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Identify, Review and Verify for Effective Emergency Response Plans

Posted on Wed, Nov 15, 2017

As potentially stressful, chaotic and financially imposing as an emergency, disaster or crisis can be, some companies are still not prioritizing preparedness and response planning.

The three building blocks of preparedness - identify, review and verify can provide the means to effective corporate emergency response plans. When all three aspects are in motion, the ongoing process of preparedness is established, giving companies the best possible prognosis for a response.

 

Identify Preparedness and Response Plan Criteria

Company profiles are becoming increasingly sophisticated with an intricate network of technology, human resources, and global influences. Companies must routinely identify relevant risks and threats in order to develop practical, compliant, and up-to-date response plans. Improvising and implementing unplanned response actions for unrecognized scenarios often results in inadequate, and potentially damaging outcomes.

Preparedness is a continual sequence of analysis. Operational consolidation, growth, and changing threat variables require recognition. To prepare for and respond to an incident, emergency managers should identify the following preparedness and response planning criteria:

  • What risks and hazards may result in an emergency or disaster response event?
  • What processes are put in place to limit the exposures to risks and hazards?
  • What community/environmental sensitivities exist?
  • Who will respond when an incident occurs?
  • What processes, procedures, and training are in place for responders?
  • How will individuals/employees secure their safety?
  • What tools/equipment are necessary to respond to an incident and who will provide them?
  • What local, state, and/or federal organizations should be consulted?
  • What regulations apply?

 Magnifying glass showing compliance word on grey background.jpeg

With risks, threats, and preparedness needs identified, companies should move forward with developing site-specific response plans. However, preparedness does not end with a completed response plan.

 

Review Response Plans

Corporate preparedness programs and applicable response plans need to be reviewed for accuracy and effective responses to newly identified variables.  Employees familiar and trained with preparedness efforts are more likely to ensure best practices are carried out.

Reviews of response procedures, mitigation opportunities, best practices, response objectives, and operational requirements are necessary to ensure preparedness and effective response measures are in place. Reviews should include, but are not limited to:

  • Data and computer needs: Review the procedural details of computer backups, data restoration methods, and the minimum program needs to re-establish critical business processes. Companies should examine current data center outsourcing or other alternatives to ensure continuity and accessibility.
  • Notification lists: Response plan administrators must be certain that newly-assigned personnel are included in the plan, as necessary, and that notifications are being delivered to accurate e-mail addresses and/or phone numbers. Review contact lists to ensure all necessary information is correct.
  • Communication needs: Clear and effective communication channels must remain available to disseminate information to employees, assess and relay damage, and coordinate a recovery strategy. Evaluate current communication equipment and/or mass notification systems to communicate to key individuals, company employees, or an entire client base, as each scenario deems necessary.
  • Supply Chain: As a company’s needs change and new suppliers come online, potential suppliers should be evaluated, and plans should be updated to reflect any changes. Alternate resources should be reviewed to ensure availability, delivery, and continued operations in the event primary suppliers are not available when needed.
  • Essential Personnel: Ensure necessary minimum staffing levels are acceptable to remain operational. Review individual responsibilities and recovery time objectives with staff, contractors, and suppliers.
  • Equipment needs: Review availability of necessary equipment and establish processes for response, recovery, and continued operations, to minimize downtime and additional recovery efforts.

The review of company emergency response plans should include debriefings with collaborative response entities. Meetings with these outside responders should confirm specific plan and response details that can be carried out to be consistent with best practices and company protocols. 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 Company(s) (gas, electric, public works, telephone, etc.)
  • Contracted Emergency Responders
  • Neighboring Businesses

 

Verification of Effectiveness and Accuracy

The overall emergency response program readiness must be verified for effectiveness and accuracy, regardless of the threat or hazard. Training and exercises are valuable verification tools that can confirm effective response planning and preparedness efforts. Verification should include, but is not limited to:

  • A system for assessing emergency scenarios and prioritizing incident responses
  • Thresholds and procedures for activating the Incident Management or Crisis Management Team
  • Notification information (if maintaining accurate contact information is challenging, consider opting for an e-mail verification system that enables each contact to verify their contact information.
  • Roles and responsibilities of the Incident Management or Crisis Management Team members
  • Communication and notification procedures to facilitate interaction among responders and Incident Management Team
  • Guidelines and checklists to assist in an efficient and organized response
  • Verification of on-site hazardous materials details, response equipment, and response times

Technology, such as a web-based response 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. These templates should enable users to incorporate the detailed, site-specific data necessary for an effective response.

