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Ten Reasons for Companies to Invest in Incident Management Programs

Posted on Thu, Sep 25, 2014

Incident Management programs shouldn’t be created for IF an incident happens...but for WHEN an incident happens.

Regulatory compliance mandates, a history of incidents, or an awareness of potential crises typically trigger companies to fund preparedness initiatives. At a minimum, preparedness endeavors and response capabilities should be audited, tested, and updated on an annual basis. Budgeting efforts should be aligned with initiatives in an effort to improve incident management and preparedness capabilities.  Below are ten “best practice” reasons why companies should prioritize funding to advance preparedness initiatives and associated response programs:

#10. Streamline and standardize improved 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. Streamlining response methods can assist responders in assessing, prioritizing, and responding to incidents.

#9. Optimize drills and training: 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.

#8 Improve regulatory compliance: Costly non-compliance fines result from the lack of implemented, thorough, and compliant programs. By systematically aligning response plans and their components with corresponding regulations, companies can identify and amend plan deficiencies that may result in fines and potential government mandated shutdowns.

#7. Simplify and automate response plans: Maintaining response plan can be an administratively taxing endeavor. Continual administrative duties associated with personnel contact information, assignments, training records, exercises, and continual plan updates may be inadequate to sustain an optimal program. Maximizing efficiency through advancements in technology can minimize time associated with maintaining incident response plans.

#6. Improve asset utilization: Companies must 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 current inefficiencies, and/or budgeting for additional response training or improved equipment will improve the overall effectiveness of an emergency management program.

#5. Demonstrate a commitment to safety:  Companies should proactively affirm the safety of employees and surrounding communities, and protection of the environment, by establishing proven countermeasures to potential threats and associated risks. Prioritizing emergency preparedness initiatives demonstrates a company’s commitment.

#4. Improve conditions:  Harmful conditions pose a risk to occupants, the environment, infrastructures, and/or the surrounding communities. By eliminating or mitigating potentially adverse conditions, unsafe activities, or ineffective responses, companies can reduce the potential for and effect of emergency situations. The risk assessment process can be used to identify potential threats or harmful conditions that can lead to incidents.

#3. Reduce Incidents:  By identifying potential threats and risks, mitigation and preventative measures can be taken to curtail the likelihood of an incident from occurring or reduce its impacts. 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.

#2. Reduce downtime:  Operational downtime and production loss reduces revenues. By optimizing and implementing the most effective and functional incident management program possible, incidents can be promptly managed and rapidly demobilized, thereby reducing response-related costs and downtime.  The repercussions from an incident can include detrimental relationships with customers, the surrounding community, and stakeholders.

#1. 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.

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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Tags: Emergency Management, Emergency Preparedness, Response Plans, Incident Management, Training and Exercises, Emergency Management Program

Renovating the Framework of Emergency Management and Incident Response

Posted on Tue, Aug 26, 2014

The modernization of communication technologies has trickled down to the frameworks of emergency management. On July 29, 2014, the 'White House Innovation for Disaster Response and Recovery Demo Day” brought together the disaster response community and innovative entrepreneurs from across the country in the hopes of integrating technological advances with preparedness and disaster response efforts.

As the connectivity of the world increases, EHS programs and emergency managers are embracing collaborative and innovative preparedness and response initiatives. However, in order to germinate or sustain an ongoing culture of preparedness, companies must prioritize funding to incorporate new and relevant systems, training, and/or equipment. Unless mandated by regulatory authorities, many companies delay best practice and technological initiatives until an incident propels response planning to the forefront.

According to the Disaster Recovery Planning Benchmark Survey: 2014 Annual Report, “more than 60% of those who took the survey do not have a fully documented disaster recovery (DR) plan and another 40% admitted that the DR plan they currently have did not prove very useful when it was called on to respond to their worst disaster recovery event or scenario.

As the “Y” or the “Millennial” generation” (those born between 1980’s and 2000) continues to enter the workforce, emerging technologies will become more ingrained into society and the workplace. These educated and tech savvy individuals accustomed to fast-paced technological advancements consider technology as an essential aspect in their lives. Based on current trends, upcoming generations will be acclimated to instantaneous communication and data extraction from any location. Text, social media, and web-based technologies will be expected as commonplace emergency management frameworks, rather than the traditional means that most companies still utilize today. In order to integrate societal norms and stay relevant with upcoming generations of employees, emergency management and disaster response framework must be aligned with currently available utilized tools.

Statistics suggest that every dollar invested in disaster preparedness yields savings of $4–$11 in disaster response, relief, and recovery.” The Harvard Humanitarian Initiative

Just as computers replaced typewriters to expand productivity, web-based response systems are replacing one-dimensional paper-based plans. Web-based response systems offer a greater streamlined functionality, renovated efficiency, and varied accessibility when compared with traditional paper-based plans.  Web-based planning system software offers every option of instant accessibility: viewed via the Internet from any location, downloaded, or printed. Increasing accessibility options while improving efficiency, functionality, and effectiveness can bolster an entire emergency management program.

