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Top 10 Reasons to Improve Emergency Response Planning

Posted on Thu, Aug 10, 2017

Emergency management programs are in place for “when” an emergency happens, not “if” an emergency happens.

Natural disaster, human error, homegrown terrorism, regulatory compliance, equipment failure, or an awareness of potential crises...the list of emergency scenarios can be extensive. When companies prioritize emergency response planning, they can optimize their response. However, the cost/benefit of effective emergency management programs is often greater than expected. Below are ten “best practice” reasons why your company should prioritize emergency response programs and preparedness initiatives:

1. Demonstrate a commitment to safety: Companies should confirm that safety is a priority. By establishing proven countermeasures to potential threats and associated risks, companies can substantiate that the safety of employees and the protection of surrounding communities and the environment is important. Prioritizing emergency preparedness initiatives demonstrates a company’s commitment.

2. Improve regulatory compliance: Regulatory non-compliance fines are an unnecessary expense. These costly fines can result from the lack of implemented, thorough, and compliant programs. By systematically aligning regulations with corresponding response plans and their components, your company can identify plan deficiencies to avoid unnecessary fines or possible mandatory shutdowns.

3. Simplify updating processes: One of the main reasons response plans aren’t effective is because they are outdated. Continual administrative duties associated with personnel contact information, assignments, training records, exercises, and continual plan updates is challenging. Maintaining up-to-date response plan has become significantly easier with advanced technology and innovative software programs. If your company has not evaluated available programs, the cost and time associated with maintaining current administratively taxing response plans may be worth the investment.

Implementing a technologically advanced enterprise-wide emergency management system offers opportunities to increase the effectiveness of planning and preparedness efforts. Gathering lessons learned from various site managers, performing site regulatory gap analyses, and implementing new proven concepts will ensure the best possible functionality and processes within a program.

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4. Standardize response methods: A consistent, company-wide emergency response management system can deliver site-specific details and management endorsed response processes.  Standardization allows employees and responders to conceptualize their roles and responsibilities across an enterprise, creating a common understanding of intended actions. Consistent, yet site specific response methods can assist responders in assessing, prioritizing, and responding to incidents.

5. Improve asset utilization: Companies should utilize employees, responders, equipment, and budgets effectively in order to minimize the effects of a crisis or disaster. Realigning current tangible assets (equipment and/or personnel), mitigating identified inefficiencies, and/or budgeting for additional response training or improved equipment will improve the overall effectiveness of an emergency management program.

6. Mitigate facility/site conditions: The conditions of your facility or site may have an impact on safety or an effective response. Conditions that pose a risk to occupants, the environment, infrastructures, and/or the surrounding communities should be altered or eliminated. The risk assessment process can be used to identify conditions that can lead to emergency incidents.

7. Reduce incidents through risk assessments: When potential threats and risks are identified, measures can be taken to minimize the impacts of those scenarios or possibly eliminate the potential of the emergency. Mitigation measures may include a variety of tactics including, but not limited to training for employees, updating safety processes and procedures, or securing or purchasing updated equipment.

8. Reduce downtime: Emergencies can cause operational downtime and production loss. This impact profits and reduces revenues. By optimizing and implementing the most effective and functional emergency management program possible, incidents can be promptly managed and rapidly demobilized, thereby reducing response-related costs and downtime.  The repercussions from an incident can also include detrimental relationships with customers, the surrounding community, and stakeholders.

9. Cost savings: Proactive compliance efforts, safety initiatives, training and exercises, and response and resiliency planning are typically less expensive than regulatory fines, sustained response efforts, and overall repercussions resulting from an incident.

10.Elevate training and drills: Employee training, emergency response drills and applicable exercises identify deficiencies in emergency response planning programs. Incorporating appropriate response training and testing response plans with detailed scenarios will improve response capabilities and coordination, as well as reduce response times.

 

Simplifying the Complexity of Response Plans:  The TRP Approach

Tags: Emergency Management Program, Emergency Response Planning

Key Preparedness and Response Planning Tips for Downstream Industries

Posted on Thu, Jan 21, 2016

According to Modalpoint, one of the “Top 10 Oil and Gas Business Drivers for 2016” will be in the downstream sector. With increased supply driving the downstream industry, certain refineries, petrochemical plants, petroleum products distributors, retail outlets and natural gas distribution companies should ensure EHS preparedness and response programs are up-to-date, effective, and compliant.

Plan deficiencies and non-compliance has proven to be expensive, time-consuming, and potentially dangerous to employees and the surrounding communities. As a result, maximizing the effectiveness of response plans and preparedness programs should be viewed as an investment in its workforce and the sustainability of the company, rather than as a subordinate expense.

