Your Solution for SMART Response Plans

Are Emergency Action Plans Enough for Company-Wide Preparedness?

Posted on Thu, Apr 20, 2017

For most companies, a visit from an Occupational Safety and Health Administration (OSHA) inspector in 2017 can be a stressful scenario. Until recently, non-compliance fines were minimal for non-serious violations. But that changed in 2016 when Congress passed the Bipartisan Budget Act of 2015 which required federal agencies, including OSHA, to adjust their civil money penalties based on inflation. 

Companies should no longer equate violations and penalties to the cost of doing business. A lack of response planning or preparedness can be detrimental in numerous ways. Any potentially escalating health, safety or environmental incident or business disruption can result in, but is not limited to:

  • Compromised employee safety and productivity
  • Lost revenues and business opportunities
  • Contractual-based penalties
  • Damaged reputation
  • Regulatory fines

 

OSHA Penalties

Until 2016, OSHA penalties and fines haven't increased in over 25 years. With an elevated focus on preparedness, companies should evaluate the potential impact of these costs compared to the establishment or improvement of safety programs.

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The Emergency Action Plan

Emergency Action Plans or Emergency Response Plans are not only required for most companies, but are essential to the well-being of employees. The Emergency Action Plan regulation (29 CFR 1910.38), states that employers with 11 or more employees must  have to create a written emergency action plan. Even for locations with ten or fewer employees, employers are still required by OSHA to communicate an EAP to staff. An emergency action plan must communicate the following minimum requirements: 

  • Means of reporting fires or other emergencies
  • Evacuation procedures, including exit route assignments
  • Procedures to be followed by employees who remain to operate critical operations before they evacuate
  • Procedures to account for all employees after evacuation
  • Procedures to be followed by employees performing rescue or medical duties
  • The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.

At a minimum, companies should be prepared in the event the unexpected occurs. But for companies with more than 10 employees, especially those with multiple locations, the basic emergency action plan may not be enough to ensure preparedness or compliance.

Response plan regulations are often specific to operational hazards, inherent threats, or incident-specific response needs. Companies should not limit response planning to simple fire emergencies, but consider an all-hazard, inclusive approach in preparedness.

Most incidents are short-lived and can be brought under control rather quickly when prepared planning is prioritized. Responses to these incidents are typically tactical in nature.

 

Response Planning and Preparedness

More serious incidents may require specialized response teams or assistance from outside entities, such as local fire, police or agencies. The emergency response plan or emergency operations plan should be inclusive of multiple possibilities and address the time period immediately after the incident. This level of preparedness prompts a rapid return of critical operations.

Preparedness planning should cover three objectives:

  • Maintain existing emergency management readiness capabilities
  • Prevent emergency management capabilities from becoming part of the emergency
  • Augment emergency management capabilities with internal and external response resources

Preparedness plans should address capabilities needed for prevention, protection, response, recovery, and mitigation activities. These plans should include, but are not limited to the following:

  1. Facility Information
  2. Hazard analysis
  3. Response checklists
  4. Required notifications
  5. Response team organization, activation procedures, and roles
  6. Identification of training requirements based on roles
  7. Guidelines for developing, conducting, and evaluating exercises
  8. Ongoing plan review and evaluation process

As agencies continue to redefine their monetary penalties, companies must not rely on the prospect of an inspection to ensure preparedness programs are sufficient. Regulatory deficiencies are most likely shared with others within the same industry, therefore, companies may identify potential solutions by researching best practices. Often, the expertise and knowledge that drove the regulation into existence stems from the problems and experiences of others, and their efforts to address the inherent problem(s).

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: Emergency Action Plan, corporate preparedness

911 Outages - Wake-Up Call for Corporate Response Planning

Posted on Thu, Apr 06, 2017

On two instances in early March, AT&T users in several states were unable to call 911, the most common emergency contact number. According the Federal Communications Commissions’ Public Safety and Homeland Security acting Bureau Chief, Lisa Fowlkes, a preliminary investigation revealed that over 12,000 callers could not reach 911 operators during the outage.  But this is not the first time a 911 outage has occurred.  On April 9, 2014, a 911-call routing facility in Colorado stopped routing calls to eighty-one 911 centers.  According to the 2014 FCC investigation, over 6,600 calls were never connected to emergency operators during that incident.

The 2014 FCC report revealed that the Colorado outage was not an isolated incident or an act of human nature. Ongoing upgrades to the 911 system have resulted in conflicts between newer and older software code. While the investigation continues into the March 2017 outage, it highlights the importance of alternate emergency contact information in emergency response plans.

