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Improvised Planning Is Costly: 7 Regulatory Compliance Tracking Factors

Posted on Thu, Aug 20, 2015

"It's not what happens to you, but how you react to it that matters." - Epictetus

Despite best mitigation efforts, emergencies and disasters occur. Although emergency managers can relate to Epictetus’s antidote, it has been proven by the abundance of regulatory fines and fees that responses should not be improvised. Numerous government agencies require that responses be planned for, exercised, and compliant across multiple fronts.

While organizations may see compliance efforts as challenging, the purpose of regulations is to shape practices to limit harm and protect communities and the surrounding environment. However, every month, companies across the nation receive regulatory enforcement mandates.

Regulatory non-compliance is expensive, time consuming, and potentially dangerous to company employees and the surrounding communities. For example, a Seattle area marine terminal that transfers large quantities of ethanol fuel and grain from rail cars to tanker trucks was fined more than $420,000 by Washington’s Department of Labor and Industries for numerous non-compliance issues. Additionally, the agency placed an immediate order to restrain the company’s ethanol transfer operation because of inadequate emergency response planning. Compliance costs are typically lower than the expenditures associated with non-compliance fines, litigation, reputational risk, and government mandated shutdown of operations.

Many industrial facilities must comply with multiple regulations sanctioned by various government agencies. For example, one specific industrial facility in Louisiana has to meet as many as 700 individual requirements. In order to ensure optimal compliance capabilities, companies should have an effective compliance management process in place that can enhance efforts, and limit the potential for fines and operational downtime.

In recent years, advanced technology has allowed an increasing number of companies to automate emergency preparedness, response processes, as well as regulatory compliance. One of the most important aspects of maintaining compliance is ensuring that required response plan and associated revisions are submitted to the proper regulatory agencies in a timely manner. The various agencies have different submission requirements regarding initial and plan revision compliance.

A company must associate each regulatory requirement with applicable mandatory submission requirements and tasks for each facility. From a corporate standpoint, incorporating a regulatory requirements tracking system can ease the complicated exponential challenges associated with managing multiple regulatory requirements for numerous locations. A regulatory compliance tracking system can eliminate redundancies that typically occur across converging compliance specifications

A methodological tracking system should itemize applicable federal, state, and local regulations, and include categorical information that satisfies that regulation. A tracking system should, at a minimum, contain the following components:

  1. Operational categories: Categories can range from air quality and hazardous materials, to construction safety and general safety and health. Depending on the detail required by the regulations, further breakouts by subcategories may also be required.
  2. Applicable Regulation Level: Regulations should be further broken down to Federal, state or local regulation categories.
  3. Time/Date Stamping: The time and date that each regulation was last updated.
  4. Compliance Feedback: Applicable notes regarding compliance or non-compliance.
  5. Industry Standard: Apply best practices related to compliance with specific regulatory requirements, when practical to do so.
  6. Facility Compliance responsibility: Identify contact assigned to maintain compliance for each regulatory requirement.
  7. Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and person(s) assigned. Reports should have filters to customize queries as required by the users.
The results of an effective compliance tracking system is an efficient and integrated program that optimizes the efforts of all stakeholders and allows for optimum compliance.

Tags: Response Plans, Regulatory Compliance, Facility Management

Oil Prices, Facility Response Plan Compliance, and Corporate Shuffling

Posted on Thu, Jun 11, 2015

Historically, low oil prices have triggered energy sector consolidations, reorganizations, and liquidations. As the industry responds to plunging company profits, a wave of mergers and potential acquisitions may be on the horizon. Once again, the dynamic nature of the oil industry will require corporate emergency managers to re-evaluate their approach to emergency management and regulatory compliance.

When companies merge and facilities are acquired, a company-wide emergency management program must consolidate and verify the regulatory compliance and the accuracy of facility response plans. Companies undergoing corporate structural changes should perform gap analyses or audits to identify procedural, policy, or regulatory compliance deficiencies.

Integrating plans under one centralized format consolidates preparedness and response objectives. In company merger circumstances, this process requires clear, concise, and frequent communication among multiple parties. A cohesive team, in cooperation with facility managers, should manage the consolidation of emergency management practices. It is critical to define preparedness objectives, response roles, and responsibilities in order to eliminate ambiguity and confusion. Responsible parties must verify and apply data, site assessments, and personnel information into cohesive, compliant, and effective plans for the new enterprise.

