Emergency Response Planning Blog

On-Site and Online Emergency Response Training

Posted on Thu, Dec 11, 2014

General emergency response training should be conducted for all site workers with industrial facilities. This preparedness training should provide employees with basic response knowledge so that they can perform defensive actions in the event of an emergency. Unless employees are specifically trained and qualified in more advanced hazardous spill response techniques, the typical employee’s trained response or function is to contain a release from a safe distance, keep it from spreading, and prevent exposures.

This general training should familiarize employees with site-specific emergency procedures, equipment, and systems. Covered topics should include, but are not limited to:

  • Incident reporting
  • Instruction and procedures for using personal protective and emergency equipment.
  • Evacuation and alarm procedures.
  • Specific roles and responsibilities in response to fires and explosions.
  • An understanding of the role of the first responder in an emergency.
  • Safe use of engineering controls and equipment.

Advanced specialized training programs typically include detailed course instruction and regulatory agency certifications.  An operational hazard or site-specific coordinated program often consist of classroom or online instruction, drills, and exercises. Specialized training may include, but is not limited to:

  • Basic hazard and risk assessment techniques.
  • Selection and use of proper personal protective equipment.
  • Basic control, containment and/or confinement operations within the capabilities of the resources available.
  • Relevant standard operating procedures and termination procedures.
  • Principles of the Incident Command System.
  • First Responder Operations Level.
  • Hazardous Materials Incident Commander.

ag066-resized-600

Retraining, or refresher courses, should be conducted for both general and specialized training requirements at a minimum of every 12 months or when certification requirements state. At a minimum, annual refresher training should cover current industry and in-house emergency operating experience, as well as changes in emergency operations plans, policies, procedures, and equipment. Additionally, annual training can highlight weaknesses identified through employee feedback and review of the program, drills, and exercises.

Federal OSHA HAZWOPER training requirements apply to “General site workers (such as equipment operators, general laborers and supervisory personnel) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards” (per 29 CFR 1910.120(e)(3)(i) for general industry and 29 CFR 1926.65(e)(3)(i) for construction).  These individuals must receive a minimum of 40 hours of instruction, either in a classroom or online, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor.

According to OSHA, trainees must become familiar with standard and site specific safety processes and applicable response equipment in a non-hazardous setting. To ensure compliance, companies should verify that appropriate and thorough hands-on training is being conducted in conjunction with any online or classroom instruction.

As web-based technologies become more accessible and mobile, different options for online training programs have evolved. These flexible training portals can be used as an intricate tool in the context of an overall training program. Online training is often in conjunction with additional site training. However, it is critical that trainees have the opportunity and mechanism to clarify unfamiliar information in order to become proficient. A computer-based training program should include access to a telephone hotline or an e-mail contact at the time the training is being conducted so that trainees will have direct access to a qualified trainer at the time their questions are raised.

To ensure online training programs are accomplishing its goals, companies should develop methods of training evaluations. OSHA recommends the following:

  • Questionnaires or informal discussions with employees can help employers determine the relevance and appropriateness of the training program.
  • Supervisors' observations. Supervisors are in good positions to observe an employee's performance both before and after the training and note improvements or changes. Drills and exercises should be routinely conducted to confirm response proficiency and specific training knowledge
  • Workplace improvements. The ultimate success of a training program may be changes in processes, procedures, or equipment that result in reduced injury or accident rates.

For free tips on conducting an effective exercise, click here or the image below:

 

Tags: Training and Exercises, Emergency Management Program, Emergency Response Planning

Crude by Rail: Cooperative Preparedness Planning and Training

Posted on Thu, Oct 23, 2014

CSX, a North American leading supplier of rail-based freight transportation, recently hosted a crude-by-rail (CBR) incident response training session at the Security and Emergency Response Training Center (SERTC) in Pueblo, Colorado. The training consisted of 40 first responders representing 12 states.  According to CSX, “The three-day training session focused on preparation for and emergency response to railroad incidents involving crude oil, and included an overview of the history of crude oil extraction, chemical and physical properties of different types of crude oil currently being transported, incident site and damage assessment, and tank car design and construction. Participants also practiced specialized response techniques and incident command scenarios during mock derailments.”

According to the Association of American Railroads’ October 4, 2014 Weekly Report, petroleum and petroleum products shipped by rail was up 12.8% from the same time frame in 2013 (1). As CBR shipments continue to increase, companies must prioritize response and safety training, as well as coordinated planning and preparedness efforts. Because a single incident can have a significant or catastrophic impact, it is imperative that pre-planning and training be incorporated with coordinated response efforts.