With this most recent investigation, the FCC prompts the question; “What plans do public safety entities have in place for public notification during 911 outages, including the provision of alternative emergency contact information, and how effective were alternatives.” C-level executives, facility managers and EHS staff should be asking the same questions.

  • What plans does your company have in place for public notification during 911 outages?
  • Do your response plans include alternative emergency contact information?
  • How effective are these alternatives in responding to your needs?

During the initial planning stage and consequential emergency planning reviews, facilities need to assess the impact of the potential emergencies, determine the need for backup or external resources, and confirm contact information. Companies must have adequate resources to effectively address emergency situations. It is critical to identify and include appropriate contact information and backup communication methods in response plans. 

The execution of a solid communication plan should begin in the planning phase, not on the verge of, during, or in the aftermath of a disaster.  All response plans should provide contact information to ensure the response team members, external resources, and stakeholders have the information needed to make educated decisions. Through pre-planning, a communication plan can be fully integrated into the overall response plan. Unfortunately, confirmation of internal and external communication tends to neglected. It is essential that contact numbers are routinely checked and updated in response plans.

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Time is critical during an emergency. An effective response can be compromised if response plans contain wrong or out of service phone numbers. If using an automated call out system, important information may not be received if numbers or e-mails have changed. A scheduled verification system should be put in place to solidify the accuracy of any applicable means of communication (ex: e-mail addresses, cell phone numbers and landlines).

Communication pre-planning should also include, but is not limited to, the following:

  1. Notification and Activation methods: Meet with employees and responders to discuss notification and activation methods. Do not assume that responders identify with company communication policies or context of emergencies communications. Through communication, employees can comprehend the safety measures necessary to limit exposures and prevent unnecessary harm.
  2. Contact Verifications: Primary and secondary contact information should be verified for personnel, responsible agencies, and contracted responders. Verification should be conducted on a periodic basis in order to maintain accurate and applicable information.
  3. Strategic Considerations: Establish a strategic framework with checklists and response criteria that will guide the communications decision-making process to allow for an effective response.
  4. Stabilization: Effective communications is the bridge to stabilizing a crisis situation. The stabilization phase may include media/public relations. In this 24/7 information age, a communications plan should include informational jurisdiction decisions about what to release, by whom, and when. Information MUST be accurate and timely in order to diffuse rumors.
  5. Recovery: The lines of communications need to remain open to return to a “business as usual” level. In order for a full recovery, communication should include:
  • Accurate damage assessment reports
  • Response personnel reports
  • Demobilization techniques
  • Employee reentry procedures
  • Lessons learned debriefings

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: Communication Plan, corporate preparedness

Six Common Response Team Roles for Facility Preparedness

Posted on Thu, Mar 23, 2017

Every company’s preparedness efforts and response plans are unique to the threats and hazards associated with their operations. As a result, each site should have unique response teams with site-specific and individually assigned responsibilities. The number of company personnel required to staff a response team will depend on the size and complexity of the facility, and the potential incidents that can occur.  A small facility may have one-person response team with a support structure to assist in the event of an unlikely larger incident, while a larger facility with varying threats and hazards may require multiple personnel.

Individuals chosen for a response team should be carefully selected. Selection should be based on authority level and experience, and capability to be trained for their appointed roles and responsibilities. The more knowledgeable individuals are of their response team roles and responsibilities, the better prepared the team can be to implement a streamlined response.

Individual responsibilities are associated to each unique role. Below are six common response team positions and coordinating responsibilities that may be necessary for your facility.

  1. Incident Commander (IC)
  • Activates selected members or all of the Emergency Response team
  • Activates additional response contractors and local resources
  • Evaluates the severity, potential Impact, safety concerns, and response requirements based on the initial information provided by the First Person On-Scene
  • Confirms safety aspects at site, including the need for personal protective equipment, sources of ignition, and potential need for evacuation
  • Communicates and provides incident briefings to company superiors, as appropriate
  • Coordinates/completes additional internal and external notifications
  • Communicates with Emergency Response Team, as the situation demands
  • Directs response and cleanup operations

 

  1. Public Information Officer
  • Communicates with the IC to determine if there are any limits on information releases
  • Develops material for use in media briefings
  • Obtains IC approval of media releases
  • Informs media and conduct media briefings
  • Arranges for tours and other interviews or briefings that may be required
  • Obtains media information that may be useful to incident planning
  • Maintains current information summaries and/or displays on the incident and provides information on the status of the incident to assigned personnel
  • Maintains Unit/Activity Log (ICS Form 214)

 

