Your Solution for SMART Response Plans

Managing Response Plans for Multiple Regulatory Agencies

Posted on Thu, Mar 20, 2014

The challenge of managing and ensuring compliant response plans for multiple facilities and multiple regulatory agencies is daunting. When audits reveal planning gaps, unless amended, enforcement mandates and costly non-compliance fines may result from the lack of an implemented, thorough, or effective regulatory compliance programs. By utilizing an enterprise-wide template approach to response plans, companies can satisfy multiple regulatory requirements through a cohesive, yet site-specific standardization of best practices.

In order for emergency plans to be timely, effective, and compliant, site-specific facility information and operational hazards must be addressed and included in a template plan. Off-the-shelf, generic response plan templates will not address every aspect required of an emergency plan. Utilizing generic templates often results in incomplete, ineffective, and non-regulatory compliant plans.

If templates are connected to a web-based database, site-specific information can be cross-referenced with regulatory requirements. As facilities are added or modified, operations are revised, or employees are re-assigned, each plan can be conveniently accessed and updated for accuracy and compliance.

The use of a consolidated emergency, or all-hazards response plan can be adapted to comply with multiple regulations. Annexed plans, such as fire pre plans or business continuity plans can be created to provide more specific and comprehensive response procedures. With a comprehensive, web-based response plan template, 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

The planning template must incorporate all local, state and federal regulations. The following questions may assist companies in determining site-specific information requirements for developing an emergency plan template.

1. How will the emergency be reported and response initiated?

  • Create notification procedures. Emergency notifications may include 911, National Response Center, and internal and/or external response teams
  • Identify alarms and how they will be activated.  Specific alarm signals may signal employee evacuation or shelter in place. Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in immediate response actions, as described in plan
  • Identify emergency classification levels to ensure appropriate response actions and resources

2. Who will be in charge of the Incident and who will conduct additional response duties?

  • Create Emergency Management Team organizational chart and activation procedures
  • Create Emergency Management Team roles and responsibilities checklists

3. What threats affect the facility or employees?

  • Perform a detailed hazard and risk analysis
  • Create response procedures for each identified threat
  • Create a process for incident documentation
  • Utilize appropriate ICS Form(s)
4. What incidents or classification level require evacuation/shelter in place
  • Create multiple evacuation routes
  • Determine criteria as to whether evacuation goes beyond facility borders
  • Identify the muster point(s) and head count procedures

5. How are response actions sustained?

  • Identify command post locations and equipment requirements
  • Identify response resources and equipment (both internal and external)
  • Create communications checklist and identify communications equipment available
  • Identify hazard control applicability and methods
  • Detail external communications and public relations policies

6. What is done after the incident is secured?

  • Create checklist for demobilization guidelines
  • Perform a post-incident review and debriefing
  • Identify  “lessons learned”, assign action items, and update response plan accordingly

In 1996, the National Response Team published the Integrated Contingency Plan (ICP) Guidance in an effort to provide companies with the means to comply with multiple federal planning requirements required by various regulatory agencies.  The ICP, based on the National Incident Management System (NIMS) and the Incident Command System (ICS), was intended to be used by companies to prepare emergency response plans for responding to releases of oil and non-radiological hazardous substances.

An industrial facility may use an ICP to incorporate one or more of the following applicable federal regulations:

EPA:

  • Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements), 40 CFR part 112.7(d) and 112.20-.21
  • Resource Conservation and Recovery Act Contingency Planning Requirements, 40 CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52.
  • Risk Management Programs Regulation, 40 CFR part 68

Department of the Interior:

  • Bureau of Safety and Environmental Enforcement Facility Response Plan Regulation, 30 CFR part 254

Department of Transportation/Pipeline and Hazardous Materials Safety Administration:

  • PHMSA Pipeline Response Plan Regulation, 49 CFR part194
  • U.S. Coast Guard, Facility Response Plan Regulation, 33 CFR part 154, part F

Occupation Safety and Health Administration (OSHA)

  • Emergency Action Plan Regulation, 29 CFR 1910.38(a)
  • OSHA's Process Safety Standard, 29 CFR 1910.119
  • OSHA's HAZWOPER Regulation, 29 CFR 1910.120

Facilities may also be subject to state emergency response planning requirements that are not included in the National Response Team ICP Guidance. Facilities are encouraged to coordinate development of their own ICP with relevant state and local agencies to ensure compliance with any additional regulatory requirements.

