Your Solution for SMART Response Plans

Tips to Ensure Regulatory Compliance at New Site Locations

Posted on Mon, May 19, 2014

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

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

How to Quickly Develop Response Plans after a Merger or Acquisition

Posted on Thu, May 01, 2014

Companies are not stagnant, as evidenced from the many acquisitions, mergers, and organic growth seen every year. The dynamic nature of the energy sector (and others) requires corporate emergency management and business continuity programs to periodically adjust their approach.

Whether a facility is located in the U.S. or abroad, ensuring compliance, employee safety, and an effective response requires a streamlined, coordinated, and exercised response plan. All response plans within the corporate enterprise should address site-specific facility details, appropriate response processes, standardized company-wide best practices, and maintain location-specific regulatory compliance. A customized response plan template enables development of  a streamlined, site-specific preparedness program that consistently delivers company-standard guidelines and practices while providing a medium for rapid assimilation of acquired facilities.

Generic response plan templates that do not account for site-specific details may result in  incomplete, ineffective, and non-regulatory compliant plans.  Companies with multiple-facility operations should utilize a customizable template with the ability to inject distinct facility information and hazards for each operation, pre-approved company best practices, as well as applicable local, state, and federal requirements. Industrial operations are required by law to institute site-specific emergency response plans, and train employees according to their response roles and method of response pertinent to operations.

Integrating response plans under one centralized format consolidates preparedness and response objectives. In company merger circumstances, this process requires clear, concise, and frequent communication.  A single individual or coordinated team 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 apply data, site assessments, and validated information into cohesive, compliant, and effective response plans for the new enterprise.

Acquired facilities must be absorbed into the company-wide emergency management program. If response plans exist, companies should perform a gap analysis or audit to identify any procedural, company policy, or compliance deficiencies.

New or outlying facilities may present preparedness and response challenges. Cultural differences, infrastructure challenges, response equipment availability, minimal response knowledge and training, and security priorities may require heighten preparedness priorities and planning efforts. As a result, new locations within multi-facility companies may be particularly vulnerable to crisis or emergency response situations.

The following fundamental preparedness and response questions may assist companies in absorbing facilities into an established 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 will be in charge of the  response?

  • Identify Incident Commander
  • Create Emergency Management Team organizational chart
  • Identify Emergency Management Team activation measures
  • Create Emergency Management Team roles and responsibilities checklists

Does the facility have a current response plan?

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

What threats affect the facility or employees?

  • Perform a detailed hazard and risk analysis
  • Verify or create response procedures for each identified threat
  • Identify the new process for incident documentation
  • Utilize appropriate ICS Forms
  • Identify current and necessary equipment necessary for response

What regulatory requirements  apply to this facility?

  • Evaluate operations for compliance
  • Identify required training and confirm documentation
  • Review submitted response plan information
  • Perform a compliance audit

If necessary, what organization will conduct additional response duties?

  • 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 the 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)
  • Identify alarm signals that signal employee evacuation or shelter in place.
  • 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

What incidents or classification level require evacuation/shelter in place

  • Create multiple evacuation routes.
  • Does the evacuation go beyond facility borders?
  • 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 a sustained response
  • Share response plan 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 response plan accordingly and amend necessary training

 

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: Response Plans, Redundant Systems, Regulatory Compliance, Facility Management, Emergency Management Program

Improving SPCC and Facility Response Plan Compliance

Posted on Mon, Apr 21, 2014

Regulatory non-compliance has proven to be expensive, time-consuming, and potentially dangerous to company employees and the surrounding communities. As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, companies may be required to develop, maintain, and submit an approved Facility Response Plan (FRP) and/or a Spill prevention, Control, and Countermeasures Plan (SPCC).

If government regulations are applicable to operations, companies need to prioritize response plan compliance in order to minimize fines, negative public perceptions, and potential government mandated shutdown of operations.  A compliant and exercised response plan can be the foundation to an efficient preparedness program.

By systematically aligning emergency plans and their components with corresponding regulations, companies can identify and amend plan deficiencies. Response plan compliance can be improved by the following:

  • Evaluate regulatory applicability across all company operations
  • Perform audits or gap analysis of response plans against regulatory requirements
  • Identify new planning requirements as regulations evolve
  • Maintain up-to-date plans that reflect facility, personnel, or operational changes
  • Exercise plans to ensure plan accuracy
  • Confirm regulatory response plan submittal requirements

Determining response plan requirements for each facility will determine the site-specific information required by the corresponding regulatory agency. A “substantial harm” facility is a facility that, because of its location, could reasonably be expected to cause substantial harm to the environment by discharging oil into or on navigable waters or adjoining shorelines. These facilities are required to develop, maintain, and submit a facility response plan.