In order for new functionalities to be introduced to the workplace, emergency managers often are required to justify the initial investment. A cost-benefit analysis of a renovated emergency management program can highlight the potential cost savings of an effective program. Any prevention, mitigation, or plan maintenance costs should be compared with the financial impact of situational recovery processes and the overall costs of an incident. These costs may include, but are not limited to:

  • Human life
  • Short term or long term business interruption
  • Lawsuit(s)
  • Infrastructure damage
  • Equipment failure
  • Inventory/stock losses
  • Fines
  • Reputation
  • Environmental destruction

The relevance of innovative techniques and lessons learned should be continually evaluated and incorporated into an emergency preparedness program if appropriate.  While often suppressed in favor of short-term profits, budgets for pertinent emergency management initiatives should be prioritized for long-term corporate sustainability. But “change for change’s sake” does not typically enhance programs. The evolution process of an emergency management program should aim to perpetuate improved responses and operational recovery times, and enhance company viability despite crisis scenarios.

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Preparedness and Emergency Management - TRP Corp

Tags: Tactical Response Planning, Emergency Management, Resiliency, Incident Management, Emergency Management Program, Communication Plan, Social Media

Oil and Gas: Combating Common Business Continuity Obstacles

Posted on Thu, Jul 24, 2014

A well-developed Business Continuity Plan (BCP) can minimize escalating business disruptions, while safeguarding key business interests, relationships, and assets. Unfortunately, many companies do not acknowledge the value of a BCP and fail to prioritize sustainability. This many be especially true of highly regulated industries, such the oil and gas industry, that prioritize mandated compliance measures.

Below are common obstacles in business continuity planning and possible countermeasures to offset these hurdles.

Lack of management support

It is challenging to perform a cost-benefit analysis that measures the benefits of business continuity. There is a high degree of uncertainty associated with implementing BCP measures. Benefits resulting from BCP and mitigation efforts are dynamic in nature, and are not limited to a single structure, department, or operation.

The financial benefits from a BCP implementation must be viewed from the long-term perspective.  A BCP can dramatically lessen the financial impact of future crises and promote operational sustainability and corporate viability. However, managers and corporate executives typically do not act based on “what if” scenarios unless regulations require implementation. Managerial actions are generally based on concrete financials that benefit departments, stockholders, and the bottom line.  

Countermeasure:2014 Global Risks Report2014 Global Risks Report by The World Economic Forum, makes a compelling case that may provoke and inspires leaders to implement continuity efforts.

Budget restraints

Because companies are in the business of making a profit, business continuity planning budgets are often compromised for other priorities.

Countermeasure: It may be helpful to estimate the cost of implementation for each critical process in relation to the cost of a critical process breakdown.  This exercise may highlight the need for a designated business continuity budget.

It may also be necessary to prioritize BCP implementation by each critical process with a step-by-step timeline for completion. Companies can identify and rank the most critical business processes, and implement BCP and mitigation measures based on those priorities. While most processes are intertwined, taking small steps to ensure process continuity is a step toward overall business continuity. Managers may be more likely to implement a BCP if it can be initiated over time.

Maintaining a culture of preparedness

Unless a company has experienced an eye-opening business continuity issue, the presence of a realistic, tangible threat may be the only protagonist to champion a culture of preparedness.

Countermeasure: Managers who emphasize, embrace, and enact safety and continuity measures, as part of standard operating procedures will create a work environment that reflects the guiding principles preparedness. As preparedness measures and best practices are ingrained in operational processes, personnel will be more apt to embrace the culture

Lack of business continuity awareness and training

When identifying company, operational, and process vulnerabilities, managers and employees frequently recognize the limits of their business continuity expertise. Oil and gas management and employees may have expertise in hazardous response planning measures and tactics, however their business continuity experience may be limited. The process of identifying business continuity mitigation opportunities, developing recovery processes, and training personnel in continuity roles and responsibilities often requires experience. Companies often disregard business continuity training and awareness as a result of ineptitude.

Countermeasure: If implementing continuity efforts are beyond the scope of managers, companies should consider hiring consultants who specialize in business continuity planning. External resources can address site-specific business continuity needs, detailed standard operating procedures for BCP activation, and personnel training. Training should convey procedural flexibility based on continuing assessment of disaster demands and provide options for each scenario. Companies can also assign a designated manager to become proficiently trained in business continuity in order to pass down preparedness guidelines and best practices.

Identifying critical processes:

Many mid to large sized companies often operate with separate, independent business units (or departments). Each critical business process within each unit must be identified and quantified in order to determine its role in the business continuity planning process. Most business unit processes are often intertwined with other critical functions, contributing to the overall profitability of a company. When critical business processes are not functional, a company’s ability to operate and reputation may be in jeopardy.