For a free Audit Preparedness Guide for Industrial Regulatory Compliance, click the image below:

Regulatory Compliance with TRP Corp

Tags: USCG, PHMSA, DOT, OSHA, Response Plans, EPA, OPA 90, Regulatory Compliance

Emergency Preparedness Measures: Can you Afford Non-Compliance?

Posted on Mon, Jan 27, 2014

The increasing number of stringent regulatory compliance standards compounds the complexity of industrial operations. Many companies believe they have the compliance component of their business under control. Others take a reactionary role rather than a proactive approach.  Without a proactive approach, incidents affecting the financial bottom line of companies, their communities, and surrounding environments will continue.

Every month, audits and enforcement mandates are issued from various federal and state agencies that oversee industrial facilities. Agencies such as OSHA, EPA, and DOT’s PHMSA inspect and fine offending companies for non-compliance for a variety of infractions. Costly non-compliance fines continually result from the lack of an implemented, thorough, or effective preparedness planning and regulatory compliance programs.

Associated penalties are continually increasing. In April of 2013, the PHMSA issued a ruling that incorporated new civil penalties. The ruling included:

  • Increasing the maximum fine possible from $55,000 to $75,000, for knowingly violating the law
  • Revising the maximum penalty from $110,000 to $175,000, for knowingly violating the law in a way that results in “death, serious illness, or severe injury” to a person, or which causes substantial destruction of property
  • Eliminating the minimum civil penalty amount, since most fines are well over the previous set minimum of $250. However, a minimum penalty will be retained for training violations, now to be set at $450.

Below is a sampling of the price of non-compliance. The list is comprised of a wide array of companies from various regulatory agencies (dates are by citation, not occurrence).

January 2013

EPA: A cold storage and ice manufacturing company was ordered to pay penalties of $225,000 for violating federal Clean Air Act requirements meant to prevent chemical releases. The company failed to implement the required Risk Management Plan relating to the use of ammonia at a number of its facilities.

February 2013

OSHA: A railway company was ordered to pay $1,121,099 for violating the whistleblower provisions of the Federal Railroad Safety Act.

March 2013

EPA and Hawaii State Department of Health: A ship repair and dry dock facility on Oahu was fined $710,000 in civil penalties for water pollution control violations. This was the largest Clean Water Act civil penalty against a ship repair facility nationwide.

April 2013

PHMSA: A compliance order and civil penalty of $104,800 was assessed to a pipeline holding company for failure to comply with pipeline safety regulations. The violations pertained to inadequate firefighting equipment and improper inspection and testing record keeping.

PHMSA: After a two-year investigation, a fine of $1.7million was proposed as a result of failing to implement measures to address known seasonal flooding risks to a pipeline system. Additionally, the company failed to establish written procedures to protect the pipeline from floods and other natural disasters, which would have minimized the volume of oil released.

May 2013

OSHA: A company that manufactures wood shavings for animal bedding was assessed $233,870 in proposed fines. Violations included 28 repeat and serious violations of the workplace safety and health standards.

June 2013

PHMSA: Proposed and collected a civil fine of $235,600 with a pipeline company that neglected to implement response plans, emergency shutdown processes, and inspections regarding the facility compressor station.

August 2013

OSHA:  An Ohio steel manufacturing plant’s compliance 24 violations added up to fines totaling $1,138,500. Fifteen of the non-compliance aspects included willful violations of OSHA’s fall protection standards

September 2013

EPA: A refinery’s parent company was issued a $8.75 million penalty for failing to comply with a 2007 settlement that resolved violations of the Clean Air Act. Between 2007 and 2011, the company violated numerous requirements of the initial settlement, including failing to comply with emissions limits. The company also failed to perform corrective actions or to analyze the cause of over 70 incidents involving emissions of hazardous gases through flaring.

October 2013

PHMSA: A pipeline company was assessed a $20,000 fine for failing to present written documentation of public awareness (as recommended by the American Petroleum Institute), and failing to providing baseline material to emergency responders or excavators.

