A facility response plan is only as effective as the information it contains and the comprehension of those utilizing the plan. As facility specifics change, response plans must change accordingly. Fundamental regulatory compliance, inherent site-specific safety issues, human resource factors, and a company’s reputation obligate specific response planning requirements for a facility. Cyclical plan maintenance is essential in order to capture multiple moving parts that impact an emergency management program.
The response plan should be reviewed annually, at a minimum. Plans should evolve as lessons are learned, new information and insights are obtained, and operational priorities are updated. Utilizing a web-based, database driven planning system simplifies the update process, despite location of influential parties. An annual review enables practical opportunities to minimize or eliminate incidents, the ability to provide “mission accomplished” in the event of an incident, and mandated regulatory compliance. The planning review cycle typically corresponds to the criteria laid out by the associated regulatory agencies; however, internal corporate policy may dictate multiple reviews throughout a fiscal year.
Decision-makers directly involved in the plan review process can determine its effectiveness and efficiency by its adequacy, feasibility, and acceptability, along with responders’ understanding of plan requirements. The plan review can also address present and future risks, and define potential response costs. According to FEMA, there are five commonly used criteria to determine the effectiveness and efficiency of response plans.
Adequacy: Emergency managers should apply their experience, judgment, intuition, situational awareness, and discretion to ensure a plan is adequately suited for a facility’s identified hazards. FEMA defines a plan as adequate if:
- The scope and concept of planned operations identify and address critical tasks effectively
- The plan can accomplish the assigned mission while complying with guidance
- The plan’s assumptions are valid, reasonable, and comply with guidance.
Feasibility: The established response procedures should be rigorous enough, yet standardized, to minimize subjectivity or interpretation, and preclude oversights in order to accomplish the assigned mission and critical tasks. This should be accomplished by using currently available resources within the minimum time frame set forth by the plan. Available resources include internal assets and those available through mutual aid, private contractors, or through existing state, regional, or Federal assistance agreements.
Acceptability: The plan meets the requirements driven by a threat or incident, goals set by decision makers, budgetary restraints, response time limitations, and abides by applicable law(s).
Completeness: The plan includes all applicable and effective emergency procedures with estimated response times, required capabilities, needs of the population, and identified success criteria. All information, including contact information, should be updated and accurate.
Compliance: The plan should comply with all internal and external guiding doctrine within the boundaries of the presiding law(s). Failure to comply with regulations can result in additional financial burdens resulting from fines, negative public perception, and possibly government-mandated shutdown of operations.
According to FEMA’s Comprehensive Planning Guide, there are six key steps in developing effective response plans. An annual review can incorporate these steps to verify the five commonly used criteria to determine the effectiveness and efficiency of emergency plans. At each step of the review, emergency managers should consider the impact on required training, exercises, and equipment costs and availability.
Step 1: Collaborative Teamwork
- Identify and verify the facility response planning team. Typically this includes an emergency manager or security manager, a hazard mitigation expert, local jurisdictions, and any additional available planning experts.
- Engage essential personnel in the review process to identify changes in capabilities and resources.
Step 2: Understand Potential Situations
- Identify any new or altered threat and/or hazard: Geographic and facility hazards and risks can be broken down into four areas:
- Natural Hazards
- Technological Hazards
- Chemical Hazards
- Human Hazards
- Assess Risk: Assign probability values to new or altered threats and hazards for the purposes of determining priorities, developing processes and procedures, and allowing for informed decision-making.
Step 3: Determine Goals and Objectives
- Identify Altered Operational Priorities: Specify goals and objectives desired for emergency responders, employees, and facility, and define a success for each operation.
Step 4: Plan Update
- Develop and analyze procedural options based on current best practices, lessons learned, and regulatory updates.
- Participants should add necessary supporting information, graphics, and/or photos taking note to comply with local, state and federal regulations.
- Identify current internal and external resources necessary to fulfil requirements, response obligations, and assignments.
- Emergency managers should identify any changes or updates to the information necessary to drive response decision-making and trigger critical response actions.
Step 5: Plan Approval and Distribution
- Senior management and, in some cases, associated regulatory agencies typically grant emergency plan approvals. Once changes are approved, the plan should be distributed to appropriate individuals/ organizations.
- A record of the individuals/ organizations that received a copy (or copies) of the plan should be maintained.
Step 6: Plan Implementation & Maintenance
- Exercise the updated plan: Evaluating the effectiveness of plans involves a combination of training events, exercises, and real-world incidents to determine whether the goals, objectives, decisions, actions, and timing outlined in the plan can lead to a successful and effective response.
- Planning teams should evaluate the process for reviewing, revising, and distributing the plan. A web-based, database driven planning systems eases the administrative burden and applicable costs associated with implementing, maintaining, and distributing response plans. Plan maintenance should be an ongoing and recurring activity.
Receive TRP's FREE Audit preparedness Guide.