By systematically analyzing operational risks and hazards, and aligning emergency plans with corresponding regulations, emergencies, crises, and targeted non-compliance fines can be minimized. The following are key preparedness and response tips to consider in the continual effort to improve a response planning program:

Data Accuracy: Establishing readily available up-to-date information has been proven to limit the duration of the emergency. The faster responders can locate, assess, access and implement accurate response actions to mitigate the emergency, the sooner an incident can be contained, and operations can be restored to “business as usual”.

Training: Training programs that include properly trained personnel, guidance, documentation, and oversight help ensure compliance with agency regulations. These regulatory requirements are designed to prevent harm and ensure adequate responses to protect the public. However, companies should not rely on regulatory training requirements and agency inspections to ensure training programs are sufficient. Companies should perform internal training to create corporate assurance, enhance EHS program value, improve operational safety, and ideally prevent harmful incidents from occurring.

Exercises: Realistic exercise scenarios can often highlight potential deficiencies and failures in the response plan and procedures, comprehension of individual roles and responsibilities, and partnership coordination. Identified deficiencies often reveal mitigation opportunities and valuable response knowledge.

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Accessibility: Web-based response plans offer the greatest secured accessibility option for stakeholders, auditors, and inspectors while bolstering an entire emergency management program. With web-based technology and an Internet connection, response planning program information embedded with database driven software can be immediately and securely available without the “version confusion” typically found in other formats. 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.

Collaboration: Response planning program effectiveness can be optimized through effective interoperability: the ability for diverse organizations to work together for a greater good. Broadening the scope of response expertise can greatly benefit a facility by limiting the timeline of potentially escalating emergencies. Local agencies may provide additional response knowledge based on particular research, experiences, or occupational training in a particular area of study.

Auditing: Audits, whether conducted by in-house professionals or experienced consultants, can often reveal the same inadequacies and mitigation opportunities as regulatory agencies. Regrettably, most companies address response plan gaps only after an incident or a financially-impacting inspection occurs. With an objective eye, a gap analysis generated by an audit can bolster an response planning program and minimize the chance of impeding incidents or budget-crippling regulatory fines.

Mitigation: While all risks cannot not be averted, a facility can become better prepared for disasters if the procedural risk mitigation measures are implemented. Adverse conditions, unsafe activities, or ineffective responses pose risks to occupants, facilities, the environment, and/or communities. The risk assessment process can be used to identify situations that may lead to incidents or prolong a response. By eliminating or mitigating risks, companies can reduce the potential for emergency situations.

Best Practices Implementation: Applying best practices to a response planning program enables emergency managers to leverage past experiences as a means to improve planning efforts for future emergency response scenarios. By analyzing past incidents and responses, executing enhancements, and reinforcing lessons learned, companies will be better prepared than their historical counterparts.

Regulatory Compliance with TRP Corp

Tags: Emergency Management Program

Business Continuity Planning Until Infrastructure Resilience Secured

Posted on Wed, May 13, 2015

For the power, oil, and natural gas industries, a growing array of physical and electronic threats, coupled with decaying infrastructures and strained budgets is a recipe for disaster. Over the past few years, countless broadcasts of threats, risks, and actual incidents have been reported. From computer system hackings to gas pipeline failures, the energy industry is under continuous pressure to preserve and upgrade the resiliency of our critical infrastructures. However, until resilience is secured and infrastructures have been upgraded, companies must continue to prioritize safety and preparedness best practices.

Reliable operations are crucial to the economic stability of companies, communities, and commerce. There has been a surge by public and private stakeholders to identify steps to improve the cyber resilience of computer-based systems that manage operational processes in the power, oil, and natural gas industries. These industries are also keenly aware of the inherited deteriorating infrastructures that support their operations.

Until effective, sustainable policies, regulatory compliance initiatives, and corporate budgets embrace widespread modernization and effectively mitigate for infrastructure resilience, companies should ensure emergency management programs and business continuity plans are current and effective. In an effort to maximize preparedness and minimize inherent risks, an emergency management program should provide:

  • A system for assessing and prioritizing incidents
  • Streamlined and standardized response methods
  • Communication and notification procedures
  • Roles and responsibilities for corporate and incident level response teams
  • Optimized training, drills and exercises
  • A demonstrated commitment to safety

According to experts, the maze of infrastructure that support the energy industries and end users requires extensive upgrades to effectively meet the nation’s energy demands. Ensuring the resilience, reliability, safety, and security of energy transmission, storage, and distribution (TS&D) infrastructure is vital.

According to the Quadrennial Energy Review (QER), the TS&D, “includes approximately 2.6 million miles of interstate and intrastate pipelines; 414 natural gas storage facilities; 330 ports handling crude petroleum and refined petroleum products; and more than 140,000 miles of railways that handle crude petroleum, refined petroleum products, LNG and coal.”

