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New Preparedness Guidelines for Medicare & Medicaid Facilities

Posted on Thu, Nov 17, 2016

The previous Medicare/Medicaid emergency preparedness regulations lacked the necessary comprehensive approach to account for the complexities of emergency preparedness. In particular, the previous regulations did not address the need for:

  1. Communication to coordinate with other systems of care within cities or states
  2. Contingency planning
  3. Training of personnel

As a condition of participation in Medicare and Medicaid, these health care providers must comply and implement all regulations within one year of the effective date, most likely by the end of 2017. Participating providers and suppliers must meet the following four common and well known industry best practice standards.

1. Risk Assessment and Emergency Planning: Based on a risk assessment, facilities must develop an emergency plan using an all-hazards approach, focusing on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters specific to the location of a provider or supplier. A risk assessment and subsequent response procedures may include, but are not limited to:

  • Hazards likely in geographic area
  • Care-related emergencies
  • Equipment and Power failures
  • Interruption in Communications, including cyberattacks
  • Loss of all/portion of facility
  • Loss of all/portion of supplies
  • Plan is to be reviewed and updated at least annually

medical_facility_preparedness.jpg2. Communication Plan: Facilities must develop and maintain a communication plan that complies with both Federal and State law. Patient care must be well-coordinated within the facility, across health care providers, and with State and local public health departments and emergency systems. The communication plan must:

  • Comply with Federal and State laws
  • Include a systematic process to contact staff, including patients’ physicians, and other necessary persons.
  • Provide a well-coordinated communication plan within the facility, across health care providers, and with state and local public health departments and emergency management agencies.

3. Policies and Procedures: Facilities must develop and implement policies and procedures based on the plan and risk assessment to comply with Federal and State laws.

4. Training and Testing: Facilities must develop and maintain training and exercises that comply with both Federal and State law. Patient care must be well-coordinated within the facility, across health care providers, and with State and local public health departments and emergency systems.
In order for health care facilities to remain compliant and evaluate and elevate preparedness levels, response plans must be tested for response readiness. A web-based exercise management system provides authorized users with secure access from a variety of locations. As facilities are added or modified, operations are revised, or employees are re-assigned, records can be conveniently added, accessed, transferred, or updated for accuracy and compliance. A comprehensive, web-based exercise management system will:

  • Reduce the need for multiple site training management and documentation
  • Minimize administrative costs
  • Minimize training discrepancies across an enterprise
  • Provide a historical record of training certifications
  • Streamline training directives from one source
  • Serve as a legal instrument, if necessary
  • Engage management in prioritizing preparedness efforts
  • Enhance reporting functionality
  • Identify regulatory compliance training gaps

The path to preparedness and recovery is often complicated by abundant information, overlooked linked processes, and static plan formats. Managing several disparate systems and multiple paper files is cumbersome and time consuming, especially in the midst of an emergency situation. When health care companies with multiple sites utilize web-based tools and streamlined methods, preparedness and response planning management can be streamlined.

Corporate Crisis Management

Tags: Event Preparedness

Make 2015 "The Year of Response Planning and Preparedness"!

Posted on Thu, Jan 08, 2015

While it is more cost efficient and less complicated to learn from other's response experiences and emergency management mistakes, every emergency scenario, exercise, or training endeavor can be used to improve the outcome of the next response. As we begin 2015, facility and emergency managers should draw from personal experiences, staff knowledge, and industry-wide lessons learned to improve their preparedness and response program.

The following discussion points, while not all-inclusive, can be used to spur emergency management program improvements and response planning reformations for 2015:

Compliance

  • What agencies and new or impending regulations apply to my location(s)?
  • Have budgets been allocated for necessary compliance mitigation resolutions?
  • If applicable, have Globally Harmonized System (GHS) Safety Data Sheets (SDS) been updated and have their properties been included in the planning process?
  • Has an inspection taken place, and if so, have non-compliant issues been mitigated?
  • Will an internal compliance audit(s) be conducted?
  • Is personnel training up-to-date and compliant with site-specific requirements?
  • Are required exercises scheduled?

Risk Assessment

  • What are the new high-risk, medium-risk, and low risk-activities or circumstances, and are how will these scenarios relate to planning?
  • Can high-risk tasks or conditions be mitigated with the current budget? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Are there additional environmentally sensitive areas that need to be addressed in the response plan?
  • Does the risk assessment utilize realistic scenarios to define potential spill volumes and downstream locations?
  • How will employees be made aware of hazards associated with specific workplace process, materials, or location(s)?

