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Don’t Make These Three Common Industrial Fire Pre-Planning Mistakes

Posted on Thu, Jun 15, 2017

Does your industrial facility have specific fire response plans or fire pre-plans? If you answered “yes”, are they accurate and up-to-date? According to investigations conducted by The US Chemical Safety Board (CSB), “Inadequate or poor emergency planning or response has been a recurring finding.” To be sure your facility does not become a statistic, fire pre-plans should be properly developed and exercised. When best practices are followed, these plans can minimize the impacts of a fire on employees, the facility, and possibly the surrounding area.

Below are three common fire pre-planning mistakes and corrective measures that can enhance the overall usability of these plans, limiting the potential impacts of a fire.

1. Lack of a Local Planning Coordination: Coordinating fire pre-plans between private and public entities can result in an expedient and safer response. Yet, many companies do not take the time to communicate and coordinate. Partnering with associated response participants will result in a more successful and streamlined implementation of the intended plan.
Coordinated efforts should be reflected when establishing, updating, exercising, and responding to fire emergencies. A coordinated effort should consist of a combination of agreed elements including:
  • Personnel
  • Procedures
  • Company protocols
  • Best practices
  • Communications systems and methods

Establishing and sharing up-to-date facility information and site-specific potential hazards in a coordinated effort prior to a fire can assist responders in:

  • Determining appropriate and proven response methods
  • Acquiring and locating necessary equipment
  • Removing site-specific obstacles
  • Identifying neighboring exposures

The faster the first responders can locate, assess, access, and mitigate the emergency, the sooner the incident will be contained and facility operations restored to “business as usual”. Limiting liabilities in a fire emergency by informing first responders of key components is crucial to your company's livelihood.

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2. Difficult Fire Pre-Plan Format: As your organization evolves, grows, and changes over time, personnel, hazards, response equipment, and overall site layout may change. Many plans are out-of-date or the most recent versions are not distributed.

Plan details, such as site-specific information, firewater system, exposures, building hazards, and foam calculations, create thorough fire pre-plans, and may need to be updated over time. Dismissing the importance of maintaining these crucial response plans with the most up-to-date information could put lives at risk, exacerbate the emergency, and become a costly loss for a company.

As a result, each time a single component of the fire pre-plan needs to be updated, a paper document needs to be redistributed. If the plans are located on an internal intranet, the updated document should replace the former version. Utilizing a web-based, database driven system offers instantaneous updates to all authorized personnel, eliminating the possibility of “version confusion”.

These plans should be in “easy-to-read” formats. It is important to remember that responders may have to refer to fire plans at night, in periods of limited light, and in inclement weather. The easier the information is to read, the better it is for all responders. When facilities are large or spread out, color-coded plot plans can be utilized for each segment of the facility. Response strategies can be developed for each area, making it much easier to respond to fires in large complexes.

Because of an increasingly technological-driven culture, the concept of utilizing technology for preparedness planning continues to expand. Establishing or converting your paper-based plans into a web-based, database driven system allows for simple modifications, streamlined company formats, and easy distribution.

3. Limited Accessibility: Industrial fires can escalate quickly and the potential danger to lives and the environment can exponentially increase with time. In the event of an emergency, up-to-date paper plans may not be readily available. Even if a company utilizes electronic plans housed on a remotely accessed intranet, emergency events can render the main data source or server inaccessible.

When an incident is isolated to a particular location, web-based response plans offer accessibility on a company-wide scale. Web-based plans can also provide hyperlinks, forms libraries, simplified interfaces, and other tools designed to improve functionality for plan users and streamline company response elements.

But with any data system, redundancy and backup efforts are essential.  In the event Internet connectivity is terminated or inaccessible, emergency managers and responders must have alternative means to access plans. Redundant data centers, scheduled downloads, and security measures must be a part of any web-based emergency management program. This allows for multiple options for accessibility, ensuring the responders have the correct information at critical times.