The QER was developed to identify the threats, risks, and opportunities for U.S. energy and climate security. The goal of the review is to enable the federal government to translate policy goals into a set of integrated actions. In April 2015, the QER recommended the following actions:

  • Establish a competitive program to accelerate pipeline replacement and enhance maintenance programs for natural gas distribution systems. The Department of Energy should establish a program to provide financial assistance to:
    • Incentivize cost-effective improvements in the safety and environmental performance of natural gas distribution systems
    • Enhance direct inspection and maintenance programs
  • Update and expand state energy assurance plans. The Department of Energy should establish a program to provide financial assistance to:
    • Improve the capacity of states and localities to identify potential energy disruptions, quantify their impacts, share information, and develop and exercise comprehensive plans that respond to those disruptions and reduce the threat of future disruptions.
    • Establish a competitive grant program to promote innovative solutions to enhance energy infrastructure resilience, reliability, and security.

Facility and supply chain management should be a crucial aspect of business continuity planning. At a minimum, the following planning considerations should be taken into account in order to safeguard critical operations:

  • Establish preventive inspection and maintenance schedules for all systems and equipment. 
  • Ensure that key safety and maintenance personnel are thoroughly familiar with all building systems, such as alarms, utility shutoffs, elevators, etc.
  • Establish company-wide computer security, download, and backup practices in order to secure technologies and communications networks.
  • Determine the impact of service disruptions and mitigate if possible (generators, fuel, relocating inventory, back up suppliers etc.) 
  • Establish procedures for restoring systems. 

NOTE: The April 2015 QAR can be read in its entirety here.

Preparedness and Emergency Management - TRP Corp

Tags: Business Continuity, Resiliency, Emergency Management Program

MITIGATION: The Ever-Present Emergency Management Tool

Posted on Thu, Apr 02, 2015

Effective mitigation can often prevent emergencies or minimize their impacts. Mitigation requires a thorough understanding of the potential risks, procedures, regulatory compliance, lessons learned, and operational goals. It is often difficult to quantify and financially justify preparedness mitigation initiatives, however, taking action in the present can often reduce human, environments, and financial consequences in the future.

It is often impractical for companies to spend relentlessly on emergency management mitigation efforts. Operations must remain profitable and margins maintained for corporate viability. Despite that a disaster can strike at any time, potential human, environmental, and financial impacts are often difficult to predict. For optimal financial benefit, mitigation efforts should meet certain key operational and response objectives. Ideally, mitigation efforts should eliminate or lessen the strategic cost of an incident, and reduce the tactical effort of regulatory compliance. Mitigation efforts should, at a minimum:

  • Reduce the likelihood of incidents
  • Improve the ability to respond to incidents
  • Improve the casualty and harm conditions through faster rescues and accident avoidance
  • Strengthen infrastructure against failure
  • Improve corporate reputation through intent and safety investment
  • Reduce projected downtime
  • Improve asset utilization
  • Solidify supply chain availability

Disaster preparedness mitigation measures should also be integrated into corporate and site-specific response planning and corporate preparedness initiatives.  Incorporating upgraded communication methods, technologies, response procedures, and lessons learned can improve the overall functionality of response plans. Response planning mitigation measures may include, but are not limited to:

  • Automating response planning through tracking, updating, and management
  • Facilitating the ability to update plans across locations, sites, rigs, geographies through updated technology
  • Automating regulatory compliance components and response planning activities
  • Reducing the compliance and safety resource consumption
  • Enabling HSE departments, emergency managers, and compliance specialists to spend less time on administrative duties, maintaining plans, reviewing compliance, and reporting
  • Automating governance and controls
  • Optimizing and coordinating drills, testing, and actual emergency responses

Identifying and prioritizing mitigation efforts can be challenging. Below are a series of discussion provoking questions that can assist in mitigation assessments. Although not industry specific, these points may identify which areas of preparedness should be mitigated in order to ensure best emergency management practices are in place (NOTE: These suggested discussion points do not address all mandated planning requirements. Please refer to your operations-specific requirements to ensure regulatory compliance.)

Risk Assessment

  • What are the current high-risk activities at the location?
  • Can high-risk tasks or conditions be mitigated? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Have sensitive areas been identified and potential consequences been assessed?
  • Did risk assessment utilize realistic scenarios to define spill and release volumes and locations?
  • Are employees made aware of hazards associated with specific workplace process, materials, or location(s)?

Compliance

  • What agencies and specific regulations apply to my location(s)?
  • If applicable, have safety data sheets (SDSs) been updated per operations and properties included in the planning process?
  • Have inspections taken place or regulatory audits been performed? If so, have non-compliant issues been mitigated?
  • When will an internal compliance audit(s) be conducted and how will findings be prioritized for mitigation?
  • Is personnel training up-to-date and compliant with site-specific requirements?

