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PREP for Corporate Regulatory Compliance

Posted on Mon, Oct 07, 2013

Industry-specific regulations often require response exercises for compliance. The National Preparedness for Response Exercise Program (PREP) is designed to facilitate the periodic testing of oil spill response plans for certain vessels and facilities, and provide companies an economically feasible mechanism for exercise compliance.

This unified federal effort provides a consistent set of guidelines that satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline Hazardous Material Safety Administration (PHMSA) , and the Bureau of Safety and Environmental Enforcement (BSSE). Completion and documentation of the PREP exercises satisfies all OPA 90 mandated federal oil pollution response exercise requirements.

Exercises must be designed to test responder competencies, and response plan components for effectiveness and accuracy.  In preparation for these exercises, companies should develop exercise-planning documents and participant packages that contain exercise objectives, scenarios, ground rules, and in some cases, simulated injects. Through exercises, responders gain an understanding of the site-specific Emergency Response Plan framework. Exercises provide a mechanism to test participants’ knowledge and understanding of how to mobilize an appropriate response, execute communications and decision-making processes, and effectively manage a worst-case spill response. Effectively planned and executed exercises typically result in improved communication and multi-agency response capabilities in the event of an actual spill.

Common exercise objectives include, but are not limited to:

  • Practice application of National Incident Management System (NIMS) and the Incident Command System (ICS)
  • Improve understanding of the Emergency Response Team and Incident Management Team organizations.
  • Improve understanding of the internal and external response capabilities, associated responsibilities, and expectations of the company.
  • Practice documenting and communicating response actions, management decision, and tracking of resources, using standardized Incident Command System (ICS) forms and the Oil Spill Response Plan.
The following 15 PREP components must be exercised during a three years period  in order to fulfill PREP requirements:

Organization

1. Notifications: Test the notification procedures identified in the Area Contingency Plan (ACP) and the Spill Response Plan.

2. Staff mobilization: Demonstrate the ability to assemble the spill response organization identified in the ACP and the Spill Response Plan.

3. Operate within response management system. Including:

  • Unified Command: Demonstrate the ability of the spill response organization to work within a unified command.
  • Response management system: Demonstrate the ability of the response organization to operate within the framework of the response management system identified in their respective plans.

Operational Response

4. Source control: Demonstrate the ability of the spill response organization to control and stop the discharge at the source.

5. Assessment: Demonstrate the ability of the spill response organization to provide initial assessment of the discharge and provide continuing assessments of the effectiveness of the tactical operations.

6. Containment: Demonstrate the ability of the spill response organization to contain the discharge at the source or in various locations for recovery operations.

7. Recovery: Demonstrate the ability of the spill response organization to recover, mitigate, and remove the discharged product (includes mitigation and removal activities).

8. Protection: Demonstrate the ability of the spill response organization to protect the environmentally and economically sensitive areas identified in the ACP and the respective industry response plan.

9. Disposal: Demonstrate the ability of the spill response organization to dispose of the recovered material and contaminated debris.

Response Support

10. Communications: Demonstrate the ability to establish an effective communications system for the spill response organization.

11. Transportation: Demonstrate the ability to establish effective multi-mode transportation both for execution of the discharge and support functions.

12. Personnel support: Demonstrate the ability to provide the necessary logistical support of all personnel associated with response.

13. Equipment maintenance and support: Demonstrate the ability to maintain and support all equipment associated with the response.

14. Procurement: Demonstrate the ability to establish an effective procurement system.

15. Documentation: Demonstrate the ability of the spill response organization to document all operational and support aspects of the response and provide detailed records of decisions and actions taken.

For a free download on "TIPS on CONDUCTING an EFFECTIVE EXERCISE", click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: USCG, PHMSA, EPA, Training and Exercises, Safety