Your Solution for SMART Response Plans

Key Facility Response Plan Tips for Spill Response Requirements

Posted on Thu, May 25, 2017

The environmental, health and safety landscape is riddled with stories of injuries, accidents, and emergencies. Some stories become headline news and others may be buried in the stacks of safety reports. Yet any incident, large or small, can impact your employees, your facilities, the surrounding environment, and your financial bottom line. While the intensity of events may vary, comprehensive, compliant, and functional response plans for each facility must be developed and maintained to address a broad scope of probable emergency and crisis situations.

Companies have an ethical and legal obligation to protect their employees while on the job. However, a response plan is only as effective as the accuracy of its information, potential emergency or crisis scenarios, and the level of responder comprehension. For facilities that store and/or utilize hazardous materials, the obligation to create a top-notch facility response plan is even greater.

The Facility Response Plan

A Facility Response Plan, which can serve as both a planning and response-guiding action document, should be easily accessible. Companies should confirm that regulatory compliance, inherent site-specific safety issues, response efforts, and human resource factors are addressed within each of their site plans. Depending on operations, a Facility Response Plan may consist of:

  • Facility information, including its name, type, location, owner, operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and analysis of potential spill hazards and previous spills
  • Discussion of small, medium, and worst-case discharge scenarios and response actions
  • Description of discharge detection procedures and equipment
  • Detailed implementation plan for response, containment, and disposal
  • Description and records of self-inspections, drills and exercises, and response training
  • Diagrams of facility site plan, drainage, and evacuation plan
  • Security (ex: fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)

As personnel responsibilities, facility or operational specifics change, response plans must change accordingly. At a minimum, cyclical plan maintenance is essential to capture multiple moving parts that impact an emergency management program. If a facility has a high-risk potential for a specific scenario or operations utilize hazardous materials, supplemental response plans, such as a fire pre-plan or business continuity plan, should be added to the overall emergency management program.

Industrial building factory.jpeg

Small, Medium and Worst-Case

It is essential that any company that transports, stores or handles hazardous materials ensure spills are properly cleaned up to minimize environmental impacts and  workers are not injured. The Environment Protection Agency (EPA) states that site-specific scenarios and response resources must be addressed for small, medium, and worst-case spills. Discharges are categorized as follows:

  • Small discharge: up to 2,100 gallons spilled
  • Medium: 2,100 to 36,000 gallons spilled, or 10% of the largest tank (whichever is less)
  • Worst Case Discharge: Volume of the largest tank over 36,000 gallons

The source of a small, medium, and worst-case discharge may stem from various facility operations and corresponding equipment components. If the worst-case discharge falls within one of the specified ranges for small or medium discharges, a smaller facility may only need to plan for that level of response. Potential discharge scenarios can be derived from human error, equipment malfunction, third party intervention, or severe weather. Typical site components relating to discharge scenarios include, but are not limited:

  • transfer hose failure
  • improper or faulty hose seals
  • valve failure
  • misaligned piping connection or seal failure
  • pump seal failure or overfill
  • tank overfill or leak
  • catastrophic failure of largest tank
Most spill scenarios are small and are unlikely to travel off site. These spills would likely be contained in specified areas or by specialized equipment. However, if the spill scenario could potentially result in oil traveling off site, its migration pattern, potential traveling distance, and specifically identified locations should be detailed.


Any spill response, despite the size of the spill, should incorporate the company defined preparedness structure and procedures. Despite the voluminous details and the nature of a spill, all employees and responders should demonstrate an understanding and application of company policies and agency requirements through an established training and exercise cycle.

TRP Corp Emergency Response Planning Exercises

Tags: Facility Response Plan, Oil Spill

Don't Be an OSHA Statistic: Preparedness & Facility Response Plan Tips

Posted on Thu, Mar 09, 2017

Every day across the United States, employees go to work expecting a typical day on the job.  Yet OSHA’s Reports of Fatalities and Incidents for Fiscal Year 2016 reveals that one or more work-related fatalities and incidents occurs daily. While some jobs are more hazardous than others, the detailed summary indicated 1,080 OSHA reported instances in 2016. How many more incidents go unreported?   Not only do emergencies and incidents happen, they happen every day - highlighting the importance of preparedness and response planning.

 

"It Won’t Happen Here"

When incidents occur, urgent and rapid decision making combined with a lack of resources and untrained personnel can lead to chaos and exacerbate the emergency. Response plans can minimize the chaos with pre-identified processes. To establish effective response plans capable of protecting employees and building occupants, companies should conduct analyses to identify necessary site-specific safety measures, including those required for regulatory compliance. Analyses should identify the following details:

  1. Site Analysis
  • Identify existing and potential site hazards through employee feedback, audits, and detailed inspections.
  1. Task Analysis
  • Determine job specific methods and procedures for each employee’s duty to reduce or eliminate associated hazards.
  • Review and update methods and procedure when an incident occurs, job responsibilities change, or if hazards are identified through analysis.
  1. Risk Analysis
  • Establish risk evaluation criteria, probability of incident, and potential consequences.
  • Monitor and review procedures for continuous improvement, effectiveness, control measures and changed conditions.

