Through timely internal audits, facility assessments, attentive training and exercise programs, and best practices, response plans can be a working reflection of facility compliance and corporate preparedness. Necessary response documentation and plans established prior to an emergency allow for a comprehensive review of processes and procedures, and can result in an improved response to actual emergencies. The following questions, while not all-inclusive, can be used as planning discussion points to identify necessary response elements in order to develop or assess emergency response plans:
- What agencies and specific regulations apply to my location(s)?
- If applicable, have material safety data sheets (MSDS) been updated and have their properties been included in the planning process?
- Has an inspection taken place, and if so, have non-compliant issues been mitigated?
- Will an internal compliance audit(s) be conducted?
- Is personnel training up-to-date and compliant with site-specific requirements?
- What are the current high-risk activities at the location?
- Can high-risk tasks or conditions be mitigated? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
- Have environmentally sensitive areas been identified and potential consequences been assessed?
- Did risk assessment utilize realistic scenarios to define spill and release volumes and locations?
- Are employees made aware of hazards associated with specific workplace process, materials, or location(s)?
- Are processes in place to monitor internal and external supply chains?
- Is external spill response support necessary and available?
- Have response equipment needs been evaluated and defined?
- How would a potential spill affect both internal and external resources?
- Have back up suppliers been identified and communicated with?
- Are personnel appropriately trained for their allocated roles?
- Have the plans been thoroughly exercised with realistic scenarios that test training comprehension?
- Is the response management team structure clear and able to be communicated?
- Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?
- Are exercises utilized to identify effective efforts and inefficiencies in response to ever-changing and site-specific scenarios?
- Does training include documenting and communicating response actions, management decision, and tracking of resources?
- Are clear procedures in place to notify, assess, and initiate a response?
- Are individual responders and their contact information verified for accuracy?
- Can approved stakeholders easily access response plans?
- Have response times and limitations been set?
- Do response elements address necessary updates, such as site construction, personnel changes, and supply chain changes?
- Have internal and external communication methods been identified?
- Are communications backup systems available and described in the plan?
- Are staff roles and responsibilities specified and communicated?
- Have alternate strategies and response procedures been identified?
- Are processes and procedures identified in the plans to assess and monitor size, shape, type, location, and movement of a spill or release?
- If applicable, have tactical response details been included in the planning process for incidents that expand beyond the confines of the facility?
- Do trajectory maps mimic local observations and historical tendencies?
- Do trajectory estimates include potential weather scenarios?
- Are sensitive sites prioritized for protection?
- Do plans include specific criteria for provisional tiered responses?
- Are waste management and demobilization processes communicated?
- Have processes been established for updating planning information prior to an emergency and during a response?
- Have plot plans and area mapping been integrated with GIS data and knowledge?
- Are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
- Has exercise feedback/lessons learned been incorporated into plan revisions?
- Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible?
- Are necessary Incident Command (ICS) forms and company paperwork readily available for response documentation?