 

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Fire Pre Plans, Fire Preparedness

Key Facility Response Plan Tips for Spill Response Requirements

Posted on Thu, May 25, 2017

The environmental, health and safety landscape is riddled with stories of injuries, accidents, and emergencies. Some stories become headline news and others may be buried in the stacks of safety reports. Yet any incident, large or small, can impact your employees, your facilities, the surrounding environment, and your financial bottom line. While the intensity of events may vary, comprehensive, compliant, and functional response plans for each facility must be developed and maintained to address a broad scope of probable emergency and crisis situations.

Companies have an ethical and legal obligation to protect their employees while on the job. However, a response plan is only as effective as the accuracy of its information, potential emergency or crisis scenarios, and the level of responder comprehension. For facilities that store and/or utilize hazardous materials, the obligation to create a top-notch facility response plan is even greater.

The Facility Response Plan

A Facility Response Plan, which can serve as both a planning and response-guiding action document, should be easily accessible. Companies should confirm that regulatory compliance, inherent site-specific safety issues, response efforts, and human resource factors are addressed within each of their site plans. Depending on operations, a Facility Response Plan may consist of:

  • Facility information, including its name, type, location, owner, operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and analysis of potential spill hazards and previous spills
  • 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 (ex: fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)

As personnel responsibilities, facility or operational specifics change, response plans must change accordingly. At a minimum, cyclical plan maintenance is essential to capture multiple moving parts that impact an emergency management program. If a facility has a high-risk potential for a specific scenario or operations utilize hazardous materials, supplemental response plans, such as a fire pre-plan or business continuity plan, should be added to the overall emergency management program.

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Small, Medium and Worst-Case

It is essential that any company that transports, stores or handles hazardous materials ensure spills are properly cleaned up to minimize environmental impacts and  workers are not injured. The Environment Protection Agency (EPA) states that site-specific scenarios and response resources must be addressed for small, medium, and worst-case spills. Discharges are categorized as follows:

  • Small discharge: up to 2,100 gallons spilled
  • Medium: 2,100 to 36,000 gallons spilled, or 10% of the largest tank (whichever is less)
  • Worst Case Discharge: Volume of the largest tank over 36,000 gallons

The source of a small, medium, and worst-case discharge may stem from various facility operations and corresponding equipment components. If the worst-case discharge falls within one of the specified ranges for small or medium discharges, a smaller facility may only need to plan for that level of response. Potential discharge scenarios can be derived from human error, equipment malfunction, third party intervention, or severe weather. Typical site components relating to discharge scenarios include, but are not limited:

  • transfer hose failure
  • improper or faulty hose seals
  • valve failure
  • misaligned piping connection or seal failure
  • pump seal failure or overfill
  • tank overfill or leak
  • catastrophic failure of largest tank
Most spill scenarios are small and are unlikely to travel off site. These spills would likely be contained in specified areas or by specialized equipment. However, if the spill scenario could potentially result in oil traveling off site, its migration pattern, potential traveling distance, and specifically identified locations should be detailed.


Any spill response, despite the size of the spill, should incorporate the company defined preparedness structure and procedures. Despite the voluminous details and the nature of a spill, all employees and responders should demonstrate an understanding and application of company policies and agency requirements through an established training and exercise cycle.

TRP Corp Emergency Response Planning Exercises

Tags: Facility Response Plan, Oil Spill

How Leading Companies Address Complex Response Planning

Posted on Thu, May 04, 2017

Whether plans are mandated by corporate policy or regulatory agencies, an effectively exercised and accessible emergency response plan can minimize impacts of an emergency on employees, the environment, and infrastructure. But when companies have multiple locations, each with site-specific risks and potential operational emergencies, how can corporate leaders know that response plans will be accessible, effective, timely and compliant?

