Your Solution for SMART Response Plans

Working Safely at Plants + Refineries during the COVID-19 Pandemic

Posted on Wed, Apr 15, 2020

Originally published on jensenhughes.com

The World Health Organization (WHO) declared the Coronavirus (COVID-19) a global pandemic on March 11, 2020. One month later, there have been more than 1,000,000 cases confirmed with close to 50,000 deaths. With no signs of slowing down, companies are grappling with how to protect their employees and still perform critical operations.

As the war on COVID-19 unfolds, the value of a well-developed Pandemic Response Plan (PRP) is being fully realized. Some organizations are dusting off their Avian Flu (H5N1) plans and realizing that these plans may only be a starting point to reaffirm what operations are truly critical, and that stockpiles of critical personal protective equipment (PPE) and cleaning materials need to be re-evaluated. Other companies — including refineries and plants — are scrambling to come to terms with their unique risks and are developing response tactics to protect their employees and deliver critical products and services.

In an ideal world, a PRP should have been developed, and materials should have been stockpiled and exercised during normal conditions prior to an outbreak. Whether or not you have a PRP in place, all companies should evaluate and examine ongoing pandemic risks and vulnerability factors to provide management and employees with critical knowledge, proactive procedures and necessary resources.

PRPs should focus on establishing a safe work environment, minimizing the spread of the disease, continuing critical business operations and ensuring the financial viability of the company.

Key Safety Practices for Industrial Plants and Refineries during COVID-19

For businesses in the critical infrastructure sectors such as industrial plants and refineries, the protection of essential workers required to perform operations that cannot be performed remotely is particularly challenging. The original design of the workspace or the requirement to interact with the general public will demand creative solutions to protect workers from becoming infected from each other or from their interaction with the general public. Some key preventative practices to maximize personnel safety include:

  1. Redesign work areas and break rooms to promote social distancing. When social distancing is not possible, such as when two or more people are working on a piece of equipment or riding together, ensure that they wear N-95 masks during that time.
  2. Redesign the product/service delivery process to protect personnel and customers.
  3. Defer/suspend access to the facility by non-essential contract service workers.
  4. Reduce the number of entrances to minimize staffing requirements and support consistent screening processes.
  5. Require that all non-critical and critical staff personnel that can work from home remain at home.
  6. Perform remote screening (although some personnel may be asymptomatic), for all persons before their planned entry to the facility to potentially reduce exposure to others. This screening may consist of completion of a standardized questionnaire asking if the person has symptoms and/or has had potential exposure to others with flu-like symptoms.
  7. In addition to remote screening, companies can use digital thermometers at entry points and implement random temperature testing during the shift to detect sick persons more quickly. It is important to ensure that persons responsible for administering temperature checks are wearing appropriate PPE.
  8. Increase frequency of cleaning common touch items/areas (e.g. doorknobs, countertops, light switches, elevator buttons, handrails, timeclocks, restrooms, breakrooms, etc.) to twice per shift.
  9. All persons confirmed to have an elevated temperature should be denied entry and informed to go home and contact their health care provider for further instructions.
    • Sending them to a medical facility is not recommended unless directed by their physician.
    • Require that personnel with flu-like symptoms or reporting close contact to a person exhibiting flu-like symptoms self-quarantine for 14 days unless testing reveals that they don’t have the virus.
    • For personnel confirmed to have flu-like symptoms, initiate a close contact tracing process to determine others that may be exposed.
  10. Reduce the frequency of shift changes and isolate contacts between primary and alternate critical staff members to minimize the potential of infection of the entire team.

Best Practices if Someone is Sick

If someone reports feeling sick while on-site:

  • Activate a response team wearing appropriate PPE (gloves, mask, and face shield) to initiate the exit process and clear co-workers from the area. Provide a mask to the symptomatic person(s) and escort them to exit with instructions to contact their health care provider.
  • Move co-workers from the immediate area to an alternate work area so that personnel can continue to perform critical work if decontamination of the primary area is required. If critical operations require utilization of the potentially contaminated workspace, furnish PPE to the minimal required staff required to continue operations while the space is being decontaminated.
  • Execute a contact tracing process and monitor personnel who had contact. Require that any symptomatic person self-quarantine for 14 days before returning to work.
  • Ensure that HIPPA compliance is maintained.
  • Activate a decontamination team to clean the person’s work area, restroom, and other areas that the person may have visited that day. Decontaminate the area using EPA approved cleaning materials, procedures and PPE. Once decontamination is complete, obtain certification from an industrial hygienist prior to re-opening the area for use without PPE.

As required by law, many industrial facilities and refineries already have emergency response plans in place and have the management systems and infrastructure to handle a variety of emergencies. However, organizations face unique risks and challenges to keeping their people safe while continuing operations during this COVID-19 crisis. We develop procedures on how to respond immediately, and protect your employees, assets and property. Learn more about how to keep your employees, operations and reputation safe from COVID-19. 

 

Tags: Pandemic Planning, Pandemic Plan

Business Continuity Planning During the Coronavirus

Posted on Fri, Mar 13, 2020


Originally published on jensenhughes.com

As (COVID-19) coronavirus seizes the world, the economy is grappling with how to respond to this growing threat. Businesses across the globe need to protect the health of their employees and minimize the impact to their business with robust business continuity planning.