Response Elements

  • Are clear procedures in place to notify, assess, and initiate a response?
  • Are individual responders and their contact information verified for accuracy?
  • Can approved stakeholders easily access response plans?
  • Have response times and limitations been identified?
  • Do response elements address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been identified in the plan, and are they accurate?
  • Are communications backup systems available and described in the plan?
  • Are staff roles and responsibilities current, specific, and communicated?
  • Have “best practice” strategies and response procedures been identified and implemented?
  • Are processes and procedures identified in the plan to assess and monitor size, shape, type, location, and movement of a spill or release?
  • If applicable, have tactical response details been included and verified for incidents that expand beyond the confines of the facility?
  • If applicable, do spill trajectory estimates and maps mimic current local observations, potential weather scenarios, and historical tendencies?
  • Have sensitive areas been identified and prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes accurate and communicated?

Documentation

  • Have processes been established for updating planning information?
  • Have updated plot plans and area mapping been integrated with accurate GIS data?
  • Are contracts, memorandums of understanding (MOUs), and other appropriate agreements and documentation in place?
  • Has exercise feedback/lessons learned been incorporated into plan revisions?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible?
  • Are necessary Incident Command (ICS) forms and company paperwork readily available for response documentation?

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Management, Emergency Management Program, Mitigation

Falling Oil Prices Should Not Compromise Compliance and Response Planning

Posted on Thu, Jan 15, 2015

After nearly five years of stability, crude oil prices have dropped over 50% in recent weeks.  According to the “Global 2015 E&P Spending Outlook”, exploration and production spending by North American Oil and Gas companies could drop 30% in 2015, affecting budgets across the industry.1 However, despite potential budget restructuring, oil and gas companies should not sacrifice regulatory compliance and safety for profitability.  Environmental, health, and safety programs must be viewed as an investment in the sustainability of a company, rather than as a subordinate expense.

Profitability, shareholder value, and cost control measures may initiate management to implement cost control measures. Regulatory compliance and response planning initiatives are often sacrificed during this process. However, the reality is that one emergency or crisis situation occurring because of noncompliance, or prolonged due to ineffective responses can cost a company many times the cost of implementing and maintaining an effective program.

In order for the oil and gas industry to continue to be one of the safest operating industrial sectors in the United States, the industry must continue to audit, test, and update preparedness endeavors and response capabilities. In the face of decreasing profits, many HSE programs involved in oil and gas, refining, petrochemical, manufacturing, and others, will encounter challenging operational environments and cost cutting initiatives. But in addition to fulfilling a moral responsibility to protect employees, the community, and the environment, an effective and exercised emergency management program must be prioritized in order to meet certain key strategic and tactical objectives. These include, but are not limited to:

  • Facilitating compliance with Federal, State, and Local regulatory requirements, eliminating the threat of potential fines.
  • Reducing property damage (ex. buildings, contents, pipelines)
  • Enhancing the ability to recover from business interruption and loss (ex. damaged industrial, commercial, and retail facilities)
  • Reducing indirect business interruption loss (ex. supply chain “ripple” effects)
  • Reducing environmental damage (ex. wetlands, parks, wildlife)
  • Enhancing a company’s image and credibility with employees, customers, suppliers and the community.
  • Reducing other nonmarket damage (ex. historic sites, schools, neighborhoods)
  • Minimizing societal losses (ex. casualties, injuries, layoffs)
  • Reducing need for emergency response (ex. ambulance service, fire protection).
  • Reducing exposure to civil or criminal liability in the event of an incident.
  • Potentially reducing insurance premiums (check with individual insurance providers for associated savings).

The emergency response and crisis management planning investment becomes much more strategic when considering of the total cost of actual emergencies and incidents. In business, these terms and financial impacts are not discussed often, but emergency response and incidents have some of the gravest and most serious moral consequences regarding humanity and the environment. When an emergency can be prevented from escalation and/or affecting the lives of employees, communities, or the environment, a company must make every effort to prevent harm.

If government regulations are applicable to operations, companies must prioritize regulatory compliance in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations. The increasing number of stringent regulatory compliance standards compounds the complexity of sliding oil prices and cost-cutting operations. Most companies believe they have the regulatory compliance component of their business under control. However, agencies such as OSHA, EPA, and DOT, continue to inspect and fine companies for non-compliance for a variety of infractions. 

Companies can reduce overall costs associated with HSE programs by easing day-to day administrative processes, ensuring regulatory compliance, and implementing and maintaining effective response capabilities. Streamlining these efforts with enterprise-wide, web-based response planning technology and best practices formats can reduce overall costs associated with variegated plans and processes across multiple locations.