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  1. Security Officer
  • Establishes contacts with local law enforcement agencies, as required
  • Requests required personnel support to accomplish work assignments
  • Ensures that support personnel are qualified to manage security problems
  • Develops Security Plan for incident facilities
  • Adjusts Security Plan for varying personnel levels, equipment changes and releases
  • Coordinates security activities with appropriate incident personnel
  • Keeps the peace and settles disputes through coordination with appropriate representatives
  • Prevents theft and unauthorized access to property
  • Documents all complaints and suspicious occurrences
  • Maintains Unit/Activity Log (ICS 214a)

 

  1. Liaison Officer:
  • Coordinates activities of the response team and company with federal, state, and local officials.
  • Maintains a log of all contacts made with regulatory/governmental agencies. Records time/date of each call and names of agency personnel contacted
  • Identifies representatives from each agency, including communication links and locations
  • Participates in planning meetings. Provides applicable agency resource status information
  • Prepares “initial” written reports to agencies as required. Obtain approval from the Legal Officer and/or IC prior to submittal to agencies
  • Work with response team to arrange site tours and briefings for elected officials, if appropriate
  • Maintains Unit/Activity Log (ICS 214a)

 

  1. Safety or HSE Officer
  • Identifies and evaluates safety and health hazards that may impact both the response workers and the public and designates exclusion zone boundaries
  • Determines levels of personal protective equipment required
  • Coordinates with government and industry health and safety officials regarding public health concerns, including evacuations, limiting access, and closure
  • Develops the Incident Safety and Health Plan (ICS 206a)
  • Ensures site specific Safety and Health Plans are written and updated as necessary and are read by all responders working at the site
  • Ensures that all responders have adequate skills to safely perform assigned tasks, and that required levels of training are documented
  • Determines the scope of environmental monitoring necessary to ensure a safe cleanup
  • Manages the safety staff needed to continuously monitor and evaluate safety and facility conditions to prevent unsafe conditions
  • Provides and/or coordinates health and safety training and regular safety briefings.
  • Attends media briefings
  • Participates in cause and origin investigation activities, if warranted
  • Maintains Unit/Activity Log (ICS 214a)

 

  1. Legal Officer
  • Assists IC and local operations during and after response operations
  • Works with agency investigators in determining the cause, responsibility, and levels of liability, if any, in the incident
  • Provides advice on documentation of events
  • Works with the environmental manager during NRDA planning and investigations
  • Maintains Unit/Activity Log (ICS 214a)

 

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: response team

Don't Be an OSHA Statistic: Preparedness & Facility Response Plan Tips

Posted on Thu, Mar 09, 2017

Every day across the United States, employees go to work expecting a typical day on the job.  Yet OSHA’s Reports of Fatalities and Incidents for Fiscal Year 2016 reveals that one or more work-related fatalities and incidents occurs daily. While some jobs are more hazardous than others, the detailed summary indicated 1,080 OSHA reported instances in 2016. How many more incidents go unreported?   Not only do emergencies and incidents happen, they happen every day - highlighting the importance of preparedness and response planning.

 

"It Won’t Happen Here"

When incidents occur, urgent and rapid decision making combined with a lack of resources and untrained personnel can lead to chaos and exacerbate the emergency. Response plans can minimize the chaos with pre-identified processes. To establish effective response plans capable of protecting employees and building occupants, companies should conduct analyses to identify necessary site-specific safety measures, including those required for regulatory compliance. Analyses should identify the following details:

  1. Site Analysis
  • Identify existing and potential site hazards through employee feedback, audits, and detailed inspections.
  1. Task Analysis
  • Determine job specific methods and procedures for each employee’s duty to reduce or eliminate associated hazards.
  • Review and update methods and procedure when an incident occurs, job responsibilities change, or if hazards are identified through analysis.
  1. Risk Analysis
  • Establish risk evaluation criteria, probability of incident, and potential consequences.
  • Monitor and review procedures for continuous improvement, effectiveness, control measures and changed conditions.

Besides the major benefit of providing guidance during an emergency, the preparedness process and analyses have other advantages. You may discover:

  • Unrecognized hazardous conditions that would aggravate an emergency situation
  • Deficiencies, such as the lack of resources (equipment, trained personnel, supplies)
  • Mitigation opportunities that can rectified incidents before an emergency occurs.