What is Business Continuity Management?

At the highest level, a business continuity management program refers to the holistic management process that identifies potential threats to your company and helps you develop organizational resilience during and after an actual event.

There are various events, including the current coronavirus pandemic that can cause significant business disruptions. These disruptions may result in temporary or permanent loss of the critical requirements — including vital records, IT infrastructure and staff needed to execute business operations.

In order to protect a company’s viability, businesses can work to develop site-specific recovery strategies that focus on a disruption during a peak business cycle, when the services or output are at the highest level and most critical point.

Business Continuity Tools During Coronavirus

A Business Impact Analysis (BIA) enables a company to identify sites and business operations that, when absent, would impact profitability and threaten company survival. While the size and complexity of essential business elements required for sustainability vary among companies, the ability to quantify and prioritize critical business operations is a key business continuity element.

Completing a BIA will allow for each department within your organization to explain and discuss how the coronavirus, or another unexpected event, may affect their business function. Managers should also review the following business continuity planning elements for each critical business function:

  • Identify the duration and point in time when an interruption would impair critical processes and develop recovery time objectives.
  • Estimate the maximum allowable downtime for each specific business function.
  • Test work-from home bandwidth and feasibility.
  • Identify and implement actions to mitigate risk and develop tactical methods for continuing critical operations safely.
  • Develop training and exercises for Business Continuity Plan (BCP) personnel assigned to support the continuity of operations.

Site-Specific Responses and the Coronavirus

A BCP should include site-specific details that can direct critical process continuation and restoration. The following continuity plan components should be included in a site-specific BCP.

1. Plan distribution list: Names, addresses, and contact information of those that retain secure access to the BCP.

2. Key contacts and notification procedures: Identify all primary and secondary contacts that must be made aware of the interruption to your business. It’s important to routinely verify contact information for accuracy, and train personnel in BCP activation and notification procedures.

3. Key staff roles and responsibilities: Develop position-specific checklists and procedures detailing responsibilities from business continuity implementation through recovery. Task teams should be formed, at a minimum, to cover each critical business process. Business Continuity Team structure, organization charts, and interfaces should be clearly communicated. It may be necessary to provide cross team training, in the event that primary team members are not available.

4. Off-site recovery location(s): Include address, contact information, available on-site equipment, and any necessary external equipment for effective operations.

5. Recovery action plan: Identify/develop incremental processes and procedures necessary to recover each critical business process. Response checklist timelines may include time increments such as 1st hour, 24-hours, 48 hours, one week, one month, and long-term recovery.

6. Customer data: Identify communication methods and necessary contact information in order to inform customers of disruptions of deliverables. Effective customer relations and communication may be critical in retaining clients and maintaining positive relationships during a business interruption.

7. Critical vendor and supplier contact list: Identify contact information of vendor and supplier dependencies and interdependencies. Transportation delays or events at suppliers’ locations could affect delivery times; therefore the plan should address this issue.

8. Alternate critical vendor and supplier list: Supply chain failures, like the ones we’re seeing across the world due to the coronavirus can be crippling to key business components. Through the planning process, alternate vendor and suppliers should be explored, and contact information and materials should be documented in order to reduce the impact of primary suppliers’ disruption.

9. Documentation and Insurance details: Identify details of insurance coverage and accurate contact information. The burden of proof when making claims typically lies with the policyholder. Accurate and detailed records are imperative. Documentation forms should be made available to all critical business unit leaders for timely documentation.

10. Technology requirements: Identify necessary hardware and software, and the minimum recovery time requirements for each critical business process.

11. Backup data details: Your plan should identify details of data backups and recovery methods (Recovery Time Objectives). If current backup procedures are questionable, mitigation measures should be evaluated prior to a business disrupting event.

12. Equipment requirements: Identify equipment requirements for each business unit, primary and alternate suppliers, and recovery time goals.

13. Review and revise: On an annual basis, or when a significant change occurs in organization structure, process flow or technology, or following an incident, incorporate newly identified hazards and vulnerabilities and mitigation processes into the business continuity plan. Include revisions in critical staff, facilities, IT requirements, vendors and suppliers and vital records.

While many countries are focused on ensuring consistent public health services, there is still a responsibility for businesses to mitigate the risks that the coronavirus poses to its employees, stakeholders and customers. BCPs allow businesses to plan, prepare and respond if the pandemic becomes more severe.

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Tags: Pandemic Planning, Pandemic Plan, Business Continuity Plan

Preparing Your Business for the Next Hurricane Dorian

Posted on Fri, Sep 13, 2019

Originally published on jensenhughes.com

On September 1st, Hurricane Dorian made landfall in the Bahamas before tearing a path towards the U.S. east coast, making a second landfall on Cape Hatteras, North Carolina. Currently, the death toll stands at 50, while the devastation to homes, businesses and public utilities, particularly on Great Abaco Island, has been unprecedented.