Supply Chain

  • When will response equipment needs be re-evaluated and defined?
  • Are there new technologies or equipment that will better suit your program's equipment needs?
  • Will current vendors have predefined supplies or equipment available in the event of an operational disruption or emergency scenario, or do new suppliers need to be evaluated?
  • Are processes in place to monitor internal and external supply chains and their response time?
  • Is additional or alternate external spill response support necessary and available?
  • How would a spill affect both internal and external resources?
  • Are back up suppliers identified, and when will their availability be confirmed?

Training

  • Are current personnel appropriately trained for their allocated roles?
  • Are new employees being trained effectively?
  • Do new training measures need to be implemented?
  • Will training comprehension be tested with realistic exercise scenarios?
  • Is the response management team structure clear and able to be communicated?
  • Will external responders included in plan preparations and exercises receive a copy of the current plan?
  • Have post exercise review mitigation measures been applied to current training and preparedness measures? If not, when will these tasks be completed?
  • Should training include any new resource tracking documentation methods, software, or amended response communication actions?

Response Elements

  • If an incident were to occur today, would your response plan minimize impacts and be a guide for an effective and coordinated response effort?
  • Is a process established for individual responders to verify their contact information to allow for timely responses? If not, can verification process improvements be made to ensure accuracy?
  • Are clear initial response action procedures in place to notify, assess, and initiate a response?
  • Can approved stakeholders easily access response plans? Have you researched innovative technology that allows for improved plan access?
  • Have response times and limitations been confirmed? Have they changed from the previous plan revision?
  • Does the current response plan address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been upgraded? If so, have these changes been addressed in the plan.
  • Are new or additional communications backup systems available and described in the plan?
  • Are there new staff roles, personnel, or modified internal or external responsibilities that need to be specified in the plan, and communicated to responders?
  • Are there alternate strategies and response procedures that need to be included in the plan?
  • Are updated processes and procedures identified in the plans to assess and monitor size, shape, type, location, and movement of a spill or release?
  • If applicable, have tactical response details been included in the planning process for incidents that expand beyond the confines of the facility? Are there any changes that need to be incorporated?
  • Do trajectory maps and estimates mimic local observations and historical tendencies?
  • Are sensitive sites prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes communicated?

Documentation

  • Are sufficient processes established for updating planning information prior to an emergency and during a response?
  • Have plot plans and area mapping been integrated with the latest GIS data and knowledge?
  • Are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), updated and in place? Are there new MOUs or contracts that need to be established or finalized?
  • Do stakeholders have a copy of your most up-to-date plans?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible to auditors?
  • Are necessary Incident Command (ICS) and company-specific forms readily available for documentation?

By analyzing the past, monitoring the present, and evaluating the “potentials” of 2015, companies can reinforce their commitment to emergency management while establishing a culture of preparedness. Executing plan enhancements and reinforcing preparedness across an enterprise strengthens a company’s resolve, ultimately creating a more resilient organization.

 

Ensure preparedness and compliance! Download this free guide by clicking the image below:

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Management, Response Plans, Oil Spill, Event Preparedness

Corporate Crisis Management Plans and Team Roles

Posted on Thu, Dec 18, 2014

Corporate crises come in a variety of forms, ranging from social media glitches to mass casualty situations. Regardless of the circumstances, every crisis has the potential to negatively impact a company’s short and long-term reputation, daily operations, and financial performance. Resolutions require a prepared crisis management plan with flexible, yet pre-identified responses and actions. Informative communication and proactive, actionable procedures can minimize the impacts associated with corporate crises.