  1. Dittrick, Paula. Barclays Sees Likely Downside to North American E&P Budgets. Oil and Gas Journal. January 9, 2015.

Regulatory Compliance with TRP Corp

Tags: Regulatory Compliance, Emergency Management Program, Emergency Response Planning

TRP's Top 10 Preparedness Blogs of 2014

Posted on Tue, Dec 30, 2014

As TRP Corp. gets ready to begin its 20th anniversary year, we would like to share our subscribers’’ “Top Ten” blogs from 2014.  While the topics vary, the goal of each blog is to provide a resourceful, informative article that guides professionals in developing effective emergency, crisis, and business continuity plans. We hope emergency managers, first responders, and safety professionals can utilize these blogs to advance emergency management, preparedness initiatives, and business continuity efforts in 2015.

Our “Top Ten” 2014 blog articles Include:

10. Preparedness, Planning, and Pandemic Plans 

Published prior to the onset of the well-publicized Ebola outbreak, this blog highlights the evidence for the need of pandemic planning and the pandemic response plan.

9. The Business Impact Analysis: A Step Towards Business Continuity 

While the size and complexity of essential business elements required for sustainability varies among industries, companies, and specific facilities, the ability to quantify and prioritize critical work flow components is a key business continuity element. This blog highlights examples of which critical business functions to analyze, and the specific components of the Business Impact Analysis.

8. Incident Response Drills and Tabletop Exercises 

Every drill or exercise presents the opportunity to improve site-specific response plans, rendering the potential for a more effective response. This blog examines the three most popular types of response exercises and details tabletop exercise planning considerations that can aid in improving preparedness levels.

7. Consultants Combat Emergency Management Challenges: Oil and Gas Industry 

Despite safety statistics, the oil and gas industry’s public safety perception has been tested by highly publicized tragic incidents, increasing the pressures on emergency managers. This blog highlights some of the challenges felt by oil and gas emergency managers, and breaks down the strategic and tactical cost-benefits of hiring specialized, reputable consultants.

6. 7 Key Points for Industrial Business Continuity and Disaster Recovery 

Companies often lack adequate recovery planning and recuperative procedures to restore critical information, essential processes, and normal business operations within an acceptable recovery time frame. This popular blog identifies seven elements that can accelerate the business continuity recovery process.

 5. Ten Reasons for Companies to Invest in Incident Management Programs 

Implementing a technologically advanced, enterprise-wide incident management system offers opportunities to increase the effectiveness of preparedness efforts with “real-time” response advantages. This blog highlights ten “best practice” reasons why companies should prioritize these programs, and advance preparedness initiatives and associated response programs.

4. Corporate Emergency Preparedness and Risk Management 

Companies that prioritize risk management and integrated preparedness goals are better prepared to educate employees on potential incidents, and their role in prevention, mitigation, response, and recovery. This popular blog highlights four “best practice” processes and prevention measures that should be included in your risk management program.

 

With carefully planned tabletop exercises, mitigation opportunities and valuable response knowledge can be revealed. Realistic exercise scenarios can often highlight potential deficiencies in response plans, individual comprehension of response roles and responsibilities, and partnership coordination efforts. This blog highlights the various types of tabletop scenarios that can be utilized to strengthen preparedness efforts and bolster your emergency management or HSE program.

2. A Lesson in Emergency Preparedness: Learn from Past Incidents 

Emergency managers should not camouflage preparedness or response failures. On the contrary, they should draw from scenario experiences and response lapses to improve their emergency management program. This blog highlights the importance of the evolution process within response planning and emergency management, and offers a series of questions that may aid in identifying plan deficiencies and mitigation opportunities.

1. Fire Pre Plan Templates: How to Make Them Work for You! 

An enterprise-wide fire pre plan template can serve as an outline of required fire response related information, yet they must be populated with site-specific details. TRP’s top blog of 2014 highlights specific elements that should be included in a fire pre plan, despite the response situation or circumstance. The blog also provides insightful fire pre plan “helpful hints” from various first responders and fire departments.

For more information regarding web-based, database driven planning systems, contact TRP at (281) 955-9600, or click the image below to set up a personalized demonstration.

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Tags: Emergency Management, Emergency Management Program

What your Employees Need to Know About Emergency Response?

Posted on Thu, Dec 11, 2014

General emergency response training should be conducted for all site workers with industrial facilities. This preparedness training should provide employees with basic response knowledge so that they can perform defensive actions in the event of an emergency. Unless employees are specifically trained and qualified in more advanced hazardous spill response techniques, the typical employee’s trained response or function is to contain a release from a safe distance, keep it from spreading, and prevent exposures.

General Emergency Training

This general training should familiarize employees with site-specific emergency procedures, equipment, and systems. Covered topics should include, but are not limited to:

  • Incident reporting
  • Instruction and procedures for using personal protective and emergency equipment.
  • Evacuation and alarm procedures.
  • Specific roles and responsibilities in response to fires and explosions.
  • An understanding of the role of the first responder in an emergency.
  • Safe use of engineering controls and equipment.

