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3 "Best Practice" Concepts for Managing Established Response Plans

Posted on Mon, May 05, 2014

The potential reality of an emergency scenario, employee injury or death, business interruption, or negative corporate reputation is an ongoing risk. Because of this persistent potential and changing variables, preparedness must be an evolutionary process.  Establishing and maintaining mechanisms, processes, and/or procedures that result in predictable and repeatable behavior that counteract negatively impacting scenarios is the objective of preparedness.

“Preparedness is best thought of as a process—a continuing sequence of analyses, plan development, and the acquisition of individual and team performance skills achieved through training, drills, exercises, and critiques.” (Dynes, et al., 1972; Kartez & Lindell, 1987, 1990).

It is important to recognize that improvising and implementing unplanned response actions is time-consuming, often inadequate, and typically damaging. Whether companies have established response plans, or are developing new plans, they must establish a process to incorporate the following response planning elements:

  1. Identify
  2. Review
  3. Verify

Each response-planning element is strongly connected with the others. When all three elements are in motion, the ongoing process of preparedness is established, giving companies the best possible prognosis for an effective response.

1. Identify: Preparedness is a continual sequence of analysis. Operational consolidation and growth, and changing threat variables require recognition. In order to prepare for and respond to an incident, emergency managers must identify:

  • What risks and hazards may result in an incident?
  • 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?
  • How will responders respond (processes and procedures)?
  • How will individuals/employees respond to secure their safety?
  • What training will responders need to respond, counteract impacts, and restore to pre-incident levels
  • What tools/equipment are necessary to respond to an incident and who will provide these necessities?
  • What local, state, and/or federal organizations should be consulted?
  • What regulations apply?
2. Review: The preparedness process and response plans must be adjusted to accommodate newly identified variables. 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:
  1. 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.
  2. 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.
  3. Communication needs: Clear and effective communication channels must remain available in order 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.
  4. 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.
  5. Essential Personnel: Ensure necessary minimum staffing levels are acceptable to remain operational.  Review individual responsibilities and recovery time objectives with staff, contractors, and suppliers.
  6. Equipment needs: Review availability of necessary equipment and establish processes for response, recovery, and continued operations, in order to minimize downtime and additional recovery efforts. .

3. Verify: 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 a e-mail notification verification system that enables each contact to verify their own information. Companies can also offer incentives, such as drawings or prizes, to encourage all personnel to register for notifications.)
  • 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 facilitate an effective and organized response
  • Verification of on-site hazardous materials details, response equipment, and response times

(Note: The compiled lists are not all-inclusive.  A comprehensive preparedness program must include the identification, review, and verification of site-specific details, regulatory compliance requirements, response parameters, training and exercise measures, and applicable hazards, risks, and threats)

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

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Tags: Facility Response Plan, Emergency Management, Emergency Preparedness, Response Plans, Emergency Response Planning, Event Preparedness

A Lesson in Emergency Preparedness: Learn from Past Incidents

Posted on Thu, Apr 17, 2014

From every event, whether a planned exercise or an actual emergency, lessons can be learned to improve the outcome of the next response. Emergency managers should not camouflage preparedness, response, or communication failures.  Instead, they should draw from the scenario experience to improve the overall emergency management program.

Immediately after an exercise or incident, it is critical to:

  1. Conduct post incident reviews
  2. Gather conclusions from interviews
  3. Identify necessary changes for program implementation
  4. Apply lessons to targeted area(s)

Actual recovery times can be evaluated and any obstacles that led to perpetuating the response should be mitigated. Emergency managers should incorporate lessons learned into response plans, highlight any additional training measures, and inject new responses procedures into exercise simulations.

The post-incident review is an evaluation of incident response used to identify and correct weaknesses, as well as determine strengths. Timing of a post-incident review is critical. An effective review requires that response and preparedness discussions take place while a disaster fresh in the minds of decision makers, responders, and the public. From this review, lessons learned can be identified and the task of preparedness and response improvement can begin.

The post-incident review process is intended to identify which response procedures, equipment, and techniques were effective or ineffective, and the reason(s) why. The question “How can our emergency response process be improved?” should be asked for each subject under the post-incident critique.

Post-incident reviews should include, but is not limited to:

  1. Name and typical duties of personnel being debriefed
  2. Date, time and whereabouts of employee during incident
  3. Specific actions performed during the incident
  4. Documentation of the positive aspects of the response and areas for improvements
  5. Recovery time and possible mitigation measures for improvement
  6. Potential lessons learned
  7. Necessary program and plan revisions
  8. Condition of equipment used, both prior to and after the incident
  9. Overall post-incident perception

Key areas of consideration that should be analyzed by a review team can include, but not limited to:

Initial Response

  • Was the emergency detected promptly?
  • How was it detected?
  • Could it have been detected earlier? How?
  • Are any instruments or procedures available to consider, which might aid in earlier detection of the incident?