According to the U.S. Congressional Budget Office, expected annual damage from hurricanes will amount to .22 percent of GDP or $39 billion by 2075. As Dorian demonstrated, hurricanes and major weather events remain a significant threat to residents and businesses operating in vulnerable areas. In preparation, companies must ensure that their operations can withstand an unprecedented business disruption and be ready for the next Dorian.

An important first step for any company is to develop a Business Continuity Plan (BCP). How would a catastrophic event impact your operations? How will your employees work? Will your supply chain be disrupted and for how long? Business continuity response processes, procedures, and personnel responsibilities ensure that you can save recovery costs, business revenues, and even people’s lives.

The BCP and Corporate Leadership

Every organization is unique and requires a tailored BCP to suit their needs. A well-developed plan should be able to sustain the viability of the affected businesses while ensuring the continuity of, and safeguarding of key business interests, relationships, and assets.

The primary purpose of a BCP is to minimize operational, regulatory, financial, and reputational impacts of a significant business disruption to accelerate the time frame to return to “business as usual”. At the base level there are core elements company leadership should champion when developing their BCP. Whether you’re running a manufacturing company, oil rig, or restaurant, leadership should:

  • Support budget allocations for the BCP program
  • Appoint key personnel to lead the program
  • Ensure the BCP team is staffed and fully trained to implement the plan
  • Provide the resources necessary to maintain an up-to date program that accounts for any site-specific changes to facilities, personnel, or processes
  • Provide ancillary support and resources to implement the BCP process and recovery strategies

Once an initial BCP is developed, company leadership should continually support plan evaluations that account for evolving operations, potential disrupting scenarios, and identified vulnerabilities. If new vulnerabilities or threats are identified, the BCP should be updated to address those newly identified variables.

The Business Continuity Plan

When effectively developed, tested and accessible, a business continuity plan can address operational disruptions of key business resources. At a minimum, it should cover your facilities or workspaces, supply chain, IT infrastructure and your employees.

Site specific recovery strategies should be developed with the assumption that the disruption will occur during the peak business cycle, when the services or output are at the highest level and most critical point.

As development in coastal areas and global warming increases, more businesses should expect to be affected by extreme weather events. BCP managers should be vigilant and regularly monitor incidents that may cause a business disruption or have a serious impact to operations. We can help you develop an effective BCP and prepare you for any emergency.

TRP Corp Hurricane Checklist

Tags: Corporate Hurricane Preparedness, Emergency Preparedness, Hurricane Preparedness

Identify, Review and Verify for Effective Emergency Response Plans

Posted on Wed, Nov 15, 2017

As potentially stressful, chaotic and financially imposing as an emergency, disaster or crisis can be, some companies are still not prioritizing preparedness and response planning.

The three building blocks of preparedness - identify, review and verify can provide the means to effective corporate emergency response plans. When all three aspects are in motion, the ongoing process of preparedness is established, giving companies the best possible prognosis for a response.

 

Identify Preparedness and Response Plan Criteria

Company profiles are becoming increasingly sophisticated with an intricate network of technology, human resources, and global influences. Companies must routinely identify relevant risks and threats in order to develop practical, compliant, and up-to-date response plans. Improvising and implementing unplanned response actions for unrecognized scenarios often results in inadequate, and potentially damaging outcomes.

Preparedness is a continual sequence of analysis. Operational consolidation, growth, and changing threat variables require recognition. To prepare for and respond to an incident, emergency managers should identify the following preparedness and response planning criteria:

  • What risks and hazards may result in an emergency or disaster response event?
  • What processes are put in place to limit the exposures to risks and hazards?
  • What community/environmental sensitivities exist?
  • Who will respond when an incident occurs?
  • What processes, procedures, and training are in place for responders?
  • How will individuals/employees secure their safety?
  • What tools/equipment are necessary to respond to an incident and who will provide them?
  • What local, state, and/or federal organizations should be consulted?
  • What regulations apply?

 Magnifying glass showing compliance word on grey background.jpeg

With risks, threats, and preparedness needs identified, companies should move forward with developing site-specific response plans. However, preparedness does not end with a completed response plan.

 

Review Response Plans

Corporate preparedness programs and applicable response plans need to be reviewed for accuracy and effective responses to newly identified variables.  Employees familiar and trained with preparedness efforts are more likely to ensure best practices are carried out.

Reviews of response procedures, mitigation opportunities, best practices, response objectives, and operational requirements are necessary to ensure preparedness and effective response measures are in place. Reviews should include, but are not limited to:

  • Data and computer needs: Review the procedural details of computer backups, data restoration methods, and the minimum program needs to re-establish critical business processes. Companies should examine current data center outsourcing or other alternatives to ensure continuity and accessibility.
  • Notification lists: Response plan administrators must be certain that newly-assigned personnel are included in the plan, as necessary, and that notifications are being delivered to accurate e-mail addresses and/or phone numbers. Review contact lists to ensure all necessary information is correct.
  • Communication needs: Clear and effective communication channels must remain available to disseminate information to employees, assess and relay damage, and coordinate a recovery strategy. Evaluate current communication equipment and/or mass notification systems to communicate to key individuals, company employees, or an entire client base, as each scenario deems necessary.
  • Supply Chain: As a company’s needs change and new suppliers come online, potential suppliers should be evaluated, and plans should be updated to reflect any changes. Alternate resources should be reviewed to ensure availability, delivery, and continued operations in the event primary suppliers are not available when needed.
  • Essential Personnel: Ensure necessary minimum staffing levels are acceptable to remain operational. Review individual responsibilities and recovery time objectives with staff, contractors, and suppliers.
  • Equipment needs: Review availability of necessary equipment and establish processes for response, recovery, and continued operations, to minimize downtime and additional recovery efforts.