 

The Response Plan

Comprehensive, compliant, and functional response plans should be created to address a broad scope of planned responses for a variety of probable emergency and crisis situations. However, if a facility has a high-risk potential for a specific scenario, supplemental response plans can be added to the overall emergency management program. Inclusive programs may include a variety of plans including Facility Response Plans, Fire Pre-Plans, and Incident Response Plans, etc.  Response plans should include the following minimum information:

  • Building description
  • Plot plan(s) and floor plan(s)
  • Owner/Manager contact information
  • Emergency equipment inventory and locations
  • Evacuation routes
  • Emergency Assembly Point details
  • Internal and/or external emergency personnel information and contact details
  • Specific hazard details and possible safety data sheet information, if applicable
  • Utility shut-off locations and descriptions
  • Alarm(s) description
  • Policies and processes situational checklists
  • Job specific procedures

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A Plan for Every Site

An enterprise-wide response planning system can provide the framework required to ensure every facility under the corporate umbrella is compliant and prepared for the unexpected. An enterprise-wide system can remove many of the challenges associated with managing multiple response plans, streamline the update process, and simplify plan reviews, ensuring a consistent path toward compliance and readiness.

An enterprise-wide response planning system should:

  • Support the ability to execute company-approved response strategies across multiple locations/facilities
  • Easily incorporate company growth and facility acquisitions
  • Enable site-specific details while not compromising company directives
  • Facilitate the ability to update corporate planning elements across locations, sites, geographies, without compromising site-specific details and response challenges
  • Be easily updated with minimal dedicated staff
  • Become an easily accessible, yet secured, shared tool for internal and external responders
  • Allow for streamlined regulatory compliance audits
  • Automate and optimizes response planning training and exercise activities
  • Reduce non-compliance issues on a company-wide scale
  • Automate regulatory governance with electronic submissions

 

Don’t be a Statistic 

With the revelation of the OSHA statistics, companies should ensure safety and preparedness is at the forefront of operations. Whether a company has one site or multiple facilities across the globe, response plans promote safety awareness and may help minimize the chance that of one of you employees becomes an OSHA statistic.

 

Preparedness and Emergency Management - TRP Corp

Tags: OSHA, Facility Response Plan, Response Plans, corporate preparedness

Ten Tips for Workplace Emergency Response Plans

Posted on Thu, Feb 23, 2017

An emergency only takes seconds to escalate. At the very least, each company facility or site should develop and implement an emergency plan for protecting employees, visitors and contractors. Whether the plan is mandated by corporate policy or regulatory agencies, a widely accessible workplace emergency plan can maximize response efficiencies and minimize impacts of the emergency on employees, the environment, and infrastructure.

FEMA identifies five mission areas that can serve as a basic understanding of the emergency management process. These areas include:

  • Prevention: Prevent, avoid, or stop an imminent, threatened or actual act.
  • Protection: Protect employees, citizens, residents, visitors and assets against threats and hazards.
  • Mitigation: Reduce the loss of life and property by lessening risks, threats, and impacts.
  • Response: Respond efficiently to save lives, protect property, and the environment, and meet basic human needs in the aftermath of a catastrophic incident.
  • Recovery: Recover through a focus on the timely restoration, strengthening and revitalization of infrastructure, sustainable operations, as well as the health, social, cultural, historic and environmental fabric of communities affected by a catastrophic incident.

For companies with multiple sites, an enterprise-wide template can streamline formats and serve as an outline for company-mandated information and regulatory compliance content. However, each location’s plan should contain site-specific details that are unique to the facility and can possibly affect the response. 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.

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To help you develop a general outline that can be used to guide your response planning agenda, Ready.gov offers the following guidance.

  1. Identify Objectives: Review preparedness and response planning performance objectives for your company or site’s program. Objectives may include regulatory compliance, hazard prevention/deterrence, risk mitigation, emergency response and business continuity.
  2. Perform a Risk Assessment: Review hazard or threat scenarios identified during a risk assessment.
  3. Identify Response Resources: Identify the availability and capabilities of resources to help stabilize the situation including people, systems and equipment within your facility, as well as external sources.
  4. Create Incident Management Team: This requires response plan knowledge, role specific training, and an effective synergy between team members and external responders.
  5. Evaluate Applicable Regulations: Determine which response planning regulations pertain to your facility and how you can ensure compliance within your site-specific plan.
  6. Develop Protective Action Response Procedures: Evaluate and include life protective action procedures such as evacuation, shelter, shelter-in-place, lockdown.
  7. Establish Hazard-Specific Response Procedures: Depending upon the response planning structure and required content, hazard-specific information may be either included within the response plan or created as a separate stand-alone plan.
  8. Coordinate with public emergency services: Work with public emergency services such as fire, police, HAZMAT teams and emergency medical services to share knowledge of your facility and its hazards, understand their capabilities to stabilize an emergency, and determine their response time to your facility that would be needed to stabilize incidents at your facility.
  9. Emergency Response Training: Training is essential so that everyone on site knows what to do in an emergency or disruption of business operations. Training should include, but not limited to
  • Response plan familiarization
  • Individual roles and responsibilities
  • Plan review training whenever a substantial change or revision is made to the plan that affects organization, procedures, roles and responsibilities, or response capability.
  • Refresher courses, as necessary
  1. Response Drills and Exercises: Corporate preparedness drills and exercises, which may include fire and evacuation drills, should be designed to test response plan components and participants’ knowledge of expectations and required duties to deploy response strategies and tactics, and restore operations.

