training efforts.
Conducting a challenging exercise outside the scope of response capabilities can also create a flawed negative reputation and unwarranted fallouts from the failed endeavor. Companies may suppress some negative impressions, feeling that a “failed” attempt at exercises may lead to internal and/or external perception that a company is poorly prepared for responding to an emergency. Pre-emptive crisis management efforts can alleviate possible unfavorable judgments. Companies sometimes promote their exercises results through public relations campaigns that highlight their dedication to overall preparedness advancements and a commitment to safety.
Whether a full scale or tabletop exercise, participants should understand and demonstrate the following:
1. A proficiency in utilizing the forms, processes, and common terminology to respond to the scenario in association with:
- National Incident Management System (NIMS)
- Incident Command System (ICS)
2. A comprehension of the specific roles and responsibilities within the following teams:
- Emergency Response Team
- Incident or Emergency Management Team organizations
Gaps in response plans or training should be identified and follow-up action taken to ensure that these gaps are addressed.
3. An understanding of external responding organization(s), and general internal responsibilities and expectations of the company: The following should be identified and confirmed for the applicable scenario:
- Communication processes
- Response methods
- Response times
- Roles and responsibilities
- Available equipment
4. The ability to document and communicate actions, management decision, and track resources, using standardized ICS forms and the Emergency response Plan: Participants should record processes and implement procedures per regulatory requirement(s) and company standards. Documentation can be used for:
- Response assessments
- Legal inquiries
- Team reviews
- Training efforts
- Identification of action items and lessons learned
- Improving emergency response plans
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 an understanding of expectations.
Threats, hazard vulnerabilities, staffing and organizational structure, facilities, and equipment are continually changing. A response exercise should be a tool utilized to identify effective efforts and inefficiencies in response to these changes. Through honest evaluations of response efforts to simulated “real-world” scenarios, emergency preparedness programs can continually improve, strengthen, and succeed... until the next change!
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The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The first phase for compliance begins on December 1, 2013. At that time, the HCS will require employees to be trained on the new label elements and the updated Safety Data Sheets (SDS) format.
The revised HCS will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. The goal is to improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals.
Two significant changes contained in the 2012 HCS include the revised labeling elements and the standardized format for SDSs, formerly known as the Material Safety Data Sheets (MSDSs). Employees may have already been exposed to the new labels and SDSs on the chemicals in their workplace during the transition phase. However, to ensure workplaces are compliant with the new regulations, it is critical that employees understand the new label and SDS formats.
OSHA requires the following training criteria to be in place prior to December 1, 2013.
Label training must include:
- Product identifier: The chemical may be identified by the name, code number or batch number. The manufacturer, importer, or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS.
- Signal word: DANGER and WARNING are the two classes utilized on the labeling. The word DANGER is used for the more severe hazards and the word WARNING is used for the less severe hazards.
- Pictogram: OSHA has designated eight pictograms to be associated with a hazard category. HCS approved pictograms are illustrated below.
SDS format and information training must cover the following topics:
- Hazard statement: The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.
- Precautionary statement: Describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
- Contact information: Name, address and phone number of the chemical manufacturer, distributor, or importer.
- Workplace label use: Describes proper storage requirements and first aid procedures
- Element integration: For chemicals that have multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class. When there are similar precautionary statements, the one providing the most protective information will be included on the label.
- Standardized 16-section format including the section numbers, the headings, and associated information:
- Section 1: Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
- Section 2: Hazard(s) identification includes all hazards regarding the chemical; required label elements.
- Section 3: Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
- Section 4: First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
- Section 5: Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
- Section 6: Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
- Section 7: Handling and storage lists precautions for safe handling and storage, including incompatibilities.
- Section 8: Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
- Section 9: Physical and chemical properties lists the chemical’s characteristics.
- Section 10: Stability and reactivity lists chemical stability and possibility of hazardous reactions.