The review of company emergency response plans should include debriefings with collaborative response entities. Meetings with these outside responders should confirm specific plan and response details that can be carried out to be consistent with best practices and company protocols. Groups to consider in planning reviews include, but are not limited to:

  • Local responders (fire, police, emergency medical services, etc.)
  • Government agencies (LEPC, Emergency Management Offices, etc.)
  • Community organizations (Red Cross, weather services, etc.)
  • Utility Company(s) (gas, electric, public works, telephone, etc.)
  • Contracted Emergency Responders
  • Neighboring Businesses

 

Verification of Effectiveness and Accuracy

The overall emergency response program readiness must be verified for effectiveness and accuracy, regardless of the threat or hazard. Training and exercises are valuable verification tools that can confirm effective response planning and preparedness efforts. Verification should include, but is not limited to:

  • A system for assessing emergency scenarios and prioritizing incident responses
  • Thresholds and procedures for activating the Incident Management or Crisis Management Team
  • Notification information (if maintaining accurate contact information is challenging, consider opting for an e-mail verification system that enables each contact to verify their contact information.
  • Roles and responsibilities of the Incident Management or Crisis Management Team members
  • Communication and notification procedures to facilitate interaction among responders and Incident Management Team
  • Guidelines and checklists to assist in an efficient and organized response
  • Verification of on-site hazardous materials details, response equipment, and response times

Technology, such as a web-based response planning system, provides companies with the tools to balance enterprise-wide standardization and site-specific regulatory criteria. Companies responsible for multiple buildings, possibly in various locations, should demonstrate a commitment to emergency management by creating a systematic template for incident response policies, procedures, and practices. These templates should enable users to incorporate the detailed, site-specific data necessary for an effective response.

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Tags: Emergency Response Planning

Are your Business Continuity Plans Ready for the Next Irma or Harvey?

Posted on Thu, Sep 21, 2017

Words like catastrophic, unprecedented and record-breaking should be reserved for works of fiction. However, when you see the communities impacted by Hurricanes Harvey and Irma, those words become reality. Intense weather systems appear to be developing with more frequency. In preparation, companies must ensure that their operations can withstand an unprecedented business disruption. They must be ready for the next Harvey or Irma.

 

Many companies have Business Continuity Plans (BCP) in place. However, they are often untested or ill-suited for extensive conditions or durations. How would a catastrophic event impact your operations? How will your employees work? Will your supply chain be disrupted and for how long? Mitigating business continuity response processes, procedures, and personnel responsibilities must be adaptive enough to account for destructive weather conditions.

The BCP and Corporate Leadership

Every organization is unique and requires a tailored BCP to suit their particular needs. A well-developed plan should be able to sustain the viability of the affected businesses unit while ensuring the continuity of, and safeguarding of key business interests, relationships, and assets.


The primary purpose of a BCP is to minimize operational, regulatory, financial, and reputational impacts of a significant business disruption to accelerate the time frame to return to “business as usual”. Simply stated, a business continuity plan is a ‘restoration plan.’  In order to effectively implement a relevant BCP, company leadership must be support the development and implementation of an effective plan. In order to ensure critical operations can withstand unprecedented events, corporate leadership should:


  • Support budget allocations for the BCP program
  • Appoint key personnel to lead the program
  • Ensure the BCP team is staffed and fully trained to implement the plan
  • Provide the resources necessary to maintain an up-to date program that accounts for any site-specific changes to facilities, personnel, or processes
  • Provide ancillary support and resources to implement the BCP process and recovery strategies

Once an initial BCP is developed, company leadership should continually support plan evaluations that account for evolving operations, potential disrupting scenarios, and identified vulnerabilities. If new vulnerabilities or threats are identified, the BCP should be updated to address those newly identified variables.

Background conceptual image with papers flying in air.jpeg

The Business Continuity Plan

When effectively developed, tested and accessible, a business continuity plan can address operational disruptions of key business resources including:

  • Facilities or Workspace
  • Infrastructure or IT Applications/Systems
  • People
  • Supply Chain

Your business continuity plan should include, but are not limited to the following considerations:

  • Notification procedures for key stakeholders
  • Internal and external contact directories
  • Business Continuity Team notification and activation procedures
  • Business Continuity Team structure, organization charts, and interfaces
  • Position-specific checklists
  • Facility information and documentation forms
  • Detailed critical process recovery tasks, workaround procedures and reference documents
  • Identification of staff required to recover those critical processes
  • Detailed information concerning alternate facilities
  • Plan Review and Update procedure

Site specific recovery strategies should be developed with the assumption that the disruption occurred during the peak business cycle, when the services or output are at the highest level and most critical point. This will improve the potential for that plan to be effective.