Notifications

  • Were proper procedures followed in notifying government agencies?
  • Were notifications prompt?
  • Was management notified promptly?
  • Were personnel notified promptly? If so, why, how and who? If not, why not?
  • Were contact numbers up to date?

Assessment/Evaluation

  • Was the magnitude of the problem assessed correctly at the start?
  • What means were used for this assessment?
  • Are any guides or aids needed to assist emergency evaluation?
  • What sources of information were available on winds, on water currents and other variables?
  • Is our information adequate?

Response Mobilization

  • What steps were taken to mobilize countermeasures to the emergency?
  • What resources were used?
  • Was mobilization prompt? Could the response time improve? How?
  • What about mobilization of labor resources?
  • Was it appropriate to mobilize company resources and was this promptly initiated?
  • What other company resources are available and have they been identified and used adequately?

Response Strategy

  • Was there a Response Plan available for reference?
  • Was it flexible enough to cope with unexpected events?
  • Does the plan include clear understanding of local environmental, political or human sensitivities?
  • What was the initial strategy for response to this emergency?
  • Is this strategy defined in the Response Plan?
  • How did the strategy evolve and change during the emergency and how were these changes implemented?

Response Resources

  • What resources were mobilized?
  • How were they mobilized?
  • How did resource utilization change with time? Why?
  • Were resources used effectively?
  • What changes would have been useful?
  • Do we have adequate knowledge of resource availability?

Command Structure

  • Who was initially in charge of responding to the emergency?
  • How did this change with time? Why?
  • What changes would have been useful?
  • Was there adequate monitoring of the incident?
  • Were communications adequate?
  • Was support from financial services adequate? Prompt?
  • Should financial procedures be developed to handle such incidents?

Upon conclusion of the post-incident interviews, the following lesson learned concepts should be examined, mitigated if possible, and incorporated for an improved emergency management program:

  1. Unidentified potential risk or hazard: A hazard and vulnerability analysis should be performed, and processes and procedures should be developed and added to the plans.
  2. Management gaps and weaknesses: If the post incident reviews revealed weaknesses or gaps in the emergency management organization, the structure and/or roles should be modified and emergency plans revised.
  3. Ineffective policies and procedures: If the policies and procedures fail to address key issues during the incident, policies and procedures would need to be modified to address inadequacies.
  4. Lack of response proficiency: If response was faulty due to deficient training, exercising, or planning, these efforts should be amplified and personnel should be familiarized with these modifications
  5. Planning deviations: If participants successfully diverged from existing processes, procedures, or plans theses areas should be modified to reflect the reality of the performance.

Applying lessons learned to an emergency management program enables the ability to use experiences as a means to improve to better prepare for future emergency scenarios. By analyzing the past, executing enhancements, and reinforcing strengths companies and municipalities will be better prepared to not repeat history.

For your free guide on preparing for your next incident, click the image below:

Preparedness and Emergency Management - TRP Corp

Tags: Tactical Response Planning, Crisis Mapping, Emergency Management, Emergency Preparedness, Facility Management, Emergency Management Program, Emergency Response Planning

Expert Insight: Managing Multiple Response Plans

Posted on Thu, Apr 10, 2014

Emergency managers are increasingly asked to “do more with less”. Reduced staffing levels and heightened personnel responsibilities due to budget constraints create enterprise-wide challenges for environment, health and safety professionals. The mandate of managing and maintaining multiple emergency response plans and ensuring regulatory compliance and site specific accuracy can be a continual uphill battle. An enterprise-wide response planning system can remove the uncertainties and challenges associated with managing multiple response plans, streamline the update process, and simplify plan reviews, ensuring a consistent path toward compliance.

An enterprise-wide response plan system can address regulatory compliance and consistency in company-wide planning standards. For companies with numerous facilities, advanced systems offer advantageous response plan management opportunities while improving the overall planning system framework and the accuracy of site-specific emergency response plans.

Defining planning objectives, budget limits, and information technology (IT) system criteria will assist in determining which enterprise-wide planning system aligns with company requirements. Below are key questions that may help determine if an enterprise-wide planning system is right for your company:

  1. Do you have more than one facility that is governed by regulatory requirements?
  2. Are your facilities required to comply with multiple agency requirements?
  3. Is there repetitive information in multiple plans at multiple facilities?
  4. Does your employee turnover rate create inaccuracies in your response plan?
  5. How effectively do you handle contact information updates and verification? How often does this occur?
  6. How often do you print updated plan copies for distribution, and what costs are involved?
  7. Do you have multiple versions of plans, leading to “version confusion”?
  8. Are your existing plans user-friendly or cumbersome?
  9. Do your personnel need better access to your existing plans?
  10. Do local responders have access to your most up-to-date emergency response plan?
  11. Are your plans updated quarterly or annually, and how do you integrate new regulatory requirements?
  12. Have you recently gone through a merger or acquisition?
  13. How much time is dedicated to maintaining, updating, and distributing your plans?
  14. How often are you audited and would you be ready if an auditor appeared tomorrow?
  15. Do audits result in fines or violations?
  16. Can you use your existing plan to expedite training?
  17. Do you have an accurate record of changes and revisions?
  18. Are you able to comply with frequently evolving regulatory requirements across your various facilities?