- Section 11: Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
- Section 12: Ecological information*
- Section 13: Disposal considerations*
- Section 14: Transport information*
- Section 15: Regulatory information*
- Section 16: Other information, includes the date of preparation or last revision
*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15 (29 CFR 1910.1200(g)(2)).
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Modern office buildings are generally considered safe and healthy working environments. However in order to maintain OSHA safety standards, office building management should include a Health, Safety, and Environmental (HSE) program that identifies regulatory requirements, including site safety and evacuation procedures. Building inspections, safety audits, and evacuation drills, can identify the need for site specific mitigation opportunities and necessary safety training to correct, minimize or eliminate unsafe procedures or processes.
Although each office building exhibits unique geographical and operational hazards, there are commonalities that may need to be addressed through a HSE program. Common office building health and safety hazards may include, but are limited to:
- Construction method
- Physical Layout
- Fire Hazards
- Handling and Storage Hazards
- Electrical Equipment
- Ladders, stands, stools
- Severe weather or naturally occurring events
- Office tools
A wide variety of emergencies, both manmade and natural, may require an office building to be evacuated or shelter in place. These emergencies may include:
- Fires, explosions, toxic material releases, radiological and biological accidents, civil disturbances and workplace violence
- Floods, earthquakes, hurricanes, tornadoes
A disorganized response and evacuation can result in confusion, injury, and/or property damage. To establish a systematic response with a safe and orderly office building evacuation, HSE programs should include an incident or emergency action plan (EAP) and associated employee training.
Some companies own and maintain their office buildings, while other employers lease office space. If the space is leased, building management and employers should create a partnership in a joint effort to promote safety. A well-developed response or EAP is an effective tool to heighten safety awareness measures. For certain employers, regulatory requirements may require a written EAP. According to OSHA, the purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. In order to customize an office-building plan, employers should:
- Identify potential hazards features and emergency scenarios
- Communicate how employees should respond to each identified emergency
- Customize plan by developing floor plans (or worksite layout)
- Communicate on-site emergency systems and/or alarms
The OSHA requirement to develop a written EAP or fire prevention plan is based on the number of employees that are physically in a facility at any time of the working day. The regulation states that employers with 10 or fewer employees do not have to create a written emergency action plan. However, employers are still required by OSHA to communicate an EAP to staff. An emergency action plan must communicate the following minimum requirements:
- Procedures for emergency evacuation, including type of evacuation and exit route assignments (29 CFR 1910.38(c)(2))
- Procedures to be followed by employees who remain to operate critical operations before they evacuate (29 CFR 1910.38(c)(3))
- Procedures to account for all employees after evacuation (29 CFR 1910.38(c)(4))
- Procedures to be followed by employees performing rescue or medical duties (29 CFR 1910.38(c)(5))
- Means of reporting fires or other emergencies (29 CFR 1910.38(c)(1))
- The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan. (29 CFR 1910.38(c)(6))
Job and site-specific emergency response training should be implemented for current employees, new hires, and supervisors. An employer must review the EAP with each employee covered by the plan:
- When the plan is developed or the employee is assigned initially to a job
- When the employee's responsibilities under the plan change
- When the plan is changed
Additionally, the EAP must address alarm system specifications. An employer must have and maintain a working alarm system that utilizes a distinctive signal and complies with the requirements in 29 CFR 1910.165.
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Every year, thousands of firefighters are injured or killed while fighting fires, performing rescues, responding to emergency medical or hazardous material incidents, or participating in necessary training. In efforts to maximize safety, save lives, and minimize injuries of firefighters, innovative technologies are being utilized by fire departments across the United States.
According to U.S. Fire Administration statistics, an estimated 81,070 firefighters are injured on the job annually in the United States, and through mid-September of 2013, 79 firefighter fatalities were reported. Structural fires are the causes of 87% of fire-related firefighter injuries. In an effort to maximize safety, access to web-based fire pre plans, as well as innovative firefighter technologies have been on the rise.