Countermeasures: Overall resilience capabilities should be prioritized to mitigate any interruption. Understanding response procedures, the interconnected structure of processes between units, and the intricacies of a “Plan B” can make the difference between corporate survival or failure. Crisis and disaster situations usually result in the loss or temporary disruption of one or more of the following necessary key business resources:

  • Facilities
  • Infrastructure
  • IT Applications/Systems
  • People
  • Supply Chain

 Unidentified threats and vulnerabilities:  

Threats and vulnerabilities must be identified in order for potential impacts to be analyzed and countermeasures to be implemented. Identification can be complicated by the continuing evolving nature of potential threats and vulnerabilities. Threats and vulnerabilities can stem from both external and internal actions. New technologies, best practices, and mitigation efforts can often minimize threats. However, as operations evolve and new concepts are introduced, additional threats and vulnerabilities can emerge.

Countermeasures: An annual risk and hazard analysis can identify potential undiscovered threats and vulnerabilities relating to business continuity. This analysis indicates the likeliness that specific threats that could occur, considering existing site-specific factors, capabilities, mitigation measures, and history. Companies should analyze potential continuity threats from typical weather patterns, geographical influences, security efforts, inherent operational hazards, as well as facility design and potential maintenance issues.

For a free download on Designing a Crisis Management Program, click the image below:

TRP Corp - Emergency Response Planning Crisis Management

Tags: Business Continuity, Resiliency, Facility Management, Emergency Management Program, Business Continuity Plan, Business Disruption

Incident Response Drills and Tabletop Exercises

Posted on Thu, Jul 17, 2014

There are various types of types of emergency response drills and exercises that target specific goals. They can range from small group discussions to complex, multi-faceted exercises. But each drill or exercise presents the opportunity to improve site-specific response plans, rendering the potential for a more effective response.

Response plan testing can begin with simple exercises intended to validate general response plan comprehension or incorporate an all-inclusive, full-scale, realistic, multi-scenario exercise. Managers should determine the goals of the exercise before settling on a particular method. To fully execute a response plan, synergistic drills or exercises should be developed to assess the following critical response skills:

  • Communication
  • Training
  • Resource management
  • Teamwork

An exercise should prepared employees and responders to minimize the impacts of an incident. Below are three of the most basic exercises.

1. Orientations: The purpose of an orientation is to familiarize participants with roles, responsibilities, plans, procedures, and equipment. Orientations can resolve questions of coordination and assignment of responsibilities. The inclusion of first responders and facility staff promotes the development of an effective plan.

2. Drills: The goal of a drill is to practice aspects of the response plan and prepare teams and participants for more extensive exercises in the future. A drill can test a specific operation or function of the response plan.  Facilities should conduct evacuations, shelter in place, and lockdown drills to demonstrate emergency response actions. Drills can be altered to incorporate various scenario situations. The procedures, individual responsibilities, and public safety coordination may be addressed depending on the presented scenario or outcome of the drill.

3. Tabletop Exercises: A tabletop exercise simulates an emergency situation in an informal, stress-free environment.  The participants, usually comprised of decision-making level staff and responders, gather to discuss simulated procedures and general problems/solutions in the context of an emergency scenario.  The focus is on training and familiarization with roles, procedures, and responsibilities relative to the emergency synopsis and potential injects.

Below is a list of common tabletop exercise planning considerations:

Condensed Exercise Time Frame: In order to exercise the emergency scenario, the exercise must progress in a condensed timeframe (not real-time). Events should move rapidly through the phases of the exercised response. However, it should be clearly understood that under real conditions the same events or actions might require additional time to complete. Conversely, real world scenarios can quickly change and transition from a basic emergency to a full scale crisis within a short time frame that require rapid decision making and expeditious responses.

Scenario Information and Position-Specific Tools: Detailed scenario information, ICS forms, and position specific events should be prepared to guide all participants through the execution of their roles and responsibilities. These tools should be included in a participation package and distributed to all participants prior to the exercise. A web-based drill and exercise management tool can streamline the distribution of these tools.

Weather Conditions: Depending on the scenario and if the weather is a critical factor, either real or simulated weather conditions may be utilized during the exercise.

“This is a Drill” Exercise Communications: All radio, telephone, fax and written communications must begin and end with the statement "This is a Drill".  Include this statement in all verbal communications, and in a prominent location on all written correspondence, including report forms, fax communications, and press releases. It may be helpful to add the date to any written documentation for organizational and regulatory compliance purposes.

Communications with external agencies, contractors, medical responders, or other parties not participating directly in an exercise must begin and end with the statement, "This is a Drill". This may involve state or federal regulatory notifications or contact with suppliers or vendors to source simulated logistical needs. In all cases, exercise participants must ensure that the all involved parties clearly understand that no actual emergency exists, and no resources or equipment should be mobilized or dispatched.