Tags: Emergency Preparedness, Workplace Safety

Homegrown Security Threats and the Facility Security Plan

Posted on Thu, Feb 09, 2017

A report by the New Jersey Office of Homeland Security and Preparedness ranked homegrown violent extremists as the number one threat to security. As a result, companies should continue to bolster their security training, response planning and preparedness efforts into 2017 so that they are better prepared to identify and respond to security issues.

According to the report, “Homegrown violent extremists are individuals inspired by foreign terrorist organizations and radicalized in the countries in which they are born, raised, or reside.”

Companies, security personnel and employees should remain vigilant.  The report identified “Eight Signs of Terrorism” that the private sector should be aware of. The signs include:

  1. Surveillance: Terrorists will attempt to determine the strengths, weaknesses, and number of personnel that may respond to an incident.
  2. Elicitation/Seeking Information: Attempt to gain information through inquiries, including seeking knowledge about a place, person, or operation.
  3. Tests of Security: Either through visual observations or physical entry, suspects may move into sensitive areas, and observing security and law enforcement responses.
  4. Acquiring Supplies: The purchase or theft of explosives, weapons, or ammunition. It could also include unusual purchasing or storing of fertilizer or harmful chemicals. Terrorists also find it useful to acquire law enforcement equipment and identification, military uniforms and decals, and flight passes, badges, or manuals.
  5. Suspicious People: Observe suspicious people who do not belong. The suspicious person could be anyone in a building, neighborhood, or business establishment who seems out of place because of their demeanor or line of questions.
  6. Dry Run: Before the execution of an operation, a practice trial is usually run to work out any flaws or unanticipated problems.
  7. Deploying Assets: Look for someone deploying assets or getting into position. This is your last chance to alert authorities before a terrorist act occurs.
  8. Terrorism Funding: Terrorists use a variety of methods to raise, launder, and transport funds including false credit cards,

But with so many dynamic and security-related response planning variables, site-specific security training and preparedness planning can be challenging. A database driven, web based response planning system can alleviate some of those challenges.

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A security assessment should be performed in order to identify areas at the facility that may be vulnerable to a security threat. In order to address security issues, a facility response plan should include, but is not limited to the following security related components:

Notifications:

  • The Facility Security Officer must have a means to effectively notify site personnel of changes in facility security conditions.
  • Transportation security incidents must be reported to the National Response Center and to appropriate emergency responders.
  • At each active facility access point, a system must be in place to allow communication with those that have security responsibilities, including the police, security control, and the emergency operations center.

Fencing and monitoring:

  • Security measures should be in place to prevent unauthorized access to storage areas. Facilities should provide continuous monitoring through a combination of lighting, security guards, and other detailed methods.

Evacuation:

  • The owner or operator must identify the location evacuation routes and assembly stations to ensure that personnel are able to safely evacuate during a security threat.

A security plan should describe the training, drills, and security actions of personnel at the facility. These actions should deter, to the maximum extent practicable, a security incident, or a substantial security threat. Facility personnel should receive varying levels of security training depending upon their responsibilities. Security training levels may vary, but might include:

  •  Knowledge of current security threats and patterns
  • Recognition and detection of dangerous substances and devices
  • Recognition of characteristics and behavioral patterns of persons who are likely to threaten security
  • Techniques used to circumvent security measures
  • Crowd management and control techniques
  • Security related communications
  • Knowledge of emergency procedures and contingency plans
  • Operation of security equipment and systems
  • Testing, calibration, and maintenance of security equipment and systems
  • Inspection, control, and monitoring techniques
  • Relevant provisions of the Facility Security Plan

 

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, Security plans

Will Regulatory Non-Compliance Cost you in 2017?

Posted on Thu, Jan 26, 2017

Corporate emergency preparedness and company-wide response planning is rarely quantified because of various uncertainties and a “not us” mind-set. Yet, when companies are not prepared for incidents, non-compliance fines can be assessed and employees, operations and profitability can be affected.

Federal Agencies, including OSHA, EPA, and PHMSA, as well as many state agencies continue to inspect and fine companies for non-compliance for a variety of infractions in hopes of creating a safer workplace and minimizing environmental impacts. Every year OSHA reveals its “Top 10 OSHA Citations”, a list compiled from nearly 32,000 workplace inspections.