Leading companies with multiple facilities are realizing that generic response planning templates often result in incomplete, ineffective, and non-regulatory compliant plans. As a result, web-based, database-driven software is gaining popularity as the practical solution for companies with complex preparedness obstacles. Advanced web-based software has been proven to streamline the challenges associated with multiple locations and regulatory requirements through a cohesive, yet site-specific standardization of best practices.

In order to maintain company-wide preparedness and regulatory compliance, every response plan must contain accurate, site-specific details consistent with operations, personnel, topography, sensitivities, weather, and other factors. This complex arrangement of continually evolving information has led leading companies to leverage this technology and reap the benefits of web-based, enterprise-wide emergency management systems.

 

Emergency Management Systems

Leading companies are embracing comprehensive, web-based response plan templates with an integrated database that can capture site-specific details for each location. With these systems, emergency managers can:

  • Reduce the need for multiple plans for a single facility
  • Minimize administrative costs
  • Simplify plan reviews
  • Minimize discrepancies across various plans
  • Streamline response directives from one source
  • More easily identify regulatory compliance gaps

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Web-Based System Benefits

Maintaining accurate details across multiple plan types for a large number of facilities is a challenge, especially when there is limited personnel. Intuitive response planning systems that streamline formats, and utilize database technology to leverage and manage information offer tremendous benefits in improving compliance and preparedness. The most advanced systems are specifically designed to improve the following:

Efficiency:  Effective response plans require cyclical maintenance. As a result of changing personnel, fluctuating external response contacts, and revolving equipment availability and inventory levels, maintaining up-to-date and actionable response plans can be administratively time-consuming. Emergency management software should eliminate the need for duplicate updates across multiple response plans. The most advanced web-based software programs utilize a database, allowing for specific repetitive information to be duplicated in the various necessary plan types across an entire enterprise. By minimizing administratively tasking duties, plan changes are more likely to be transferred into the system, optimizing the accuracy of the plans.

Accessibility of plans: In the event of an emergency, updated paper plans are typically not available from all company locations. Additionally, accessing plans housed on a company intranet may be dubious if an incident renders company servers inaccessible.  Although the intranet approach has improved overall plan accessibility, a number of significant difficulties remain. With an intranet approach, plan maintenance, version control, and consistency across multiple plans remain challenging and time-consuming.

Web-based planning software offers every option of instant accessibility: viewed via the Internet from any location, downloaded, or printed. Increasing accessibility options while improving efficiency, functionality, and effectiveness can bolster an entire emergency management program.

Instantaneous updates: With web-based technology and an Internet connection, revised information is immediately available to all approved stakeholders. Both paper-based plans and those housed on a company intranet are often out of date with multiple versions in various locations, potentially misinforming the response team.  Microsoft Word or PDF documents, often the format used in response plans, are cumbersome to revise for various plan types and locations. Web-based systems can eliminate ”version-confusion” and allows responders to apply the most up-to-date and tested processes to a response.

Superior functionality: Web-based plans can provide hyperlinks, forms libraries, simplified interfaces, and other tools designed to improve functionality for plan users. Simplifying documentation during an incident enables prompt response progress, improved regulatory compliance, and a more accurate account of the response. Easy to follow response plans allow responders to carry out specified industry and company procedures in accordance with proven best practices responses.

Multi-purpose data: Typically, response plans share common data with a variety of additional plan types including business continuity, pre-fire plans, hurricane plans, and others. Web-based, database driven plans utilize one database to manage this information, effectively leveraging plan content and revision efforts to all plans and locations that utilize that data.

If best practices are implemented, and training and exercises confirm effective response processes and procedures are in place, response plans can be an effective tool for responders. However, leading companies utilizing web-based, database software are recognizing that swift accessibility to plans with an accurate list of contacts, site-specific response procedures, and available resources, expedite the response process and minimizing impacts across the board.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: Response Plans, Cloud Computing, Regulatory Compliance

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

Industry factory in kawasaki at night.jpeg

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.

fencing-resized-600.jpg

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