Response Equipment Deployment: Emergency equipment and vehicles should be simulated for tabletop exercises. Staging area locations should be identified.

Injects: Injects may be provided to some participants or as a component of the exercise. An inject describes an additional event or circumstance that requires a response or action from the participant.

Exercise Termination and Debriefing: Following termination of the exercise, a debriefing of all exercise participants should be conducted.  All participants should have the opportunity to provide feedback on the exercise and complete an exercise evaluation form. Feedback should be evaluated for potential response plan mitigation opportunities.

Follow-up on Action Items: Exercises may provide insight into the deficiencies in an emergency response plan. In order to take response efforts to the next level, action items resulting from the exercises should be completed in a timely manner.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: Tabletop Exercise, Training and Exercises, Facility Management, Emergency Management Program, Communication Plan, Workplace Safety, HSE Program

Documenting Oil and Gas Emergency Response Drills and Exercises

Posted on Thu, Jun 26, 2014

Amidst the business of sustaining profitable operations, oil and gas companies must ensure that work conditions are safe. Oil and gas operations have innate risks, hazards, and, in the event of a release or spill, potential detrimental impacts. As a result, regulatory agencies require response drills and exercises that adequately reflect the current operations and emergency response capabilities.

The National Preparedness for Response Exercise Program (PREP) is designed to facilitate the periodic testing of oil spill response plans for certain vessels and facilities, and provide companies an economically feasible mechanism for exercise compliance. This unified federal effort provides a consistent set of guidelines that satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline Hazardous Material Safety Administration (PHMSA), and the Bureau of Safety and Environmental Enforcement (BSSE). Completion and documentation of the PREP exercises satisfies all OPA 90 mandated federal oil pollution response exercise requirements.

Drill frequency and specific requirements vary depending on operations, vulnerabilities, facility location, and site hazards. However, documentation of oil and gas emergency preparedness drills and exercises is mandated by various regulatory agencies. Thorough documentation also:

  • Identifies deficiencies and mitigation opportunities
  • Provides a historical record of the event
  • Engages management in preparedness efforts
  • Serves as a legal instrument, if necessary
  • Ensures training accountability
  • Accounts for preparedness efforts and plan maintenance cost

In order to satisfy the PREP requirement, oil and gas companies must be able to document all operational and support aspects of a response, and provide detailed records of decisions and actions taken. An exercise tracking system that is integrated into an overall response planning system can minimize the documentation efforts associated with drills and exercises. A tracking system should:

  • Improve regulatory compliance with thorough documentation·
  • Provide a tool for scheduling exercises, and documenting PREP objectives, exercise objectives, lessons learned, scenarios, and action items.
  • Provide a tool for developing exercise final reports and a method of assigning and tracking outstanding action items to improve follow-up.
  • Provide a reporting mechanism to track PREP objectives completed during any 3 year cycle, outstanding action items, and a summary report by facility that indicates progress in meeting PREP exercise requirements.
  • Provide a “snapshot” of exercises completed for the year for every facility via a summary report.

To ensure employees and identified essential response personnel are prepared to respond to an incident in an efficient and effective manner, oil and gas companies should establish minimum exercise guideline requirements. Management should ensure that:

  • All aspects of response plans are exercised at least once per year with the appropriate response, incident management, and support teams taking part.
  • Notification exercises for Qualified Individuals are conducted on a quarterly basis. This exercise should involve unannounced checks of the communication processes, and systems.
  • National and local training and exercise requirements should be used to assess the overall integrated preparedness of a response with the authorities.

If not physically present during a drill and/or exercise, the final documentation from the events can be submitted to local responders or fire marshals for review. If a web-based planning system is utilized, drill and exercise documentation can be securely shared and accessed by approved stakeholders. In the event of an actual incident, the lessons learned from these drills and exercises can minimize impacts and prevent further consequences.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: Testing, Tabletop Exercise, Training and Exercises, Emergency Management Program, HSE Program

Expert Insight on Emergency Response Tabletop Exercises and Scenarios

Posted on Fri, Jun 20, 2014

Emergency response training simulations are an integral part of a sound emergency management program. Exercises offer training opportunities for responders to strengthen their capacity for responding to various site-specific emergencies. By facilitating different types of drills and exercises, facilities can identify the appropriate methods for preventing, preparing for, responding to, and recovering from crises.

Real world exercise scenarios can often highlight potential deficiencies in response plans, individual comprehension of response roles and responsibilities, and partnership coordination efforts. Deficiencies often reveal mitigation opportunities and valuable response knowledge that can be applied to response plans and an actual emergency response situations.

There are various types of emergency drills and exercises for response training and planning validation. Companies can test response plans with simple orientations and drills, and work their way toward full-scale exercises, inclusive of multiple components and coordinated efforts.