Corporate-level managers may have substantial input regarding long-term environmental, health and safety goals and associated budgeting. However, EHS personnel and those who manage site-specific response plans often determine the success or failure of the program and are responsible for regulatory compliance.  A company-wide response planning system should ease the day-to-day challenges associated with managing and maintaining multiple response plans and site-specific regulatory audits, yet seamlessly integrate and interface with established company policies and cultures.

In addition to simplifying the administrative duties of managing multiple response plans, an enterprise-wide response planning system should:

  • Support the ability to execute company approved response strategies across multiple locations/facilities
  • Easily incorporate company growth and facility acquisitions
  • Enable site-specific details while not compromising company directives
  • Facilitate the ability to update corporate planning elements across multiple locations, without compromising site-specific details and response challenges
  • Be easily updated with minimal dedicated staff
  • Become an easily accessible, yet secured, shared tool for internal and external responders
  • Allow for streamlined regulatory compliance audits
  • Automate and optimize response planning training and exercise activities
  • Reduce non-compliance issues on a company-wide scale
  • Automate regulatory governance with electronic submissions

An enterprise-wide response planning system enables EHS departments to spend more time on preparedness planning and maximizing response efforts versus plan maintenance, documentation, compliance, and reporting. The result is a more streamlined company emergency management program that reduces administrative efforts, non-compliance fines, and ineffective responses.

Be prepared for your next incident! Click the image below to download your free guide.

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Tags: Choosing a Consultant, Facility Response Plan, Response Plans, Emergency Management Program, Emergency Response Planning

8 Expert Tips: Improve Your Preparedness and Response Planning Program

Posted on Mon, Apr 07, 2014

Improving the effectiveness of emergency response programs should be an ongoing event. From technological advancements to best practices implementation, continually evolving planning programs can reduce unexpected impacts on individuals, infrastructures, and the environment.

Below are eight tips to consider in the continual effort to improve a response-planning program:

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

The specific information regarding company operations, on-site equipment, and employees are continuously changing.  Accurate details of these modifications, expansions, and adjustments must be incorporated into the emergency response-planning program.  If the information contained within the plan is missing or out-of-date, the response will be hindered.  Additionally, necessary compliance data relevant to ever-changing regulatory requirements must be accurately applied in order to eliminate the potential for fines.

2. Training: Training programs that include properly trained personnel, guidance, documentation, and oversight help ensure compliance with agency regulations. These regulatory requirements are designed to prevent harm and ensure adequate responses to protect the public. However, companies should not rely on regulatory training requirements and agency inspections to ensure training programs are sufficient.

Companies need to perform cyclical internal training program audits to create corporate assurance, add EHS program value, improve operational safety, and ideally prevent harmful incidents from occurring. Objective internal auditing emphasizes corporate responsibility to employees, the environment, and the surrounding communities and can often reveal inadequacies and mitigation opportunities. Training audits can bring a systematic, disciplined approach to evaluating and improving the effectiveness of risk management, control, and corporate governance processes.

3. Exercises: Real world exercise scenarios can often highlight potential deficiencies in the response plan and procedures, comprehension of individual roles and responsibilities, and partnership coordination. However, it is through identified deficiencies that mitigation opportunities are revealed and valuable response knowledge and experiences can be attained.

Exercises provide a setting for operational response procedures to be tested. In preparation for these exercises, companies should develop exercise-planning documents, including participant 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.

4. Accessibility: Web-based response plans offer the greatest secured accessibility option for stakeholders, auditors, and inspectors while bolstering an entire emergency management program. With web-based technology and an Internet connection, response planning program information embedded with database driven software can be immediately and securely available without the “version confusion” typically found in other formats. Both paper-based plans and those housed on a company intranet are often out of date with multiple versions in various locations, potentially misinforming the response team.

5. Collaboration: Response planning program effectiveness can be optimized through effective interoperability: the ability for diverse organizations to work together for a greater good. Broadening the scope of response expertise can greatly benefit a facility by limiting the timeline of potentially escalating emergencies. Coordinating planning, training, drills, and resource availability with local agencies and responders is an important aspect of an effective environmental, health and safety program.

Local agencies may provide additional response knowledge based on particular research, experiences, or occupational training in a particular area of study. Emergency managers should continually meet with government agencies, community organizations, and utility companies throughout the entire planning cycle to discuss likely emergencies and the available resources to minimize the effects on the community.

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

7. Mitigation: Adverse conditions, unsafe activities, or ineffective responses pose risks to occupants, facilities, the environment, and/or communities. By eliminating or mitigating risks, companies can reduce the potential for emergency situations. The risk assessment process can be used to identify situations that may lead to incidents or prolong a response.

