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Corporate Preparedness Training and Response Exercise Management Tips

Posted on Thu, Dec 01, 2016

A company with multiple locations is often challenged with confirming and managing compliant preparedness practices and effective response planning programs under continuously evolving conditions. Each facility under the corporate umbrella typically has distinguishing operational structures, inherent hazards, and varying regulatory compliance guidelines. In short, maintaining preparedness and efficient response plans across an enterprise is a complex venture.

The preparedness components of each facility within a corporate enterprise must address site-specific operations, appropriate response processes, standardized company-wide best practices, and maintain location-specific regulatory compliance. Whether a facility is domestically located or abroad, ensuring compliance, employee safety, and an effective response requires a comprehensive preparedness training and exercise program. By utilizing available technology to manage these enterprise-wide programs, companies can verify compliance and ensure response readiness through a cohesive, yet site-specific standardization of best practices.

With proper maintenance and utilization of a training and exercise portal, individuals can be positioned to achieve and maintain peak optimal response capabilities. Preparedness training combined with tested response plan exercises can result in:

  • Response plan familiarization
  • Understanding individual roles and responsibilities
  • Improved response plans

Most companies, especially medium to large ones should implement a preparedness and response training and exercise management system with the ability to identify and sort specialized data.  This enables company managers to focus their efforts on operations and profitability. A centralized interactive, database-drive interface of scheduled, lapsed, and completed training requirements enables approved corporate personnel, facility managers, emergency managers, and health, safety, and environmental departments to:

  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

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An enterprise-wide system is critical to enable systematic management of the training and exercise program for all company  locations. Managing several disparate systems and various paper files is cumbersome, time consuming and increases the potential for error. Web-based training and exercise management systems can provide authorized users with secure access from a variety of locations, simplifying the ability to update and document information as necessary. Additionally, as facilities are added or modified, operations are revised, or employees are re-assigned, training and exercise records can be conveniently added, accessed, transferred, or updated for accuracy and compliance. A comprehensive, web-based training and exercise management system will:

  • Reduce multiple site management and documentation formats
  • Streamline company protocols
  • Minimize administrative costs across the company
  • Minimize training discrepancies across an enterprise
  • Provide a historical record of training certifications and facility exercises
  • Engage company management in prioritizing preparedness efforts
  • Enhance reporting functionality and compliance
  • Reveal regulatory compliance training and exercise gaps
  • 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 and exercises versus completed and scheduled events
  • Print automated certifications and wallet cards
  • Serve as a legal instrument, if necessary

Advanced web-based technologies can also facilitate online training and provide classroom resources. While it is not required by regulations to implementing a web-based preparedness tool, it can reduce the ongoing corporate costs associated with classroom instruction and company-wide exercise management. Implementing a customized training and exercise 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.

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Tags: Training and Exercises

"Top 10" Guide for Response Plan Exercises

Posted on Thu, Nov 03, 2016

Corporate preparedness exercises should be designed to test response plan components and practice response management practices, including team roles, response strategies and tactics. Yet, corporate culture and their concerns about public perceptions often reject the ideology of growth through failure. 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. Exercises should be utilized and perceived as tools for continuous improvement.

Response Plan Exercise Guidelines

Key guidelines for an effective Response Plan Exercise include, but are not limited to:

  1. Select exercise objectives based on the specific audience in attendance, and their level of experience.
  2. Discuss exercise objectives with participants so that everyone is focused and understands the intent and purpose.
    • Detailed scenario information, ICS forms, and position specific events should be prepared in advance 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.
  3. Design scenarios to be realistic, with a level of detail consistent with objectives, and time allotted to conduct the exercises.
    • In order to exercise the emergency scenario, the exercise must progress in a condensed time-frame (not real-time). Events should move rapidly through some phases of the exercised response. However, it should be clearly understood that under real conditions the same events or actions would require much more time to complete.
  4. The objectives of the exercise may vary depending on the participants’ key functions, and may include, but not be limited to testing public affairs procedures, equipment deployment, response procedures, emergency notifications, communications processes, among others.prepdrill-resized-600.jpg
  5. Exercise participants should initially be limited to company personnel, until they have sufficient experience to respond effectively. Once the team is trained in this process, and perhaps have received additional ICS or NIMS training, participation by outside parties (including LEPC, fire and police department, state and federal response agencies, corporate team representatives, and response contractors) can be extremely valuable.
  6. Determine the most appropriate type of exercise to best suit objectives and budget: tabletop, command post, or training.
  7. Interject situations during the exercise to ensure that all participants are engaged and challenged. An Inject describes an event or circumstance that requires a response or action from the participant.
    • Depending on the scenario, and how much a factor weather is, either real or simulated weather conditions may be utilized during the exercise.
  8. Ensure that exercise participants maintain documentation throughout the event, and utilize this information for debriefing and final report.
    • “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.
    • "This Is A Drill" Communications with Non-Participating Parties: 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
  9. Ensure that timely final reports are completed, with lessons learned and action items documented.
    • 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.
  10. Determine action items and update response plan with lessons learned. Exercises 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.