“It takes 20 years to build a reputation and five minutes to ruin it. If you think about that, you’ll do things differently”. -Warren Buffett

A properly developed and implemented crisis management plan can result in:

  • Crisis resolution
  • Continuation of business as usual
  • A preserved, or possibly enhanced corporate reputation
  • Financial sustainability

It is critical that a basic crisis management planning framework, response measures, and communication strategies be established and exercised before a crisis actually occurs. Most successful responses result from a prepared strategy, with a cooperative understanding of the incident, response roles, and assigned responsibilities. Since each crisis is unique and comes with varying degrees of impact, each crisis must be evaluated and resolved individually based on:

  • The potential impact on current and potential clients and customers
  • The potential impact to employees and the company
  • Stakeholders interested in the outcome of the incident
  • The level of control the company has over the situation
  • Complexity of the crisis and specialists required

A crisis management team (CMT) may be activated for any situation that involves a threat to people or property, a business interruption that could have a negative financial impact, or an incident that may result in damage to the company's reputation and/or financial well being. CMTs, often comprised of a small group of senior managers, typically respond, coordinate, and set necessary actions in play according to the specific crisis situations. The team members should be trained to manage an array of potential crises, additional risks and exposures, and management stakeholder interests.

Depending on the crisis planning and crisis management requirements, the following CMT roles may provide a company with the essential functions necessary to manage crisis situations.

  • Crisis Manager: Approves the Crisis Management Plan and provide overall leadership
  • Security Manager: Reviews and revises the plan on necessary security related procedures
  • Public Affairs Advisor: Participates in all aspects of Crisis Communications
  • Medical Advisor: Assess and assists in human health impacts of crises
  • Human Resource Advisor: Maintains a current, accessible contact list of all employees, contract employees, and responders
  • Health, Safety, Security, and Environmental Advisor: Coordinates the implementation, training, and updating of Incident Response Plans
  • Legal Advisor: Ensures the availability of legal representative related to crises
  • Crisis Management Advisor: Supervises and coordinates necessary CMT support roles.  Individuals may be assigned to work directly under any core CMT position to fill a specific need. Support roles may include:
    • Aide(s): Administrative resource(s)
    • Business Unit Advisor(s): Anticipates Business Unit issues, develops strategic plans to proactively address these issues, and adjust staffing of Business Unit Group and to suit evolving needs
    • Subject Matter Expert(s): Be available to assist crisis manager on as “as needed” basis.

If the crisis warrants, the pre-identified crisis team would be responsible for developing media strategy, public statements, and key messages, as well as identifying and briefing one or more spokespersons to deliver the pre-approved messages to media outlets. A specific individual or individuals should be assigned to media/public relations to ensure messaging consistency and information availability.

While the specific circumstances will define a crisis response strategy, basic communications processes typically remain consistent. Companies must be tuned into the vast digital network of social chatter. Viral rumors and antagonistic communications can often be inhibited with a timely, factual, and proactive crisis communications campaign.

For a free download on crisis management, click here or the image below:

TRP Corp - Emergency Response Planning Crisis Management

Tags: Resiliency, Crisis Management, Facility Management, Event Preparedness

Be Ready with Hats, Gloves, and Business Continuity Plans

Posted on Mon, Nov 17, 2014

Winter is rushing in with a vengeance this November. But it wasn't too long ago that the meteorological term “Polar Vortex” was indoctrinated in the minds of millions across the United States. In January 2014, arctic temperature plummeted unusually south and two-thirds of the nation was paralyzed by record breaking cold. Will we have another Polar Vortex-filled winter that impacts businesses across the country?

According to Evan Gold, Senior Vice President at Planalytics, a business weather intelligence company, January’s polar vortex resulted in a $50 billion economic disruption, the most delivered by a weather phenomenon since Superstorm Sandy in 2012.

Severe weather habitually effects routine business operations and profitability. Weather can be the culprit of power outages, dangerous temperatures, supply disruptions, safety hazards, and potentially impair access to key infrastructures. The January 2014 events, which impacted nearly 200 million people, is one of the many examples of how severe weather affects operational continuity.

As we begin another winter season, companies should perform a business impact analysis (BIA), a precursor to a business continuity plan. The process of a BIA allows for targeted recovery strategies to be developed in the event of an emergency. A BIA should be utilized to identify likely consequences of critical business process disruptions.

After each critical business process is identified, the potential impacts resulting from loss of facilities and/or necessary infrastructure, personnel, or supply chain can be examined for each process. Key minimum recovery components along with incremental recovery time objectives should be detailed for each critical area identified. The following components should be evaluated for each critical business process.