While all risks cannot be averted, a facility can become better prepared for disasters if the procedural risk mitigation measures are implemented. Mitigation measures may include a variety of tactics including, but not limited to training for employees, updating safety processes and procedures, or purchasing updated equipment.

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

Be prepared for your next incident! Click the image below to download your free guide.

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Response, Emergency Preparedness, Response Plans, Training and Exercises, Emergency Response Planning, Communication Plan

The Preparedness Secrets to Reducing Response Time

Posted on Thu, Apr 03, 2014

In emergency management, response time is critical. The faster an effective response can be initiated, the less chance of an incident escalating and adversely impacting the facility, employees, the environment, and a company’s reputation. Rapid incident response requires accurate communication, training, and exercises.

An accurate plan must be in place for optimal response times. Verification of contact information for company personnel, emergency responders, and agencies should be done on a periodic basis. Any delay in communication will increase response times, delay response actions, and exacerbate the potential impacts.

In order to react quickly, companies need to prepare response plans with flexible, yet pre-identified response strategies. It is critical that the emergency management framework, response measures, and communication strategies be tested and exercised before an incident occurs.

Response plan audits ensure detailed accuracy, plan applicability, and regulatory compliance. Throughout the audit process, a variety of aspects can be tested to ensure optimal response times. Certain elements to test include, but are not limited to:

  • Viability of communications systems (monthly)
  • Alerts, notifications, and activation procedures (quarterly) for all response personnel
  • Response equipment (monthly)
  • Accessibility of response plan
  • Primary and backup infrastructure systems and services
  • Plans for recovering vital records, critical information systems, services, and data
Most successful and timely responses result from a prepared strategy, with a cooperative understanding of response roles and responsibilities. Having a “real-time” incident management system in place may alleviate some of the shortfalls in response measures. However, employees and responders must be trained in response procedures in order to carry out expected actions. In order to limit response times, the following training and exercise concepts should be implemented:

TRAINING

  • Train employees on response roles and responsibilities
  • Conduct incident response orientations and briefings for the entire workforce
  • Train company leadership on response team organization and applicable functions
  • Train personnel on response plans and procedures
  • Allow opportunities for response personnel to demonstrate familiarity with the plans and procedures
  • Report documented training to applicable regulatory agencies

EXERCISES

  • Exercise physical security attributes at the site
  • Test internal and external interdependencies,  with respect to performance of critical response functions
  • Conduct exercises that incorporate deliberate response actions and measure overall response time
  • Conduct exercises using scenarios that involve evacuation, shelter in place, or virtual office accessibility
  • Demonstrate coordinated communications capability
  • Allow opportunity for continuity personnel to demonstrate their familiarity with the recovery and restoration procedures to transition from a continuity environment to normal activities

Coordinating planning, training, drills, and resource availability with local agencies and responders is an important aspect of an effective environmental, health and safety program. Broadening the scope of response expertise can minimize response time. Local agencies may provide additional response knowledge based on particular research, experiences, or training. Not only can response time be reduced, but also the overall duration of the incident.

Emergency managers should continually meet with potential response partners such as government agencies, community organizations, neighboring companies, and utilities companies.  Communicating with external alliances throughout the entire planning cycle can drastically reduce response time. Sources of local collaborative response efforts and plan management information may include:

  • Community Emergency Management office
  • Mayor or Community Administrator’s office
  • Local Emergency Planning Committee (LEPC)
  • Fire Department
  • Police Department
  • Emergency Medical Services organizations
  • American Red Cross
  • National Weather Service
  • Public Works Department
  • Telephone companies
  • Electric companies
  • Neighboring businesses

Companies that are required to maintain emergency response plans for regulatory purposes should consider the use of web-based response plans that integrate with real-time incident management systems in order to maximize their emergency response efforts.

Be prepared for your next incident! Click the image below to download your free guide.

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Tags: Tabletop Exercise, Emergency Response, Emergency Preparedness, Response Plans, Emergency Response Planning

Pro Tip: The Role of Templates in Response Plan Compliance

Posted on Thu, Mar 27, 2014

Emergency response plan templates often include the basic fundamentals of response planning. They should be utilized as a general outline for developing emergency response plans and a guide for regulatory compliance. However, response plans must also reflect the unique nature of  every company, facility, and operation. Consideration of site-specific details of each operation is important to ensure regulatory compliance.

In order for emergency response plan templates to be effective, specific facility information and operational hazards, as well as local, state and federal requirements must be addressed and included in plans. Industrial operations are required by law to institute site-specific emergency response plans and train employees in the appropriate level and method of response. Utilizing generic procedures from basic templates may result in  ineffective plans that are not in compliance with regulatory requirements.

By utilizing a template as an outline, companies can begin the process of creating  emergency response plans. 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. Below are twelve basic template topics that should be evaluated for site-specific applicability and implementation.