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Tags: Emergency Response Planning

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.

 Cement Plant and power sation during sunset.jpeg

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

What's Your Plan? Emergency Action Plan or Emergency Response Plan?

Posted on Thu, Apr 14, 2016

Whether your company manufactures consumer products or provides hotel accommodations for thousands of guests across the globe, response planning is a crucial preparedness element that must be implemented in order to minimize the impact of emergencies. For most sites, the foundational response planning tool mandated by government agencies is either the Emergency Action Plan (EAP) or the Emergency Response Plan (ERP). However, while the two plan types sound similar, they have key differences and applicability.

Emergency Action Plan: An EAP can be utilized by a “non-responding” facility where only defensive responses are in play. Generally, these responses equate to evacuation and communication with responders. The EPA has adopted a policy for non-responding facilities similar to that adopted by OSHA in its Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard (29 CFR 1910.120), which allows certain facilities to develop an emergency action plan to ensure employee safety, rather than a full-fledged emergency response plan.

The OSHA regulation (29 CFR 1910.38), states that employers with 10 or fewer employees do not have to create a written emergency action plan. However, employers are still required by OSHA to communicate an EAP to staff. An emergency action plan must communicate the following minimum requirements:

  • Procedures for emergency evacuation, including type of evacuation and exit route assignments (29 CFR 1910.38(c)(2))
  • Procedures to be followed by employees who remain to operate critical operations before they evacuate (29 CFR 1910.38(c)(3))
  • Procedures to account for all employees after evacuation (29 CFR 1910.38(c)(4))
  • Procedures to be followed by employees performing rescue or medical duties (29 CFR 1910.38(c)(5))
  • Means of reporting fires or other emergencies (29 CFR 1910.38(c)(1))
    The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.(29 CFR 1910.38(c)(6))

A facility that is not bound by ERP regulations may utilize the EAP if they are located in an area with access to municipal responders and emergency response resources that can facilitate an effective response.

Emergency Response Plan: Depending on industry, operations, and site hazards, sites may be required to submit specialized response plans to one or a variety of federal regulatory agencies. When an ERP is in place, the facility has established first responding capabilities with the intent to initiate offensive actions. (Note: The purpose of the first responder at the operations level, is to protect life, property, or the environment from the effects of the release, not stop the release.)

OSHA regulations (29 CRF 1910.120(q)) state that “an emergency response plan shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations. The plan shall be in writing and available for inspection and copying by employees, their representatives and OSHA personnel.” According to the Employers who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, are exempt from the requirements of this paragraph if they provide an emergency action plan in accordance with 29 CFR 1910.38.

Emergency response plans need to serve a specific response purpose and meet explicit planning objectives. Every response plan should include site-specific details that are unique to your facility. Below is a list of some basic planning objectives that may be relevant to your facility:

  1. Establish site specific emergency response procedures for each potential threat, risk or emergency scenario. These may include, but are not limited to:
    a. Medical emergencies
    b. Hazardous releases
    c. Fire
    d. Severe weather
    e. Security issues
  2. Design an emergency response team framework and assign personnel to fill primary and alternate roles.
  3. Define notification and emergency response team activation procedures.
  4. Establish communication procedures and a primary and alternate Emergency Operations Center location.
  5. Identify and quantify necessary response equipment
  6. Ensure emergency response team personnel receive applicable and required training
  7. Establish mitigation procedures and protective actions to safeguard the health and safety of on-site personnel and nearby communities.
  8. Identify and ensure availability of responders and supply chain resources
  9. Maintain compliance with all applicable local, state, and federal requirements for environmental hazards, response plans, and training requirements.
  10. Integrate best practices and lessons learned from past training and exercises, actual emergencies, and incident reviews.

