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Facility Response Plan Audits Necessary in Mergers and Acquisitions

Posted on Mon, Mar 31, 2014

As companies merge, acquire facilities, or expand operations, applicable location-specific threats, risks, and regulations must be incorporated into response plans. Emergency preparedness programs and facility response plans need to be reviewed, at a minimum, on an annual basis to adequately reflect expanding operations. However, if an acquisition or merger occurs, it is essential to evaluate and align facilities and processes with corporate standards and applicable regulatory requirements.

Enterprise expansion requires environmental, health, and safety (EHS) managers to sharpen their location-based understanding of regulations, security needs, and associated response plan components specific to each location. As part of a company’s asset management program, engaging experienced personnel in response plan data review, safety and response audits, and response plan validation can highlight areas where the local knowledge is imperative.

The new response planning documents should include updates from various stakeholders and collaborating response groups. Open communications with internal and external responders will ensure plan and response procedures are current, and carried out in accordance with 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 Companies (Gas, Electric, Public Works, Telephone, etc.)
  • Contracted Emergency Responders
  • Neighboring Businesses

Whether a facility is domestically located or abroad, ensuring enterprise-wide compliance and employee safety requires streamlined, coordinated, and exercised response plans. A poorly managed and inadequate response can negatively affect a company’s reputation, operations, business interests, and relationship with key regulators, partners, and local entities.

Internal or external experts, as well as independent consultants can assist in response plan audits to ensure compliance, accuracy, and effectiveness. All response plans within the corporate enterprise should address site-specific facility details, appropriate response processes, standardized company-wide best practices, and maintain location-specific regulatory compliance.

The response plan audit process, followed by exercises, can minimize the “lessons learned” transfer process knowledge gap among incoming personnel. Important threat identification, operational site specifics, and response process and procedural details may have gone unnoticed in the transition, potentially compromising safety and emergency response.

After an audit, new or unidentified risks should be slated for possible mitigation measures and regulatory gaps should be documented. However, if the risks cannot be eliminated, new countermeasure processes and procedures must be implemented and response plans adjusted accordingly. Important threat identification, operational site specifics, and response process and procedural details may have gone unnoticed in the transition, potentially compromising safety and emergency response.

Other business units or divisions outside headquarters’ domain may present additional preparedness and response challenges. Audits should be inclusive of cultural differences, infrastructure challenges, or security priorities that may heighten preparedness priorities and planning efforts. As a result, an expanding company may be particularly vulnerable to crisis or emergency response situations.

Audits should verify that response plans have been effectively developed for each potential scenario. In additional to specific operational hazards and site specific regulations, response planning may incorporate, but is not limited to the following:

Natural Disasters: Each geographic location is saddled with specific potential natural threats. If historically applicable, plans should address

  • Earthquakes
  • Hurricanes/typhoons
  • Sand/wind storms
  • Tornados
  • Floods
  • Tsunami

Security Breach: A security breach can affect multiple aspects of a company, from business continuity to the physical safety of employees. Plans may include response processes for:

  • Computer hacking
  • Catastrophic IT failure
  • Facility security measures
  • Civil unrest
  • Personnel/employee security

Industry/Sector Issues: As industry specific equipment, regulatory requirements, and technologies evolve, preparedness efforts should adapt to include safety processes, continuity procedures, and best practices for.

  • Supply disruptions
  • Regulations
  • Plan maintenance
  • Plan accessibility
  • Employee training
  • Exercises

Though preparedness, companies can minimize the effects of costly crisis and emergency situations, as well are potential regulatory fines. Timely resolutions with limited impact to the facility, employees, the environment, reputation, and the financial bottom line will allow companies to better position themselves for growth, prosperity, and longevity.

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

Regulatory Compliance with TRP Corp


Tags: Response Plans, Regulatory Compliance, Emergency Management Program, Security plans, Safety