  1. Local, State and Federal regulations
  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

A plan template should be supplemented, at a minimum, with the following information:

Description of Facility Infrastructure and Summary of Physical Site Attributes:  Emergency response plans should include the following site-specific details:

  • Facility Name
  • Address
  • Latitude/Longitude
  • Contact Numbers
  • Key contacts
  • Site operations and equipment
  • Products handled
  • Number of employees
  • Nearby waterways.
  • Site drainage.
  • Details of tanks, pipelines, utilities, and other major equipment
  • Site security features, including fencing, visitor access, and lighting

Plan distribution list: Include the names and addresses of personnel who have plan copies

Key contacts: Identify all primary and secondary key contacts that may be included in a response. It is crucial to routinely verify contact information for accuracy. Key contacts may include 911, National Response Center, and internal and external response teams. Response equipment  suppliers should be identified

Alarm Identification and Notification Process:  Identification of  alarms that may signal an emergency, evacuation, or shelter in place. It is imperative to perform exercises with alarms to confirm they are in proper working condition and employees react accordingly. Ensure employees are trained in and understand  required notifications.

Key Staff Roles and Responsibilities: Job-specific checklists and procedures detailing responsibilities from initial response actions through demobilization.  It is a good idea to  provide training to at least two people per position in case primary team members are not available. It s helpful to:

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

Response Actions: Response action checklists for  for each potential scenario.  .

  • Perform a detailed hazard and risk analysis
  • Create response procedures for each identified threat
  • Identify hazard control applicability and methods
  • Detail external communications and public relations policies

Response Equipment: Major on-site and external response equipment should be itemized. Equipment availability and applicable contact information should be reviewed and verified. The consequences of a supply chain failure during a response  can severely limit effectiveness. Transportation delays could affect response equipment delivery times. Plan and mitigate accordingly.

Documentation Process: Accurate and detailed records of a response are imperative. Regulatory authorities may require specific response documentation. The burden of proof typically falls on the responsible party  when making insurance claims.

  • Create process for incident documentation
  • Utilize appropriate ICS Forms

Emergency Operations Center Location(s): Include location, address, contact info, available equipment, and any necessary external equipment for effective response operations.

Visual Aids: Include plot plans, evacuation routes, maps, and any other graphic displays that may aid in a response.

  • Identify multiple evacuation routes
  • Identify shelter in place areas
  • Identify the muster point(s)

Demobilization and Post-Incident Review: Specific demobilization guidelines provide organized and agreed-to procedures to help facilitate a more organized and expedited return to normal operating conditions, and help to minimize costs by standing-down response resources in a timely manner.

  • Create a checklist to identify demobilize gudelinesPerform a post incident review and debriefing
  • Document newly identified hazards and vulnerabilities
  • Identify  “lessons learned”  and action items
  • Update response plan accordingly

Templates should be populated with industry-specific, best practice response techniques. Once the initial emergency plan is completed, response plan audits, exercises, and consulting assistance may be required to confirm emergency plan compliance and effectiveness.

Interested in auditing response plans for effectiveness and compliance, download the "Audit Preparedness Guide for Industrial Regulatory Compliance".

Regulatory Compliance with TRP Corp

Tags: Testing, Resiliency, Response Plans, Regulatory Compliance, Emergency Response Planning, Safety

Consultants Combat Emergency Management Challenges: Oil and Gas Industry

Posted on Mon, Mar 24, 2014

According to the U.S. Department of Labor’s Bureau of Labor Statistics, the oil and gas extraction industry, as well as the petroleum and coal products manufacturing, accounted for the some of the lowest recordable occupational injury incident rates in private industry for 2011. But despite statistics, the industry’s public safety perception has been tested by highly publicized tragic incidents, increasing the pressures on emergency managers.

Preparedness planning and emergency management within the highly regulated energy industry requires expertise. Those who manage these programs face many challenges. Preparing for resilience requires planning, internal and external response coordination, training, and exercises. In addition to grappling with budget restraints, program managers are responsible for planning, regulatory compliance, and possibly responding to  emergencies. Implementing this level of company and facility resilience often requires external expertise or the services of specialized consultants.

Oil and gas emergency management program challenges may include:

  1. Maintaining multiple and complex response plans
  2. A lack of detailed site-specific response strategies
  3. Frequent personnel changes
  4. Evolving compliance requirements
  5. Regulatory audits
  6. Emergency management personnel who have other full-time responsibilities
  7. Minimal time available for training   
  8. Training
  9. Increased risk of regulatory penalties and fines
  10. Reduced budgets
  11. Gathering or verifying site-specific information for Oil Spill Response, Emergency Response, and SPCC Plans.
  12. Providing professional engineer certification for SPCC plans.
  13. Developing Oil Spill Tactical Plans for response strategies downstream of your facilities and pipelines.
  14. Developing response pre-plans for tanks, process units, and buildings,  and high angle and confined space rescue plans.
  15. Conducting emergency response assessments of personnel, response equipment, plans, and response contractors.

The ramifications of non-compliance or a hazardous incident can be exceedingly detrimental to oil and gas companies. As a result, many oil and gas companies utilize consultants to ensure their preparedness program levels match regulatory compliance requirements and best practice implementation. These specialized experts recognize that proven best practices and strict compliance reduces the inherent hazards associated with oil and gas operations.