November 2013

OSHA: An Arkansas-based meat processor was issued a total of $121,720 in proposed fines for violations at various sites. The inspection, which began on May 15, 2013, was conducted under OSHA's Site Specific Targeting Program, which directs enforcement resources to high-hazard workplaces with the highest rates of injuries and illnesses. OSHA found a cross section of mechanical, electrical and fall hazards, as well as several deficiencies in the process safety management program. The hazards include failing to guard skylights and roof hatchway, guard a press, provide safety-related work practices to prevent electric shock and arc flash burns, and provide workers with protective equipment when using energized equipment. 

December 2013

EPA: A paint manufacturer was penalized $153,917 for violating federal hazardous waste laws. Violations included failure to properly identify hazardous wastes, failure to properly label and store hazardous waste containers, and failure to train personnel who manage hazardous waste.

For a free download on conducting effective exercises, click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: DOT, OSHA, Emergency Preparedness, EPA, Regulatory Compliance, Emergency Management Program

Don't Get Caught Non-Compliant: Top Tips for Regulatory Compliance

Posted on Thu, Jan 23, 2014

In early January, a chemical leak from a Freedom Industries storage facility caused West Virginia American Water to shut off the water supply to nearly 300,000 people. The West Virginia Department of Environmental Protection identified five violations which will likely result in substantial fines. In addition, criminal penalties may be pursued.

As demonstrated month after month, compliance is a requirement, not an option.  Some argue that the bureaucracy is riddled with inefficiencies. However, the “rules” are aimed to protect communities and the surrounding environment.  According to David Hall’s Wall Street Journal article, The Morning Ledger: Companies Beef Up Compliance Departments, “Hefty fines and other penalties have jolted companies, especially banks, into a compliance hiring spree, as governments at home and abroad tighten business laws and regulations and ramp up their enforcement activity.” Compliance costs are typically lower than the expenditures associated with non-compliance fines, litigation, reputational risk, and government mandated shutdown of operations. Companies must implement a budget that ensures regulatory compliance.

Managing regulatory compliance for industrial facilities can be a daunting task. Industrial facilities must operate profitably; yet comply with a complex array of federal, state and local regulations.  The consequences of disregarding the various required elements can be corporate self-destruction.

Key concepts for managing regulatory compliance from a corporate perspective include, but are not limited to:

Database Technology

Technology is a useful, and relatively inexpensive tool that enables companies to monitor continually evolving regulatory requirements. In recent history, companies have utilized Excel spreadsheets to manage requirements. However, as a company expands or new regulations are implemented, spreadsheets can become overwhelming, ineffective, and time consuming. Larger operations should consider utilizing database technology to ensure that compliance can be effectively managed on an enterprise-wide level. Utilizing a database limits the duplication of tasks generated when multiple agencies have regulations that are related to the same subject matter.

Available Expertise

Internal resources or outsourced compliance expertise can enable a company to leverage regulatory knowledge enterprise-wide. In order to focus on core business components and reduce managerial and administration efforts required to manage compliance, companies can examine utilizing consultants to ensure appropriate response planning and compliance measures.

Facility-Specific Regulations

A company must recognize mandatory submission requirements and tasks for each facility associated with each regulatory requirement. The implementation of a tracking management system that can eliminate redundancies across converging compliance requirements is extremely beneficial for organizations that have multiple applicable regulatory requirements.

A methodological tracking system should itemize applicable federal, state, and local regulations, and include categorical information that satisfies that regulation. A tracking system should, at a minimum contain the following components: 

  • Operational categories: 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 breakouts by subcategories may also be required.
  • Applicable Regulation Level:  Regulations should be further broken down to Federal, state or local regulation categories.  
  • Time/Date Stamping: The Time and Date that each regulation was last updated.
  • Compliance Feedback:  Applicable notes regarding compliance or non-compliance.
  • Industry Standard:  Apply best practices related to compliance with specific regulatory requirements, when practical to do so.
  • Cross-reference: Itemize list of additional regulations that may be applicable to the information provided.
  • Facility Compliance responsibility: Identify contact assigned to maintain compliance for each regulatory requirement.
  • Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and person(s) assigned. Reports should have filters to customize queries as required by the users.
  • Search Functionality - Create the ability to search database for key words and phrases associated with regulations.