In order to be fully integrated with external resources, the Emergency Response Plan structure should be consistent with the National Incident Management System and integrated with Incident Command System concepts.

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Tips for Merging Response Plan Templates and ICS

Posted on Thu, Sep 10, 2015

Response planning is a multi-faceted entity, composed of critical information, procedural comprehension, and response process awareness. Two contributors to effective preparedness comes from the site-specific information within the plans and a standardized response management process by which procedures are carried out. The two concepts, site-specific and standardization, may appear to contradict each other. However when merged properly, companies can strengthen preparedness initiatives and enable a flexible, effective, efficient, and all-hazards incident management response.

By integrating up-to-date, site-specific response plans, company EHS protocols, and Incident Command System (ICS) components, response operations can be streamlined and coherent without being hindered by jurisdictional boundaries. Utilizing ICS in conjunction with site-specific plans can also consolidate an effective response that includes multiple combinations of facilities, equipment, personnel, procedures, and communication methods.

However, when companies implement or utilize a basic template approach without consideration of site-specific details, the result is often an incomplete, ineffective, and non-regulatory compliant plan. In addition, implementing an incident command approach without site-specific information often results in inadequate and prolonged responses.

By utilizing a template as an outline, companies can begin the process of creating response plans. Companies may consider web-based technology to streamline template formats across an enterprise. A generic plan template may not address every regulatory and/or site specification, so it is essential to evaluate site-specific variables and applicable regulatory requirements. If templates are tied to a web-based database, site-specific information can often be cross references with regulatory requirements. As facilities are added or renovated, operations are revised, or employees revolve, each web-based plan can be conveniently accessed and updated for accuracy and compliance.

Below are twelve basic template topics that should be evaluated for site specific applicability and implementation.

  1. Laws and regulating authorities
  2. Hazard identification and risk assessment
  3. Hazard mitigation procedures
  4. Resource management
  5. Response direction, control, and coordination
  6. Notifications and warning systems
  7. Operations and safety procedures
  8. Logistics and facilities infrastructure specifics
  9. Training
  10. Exercises, evaluations, and corrective actions
  11. Crisis communications
  12. Finance and administrative duties

Once site specifications and regulatory requirements are identified, plans should be formatted within a common and unified incident planning organizational structure. The structure is based on a set of essential features that apply to the management of any incident or all-hazards events. Features included in ICS are:

  1. Common terminology - use of similar terms and definitions for resource descriptions, organizational functions, and incident facilities across disciplines
  2. Modular organization - response resources are organized according to their responsibilities. Assets within each functional unit may be expanded or contracted based on the requirements of the event.
  3. Management by objectives - specific, measurable objectives for various incident management functional activities and direct efforts to attain them. Planning should allow for a timely response, documentation of the results, and a way to facilitate corrective actions.
  4. Incident action planning - Incident Action Plans (IAPs) guide response activities, and provide a concise means of capturing and communicating a company’s incident priorities, objectives, strategies, protocol, and tactics in the contexts of both operational and support activities.
  5. Manageable span of control - response organization is structured so that each supervisory level oversees an appropriate number of assets (varies based on size and complexity of the event) so it can maintain effective supervision.
  6. Pre-designated incident facilities - assignment of locations where expected incident-related functions will occur.
  7. Comprehensive resource management - systems in place to describe, maintain, identify, request, and track resources.
  8. Integrated communications - ability to send and receive information within an organization, as well as externally to other disciplines.
  9. Consolidated action plans - a single, formal documentation of incident goals, objectives, and strategies defined by unified incident command.
  10. Establishment and transfer of command - Clearly identify and establish the command function from the beginning of incident operations. If command is transferred during an incident response, a comprehensive briefing should capture essential information for continuing safe and effective operations.
  11. Chain of command and unity of command - Identify clear responsible parties and reporting relationships
  12. Unified command structure - multiple disciplines work through their designated managers to establish common objectives and strategies to prevent conflict or duplication of effort.
  13. Accountability - Develop process and procedures to ensure resource accountability including: check-in/check-out, Incident Action Planning, unity of command, personal responsibility, span of control, and resource tracking.
  14. Dispatch/deployment - Limit overloading response resources by enforcing a “response only when requested or dispatched” process in established resource management systems.
  15. Information and intelligence management - The incident management organization must establish a process for gathering, analyzing, assessing, sharing, and managing incident-related information and intelligence.