 

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Tags: Training and Exercises

Spill Response: HAZWOPER or Hazard Communication Standard Training?

Posted on Thu, Sep 08, 2016

The costs associated with effective employee training, spill prevention, and spill response planning are often much less than the costs associated with fines, spill cleanup, and other civil liabilities. As a result, companies should not wait for a safety incident or regulatory inspections to ensure their emergency management programs are sufficient.

When hazardous materials are on site, employees must be trained to distinguish between incidental spills that can be handled in house and emergency spills that require evacuation and Hazmat team assistance. OSHA would prefer that all potentially exposed employees are trained to at least the awareness level. However, the properties of hazardous substances combined with the circumstances of a release  affects the applicable OSHA standards, the corresponding mandated employee training level, and the subsequent emergency procedures. 

Spills without emergency consequences are considered “Incidental Spills” and are covered by the Hazard Communication Standard (29 CFR 1910.1200). Under the specification of the Standard, employees who are trained on the hazards of the chemicals they are working with may safely clean up an incidental spill. An incidental spill can be described as:

  • Hazardous
  • Limited in quantity
  • Limited in exposure potential
  • Limited in Toxicity
  • NO or minor safety threat to employees or immediate vicinity
  • NO or minor health hazard to employees or immediate vicinity
  • NO or minor effects from cleanup process
  • NO potential to become an emergency within a short time frame.

“Emergency spills” are covered by the standard for Hazardous Waste Operations and Emergency Response (HAZWOPER). For the definition of "emergency response" to be satisfied under HAZWOPER, the release or situation must pose an emergency and may:

  • Cause high levels of exposures to toxic substances
  • Be life or injury threatening
  • Mandate personnel evacuation
  • Cause Immediately Dangerous To Life or Health (IDLH) conditions
  • Cause a fire and explosion hazard (exceeds or has potential to exceed 25% of the lower explosive limit (LEL)
  • Require immediate attention because of potential danger
  • Present an oxygen deficient condition

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Where applicable, all employees involved in an emergency response must be trained under 29 CFR 1910.120.  HAZWOPER training can include:

  • General site workers: Individuals, such as equipment operators, general laborers and supervisory personnel, who are engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health.
  • Operations crew: Individuals involved in hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with Environmental Protection Agency to implement RCRA regulations.
  • Emergency response operations team: Those directly involved in responding to the releases of, or substantial threats of releases of hazardous substances, regardless of the location of the hazard.

Numerous organizations have emergency response policies in place based on misinterpretation of the HAZWOPER regulations. The purpose of the initial responder (operations level) of an emergency is to protect life, property, or the environment from the effects of the release, not stop the release. Operational responders are trained to respond in a defensive fashion without actually trying to terminate the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.

There are various training levels within HAZWOPER. Training levels should reflect the type of work and the potential hazard involved in the work.

  • 24-hour HAZWOPER Training: Appropriate training for those who are less directly involved with uncontrolled hazardous waste sites (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying).
  • 40-hour HAZWOPER Training: Those individuals directly involved in the cleaning up of hazardous materials, its storage, or its transportation should take the 40-hour HAZWOPER course. The 40 hour course is required for the safety of workers at uncontrolled hazardous waste sites.
  • 8 hours HAZWOPER Training: Managers are required to attain the same level of training (either the 40-hour or 24-hour training) as those they supervise, and an additional 8 hours.

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises

New PREP Guidelines Go Into Effect: June 2016

Posted on Thu, Apr 28, 2016

In April 2016, the EPA released its most recent revision to the Preparedness for Response Exercise Program (PREP). The updated guidelines go into effect June 2016 and incorporate various lessons learned and industry input.

PREP was initially developed to establish an economically feasible exercise program to meet the intent of section 4202(a) of the Oil Pollution Act of 1990 (OPA 90). Completion of the exercises described in the new guidelines is one option for maintaining compliance with OPA 90 response exercise requirements.

Exercise programs 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.