One of the most important aspects of maintaining compliance is ensuring that required response plan and associated revisions are submitted to the proper regulatory agencies in a timely manner. The various agencies have different submission requirements regarding initial and plan revision compliance.

For a free fire pre plan guide, click the image below:

 

TRP Corp Fire Pre-Plans Pre Fire Plan

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Tags: DHS, DOT, OSHA, CFATS, Response Plans, EPA, Regulatory Compliance

Preparing for Supply Chain Disruptions with Business Continuity Plans

Posted on Mon, Mar 25, 2013

In October 2012, Hurricane Sandy’s unprecedented devastation caused havoc on the mid-Atlantic and east coast of the U.S. Infrastructure and supplies chain disruptions occurred across highly populated areas and multiple jurisdictions, severely affecting thousands of companies.  Ensuring ample supplies in the midst of an incident can be challenging. By identifying and pre-contracting vendors and alternate suppliers prior to an incident, a company improves its ability to quickly and successfully respond to incidents.

Hurricane Sandy’s storm surges and consequential flooding disrupted port operations and cut off dockage of incoming fuel tankers. Flooded automated pipeline fuel delivery equipment became inoperable. Power failures ceased fuel terminals transfers of gasoline into tanker trucks, and gas stations could not be restocked or operate pumps. As a result of the shortage, frustrated residents and businesses were forced to either go without the essential fuel or endure long lines and extreme supply uncertainty. The severe supply interruption created an additional level of business continuity issues.

Companies are often at the mercy of the “red tape” of governmental processes when disruptions envelope a wide area. In a business-driven society, regulations safeguard employees' rights, protect the environment, and/or monitor potential injustices. But in the case of Hurricane Sandy, licensing requirements and potential financial penalties exacerbated an already fragile supply chain.

Two bills, co-sponsored by Sen. Jennifer Beck and Sen. Robert Gordon, have been presented by the Senate Transportation Committee to streamline gasoline supply chain disruptions in the event of an emergency.

1. “Bill S-2581, provides a mechanism for fuel merchants to import motor fuel during the time of a state of emergency. Under current law, fuel merchants cannot purchase motor fuel from another state and import it in New Jersey unless the merchant first obtains a distributor’s license. After Hurricane Sandy, Governor Christie issued an executive order temporarily waiving this licensing provision to allow fuel to travel across state lines to boost supplies in New Jersey. The bill would eliminate the need for the Governor to issue future executive orders.” - Senator Jennifer Beck

2.  “Bill S-2582, provides that during a state of emergency, when a retail motor fuel dealer exhausts the supply of a lowest grade gas that dealer can sell any remaining supply of higher octane motor fuel at the same price as the price of the lowest grade motor fuel.”  - Senator Jennifer Beck

Senator Beck stated that the fuel shortage slowed the recovery process. “These bills remove regulatory hurdles that restrict the fuel supply during emergencies when we can ill afford red tape”, said Beck. While minimizing “red tape” helps streamline and ease the recovery process, companies should also prepare for, and expect delayed or interrupted supply availability after large-scale incident.

A business continuity plan (BCP) can help minimize or counteract many of the potential impacts of an incident.  Companies should utilize this tool to prepare for incidents that could impair or impede the ability to operate as a result of a temporary or permanent loss of infrastructure, equipment, supplies, critical staff, or data. Companies  can endure significant challenges and potential financial losses.

The following minimum business continuity planning elements should be considered when developing a BCP:

  • Identify critical business processes to maintain continued operation and mitigate as practicable.
  • Identify the triggering events that initiate an emergency action, and specify checklist items to be taken.
  • Train assigned personnel to complete required checklist action(s) in case business continuity implementation is necessary.
  • Identify typical transportation methods and necessary staffing levels to reveal potential threats to continued productivity.
  • Identify key vendor and supply chain requirements. Transportation delays could affect delivery times of essential supplies. Plan and mitigate accordingly.
  • Identify technology requirements such as back up timelines, communication methods, and if possible, mitigate any potential networking disruptions.
  • Identify and arrange for potential alternate locations, if applicable (ex. satellite offices, home-based opportunities, alternate locations).
  • Identify recovery time objectives for each critical process.
  • Review and update personnel contact information and notification procedures.
  • Minimize vulnerabilities by proactively implementing measures to ensure the safety and security of the facility and employees, as needed.
  • Review emergency action and response plans with employees.

