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Compliance Tips for Industrial Emergency Management Exercise Programs

Posted on Tue, Jun 17, 2014

The National Preparedness for Response Exercise Program (PREP) is a unified federal effort established to provide a consistent set of guidelines that satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline and Hazardous Materials Safety Administration, and the Bureau of Safety and Environmental Enforcement in an economically feasible manner.

The intent is to create a workable exercise program which meets section 4202(a) of the Oil Pollution Act of 1990 amending section 311(j) of the Federal Water Pollution 6 Control Act, by adding a new subsection for spill response preparedness (33 USC 1321(j)(7)). Facilities and vessels required to adhere to these regulations must establish a compliant exercise program to ensure an adequate response to an oil spill.

Plan holders may develop a customized exercise program based on site operations or utilize the PREP exercise guidelines. The program must comply with the appropriate Federal oversight agency and regulatory exercise requirements. In order to maintain PREP compliance, all core components of a response plan must be exercised every three years. However, it is not required to conduct a major exercise every three years. PREP compliance can be obtained by exercising individual components within in a three-year cycle. The exercises must incorporate the following core PREP components:

  1. Notifications
  2. Staff mobilization
  3. Ability to operate within the response management system described in the Plan
  4. Discharge prevention/control
  5. Assessment of discharge
  6. Containment of discharge
  7. Recovery of spilled material
  8. Protection of sensitive areas
  9. Disposal of recovered material and contaminated debris
  10. Communications
  11. Transportation
  12. Personnel support
  13. Equipment maintenance and support
  14. Procurement
  15. Documentation

Exercises should be designed to test the aforementioned response plan components for effectiveness and accuracy. In order to satisfy the PREP requirement, plan holders must be able to document all operational and support aspects of a response, and provide detailed records of decisions and actions taken. Exercise requirements vary depending on operations. Vessels, unmanned barges, and certain identified facilities each have specific exercise requirements. Generally, the types of exercises required include:

1. Qualified Individual (QI) notification exercises: The purpose of the QI notification exercise is to ensure that the QI (or designee) listed in the response plan will respond as expected and carry out his or her required duties in a spill response emergency. Contact by telephone or electronic messaging must be made with the QI, and confirmation must be received from him or her to satisfy the requirements of this exercise. At least once per year, the QI notification exercise should be conducted during non-business hours.

2. Emergency procedures exercises: The purpose of the emergency procedures exercises is to ensure that personnel are capable of conducting the initial actions necessary to mitigate the effects of a spill. Specific regulations apply to vessels and unmanned barges. USCG and EPA Marine Transportation-Related Facilities have the option of conducting emergency procedures exercises. For the purpose of the PREP, emergency procedures for facilities are the procedures established to mitigate or prevent any discharge or a substantial discharge threat resulting from facility operational activities associated with cargo transfers. An unannounced emergency procedures exercise would satisfy the facility's requirement for the annual unannounced exercise.

3. Equipment deployment exercises: The purpose of equipment deployment exercises is to ensure response equipment is appropriate for the operating environment and that operating personnel are trained in its deployment and operation. It is not necessary to deploy every piece and type of equipment as long as all equipment is included in a periodic inspection and maintenance program. The inspection and maintenance program should ensure that the equipment remains in good working order.

4. Spill Management Team (SMT) tabletop exercises: At least one SMT Tabletop Exercises in a triennial cycle should involve a worst-case discharge scenario. If a response plan lists different types of SMTs for varying spill sizes (ex, a local SMT for small spills, a regional team for larger spills, and a national team for major spills), each team identified should be required to conduct an annual SMT tabletop exercise.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: USCG, PHMSA, OPA 90, Training and Exercises