  1. Recovery Time: Identify how long it would take to recover a specific critical process under scenario specific circumstances.
  2. IT requirements: If electronic data must be available to recover specific processes to a minimum service level, identify the necessary requirements.
  3. Data Backup History: Indicate how old the data can be to satisfy recovery (i.e. last weekly backup, last monthly backup, last quarterly backup, etc.) and review recovery methods.
  4. Review alternate location options: Identify needs and review options for off-site backup processes.
  5. Staffing minimums: Identify needs throughout recovery time objectives to optimize recovery.
  6. Impact Level: Indicate how severely the process would be impacted considering current/existing mitigation measures (ex. minimal, somewhat severe, severe).
  7. Likelihood Level: Indicating how likely each specific threat could occur considering current/ existing capabilities, mitigation measures, and history.

Timely recovery also depends on specific preparedness and planning initiatives. Establishing processes, training employees, and restocking necessary equipment can drastically reduce the overall potential damage to operations and the financial bottom line. In order to minimize the effects of severe winter weather on continuity, preparedness protocols should be established. Depending on location and specific operations, these protocols should include, but are not limited to the following:

  • Monitor news and weather reports on television or the radio (with battery backup)
  • Alert employees or others on-site that severe weather is approaching and communicate expectations
  • Be aware of the dangers posed extreme temperatures, and ice and snow falling from equipment and buildings; mediate if possible
  • Identify infrastructure dangers posed by cold weather on exposed piping (hazardous releases, flooding, etc)
  • Prepare and insulate exposed piping
  • Winterize and shut off landscaping sprinkler systems
  • Contract snow removal services or obtain the necessary equipment (snow shovels, ice scrapers, rock salt, tire chains, etc.)
  • Ensure that company vehicles have a full tank of gas and are functioning properly (heater, deicing fluid, antifreeze levels, windshield wipers)
  • Ensure flashlights are in proper working order and have additional batteries on site.
  • Monitor ice and snow accumulation on any on site tanks, sheds, or buildings and identify non-hazardous procedures for mitigation.
  • If necessary, obtain generators to re-power facilities or necessary equipment
  • If appropriate, leave water taps slightly open so they drip continuously to prevent pipes from freezing.
  • Understand and implement cold weather response techniques when responding to product spills as released product may flow under ice or snow.
  • Establish and maintain communication with personnel
  • Consider limiting vehicle traffic
  • Maintain building temperature at acceptable levels and understand safety measures if using space heaters.
  • Notify supervisors if facility(s) loses power or is otherwise unable to operate

Preparedness and Emergency Management - TRP Corp

Tags: Business Continuity, Event Preparedness, Extreme Weather

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.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

 

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

An Expert Guide to Demobilization and Post-Incident Recovery

Posted on Mon, Apr 28, 2014

Pre planning for demobilization and post-incident recovery allows for a collaborative understanding of necessary recovery elements and critical business unit restoration processes. Recovery objectives should include the meticulous restoration, strengthening, and revitalization of the site, surrounding infrastructures, and operations.

Disaster response operations should prioritize timely and accurate communication to facility managers, critical decision makers, emergency response teams, stakeholders, vendors and contractors, and, if applicable, the public in order to accelerate recovery without duplicating efforts. Once the response is concluded, specific demobilization guidelines provide “agreed-to procedures” to help facilitate a more organized and expedited return to normal operating conditions.  

The process of standing down response resources in an efficient and timely manner provides considerable cost benefits.

Issues to consider for demobilization include:

  • The On-Scene Incident Commander should approve the release or demobilize of response resources prior to initializing the process
  • Assign personnel to identify surplus resources and probable resource release times
  • Establish demobilization priorities based on the specific incident
  • Verify established decontamination procedures and necessary resources are available
  • If necessary, develop/communicate a Disposal Plan for the disposal of hazardous materials or wastes, as necessary.
  • Identify personnel travel needs and coordinate travel arrangements, as necessary.
  • Plan for equipment repair, decontamination, maintenance services, and inspections, as necessary
  • Initialize impact assessments and post-incident reviews

Even as the site response is being demobilized, responders must maintain heightened safety awareness. Any incident that extends beyond normal operating procedures may require a recovery plan component. The ability to institute a successful recovery plan requires stakeholders to maintain a clear understanding of post-disaster roles, responsibilities, and objectives. These components may include, but are not limited to:

RECOVERY PLANNING

  • Coordinate development, training, and exercise of the disaster recovery plan.
  • Establish and maintain contacts/networks for recovery resources and support systems.
  • Promulgate principles and practices that perpetuate resiliency and sustainability