Firefighter Nation highlighted four areas where technology is making its impact on firefighting. Those areas include:
- Tablet computers
- Simulation Training
- Importance of Preplanning
For decades, Fire Pre Plans were housed in binders or embedded within foldable maps. With the wide availability of mobile phones and tablets computers, cloud and web-based technologies have allowed fire departments to communicate real-time pre plan information and gather pertinent information at their fingertips. Tablets feature multiple communication methods, including email and instant messaging apps, as well as specialized information applications, such as WISER, that allow firefighters to determine the hazardous nature of the incident instantaneously. This year, Charlottesville Fire Department installed iPads in their engines, brush trucks, ladder truck, tanker, and command vehicle. Through the addition of mobile hardware, site-specific information, responder locations, and estimated response times can be transmitted to fire stations and other responders.
Technology has enabled firefighter tracking to advance beyond typical GPS. Honeywell recently released GLANSER (Geo-spatial Location, Accountability and Navigation System for Emergency Responders). According to Honeywell, GLANSER is “capable of tracking firefighters in a multi-story building within one to three meter’s accuracy, showing an incident commander what floor a firefighter is on, what area of the floor the firefighter is working in, and whether the firefighter needs help.” However, unlike typical tracking systems, GLANSER doesn’t rely on GPS. Tony Wyman, Honeywell First Responder Products Vice-president of Marketing stated, “In an environment like an open field, GPS connectivity is a viable solution to the problem of finding and tracking a lost firefighter. But in a structure where GPS may be unable to penetrate, it might be worthless. What firefighters and incident commanders need, is a robust, scalable and affordable system that can operate reliably in a GPS-denied environment. That is what GLANSER can do.” Honeywell plans to test the system with two major fire departments this summer and perform extensive field-testing in the second half of 2013.
Drones, once reserved for specialized military operations, have proven exceptionally effective in mapping forest fires and depicting the extent of flooding situations. Surveillance drones can provide real-time imagery affording responders a birds-eye view of an area. The recent California RIM fires and Colorado flooding highlighted the invaluable utilization of drones to evaluate and determine response limitations, countermeasures, and tactical solutions. Aerial images of the RIM fire allowed engineers to create predictive models of how the fire would potentially spread, allowing for effective countermeasure to be implemented.
According to Firefighting Nation, there are several effective training simulation software programs to assist firefighters in re-creating an emergency incident. The article mentions CommandSim, Digital Combustion, and Action Training Systems as potentially effective software training programs. To be most effective, simulation software should allow fire departments to download identified hazards and site-specific pre plan information into the simulation to reflect real-world applicable scenarios.
Despite the advancement in fire fighting technology, optimizing an effective response requires preparedness. Fire pre plans provide useful information about particular structures. Pre plans can be developed for schools, office buildings, hospitals, hotels, apartment buildings, shopping centers, laboratories, industrial facilities, and other sites. These plans may describe the building’s size, number of floors, construction details and materials, occupancy, and hazardous materials locations. Pre-incident photos, hydrant locations, and other water sources should be included in a pre plan in order to quickly determine how to approach a scene and identify the equipment necessary to combat the blaze. Web-based pre plan software can be easily shared with mutual-aid companies and additional responders, allowing for a unified and cohesive response.
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Industry-specific regulations often require response exercises for compliance. 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.
Exercises must be designed to test responder competencies, and response plan components for effectiveness and accuracy. In preparation for these exercises, companies should develop exercise-planning documents and participant packages that contain exercise objectives, scenarios, ground rules, and in some cases, simulated injects. Through exercises, responders gain an understanding of the site-specific Emergency Response Plan framework. Exercises provide a mechanism to test participants’ knowledge and understanding of how to mobilize an appropriate response, execute communications and decision-making processes, and effectively manage a worst-case spill response. Effectively planned and executed exercises typically result in improved communication and multi-agency response capabilities in the event of an actual spill.