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

Who is assigned to an emergency response?
  • Identify Incident Commander for each location
  • Create or update Emergency Management Team organizational chart
  • Identify and verify Emergency Management Team activation measures
  • Create or update Emergency Management Team roles and responsibilities checklists

Does the facility have a compliant response plan?

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

tanks-resized-600

What threats affect the facility or employees?

  • Perform a detailed hazard and risk analysis
  • Prioritize and carry out necessary mitigation measures
  • Verify or create response procedures for each identified threat
  • Identify the new process for incident documentation
  • Utilize appropriate ICS Forms
  • Identify current and/or necessary equipment necessary for response
  • Establish training and scenario-specific exercises to ensure process are responses are effective for identified threats/hazards

What regulatory requirements apply to each facility?

  • Evaluate all applicable regulations based on:
    • location
    • industry
    • operations
    • hazards
    • response specifics
  • Identify required training and implement compliant program
  • Review submitted response plan information
  • Confirm training and planning documentation
  • Perform plan(s) compliance audits

What is required for an effective and timely response?

  • Identify response capabilities and determine if additional resources are necessary
  • Initiate a Memorandum of Understanding or contract specific response needs
  • Confirm contact information, availability, and response times
How will an emergency be reported and response initiated?
  • Create site-specific notification procedures. (Emergency notifications may include 911, National Response Center, internal or external response team, emergency services, and others)
  • Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in alarm procedures and immediate response actions per roles and responsibilities
  • Implement company approved emergency classification levels to associated response procedures with emergency conditions to prevent the incident from escalating
  • Create multiple evacuation routes
  • Identify the muster point(s) and head count procedures

How are response actions sustained?

  • Establish command post location
  • Identify internal and external response resources and equipment for necessary sustained response actions
  • Share plans with appropriate responders/stakeholders
  • Develop a communications plan and identify sustainable communications equipment
  • Identify hazard control applicability and methods
  • Detail external communications and public relations policies

What is done after the incident is secured?

  • Create checklist to demobilize the response
  • Identify post incident review and debriefing objectives
  • Generate a means to apply “lessons learned”
  • Update plan accordingly and amend necessary training

Regulatory Compliance with TRP Corp

 

Tags: Facility Response Plan, Regulatory Compliance, Facility Management

The Importance of Response Plan Training for the First Responder

Posted on Thu, Jan 22, 2015

Any employee has the potential to be put in a first responder role in the event of an emergency at the office, jobsite, or facility.  As a result, all employees should be trained in response measures appropriate for site-specific vulnerabilities and identified risks. The rapid mobilization and proficiency of initial actions, as well as response procedure familiarity is essential in order to minimize potential chaos, scenario consequences, and plausible chain-reaction events.

In order to avoid the onset of panic or prolong emergency circumstances, necessary and effective reactive measures should become second nature to any potential initial responder. Familiarity through training and exercises can combat the natural effects of stress in tense situations. Having a well-rehearsed emergency plan enables efficient and effective response coordination, reduces losses, and can limit the impact to employees, the environment, and surrounding community.

Efforts must be made to train non-response team members in initial response actions and the appropriate initiation procedures. Any employee or contractor, upon discovering a significant event or condition that requires urgent response from outside trained personnel, should be trained to take the suggested initial response actions listed below:

Initial Response Actions:

  1. Warn others in the immediate area through verbal communication and/or activate local alarms.

  2. Take immediate personal protective measures (PPE, move to safe location, etc.).

  3. Report the emergency to Security or 9-1-1, depending on company policy.

  4. Implement local response actions (process shutdowns, activate fire protection systems, etc.) if safe to do so, and consistent with level of training and area specific procedures.

Industrial facility employees often encounter unique, site-specific hazards, and potential threats, unlike those in other fields. Specialized training must complement response team roles and responsibilities in order to address these specific vulnerabilities and risks. But despite an industrial setting, not all employees will be assigned to a formal response team.

