Your Solution for SMART Response Plans

Oil Prices, Facility Response Plan Compliance, and Corporate Shuffling

Posted on Thu, Jun 11, 2015

Historically, low oil prices have triggered energy sector consolidations, reorganizations, and liquidations. As the industry responds to plunging company profits, a wave of mergers and potential acquisitions may be on the horizon. Once again, the dynamic nature of the oil industry will require corporate emergency managers to re-evaluate their approach to emergency management and regulatory compliance.

When companies merge and facilities are acquired, a company-wide emergency management program must consolidate and verify the regulatory compliance and the accuracy of facility response plans. Companies undergoing corporate structural changes should perform gap analyses or audits to identify procedural, policy, or regulatory compliance deficiencies.

Integrating plans under one centralized format consolidates preparedness and response objectives. In company merger circumstances, this process requires clear, concise, and frequent communication among multiple parties. A cohesive team, in cooperation with facility managers, should manage the consolidation of emergency management practices. It is critical to define preparedness objectives, response roles, and responsibilities in order to eliminate ambiguity and confusion. Responsible parties must verify and apply data, site assessments, and personnel information into cohesive, compliant, and effective plans for the new enterprise.

The following fundamental preparedness and response questions may assist companies in unifying facilities into a compliant emergency management program. Determining site-specific information, possible mitigation efforts, and response capabilities can mobilize stakeholders to develop necessary and required response planning objectives. (Note: The questions below are meant to initialize conversations and should not be considered a thorough checklist for preparedness and response planning)

Who is assigned to an emergency response?
  • Identify Incident Commander for each location
  • Create or update Emergency Management Team organizational chart
  • Identify and verify Emergency Management Team activation measures
  • Create or update Emergency Management Team roles and responsibilities checklists

Does the facility have a compliant response plan?

  • Update necessary personnel, contact information, and notifications procedure
  • Perform a gap analysis of the current plan(s) against new operations, equipment, company policies, industry best practices, and applicable local and state regulations
  • Review agency approval and electronic submittal processes, and comply as necessary

tanks-resized-600

What threats affect the facility or employees?

  • Perform a detailed hazard and risk analysis
  • Prioritize and carry out necessary mitigation measures
  • Verify or create response procedures for each identified threat
  • Identify the new process for incident documentation
  • Utilize appropriate ICS Forms
  • Identify current and/or necessary equipment necessary for response
  • Establish training and scenario-specific exercises to ensure process are responses are effective for identified threats/hazards

What regulatory requirements apply to each facility?

  • Evaluate all applicable regulations based on:
    • location
    • industry
    • operations
    • hazards
    • response specifics
  • Identify required training and implement compliant program
  • Review submitted response plan information
  • Confirm training and planning documentation
  • Perform plan(s) compliance audits

What is required for an effective and timely response?

  • Identify response capabilities and determine if additional resources are necessary
  • Initiate a Memorandum of Understanding or contract specific response needs
  • Confirm contact information, availability, and response times
How will an emergency be reported and response initiated?
  • Create site-specific notification procedures. (Emergency notifications may include 911, National Response Center, internal or external response team, emergency services, and others)
  • Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in alarm procedures and immediate response actions per roles and responsibilities
  • Implement company approved emergency classification levels to associated response procedures with emergency conditions to prevent the incident from escalating
  • Create multiple evacuation routes
  • Identify the muster point(s) and head count procedures

How are response actions sustained?

  • Establish command post location
  • Identify internal and external response resources and equipment for necessary sustained response actions
  • Share plans with appropriate responders/stakeholders
  • Develop a communications plan and identify sustainable communications equipment
  • Identify hazard control applicability and methods
  • Detail external communications and public relations policies

What is done after the incident is secured?

  • Create checklist to demobilize the response
  • Identify post incident review and debriefing objectives
  • Generate a means to apply “lessons learned”
  • Update plan accordingly and amend necessary training

Regulatory Compliance with TRP Corp

 

Tags: Facility Response Plan, Regulatory Compliance, Facility Management