 

Specialized Response Training

Advanced specialized training programs typically include detailed course instruction and regulatory agency certifications.  An operational hazard or site-specific coordinated program often consist of classroom or online instruction, drills, and exercises. Specialized training may include, but is not limited to:

  • Basic hazard and risk assessment techniques.
  • Selection and use of proper personal protective equipment.
  • Basic control, containment and/or confinement operations within the capabilities of the resources available.
  • Relevant standard operating procedures and termination procedures.
  • Principles of the Incident Command System.
  • First Responder Operations Level.
  • Hazardous Materials Incident Commander.

Retraining, or refresher courses, should be conducted for both general and specialized training requirements at a minimum of every 12 months or when certification requirements state. At a minimum, annual refresher training should cover current industry and in-house emergency operating experience, as well as changes in emergency operations plans, policies, procedures, and equipment. Additionally, annual training can highlight weaknesses identified through employee feedback and review of the program, drills, and exercises.

Hazardous_Waste_Response_Training.jpg

Federal OSHA HAZWOPER training requirements apply to “General site workers (such as equipment operators, general laborers and supervisory personnel) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards” (per 29 CFR 1910.120(e)(3)(i) for general industry and 29 CFR 1926.65(e)(3)(i) for construction).  These individuals must receive a minimum of 40 hours of instruction, either in a classroom or online, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor.

According to OSHA, trainees must become familiar with standard and site specific safety processes and applicable response equipment in a non-hazardous setting. To ensure compliance, companies should verify that appropriate and thorough hands-on training is being conducted in conjunction with any online or classroom instruction.

Online Response Training Programs

As web-based technologies become more accessible and mobile, different options for online training programs have evolved. These flexible training portals can be used as an intricate tool in the context of an overall training program. Online training is often in conjunction with additional site training. However, it is critical that trainees have the opportunity and mechanism to clarify unfamiliar information in order to become proficient. A computer-based training program should include access to a telephone hotline or an e-mail contact at the time the training is being conducted so that trainees will have direct access to a qualified trainer at the time their questions are raised.

To ensure online training programs are accomplishing its goals, companies should develop methods of training evaluations. OSHA recommends the following:

  • Questionnaires or informal discussions with employees can help employers determine the relevance and appropriateness of the training program.
  • Supervisors' observations. Supervisors are in good positions to observe an employee's performance both before and after the training and note improvements or changes. Drills and exercises should be routinely conducted to confirm response proficiency and specific training knowledge
  • Workplace improvements. The ultimate success of a training program may be changes in processes, procedures, or equipment that result in reduced injury or accident rates.

For free tips on conducting an effective exercise, click here or the image below:

TRP Corp Emergency Response Planning Exercises

 

Tags: Training and Exercises, Emergency Management Program, Emergency Response Planning

Maintaining Regulatory Compliance in an Oil Industry Acquisition

Posted on Thu, Oct 30, 2014

Oil companies are not stagnant entities.  Every year, the industry experiences acquisitions, mergers, and systemic transformations. The dynamic nature of the energy sector requires environmental, health, and safety departments, as well as facility managers, to periodically review and adjust their approach to emergency management and regulatory compliance.

Whether a facility is located in the U.S. or abroad, ensuring compliance, employee safety, and an effective response requires a streamlined, coordinated, and exercised response plan. All response plans, including SPCC's and facility response plans, within the corporate enterprise should address site-specific facility details, applicable and tested response processes, and standardized company-wide best practices while maintaining location-specific regulatory compliance. A customizable response plan template can enable the development of a streamlined, site-specific preparedness program that consistently delivers company-standard guidelines and practices while providing a medium for rapid assimilation of merging or acquired facilities.

Industrial operations are required by law to institute site-specific emergency response plans, and train employees according to their response roles and pertinent response methods. Acquiring one or more new facilities typically presents challenges that generic or static response plan templates do not account for. Failure to incorporate site-specific details may result in incomplete, ineffective, and costly non-compliant plans.  Companies with multi-facility operations should utilize a customizable template with the ability to inject distinct facility information and hazards for each operation, pre-approved company best practices, as well as applicable local, state, and federal requirements.

Integrating response plans under one centralized format enables consolidated preparedness and response objectives. Acquired facilities must be absorbed into the company-wide emergency management program. If response plans exist, companies should perform a gap analysis or audit to identify any procedural, company policy, or compliance deficiencies that may be applicable to the new facilities. It is critical to define preparedness objectives, response roles, and responsibilities in order to eliminate ambiguity and confusion.  Responsible parties must apply new data, site assessments, and validated information into cohesive, compliant, and effective response plans for the new enterprise.

New or outlying facilities may present preparedness and response challenges. Cultural differences, infrastructure challenges, response equipment availability, minimal response knowledge and training, and security priorities may require heighten preparedness priorities and planning efforts. As a result, new locations may be particularly vulnerable to crisis or emergency response situations.