In May 2014, the Department of Transportation (DOT) mandated initial coordination by instituting an emergency order for railroads to communicate specific information to each State Emergency Response Commission (SERC). The notifications must provide information regarding the estimated volumes and frequencies of train traffic implicated. Rail companies that transport 1,000,000 gallons or more of Bakken crude oil must adhere to the emergency order.

Specifically, the emergency order dictated that the notifications must: 

  1. Provide a reasonable estimate of the number of trains expected to travel, per week, through each county within the state
  2. Identify and describe the petroleum crude oil expected to be transported in accordance with 49 CFR part 172, subpart C
  3. Provide all applicable emergency response information required by 49 CFR part 172, subpart G
  4. Identify the routes over which the material will be transported.

Communication and cooperative pre-incident planning provides a tool for railroad companies and response agencies to begin the collaborative process of preparedness. This endeavor should be a coordination of overall response strategies that are made part of CBR response plans, training, drills, and exercises. A derailment that includes crude may require mutual aid efforts and a clear, yet robust Incident Management System.

crude by rail prearedness

In order for an incident management system to be effective, specific situational checklists should be created.  Rail employees, and local incident responders must be trained in applicable emergency procedures, communications cycles, and documentation requirements.  Rail incidents should be managed through clearly identified and communicated objectives. These objectives may include, but are not limited to:

  • Establishing specific and step-by-step 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

Maintaining an accurate and up-to-date picture of resource utilization is a critical component of incident management and emergency response. This may be especially challenging on select high or low density rail routes.  Each real-time incident management status update should include the following information in order to clarify response status:

  • 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

Improving rail car emergency response training, reactive decision management, timeliness of an ongoing response, and swift implementation of recovery strategies can limit resulting effects of any CBR emergency situation. As the shipments of CBRl continue to increase, it is imperative that companies, in conjunction with local responders prioritize well-coordinated preparedness initiatives.

NOTE: SERTC was established in 1985 to train railroad officials to safely handle accidents involving tank cars carrying hazardous materials. Because the initial endeavors were so successful, hands-on training courses were extended to serves the public sector emergency response community, the chemical industry, government agencies, and emergency response contractors from all over the world.  

(1)   Association of American Rail Traffic Weekly Rail Traffic Report, Oct. 9, 2014.

For enterprise-wide response planning guidance, click here or the image below:

 

Tags: Response Plans, Oil Spill, Training and Exercises, Safety, Crude by Rail

Ten Reasons for Companies to Invest in Incident Management Programs

Posted on Thu, Sep 25, 2014

Incident Management programs shouldn’t be created for IF an incident happens...but for WHEN an incident happens.

Regulatory compliance mandates, a history of incidents, or an awareness of potential crises typically trigger companies to fund preparedness initiatives. At a minimum, preparedness endeavors and response capabilities should be audited, tested, and updated on an annual basis. Budgeting efforts should be aligned with initiatives in an effort to improve incident management and preparedness capabilities.  Below are ten “best practice” reasons why companies should prioritize funding to advance preparedness initiatives and associated response programs:

#10. Streamline and standardize improved response methods:  A consistent company-wide emergency response management system can deliver site-specific details and management endorsed response processes.  Standardization allows employees and responders to conceptualize their roles and responsibilities across an enterprise, creating a common understanding of intended actions. Streamlining response methods can assist responders in assessing, prioritizing, and responding to incidents.

#9. Optimize drills and training: Employee training, emergency response drills, and applicable exercises identify deficiencies in emergency response planning programs. Incorporating appropriate response training and testing response plans with detailed scenarios will improve response capabilities and coordination, as well as reduce response times.

#8 Improve regulatory compliance: Costly non-compliance fines result from the lack of implemented, thorough, and compliant programs. By systematically aligning response plans and their components with corresponding regulations, companies can identify and amend plan deficiencies that may result in fines and potential government mandated shutdowns.

#7. Simplify and automate response plans: Maintaining response plan can be an administratively taxing endeavor. Continual administrative duties associated with personnel contact information, assignments, training records, exercises, and continual plan updates may be inadequate to sustain an optimal program. Maximizing efficiency through advancements in technology can minimize time associated with maintaining incident response plans.

Incident Management - TRP CORP

#6. Improve asset utilization: Companies must utilize employees, responders, equipment, and budgets effectively in order to minimize the effects of a crisis or disaster. Realigning current tangible assets (equipment and/or personnel), mitigating current inefficiencies, and/or budgeting for additional response training or improved equipment will improve the overall effectiveness of an emergency management program.

#5. Demonstrate a commitment to safety:  Companies should proactively affirm the safety of employees and surrounding communities, and protection of the environment, by establishing proven countermeasures to potential threats and associated risks. Prioritizing emergency preparedness initiatives demonstrates a company’s commitment.