“One remarkable thing about the list is that it rarely changes,” says the Department of Labor staff. Year after year, OSHA inspectors see thousands of the same job hazards, any one of which could result in a fatality or severe injury.

As in years’ past, OSHA published released its “Top 10”.  The Top Ten most frequently cited OSHA standards include:

  1. 501 - Fall Protection
  2. 1200 - Hazard Communication
  3. 451 - Scaffolding
  4. 134 - Respiratory Protection
  5. 147 - Lockout/Tagout
  6. 178 - Powered Industrial Trucks
  7. 1053 - Ladders
  8. 212 - Machine Guarding
  9. 305 - Electrical, Wiring Methods
  10. 303 - Electrical, General Requirements

As we move further into 2017, companies should utilize this list as a stepping stone to conduct assessments, identify potential site-specific compliance lapses, and mitigate highly recognized hazards. When companies can deliberately protect lives, prevent environmental hazardous, limit property damage and eliminate regulatory fines, they are investing in the sustainability of their company.

Since agencies redefined their monetary penalties in 2016, companies must not rely on the prospect of a regulatory agency inspection to ensure preparedness programs are sufficient. Prioritizing safety, preparedness and response planning can often mitigate these highly- recognized hazards. Below are just a few of the citation results from 2016 agency audits:

January 2016

  • OSHA: A manufacturer of swimming pool chemicals and acetone products was assessed fines totaling $61,600 for lacking a process safety management program.

February 2016

  • EPA: Salt Lake County, Utah failed to develop and implement a stormwater pollution prevention and management program that minimized the discharge of pollutants to the maximum extent. The County was responsible for a $140,000 fine.

March 2016

  • OSHA: A popular Washington DC hotel was fined $76,000 for exposing employees to more than two dozen workplace safety and health hazards.

April 2016

  • EPA: A Company that provided corrosion protection for steel products was fined $14,436 for illegally discharging liquid waste into nearby artificial wetlands.

May 2016

  • OSHA: A Frozen food company received multiple serious and willful violations totaling $168,000. Violations included, but were not limited to:
    • Newly hired employees were not trained in the company’s Emergency Action Plan
    • Lack of pre-emergency planning coordination with external responders during an ammonia release
    • Inadequate hazardous material response training

Greenhouse_Gases.jpgJune 2016

  • EPA: A national chain specialty grocery store was assessed a $500,000 civil penalty related to greenhouse gases emissions from refrigeration equipment at 453 of its stores.

July 2016

  • OSHA: A Houston contractor was found violating serious trench hazards for the sixth time in 10 years. The contracted was fined $124,000.

August 2016

  • EPA: A California power company agreed to pay $47,000 to settle EPA claims. The EPA stated that the company violated federal regulations in its spill management

September 2016

  • EPA: A petroleum company was assessed a non-compliance fine of $345,000 regarding the Clean Water Act’s stormwater discharge requirements associated with industrial activities. Non-compliant activities included failing to:
    • Implement best management practices
    • Implement a Stormwater Pollution Prevention Plan
    • Monitor and report discharge data of the facility’s discharges of pollutants
    • Obtain the appropriate stormwater discharge permit associated with industrial activity.

October 2016

  • PHMSA: A gas transmission company was assessed $550,400 for safety violations that occurred during an accidental release, including:
    • Failing to notify the National Response Center following the release
    • Failure to document proper DOT accident report
    • Failure to correct hazardous condition
    • Failure to follow operational and maintenance procedures

November 2016

  • OSHA: A Louisiana contractor was issued more than $150,000 in fines to a Louisiana contractor for confined space violations after fumes sicken two workers. OSHA issued citations for six serious violations and one willful violation.

December 2016

  • PHMSA fined a natural gas company $110,700 due to violations of pipeline safety regulations for:
    • Failure to provide cathodic protection
    • Failure to test pipelines under cathodic protection
    • Failure to test relief capacity
    • Failure to develop and cover certain tasks associated with Operator Qualification Program

 

  • Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance

NEW Hazardous Waste Generator Regulations: Effective May 30, 2017

Posted on Thu, Jan 12, 2017

On November 28, 2016, the EPA published its final ruling that revised Resource Conservation and Recovery Act's (RCRA) hazardous waste generator regulatory program. According to the EPA, “the new ruling is intended to provide greater flexibility in how hazardous waste is managed to better fit today's business operations, enhance the safety of facilities that create hazardous waste and improve the response capabilities of emergency responders by improving risk communication.” The final rule goes into effect on May 30, 2017.

