Chemical plants present unique preparedness and incident response readiness challenges. When all potential hazards are analyzed and evaluated according to their likelihood of causing injury, damage, and severity of the impact, a regulatory compliant, effective, and site specific training and exercise program should be implemented.
Chemical plants are required to conduct and document response training and exercises to satisfy certain EPA and OSHA regulations. The objective of safety and response plan training and exercises is to promote a safe work environment, instill specialized response skills, and improve overall preparedness. Although training and exercises are often considered separate components, these coordinated methods blend to optimize safety and preparedness objectives.
Training: An individual instructional component or instructor-led classroom-based activity with a focus on individual knowledge development sufficient to perform specific roles and undertake prescribed responsibilities.
Exercise: The activity of practicing roles, responsibilities, and/or procedures with a focus on development of individual skills and/or to test and identify deficiencies in plans and procedures.
Chemical plant emergency managers should aim to create an efficient method to track individual training needs and identify team members’ current qualifications. Through proper maintenance of a training portal, individuals will remain at peak optimal response capabilities. Training should include, but not be limited to:
- Familiarization with Response Plan
- Individual roles and responsibilities.
- Plan review training whenever a substantial change or revision is made to the plan that affects organization, procedures, roles and responsibilities, or response capability.
- Refresher courses, as necessary
OSHA’s HAZWOPER training for general employee may range from “first responder awareness level” to the “hazardous material specialist” level. Each chemical plant under a corporate umbrella may require further specialized training depending on the current operations, unique hazards, location, and associated regulations.
The goal of the exercise program should be to improve the overall readiness and capabilities of emergency response program that encourages:
- Realistic scenarios
- Proper training validation
- Effective emergency plans
- Identification of action items
- Operational response capabilities
- Preparedness to respond to incidents, regardless of the threat or hazard.
To ensure chemical plant employees and response personnel are prepared to respond to an incident in an efficient and effective manner, exercise guidelines should be established as minimum requirements within an emergency preparedness program. Management should ensure that:
- All aspects of response plans are fully exercised annually (at a minimum) with participation of the appropriate response, incident management, and support teams.
- Each response plan component is exercised at more frequent intervals, as appropriate, to prepare for the main annual exercise.
- Notification exercises for each team and response component are verified and practiced at least twice per year. This exercise should involve unannounced checks of the communication procedures, equipment, and contact information.
- National and local training and exercise requirements should be used to assess the overall preparedness of your response teams.
Companies often utilize the following range of exercise activities in planning and executing their program:
Level 1 Tabletop Exercises: Useful for considering policy issues, and for building team relationships in a low stress environment.
Level 2 Mobilization and/or Notification Exercise: Used to validate mobilization and response times, and verify internal/external notifications and contact information.
Level 3 Limited Exercises: Used to validate mobilization and response capabilities of specific team functions, and the status of integration and coordination among these groups and other company-based response organizations.
Level 4 Full Scale Exercise: Full-scale exercises offer comprehensive validation of current emergency and crisis management system, and should demonstrate a degree of response integration throughout the system.