Common exercise objectives include, but are not limited to:
- Practice application of National Incident Management System (NIMS) and the Incident Command System (ICS)
- Improve understanding of the Emergency Response Team and Incident Management Team organizations.
- Improve understanding of the internal and external response capabilities, associated responsibilities, and expectations of the company.
- Practice documenting and communicating response actions, management decision, and tracking of resources, using standardized Incident Command System (ICS) forms and the Oil Spill Response Plan.
The following 15 PREP components must be exercised during a three years period in order to fulfill PREP requirements:
1. Notifications: Test the notification procedures identified in the Area Contingency Plan (ACP) and the Spill Response Plan.
2. Staff mobilization: Demonstrate the ability to assemble the spill response organization identified in the ACP and the Spill Response Plan.
3. Operate within response management system. Including:
- Unified Command: Demonstrate the ability of the spill response organization to work within a unified command.
- Response management system: Demonstrate the ability of the response organization to operate within the framework of the response management system identified in their respective plans.
4. Source control: Demonstrate the ability of the spill response organization to control and stop the discharge at the source.
5. Assessment: Demonstrate the ability of the spill response organization to provide initial assessment of the discharge and provide continuing assessments of the effectiveness of the tactical operations.
6. Containment: Demonstrate the ability of the spill response organization to contain the discharge at the source or in various locations for recovery operations.
7. Recovery: Demonstrate the ability of the spill response organization to recover, mitigate, and remove the discharged product (includes mitigation and removal activities).
8. Protection: Demonstrate the ability of the spill response organization to protect the environmentally and economically sensitive areas identified in the ACP and the respective industry response plan.
9. Disposal: Demonstrate the ability of the spill response organization to dispose of the recovered material and contaminated debris.
10. Communications: Demonstrate the ability to establish an effective communications system for the spill response organization.
11. Transportation: Demonstrate the ability to establish effective multi-mode transportation both for execution of the discharge and support functions.
12. Personnel support: Demonstrate the ability to provide the necessary logistical support of all personnel associated with response.
13. Equipment maintenance and support: Demonstrate the ability to maintain and support all equipment associated with the response.
14. Procurement: Demonstrate the ability to establish an effective procurement system.
15. Documentation: Demonstrate the ability of the spill response organization to document all operational and support aspects of the response and provide detailed records of decisions and actions taken.
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Emergency planning is an ongoing process. Preparing for every unknown site-specific contingencies is potentially unrealistic. Yet, planning for every all-inclusive identified incidents is daunting and time consuming. Despite scenario specifics, the need to communicate detailed site information remains constant. While every effort should be made to include processes and procedures for the most likely and applicable emergency scenarios relevant to your operations, training employees on the basic site-specific response facts is fundamental in emergency management.
The need to swiftly communicate accurate and pertinent information is common to each emergency scenario. Detailed information should be readily available to ensure all emergency managers, response personnel, and applicable agencies are quickly notified in the event of an incident. Information, at a minimum should include:
- Type of incident (medical, fire, oil spill, etc.)
- Casualties or injured parties
There is a fine line between comprehensive details and overwhelming information. Developing a summary of key facility details will enable initial responders to quickly relay features of the facility and its operations. Although the structure of a company’s emergency response team can vary, personnel should have basic knowledge of the following site-specific incident response information:
- Location of Emergency Response Plan
- Location of Response Pre-Plans
- Overview and contact information for on-site Security
- Instructions on who to contact and how to activate alarms, if applicable
- Identification of on-site Incident Commander
Individuals who demonstrate a clear understanding of their response team role(s) and responsibilities are better prepared to implement a streamlined and effective response. Response plans with detailed site information provide the necessary foundation for a response team to build from. However, a short summary of approved response procedures, in addition to a full-scale emergency response plan, can assist non-response team members in performing initial response efforts. Response plan contents should include, at a minimum, the following general information:
- Facility Name
- Contact Number
- Contact Person (and/or facility manager)/contact number(s)
- Site Description, including detailed information such as operations, products handled, number of employees, and any specific physical attributes
- Summary of Physical Site Attributes
- Identification of waterways in the vicinity
- Summary of site drainage properties
- Site topography
- Site security features, including fencing, visitor access, and lighting
Companies can expand upon facility specific information by incorporating and sharing fire pre-plans with response groups. Fire pre plans provide useful, site-specific information for responding to fires in schools, office buildings, hospitals, hotels, apartment buildings, shopping centers, laboratories, and other structures. Identification of pertinent emergency response information and up-to-date photographs can greatly assist firefighters in understanding the hazards and best strategy for rescues, and reducing potential for injuries and property damage.