Managing Vulnerabilities

BCP managers should regularly monitor incidents that may cause a business disruption and/or have a serious impact to operations.  A BCP manager should:

  • Comprehend basic BC principles and methods
  • Ensure consistency in business impact analysis to identify critical business functions
  • Understand the correlation between operations, business continuity, IT disaster recovery, and emergency planning
  • Ensure that the BCP reflects the current hazard risk analysis, mitigation processes, business impact analysis, response management, and recovery strategies
  • Encourage coordination between all company staff while implementing a BCP
  • Identify and initiate appropriate, cost-effective strategies and procedures to recover critical business functions and information assets
  • Formally assign BC responsibilities to appropriate department managers and ensure each receives proper training to implement the BCP
  • Ensure that necessary contractual agreements exist for recovery of critical business functions and information resources
  • Review, update, and communicate BCP content changes
  • Continual improve the BCP as required

Note: The list of vulnerabilities is not all-inclusive. Additional vulnerabilities may be applicable to your company.

TRP Corp Hurricane Checklist

Tags: Business Continuity Plan

Risk Mitigation and Corporate Response Planning

Posted on Thu, Aug 24, 2017

“For every action, there is an equal and opposite reaction.” - Sir Issac Newton

In an industrial facility, every action has the ability to become an emergency, incident or disaster. Most “actions” are intended to contribute to the financial bottom line, but others may put your employees, the facility or surrounding environments at risk. These actions can create unsafe conditions, operational risks, or environmental damage. Once recognized and evaluated, these hazards, threats and risks may be eliminated or controlled through mitigation measures and procedural planning.

The Corporate Risk Assessment

In order to identify necessary responses to incidents or emergency situations, a detailed risk assessment should be should conducted for potential emergency scenarios.  As risk assessment may include but is not limited to the following:

  • Identify your site-specific hazards, threats or risks. These may include, but are not limited to:
    • Fire
    • Explosion
    • Natural Hazards
    • Terrorism
    • Hazardous materials spill or release
    • Workplace violence
    • Employee pandemic
    • Utility outage
    • Mechanical breakdown
    • Supply chain failure
    • Cyber attack
  • Based on the hazards, identify if the impact is low, medium or high for each of the following:
    • People
    • Property
    • Operations
    • Environment
    • Financial
    • Regulatory or legal
    • Contractual
    • Reputation
  • Identify your site-specific hazards and consider:
    • High probability/low impact scenarios
    • Low probability/high impact scenarios

The probability and impact severity of a risk should determine the priority level for planning and mitigating the hazard.

Minimize Impacts through Mitigation

Current processes, procedures, and assets can directly minimize the impact or likelihood of unsafe actions or circumstances. These may be unique to each specific industry, company, and site. Some processes, procedures, or assets may simplify or automate reactions, responses or recovery requirements.

It is important to understand that a single asset may be able to mitigate multiple hazards. Examples of assets include, but are not limited to;

  • Local response groups
  • On-site fire brigades
  • Backup generators
  • Response equipment
  • Routine data backups

Continuous Improvement on the Mechanism of Metal Gears..jpeg

As you assess potential impacts, identify any vulnerabilities or weaknesses in your current processes, procedures, and assets that would make them susceptible to loss. When these vulnerabilities are identified, it presents opportunities for hazard prevention through procedures/processes upgrades or risk mitigation.

Your company should review or initiate a risk mitigation budget based on the results of the risk analysis. The probability and impact severity should determine the priority level for correcting the hazard. The higher the probability and impact severity, the higher the emphasis should be on corrective action. With priorities in place, mitigation measures may include:

  • Changing operational processes and procedures
  • Eliminating the cause of a potential threat
  • Addressing regulatory compliance issues resulting from internal or external audits
  • Introducing risk reducing engineering controls, when applicable
  • Implementing proactive administrative controls or work place practices
  • Establishing systematic equipment inspection processes
  • Developing a communication plan that includes a contact verification system
  • Updating or develop applicable response plans

Business Continuity Plans

Business continuity and response plans should address the results from a site-specific risk assessment. When companies utilize systematic methods to identify objectives and implement potential response in conjunction with intuitive formats, the process of recovery, continuity, and sustainability can be streamlined.

At a minimum, a business continuity plans should identify the following:

  • Key operations and critical activities
  • Critical processes and strategies for recovery
  • Resources necessary for recovery
  • Evacuation and relocation information and policies
  • Key response personnel

 

Need information regarding crisis and emergency management industry standards and best practices, click the image below to submit form information: 

Corporate Crisis Management

Tags: Business Risk, Mitigation, corporate preparedness

Top 10 Reasons to Improve Emergency Response Planning

Posted on Thu, Aug 10, 2017

Emergency management programs are in place for “when” an emergency happens, not “if” an emergency happens.

Natural disaster, human error, homegrown terrorism, regulatory compliance, equipment failure, or an awareness of potential crises...the list of emergency scenarios can be extensive. When companies prioritize emergency response planning, they can optimize their response. However, the cost/benefit of effective emergency management programs is often greater than expected. Below are ten “best practice” reasons why your company should prioritize emergency response programs and preparedness initiatives:

1. Demonstrate a commitment to safety: Companies should confirm that safety is a priority. By establishing proven countermeasures to potential threats and associated risks, companies can substantiate that the safety of employees and the protection of surrounding communities and the environment is important. Prioritizing emergency preparedness initiatives demonstrates a company’s commitment.