#4. Improve conditions:  Harmful conditions pose a risk to occupants, the environment, infrastructures, and/or the surrounding communities. By eliminating or mitigating potentially adverse conditions, unsafe activities, or ineffective responses, companies can reduce the potential for and effect of emergency situations. The risk assessment process can be used to identify potential threats or harmful conditions that can lead to incidents.

#3. Reduce Incidents:  By identifying potential threats and risks, mitigation and preventative measures can be taken to curtail the likelihood of an incident from occurring or reduce its impacts. Mitigation measures may include a variety of tactics including, but not limited to training for employees, updating safety processes and procedures, or securing or purchasing updated equipment.

#2. Reduce downtime:  Operational downtime and production loss reduces revenues. By optimizing and implementing the most effective and functional incident management program possible, incidents can be promptly managed and rapidly demobilized, thereby reducing response-related costs and downtime.  The repercussions from an incident can include detrimental relationships with customers, the surrounding community, and stakeholders.

#1. Cost savings:  Proactive compliance efforts, safety initiatives, training and exercises, and response and resiliency planning are typically less expensive than regulatory fines, sustained response efforts, and overall repercussions resulting from an incident.

Implementing a technologically advanced enterprise-wide emergency management system offers opportunities to increase the effectiveness of planning and preparedness efforts. Gathering lessons learned from various site managers, performing site regulatory gap analyses, and implementing new proven concepts will ensure the best possible functionality and processes within a program.

For a free Response Procedures Flowchart, click here or the image below:

Tags: Emergency Management, Emergency Preparedness, Response Plans, Incident Management, Training and Exercises, Emergency Management Program

Incorporating Business Continuity into Industrial Settings

Posted on Thu, Aug 21, 2014

As complex, advanced technologies, systems, and networks become ingrained in industrial operations and processes, the potential impacts from even minor disruptions increases. Industrial companies that prepare for a large variety of disruptions can limit its impact on business processes and accelerate the return to normal operations. For those not prepared, a targeted incident can become an escalated situation, negatively affecting profitability, customer relationships, and overall business performance. Business continuity plans (BCP) are crucial to ensure long-term viability, yet many industrial companies do not prioritize them.

Many business continuity issues can start as minor, isolated instances or aggravating inconveniences. However, if not addressed in a timely manner, incidents can escalate, potentially spreading to other key processes. With an effective BCP, mitigation measures, and proper employee training, potential disruptions and operational impacting events can be prevented.

Regardless of the size of your enterprise or scope of facility operations, industrial locations should have the following continuity elements in place.

  • Standard procedures and assigned responsibilities regarding risk management, restoration, and IT recovery for each critical business area.
  • A BIA (Business Impact Analysis)
  • A risk assessment that identifies and prioritizes operational imposing scenarios
  • Recovery Time Objectives (RTOs) based on cost-benefit analyses and BIAs
  • Documented BCP with response, recovery, and restoration procedures
  • BCP exercises aimed at improving RTOs and strategies by ensuring plans are accurate, actionable, and thorough
  • Audits that test corporate-level standardization and policy implementations
  • BCP training for managers and employees

The process of developing a BCP can identify continuity weaknesses within an enterprise and at specific facilities, as well as lapses within individual responsibility and operational processes. To strengthen the prospects of corporate viability, planning and training should include detailed standard operating procedures for BCP activation and address RTOs for each key business process. The BCP should offer procedural flexibility based on real-time situational assessment, as well as procedural variations for each scenario. Precise, site-specific, and accurate BCPs in conjunction with effective training and carefully planned exercises can often counteract a lack of general continuity awareness.

Industrial Emergency Preparedness

Many industrial facilities managers typically have expertise in proper hazard communications and emergency response techniques. However, industrial facility managers and their employees may lack business continuity experience and necessary expertise. If establishing BCPs or initiating continuity efforts are beyond the scope of managers, companies should consider hiring consultants who specialize in business continuity planning.

Employees who are trained in daily continuity procedures, in addition to response and restorative continuity methods will be better prepared in the event of a business-interrupting incident. By incorporating business continuity training, companies can expand their resilience strategies while minimizing risks to their employees, operations, reputation, and the financial bottom line.

BCP training should include a detailed account of specific roles and responsibilities. This will ensure continuity of knowledge among participants, enterprise-wide standard operating procedures, and site-specific business continuity processes. Companies should also be vigilant in training new hires, as well as be receptive to unique business continuity lesson learned that can be used to strengthen the BCP.