Employees who may be exposed to hazardous substances are required to be HAZWOPER certified. HAZWOPER, an acronym for the Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Standard, communicates the required training that addresses hazardous operations and potential spills or releases. The intent of the HAZWOPER standard is to protect workers engaged in "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v)).  However, this does not mean that all HAZWOPER certified employees are responsible for terminating a release. According to the standard, the following first responder levels are not trained to terminate a hazardous incident.

The Awareness Level:  According to OSHA, the first responders at the “awareness level” must demonstrate competency in areas such as recognizing the presence of hazardous materials in an emergency, the risks involved, and the role they play in their employer’s plan.

Who should be trained? This level is applicable for persons who, in the course of their normal duties, could be the first on the scene of an emergency involving hazardous material. Responders at the awareness level are expected to recognize the presence of hazardous materials, protect themselves, call for trained personnel, and secure the area without engagement.

Individual companies can set their own hourly training requirements; however, employees must be capable of demonstrating the following:

  • What hazardous substances are, and associated risks during an incident

  • The potential outcomes associated with an emergency when hazardous substances are present

  • Ability to recognize the presence of hazardous substances in an emergency

  • Ability to identify the hazardous substances, if possible

  • The role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook

  • Ability to realize the need to make appropriate notifications for additional resources

The Operations Level: Operations level responders meet and exceed the competency level of the awareness responder. Operational responders are trained to respond in a defensive fashion without actually trying to terminate the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.

Who should be trained? These responders are part of the initial response for the purpose of protecting nearby persons, the environment, and/or property from the effects of the release.   Operations may receive additional training in HAZMAT/CBRNE defensive techniques of absorption, damming and diking, diverting, retention, vapor dispersion and suppression. They may also be trained in basic decontamination procedures and PPE.

First responders at the operational level should complete the 8-hour HAZWOPER training course or have had sufficient experience to objectively demonstrate competency in the following areas:

  • Basic hazard and risk assessment techniques

  • How to select and use proper personal protective equipment

  • Basic hazardous materials terms

  • How to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit

  • How to implement basic decontamination procedures

  • The relevant standard operating procedures and termination procedures

For a free download on conducting an effective exercise, click here or the image below.

TRP Corp Emergency Response Planning Exercises

Tags: OSHA HAZWOPER, Facility Response Plan, Response Plans, Facility Management, Disaster Response, Workplace Safety, Chemical Industry, HSE Program

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

The SPCC Plan Template and Compliance Components

Posted on Thu, Nov 13, 2014

According to a February 2012 EPA report, approximately 55% of 3,700 facilities inspected from 2007-2010, were not in compliance with existing Spill Prevention, Control, and Countermeasure (SPCC) guidelines. If these regulations are applicable to operations, companies need to prioritize plan compliance with facility management in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations. New production facilities have 6 months to prepare and submit their site-specific SPCC plan in order to be in compliance with the regulation.

According to the EPA, most SPCC enforcement actions are due to incorrect or missing required documentation or nonexistent plans. If a facility does not have a documented plan, it will not be entitled to “informal enforcement” (verbal feedback and check sheet documenting potential violations). By utilizing a template as an outline, companies can begin the process of creating a compliant plan.

In order for a standardized template to be a compliant document, it is essential to evaluate and incorporate site-specific variables and applicable requirements.  Development of an effective plan requires detailed knowledge of the facility and the potential effects of an oil spill. While each plan must be unique to the facility it covers, certain standard elements must be included to ensure regulatory compliance.

Typical elements of an SPCC plan include:

  • Professional Engineer Certification
  • Conformance declaration
  • Certification of the Applicability of the Substantial Harm Criteria
  • Facility description, plot plan, and contacts
  • Potential spill volume and flow rates
  • Inspections, tests and record keeping processes
  • Personnel training requirements
  • Loading/Unloading and transfer details
  • Discharge prevention measures
  • Security Measures
  • Recovered material drainage and disposal methods
  • Bulk Storage tanks details
  • Secondary containment locations and volumes
  • Discharge notification information and procedures
SPCC - TRP Corp

An SPCC plan template should be supplemented with the following site-specific information:

Description of Facility Infrastructure and Physical Attributes: 

Plans should include site-specific details of the designated facility. This includes:

  • Facility Name
  • Address
  • Latitude/Longitude
  • Contact Number
  • Contact Person (and/or facility manager)/contact number(s)
  • Site operations
  • Products handled
  • Number of employees
  • Identification of waterways in the vicinity
  • Summary of site drainage properties
  • Site topography
  • Details of tanks, pipelines, utilities, etc.
  • Site security features, including fencing, visitor access, and lighting

Plan distribution list: Include the names and addresses of those that maintain paper 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. Response equipment and alternate response equipment suppliers should be identified. (Key contacts may include 911, National Response Center, and internal and external response teams.)