Once the initial response plan is completed, plan audits, exercises, expert assistance, and/or consultation services may be required to confirm plan compliance and effectiveness.

Preparedness and Emergency Management - TRP Corp

Tags: Response Plans, Incident Management, ICS, Emergency Response Planning

Enterprise-Wide Contingency Planning & Regulatory Compliance

Posted on Thu, May 07, 2015

Emergency Operations Plans (EOPs), or Emergency Response Plans, are often the centerpiece of a comprehensive emergency management program. EOPs should be flexible enough to be effective in a variety of emergency scenarios. However, many company emergency management programs, as well as specialized industrial facilities utilize an integrated contingency plan (ICP) to consolidate a variety of required site and response information.

An ICP is a comprehensive plan that documents necessary response actions, identifies the resources required to effectively manage potential hazards, and can fulfill compliance mandates for a variety of regulatory agencies.  ICPs enable facilities to comply with multiple federal planning requirements by consolidating them into one functional response plan.  Elements of an ICP will reflect the complexity of operations, response components, and required documentation. Depending upon the EOP’s structure and required content, hazard-specific information may be either included within an ICP or created as a separate stand-alone plan that can be distributed exclusively.

However, enterprise response planning with a variety of information into an ICP often becomes challenging when:

  • A company has multiple facilities utilizing multiple formats
  • The comprehensive plan format does not allow for the facility-specific information required for regulatory compliance
  • Plan updates result in “version confusion” or lack of data consistency
  • Known quantities of hazardous materials vary depending on operational status

An enterprise-wide template should serve as an outline for compliance required information, but should be populated with site-specific details. Utilizing a customizable, secure, web-based template with a database of common company planning information allows each site to provide facility-specific compliance data, as well as the precise information required to assist responders in determining the best response for the specific scenario.

With effective web-based formats and comprehensive, yet site-specific capability, emergency managers can;

  • Reduce the need for multiple plans
  • Minimize administrative costs
  • Simplify plan reviews
  • Minimize discrepancies across various plans
  • Streamline response effort directives from one source
  • Simplify required distribution in a secured manner

ICPs do not exempt facilities from applicable regulatory planning requirements pertinent to releases of hazardous and non-hazardous substances. Companies must evaluate each site for applicable regulatory requirements. . Fortunately, multiple federal agencies endorse the use of an ICP as a means to incorporate response planning regulations, and simplify the complex planning process. An ICP may be used to incorporate one or more of the following applicable federal regulations:

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

While ICPs may simplify the planning process, many companies still choose to maintain separate plans. Stand-alone plans typically contain site-specific, unique response details that apply to a single hazard, such as pandemic, hurricane, fire, or hazardous spill. Procedural, tactical, and/or incident-specific action plans tend to be location-based and often highlight operational hazards, inherent threats, or response needs. These stand-alone plans are often shared with specialized local responders and/or regulatory agencies to address specific regulatory requirements, such as the EPA’s SPCC plans (spill prevention, control, and countermeasure). Other stand-alone plans may be developed for crisis management situations, security-related incidents, and/or business continuity scenarios.

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Tags: Pipeline, Facility Response Plan, Response Plans, Regulatory Compliance, Emergency Response Planning

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

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

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

Tips for Determining Which Emergency Management Planning Consultant is Right!

Posted on Mon, May 12, 2014

Preparedness, response planning, and emergency management within regulated industries or sensitive environments often requires outside expertise.  Program managers are often responsible for predicting, preparing, complying, documenting, and possibly, responding to site-specific emergency scenarios. Yet, limited staffing, constrained timeframes, or the need for specialized expertise often hinders an all-inclusive implementation of “best practices” programs and effective emergency response plans. Implementing this level of resilience often requires external expertise or the services of specialized consultants.

In the area of emergency response planning, an external expert, or consultant, should ease the day-to-day challenges associated with developing and maintaining multiple response plans and site-specific regulatory compliance. However, experienced consultants can provide these services while seamlessly integrating and interfacing with established data, company policies, and cultures.