TRP Corp - Oil and Gas Consultant

The costs associated with contracting consulting services are always in question. When hiring an external emergency management and preparedness consultant, oil and gas 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.

A consultant can improve safety performance and reduce the strategic cost of an incident by:

  • Reducing the overall number of incidents
  • Improving the ability to respond effectively
  • Improving the casualty and harm conditions through expedited responses and accident avoidance
  • Proactively showing intent and safety investment through the media and public
  • Helping reduce downtime
  • Improving asset utilization

In addition, the tactical cost of compliance can be reduced if a competent and proven consultant is contracted. A consultant can improve the tactical cost of compliance by:

  • Simplifying and automating tracking, updating, and management
  • Facilitating a universal ability to update response management plans across all locations and facilities
  • Automating core compliance and response planning activities
  • Reducing the compliance and safety resource requirements
  • Enabling EHS workers to spend time planning and performing vs. complying and reporting
  • Optimizing and coordinating drills, exercises, and actual emergency responses

Consultants can also provide assistance in responding to incidents or non-compliance issues. With each occurrence, vital proactive measures, including procedural and preparedness efforts, can be implemented in order to safely minimize future mandates, fines, accidents, and/or catastrophes.

Learn why Audits can minimize non-compliance, what documents should be reviewed, how they can imprive HSE programs: Download your Audit Preparedness Guide for Industrial Regulatory Compliance (click the image below):

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Tags: Choosing a Consultant, Facility Response Plan, Emergency Management, OPA 90, Emergency Response Planning, Workplace Safety

Tips for Up-To-Date and Compliant Response Plans: The Ongoing Challenge

Posted on Thu, Mar 13, 2014

Emergency planning is an ongoing process. Company operations, utilized equipment, and employees are continuously changing.  Modifications, expansions, and adjustments need to be incorporated into the emergency response plan to ensure compliance and an accurate and effective response in the event of an emergency. The ever-changing regulatory requirements and plan submittal processes must be observed and applied in order to eliminate the potential for fines.

Corporate emergency preparedness programs and applicable plans need to be reviewed, at a minimum, on an annual basis. However, plan reviews and potential updates should be conducted under the following situations:

  • Regulations deem changes are mandatory
  • An incident has occurred that highlights new best practices
  • A change in the status of current operations
  • A change in internal/external response capabilities
  • Changes to contact information
  • Company merger or acquisition
  • Site alterations/renovations
  • A vulnerability analysis reveals new risks/threats
  • A change in response resources/equipment

A concerted effort is being made in the emergency preparedness industry for companies to embrace new technologies and apply them to their environmental, health, and safety practices. The ability to streamline updates and share real-time incident information allows for a targeted, faster, and efficient response. It is crucial that first responders, company decision makers, and the emergency services community utilize rapid informational measures for situational assessments. However, if the information is out-of date, responders may be at risk, effective response decisions will not be implemented, and regulatory compliance may be compromised.

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

A methodological process should be applied to updating response plans. While tracking systems can itemize applicable federal, state, and local regulations, categorical information should be reviewed for accuracy. 

One of the most important aspects of maintaining up-to-date and compliant plans is to update the information in a timely manner. Cyclical response planning checks enable continuous reviews and potential revision opportunities, creating the most efficient and compliant response plan possible. Companies must be aware of the various submission requirements of applicable regulatory agencies regarding revisions and compliance.

Cyclical response plan reviews should include internal response plans and policies, and the following response areas for accuracy and effectiveness:

  • Safety and health procedures
  • Evacuation plan
  • Fire protection plan
  • Environmental policies
  • Security procedures
  • Response procedures
  • Communication Plans
  • Employee manuals
  • Business Continuity plan
  • Risk management plan
  • Hurricane/Tornado/Flood Plans
  • Mutual aid agreements

The review of company emergency response planning documents should include updates from collaborating response groups. Open communications with internal and external responders will ensure plan and response procedures are current, and carried out in accordance with company protocol. Groups to consider in planning reviews include, but are not limited to:

  • Local responders fire, police, emergency medical services)
  • Government agencies (LEPC, emergency management offices, etc)
  • Community organizations (Red Cross, weather services)
  • Utility company(s) (gas, electric, public works, telephone)
  • Contracted emergency responders
  • Neighboring businesses

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

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Tags: Testing, Business Continuity, Emergency Preparedness, Response Plans, Regulatory Compliance, Emergency Management Program, Emergency Response Planning

Securely Share Response Plans with Inspectors, Responders, and Auditors

Posted on Mon, Mar 10, 2014

Industrial facilities are vulnerable to innate risks, targeted threats, and security breaches. These vulnerabilities vary according to the location, site characteristics, operations, and hazards. Site-specific response plans are often required by regulatory agencies to address these vulnerabilities.  To counteract potential incidents relating to vulnerabilities and comply with government mandates, response plans are shared with regulators, auditors, inspectors, and responders. However, in order to minimize additional vulnerabilities, applicable confidential information should be secured from unauthorized individuals.