Highlights of New RCRA Rule 

  1. Reorganized hazardous waste generator regulations to make them more user-friendly, and thus improve their usability by the regulated community.
  2. Provide a better understanding of how the RCRA hazardous waste generator regulatory program works.
  3. Address gaps in the existing regulations to strengthen environmental protection.
  4. Provide greater flexibility for hazardous waste generators to manage their hazardous waste in a cost-effective and protective manner.
  5. Make technical corrections and conforming changes to address inadvertent errors and remove obsolete references to programs that no longer exist.

This final rule includes over 60 changes to the hazardous waste generator regulations that clarify existing requirements, increase flexibility, and improve environmental protection. These changes also reorganize the regulations to make them easier to follow and make certain technical corrections. The new ruling is aimed at the following:

User-Friendly and Flexibility

  • Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed.
  • Allowing a very small quantity generator (VSQG) to send its hazardous waste to a large quantity generator under control of the same person.

Improved Environmental Protection

  • Updating the emergency response and contingency planning provisions for small quantity generators (SQGs) and large quantity generators (LQGs) to include Local Emergency Planning Committees (LEPC).
  • Requiring periodic re-notification for SQGs every four years (SQGs only notify once under the current system).
  • Improved labeling and marking that clearly indicate the hazards of the hazardous waste contained inside of containers and tanks.

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Improve Generator Compliance

  • Clarification on generator categories and applicable guidelines regarding acute and non-acute hazardous waste.
  • Revises RCRA biennial reporting inconsistencies.
  • Replaces the phrase “conditionally exempt small quantity generator” with the phrase “very small quantity generator” to be consistent with the LQGs and SQGs generator categories.

Reorganization Regulations and Technical Corrections

  • VSQG regulations are moved to 40 CFR part 262, where the regulations for SQGs and LQGs are located.
  • Consolidates various generator regulations from other parts of the hazardous waste standards into 40 CFR part 262 to replace the current lists of cross references.
  • Corrects inadvertent errors in the regulations, obsolete programs, and unclear citations.

For a complete synopsis of the new Hazardous Waste Generator Improvements Rule, read the entire rule in the Federal Register.

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance

Top TRP Corporate Preparedness Blogs of 2016

Posted on Thu, Dec 29, 2016

As 2016 dwindles and our readers anticipate the New Year, TRP is looking forward to its 22nd year of innovation and service.  In addition to providing resourceful, informative articles that guide professionals in developing effective, compliant, cohesive, and world-class response plans, our response planning experts and in-house software development staff continue to introduce evolutionary technological improvements, upgrades, and state-of-the-art response planning tools and services.

Yet, before we move on to 2017, TRP would like to share our “Top Ten” blogs from 2016.  While the topics vary, we hope corporate and facility emergency managers, first responders, and industrial safety professionals can utilize these blogs to advance emergency management, preparedness initiatives, and safety efforts in 2017. 

Our “Top Ten” 2016 blog articles include:

10) The Evolution of Response Planning - The TRP Story: (July 14, 2016) TRP President, Steve Bassine, discusses TRP's origins, its evolution, and the company’s response to the changing demands of corporate preparedness, response planning, and regulatory compliance.

9) 3 Critical Pre-Planning Elements for Effective Crisis Management Plans: (September 1, 2016) The modern pathways of communication are so quick that companies must have solid communication and crisis management plans. Pre-planning communications details, methods, and response strategies for crisis management plan is essential for minimizing the impact a crisis situation.

8) Corporate Crisis Management Plans - Stabilizing the Chaos: (September 15, 2016) Every crisis has the potential to negatively impact a company’s reputation, daily operations, and financial performance. Learn how a strategic crisis management response plan framework with management, communications & recovery checklists and criteria is essential to have in place prior to any crisis scenario in order to guide the decision-making process.

7) Spill Response: HAZWOPER or Hazard Communication Standard Training? (September 8, 2016) Discover how spill response training levels distinguish between incidental spills and emergency spills that require evacuation and Hazmat team assistance.

6) “Top 10" Guide for Response Plan Exercises: (November 3, 2016) Learn the “Top 10” corporate preparedness exercise guidelines for effectively testing response plans and coordinating disaster responses to crises and emergencies.

5)  Business Continuity Scenarios to Review for Effective Preparedness: (August 4, 2016) The list of potential threats, risks and interruptions that can influence the operational status of a business unit is continuously evolving. TRP highlights potential scenarios that should be considered when developing business continuity plans and ensuring corporate preparedness.

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4) New PREP Guidelines Go Into Effect: June 2016: (April 26, 2016) Identify new PREP guidelines that went into effect in June that aligns terms, expands spill countermeasure topics, and includes salvage, marine firefighting, non-tank vessel exercise requirements.