In order to satisfy PREP guidelines, all of the core components must be exercised once every three years, at a minimum. Today, a unified effort comprised of the following agencies make up the PREP Compliance, Coordination, and Consistency Committee (PREP 4C):

  • U.S. Coast Guard (USCG)
  • Environmental Protection Agency (EPA)
  • Pipeline and Hazardous Materials Safety Administration (PHMSA)
  • Bureau of Safety and Environmental Enforcement (BSEE)

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PREP Revisions

According to the April 5, 2016 Marine Safety Information Bulletin, “This revision modernizes the NPREP Guidelines to better align policy with the existing regulations and improve interagency consistency.”  The revisions, which are the first in over a decade, align certain PREP terminology with the Homeland Security Exercise and Evaluation Program (HSEEP), expand spill countermeasure topics, and incorporate salvage, marine firefighting, non-tank vessel exercise requirements.

PREP Terminology: The guidelines stipulate that new terminology does not imply new or different requirements than what is contained in regulations. These new terms should be viewed and treated as “synonyms” that have been adopted to ensure that the PREP program is consistent and easily compared to nationwide exercise terminology used in most other current programs. Updated terminology includes, but is not limited to:

  • Spill Management Team: Replaced by the term “Incident Management Team (IMT)
  • Containment: Wherever the word containment is used in the context of containing oil under the water's surface, the word “subsea” will precede the word “containment”. Where the word “containment” is used by itself, it is presumed to be associated with efforts to contain oil on the water's surface.
  • Oil Spill Removal Organization (OSRO): The definition of an OSRO has been updated to include, and better describe, a broader range of response resources and services, including source control, all spill countermeasures, and supporting services that an OSRO may provide in order to adequately contain, secure, recover, or mitigate a discharge of oil.

Spill Countermeasure topics:  The following updates were incorporated into the new exercise guidelines:

  • The “Recovery” Core Component in Appendix A was retitled “Mitigation,” and the supporting language was broadened to clarify that mitigation may include the use of various spill countermeasures, including, but not limited to, dispersants, in-situ burning, and bioremediation, in addition to mechanical oil recovery.
  • Plan holders will only be required to exercise Subsea Dispersant Injection (SSDI) equipment upon receiving direction from the Chief of Oil Spill Preparedness Division, or the Chief's designated representative. However, plan holders should carefully describe how SSDI capabilities will be used in their OSRPs.

Salvage, Marine Fire Fighting, Non‐tank Vessel Exercise Requirements: Requirement updates include:

  • Credit for equipment deployment exercises for salvage and marine firefighting services may be claimed for real world operations, when documented as outlined in Chapter 3 of the guidelines. This also applies to traditional oil spill recovery and storage equipment.
  • The committee determined that the best way to provide clarity on the issue of Dispersant-Related Objectives during PREP Exercises was to broaden the definition of OSRO to include all providers that offer any and all spill response resources designed to contain and secure a discharge, and recover or mitigate the impacts of the spilled oil through various countermeasures and supporting services, including mechanical recovery, in-situ burning, dispersants, bioremediation, salvage, source control, and other response services directly supporting the incident such as aerial surveillance and remote sensing.
  • A vessel that has successfully completed a Government-Initiated Unannounced Exercise (GIUE) will not be required to participate in another GIUE in any COTP zone for 36 months. Other vessels under that same plan will not be required to complete another GIUE in that same COTP zone for 36 months. Other vessels in the same plan may be subject to a GIUE in another COTP zone at any time.
  • The frequency of remote assessment and consultation exercises is significantly reduced, from quarterly to annually per vessel when the vessel operates in U.S. waters. The economic burden of this exercise on vessel stakeholders is correspondingly reduced. Annual per vessel credit is appropriate for remote assessment and consultation exercises to ensure that each vessel in the fleet would have the opportunity to simulate initiation of a remote assessment and consultation assessment each year.

A full list of updated 2016 PREP Guidelines can be found on the Federal Register Website.

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises, Regulatory Compliance

Chemical Plant Response Training and Exercises

Posted on Thu, Feb 04, 2016

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.

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises, Chemical Industry

2015 Emergency Management Conferences to Consider

Posted on Thu, Feb 05, 2015

Since the 1990s, incidents, disasters, education, and technology have continued to alter emergency management at an increasing rate. Professionals who may have begun their careers in one of the three sub-disciplines of environment, health or safety (EHS), have been required to broaden their expertise beyond singular objectives and implement new systems, processes, training, and/or equipment to drive improvements across all operations.

Today, these professional are continually challenged to improve processes based on lessons learned, experiences, and industry advancements while balancing the profit/loss scale with sustainability. Because of these challenges, the opportunity for ongoing communication, collaboration, and education is a valuable tool.

These informative conferences can aid in fostering a culture of safety and preparedness. While many are industry specific, below is a list of 2015 conferences that can inspire EHS professionals and enhance their company programs. (The list reflects statements from the conference presenters and should not be considered a TRP Corp endorsement. Cost identified is the general registration fee for full conference access. Early registration discounts and other pricing may be available).