Besides the major benefit of providing guidance during an emergency, the preparedness process and analyses have other advantages. You may discover:

  • Unrecognized hazardous conditions that would aggravate an emergency situation
  • Deficiencies, such as the lack of resources (equipment, trained personnel, supplies)
  • Mitigation opportunities that can rectified incidents before an emergency occurs.

 

The Response Plan

Comprehensive, compliant, and functional response plans should be created to address a broad scope of planned responses for a variety of probable emergency and crisis situations. However, if a facility has a high-risk potential for a specific scenario, supplemental response plans can be added to the overall emergency management program. Inclusive programs may include a variety of plans including Facility Response Plans, Fire Pre-Plans, and Incident Response Plans, etc.  Response plans should include the following minimum information:

  • Building description
  • Plot plan(s) and floor plan(s)
  • Owner/Manager contact information
  • Emergency equipment inventory and locations
  • Evacuation routes
  • Emergency Assembly Point details
  • Internal and/or external emergency personnel information and contact details
  • Specific hazard details and possible safety data sheet information, if applicable
  • Utility shut-off locations and descriptions
  • Alarm(s) description
  • Policies and processes situational checklists
  • Job specific procedures

Industry factory in kawasaki at night.jpeg

A Plan for Every Site

An enterprise-wide response planning system can provide the framework required to ensure every facility under the corporate umbrella is compliant and prepared for the unexpected. An enterprise-wide system can remove many of the challenges associated with managing multiple response plans, streamline the update process, and simplify plan reviews, ensuring a consistent path toward compliance and readiness.

An enterprise-wide response planning system should:

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

 

Don’t be a Statistic 

With the revelation of the OSHA statistics, companies should ensure safety and preparedness is at the forefront of operations. Whether a company has one site or multiple facilities across the globe, response plans promote safety awareness and may help minimize the chance that of one of you employees becomes an OSHA statistic.

 

Preparedness and Emergency Management - TRP Corp

Tags: OSHA, Facility Response Plan, Response Plans, corporate preparedness

Homegrown Security Threats and the Facility Security Plan

Posted on Thu, Feb 09, 2017

A report by the New Jersey Office of Homeland Security and Preparedness ranked homegrown violent extremists as the number one threat to security. As a result, companies should continue to bolster their security training, response planning and preparedness efforts into 2017 so that they are better prepared to identify and respond to security issues.

According to the report, “Homegrown violent extremists are individuals inspired by foreign terrorist organizations and radicalized in the countries in which they are born, raised, or reside.”

Companies, security personnel and employees should remain vigilant.  The report identified “Eight Signs of Terrorism” that the private sector should be aware of. The signs include:

  1. Surveillance: Terrorists will attempt to determine the strengths, weaknesses, and number of personnel that may respond to an incident.
  2. Elicitation/Seeking Information: Attempt to gain information through inquiries, including seeking knowledge about a place, person, or operation.
  3. Tests of Security: Either through visual observations or physical entry, suspects may move into sensitive areas, and observing security and law enforcement responses.
  4. Acquiring Supplies: The purchase or theft of explosives, weapons, or ammunition. It could also include unusual purchasing or storing of fertilizer or harmful chemicals. Terrorists also find it useful to acquire law enforcement equipment and identification, military uniforms and decals, and flight passes, badges, or manuals.
  5. Suspicious People: Observe suspicious people who do not belong. The suspicious person could be anyone in a building, neighborhood, or business establishment who seems out of place because of their demeanor or line of questions.
  6. Dry Run: Before the execution of an operation, a practice trial is usually run to work out any flaws or unanticipated problems.
  7. Deploying Assets: Look for someone deploying assets or getting into position. This is your last chance to alert authorities before a terrorist act occurs.
  8. Terrorism Funding: Terrorists use a variety of methods to raise, launder, and transport funds including false credit cards,

But with so many dynamic and security-related response planning variables, site-specific security training and preparedness planning can be challenging. A database driven, web based response planning system can alleviate some of those challenges.

fencing-resized-600.jpg

A security assessment should be performed in order to identify areas at the facility that may be vulnerable to a security threat. In order to address security issues, a facility response plan should include, but is not limited to the following security related components:

Notifications:

  • The Facility Security Officer must have a means to effectively notify site personnel of changes in facility security conditions.
  • Transportation security incidents must be reported to the National Response Center and to appropriate emergency responders.
  • At each active facility access point, a system must be in place to allow communication with those that have security responsibilities, including the police, security control, and the emergency operations center.