A tabletop exercise is one of the simplest type of comprehensive exercises to conduct in terms of planning, preparation, and coordination. It should facilitate analyses of an emergency situation and the most effective processes to respond and recover. The informal, stress-free environment should be designed to prompt constructive discussions about existing emergency response plans as participants identify, investigate and resolve issues. The success of the exercise is mainly determined by the identification of problem areas, and applying applicable corrections.

These exercises should replicate realistic and site-specific emergency scenarios that allow participants to increase their awareness of roles and responsibilities required to respond, stabilize, terminate, and recover from emergencies. In preparation for these exercises, companies should develop exercise planning documents, including participant's and controller’s packages that contain exercise objectives, scenarios, ground rules, and simulation scripts. These guidelines, at a minimum, should be provided to all participants prior to the exercise to allow for a thorough examination of exercise expectations. A training and exercise management system can streamline and simplify the documentation and administrative duties associated with exercises planning.

The goal of a tabletop exercise program should be to improve the overall readiness and capabilities of emergency response program that encourages:

  • Realistic scenarios
  • Proper training validation
  • Effective emergency plans
  • Action item identification
  • Operational response capabilities
  • Personnel preparedness to respond to incidents, regardless of the threat or hazard

The Department of Homeland Security addresses four types of exercise scenarios used in risk management and emergency planning:

1. Basic Scenario:  Provides basic information about one specific variable or risk, such as internal or external hazard, attack type, or potential target. Scenarios can be used to establish response parameters and instructions based on a singular applicable variable (Ex: tank 101 fire or leak at a loading dock).

2. Narrative Scenario: Story-like, highly detailed scenarios with many fixed factors. Narrative drills are typically used for planning purposes rather than risk analysis. Narratives identify characteristics of a scenario, detailed background information, and each components of the scenario.

3. Visual Modeling:  Highly structured scenarios that display multiple potential variables of an emergency situation. Depending on the level of detail, visual models can become highly comprehensive and complex. The Department of Homeland Security identifies three methods of visual planning: attack paths, fault trees and event trees.

Attack paths: A systematic method that examines the sequence of events that occurred prior to the incident.

Fault trees: A detailed, deductive tool is used to assess the ill-fated sequence of events that led to the incident. A fault tree highlights potential hazards and ineffective processes.

Event trees: Assess the components it takes to respond and recover from an incident. Event trees highlight the necessary planning initiatives required to counteract the incident.

4. Future Scenario: Speculative narratives that consider how trends, such as social media usage or global warming, will impact future risks. This scenario can to identify “future-state” planning strategies against a range of alternative risk possibilities.

For a free download entitled, "Tips on How to Conduct an Effective Exercise", click the image below:

TRP Corp Emergency Response Planning Exercises

 

Tags: Tabletop Exercise, OSHA, Emergency Management, Response Plans, Training and Exercises, Emergency Management Program

Tips for Managing Corporate Emergency Management Training Programs

Posted on Thu, Jun 12, 2014

The ability to schedule, communicate, develop, document, and deliver training is a critical aspect of your environmental, health, safety and emergency response program. Training familiarizes employees and responders with safety and emergency procedures, equipment, and systems, and can identify deficiencies and mitigation opportunities in emergency response planning programs.

Managing the administrative duties associated with training requirements can be time consuming and complex, particularly for large companies. With the multiple variables associated with training, many large companies implement a training and exercise management system. An emergency response planning system with a training component can ease the burdens of documentation, scheduling, and maintenance. Managing an enterprise-wide training program can be complicated by:

  • Multiple fluctuating certification/expiration dates
  • Diverse and varying scope of responder/employee responsibilities
  • Site-specific operations and response objectives
  • Maintaining company standards and best practice priorities
  • Regulatory compliance measures
  • Multiple facilities across several locations
  • Employee turnover

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Accurate and verifiable training documentation enables response plans and procedures to be implemented as intended. Training topics and specialized training includes, but is not limited to:

  • Hazard and risk assessment techniques
  • Selection criteria of proper personal protective equipment
  • Incident reporting
  • Instruction and procedures for using personal protective and emergency equipment
  • Evacuation and alarm procedures
  • Specific roles and responsibilities in according to response scenarios (i.e. fire, explosion, severe weather)
  • An understanding of the role of the first responder in an emergency (i.e.  First Responder Operations Level)
  • 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

Training and exercise administrative requirements may be dictated by company policy, site operations, hazardous material response needs, or governmental agencies. In addition to yearly response plan reviews and scheduled updates; training documentation modifications may be required:

  • After each training drill or exercise
  • After each emergency
  • When personnel or response tasks change
  • When the layout or design of the facility changes
  • When policies or procedures change

Continual administrative duties associated with personnel training documentation may be timely or inadequately performed, jeopardizing regulatory compliance or the sustainability of an optimal emergency management program. Maximizing efficiency through advancements in technology can minimize administrative maintenance time. An enterprise-wide training and exercise management system can:

  • Improve regulatory compliance by comparing actual training dates to required training frequencies
  • Reduces costs by incorporating all training and exercise records and documentation into an existing database already being utilized for your emergency planning system.
  • Provide reporting tools to identify personnel requiring training, generate lists of completed training per person, and  document all training completed.
  • Automatically generate training agenda and certificates  for each scheduled training session
  • Simplify communication to attendees by generating emails regarding training requirement reminders, class agendas,
  • Initiate scheduled training requirement reminders to each facility. A comprehensive system will allow for developing a customized email message that will be automatically sent to a list of personnel for a selected time period (example monthly).

Technology has bolstered the availability and popularity of online training. However, depending on the certification, trainees often must complete corresponding classroom training offered by a local government agency such as the emergency management agency, fire or police department. But regardless of the training format, employers must document certifications and verify site-specific response comprehension.

Companies should require annual site-specific training, and routinely implement unannounced emergency drills and scheduled response exercises. Annual refresher training should cover current industry and in-house emergency operating experience; changes in emergency operations plans, policies, procedures, and equipment; as well as, familiarize employees and responders with response procedures, equipment, and systems. Annual training events can be used as a trigger for discussions and feedback on the company’s emergency management program, drills, and exercises. These discussions often cultivate an environment of safety and preparedness, identify mitigation opportunities, and possibly, training deficiencies.

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises, Regulatory Compliance, Emergency Management Program, Workplace Safety, OSHA HAZWOPER standard training, HSE Program

Managing Multiple Emergency Action Plans: The Template Approach

Posted on Thu, May 29, 2014

Enterprise-wide standardization breeds familiarity. Yet, each facility requires customization due to site-specific risks, threats, and emergency response challenges. This continually evolving component of preparedness, response planning, and regulatory compliance complicates the administrative duties associated with maintaining a company’s multiple Emergency Action Plans (EAPs).

Technology, such as a web-based planning system, provides companies with the tools to balance enterprise-wide standardization and site-specific regulatory criteria. Companies responsible for multiple buildings, possibly in various locations, should demonstrate a commitment to emergency management by creating a systematic template for incident response policies, procedures, and practices. Yet, these templates should enable users to incorporate the detailed, site-specific data necessary for an effective response.

While much of the information required in an EAP is site-specific, a template approach ensures regulatory requirements are communicated and pre-approved company protocols are identified. At a minimum, a template for EAPs should include:

  • Procedure(s) for reporting a fire or other emergency
  • Procedure(s) for emergency evacuation, including type of evacuation and exit route assignments
  • Procedure(s) to be followed by employees who remain to operate critical plant operations before they evacuate
  • Procedure(s) to account for all employees after evacuation
  • Procedure(s) to be followed by employees performing rescue or medical duties
  • Contact Information of company/building/site management
  • Alarm system details

The primary goal of an EAP is to protect lives. To establish effective EAPs capable of protecting employees or building occupants, companies should conduct analyses to identify necessary site-specific safety measures, including those required in OSHA’s 29 CFR 1910.38 regulation. Analyses should identify the following details:

1. Site Analysis

  • Identify existing and potential site hazards through employee feedback, audits, and detailed inspections.

2. Task Analysis

  • Determine job specific methods and procedures for each employee’s duty to reduce or eliminate associated hazards.
  • Review and update methods and procedure when an incident occurs, job responsibilities change, or if hazards are identified through analysis.

3. Risk Analysis

  • Establish risk evaluation criteria, probability of incident, and potential consequences.
  • Monitor and review procedures for continuous improvement, effectiveness, control measures and changed conditions.

After initial analyses, site-specific EAPs should be developed and shared with building occupants. Depending on the characteristics of the building, and inherent roles and responsibilities of the occupants, an EAP may be a component of a comprehensive emergency response-planning program.  This inclusive program may include Facility Response Plans and site-specific Fire Pre Plans. Building emergency response plans should include the following minimum information:

●       Building description

●       Owner/Manager contact information

●       Emergency Assembly Point details

●       Internal and/or external emergency personnel information and contact details

●       Specific hazard details and possible MSDS information, if applicable

●       Utility shut-off locations and descriptions

●       Alarm(s) description

●       Emergency equipment inventory and locations

●       Plot plan(s) and floor plan(s)

●       Risk, site and task identified situational checklists and job specific procedures

Emergency management programs, especially those inclusive of multiple buildings, should include health, safety and environmental training to communicate regulatory requirements, site response methods, and other applicable required safety training. EAPs require that companies designate and train employees to assist in the safe and orderly evacuation of other employees. Job and site specific training should be implemented for current employees, new hires, or supervisors that may need to carry out direct reports’ responsibilities.