Certain facilities that store and use oil are required to prepare and submit facility response plans to respond to a worst case discharge of oil and to a substantial threat of such a discharge.” - EPA

TRP Corp - Substantial Harm

In addition to maintaining a site-specific plan, an FRP mandated facility must keep a log of response training drills and exercises, along with plan updates reflecting material changes. Records of inspections of response equipment must be kept for five years. If response-planning requirements under 40 CFR 112.20 are not applicable, a facility must complete the certification form in 40 CFR Part 112 Appendix C Attachment C-II.

According to EPA, key elements of an FRP should include:

  • A stand alone Emergency Response Action Plan
  • Facility name, type, location, owner and operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and evaluation of potential spill hazards and precious spills
  • Identification of small, medium and worst case discharge scenarios and response actions.
  • Description of discharge detection procedures and equipment
  • Detailed implementation plan for containment and disposal
  • Facility and response self-inspection, training, exercises and drills, and meeting logs
  • Diagrams of facility and surrounding layout, topography, and evacuation paths
  • Description of site-security and security equipment

In addition to an FRP, facilities such as oil production facilities, bulk storage terminals, power plants, automotive plants, chemical plants, power plants, transportation centers, laboratories, and compressor stations may be required to submit SPCC plans. SPCC Plans identify prevention practices related to the storage of oil and management of tanks and other storage equipment. SPCC plans can often be confused with oil spill contingency plans, which typically address response measures after a spill has occurred.

Under the Federal Rule 40 CFR 112, facilities that store more than 1,320 gallons of oil or petroleum-based liquids aboveground or more than 42,000 gallons of oil underground s are required to have a SPCC (Spill Prevention, Control, and Countermeasure Plan). - EPA

Development of a unique SPCC Plan requires detailed knowledge of the facility and the potential effects of any oil spill. While each SPCC 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
  • Discussion of conformance with federal regulations
  • 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

Response plan standardization across a company enterprise allows for a familiar format, a synchronized response, and is the best option for ensuring regulatory compliance across multiple response plans.

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

Preparedness and Emergency Management - TRP Corp

Tags: Facility Response Plan, SPCC, EPA, Regulatory Compliance, Facility Management

A Lesson in Emergency Preparedness: Learn from Past Incidents

Posted on Thu, Apr 17, 2014

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

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

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

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

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

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

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

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

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

Initial Response

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

Notifications

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

Assessment/Evaluation

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

Response Mobilization

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

Response Strategy

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

Response Resources

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

Command Structure

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

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

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

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

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

Preparedness and Emergency Management - TRP Corp

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

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

The Facility Response Plan Annual Review

Posted on Mon, Feb 10, 2014

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

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

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

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

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

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

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

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

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

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

Step 1: Collaborative Teamwork

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

Step 2: Understand Potential Situations

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

hazardous_waste_TRP.jpg

Step 3: Determine Goals and Objectives

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

Step 4: Plan Update

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

Step 5: Plan Approval and Distribution

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

Step 6: Plan Implementation & Maintenance

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

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Regulatory Compliance with TRP Corp

 

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

Response Planning Discussion Points: The Path to Preparedness

Posted on Mon, Feb 03, 2014

Through timely internal audits, facility assessments, attentive training and exercise programs, and best practices, response plans can be a working reflection of facility compliance and corporate preparedness. Necessary response documentation and plans established prior to an emergency allow for a comprehensive review of processes and procedures, and can result in an improved response to actual emergencies. The following questions, while not all-inclusive, can be used as planning discussion points to identify necessary response elements in order to develop or assess emergency response plans:

Compliance

  • What agencies and specific regulations apply to my location(s)?
  • If applicable, have material safety data sheets (MSDS) 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?

Risk Assessment

  • What are the current high-risk activities at the location?
  • Can high-risk tasks or conditions be mitigated? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Have environmentally sensitive areas been identified and potential consequences been assessed?
  • Did risk assessment utilize realistic scenarios to define spill and release volumes and locations?
  • Are employees made aware of hazards associated with specific workplace process, materials, or location(s)?

Supply Chain

  • Are processes in place to monitor internal and external supply chains?
  • Is external spill response support necessary and available?
  • Have response equipment needs been evaluated and defined?
  • How would a potential spill affect both internal and external resources?
  • Have back up suppliers been identified and communicated with?