Fencing and monitoring:

  • Security measures should be in place to prevent unauthorized access to storage areas. Facilities should provide continuous monitoring through a combination of lighting, security guards, and other detailed methods.

Evacuation:

  • The owner or operator must identify the location evacuation routes and assembly stations to ensure that personnel are able to safely evacuate during a security threat.

A security plan should describe the training, drills, and security actions of personnel at the facility. These actions should deter, to the maximum extent practicable, a security incident, or a substantial security threat. Facility personnel should receive varying levels of security training depending upon their responsibilities. Security training levels may vary, but might include:

  •  Knowledge of current security threats and patterns
  • Recognition and detection of dangerous substances and devices
  • Recognition of characteristics and behavioral patterns of persons who are likely to threaten security
  • Techniques used to circumvent security measures
  • Crowd management and control techniques
  • Security related communications
  • Knowledge of emergency procedures and contingency plans
  • Operation of security equipment and systems
  • Testing, calibration, and maintenance of security equipment and systems
  • Inspection, control, and monitoring techniques
  • Relevant provisions of the Facility Security Plan

 

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, Security plans

Severe Weather Projections Require Energy Sector Response Planning

Posted on Thu, Oct 15, 2015

According to an October 2015 report by the Department of Energy, the US energy infrastructure may not be able to withstand projected extreme weather changes associated with temperatures, precipitation, hurricanes, wildfire, and sea-level rise. Infrastructures were designed to perform across a known range of historical conditions. However, record breaking climate conditions that fall outside historical parameters have the potential to expose new vulnerabilities and stress the US energy infrastructure. As a result, it is imperative that companies ensure preparedness and response planning initiatives that reflect a new range of potential risks and climatological threats.

The private sector, which owns and operates the majority of energy assets in the US, holds central responsibility for identifying and implementing appropriate measures to ensure infrastructure resilience, continuity, and response. “In recent years, record temperatures, droughts, and floods have damaged energy infrastructure and disrupted energy systems, affecting American families and businesses across the country,” said Energy Secretary Ernest Moniz. The report highlighted the following major energy systems and susceptible locations that have the potential to be affected by regional climate impacts:

  • Oil and gas upstream operations are most vulnerable in the Southeast, Southern Great Plains, and Alaska, particularly to decreasing water availability, and increasing temperatures and frequency of intense storms, hurricanes and storm surge.
  • Fuel transport in every region is vulnerable to a variety of climate impacts, including increasing heavy precipitation, heat waves, drought, hurricanes, and sea level rise-enhanced storm surge.
  • Thermoelectric power generation is vulnerable to increasing temperatures and reduced water availability in most regions, particularly in the Midwest, Great Plains, and southern regions.
  • Hydropower is vulnerable to reduced snowpack, earlier melting, and changes to precipitation and runoff patterns, mainly in western regions.
  • Bioenergy crops in the Midwest and Northern Great Plains may be harmed by higher temperatures and more frequent droughts and floods.
  • Electric grid operations and infrastructure in every region is vulnerable to a variety of climate impacts, including increasing temperatures, heavy rainfall events, wildfire, hurricanes, and storm surge.
  • Electricity demand is affected by increasing temperatures and is a key vulnerability in nearly every region.

Projected Climate Impacts on US Energy Sector by Region

Source: U.S. Department of Energy, Office of Energy Policy and System Analysis 

With the potential for more frequent and severe disruptions, preparedness and response planning measures should be reviewed. At a minimum, the following severe weather measures should be included in a site-specific preparedness program:

PREPAREDNESS

Establish, verify, and exercise communication plans:
  • Verify contact details and identify communication procedures with employees, emergency personnel, critical business unit leaders, and contractors in the event of an emergency
  • Establish response plans in a portable format that can accessed through a variety of methods
  • Verify availability and viability of communication equipment
  • Monitor and determine applicable response procedures based on radio, television, and/or weather reports

Establish, verify, and exercise resource management and supply chain measures:

  • Coordinate activities with local and state response agencies
  • Evaluate equipment needs
  • Pre-select alternate resources to ensure necessary response equipment is available when needed
  • Pre-select alternate delivery of critical needs in the event primary suppliers are not able to provide required services such as:
    • Electrical power
    • Water
    • Fuel
    • Telecommunications
    • Transportation
    • Staffing
    • Waste Management
    • Operations-specific equipment

Establish, verify, and exercise personnel roles and responsibilities:

  • Conduct site specific awareness training, including facility evacuation routes and shelter in place procedures
  • Identify employees that should remain on-site (if deemed safe), and their responsibilities.
  • Identify necessary minimum staffing levels and assignments necessary for recovery operations.
  • As the storm passes, ensure staff, contractors, and suppliers understand their individual responsibilities and recovery time objectives.
  • Train employees to recognize, report, and avoid hazardous chemicals discovered during debris clean up.
  • Ensure that key safety and maintenance personnel are thoroughly familiar with all building systems, such as alarms, utility shutoffs, elevators, etc.