RECOVERY OPERATIONS

  • Assess damage
  • Verify facility accessibility and safety
  • Identify internal and external recovery team contacts and contractors
  • Identify the scope of work for repair
  • Development of site specific plans and schedules for executing repairs
  • Restoration of operations
  • Institute mitigation measures
  • Identify “lessons learned” through post-incident reviews

Once the recovery period begins and/or appears that it will extend beyond the recovery capabilities of the facility, the Incident Commander should be responsible for the following:

  • Lead the creation and coordinate the activities of local recovery-dedicated organizations and initiatives.
  • Work with the federal, state, and local agency coordinators to develop a unified and accessible communication strategy.
  • Participate in damage and impact assessments with other recovery partners.
  • Organize recovery-planning processes to fully engage stakeholders and identify recovery objectives, priorities, resources, capabilities, and recovery capacity.
  • Ensure inclusiveness of the community in the recovery process through media and public relations efforts
  • Continually communicate recovery priorities to government liaisons, recovery stakeholders, employees, and the community.
  • Incorporate critical mitigation, resilience, sustainability and accessibility building measures into the recovery plans and efforts.
  • Lead the development of the facility’s recovery plan(s) and ensure that they are actionable and feasible based on available funding and capacity.
  • Collaborate with State, Federal and other stakeholders to identify external financial support for recovery, leverage the resources where possible and resolve potential duplication of assistance.
  • Work closely with the recovery leadership at all levels to ensure a well-coordinated, timely, and well-executed recovery.
  • Develop and implement recovery progress measures and communicate adjustments and improvements to applicable stakeholders and authorities.

The primary purpose of post-incident reviews is to identify deficiencies in the response plan and determine necessary actions to correct the deficiencies. The post-incident reviews can often reveal which response procedures, equipment, and techniques were effective, and which were not and the reason(s) why. These reviews can lead to “lessons learned” and should be reflected in the response plan, training efforts, and exercise objectives.

At a minimum, post-incident review checklists should include:

  • Name and typical duties of personnel being debriefed
  • Date, time and whereabouts of employee during incident
  • Actions taken during incident
  • Positive aspects of how the response occurred
  • Aspects identified for improvement

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

Preparedness and Emergency Management - TRP Corp

Tags: Incident Action Plan, Emergency Management, Emergency Preparedness, Incident Management, Event Preparedness

2 Tips for Simplifying Future Regulatory Compliance Audits

Posted on Thu, Mar 06, 2014

The goal of performing gap analyses, audits, and regulatory inspections is to minimize the potential for emergency incidents, ensure regulatory compliance, and streamline response actions. Maximizing safety standards and processes, and implementing “best practices” should be part of a company’s core ethical principles, even when law does not mandate them.

In order to simplify future audits, companies should become familiar with the following two key concepts:

  1. Industry Best Practices
  2. Regulatory Recognition

Companies should not rely on the prospect of a regulatory agency inspection to ensure preparedness programs are sufficient. Your facility’s innate problems are most likely shared with others within your industry. Companies can be guided on how to approach a problem or implement a solution by researching applicable best practices. Often, the expertise and knowledge that drove the best practices into existence stems from the emergency response experiences of others and their motivated efforts to address the inherent problem(s).

While companies may not need to “reinvent the wheel” when it comes to safety and response procedures, facilities need to confirm that the best practices apply to their site-specific situation.  There are numerous industry-specific best practices within safety, preparedness, and response planning. Additionally, each facet of a company’s operations can be broken down to examine specific best practices for a particular action, material, scenario, or site circumstance.  For example, best practices exist in the following areas:

  • Pre-incident planning
  • Training
  • Exercises
  • National Incident Management System
  • Security
  • Fire brigades
  • Rescue
  • Hazardous materials handling/response
  • Fire loss prevention
  • Evacuation
  • And more

To identify applicable best practices, companies must identify site and operational risks and associated necessary responses. Each facility should be analyzed for potential risks and/or hazards. Once hazards are recognized and evaluated, they should be eliminated or controlled through mitigation and/or procedural planning. Identified site characteristics, countermeasures, and response efforts should be included in required regulatory plans.