Response Plans must be shared, but information security must be a priority. There are generally three basic means to share response plans with recipients.

1) Paper plans

Long before tablet computers and smart phones, companies composed and shared binder-bound response plans. These plans, which are still used in large numbers today, were/are mailed to agencies, printed for auditors and inspectors, and reproduced for response stakeholders. Paper plan accessibility is limited to physical distribution tactics. This traditional concept may not provide the security measures necessary for the modern world. Paper plans share the following common pitfalls, possibly rendering non-compliance and an ineffective response.

Paper plans are often:

  • Inaccessible: Most plan users will only have a paper copy and will not carry it wherever they go. Because of the lack of accessibility, it is often difficult for a program managers to know when plans were last updated, or approved by regulatory agencies.
  • Inefficient: Repeated information updates, especially in multiple plans, is time consuming There are often duplicate or overlapping information requirements from one plan type to another, and for multiple facilities.
  • Out of date: Having multiple versions of plans in various locations leads to version confusion. It is often difficult to determine and document when company, site, or personnel information has changed. Example: Corporate emergency manager's contact information may reside in many plans. If/when that person's contact information changes, it has to be physically changed in each plan.
  • Inconsistent:  Plan formats usually vary from one facility to another, making it difficult to manage training and compliance efforts.
  • Cumbersome: A company may have multiple plan types, documents, and records for various regulatory agencies. During an audit, inspection, or response, the pure physicality of paper plans can be hindering.

2) Intranet-based plans

Some companies host response plans on their local intranet, or company network. These plans can often be accessed remotely through a Virtual Private Network (VPN). In order to establish a VPN connection with a company's server, the endpoints are typically authenticated to secure access. Plans can be shared through a VPN connection, potentially expanding the accessibility to approved viewers.

Secured access has been historically accomplished through passwords, personal data advanced biometrics, or a combination of security means. Once the connection is made, authorized individuals should be able to securely access a company's network. However, as recent headlines have revealed, company networks are often vulnerable to hackers, data breaches, and network attacks, potentially exposing private company information and broadening vulnerabilities. Companies must prioritize network security, especially when response plans are hosted within this critical business function.

In a variety of scenarios or in the event of an emergency, company servers may be inaccessible; rendering responders ill informed when response information is needed most. It is imperative to regularly back up response data and establish an alternate means to retrieve necessary response information in the event that site and/or company network is involved in the incident. 

Although plan accessibility may be improved with an intranet system, the plans may still be subject to some of the same pitfalls as paper plans:

  • Inaccessibility
  • Inefficient
  • Inconsistent

Efficiency and consistency across multiple plans remains challenging and time consuming when documents utilize separate static word-based files.

3) Web-based plans

As mobile technology advances and becomes more commonplace, many companies are beginning to realize the benefits of web-based emergency response planning systems. Web-based emergency response planning systems offer secured, immediate, and direct access to your emergency response plans from any computer. Since company response plans are no longer stored in a single, centralized location, the risk of inaccessibility, loss, or damage of these critical records in an emergency situation is minimized. More importantly, since every member of your team can easily locate and navigate your emergency response plans at a moment’s notice through a password protected website, your incident response time and management capabilities improve dramatically.

For organizations with multiple facilities and locations, web-based response planning provides site-specific emergency response plans that integrate seamlessly with your organization-wide procedures and policies. This optimizes the opportunity for every location to remain in compliance with state, federal and municipal regulations.

Response plans that utilize an informational database, plans securely open to the latest plan version, providing ability for plans to be shared or printed for auditor analysis and inspectors’ review.

Some benefits of a web-based business continuity system include:

  • Instantaneous Accessibility: A web-based planning system software offers every option of instant accessibility:
    • Viewed via the Internet from any location
    • Downloaded
    • Printed.

Web-based response plans increase accessibility options while improving efficiency, functionality, and effectiveness.

  • Efficiency: The most advanced web-based software programs utilize a database, allowing for repetitive information to be duplicated in all plan types across an entire enterprise. By minimizing administratively tasking duties, plan changes are more likely to be performed, thereby improving accuracy of the plans. Web-based plans can provide hyperlinks, forms libraries, simplified interfaces, and other tools designed to improve functionality for plan users.
  • Instantaneous Updates: Revised information is immediately available to all stakeholders. Web-based, database driven plans utilize one database to manage this information, effectively leveraging plan revision efforts to all plans that utilize that data.

Web-based response plans offer the greatest secured accessibility option for stakeholders, auditors, and inspectors while bolstering an entire emergency management program.

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Tags: Resiliency, Response Plans, Incident Management, Redundant Systems, Regulatory Compliance, Emergency Response Planning, Information Security

The Facility Response Plan Annual Review

Posted on Mon, Feb 10, 2014

A facility response plan is only as effective as the information it contains and the comprehension of those utilizing the plan. As facility specifics change, response plans must change accordingly. Fundamental regulatory compliance, inherent site-specific safety issues, human resource factors, and a company’s reputation obligate specific response planning requirements for a facility. Cyclical plan maintenance is essential in order to capture multiple moving parts that impact an emergency management program.

