Response planning challenges are often exaggerated by corporate downsizing, reorganizations, mergers, or acquisitions. As companies reorganize and/or grow, response plans can quickly become outdated and non-compliant. Through internal audits, companies can identify regulatory compliance requirements and whether minimum corporate emergency preparedness criteria are met. However, audits also may reveal process or procedural inadequacies, contradictory plan formats, or inaccurate information.
Whether organizational changes are the result of new facilities or acquired through a merger or acquisition, ensuring preparedness, regulatory compliance, and employee safety requires a committed emergency management staff and a fundamental emergency management program with streamlined, coordinated, and exercised response plans. Although there are many complexities and costs associated with regulatory compliance, the regulations exist to protect public interest, the company, and surrounding sensitive environments. If staff, programs, and/or plans are insufficient for an effective response, the status quo of companies and communities may be compromised.
With so many operational components, it is critical that plans be audited to determine potential discrepancies and regulatory deficiencies. Once discrepancies and deficiencies are identified, adjustments can be made for to ensure compliance, efficiency, and effectiveness. Response plan audits often identify the following:
- Personnel listed in plans are no longer employed with the company
- Emergency response duties and responsibilities are not assigned to appropriate personnel
- Inaccurate contact information for company personnel and external resources
- Lack of detailed oil or hazardous material spill response procedures regarding
- Lack of specific tank fire pre-plans and foam calculations
- Training deficiencies
- Inefficient documentation of training records
- Inconsistencies with Area Contingency Plans and/or local regulations
- Differing plan formats and versions resulting in varied information and disjointed composition
- No efficient process for implementing lessons learned, changes in policies, or regulatory requirements
A dedicated regulatory intelligence team or the EHS manager may be responsible for the daunting task of sifting through the mountains of location-specific regulations, mandates, and guidelines in order to modify determined deficiencies. In some instances following an external regulatory compliance audit, authorized agencies may demand deficiencies be addressed within a certain time frame. Agencies can impose fines and ultimately shut down operations for missed deadlines or ignored requisitions.
Those responsible for the emergency management program must remain vigilant to ensure plans are up-to-date and compliant in order to minimize financial penalties. When regulatory fines are assessed, companies can encounter additional collateral damage. Negative media exposure and antagonistic public opinion can quickly escalate when companies mismanage personnel safety or disturb environments that result from regulatory compliance failures. Ineffectively planning for or responding to an oil spill, fire, or other incidents can lead to a company’s demise. In order to prevent escalating effects, response plan audits and reviews should be scheduled, at a minimum, on an annual basis
While companies may not need to “reinvent the wheel” when it comes to safety and response procedures, facilities need to confirm that best practices apply to their site-specific situation. Each facet of a company’s operations should be broken down to examine specific best practices for a particular action, material, scenario, or site circumstance. For example, safety and response best practices exist in the following areas:
- Pre-incident planning
- National Incident Management System
- Fire brigades
- Hazardous materials handling/response
- Fire loss prevention
An effective compliance management process that includes regularly scheduled plan audits can result in an efficient and integrated program that optimizes the efforts of all company stakeholders and limits operational downtime. Effective technology can aid in managing response planning administrative duties associated with continually evolving personnel, operations, and regulatory requirements. Multi-facility operations should consider utilizing web-based technology to ensure enterprise-wide compliance on multiple government agency fronts.