2. Improve regulatory compliance: Regulatory non-compliance fines are an unnecessary expense. These costly fines can result from the lack of implemented, thorough, and compliant programs. By systematically aligning regulations with corresponding response plans and their components, your company can identify plan deficiencies to avoid unnecessary fines or possible mandatory shutdowns.

3. Simplify updating processes: One of the main reasons response plans aren’t effective is because they are outdated. Continual administrative duties associated with personnel contact information, assignments, training records, exercises, and continual plan updates is challenging. Maintaining up-to-date response plan has become significantly easier with advanced technology and innovative software programs. If your company has not evaluated available programs, the cost and time associated with maintaining current administratively taxing response plans may be worth the investment.

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.

 Cement Plant and power sation during sunset.jpeg

4. Standardize 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. Consistent, yet site specific response methods can assist responders in assessing, prioritizing, and responding to incidents.

5. Improve asset utilization: Companies should 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 identified inefficiencies, and/or budgeting for additional response training or improved equipment will improve the overall effectiveness of an emergency management program.

6. Mitigate facility/site conditions: The conditions of your facility or site may have an impact on safety or an effective response. Conditions that pose a risk to occupants, the environment, infrastructures, and/or the surrounding communities should be altered or eliminated. The risk assessment process can be used to identify conditions that can lead to emergency incidents.

7. Reduce incidents through risk assessments: When potential threats and risks are identified, measures can be taken to minimize the impacts of those scenarios or possibly eliminate the potential of the emergency. 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.

8. Reduce downtime: Emergencies can cause operational downtime and production loss. This impact profits and reduces revenues. By optimizing and implementing the most effective and functional emergency management program possible, incidents can be promptly managed and rapidly demobilized, thereby reducing response-related costs and downtime.  The repercussions from an incident can also include detrimental relationships with customers, the surrounding community, and stakeholders.

9. 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.

10.Elevate training and drills: 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.

 

Simplifying the Complexity of Response Plans:  The TRP Approach

Tags: Emergency Management Program, Emergency Response Planning

Rain, Stormwater and Company Regulatory Compliance

Posted on Thu, Jul 27, 2017

According to the National Climate Assessment’s 2014 report,  “Heavy downpours are increasing nationally.”1 That means, when it rains, it often pours. The study revealed that rain intensity in the Southwest has increased nearly 30 percent in recent decades. However, intense rain is not limited to specific areas of the country. The National Centers for Environmental Information, part of the National Oceanic and Atmospheric Administration, noted that between October 2016 and March 2017, California averaged 30.75 inches of precipitation, the second-highest average since such records began being kept in 1895.

Companies need to take notice and ensure they have compliant stormwater pollution prevention plans as required by the Environmental Protection Agency, and response plans that address responses to localized flooding.

The purpose of a Stormwater Pollution Prevention Plan (SWPPP) is to identify potential stormwater pollution sources and reduce the potential for pollutants to reach nearby waterways. The EPA issues “General Permits” for stormwater discharges associated with industrial activity under the National Pollutant Discharge Elimination System (NPDES) program (as defined in 40 CFR 122.21 and 40 CFR 122.26). Establishing procedures and controls is necessary to accomplish the following SWPPP objectives.

  • Identify pollutants that may come in contact with stormwater.
  • Establish measures to prevent pollutants from coming in contact with stormwater.
  • Establish controls to reduce or eliminate the potential for contaminated storm water being released to the environment.

Runoff that contacts industrial materials can transport pollutants into nearby water sources. When companies are not in compliance with NPDES regulations, they may be assessed fines.

For example, the Ohio Environmental Protection Agency ordered a company building a natural gas distribution pipeline to pay $431,000 for water and air pollution violations at various locations across the state. Over the course of three months, Ohio officials revealed that 18 incidents including mud spills from drilling, stormwater pollution and open burning at construction sites have been reported. The company was ordered to submit plans to address potential future releases and restore impacted wetlands which stretch from Washington County in southeastern Ohio to Defiance County in the northwest.

rain runoff.jpeg

An SWPPP and required site evaluations should be incorporated, as necessary, into a company’s enterprise-wide emergency management program. Completed site compliance evaluation checklists must be retained for a period of one year after the expiration of the General Permit.