The response plan should be reviewed annually, at a minimum. Plans should evolve as lessons are learned, new information and insights are obtained, and operational priorities are updated. Utilizing a web-based, database driven planning system simplifies the update process, despite location of influential parties. An annual review enables practical opportunities to minimize or eliminate incidents, the ability to provide “mission accomplished” in the event of an incident, and mandated regulatory compliance. The planning review cycle typically corresponds to the criteria laid out by the associated regulatory agencies; however, internal corporate policy may dictate multiple reviews throughout a fiscal year.

Decision-makers directly involved in the plan review process can determine its effectiveness and efficiency by its adequacy, feasibility, and acceptability, along with responders’ understanding of plan requirements. The plan review can also address present and future risks, and define potential response costs. According to FEMA, there are five commonly used criteria to determine the effectiveness and efficiency of response plans.

Adequacy: Emergency managers should apply their experience, judgment, intuition, situational awareness, and discretion to ensure a plan is adequately suited for a facility’s identified hazards. FEMA defines a plan as adequate if:

  1. The scope and concept of planned operations identify and address critical tasks effectively
  2. The plan can accomplish the assigned mission while complying with guidance
  3. The plan’s assumptions are valid, reasonable, and comply with guidance.

Feasibility: The established response procedures should be rigorous enough, yet standardized, to minimize subjectivity or interpretation, and preclude oversights in order to accomplish the assigned mission and critical tasks. This should be accomplished by using currently available resources within the minimum time frame set forth by the plan. Available resources include internal assets and those available through mutual aid, private contractors, or through existing state, regional, or Federal assistance agreements.

Acceptability: The plan meets the requirements driven by a threat or incident, goals set by decision makers, budgetary restraints, response time limitations, and abides by applicable law(s).

Completeness: The plan includes all applicable and effective emergency procedures with estimated response times, required capabilities, needs of the population, and identified success criteria. All information, including contact information, should be updated and accurate.

Compliance: The plan should comply with all internal and external guiding doctrine within the boundaries of the presiding law(s). Failure to comply with regulations can result in additional financial burdens resulting from fines, negative public perception, and possibly government-mandated shutdown of operations.

According to FEMA’s Comprehensive Planning Guide, there are six key steps in developing effective response plans. An annual review can incorporate these steps to verify the five commonly used criteria to determine the effectiveness and efficiency of emergency plans. At each step of the review, emergency managers should consider the impact on required training, exercises, and equipment costs and availability.

Step 1: Collaborative Teamwork

  • Identify and verify the facility response planning team. Typically this includes an emergency manager or security manager, a hazard mitigation expert, local jurisdictions, and any additional available planning experts.
  • Engage essential personnel in the review process to identify changes in capabilities and resources.

Step 2: Understand Potential Situations

  • Identify any new or altered threat and/or hazard: Geographic and facility hazards and risks can be broken down into four areas:
  1. Natural Hazards
  2. Technological Hazards
  3. Chemical Hazards
  4. Human Hazards
  • Assess Risk: Assign probability values to new or altered threats and hazards for the purposes of determining priorities, developing processes and procedures, and allowing for informed decision-making.

hazardous_waste_TRP.jpg

Step 3: Determine Goals and Objectives

  • Identify Altered Operational Priorities: Specify goals and objectives desired for emergency responders, employees, and facility, and define a success for each operation.

Step 4: Plan Update

  • Develop and analyze procedural options based on current best practices, lessons learned, and regulatory updates.
  • Participants should add necessary supporting information, graphics, and/or photos taking note to comply with local, state and federal regulations.
  • Identify current internal and external resources necessary to fulfil requirements, response obligations, and assignments.
  • Emergency managers should identify any changes or updates to the information necessary to drive response decision-making and trigger critical response actions.

Step 5: Plan Approval and Distribution

  • Senior management and, in some cases, associated regulatory agencies typically grant emergency plan approvals.  Once changes are approved, the plan should be distributed to appropriate individuals/ organizations.
  • A record of the individuals/ organizations that received a copy (or copies) of the plan should be maintained.

Step 6: Plan Implementation & Maintenance

  • Exercise the updated plan: Evaluating the effectiveness of plans involves a combination of training events, exercises, and real-world incidents to determine whether the goals, objectives, decisions, actions, and timing outlined in the plan can lead to a successful and effective response.
  • Planning teams should evaluate the process for reviewing, revising, and distributing the plan. A web-based, database driven planning systems eases the administrative burden and applicable costs associated with implementing, maintaining, and distributing response plans. Plan maintenance should be an ongoing and recurring activity.

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Tags: Facility Response Plan, Emergency Preparedness, Response Plans, Facility Management, Emergency Response Planning, Workplace Safety