Training

  • Are personnel appropriately trained for their allocated roles?
  • Have the plans been thoroughly exercised with realistic scenarios that test training comprehension?
  • Is the response management team structure clear and able to be communicated?
  • Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?
  • Are exercises utilized to identify effective efforts and inefficiencies in response to ever-changing and site-specific scenarios?
  • Does training include documenting and communicating response actions, management decision, and tracking of resources?

Response Elements

  • Are clear procedures in place to notify, assess, and initiate a response?
  • Are individual responders and their contact information verified for accuracy?
  • Can approved stakeholders easily access response plans?
  • Have response times and limitations been set?
  • Do response elements address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been identified?
  • Are communications backup systems available and described in the plan?
  • Are staff roles and responsibilities specified and communicated?
  • Have alternate strategies and response procedures been identified?
  • Are 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?
  • Do trajectory maps mimic local observations and historical tendencies?
  • Do trajectory estimates include potential weather scenarios?
  • Are sensitive sites prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes communicated?

Documentation

  • Have processes been established for updating planning information prior to an emergency and during a response?
  • Have plot plans and area mapping been integrated with GIS data and knowledge?
  • Are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
  • Has exercise feedback/lessons learned been incorporated into plan revisions?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible?
  • Are necessary Incident Command (ICS) forms and company paperwork readily available for response documentation?
For a free download of a Response Procedures Flow Chart, click the image below:
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Tags: Response Plans, Crisis Management, Facility Management, Emergency Response Planning, Safety, Disaster Response, Business Disruption

Proposed Changes to the NPDES General Permitting Requirements

Posted on Mon, Nov 04, 2013

On September 27, 2013, the U.S Environmental Protection Agency (EPA) requested public comments regarding proposed changes in the 2013 National Pollutant Discharge Elimination System (NPDES) general permit for storm water discharges from industrial activity.  Once finalized, the new permit will replace the 2008 document, which was issued for a five-year term on September 29, 2008.

According to the EPA, the NPDES general permit, also referred to as the Multi-Sector General Permit (MSGP), covers multiple facilities with common discharges within a specific geographic area. A general permit applies the same or similar conditions to all dischargers covered under the general permit. The EPA issues these permits for storm water discharges associated with industrial activity, under the NPDES program (as defined in 40 CFR 122.21 and 40 CFR 122.26).

Four states (Idaho, Massachusetts, New Hampshire and New Mexico), Indian lands, and several territories do not have their own federally approved storm water permitting programs.  Within these areas, entities that are subject to industrial storm water discharge regulations are required to apply to the EPA to obtain coverage under the MSGP. Due to the delay to allow for comments, the 2008 MSGP has been administratively continued in accordance with 40 CFR 122.6, and will remain in effect until the new draft permit is finalized. EPA estimates that the new MSGP will be reissued in the spring of 2014.

The MSGP covers 29 different industrial sectors with specific and varying compliance requirements. As written, the draft MSGP includes several new or modified requirements from the 2008 MSGP. The EPA proposes the following:

  • The EPA will perform Environmental Assessments (EA) for dischargers subject to any New Source Performance Standards (NSPS). The EA will consider the potential environmental impacts from the discharge of pollutants in storm water discharges from new sources associated with industrial facilities, where EPA is the permitting authority, to determine whether to prepare an Environmental Impact Statement (EIS).
  • The EPA will require electronic submission of numerous reporting documents including each notice of intent, notice of termination, discharge monitoring reports, annual reports, and all monitoring data, unless a waiver is granted. Waivers would be granted for a one-time use for single information submittal.
  • The EPA will prohibit the discharge of pavement wash waters directly to any surface water or storm drain inlet, unless the facility has implemented control measures or subjected the wastewater runoff to dry clean-up techniques prior to discharge.
  • The EPA will require that each permit holder make a copy of its Storm water Pollution Prevention Plan (SWPPP) publicly available, either by identifying a URL link on the notice of intent (“NOI”) that is filed with EPA to apply for the permit, and then posting the SWPPP on the internet, or by providing storm water management information in the NOI itself. The information required includes a detailed description of:
    • The onsite industrial activities exposed to storm water, including potential spill and leak areas
    • The pollutants associated with each industrial activity exposed to storm water and/or authorized non-storm water
    • The control measures employed to comply with the non-numeric technology-based effluent limits
    • Additional measures taken to comply with requirements in Part 2.2
    • The good housekeeping, maintenance, and inspections schedules
  • The proposed permit clarifies effluent limits to include a greater level of specificity in order to make the requirements more clearly articulated, transparent, and enforceable. These clarifications include requirements for minimizing exposure, good housekeeping, maintenance, spill prevention and response procedures, and employee training.
  • The proposed permit modifies specificity of corrective actions, including the necessary actions to be implemented prior to deadlines. The draft permit would require that corrective action steps be taken immediately (i.e., on the same day the condition was found) in order to ensure that pollutant discharges are minimized and that a permanent solution is implemented expeditiously. The draft MSGP also requires that subsequent action must be taken to install a new or modified control and make operational, or complete the repair, before the next storm event if possible, and within 14 calendar days from the discovery of the condition.
  • The EPA will require that all annual reports submitted under the new MSGP include a summary of the routine inspections and assessments conducted at the facility throughout the previous year.
  • The proposed permit clarifies that one is considered a discharger to impaired water if the discharge flows directly to the water, including if the discharge enters a storm water collection system that discharges to impaired water.
  • The EPA proposal clarifies language associated with the conduct of corrective actions. These actions are currently required under a limited set of circumstances.  The proposed permit expands the conditions under which corrective actions will be required and imposes specific deadlines for completing these actions, including immediate actions on the day of discovery to address conditions that require corrective action.