Regulatory compliance - TRP Corp

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

Who will be in charge of the response and how will it be organized?

  • Identify Incident Commander
  • Create Emergency Management Team organizational chart
  • Identify Emergency Management Team activation measures
  • Create Emergency Management Team roles and responsibilities checklists

Does the facility have a current response plan to draw from?

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

What threats affect the new facility and its employees?

  • Perform a detailed hazard and risk analysis
  • Verify or create response procedures for each identified threat
  • Identify process for incident documentation
  • Utilize appropriate ICS Forms
  • Identify current and necessary equipment necessary for response

What regulatory requirements apply to this facility?

  • Evaluate operations for compliance
  • Identify required training and confirm documentation
  • Review submitted response plan information
  • Perform a compliance audit

If necessary, what organization will conduct additional response duties?

  • Identify response capabilities and determine if additional resources are necessary
  • Initiate a Memorandum of Understanding or contract specific response needs
  • Confirm contact information, availability, and response times

How will the emergency be reported and response initiated?

  • Create site-specific notification procedures
  • Identify site-specific alarms that signal employee evacuation or shelter in place.
  • Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in alarm procedures and immediate response actions per designated roles and responsibilities
  • Implement company approved emergency classification levels to associated response procedures with emergency conditions to prevent the incident from escalating

What incidents or classification level require evacuation/shelter in place

  • Establish multiple evacuation routes.
  • Does the evacuation go beyond facility borders?
  • Identify the muster point(s) and head count procedures?

How are response actions sustained?

  • Establish command post location
  • Identify internal and external response resources and equipment for a sustained response
  • Share response plan with appropriate responders/stakeholders
For a free Audit Preparedness Guide, click the image below:
Regulatory Compliance with TRP Corp
TRP offers a variety of free resources at http://www.emergency-response-planning.com/downloads/

Tags: Facility Response Plan, SPCC, Oil Spill, Emergency Management Program

SPCC Planning and Regulatory Compliance Inspections

Posted on Thu, Oct 16, 2014

The challenge of managing and ensuring compliance of Spill Prevention, Control and Countermeasure (SPCC) plans for multiple facilities can be complex. Detailed government inspections, enforcement mandates, costly non-compliance fines, and negative publicity may result from the lack of implemented, site-specific, and up-to-date plans. By utilizing available technology to manage multiple SPCC plans, companies can verify compliance through a cohesive, yet site-specific, standardization of best practices.

For facilities with aboveground storage tank capacities exceeding 1,320 gallons or underground tanks with capacities above 42,000 gallons, Environmental Protection Agency (EPA) compliance requires accurate and up-to-date SPCC plans. A professional engineer must certify SPCC plans if your facilities have more than 10,000 gallons of aboveground oil storage capacity.

Maintaining SPCC compliance requires preparing plans that outline facility-specific spill prevention procedures, associated equipment to prevent spills from occurring, and countermeasures to address the effects of potential oil spills on sensitive environments. For organizations that have many facilities, web-based response planning provides seamless integration of approved enterprise-wide procedures and policies with site-specific, SPCC required information. This optimizes the potential for every location to remain in compliance with SPCC regulations.

Since 1973, the EPA has conducted scheduled or unannounced facility inspections to ensure that facilities identify site-specific practices related to the storage and management of oil and oil tanks, and response procedures in the event of an oil spill. According to the EPA, the SPCC Inspections serve two primary functions:

  1. To ensure that oil storage facilities, refineries, electrical utilities and oil production fields, among other subject industries, are in compliance with 40 Code of Federal Regulations (CFR) part 112.
  2. To give U.S. Environmental Protection Agency representatives the opportunity to educate owners and operators about the regulations and ways to ensure compliance.

SPCC TRP Corp

In order to meet SPCC regulatory requirements, every applicable facility in your organization is required to regularly update and maintain SPCC plans per EPA regulation 40 CFR 112.20. The following is an abbreviated checklist of SPCC associated planning elements that EPA representatives may evaluate during facility inspections:

  • Storage tanks and other equipment containing oil
  • Storage tank integrity testing requirements
  • Truck loading/unloading areas
  • Transfer procedures and equipment (including piping)
  • Facility layout and diagram
  • Drainage patterns and oil discharge predictions
  • Secondary containment or diversionary structures and their ability to contain a release of oil
  • Site security measures
  • Operating procedures
  • Personnel training and oil discharge prevention briefings
  • Plan certification (by a Professional Engineer (PE) or in certain cases by the facility owner/operator)
  • Recordkeeping

Since the prevention and countermeasures identified in SPCC plans must be implemented throughout the facility in order to be in compliance with regulations, a copy of your SPCC plans must be available to inspectors for reference at all times. In addition, it is essential to provide inspectors with relevant documentation of all operating and inspection procedures, spill prevention measures, training records and other compliance verification information.