Ensuring regulatory compliance, preparedness and employee safety requires a fundamental emergency management program. With the intensity of rainfall rising, your emergency management program should be sure to plan for extreme weather scenarios with effective and realistic response plans. Below are preparedness t concepts to guide your flood emergency response planning:

  1. Assess the flood risk potential in your area. Be aware of stream, ditches, drainage areas, and other low-lying areas on the property.
  2. Map facility and identify multiple access and egress routes.
  3. Familiarize staff with the evacuation plan and alternate routes.
  4. Ensure important documents and server(s) are not stored in basement or ground level, and review backup procedures.
  5. Update employee contact lists with alternate contact information in the event an evacuation is necessary.
  6. If evacuation is necessary, assign trained personnel to secure the premises and equipment (such as sandbagging and/or extending regulator vents and relief stacks above the level of anticipated flooding, as appropriate.).
  7. Perform continuous monitoring of the flood through various media outlets and weather tracking.
  8. Unplug all electrical devices.
  9. If flooding is probable, discuss shutting off high voltage power and natural gas lines with energy providers.
  10. Maintain hazards awareness regarding, but not limited to:
    • Structural damage
    • Downed power lines
    • Leaking natural gas, water, and sewer lines
    • Poisonous snakes and other wildlife sheltering in structures, vehicles, and furniture
    • Direct contact with flood water, mud, and animal carcasses
  11. Deploy personnel so that they will be in a position to take emergency actions, such as shutdown, isolation, or containment in the event of an emergency.
  12. Identify, contract, and communicate with water damage specialist(s).
  13. Ensure cleanup equipment is available, adequate, and ample. If clean up will be done by employees, Personal Protective Equipment (PPE) may be required. OSHA requires Personal Protective Equipment (PPE) for cleanup operations if the water source is contaminated with sewage, chemicals, or other biological pollutants.
  14. Consider obtaining portable pumps and hoses from local suppliers.
  15. If applicable, determine if flooding can expose or undermine pipelines as a result of erosion or scouring.
  16. If applicable, coordinate with emergency and spill responders on pipeline location(s) and condition, and provide maps and other relevant information to them.
  17. If applicable, advise the State Pipeline Safety Office (for intrastate lines), or RSPA's Regional Pipeline Safety Office (interstate lines) prior to returning pipelines to service, on increasing the operating pressure, or otherwise changing the operating status of the line.
  18. Conduct a post-incident review and identify mitigation opportunities to prevent future flooding impacts.

Source

1 Renault, Marion. The Columbus Dispatch. 9 May 2017. http://www.cantonrep.com/news/20170509/ohio-epa-fines-rover-pipeline-contractor-430000. 14 July 2017.
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Common Crisis Management Planning Mistakes to Avoid

Posted on Thu, Jul 13, 2017

Whether it a social media post gone wrong or an unexpected supply chain disruption, your company needs to be being able to identify potential crises, prioritize responses, and engage with stakeholders effectively. During a crisis, your company should be able to depend on a response plan in order to protect the financial and reputational aspects of your operations. Poor crisis management performance can be prevented with proper planning.

Below are six common crisis management planning mistakes that can negatively impact a response.

1. Failure to predict potential crisis situations: Your Company must determine potential crises, analyze them, and design responses to each. Regardless of the circumstances, every crisis has the potential to negatively impact the company’s reputation, daily operations, and financial performance.

In addition to planning for potential natural disasters, companies must plan for business continuity issues, operational hazards, and security vulnerabilities. Whether security vulnerabilities come in the form of a network intrusion, a computer virus, or an actual physical attack, site and electronic security should be taken into consideration when assessing potential threats.

2. Unclear communications plan on company positions: Pre-planned communications methods must be in place to state a company’s position on potential issues. Companies must be prepared to voice factual and timely information before falsehoods and negative public images spiral into rumors and publicity nightmares. A crisis will likely generate news coverage that may adversely impact employees, investors, customers, suppliers, and possibly the community. It may directly harm a company's reputation, offices, and revenues. Additionally, policies and procedures, as well as information regarding the organization should be developed well in advance of any crisis.

Companies should also establish effective communication pathways with local emergency services, hospitals, police, and fire departments. Any miscommunication can add to the duration of incidents and potentially expound upon the crisis scenario. Companies should identify support organizations during the crisis management planning process and make contact information available as necessary. A detailed and collaborative planning effort can equate to a faster recovery time, minimizing the ongoing effects of the disaster.

3. Insufficient regulatory compliance: Companies must be fully aware of the regulations and/or laws enacted by state or federal mandates that could affect company operations. Compliance costs are typically lower than the expenditures associated with non-compliance fines, litigation, reputational risk, and government mandated shutdown of operations. Companies must implement a budget, safety program, and preparedness measures that ensures regulatory compliance.

4. Overlooked prevention and mitigation measures: There are various communication and crisis response details and variables that must be considered and planned for. However, there may also be mitigation measures that can prevent crisis situations and proactively deter negative perceptions and actions. This may include performing safety and operational audits and assessments, additional personnel training and business continuity planning.

For example, business continuity combined with hurricane planning can prepare a company to react to an impending storm. In developing these plans, employees must have the resources, procedures, and safeguards to successfully mitigate its effects and sustain critical business processes.

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5. Lack of effective Crisis Management Planning: Companies should prepare a plan for responding to all internal and external aspects of the crisis. A useable Crisis Management tool should include, but is not limited to the following:

  • A contacts database of response organizations/individuals
  • Stakeholder identification, assessment, and documentation tools and reports
  • Task scheduling, documentation, and reporting tools
  • Crisis Management performance assessment tool
  • Incident, exercise, and maintenance modes
  • Database containing all incidents and exercises, with ability to retrieve all documented conversations and tasks
  • Accessibility to multiple users simultaneously involved in multiple incidents
  • Integrated help system
  • Intuitive maintenance tools

6. Failure to establish a command hierarchy or structure: A Crisis Management Team (CMT) should be aware of their roles and responsibilities, and be properly trained to act on those responsibilities should a critical incident or crisis occur. It is not effective for a team to be established and assigned roles as a crisis is unfolding. Each member of the CMT must be in place and comfortable with their role long before an incident occurs. Inability to provide clear specific duties, tasks, or functions for each team member during a crisis will create indecision, confusion, and an inability to perform at optimal levels.