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

TRP Download

Tags: DOT, Business Continuity, Supply Chain, Business Continuity Plan, Business Disruption

Record Crude Rail Shipping Highlights Need for Preparedness Planning

Posted on Mon, Mar 18, 2013

In recent months, near record U.S. crude oil production has made railcar transportation a viable and cost-effective alternative to pipelines for market distribution. According to the Oil and Gas Financial Journal, total petroleum-based shipments increased 46% from 2011 to 2012. Railroads are stepping in to haul petroleum-based products from locations that lack ample pipelines, such as North Dakota’s Bakken shale fields.  Shale field regions have seen enormous rail loading terminal development in recent months to keep up with output. Much of the railcar growth and resurgence in Texas is related to the Eagle Ford shale production and activity in the Permian Basin.

The benefits of the digital railroad to the future of the U.S. transportation infrastructure will rival the benefits of railroads in the 1800s to the western United States. It will be a true renaissance. -  John M. Samuel, The Freight Railroad Renaissance.

U.S. oil production is expected to increase 24% by 2014. However, crude has little value unless it can be transported to refineries. It is unlikely that new refining capacity closer to production locations will fill the gap soon due to the long, rigorous process required for permitting construction of such a facility. With the delays in the Keystone pipeline approvals, railcars are increasingly being used to import necessary operational equipment to production sites and transport extracted crude to other areas.

In a February 21, 2013 press release, the Association of American Railroads reported that U.S. Class I railroads carried a record 233,811 carloads of crude oil in 2012, which is an increase of 256% from 65,749 carloads in 2011. With pipeline capacity still severely limited in key geographic locations, oil stakeholders are moving more crude oil by rail.

RailCar Crude - TRP Corp

Railcars offer stakeholder flexibility and can be scaled to meet customer’s needs by adding or removing cars, as needed. Railroads see the boom on the horizon and are investing heavily in new locomotives, rail cars, railroad ties and infrastructure. BNSF Railway announced that it would boost oil rail shipments by 40% this year. In far north Fort Worth, General Electric has hired 300 new employees at a new locomotive plant, with the first engine expected to roll out the door soon.

But with railcar growth, stakeholders need to emphasize effective preparedness and response in order to protect life, property, and the environment. Railway segments, whether new or existing, can share common acreage with waterways, residential neighborhoods, businesses, schools, and municipalities. Railcars carrying crude or other hazardous material are a distinct type of risk since they do not utilize secondary containment. If a spill were to occur, the impact could be devastating on multiple fronts.

By creating tactical response plans, stakeholders can identify and plan for key geographical challenges that may delay responding to and managing oil spills.

The primary objectives of tactical response plans are to:

  • Allow response personnel to prepare for and safely respond to spill incidents
  • Pre-identify effective response locations downstream of potential spill sources
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response
  • Outline response procedures and techniques for specific locations
  • Improve regulatory compliance efforts
  • Minimize impact

Tactical spill plans should include, but are not limited to:

  • Photographs of each site (including ground and aerial views, if possible)
  • Maps
  • Latitude and Longitude
  • Land/property owner information
  • Driving directions to the site from main roads
  • Description of potential staging area(s)
  • Specific response tactics for the site location
  • Description of site and applicable waterways
  • Site access specifications
  • Security requirements
  • Waterway flow rates and composition
  • Any critical response information that may be informative to responders
  • Recommended equipment and personnel to implement response strategy
  • Other site specific pertinent issues that may hinder a response

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

TRP Fire Pre Plan Image

Tags: DOT, Emergency Management, Emergency Preparedness, Oil Spill, Supply Chain

Integrated Contingency Plan - The "One Plan" for Regulatory Agencies

Posted on Thu, Aug 16, 2012

In 1996, the National Response Team published the Integrated Contingency Plan (ICP) Guidance in an effort to provide facilities with the means to comply with multiple federal planning requirements required by various regulatory agencies by consolidating them into one emergency response plan

By creating a single comprehensive integrated contingency plan, emergency managers can;

  • reduce the need for multiple plans
  • minimize administrative costs
  • simplify plan reviews
  • minimize discrepancies across various plans
  • streamline response directives from one source

An ICP does not exempt facilities from applicable regulatory planning requirements pertinent to releases of oil and non-hazardous substances. Multiple federal agencies endorse the use of an ICP as a means to incorporate statutes and regulations, include requirements for emergency response planning. A particular facility may use an ICP to incorporate one or more of the following applicable federal regulations:

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

Facilities may also be subject to state emergency response planning requirements that is not included in the National Response Team ICP Guidance. Facilities are encouraged to coordinate development of their ICP with relevant state and local agencies to ensure compliance with any additional regulatory requirements.