With a comprehensive, web-based, database-driven SPCC plan management system, emergency managers and health, environmental, and safety departments can:

  1. Simplify audits
  2. Easily identify required information
  3. Verify accuracy of plan contents through secured access
  4. Revise information in real-time, as necessary
  5. Identify regulatory compliance gaps
  6. Account for necessary mitigation endeavors
  7. Ease maintenance and administrative efforts
  8. Provide electronic copies of plans to government agencies

Proactive responsive, procedural, and preparedness measures, in conjunction with innovative planning system technologies can maximize compliance efforts and minimize accidents and catastrophes. Transitioning to a web-based system to maintain SPCC plans can enhance accessibility, portability, and redundancy, potentially easing communication barriers with responders and regulatory audits.

For a free download entitled, "The Facility Response Plan and the Spill Prevention, Control, and Countermeasure Plan", click here or the image below:

TRP - SPCC and FRP

Tags: SPCC, EPA, Regulatory Compliance, Facility Management, Emergency Management Program

How to Maximize Corporate Emergency Preparedness for the Unpredictable

Posted on Thu, Oct 02, 2014

Planning for the unpredictable is part of emergency preparedness. Whether preparedness is mandated by corporate policy or regulatory agencies, risk management in cooperation with widely accessible emergency response plans can maximize efficiency and minimize the impacts on employees, the environment, and infrastructure. However, efforts to prepare for, manage, or mitigate risks are often unexecuted, shelved by constrained resources, profit margins, politics, or alternative goals.

In an effort to maximize preparedness and minimize inherent risks, corporate emergency management should provide:

  • A system for assessing and prioritizing incidents
  • Streamlined and standardized response methods
  • Communication and notification procedures
  • Roles and responsibilities for corporate and incident level response teams
  • Optimized training, drills and exercises
  • A demonstrated commitment to safety

By prioritizing an emergency management program, a company demonstrates the foresight to address emergency situations and associated challenges, and proactively affirms its efforts to ensure the safety of employees, the environment, and the surrounding communities. However, in order to maximize safety and plan for inherent emergency situations, site-specific threats and risks must be identified, assessed, mitigated, and planned for.

To manage workplace risks, each facility should be analyzed for potential hazards. These threats to operational status quo may be present in the form of unsafe acts and/or unsafe conditions. Once risks are recognized and evaluated, they should be eliminated if possible, or controlled through procedural planning. A risk management program should include, but not be limited to the following processes and prevention program.

RISK RECOGNITION:

  • Risk recognition can occur through inspections, audits, and job hazard analysis
  • All levels of management should take interest in their company’s risk management program
  • Each manager should establish realistic goals for risk reduction and prevention within their area of responsibility
  • Consult with local or online sources that have pre-identified risks based on site operations and location.

RISK EVALUATION:

  • Evaluate accident probability for each process, procedure, and handled material and resulting level of potential severity if an accident were to occur
  • Evaluation should take into account the time, place, and conditions in which threats or hazards might occur
  • The probability and severity of a risk should determine the priority level for correcting the hazard. The higher the probability and severity of risk, the higher the emphasis should be on corrective action

Business_Continuity_Plan_TRP.jpg

RISK ELIMINATION or RISK CONTROL

  • Targeted effort should be made to isolate and eliminate the root cause
  • Realized mitigation opportunities may reduce the amount of response resources required in the event of an incident
  • If root cause cannot be eliminated, changes in process and procedure should be made in order to reduce risk:
    • Implement risk reducing engineering controls, when applicable
    • Implement proactive administrative controls or work place practices
    • Establish process to identify inoperable or malfunctioning equipment and machinery through systematic inspections
    • Establish processes to minimize the effects of naturally occurring hazards
    • Ensure control does not hinder regulatory compliance

RISK COMMUNICATION:

  • Apply the results of analysis through planning and exercises. Employees should be made aware of hazards associated with any workplace process, materials, or location.
  • Accident prevention signs should be posted to remind occupants of the presence of hazards
  • Establish and communicate emergency response plans to employees and appropriate emergency response teams. This includes up to date contact information and notification procedures
  • Calculate, specify, and communicate resource requirements and operational capacities for each targeted scenario to internal and external responders
  • Counteract onsite response deficiencies for each scenario by implementing coordinated interoperability communication

Understanding your company’s risks, from the facility to the corporate level, is essential to preparedness and sustainability. Companies that prioritize risk management and integrate preparedness goals are better prepared to educate employees on potential incidents, and their role in protection, prevention, mitigation, response, and recovery.

Auditing your current program is crucial. Click here, or the image below, to download a free Audit Preparedness Guide:

Regulatory Compliance with TRP Corp

Tags: BCM Standards, Emergency Management, Emergency Preparedness, Business Risk, Emergency Management Program, Hazard Identification