Those subject to the 2008 MSGP should carefully review the proposed requirements, as well as the sector-specific requirements that apply to their industry to ensure comprehension of the changes. Formal comments on the proposed draft will be accepted through November 26, 2013.

For a free sample Response Procedures Flow Chart, click the image below:

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Tags: NPDES, SWPPP, EPA, Regulatory Compliance, Facility Management, Flood Preparedness

Office Building Emergency Management and Emergency Action Plans

Posted on Thu, Oct 24, 2013

Modern office buildings are generally considered safe and healthy working environments. However in order to maintain OSHA safety standards, office building management should include a Health, Safety, and Environmental (HSE) program that identifies regulatory requirements, including  site safety and evacuation procedures. Building inspections, safety audits, and evacuation drills, can identify the need for site specific mitigation opportunities and necessary safety training to correct, minimize or eliminate unsafe procedures or processes.

Although each office building exhibits unique geographical and operational hazards, there are commonalities that may need to be addressed through a HSE program.  Common office building health and safety hazards may include, but are limited to:

  • Construction method
  • Ventilation
  • Illumination
  • Noise
  • Physical Layout
  • Exit/Egress
  • Fire Hazards
  • Handling and Storage Hazards
  • Electrical Equipment
  • Ladders, stands, stools
  • Severe weather or naturally occurring events
  • Office tools

A wide variety of emergencies, both manmade and natural, may require an office building to be evacuated or shelter in place. These emergencies may include:

  • Fires, explosions, toxic material releases, radiological and biological accidents, civil disturbances and workplace violence
  • Floods, earthquakes, hurricanes, tornadoes

A disorganized response and evacuation can result in confusion, injury, and/or property damage. To establish a systematic response with a safe and orderly office building evacuation, HSE programs should include an incident or emergency action plan (EAP) and associated employee training.

Some companies own and maintain their office buildings, while other employers lease office space. If the space is leased, building management and employers should create a partnership in a joint effort to promote safety. A well-developed response or EAP is an effective tool to heighten safety awareness measures. For certain employers, regulatory requirements may require a written EAP. According to OSHA, the purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. In order to customize an office-building plan, employers should:

  • Identify potential hazards features and emergency scenarios
  • Communicate how employees should respond to each identified emergency
  • Customize plan by developing floor plans (or worksite layout)
  • Communicate on-site emergency systems and/or alarms

The OSHA requirement to develop a written EAP or fire prevention plan is based on the number of employees that are physically in a facility at any time of the working day. The regulation states that employers with 10 or fewer employees do not have to create a written emergency action plan. However, employers are still required by OSHA to communicate an EAP to staff. An emergency action plan must communicate the following minimum requirements:

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

Job and site-specific emergency response training should be implemented for current employees, new hires, and supervisors. An employer must review the EAP with each employee covered by the plan:

  • When the plan is developed or the employee is assigned initially to a job
  • When the employee's responsibilities under the plan change
  • When the plan is changed

Additionally, the EAP must address alarm system specifications. An employer must have and maintain a working alarm system that utilizes a distinctive signal and complies with the requirements in 29 CFR 1910.165.

For a free download on Fire Pre Planning, click the image below:

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Tags: Training and Exercises, Facility Management, Emergency Management Program, Communication Plan, Emergency Action Plan

USCG Oil Spill Planning and the Facility Response Plan

Posted on Thu, Sep 26, 2013

Oil Pollution Act of 1990 (OPA 90) created comprehensive prevention, response, liability, and compensation policies for vessel and facilities that could cause oil pollution to U.S. navigable waters. For facilities adjacent or nearby shorelines, OPA 90 highlights the need for site-specific Facility Response Plans (FRP).

