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Enterprise-Wide Contingency Planning & Regulatory Compliance

Posted on Thu, May 07, 2015

Emergency Operations Plans (EOPs), or Emergency Response Plans, are often the centerpiece of a comprehensive emergency management program. EOPs should be flexible enough to be effective in a variety of emergency scenarios. However, many company emergency management programs, as well as specialized industrial facilities utilize an integrated contingency plan (ICP) to consolidate a variety of required site and response information.

An ICP is a comprehensive plan that documents necessary response actions, identifies the resources required to effectively manage potential hazards, and can fulfill compliance mandates for a variety of regulatory agencies.  ICPs enable facilities to comply with multiple federal planning requirements by consolidating them into one functional response plan.  Elements of an ICP will reflect the complexity of operations, response components, and required documentation. Depending upon the EOP’s structure and required content, hazard-specific information may be either included within an ICP or created as a separate stand-alone plan that can be distributed exclusively.

However, enterprise response planning with a variety of information into an ICP often becomes challenging when:

  • A company has multiple facilities utilizing multiple formats
  • The comprehensive plan format does not allow for the facility-specific information required for regulatory compliance
  • Plan updates result in “version confusion” or lack of data consistency
  • Known quantities of hazardous materials vary depending on operational status

An enterprise-wide template should serve as an outline for compliance required information, but should be populated with site-specific details. Utilizing a customizable, secure, web-based template with a database of common company planning information allows each site to provide facility-specific compliance data, as well as the precise information required to assist responders in determining the best response for the specific scenario.

With effective web-based formats and comprehensive, yet site-specific capability, emergency managers can;

  • Reduce the need for multiple plans
  • Minimize administrative costs
  • Simplify plan reviews
  • Minimize discrepancies across various plans
  • Streamline response effort directives from one source
  • Simplify required distribution in a secured manner

ICPs do not exempt facilities from applicable regulatory planning requirements pertinent to releases of hazardous and non-hazardous substances. Companies must evaluate each site for applicable regulatory requirements. . Fortunately, multiple federal agencies endorse the use of an ICP as a means to incorporate response planning regulations, and simplify the complex planning process. An ICP may be used to incorporate one or more of the following applicable federal regulations:

EPA
  • Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements), 40 CFR part 112.7(d) and 112.20-.21
  •  RCRA (Resource Conservation and Recovery Act) Contingency Planning Requirements, 40 CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52.
  • RMP (Risk Management Programs), 40 CFR part 68
Department of Transportation/Pipeline and Hazardous Materials Safety Administration
  • RSPA Pipeline Response Plan Regulation, 49 CFR part 194
  • US Coast Guard, Facility Response Plan Regulation, 33 CFR part 154, Subpart F
Occupation Safety and Health Administration (OSHA)
  • Emergency Action Plan Regulation, 29 CFR 1910.38(a)
  • OSHA's Process Safety Standard, 29 CFR 1910.119
  • OSHA's HAZWOPER Regulation, 29 CFR 1910.120

While ICPs may simplify the planning process, many companies still choose to maintain separate plans. Stand-alone plans typically contain site-specific, unique response details that apply to a single hazard, such as pandemic, hurricane, fire, or hazardous spill. Procedural, tactical, and/or incident-specific action plans tend to be location-based and often highlight operational hazards, inherent threats, or response needs. These stand-alone plans are often shared with specialized local responders and/or regulatory agencies to address specific regulatory requirements, such as the EPA’s SPCC plans (spill prevention, control, and countermeasure). Other stand-alone plans may be developed for crisis management situations, security-related incidents, and/or business continuity scenarios.

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Tags: Pipeline, Facility Response Plan, Response Plans, Regulatory Compliance, Emergency Response Planning