Effective tools are often the superpower that managers need to help reduce HSE department workloads. Declining oil prices, industry volatility, and resulting budget cuts are pressing some oil and gas companies to operate at minimal staffing levels. Yet regulatory compliance requirements, maintaining high safety standards, and environmental protection efforts remain constant.
As a result, HSE managers are being asked to “do more with less”, stretching their capabilities and creating enterprise-wide preparedness and plan maintenance challenges. HSE managers must seek out available tools to help leverage their time, while ensuring preparedness measures are maintained, multiple response plans are managed, and regulatory compliance is maintained.
For pipeline and terminal operations, and others with numerous facilities requiring multiple plan types, advanced web-based systems offer advantageous plan management opportunities. These advanced systems are ideal for companies with facilities that must comply with the Oil Pollution Act of 1990 (OPA 90) requirements.
OPA 90 was created to instill comprehensive prevention, response, liability, and compensation policies for facilities that could cause oil pollution to U.S. navigable waters. The law requires that certain facilities submit Facility Response Plans (FRPs) that provide detailed site specific procedures to respond to a worse-case discharge.
FRPs require information and response details from each applicable facility including, but not limited to:
- Emergency Response Action Plans, which serves as both a planning and action document
- Facility information, including name, type, location, owner, and operator information
- Emergency notification, equipment, personnel, and evacuation information
- Identification and analysis of potential spill hazards and spill history
- Discussion of small, medium, and worst-case discharge scenarios and response actions
- Description of discharge detection procedures and equipment
- Detailed implementation plan for response, containment, and disposal
- Description and records of self-inspections, drills and exercises, and response training
- Diagrams of facility site plan, drainage, and evacuation plan
- Security (e.g., fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)
- Response team organization, roles, activation procedures, and personnel assignments
When dedicated HSE staffing is limited, maintaining the many site-specific details required for OPA 90 compliance stretches available human resources. By creating all-inclusive emergency response plans through a system that accounts for OPA 90 requirements and other emergency planning regulations, HSE managers can leverage their time more effectively.
The key superpower of advanced planning systems that utilize a centralized database is that this tool can incorporate multiple required emergency planning requirements from various agencies including, but not limited to:
- Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements), 40 CFR, part 112.7(d) and 112.20-.21
- 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.
- Risk Management Programs Regulation, 40 CFR, part 68
- Department of Transportation
- Pipeline and Hazardous Materials Safety Administration, 49 CFR, part 194
- S. 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
Facilities may also be subject to site-specific, state planning requirements that are not typically contained in the general emergency response plan. HSE managers should coordinate the development of their plans with relevant state agencies to ensure compliance with any additional regulatory requirements.
Regulatory compliance and response planning initiatives are sometimes sacrificed in cost control activities. However, noncompliance fines or one ineffective response to an emergency situation can result in many times the cost of implementing and maintaining an effective program.