For a crisis management plan to be properly initiated, those selected for the crisis management team should understand established response policies, the context of crisis communications, and their individual responsibilities. A strategic response framework with checklists and criteria that can guide the decision-making process should be developed and tested prior to a crisis.

7. Failure to exercise: It's one thing to have a plan in place, but if the response team has never practiced potential scenarios, the plan is not likely to be effective. Lessons learned and plan updates (including updated contacts and procedures) should be readily available and provided to all crisis response team members. Each member should be included to practice elements in the plan on a regular basis.

8. Failure to establish workable format: The response plan should be in a format that is intuitive and easy to use. In some cases, a quick reference guide should be readily available to all team members.

9. Failure to evaluate and update: If the crisis management plan is exercised or activated, team members should review results and feedback to determine if adjustments should be made. Lessons learned from exercises and incidents have demonstrated that many companies lack the tools to properly manage a response. In order to take response efforts to the next level, action items resulting from the exercises should be completed in a timely manner.

Specific recovery guidelines provide agreed-to procedures to help facilitate an expedited return to normal operating conditions.

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What you Need to Know About Company-Wide Emergency Action Plans

Posted on Thu, Jun 29, 2017

If you have a small staff and the size of your site is easily manageable, developing a comprehensive emergency action plan for one location may not be a difficult task. However, ensuring compliant and site-specific emergency action plans for multiple locations and an exponential number of employees can be a challenge.

Any business with more than 10 onsite employees is likely to require an Emergency Action Plan (EAP) by the Occupation Safety and Health Administration (OSHA), but what happens when your company has multiple locations? Why should these plan be a priority and how do you confirm compliance for each location?

What is an Emergency Action Plan?

An EAP is intended to guide employer and employee actions, such as evacuation, during workplace emergencies. These plan are typically utilized when an onsite fire brigade is not in place. At a minimum, an EAP must include the following requirements:

  • Means of reporting fires or other emergencies
  • Evacuation procedures, including exit route assignments
  • Procedures for employees who remain to operate critical operations before they evacuate
  • Procedures to account for all employees after evacuation
  • Procedures to be followed by employees performing rescue or medical duties
  • The name or job title of every employee who may be contacted

While not required for compliance, OSHA also suggests:

  • Description of the alarm system that informs employees to take certain actions
  • The site of an alternative communications center
  • A secure location to store originals or duplicate copies of accounting records, legal documents, your employees' emergency contact lists, and other essential records.

 

Why Prioritize Emergency Action Plans?

According to the 2016 OSHA Field Operations Manual, any employer who willfully or repeatedly violates regulations may be assessed a civil penalty of at least $8,908 for each willful violation. The exponential violation cost for companies with multiple locations could be staggering and financially crippling.

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As agencies continue to redefine their monetary penalties and prioritize employee safety issues, companies must not rely on the prospect of an agency inspection to ensure preparedness programs are sufficient. For companies with multiple locations, the EAP details should be part of an overall emergency management program and create an atmosphere of response readiness. Each plan should identify site-specific actions by employers, employees, or other building occupants to ensure safety from fire emergencies and other potentially devastating scenarios.

If government regulations are applicable to your facilities or operations, your enterprise must prioritize compliance and associated management techniques in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations.

 

How to Confirm EAP Compliance?

When company operations span across multiple locations, compliance verification in addition to daily operational oversight can become increasingly complicated. The cost to initiate, upgrade, and/or maintain a proactive EHS program may be seen as a excessive and possibly trivial company expense. However, compliance efforts and compliance tracking software programs are often less expensive than agency fines. By confirming regulatory compliance, companies can deliberately protect lives, prevent hazardous impacts, limit property damage, and eliminate increasing regulatory fines.

Effective technology can be a useful and relatively inexpensive tool for companies to monitor continually evolving operations and regulatory requirements. While many businesses utilize Excel spreadsheets to manage these requirements, the technique is burdensome, administratively taxing, and often ineffective for mid to large size companies. As companies grow and expand, the number of spreadsheets can be extensively overwhelming and complex. Midsize and larger operations should consider utilizing database technology to ensure enterprise-wide compliance on multiple government agency fronts.

In order to minimize non-compliance, owners should identify potential emergency scenarios and necessary site-specific safety measures, including those required in OSHA’s EAP.

A comprehensive response planning system should identify the resources required to effectively manage potential hazards, document necessary response actions, and fulfill multiple compliance mandates. Upgrading to web-based response planning software will enable each location across an enterprise to;

  • Reduce the need for multiple plans
  • Minimize administrative costs
  • Simplify plan reviews
  • Minimize discrepancies across various plans
  • Streamline response directives from one source

 

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Tags: Emergency Action Plan