National Response Team is composed of 16 Federal agencies having major responsibilities in environmental, transportation, emergency management, worker safety, and public health areas is the national body responsible for coordinating Federal planning, preparedness, and response actions related to oil discharges and hazardous substance releases

For a sample Emergency Response Checklist, download our helpful and informative guide.

Tags: PHMSA, DOT, OSHA, Emergency Management, EPA, Regulatory Compliance, Facility Management, Emergency Management Program, Emergency Action Plan

Pipeline Safety versus Regulation Overload

Posted on Thu, Jan 26, 2012

On January 3, 2012, President Obama signed the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 into law. The law provides the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) with stronger enforcement tools, doubles maximum fines for safety violations to $2 million, and requires new pipeline safety standards.

Prompted by the deadly 2010 San Bruno, CA gas pipeline explosion that killed 8 people, injured dozens of others and damaged or destroyed more than 100 homes, the new law requires PHMSA to require operators to install automatic or remote-controlled shut-off valves and excess flow valves in new or replaced transmission pipeline.

However, some safety advocates feel the law does not align itself with several key recommendations arising from the 2010 investigations, including stricter leak-detection or integrity management requirements. Additionally, the National Transportation and Safety Board suggested that new automatic valves would be highly beneficial on aging pipelines in highly populated areas. It was stated that the disaster in San Bruno would have been far less devastating if the new valves had been installed. Unfortunately, the cost of replacing valves on existing pipelines is far more expensive than during the initial or replacement phase.

US Transportation Secretary, Ray LaHood stated, “To promote regulatory certainty for the pipeline industry, the new bill prohibits PHMSA during a 2-3 year congressional review period, from issuing regulations establishing leak-detection requirements or expanding integrity management requirements beyond high-consequence areas. However, this restriction would not apply if a condition poses any risk to public safety, property, or the environment.”

According to the PHMSA, The United States currently has approximately 2.3 million miles of pipelines that transport oil, natural gas, and hazardous liquids.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

Exercises - TRP Corp

Tags: PHMSA, Pipeline, DOT, Department of Homeland Security

Incident Management of Transporting Hazardous Material

Posted on Mon, Jun 20, 2011

According to the Federal Highway Administration, millions of tons of flammable, corrosive, poisonous, and radioactive materials are transported daily across the U.S. Without much attention from the general public, the majority of hazardous materials cargoes arrive safely at their destinations. However, incidents do occur and occasionally there are serious threats to life or property.

A hazardous materials cargo spill is a release of a substance or material capable of posing an unreasonable risk to health, safety, or property when transported for commercial purposes. Unlike a vehicular fluid spill, a multitude of factors dictate the size and nature of the spill, including the type of material being transported, the original load size, the physical properties of the material, and the amount of damage to the transporting vessel.

Emergency planning procedures for carriers of spilled hazardous material should, at a minimum, include the following:

  • If a problem is suspected, pull the vehicle off the road and stop away from populated areas.
  • If vehicle must be stopped on or near the roadway, place warning devices (use hazard signs and 4-way flashers).
  • Do not move the vehicle. If the vehicle must be left unattended, leave it in gear and use the hand brake and chocks.
  • Retrieve shipping papers and keep them with you.
  • Check for injured parties/administer first aid if possible.
  • If appropriate per training standards, take steps to prevent fire, isolate sources of ignition, and prevent additional release of hazardous material(s).

The following Department of Transportation chart represents the number of incidents by DOT Hazard Classification from 2002 through 2007.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

Exercises - TRP Corp

Tags: DOT, Emergency Preparedness, Oil Spill, Emergency Management Program

Developing Emergency Procedures for Loading Racks

Posted on Thu, May 19, 2011

Modern loading-racks systems are designed, constructed, and installed according to strict codes and regulations. Additionally, proper procedures and thoroughly trained personnel help to ensure safe operation. However, equipment failures and human error may contribute to an emergency situation at the loading/unloading rack.