Carelessly choosing a consultant can lead to delayed implementation, costly and conflicting approaches, and unfulfilled expectations. The following three components should be carefully evaluated when seeking assistance for developing emergency response plans.

1. Company/Employee Support: It is often the company or individuals that have difficulty accepting change. The goal of hiring consultants is to implement positive change. Best practices strategies, processes, and advanced technologies cannot deliver results without company and individual support. Those responsible for hiring consultants must accept, adopt, drive, and sustain changes to realize tangible impacts and overall benefits.

2. Communication Compatibility: The working relationship between a client and the consultant is critical.  Both entities must be able to communicate effectively in order to attain identified objectives. The consultant must be upfront regarding costs, timelines, capabilities, and obstacles to ensure mutual understanding. The client should clearly identify the approved budget, implementation timeline, specific needs and objectives, and availability.  A positive working relationship and unified project management approach establishes common goals which enables goals to be successfully implemented.

3. Consultant Approach: Consultant-specific methods and tools, such as gap analyses, project management frameworks, site evaluations, and specific mediation approaches are important to comprehend. For an approach method to be effective, it has to be tailored to the situation of the client and changed whenever necessary to achieve set objectives.

Consultant must be able to work closely with their clientele to develop customized plans that can improve a company's ability to prevent incidents, respond effectively, and restore operations to pre-incident levels.  Plans should be regulatory compliant and site-specific, identifying unambiguous responses for emergency situations such as fires, natural disasters, terrorist activities, pandemics or other events. Consultants should:

  • Have a proven track record in assisting in developing comprehensive, effective plans and processes
  • Have hands-on experience in emergency response, security, safety, and disaster preparedness
  • Understand budget parameters and confirm services for the agreed cost
  • Demonstrate a comprehensive understanding of local, state, and federal regulatory requirements applicable to a client’s industry, operations, and location
  • Provide references from current clients and relevant experience of staff
  • Communicate the information and time required of the company to develop compliant and effective response plans
  • Be available for meetings and updates, and address questions or concerns regarding the process, approach, and/or objectives
  • Clarify specific methods, techniques, and approaches used to meet objectives and be open to modifications

Consultants who develops customized emergency response plans should be experienced in:

  • Maintaining multiple and complex response plans
  • Addressing plan maintenance issues regarding infrastructure, personnel, and/or regulatory compliance changes
  • Regulatory audits
  • Training and exercises
  • Gathering or verifying site-specific information
  • Conducting emergency response assessments of personnel, response equipment, plans, and response contractors.

The costs associated with contracting consulting services are always in question. When hiring an external emergency management and preparedness consultant, companies should evaluate the strategic cost of an incident and the tactical cost of safety compliance versus the consultant fee. The cost benefit of hiring a specialized, reputable consultant typically outweighs the financial impacts associated with non-compliance or a catastrophic incident. 

 

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: Choosing a Consultant, Response Plans, Training and Exercises, Emergency Management Program, Emergency Response Planning, Deadline Approaching

4 Preparedness Templates Every Response Plan Administrator Must Have

Posted on Thu, May 08, 2014

Every company, whether an industrial enterprise or a large office building management group, must operate profitably and ensure the safety of its employees, yet comply with a complex array of federal, state and local regulations.  A lack of response planning and neglectful preparedness efforts can result in regulatory compliance fines, infrastructure damage, a negative public perception, and possibly a government-mandated shutdown of operations. While response plan requirements vary by industry, operation, and applicable regulations, utilizing these four preparedness elements can lay the foundation for a basic response planning program.

1. Emergency Response Plan: Every effort should be made to include processes and procedures to respond to the most likely emergency scenarios relevant to your site. Depending on industry, operations, and site hazards, companies may be required to submit specialized response plans to one or a variety of federal regulatory agencies.