Alarm Identification and Notification Process:  Specific alarm signals 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 immediate notification response actions per roles and responsibilities.

Pertinent and updated contact numbers should be listed in the plan and verified. Plan administrators must be certain that all applicable contacts listed in notifications are accurate and/or phone numbers, especially in case of an evacuation. Verification of contact information for both personnel and external responders should be done on a periodic basis.

If maintaining accurate contact information is challenging, consider opting for an e-mail notification verification system that enables individuals to verify their own information.

Response Actions:  Checklists and procedures detailing specific key response actions should be listed in the plan. In addition to these requirements, task teams should be formed, at a minimum, to cover each process. It is crucial to train employees on each site-specific component of the plan. Companies often provide extended training in case primary emergency management team members are not available.

Hazardous Waste Storage and Disposal: Applicable contact information for external suppliers should be reviewed and verified. The consequences of a supply chain failure on response components can exacerbate an emergency scenario. Transportation delays could affect necessary equipment delivery times. As a result, facilities should plan and mitigate accordingly.

For a free download on compliant facility preparedness, click the image below:

Preparedness and Emergency Management - TRP Corp


Tags: SPCC, Regulatory Compliance, Facility Management

SPCC Planning and Regulatory Compliance Inspections

Posted on Thu, Oct 16, 2014

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

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

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

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

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

SPCC TRP Corp

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

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

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

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

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

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

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

TRP - SPCC and FRP

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

The Facility Response Plan Assessment

Posted on Thu, Aug 07, 2014

As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, certain facilities that store and use oil are required to develop, maintain, and submit an approved Facility Response Plan (FRP). These plans should address the elements and responses associated with substantial threats and worst case discharges of oil. If the Oil Pollution Act regulations are applicable to a facility, the operating company must prioritize response plan compliance in order to minimize fines, negative public perceptions, and potential government mandated shutdown of operations.

Maintaining a FRP is an ongoing process. As company operations evolve, and equipment and employees change, adjustments need to be incorporated into the FRP to ensure accuracy, compliance, and effective response capabilities. Additionally, the plan submittal processes must be observed and applied in order to eliminate the potential for fines.

This FRP assessment is designed to recognize best practices. Following the set of questions, the scoring section can assist in identifying potential necessary actions that can reduce the risk of non-compliance and/or ineffective responses.

1. Have your personally reviewed your company’s FRP within the past 12 months?

Yes _____ No_____

2. Do your employees have a clear understanding the FRP and their designated responsibilities if a worst-case scenario were to occur?

Yes _____ No_____

3. Have your external responders participated in a comprehensive review of your emergency management system or a response exercise within the last 12 months?

Yes _____ No_____

4. Does your plan identify a Qualified Individual and alternate who has full authority to obligate funds required to carry out necessary response actions and act as liaison with Federal On-Scene Coordinator?

Yes _____ No_____

5. Does your FRP identify a public relations contact or information officer who has knowledge of public affairs policies identified in your company’s FRP?

Yes _____ No_____

6. Were representatives of external resources involved in developing and testing the company’s FRP?

Yes _____ No_____

7. Does your company have adequate documentation  procedures and capabilities to document plan l changes, training, and exercises?

Yes _____ No_____

8. Is your FRP consistent with the National Contingency Plan and any Area Contingency Plan?

Yes _____ No_____

9. Have you spent more than two hours during the past six months in face-to-face discussion with your incident management team about how to improve spill response management?

Yes _____ No_____

10. Are your response procedures brief and organized in a manner that enables your employees or response teams to effectively respond to a range of incidents?

Yes _____ No_____

11. Does your FRP clearly identify discharge detection procedures and equipment?

Yes _____ No_____

12. Are your current mutual aid agreements or external responder contracts current?

Yes _____ No_____

13. Is your incident response team equipped and trained to set up incident command center?

Yes _____ No_____

14. Does your FRP include detailed disposal procedures and contractors?

Yes _____ No_____

15. Does your FRP contain alternates for each Incident Management Team position in the event that the primary contacts are unavailable?