Although all companies should prepared for inevitable business disruptions, industrial facilities typically have heightened levels of vulnerabilities. In an industrial setting, hazards are often identified in order for potential impacts to be fully analyzed and countermeasures to be implemented. For business continuity strategies, a business impact analysis (BIA) can identify, quantify, and qualify the impacts in time of a loss, interruption or disruption of business activities on an organization, and provides the data from which appropriate continuity strategies can be determined.  

Whether business disruptions stem from technological, man-made, or natural disasters, business continuity plans can be a valuable tool for protecting viability, securing resources, and maintaining customer relationships.

Click on the image below to download TRP Corp's free Industrial Preparedness white paper.

Tags: BCM Standards, Business Continuity, Resiliency, Training and Exercises, Business Continuity Plan, Business Disruption

The Facility Response Plan Assessment

Posted on Thu, Aug 07, 2014

As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, certain facilities that store and use oil are required to develop, maintain, and submit an approved Facility Response Plan (FRP). These plans should address the elements and responses associated with substantial threats and worst case discharges of oil. If the Oil Pollution Act regulations are applicable to a facility, the operating company must prioritize response plan compliance in order to minimize fines, negative public perceptions, and potential government mandated shutdown of operations.

Maintaining a FRP is an ongoing process. As company operations evolve, and equipment and employees change, adjustments need to be incorporated into the FRP to ensure accuracy, compliance, and effective response capabilities. Additionally, the plan submittal processes must be observed and applied in order to eliminate the potential for fines.

This FRP assessment is designed to recognize best practices. Following the set of questions, the scoring section can assist in identifying potential necessary actions that can reduce the risk of non-compliance and/or ineffective responses.

1. Have your personally reviewed your company’s FRP within the past 12 months?

Yes _____ No_____

2. Do your employees have a clear understanding the FRP and their designated responsibilities if a worst-case scenario were to occur?

Yes _____ No_____

3. Have your external responders participated in a comprehensive review of your emergency management system or a response exercise within the last 12 months?

Yes _____ No_____

4. Does your plan identify a Qualified Individual and alternate who has full authority to obligate funds required to carry out necessary response actions and act as liaison with Federal On-Scene Coordinator?

Yes _____ No_____

5. Does your FRP identify a public relations contact or information officer who has knowledge of public affairs policies identified in your company’s FRP?

Yes _____ No_____

6. Were representatives of external resources involved in developing and testing the company’s FRP?

Yes _____ No_____

7. Does your company have adequate documentation  procedures and capabilities to document plan l changes, training, and exercises?

Yes _____ No_____

8. Is your FRP consistent with the National Contingency Plan and any Area Contingency Plan?

Yes _____ No_____

9. Have you spent more than two hours during the past six months in face-to-face discussion with your incident management team about how to improve spill response management?

Yes _____ No_____

10. Are your response procedures brief and organized in a manner that enables your employees or response teams to effectively respond to a range of incidents?

Yes _____ No_____

11. Does your FRP clearly identify discharge detection procedures and equipment?

Yes _____ No_____

12. Are your current mutual aid agreements or external responder contracts current?

Yes _____ No_____

13. Is your incident response team equipped and trained to set up incident command center?

Yes _____ No_____

14. Does your FRP include detailed disposal procedures and contractors?

Yes _____ No_____

15. Does your FRP contain alternates for each Incident Management Team position in the event that the primary contacts are unavailable?

Yes _____ No_____

16.  Do key individuals have secured, immediate access to the most up-to-day FRP without potential “version confusion”?

Yes_____No_____

Self-Assessment Scoring

To assess your emergency management program, give yourself one point for each "yes" and zero points for each “no”. Total your score and grade your risk.

13–16 points: In general, your FRP is well managed. Look back at your "no" answers and decide what you can do to mitigate this area of exposure. Be sure to monitor regulatory requirements and any operational shifts that could alter the effectiveness of your FRP. For a comprehensive understanding of the status of your plan, perform a full FRP audit by qualified in-house experts or experienced consultants.

9-12 points: You are making good progress, but there are a number of actions required to reduce your risk of non-compliance or response inefficiency. You may wish to focus your attention on areas indicated by the "no" answers. Based on the results of reviews in these areas, you can decide what further steps are necessary. An expert evaluation of your current plan with response plan professionals can minimize potential fines and maximize response efficiencies.

5-8 points: Your company may be at risk, but you have taken the first step of mitigation: awareness. This score suggest your emergency management responsibilities are being partially met, but there is significant room for improvement. A response-planning consultant with FRP experience can assist planners with site evaluations, regulatory compliance criteria, mitigation efforts, and plan substantiation.

