Your Solution for SMART Response Plans

The Facility Response Plan Assessment

Posted on Thu, Aug 07, 2014

As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, certain facilities that store and use oil are required to develop, maintain, and submit an approved Facility Response Plan (FRP). These plans should address the elements and responses associated with substantial threats and worst case discharges of oil. If the Oil Pollution Act regulations are applicable to a facility, the operating company must prioritize response plan compliance in order to minimize fines, negative public perceptions, and potential government mandated shutdown of operations.

Maintaining a FRP is an ongoing process. As company operations evolve, and equipment and employees change, adjustments need to be incorporated into the FRP to ensure accuracy, compliance, and effective response capabilities. Additionally, the plan submittal processes must be observed and applied in order to eliminate the potential for fines.

This FRP assessment is designed to recognize best practices. Following the set of questions, the scoring section can assist in identifying potential necessary actions that can reduce the risk of non-compliance and/or ineffective responses.

1. Have your personally reviewed your company’s FRP within the past 12 months?

Yes _____ No_____

2. Do your employees have a clear understanding the FRP and their designated responsibilities if a worst-case scenario were to occur?

Yes _____ No_____

3. Have your external responders participated in a comprehensive review of your emergency management system or a response exercise within the last 12 months?

Yes _____ No_____

4. Does your plan identify a Qualified Individual and alternate who has full authority to obligate funds required to carry out necessary response actions and act as liaison with Federal On-Scene Coordinator?

Yes _____ No_____

5. Does your FRP identify a public relations contact or information officer who has knowledge of public affairs policies identified in your company’s FRP?

Yes _____ No_____

6. Were representatives of external resources involved in developing and testing the company’s FRP?

Yes _____ No_____

7. Does your company have adequate documentation  procedures and capabilities to document plan l changes, training, and exercises?

Yes _____ No_____

8. Is your FRP consistent with the National Contingency Plan and any Area Contingency Plan?

Yes _____ No_____

9. Have you spent more than two hours during the past six months in face-to-face discussion with your incident management team about how to improve spill response management?

Yes _____ No_____

10. Are your response procedures brief and organized in a manner that enables your employees or response teams to effectively respond to a range of incidents?

Yes _____ No_____

11. Does your FRP clearly identify discharge detection procedures and equipment?

Yes _____ No_____

12. Are your current mutual aid agreements or external responder contracts current?

Yes _____ No_____

13. Is your incident response team equipped and trained to set up incident command center?

Yes _____ No_____

14. Does your FRP include detailed disposal procedures and contractors?

Yes _____ No_____

15. Does your FRP contain alternates for each Incident Management Team position in the event that the primary contacts are unavailable?

Yes _____ No_____

16.  Do key individuals have secured, immediate access to the most up-to-day FRP without potential “version confusion”?

Yes_____No_____

Self-Assessment Scoring

To assess your emergency management program, give yourself one point for each "yes" and zero points for each “no”. Total your score and grade your risk.

13–16 points: In general, your FRP is well managed. Look back at your "no" answers and decide what you can do to mitigate this area of exposure. Be sure to monitor regulatory requirements and any operational shifts that could alter the effectiveness of your FRP. For a comprehensive understanding of the status of your plan, perform a full FRP audit by qualified in-house experts or experienced consultants.

9-12 points: You are making good progress, but there are a number of actions required to reduce your risk of non-compliance or response inefficiency. You may wish to focus your attention on areas indicated by the "no" answers. Based on the results of reviews in these areas, you can decide what further steps are necessary. An expert evaluation of your current plan with response plan professionals can minimize potential fines and maximize response efficiencies.

5-8 points: Your company may be at risk, but you have taken the first step of mitigation: awareness. This score suggest your emergency management responsibilities are being partially met, but there is significant room for improvement. A response-planning consultant with FRP experience can assist planners with site evaluations, regulatory compliance criteria, mitigation efforts, and plan substantiation.

Fewer than 5 points: Your facility, employees, operations, and reputation are at risk! Prompt action is necessary to ensure a compliant emergency management program. You need to take immediate action for regulatory compliance and to improve the ability to respond effectively to an incident. A comprehensive review of your FRP and preparedness efforts is warranted to reduce your risk.

Helpful hints:

  1. Review FRP’s on a cyclical basis. If turnover is high or operations are rapidly evolving, FRPs should be reviewed quarterly, at a minimum.
  2. Ensure training, drills, and exercises are optimized. Each training event, drill, or exercise presents the opportunity to improve response process responsibility and site-specific response procedure awareness, rendering the potential for a more effective response.
  3. Despite the added strain of publicity during a crisis, engaging with the media should be incorporated into the planning process. Ensure the facility or company has a designated point of contact for media and site personnel. Consistent, accurate messages alleviate public anxiety and provide a level of credibility. The more information that is provided, the less the media will have room for interpretation.
  4. Documentation provides historical records, keeps management informed of site practices, serves as a legal instrument, if necessary, and supports time and maintenance costs.
  5. Consider utilizing a web-based, database driven planning system. A widely accessible emergency response plan can maximize efficiency and minimize impacts of an emergency on employees, the environment, and infrastructure. Incorporating TRP’s enterprise-wide emergency management system can maximize efforts, minimize maintenance costs, and allow for a streamlined and familiar response process.

For free download on facilitating effective oil spill exercises, click on the image below:

TRP Corp Emergency Response Planning Exercises 

 

Tags: Facility Response Plan, Response Plans, EPA, Oil Spill, Training and Exercises, Facility Management, Workplace Safety