Yes _____ No_____

16.  Do key individuals have secured, immediate access to the most up-to-day FRP without potential “version confusion”?

Yes_____No_____

Self-Assessment Scoring

To assess your emergency management program, give yourself one point for each "yes" and zero points for each “no”. Total your score and grade your risk.

13–16 points: In general, your FRP is well managed. Look back at your "no" answers and decide what you can do to mitigate this area of exposure. Be sure to monitor regulatory requirements and any operational shifts that could alter the effectiveness of your FRP. For a comprehensive understanding of the status of your plan, perform a full FRP audit by qualified in-house experts or experienced consultants.

9-12 points: You are making good progress, but there are a number of actions required to reduce your risk of non-compliance or response inefficiency. You may wish to focus your attention on areas indicated by the "no" answers. Based on the results of reviews in these areas, you can decide what further steps are necessary. An expert evaluation of your current plan with response plan professionals can minimize potential fines and maximize response efficiencies.

5-8 points: Your company may be at risk, but you have taken the first step of mitigation: awareness. This score suggest your emergency management responsibilities are being partially met, but there is significant room for improvement. A response-planning consultant with FRP experience can assist planners with site evaluations, regulatory compliance criteria, mitigation efforts, and plan substantiation.

Fewer than 5 points: Your facility, employees, operations, and reputation are at risk! Prompt action is necessary to ensure a compliant emergency management program. You need to take immediate action for regulatory compliance and to improve the ability to respond effectively to an incident. A comprehensive review of your FRP and preparedness efforts is warranted to reduce your risk.

Helpful hints:

  1. Review FRP’s on a cyclical basis. If turnover is high or operations are rapidly evolving, FRPs should be reviewed quarterly, at a minimum.
  2. Ensure training, drills, and exercises are optimized. Each training event, drill, or exercise presents the opportunity to improve response process responsibility and site-specific response procedure awareness, rendering the potential for a more effective response.
  3. Despite the added strain of publicity during a crisis, engaging with the media should be incorporated into the planning process. Ensure the facility or company has a designated point of contact for media and site personnel. Consistent, accurate messages alleviate public anxiety and provide a level of credibility. The more information that is provided, the less the media will have room for interpretation.
  4. Documentation provides historical records, keeps management informed of site practices, serves as a legal instrument, if necessary, and supports time and maintenance costs.
  5. Consider utilizing a web-based, database driven planning system. A widely accessible emergency response plan can maximize efficiency and minimize impacts of an emergency on employees, the environment, and infrastructure. Incorporating TRP’s enterprise-wide emergency management system can maximize efforts, minimize maintenance costs, and allow for a streamlined and familiar response process.

For free download on facilitating effective oil spill exercises, click on the image below:

TRP Corp Emergency Response Planning Exercises 

 

Tags: Facility Response Plan, Response Plans, EPA, Oil Spill, Training and Exercises, Facility Management, Workplace Safety

Oil and Gas: Combating Common Business Continuity Obstacles

Posted on Thu, Jul 24, 2014

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

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

Lack of management support

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

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

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

Budget restraints

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

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

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

Maintaining a culture of preparedness

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

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

Lack of business continuity awareness and training

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

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

Identifying critical processes:

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

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

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

 Unidentified threats and vulnerabilities:  

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

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

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

TRP Corp - Emergency Response Planning Crisis Management

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

Incident Response Drills and Tabletop Exercises

Posted on Thu, Jul 17, 2014

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

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

  • Communication
  • Training
  • Resource management
  • Teamwork

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

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

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

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

Below is a list of common tabletop exercise planning considerations:

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

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

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

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

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

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

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

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

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

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

TRP Corp Emergency Response Planning Exercises

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

Post Acquisition Response Planning Checklist for the Emergency Manager

Posted on Thu, May 22, 2014

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

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

1. Response Plan Audit

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

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

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

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2. Response Team Details

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

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

 

3. Contact Information Verification

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

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

 

4. Response Training Requirements

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

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

 

5. Exercise the Response Plan

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

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

 

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

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

 

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