In order to attain compliance, applicable regulations must be recognized. Regulations must be recognized in order for a gap on processes, procedures, or responses to be identified. Regulatory recognition can occur through routine inspections, job hazard analyses, and audits. Facility managers, and company health, safety, and environmental managers should become familiar with regulations applicable to their area of responsibility .  These individuals, or a consultant with specialized industry and regulatory experience, should identify all applicable regulations based on location, industry, operations, hazards, and response specifics. According to FEMA, companies should review applicable regulations relating to the following areas:

  • Employee Safety & Health:  Emergency action plans are one of the OSHA standards that apply to many employers with 10 or more employees. Other regulations pertain to means of egress (exits), medical services, hazardous waste, confined spaces, fire protection, firefighting and more.
  • Environmental Regulations: Businesses that manufacture, treat, store, or dispose of hazardous chemicals that exceed threshold quantities may be required to comply with multiple environmental regulations.
  • Business Continuity and Information Technology: Businesses that store customer contacts and financial information, such as credit card data, may have to comply with information security regulations. Companies should remain in communication with their specific industry trade group or state office of economic development for applicable regulations.
  • Life Safety and Fire Codes: Life Safety codes are designed to ensure that building occupants can be safely evacuated if there is a fire or other emergency within a building. Fire prevention codes specify requirements for fire safety.

Audits, whether done by in-house professionals or specialized contractors, can often reveal the same inadequacies and mitigation opportunities as regulatory inspections, without the potential reputational and financial consequences of non-compliance. . With an objective eye, an audit can bolster an overall emergency management program and minimize the chance of impeding incidents or regulatory fines.

For a free white paper on how audits can assist your company with regulatory compliance, click the image below:

Regulatory Compliance with TRP Corp

Tags: Emergency Management, Emergency Preparedness, Regulatory Compliance, Facility Management, Emergency Management Program, Event Preparedness

Administrative and Logistical Considerations in Response Planning

Posted on Thu, Dec 05, 2013

Corporate emergency preparedness can be defined as the preemptive activities that establish a state of readiness to effectively respond to events that could affect the health and safety of employees, facilities, the environment, and/or the community. These actions, which ideally consist of planning, training, equipping, exercising, evaluating, and mitigating, are required to sustain operational capabilities, despite a range of incident management scenarios.  It is the goal of corporate preparedness to protect individuals, the integrity and functionality of infrastructures, and viability while minimizing the adverse operational impacts of events.

Many aspects of preparedness rely on underlying administrative duties and associated response plans. According to the Department of Homeland Security (DHS), preparedness plans are meant to describe how personnel, equipment, and other governmental and nongovernmental resources will be used to support incident management requirements. These plans represent the operational core of preparedness and provide mechanisms for:

  • Establishing priorities
  • Implementing response functions
  • Integrating multiple entities
  • Establishing collaborative relationships
  • Ensuring communications systems and procedures support incident management activities

There are a wide range of administrative actions associated with achieving a state of preparedness and attaining response goals.  In particular, documents or response plans written prior to the emergency allow for comprehensive review of procedures that may result in improvements in plan and response to actual emergency scenarios. A variety of regulatory authorities govern most aspects of company preparedness administrative procedures and practices.  These requirements may be dictated by company policy, local, state, and/or federal governmental agencies.

A typical response planning process requires ample time for the administrative duties. These duties may encompass details associated with hazard identification, review of plan drafts, exercising the plan, integration of mitigation efforts, training evaluations, and plan distribution. In addition to a yearly review, plan modifications may require administrative efforts:

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

Prior to an incident, required corporate preparedness administrative duties and actions may include, but are not limited to, the following:

  • Establishing a written emergency management plan
  • Maintaining training records
  • Mitigation efforts communication and documentation
  • Documenting training, exercises, and associated critiques
  • Communicating with emergency response organizations during planning activities. 
Administrative actions during and after an emergency may include:
  • Maintaining telephone logs
  • Keeping a detailed record of events
  • Maintaining a record of injuries and follow-up actions
  • Accounting for personnel
  • Coordinating notification of family members
  • Issuing press releases
  • Maintaining sampling records
  • Managing finances
  • Coordinating personnel services
  • Documenting incident investigations and recovery operations
  • Response plan maintenance
  • Regulatory submittals

Preparedness administrative duties are often the responsibility of an environmental, health and safety (EHS) department. The size of the planning or incident management team will depend on a facility's operations, requirements, and resources. However, each position within the team has unique planning administrative duties specific to the nature of their responsibility. The responsibilities of the logistics section chief, as well as the planning section chief, rely heavily on organized administrative efforts. The potential complexity of site emergency response logistics should be analyzed, optimized, and communicated within the response plan.  Logistical documentation of the expected and actual resource flow of an incident can minimize response time and maximize efficiency.