Responding to an oil spill is a dynamic scenario with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. As a result, a FRP must provide guidelines to quickly, safely, and effectively respond to a spill.

OPA 90 greatly increased federal oversight of oil related vessels and facilities in attempt to provide greater environmental safeguards. OPA 90 implemented the following key points:

  • Set new requirements for vessel construction, crew licensing, and manning
  • Mandated contingency planning
  • Enhanced federal response capability
  • Broadened enforcement authority
  • Increased penalties
  • Created new research and development programs
  • Increased potential liabilities
  • Significantly broadened financial responsibility requirements.

Facilities can enhance oil spill response efforts and incorporate regulatory compliance by preparing site-specific FRPs.  A FRP must provide responders with processes and procedures to quickly, safely, and effectively respond to a spill to prevent further damaging effects. The following are US Coast Guard OPA 90 Facility Response Plan components (33 CFR 154.1035):

Prioritized notification procedures

  1. List of facility response personnel.
  2. List of Federal, State or local agencies, as required
  • Spill response notification forms to Federal, State, local agencies. Form must state that initial notification must not be delayed by collection of data.
  • Notification of the National Response Center.

Facility’s spill mitigation procedures

  1. Description of volume and oil groups that would be involved in the following:
    • Average, maximum and worse discharge from the MTR facility. And, where applicable, the worst case discharge from the non-transportation-related facility.
  2. Prioritized list of procedures and facility personnel (identified by job title).  Procedures must address actions to be taken in the event of a discharge, potential discharge or emergency involving equipment and scenarios.
  3. Listing of equipment and the responsibilities of facility personnel to mitigate an average most probable discharge.

Facility's response activities: Responsibilities of facility personnel to initiate a response and supervise response resources pending arrival of qualified individuals.

  1. Responsibilities and authority of the qualified individual and alternate as required in § 154.1026.
  2. Application of the following organizational structure to manage response actions:
    • Command and control
    • Public information
    • Safety
    • Liaison with government agencies
    • Spill operations
    • Planning
    • Logistics support
    • Finance
  3. Identification oil spill removal organizations and the spill management teams to be capable of providing the following response resources:
  • Equipment and supplies to meet § 154.1045, 154.1047, as appropriate
  • Trained personnel for response to be on hand for the first 7 days of the response
  • Job descriptions for each spill management team member within the organizational structure in a response action.
  • For mobile facilities in more than one COTP zone, oil spill removal organizations and the spill management teams must be identified from paragraph (3)(iv) and included in each COTP zone.

Sensitive Environments

  1. Identification of areas of economic importance and environmental sensitivities which are potentially impacted by a worst case discharge
  2. Development of plans to contain detailed information as to how they will respond to small, medium, and worst-case spills. Identification of  appropriate equipment and personnel as described in § 154.1028 to protect sensitive elements by one of the following calculations:
    • Persistent oils and non-petroleum oils discharged into non-tidal waters, the distance from the facility reached in 48 hours at maximum current.
    • Persistent and non-petroleum oils discharged into tidal waters, 15 miles from the facility down current during ebb tide and to the point of maximum tidal influence or 15 miles, whichever is less, during flood tide.
    • Non-persistent oils discharged into non-tidal waters, the distance from the facility reached in 24 hours at maximum current.
    • Non-persistent oils discharged into tidal waters, 5 miles from the facility down current during ebb tide and to the point of maximum tidal influence or 5 miles, whichever is less, during flood tide.
    • Spill trajectory or model may be substituted if acceptable to Captain of the Port.
    • Procedures contained in the Environmental Protection Agency’s regulations on oil pollution prevention may be substituted for non-tidal and tidal waters.
    • Captain of the Port may require additional sensitive elements to be protected depending on trajectory.
  3. Disposal Plan

Training and Exercises

  1. Training and drill procedures facility owner or operator must fulfill
  2. Plan reviews and update procedures

Site Specifications

  1. List of contacts must include primary and alternate personnel, response contractors and Federal, state and local officials.
  2. Equipment list and records
  3. Communications plan
  4. Site-specific safety and health plan

The above is a summary of the USCG regulation. For more specific information regarding requirements for facilities that could reasonably be expected to cause significant and substantial harm to the environment, please see  33 CFR 154.1035.

Understanding the required elements of the SPCC and FRP, and associated inspections may minimize potential regulatory penalties and fines and curtail operational downtime. For a free download on the SPCC and FRP nspections, click the image below:

TRP - SPCC and FRP

Tags: USCG, Facility Response Plan, OPA 90, Oil Spill, Facility Management, Communication Plan