Loading-rack systems can deliver product at high discharge rates, and in the unlikely event of an accident while the system is operating, there is potential for significant exposure. As a result, emergency procedures should be developed for the following potential loading/unloading rack situations:

Minor Spills
Drivers and operators are responsible for thoroughly washing down a spill before resuming loading operations or starting engines.

Major Spill Emergency Shutdown

  • Manual Shutdown Buttons should be installed and available at all loading bays and racks, to allow for immediate shutdown all loading operations in response to any abnormal condition.
  • Activation of the Emergency Shutdown System should automatically shut down all loading operations and activate local alarms.

Fire System Activation

  • Manual Fire Pull Stations should be installed and available at all loading bays and racks, and may be used to manually activate a fixed Fire Suppression System.
  • Fire Suppression Systems should also activate automatically if the detection system detects the presence of a fire.
  • Activation of the Emergency Shutdown System should automatically shut down all loading operations and activate local alarms.

Evacuation

During an emergency, or when Fire Suppression Systems are activated, non-facility employees should evacuate a safe distance to the designated local Assembly Area.

Emergency Reporting and Notification
All emergencies, or activation of Fire Suppression Systems, should be reported immediately to the Incident Commander of Area Supervisor.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

Exercises - TRP Corp

Tags: DOT, Regulatory Compliance, Facility Management, Emergency Management Program

OSHA's Hazard Communication Standard and Emergency Training

Posted on Thu, Apr 14, 2011

NOTE: The Hazard Communication Standard, including Safety Data Sheets (SDS) format, has been updated. See TRP's "Phased Compliance of the Hazard Communication Standard..." blog. 

 

The Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Occupational Safety and Health Administration (OSHA) both have regulations focused on safety for transportation of hazardous materials. 

In 1986, OSHA initiated the Hazard Communication Standard - 29 CFR1910.1200. The purpose of this regulation is to communicate information to employees who may be exposed to hazardous chemicals in the workplace. As a result of this standard, each container of hazardous chemicals must:

  • Be labeled, tagged or marked with the identity of the hazardous chemical
  • Contain an appropriate hazard warning
  • Identify the name and address of the chemical manufacturer, importer, or other responsible party.

Based on the information on the label, the chemical manufacturer or other responsible party should be able to be contacted to determine emergency control measures and to estimate worst-case exposures.

According to OSHA, a MSDS must accompany each initial shipment of hazardous chemical and be readily accessible to employees handling the chemical. Since DOT requires truck drivers to carry MSDS information with the bill of lading for all shipments of hazardous cargo, which satisfies both agency requirements. Additionally, DOT requires transported hazardous materials to contain proper labeling in compliance with 49 CFR 172.302.

If the potential exists for an emergency situation to develop, training must be provided as described in 29 CFR 1910.1200. Training includes, but is not limited to:

  • Applicable leak and spill cleanup procedures
  • Appropriate PPE usage
  • Decontamination procedures and safety precautions

If an emergency response may be required for transported hazardous materials, emergency response plans must be developed and implemented and the provisions of OSHA’s Hazardous Waste Operations and Emergency Response Standard - 29 CFR 1910.120 apply.

When organizations opt to respond to emergencies with company personnel, a sufficient number of trained personnel must be available. In most cases, this is not the truck driver. However, the training required under 29 CFR 1910.120(q)(6) depends on the duties and functions to be performed by the truck driver. If truck drivers are expected to stop leaks involving hazardous materials and clean up potential spills, then a minimum of technician or specialist level training is required.

On March 10, 2011, the Department of Transportation announced a proposed rule to improve the safety of transferring hazardous materials to and from cargo tank motor vehicles. The notice proposes to add the following requirements:

  • Practice drills and classroom training of truck drivers and other workers who unload or load hazardous material
  • Training on automatic valve shut systems
  • Developing inspection and maintenance programs to ensure the safety of hoses, valves and other equipment used in loading and unloading.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

TRP Corp Emergency Response Planning Exercises

 

Tags: PHMSA, OSHA HAZWOPER, DOT, Emergency Preparedness, Regulatory Compliance