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Pro Tip: The Role of Templates in Response Plan Compliance

Posted on Thu, Mar 27, 2014

Emergency response plan templates often include the basic fundamentals of response planning. They should be utilized as a general outline for developing emergency response plans and a guide for regulatory compliance. However, response plans must also reflect the unique nature of  every company, facility, and operation. Consideration of site-specific details of each operation is important to ensure regulatory compliance.

In order for emergency response plan templates to be effective, specific facility information and operational hazards, as well as local, state and federal requirements must be addressed and included in plans. Industrial operations are required by law to institute site-specific emergency response plans and train employees in the appropriate level and method of response. Utilizing generic procedures from basic templates may result in  ineffective plans that are not in compliance with regulatory requirements.

By utilizing a template as an outline, companies can begin the process of creating  emergency response plans. A generic plan template may not address every regulatory and/or site specification, so it is essential to evaluate site-specific variables and applicable regulatory requirements. Below are twelve basic template topics that should be evaluated for site-specific applicability and implementation.

  1. Local, State and Federal regulations
  2. Hazard identification and risk assessment
  3. Hazard mitigation procedures
  4. Resource management
  5. Response direction, control, and coordination
  6. Notifications and warning systems
  7. Operations and safety procedures
  8. Logistics and facilities infrastructure specifics
  9. Training
  10. Exercises, evaluations, and corrective actions
  11. Crisis communications
  12. Finance and administrative duties

A plan template should be supplemented, at a minimum, with the following information:

Description of Facility Infrastructure and Summary of Physical Site Attributes:  Emergency response plans should include the following site-specific details:

  • Facility Name
  • Address
  • Latitude/Longitude
  • Contact Numbers
  • Key contacts
  • Site operations and equipment
  • Products handled
  • Number of employees
  • Nearby waterways.
  • Site drainage.
  • Details of tanks, pipelines, utilities, and other major equipment
  • Site security features, including fencing, visitor access, and lighting

Plan distribution list: Include the names and addresses of personnel who have plan copies

Key contacts: Identify all primary and secondary key contacts that may be included in a response. It is crucial to routinely verify contact information for accuracy. Key contacts may include 911, National Response Center, and internal and external response teams. Response equipment  suppliers should be identified

Alarm Identification and Notification Process:  Identification of  alarms that may signal an emergency, evacuation, or shelter in place. It is imperative to perform exercises with alarms to confirm they are in proper working condition and employees react accordingly. Ensure employees are trained in and understand  required notifications.

Key Staff Roles and Responsibilities: Job-specific checklists and procedures detailing responsibilities from initial response actions through demobilization.  It is a good idea to  provide training to at least two people per position in case primary team members are not available. It s helpful to:

  • Create Emergency Response Team organizational chart
  • Develop Emergency Management Team activation procedures
  • Create  Emergency Management Team roles and responsibilities checklists

Response Actions: Response action checklists for  for each potential scenario.  .

  • Perform a detailed hazard and risk analysis
  • Create response procedures for each identified threat
  • Identify hazard control applicability and methods
  • Detail external communications and public relations policies

Response Equipment: Major on-site and external response equipment should be itemized. Equipment availability and applicable contact information should be reviewed and verified. The consequences of a supply chain failure during a response  can severely limit effectiveness. Transportation delays could affect response equipment delivery times. Plan and mitigate accordingly.

Documentation Process: Accurate and detailed records of a response are imperative. Regulatory authorities may require specific response documentation. The burden of proof typically falls on the responsible party  when making insurance claims.

  • Create process for incident documentation
  • Utilize appropriate ICS Forms

Emergency Operations Center Location(s): Include location, address, contact info, available equipment, and any necessary external equipment for effective response operations.

Visual Aids: Include plot plans, evacuation routes, maps, and any other graphic displays that may aid in a response.

  • Identify multiple evacuation routes
  • Identify shelter in place areas
  • Identify the muster point(s)

Demobilization and Post-Incident Review: Specific demobilization guidelines provide organized and agreed-to procedures to help facilitate a more organized and expedited return to normal operating conditions, and help to minimize costs by standing-down response resources in a timely manner.

  • Create a checklist to identify demobilize gudelinesPerform a post incident review and debriefing
  • Document newly identified hazards and vulnerabilities
  • Identify  “lessons learned”  and action items
  • Update response plan accordingly

Templates should be populated with industry-specific, best practice response techniques. Once the initial emergency plan is completed, response plan audits, exercises, and consulting assistance may be required to confirm emergency plan compliance and effectiveness.

Interested in auditing response plans for effectiveness and compliance, download the "Audit Preparedness Guide for Industrial Regulatory Compliance".

Regulatory Compliance with TRP Corp

Tags: Testing, Resiliency, Response Plans, Regulatory Compliance, Emergency Response Planning, Safety