Emergency responses plans need to serve a specific response purpose and meet explicit planning objectives. Below is a list of some basic planning objectives that may be relevant to your facility:

  1. Establish site-specific emergency response procedures for each potential threat, risk or emergency scenario. These may include, but are not limited to:
    1. Medical emergencies
    2. Hazardous releases
    3. Fire
    4. Severe weather
    5. Security issues
  2. Design an emergency response team framework and assign personnel to fill primary and alternate roles.
  3. Define notification and emergency response team activation procedures.
  4. Establish communication procedures and a primary and alternate Emergency Operations Center location.
  5. Identify and quantify necessary response equipment
  6. Ensure emergency response team personnel receive applicable and required training.
  7. Establish mitigation procedures and protective actions to safeguard the health and safety of on-site personnel and nearby communities.
  8. Identify and ensure availability of responders and supply chain resources.
  9. Maintain compliance with all applicable local, state, and federal requirements for environmental hazards, response plans, and training requirements.
  10. Integrate best practices and lessons learned from past training and exercises, actual emergencies, and incident reviews.

2. Fire Pre plan: The purpose of the pre fire emergency plans is to ensure a coordinated, expedient, and safe response in the event of a fire. The information listed in a fire pre-plan, such as floor plan(s) and details of on-site hazardous material(s), may also required by multiple agencies (OSHA, DOT, EPA, USCG) as part of an overall emergency response plan.  However, specific fire fighting information, such as construction details, hydrant, and utility valve locations may be useful to responders if highlighted in a stand-alone format and shared with responders prior to an emergency.

Having up-to-date information readily available, and available to knowledgeable responders has been proven to limit the duration of the emergency.  The faster responders can locate, assess, access, and mitigate the emergency, the sooner an incident can be contained...and the sooner facility operations can be restored to “business as usual”.

3. Business Continuity: Companies should establish methods to preserve critical business processes during adverse conditions to ensure operational viability and minimize the potential of lost revenues. Failure to develop an effective business continuity plan can lead to costly and devastating impacts, often affecting the long-term viability of a company.

The following business continuity planning cycle should be incorporated into every business process in order to reduce the duration of a disruption during an emergency.

  • PLAN: Identify the following -
    • Potential risks/threats
    • Trigger events
    • Impacted business processes/activities
    • Incident response structure
    • Warning and communication process
    • Recovery time objectives
  • ESTABLISH: Define the following -
    • Parameters of business continuity strategy
    • Communication and documentation processes
    • Training requirements
    • Detailed employee/ vendor contact information
    • Supplier dependencies and alternate resources
  • IMPLEMENT:
    • Initiate response checklists
    • Activate relocation strategies of critical processes
  • OPERATE: Manage critical processes and recovery time objectives.
  • MONITOR:
    • Equipment requirements
    • Primary and alternate facility details
    • Application and software requirements
  • MAINTAIN: Update key details and associated processes as deficiencies and inaccuracies are identified
  • CONTINUALLY IMPROVE: Incorporate lessons learned into the plans and training and periodically evaluate critical business processes to ensure that evolving businesses practices are captured.

4. Crisis Management Plan: When incidents occur, a crisis management plan (CMP) can minimize the escalation effect; such as a company’s short and long-term reputation, adverse financial performance, and overall impingement of company longevity. The associated level of preparedness may mean the difference between a crisis averted and an exhaustive corporate disaster.  

The following concepts should be utilized to generate an effective crisis management plan:

  • PREDICT: Identify all potential threats to “business as usual” operations. This can range from incidents requiring an emergency response to human resource controversies.
  • POSITION: Determine what your position or viewpoint will be on potential issues.
  • PREVENT: Take preventive measures to avert emergency situations and proactively deter negative perceptions. This includes generating effective response procedures and recovery processes for a variety of potential threats..
  • PLAN:  If mitigation efforts fail or an emergency situation arises, prepare a plan for responding to all internal and external aspects of the crisis. This may include identifying and communicating with media, and all audiences that may be affected by each crisis situation.
  • PERSEVERE: Follow your plan and communicate company positions and ongoing activities to counteract the incident. Proactive efforts, honesty, empathy, and preparedness will assist in maintaining company viability and reputation.
  • EVALUATE: If the CMP is enacted, review the results to determine if adjustments should be made.

 

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: Fire Pre Plans, Business Continuity, Fire Preparedness, Emergency Preparedness, Response Plans, Crisis Management, Emergency Response Planning, Business Continuity Plan