Safety audits, inspections, task analyses, and incident investigations often identify a need for additional training and/or highlight necessary changes that may apply response plans.  EAPs must be reviewed when:

  • Initial plan is developed
  • A new employee is assigned to the EAP
  • Employee emergency response role or responsibilities change
  • Plan is revised

 

Challenged with managing preparedness amongst your various facilites? Download TRP's best practices guide on response planning for large organizations with multi-facility operations.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: OSHA, Regulatory Compliance, Emergency Management Program, Workplace Safety, Emergency Action Plan

Post Acquisition Response Planning Checklist for the Emergency Manager

Posted on Thu, May 22, 2014

Emergency response plans should be reviewed annually, at a minimum. However, when facility acquisitions occur, companies must initiate the process of developing site-specific emergency response plan(s).  Newly acquired facilities must be analyzed for operational hazards, site-specific risks, response capabilities, and regulatory requirements as soon as possible. A post acquisition checklist should include emergency management components that ensure new facilities are able to effectively respond in case of an emergency.

At a minimum, a post acquisition checklist should incorporate the following five emergency management components:

1. Response Plan Audit

Audits should verify that response plans have been effectively developed for each potential scenario and satisfy all applicable regulatory requirements. Whether conducted by in-house professionals or experienced consultants, audits can often reveal mitigation opportunities, response inadequacies, plan inconsistencies, and gaps in regulatory compliance.

All regulatory requirements should be met. These are typically based  on location(s), industry, operations, and hazards. At a minimum, an audit of newly acquired facilities should include:

  • Evaluation of  operations for compliance
  • Checking accuracy of plan content
  • Identification of required training and confirm necessary documentation
  • Review of plan approval and submittal process

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2. Response Team Details

Forming a response team and assigning responsibilities is one of the crucial steps in emergency response planning. Individuals should be selected based on authority level and experience, and should be trained for their expected, site-specific tasks. The more knowledgeable individuals are of their response team roles and responsibilities, the better prepared a team can be to implement a streamlined response in the event of an emergency. At the minimum, response team implementation should:

  • Identify Incident Commander and other response team members
  • Verify the new response team organizational chart
  • Identify site-specific response team activation measures
  • Create response team roles and responsibilities checklists

 

3. Contact Information Verification

Confirming the accuracy of response plan notifications is critical. Unfortunately, the contact verification step is often neglected. When new plans are developed, it is essential that contact numbers be verified for accuracy. When response time is of the essence, a response should never be prolonged because of inaccurate or out of service contact information. If companies utilize an automated call out system, important information may not be received if contact information is incorrect.

Contact verification procedures should be implemented to solidify the accuracy of all contact information, including  email addresses, cell phone numbers, and land lines for all stakeholders listed in the plan.

 

4. Response Training Requirements

When new facilities are acquired, a training evaluation can highlight established or necessary response training programs, and reveal inadequacies, mitigation opportunities, and misaligned objectives. The following can be used to evaluate and implement training program priorities:

  1. Emphasize the basic and program-specific training and refresher requirements
  2. Designate a single point of contact to be responsible for training compliance
  3. Strengthen controls over the training process to ensure that credentials are only issued to those who demonstrate training requirement completion
  4. Identify specific training requirements applicable to positions and perform cyclical training audits
  5. Amend existing external cooperative agreements to require training compliance with response position descriptions
  6. Correct limitations in the Emergency Management system, such as populating the system with a complete list of training requirements and enabling certificates to be uploaded into the system
  7. Develop and implement a monitoring and oversight program to better manage and assess training requirements, reports, supervisory oversight, and compliance
  8. Confirm documentation methods

 

5. Exercise the Response Plan

A true test of an emergency plan is best conducted through emergency drills and exercises. Designing and conducting exercises is time consuming, but valuable for training, assessing the state of your program, and identifying gaps and deficiencies that should be addressed prior to experiencing an actual emergency. The following criteria should be evaluated when exercising the effectiveness and accuracy of a response plan and corresponding processes:

  • Prevention or Deterrence: The ability to detect, prevent, preempt, and deter incidents or emergencies.
  • Infrastructure Protection: The ability to protect critical infrastructure from site-specific threats and hazards.
  • Preparedness: The ability to plan, organize, and equip personnel to perform assigned response missions under various conditions and scenarios.
  • Emergency Assessment/Diagnosis: The ability to achieve and maintain a common operating structure, including the ability to detect an incident, assess impact, and initiate notifications.
  • Emergency Management/Response: The ability to control, collect, and contain a hazard, minimize its effects, and conduct environmental monitoring. Mitigation efforts may be implemented before, during, or after an incident
  • Incident Command System (ICS):  The ability to direct, control, and coordinate a response; manage resources; and provide emergency public information with the direction of an Incident Command System.
  • Evacuation/Shelter: The ability to provide initial warnings to the at-risk population, notify people to shelter-in-place or evacuate, provide evacuation and shelter. support; confirm headcount, and manage traffic flow to and from the affected area.
  • Victim Care: The ability to treat victims at the scene per training, arrange for transport patients, and handle, track, and secure human remains. Provide tracking and security of patients’ possessions, potential evidence, and manage mental health.
  • Investigation/Apprehension: The ability to investigate the cause or source of the incident, and/or cooperate with local authorities for any man made emergencies
  • Recovery/Remediation:  The ability to restore essential business units and/or operations, cleanup the environment and render the affected area safe, provide necessary services to victims and/or the public; and restore a sense of well-being at the facility.