International Disaster Conference and Expo: February 10-12, 2015 (New Orleans, LA) -  This conference unites public and private sector professionals from around the world for discussions regarding policy, lessons learned, best practices, and forward thinking, resulting in the mitigation of loss of life and property when catastrophic events occur. $450 (private sector), $150 (public sector)

Society of Petroleum Engineers E&P Health, Safety, Security, and Environmental Conference-America: March 16-18, 2015 (Denver, CO) - Since 1993, this conference has provided a setting for HSE professionals and experts to exchange knowledge, learn, and network. The event brings together industry, government, and academia to share best practices and innovative solutions.  Cost varies from $75 to $925

Disaster Recovery Journal Spring World: March 22-25, 2015 (Orlando, FL) - Industry leaders gather to explore topics that address some of today’s most challenging and pressing business continuity and disaster response issues. Break-out sessions are scheduled to address strategic, managerial, technical, information, advanced, and emergency response. $1295

Preparedness, Emergency Response and Recovery Consortium and Exposition: March 24-26, 2015 (Orlando, FL) - This focus of this conference is placed on coordination and collaboration between the various organizations and stakeholders, contributing to disaster preparedness, healthcare response, rescue and evacuation, sheltering in place, and recovery operations. The setting brings together healthcare, medical, public health, and volunteer emergency management personnel involved in disaster recovery and response efforts. Individuals representing governmental, public, and private sectors come together to discuss shared practices in preparedness, mitigation, response and recovery. $500

IEEE Symposium on Technologies for Homeland Security: April 14-16, 2015 (Waltham, MA) - Brings together innovators from leading academic, industry, business, Homeland Security Centers of Excellence, and government programs to provide a forum to discuss ideas, concepts, and experimental results. Showcases emerging technologies in cyber-security; attack and disaster preparation, recovery, and response; land and maritime border security; and biometrics and forensics. $265-$535

Partners in Emergency Preparedness Conference: April 14-16, 2015 (Tacoma, WA) -  The Partners in Emergency Preparedness Conference (a non-profit 501(c)3 charitable organization) is the largest and most successful regional emergency preparedness conference in the Pacific Northwest. Partners in Emergency Preparedness annually hosts nearly 700 people representing business, schools, government, the nonprofit sector, emergency management professionals, and volunteer organizations. $425

Continuity Insights Management Conference:  April 20-22, 2015 (Scottsdale, AZ) - This conference provides the opportunity for strategic business continuity discussions, where professionals can learn from and network with those responsible for the integrity, availability, resilience, and security of their organizations. The conference includes a review of the latest technologies and practices, and the ability to earn additional certification with post-conference workshops. $1295-$1495

World Conference on Disaster Management: June 8-11, (Toronto, ON Canada) - Celebrating its 25th anniversary, this conference delivers a global perspective on current and emerging issues. Presentations cover practice, research, and innovation in emergency management, business continuity and crisis communications. $350

Volunteer Protection Programs Participants’ Association: (VPPPA): August 24-27, 2015 (Grapevine, TX) - Encourages and provides opportunities for EHS professionals to network, learn, and advance as leaders in occupational safety and health issues. Participants range from safety and health managers, employee safety team members, industrial hygienists, union representatives, consultants, environmental health specialists, and human resource managers Government agency representatives from the Occupational Safety and Health Administration (OSHA) and Department of Energy (DOE) are also available for networking and education. (Cost not release by publication date.)

IAEM-USA 60th Annual Conference & EMEX 2012: November 13-18, 2015 (Las Vegas, NV) - Partnering conference of the International Association of Emergency Managers (IAEM) and Emergency Management and Homeland Security (EMEX) that provides a forum for current trends and topics, information about the latest tools and technology, and advances IAEM-USA committee work. Sessions encourage stakeholders at all levels of government, the private sector, public health, and related professions to exchange ideas on collaborating to protect lives and property from disaster.  More than 2,500 participants are expected to attend this 63rd conference. (Cost not release by publication date.)

Clean Gulf: November 10-12, 2015 (New Orleans, LA) - Opportunity for companies, regulatory agencies, and associations involved in exploration, production, shipping, transportation or storage of petroleum, petrochemicals or hazardous materials to view the latest products, services and technologies, as well as hear about the latest trends and developments in the oil spill response industry. This event is co-located with the Deepwater Prevention & Response Conference. (Cost not released by publication date.)

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Tags: Choosing a Consultant, Conference, Emergency Management, Training and Exercises, Disaster Response

What your Employees Need to Know About Emergency Response?

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.

General Emergency Training

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.

 

Specialized Response Training

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.

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.

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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.

Online Response Training Programs

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.

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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.

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.

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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.

#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.

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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.

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.

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