Before an emergency, logistical duties may include the following:

  • Identify and acquire service and support requirements for planned and expected operations
  • Supply allocation details
  • Designating emergency facilities
  • Establishing training facilities
  • Establishing mutual aid agreements
  • Preparing a resource inventory
  • Provide input to and review the response plan(s)

During an emergency, logistics may entail:

  • Participating in preparation of the Incident Action Plan (IAP)
  • Providing utility maps to emergency responders
  • Providing material safety data sheets to employees
  • Coordinating and processing requests for additional resources
  • Repairing equipment
  • Arranging for medical support, food and transportation
  • Arranging for shelter facilities
  • Providing for backup power
  • Providing for backup communications
  • Recommend release of resources in conformity with Incident Demobilization Plan
 

 

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Tags: Cloud Computing, Training and Exercises, Supply Chain, Event Preparedness, Communication Plan

Supplementing the All-Hazard EOP: Emergency Operations Plan

Posted on Mon, Jun 17, 2013

Each company’s emergency operations plan (EOP) should document response actions and identify the internal and external resources required to effectively manage all potential hazards.  The EOP, often termed the “emergency response plan”, is the centerpiece of a comprehensive emergency management effort.

An EOP should be flexible enough for use in all emergencies. However, many company emergency management programs, as well as certain specialized industrial facilities may require several types of plans. Specialized plans may focus on specific operational hazards, inherent threats, or incident-specific response needs.  Depending upon the EOP’s structure and required content, hazard-specific information may be either included within the response plan or created as a separate stand-alone plan. FEMA identifies the following supplemental plans:

Administrative Plans

Administrative plans describe policies and procedures basic to the support of internal processes. Such plans are not the direct concern of an EOP. However, if it is assumed that provisions of an administrative plan apply in emergency situations, then the administrative plan may be referenced in the EOP. If an emergency dictates exceptions to normal administrative operations, the administrative plan becomes a relevant function of the EOP. Examples for emergency administrative processes include financial management, personnel management, records reviews, and labor relations’ activities.

Mitigation Plans

Mitigation planning is often a long-term effort and may be a part of a company’s strategic development plan. Existing plans for mitigating hazards are relevant to an EOP, since both originate from a hazard-based analysis and share similar component requirements. Processes and procedures in a mitigation plan can prompt effective recovery decision-making efforts, and implement a mitigation strategy aimed at reducing the long-term risk to lives, the environment, and property.

Preparedness Plans

Preparedness plans should address capabilities needed for prevention, protection, response, recovery, and mitigation activities. These plans should include, but are not limited to the following:

  1. Facility Information
  2. Training needs based on roles and responsibilities
  3. Means for developing, conducting, and evaluating exercises.  
  4. The process for correcting identified deficiencies
  5. Hazard analysis and potential spill volumes, if applicable
  6. Notifications (shouldn’t this be part of an EOP?
  7. Contracting and procurement requirements and procedures

Results of these efforts should be incorporated in the EOP. Based on the preparedness plan, the EOP assumes accuracy of available identified equipment and facilities, training and exercises are adequate, and additional response resources have been evaluated. Measures to safeguard emergency management personnel, as well as vital records and existing equipment, should be part of an EOP.

Preparedness planning should cover three objectives

  • Maintain existing emergency management readiness capabilities
  • Prevent emergency management capabilities from becoming part of the emergency
  • Augment emergency management capabilities with internal and external response resources

Prevention and Protection plans

These procedural, tactical, and/or incident-specific action plans tend to be facility focused. These plans contain site-specific, unique response details that apply to a single hazard, such as pandemic, hurricane, or fire pre plans. These plans may also pertain to specific regulatory requirements, such as SPCC (spill prevention control and countermeasure plans required by EPA).