Fewer than 5 points: Your facility, employees, operations, and reputation are at risk! Prompt action is necessary to ensure a compliant emergency management program. You need to take immediate action for regulatory compliance and to improve the ability to respond effectively to an incident. A comprehensive review of your FRP and preparedness efforts is warranted to reduce your risk.

Helpful hints:

  1. Review FRP’s on a cyclical basis. If turnover is high or operations are rapidly evolving, FRPs should be reviewed quarterly, at a minimum.
  2. Ensure training, drills, and exercises are optimized. Each training event, drill, or exercise presents the opportunity to improve response process responsibility and site-specific response procedure awareness, rendering the potential for a more effective response.
  3. Despite the added strain of publicity during a crisis, engaging with the media should be incorporated into the planning process. Ensure the facility or company has a designated point of contact for media and site personnel. Consistent, accurate messages alleviate public anxiety and provide a level of credibility. The more information that is provided, the less the media will have room for interpretation.
  4. Documentation provides historical records, keeps management informed of site practices, serves as a legal instrument, if necessary, and supports time and maintenance costs.
  5. Consider utilizing a web-based, database driven planning system. A widely accessible emergency response plan can maximize efficiency and minimize impacts of an emergency on employees, the environment, and infrastructure. Incorporating TRP’s enterprise-wide emergency management system can maximize efforts, minimize maintenance costs, and allow for a streamlined and familiar response process.

For free download on facilitating effective oil spill exercises, click on the image below:

 

 

Tags: Facility Response Plan, Response Plans, EPA, Oil Spill, Training and Exercises, Facility Management, Workplace Safety

Incident Response Drills and Tabletop Exercises

Posted on Thu, Jul 17, 2014

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

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

  • Communication
  • Training
  • Resource management
  • Teamwork

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

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

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

emergency response drill - TRP CORP

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

Below is a list of common tabletop exercise planning considerations:

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

Scenario Information and Position-Specific Tools: Detailed scenario information, ICS forms, and position specific events should be prepared to guide all participants through the execution of their roles and responsibilities. These tools should be included in a participation package and distributed to all participants prior to the exercise. A web-based drill and exercise management tool can streamline the distribution of these tools.

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

“This is a Drill” Exercise Communications: All radio, telephone, fax and written communications must begin and end with the statement "This is a Drill".  Include this statement in all verbal communications, and in a prominent location on all written correspondence, including report forms, fax communications, and press releases. It may be helpful to add the date to any written documentation for organizational and regulatory compliance purposes.

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

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

Injects: Injects may be provided to some participants or as a component of the exercise. An inject describes an additional event or circumstance that requires a response or action from the participant.

Exercise Termination and Debriefing: Following termination of the exercise, a debriefing of all exercise participants should be conducted.  All participants should have the opportunity to provide feedback on the exercise and complete an exercise evaluation form. Feedback should be evaluated for potential response plan mitigation opportunities.

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

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

Tags: Tabletop Exercise, Training and Exercises, Facility Management, Emergency Management Program, Communication Plan, Workplace Safety, HSE Program

Tips for Facility Security Planning and Training

Posted on Thu, Jul 10, 2014

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

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

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

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

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

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

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

facility security plan - TRP CORP

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

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

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

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

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

Tags: Resiliency, Training and Exercises, Security plans, Department of Homeland Security, Communication Plan, HSE Program

How to Manage Preparedness Training for Multiple Downstream Facilties

Posted on Thu, Jul 03, 2014

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

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

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

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

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

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

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

Training management System - TRP CORP

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

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

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

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

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

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

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

Tags: OSHA, Training and Exercises, Workplace Safety, HAZWOPER, HSE Program

Documenting Oil and Gas Emergency Response Drills and Exercises

Posted on Thu, Jun 26, 2014

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

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

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

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

Oil and Gas Emergency Response Planning - TRP

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

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

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

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

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

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

Tags: Testing, Tabletop Exercise, Training and Exercises, Emergency Management Program, HSE Program

Expert Insight on Emergency Response Tabletop Exercises and Scenarios

Posted on Fri, Jun 20, 2014

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

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

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

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

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

tabletop exercise - TRP Corp

The goal of a tabletop exercise program should be to improve the overall readiness and capabilities of emergency response program that encourages:

  • Realistic scenarios
  • Proper training validation
  • Effective emergency plans
  • Action item identification
  • Operational response capabilities
  • Personnel preparedness to respond to incidents, regardless of the threat or hazard

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

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

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

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

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

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

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

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

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

 

Tags: Tabletop Exercise, OSHA, Emergency Management, Response Plans, Training and Exercises, Emergency Management Program