 

Challenged with managing response plans for multiple facilites? Download TRP's best practices guide on response planning for large organizations with multi-facility operations.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

 

Tags: Response Plans, Training and Exercises, Facility Management, Emergency Management Program, Workplace Safety

Tips to Ensure Regulatory Compliance at New Site Locations

Posted on Mon, May 19, 2014

Enterprise expansion requires environmental, health, and safety (EHS) managers to sharpen their location-based understanding of regulations, security needs, and associated response plan components specific to each location. As part of a company’s asset management program, experienced personnel should review response plan data , safety and response audits, response plan validation, and regulatory compliance evaluations.

Corporate changes can initiate tensions and reveal undiscovered company perceptions. Regulatory compliance should coincide with each of the following corporate events:

  • Merger or acquisition
  • Organizational restructuring and expansion
  • Downsizing creating operational changes at other facilities
  • Facility closings
  • Management successions/promotions

Regulation evaluations are particularly important when a facility is added in a new location. Whether the new facility is built from the ground up or acquired through a merger or acquisition, ensuring regulatory compliance and employee safety requires a committed emergency management staff and an established, fundamental preparedness program with streamlined, coordinated, and exercised response plans. All  response plans should incorporate site-specific facility details, appropriate response processes, and standardized company-wide best practices, while maintaining compliance with local, state, and federal regulations.

When a new facility is added to a corporate enterprise, is important to build and maintain a credible relationship with regulators. This teamwork-based philosophy may foster relationships, community acceptance, a favorable reputation, and the potential for collaborative interoperability among the response groups. The mergers/acquisition team or newly assigned facility EHS manager/staff should closely examine and implement:

  • Regulations and guidelines
  • Emerging best practices
  • Company policies
  • Location-specific, external coordination
  • Electronic publishing and compilation practices
  • Necessary site and facility inspections
  • Employee training
  • Local industrial partnerships

Open communications with internal and external responders will ensure plan and response procedures are current, and carried out in accordance with company protocols and federal, state, and local regulations. Groups to consider in planning reviews include, but are not limited to:

  • Local responders (fire, police, emergency medical services, etc.)
  • Government agencies (LEPC, Emergency Management Offices, etc)
  • Community organizations (Red Cross, weather services, etc)
  • Utility companies (Gas, Electric, Public Works, Telephone, etc.)
  • Contracted Emergency Responders
  • Neighboring Businesses
  • Consultants/Contractors

Company growth emphasizes the need for systematic enterprise coordination, especially in the area of emergency management. A dedicated regulatory intelligence team or the EHS manager may be responsible for the daunting task of sifting through the mountains of location specific, yet divergent, regulations, mandates, and guidelines. Those responsible must remain attentive to ensure emergency plans are up-to-date and compliant in order to eliminate potential fines or operational shutdown. If company experts are not available, local compliance expertise should be outsourced in order to leverage site-specific knowledge and impart applicable requirements that should be included in emergency plans.

Ensuring location specific compliance and effective emergency response planning, regardless of location, requires a streamlined, coordinated response plan. A compliant response plan should:

  • Provide strategic regulatory guidance for operational safety and incident response
  • Establish an efficient planning archive for audits and reviews that corresponds with compliance updates
  • Provide high-quality, complete user/reviewer-friendly documents that are able to be electronically transmissible and reproducible
  • Identify hazardous product information and applicable effective responses
  • Ensure functional units comply with regulatory requirements and common regulatory practices

With extensive information potentially crossing multiple regulatory agencies, emergency plans must become more interactive and transparent.  An enterprise web-based emergency management system can unify content and cross-reference regulatory requirements while enabling secured access to approved stakeholders. New site locations under a company umbrella should address site-specific facility details, appropriate response processes, standardized company-wide best practices, and maintain location-associated regulatory compliance.  

Planning and regulatory compliance is not a theoretical process that occurs without an understanding of site-specific operations and local hazards. Companies should not try to apply generalized scripting processes that assign hazard and response actions with unjustified precision. Site-specific plans should provide a fact-based starting point for emergency operations and regulatory compliance.

Challenged with managing preparedness amongst your various facilites? Download TRP's best practices guide on response planning for large organizations with multi-facility operations.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

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