3) What's Your Plan? Emergency Action Plan or Emergency Response Plan? (April 14, 2016) A brief description of the differences between Emergency Action Plans (EAP) and Emergency Response Plans (ERP) and how they each impact the specifics and details that must be included in corporate response plans.

2) U.S. Coast Guard Updates OSRO Classification Guidelines for 2016 (June 16, 2016) In March 2016, the US Coast Guard’s National Strike Force Coordination Center released the new 2016 Oil Spill Removal Organization (OSRO) Guidelines. Companies that contract OSROs to control a worst case discharge spill scenario must be aware of new USCG OSRO classification guidelines.

1) 10 Questions Executives Should Ask about Response Plans and Compliance: (July 7, 2016) Prioritizing compliance, preparedness, and response not only facilitates a unified culture of safety, but heightens a company’s ability to fulfill their moral responsibility to protect employees, the community, and the environment. TRP highlights ten questions that executives should initiate to company managers to ensure effective and compliant response planning programs are in place.

TRP’s industry-proven technology has resulted in many large-scale enterprise-wide implementations across highly regulated industries. The TRP SMARTPLANTM platform has enabled these companies to transition from static mismatched formats and non-functional binder-based response plans to an all-inclusive, user-friendly, web-based preparedness program.

Preparedness and Emergency Management - TRP Corp

Tags: corporate preparedness

Response Plan Compliance Tracking and Submission

Posted on Thu, Dec 15, 2016

Regulatory Compliance is Not Optional

Month after month, companies are reminded through assessed fines and mandated enforcements that regulatory compliance is not optional. In August 2016, the U.S. Environmental Protection Agency (EPA) settled with an oil and gas equipment company for hazardous waste violations at five Texas facilities. The company was assessed a penalty of $237,980 for violations regarding improperly generating, transporting and disposing of hazardous waste.

These types of cases are not restricted to one industry. If regulations apply to operations, non-compliance fines can be assessed. The most widely applicable regulations to industrial companies are those under the realm of the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA).

 

Typical Industrial Requirements

Below are a sample of the EPA requirements that may be applicable to industrial operations:

  • National Pollutant Discharge Elimination System (NPDES) - Permitting program designed to control water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.
  • Facility Response Plan (FRP) - Requires an owner or operator of a facility that could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines to prepare and submit a facility response plan.
  • Resource Conservation and Recovery Act (RCRA) - The primary governing law that oversees the generation and containment of solid and hazardous waste.
  • Spill Prevention Control and Countermeasure Plans (SPCC) – Requires developing site specific plans for oil storage facilities that describe spill prevention and response procedures.
  • Emergency Planning and Community Right to Know (EPCRA) - Establishes requirements for federal, state and local governments, Indian tribes, and industry regarding emergency planning and "Community Right-to-Know" reporting on hazardous and toxic chemicals to enable a more effective emergency response planning process.

 

Response Plan Submissions

A simplified regulatory submission process is highly beneficial when companies have multiple facilities in various locations. Despite similar operations within the same industry, each site may need to comply with specific local, state, and/or federal regulatory mandates. Companies should have a systematic method to itemize these varied regulations and include categorical information that satisfies that regulation. Implementing a web-based planning system with a regulatory tracking element can eliminate redundancies across converging compliance requirements and minimize dedicated administrative time.

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Compliance Tracking System

Using database technology allows association of each regulatory requirement to applicable facilities. Additionally, updating evolving regulatory information can be effectively managed across multiple facilities with the use of a database. At a minimum, a web-based tracking system should contain the following components:

  • Operational Category: Categories can range from air quality and hazardous materials, to construction safety and general safety and health. Depending on the detail required by the regulations, further subcategories may be utilized.
  • Applicable Regulation Level: Regulations should be further broken down to federal, state or local regulation categories. 
  • Update History: Date that each regulation was last updated.
  • Compliance Task: Tasks that needs to be completed for compliance.
  • Compliance Feedback: Applicable notes.
  • Industry Standard: Industry standards or best practices that apply to the specific -regulatory requirement.
  • Cross-reference: Itemized list of additional regulations that may be applicable to the information provided.
  • Facility Compliance Responsibility: Person(s) responsible to maintain compliance for each regulatory requirement.
  • Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and persons assigned. Reports should have filters to customize queries as required by the users.

The ability to track company-wide compliance and streamline the regulatory submission process is administratively advantageous for the individual company, as well as the multiple regulatory agencies. With required response plans in an easy to use electronic format, companies can ensure compliance and easily adhere to new, and future regulatory submission policies.

To receive your free white paper on Response Planning for Large Organizatiojns, click the image below:

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: Response Plans, Regulatory Compliance