Continuity Plans

Business continuity, or continuity of operations plans, identify essential business functions necessary to sustain key operations in the event of an operational disruption. These plans address employee responsibilities, processes, and procedures applicable to the continued performance of core capabilities and critical operations during a potential incident. They also describe the process for timely resumption of normal operations once the emergency has ended.

Recovery Plans

Typically, an EOP does not identify recovery actions beyond rapid damage assessment and the actions necessary to satisfy the immediate life support needs of disaster victims. The EOP should provide a process for transition to short-term recovery plans. Pre-disaster planning for long-term mitigation and recovery requires identification of strategic priorities for restoration, improvement, and growth.

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

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Tags: Emergency Management, Emergency Preparedness, Response Plans, Event Preparedness, Business Continuity Plan

Incident Specific Response Planning

Posted on Thu, May 30, 2013

No two crisis situations or responses are identical. As a result, Emergency Managers and Environmental Health and Safety (EHS) Managers responsible for developing and managing comprehensive, compliant, and functional response plans should create a broad scope of planned responses for potential emergency and crisis situations. In many circumstances, response efforts to various incidents may be similar. However, supplemental response procedures for specific hazards or threats can be added to the overall emergency management program to address these scenarios.

Focused supplemental response procedures or plans, for specific events such as pandemic flu and hurricanes can encompass a full range of hazards and potential threats and unique response details that apply to that single hazard. Depending upon response plan structure and volume of content, hazard-specific information may be included within an all-hazards response plan, or created as a stand-alone plan.

Hazard or incident-specific plans should include the same level of detail as the basic response plan, including, but not limited to:

  • Specific location(s)
  • Contact information for internal and external responders
  • Evacuation routes
  • Plot Plans
  • Specific provisions and protocols for warning employees, the public, and disseminating emergency information
  • Personal protective equipment and detection devices
  • Policies and processes for each specific hazard response
  • Identification of additional potential hazards
  • Response team roles and responsibilities
  • Recovery and restoration processes

Just as in the primary response plan, a planning team may use supporting documents as necessary to clarify the contents of the incident specific plan. These supporting documents can include hazard specific aerial photographs, facility maps, checklists, resource inventories, and summaries of critical information. Supplemental response plans may include, but are not limited to:

  • Assessment and control of the hazard information
  • Identification of unique prevention and preparedness of critical infrastructure/key resources
  • Initial protective actions
  • Communications procedures and warning systems
  • Implementation of protective actions
  • Identification of short-term stabilization actions
  • Implementation of recovery actions

Below are examples of potential supplemental response plans. Theses plans should be aligned with site-specific company facilities and personnel details.

  • Hurricane Plans:  Identifies response procedures and specific pre and post hurricane responsibilities according to landfall prediction timeline. May require providing evacuation route maps or shelter in place areas. Evacuation routes and scope of evacuation may change depending on the location of the facility, potential threats, or forecast.
  • Fire Pre Plans: Addresses specific information necessary to effectively fight a fire and limit exposures. Chemical and hazardous details in regards to particular buildings, tanks, and process units, and foam and water requirements should be included in fire pre plans.
  • Pandemic Plans: Documents procedures and methods necessary to maintain and restore operations of critical business processes in the event of a pandemic outbreak among the local population and workforce.
  • Additional Natural Disasters: Natural hazards tend to occur repeatedly in the same geographical locations because they are related to weather patterns or physical characteristics of an area. Depending on your specific risks, supplemental plans may be developed for one or more of the following:
    • Floods
    • Tornadoes
    • Thunderstorms and Lightning
    • Winter Storms and Extreme Cold
    • Extreme Heat
    • Earthquakes
    • Volcanoes
    • Landslide and Debris Flow (Mudslide)
    • Tsunamis
    • Wildfires

The planning development stage must include the identification of potential site specific hazards, and the critical responses necessary to respond to those hazards. To ensure consistency, it is a best practice for hazard-specific plans to follow the same layout and organizational format as the main response plan. This allows for familiarity and continuity, which enables the information to be identified and disseminated in a timely manner. Best practices also dictate that plans be developed during normal operational conditions, prior to any threatened outbreak. Training on the specific response plans allows for a complete understanding of assigned responsibilities and processes if an actual incident were to occur.

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

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Tags: Fire Pre Plans, Event Preparedness, Extreme Weather, Hurricane Preparedness, Flood Preparedness, Emergency Action Plan