The information listed in a fire pre-plan, such as floor plan(s) and details of on-site hazardous material(s), are required by multiple agencies (OSHA, DOT, EPA, USCG) as part of an overall emergency response plan. However, other specific fire fighting information, such as construction details, hydrant, and utility valve locations may be useful to responders if highlighted in a stand-alone format and shared with responders prior to an emergency. Information to include when developing fire pre plans are as follows:
- Building Information
- Emergency Procedures
- Alarms/Emergency Lighting
- Fire Protection Equipment
- Special Hazards
- Building floor plans/photographs
Making site-specific facility information and response procedures available to employees, internal response teams, and local first responders improves the potential for a successful response. The faster responders can identify, locate, assess, access, and mitigate the emergency, the sooner an incident can be contained. Expediting response efforts through preparedness and response training can minimize the harmful effects of an incident.
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On August 27/28, 2013, representatives from the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Railroad Administration (FRA) met with stakeholders to initiate a comprehensive review of operational factors that affect the safety of the transportation of hazardous materials by railway.
“We know we can’t wait. The volume of crude oil moving by rail has quadrupled in less than a decade,” said Cynthia Quarterman, PHMSA Administrator. “As greater quantities of HAZMAT are transported by rail, the risks increase, and we have to make sure our regulations and practices keep pace with the market and new technology. We have to identify gaps and close them.”
The late August meeting was used to pinpoint potential reforms, including tougher regulations, and railroad and personnel controls of trains carrying large volumes of crude oil, ethanol and other hazardous cargo. According to the Oil and Gas Financial Journal, total petroleum-based shipments increased 46% from 2011 to 2012. Railroads are used to haul petroleum-based products from locations that such as North Dakota’s Bakken shale fields, where pipelines are lacking. Because of the statistics and a recent accident, there is a heightened awareness for new inspections and oil samplings. This effort, dubbed the “Bakken blitz” by some regulators puts a spotlight on concerns about improper classification of crude oil hazards, the use of unsuitable or unsafe tank cars, security issues, and best practices.
The review comes on the heels of the July 6th Lac-Megantic, Quebec railcar disaster that killed 47 people, forced evacuation of 2,000, and destroyed the town center. The incident was sparked when an unmanned train with a boxcar and 63 loaded tank cars derailed and exploded in the core of town.
FRA’s inspection data since January 2010 shows significant non-compliance with FRA’s securement regulations, 49 CFR 232.103(n), with nearly 4,950 recorded defects in that time. Although railcar accidents have an overall downward trend, accidents associated with “securement” problems rose 31% in the last fiscal year. This data, coupled with the significant increase in hazardous crude by rail transportation, reveals key gaps in railroad and regulatory efforts.
In early August, the FRA and PHMSA issued emergency orders on securing unattended and managing stationary trains. While train accidents involving hazardous materials are caused by a variety of factors, nearly one-half of all accidents are related to railroad human factors or equipment defects. Under current DOT regulations, all freight railroads are required to develop and implement risk assessments and security plans in order to transport any hazardous material, including a plan to prevent unauthorized access in rail yards, facilities and trains carrying hazardous materials. The emergency order highlights the regulation and requires the following:
- Railroads are prohibited from leaving trains or vehicles that are transporting hazardous materials unattended unless the railroad complies with a plan that identifies the specific locations and circumstances for which it is safe and suitable for leaving such trains or vehicles unattended.
- Railroads must develop specific processes for employees responsible for securing any unattended train or vehicles transporting hazardous materials.
- Railroads must review, verify, and adjust, as necessary, existing requirements and instructions related to the number of hand brakes to be set on unattended trains and vehicles and that railroads review and adjust, as necessary, the procedures for verifying that the number of hand brakes is sufficient to hold the train or vehicle with the air brakes released.
- Railroads must implement operating rules and practices requiring the job briefing of securement among crewmembers and other involved railroad employees before engaging in any job that will impact or require the securement of any train or vehicle in the course of the work being performed.
- Railroads must develop procedures to ensure that a qualified railroad employee inspects all equipment that any emergency responder has been on, under, or between for proper securement before the rail equipment or train is left unattended.
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The Environmental Protection Agency (EPA) estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the SPCC Rule:
A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires SPCC plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.
The SPCC inspection program is designed to detect oil leaks, spills, or other potential integrity or structural issues before a spill occurs. The type of inspection program, scope, and frequency will depend on site-specific conditions, spill history, and type of facility. Typically, inspection programs are in accordance with industry standards. However, companies can decide to deviate from industry standards when another approach would be more appropriate or cost effective, based on site-specific factors. The result may be a Hybrid Inspection Program.
The EPA classifies a Hybrid Inspection Program as a customized, site-specific inspection program based on relevant industry standards (in whole or in part) and other good engineering principles. According to the EPA, the components of a Hybrid Inspection Program would likely include frequent visual inspections by the operator, as well as periodic inspections (plus testing as appropriate) by an EPA certified inspector. A company must document environmentally equivalent inspection and testing alternatives, the reason for the deviation, and describe the alternative method in detail, including how it is environmentally equivalent in the SPCC Plan.
It is recommended that formal container test records or reports be retained for the life of a container under the Hybrid Inspection Program. When implementing a Hybrid Inspection Program, the EPA recommends the following elements:
Inspection elements for shop-built tanks:
- Visually inspect exterior of tank
- Evaluate external pitting
- Evaluate “hoop stress and longitudinal stress risks” where corrosion of the shell is present
- Evaluate condition and operation of appurtenances
- Evaluate welds
- Establish corrosion rates and determine the inspection interval and suitability for continued service
- Evaluate tank bottom where it is in contact with ground and no cathodic protection is provided
- Evaluate the structural integrity of the foundation
- Evaluate anchor bolts in areas where required
- Evaluate the tank to determine it is hydraulically sound and not leaking
Inspection elements for field-erected tanks:
- Evaluate foundation
- Evaluate settlement
- Determine safe product fill height
- Determine shell corrosion rate and remaining life
- Determine bottom corrosion rate and remaining life
- Determine the inspection interval and suitability for continued service
- Evaluate welds
- Evaluate coatings and linings
- Evaluate repairs for risk of brittle fracture
- Evaluate the tank to determine it is hydraulically sound and not leaking.
When industry standards do not apply to a container or the container is outside the scope of the standard, a PE does not need to provide and certify an environmental equivalence justification. However, specific inspection protocols must be described in the SPCC Plan, and records of inspections and tests must be maintained for three years. Containers included outside the scope of industry standard can include, but are not limited to:
- Containers storing oils that have a specific gravity greater than 1.0
- Oil containers operated at elevated temperatures
- Animal fat or vegetable oils (AFVOs) containers
Regional EPA representative(s) conduct both announced and unannounced inspections at facilities. A copy of the facility’s SPCC Plan with site-specific inspection procedures should be available for inspector(s) to review at all times. Additional documentation, including operating procedures, spill prevention measures, personnel training, drainage discharges, and spills should be provided to inspector(s), as well as site plans for tankage, diversionary structures, and drainage patterns.
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