Infrastructure-related RESPONSE MEASURES

  • Evaluate building structures, roadways, surfaces, trenches and excavations for damage, stability and safety
  • Inspect the worksite before allowing employees to enter
  • Report hazards such as downed power lines, frayed electrical wires, or gas leaks to the appropriate authorities
  • Assume all wires and power lines are energized
  • Beware of overhead and underground lines, especially when moving ladders or equipment near them
  • Utilize a site plan for collection of debris
  • Inform employees where debris is being collected and deposited of any special hazards they may encounter during recovery efforts
  • Be aware of possible biological hazards
  • Use flaggers, traffic cones and highway channeling devices to steer traffic away from hazards and employees working along roadways
  • Provide traffic flow details and train employees to stay clear of all motorized equipment.
  • Provide radio equipment and extra batteries to all spotters and equipment operators, so warnings can be communicated
  • Utilize point of contact for employees check in procedures
  • Freeze all computer system updates so that systems will not be damaged by electrical surges
  • Ensure employee safety
    • Before engaging in strenuous tasks in extreme temperatures, consider employee's physical condition, weather factors, and the nature of the task.
    • Wear long pants, a long-sleeved shirt and sturdy shoes when examining walls, doors, staircases and windows for damage
    • If applicable, provide all employees with personal protective equipment (PPEs), including hard hats, safety glasses, work boots, and gloves
Preparedness and Emergency Management - TRP Corp

Tags: Facility Response Plan, Extreme Weather

FRP Compliance for Crude Oil Storage Facilities

Posted on Thu, Aug 27, 2015

According to an August 11th report by the U.S. Energy Information Administration, crude oil storage fell slightly from 1,150.4 million barrels on July 31, 2015 to 1,148.7 million barrels on August 7, 2015. Although crude levels continue to vary, facilities that are bound by the EPA Facility Response Plan (FRP) requirement must ensure compliance. This is especially true during mergers, acquisitions, and when new storage facilities come online. In response to the potential growth opportunities, numerous U.S. companies are expanding storage capabilities.

  • Magellan Midstream Partners and LBC Tank Terminals have a $95 million crude oil storage and transportation project along Houston’s Gulf Coast. The two companies said they will build about 700,000 barrels of new crude oil storage and distribution infrastructure near Seabrook, Texas, about 30 miles southeast of Houston. The new storage will be connected into the area’s existing oil transportation infrastructure by a planned 18-inch diameter pipeline.
  • The Louisiana Offshore Oil Port is adding three new above-ground oil tanks and 1.1 million barrels of storage capacity to its Clovelly Hub, one of the nation's largest oil trading and distribution centers. It is expected to be completed by late summer 2016.
  • Florida Fuel Connection is investing $75 million to build a petroleum terminal and rail transportation facility near the Mississippi River.

tanks-resized-600

Because a single oil spill can have a significant or catastrophic impact, it is imperative for emergency managers to evaluate response processes for best practices and maintain the most current FRP possible. Storage facilities that meet EPA capacity thresholds and could reasonably cause "substantial harm" to the environment by discharging oil into or on navigable waters, must prepare and submit FRPs. Facilities that could cause "significant and substantial harm" are required to have their plans approved by an EPA Regional Administrator (RA).

Substantial Harm
According to the FRP rule, a facility may pose "substantial harm" if:

  1. The site has a total oil storage capacity greater than or equal to 42,000 gallons and it transfers oil over water to/from vessels; or
  2. The site has a total oil storage capacity greater than or equal to 1 million gallons and meets one of the following conditions:
  • Does not have sufficient secondary containment for each aboveground storage area.
  • Is located at a distance such that a discharge from the facility could cause "injury" to fish, wildlife, and sensitive environments.
  • Is located at a distance such that a discharge from the facility would shut down a public drinking water intake.
  • Has had a reportable discharge greater than or equal to 10,000 gallons within the past five years.

If the facility meets the criteria, an FRP is required to be prepared and submitted to the regional EPA office. Once the FRP is submitted to the EPA, the regional administrator (RA) will review and determine if the facility should be classified as a significant and substantial harm facility. If the regional administrator determines that the facility could cause significant and substantial harm, the FRP requires approval by the RA.

Significant and Substantial Harm
An RA determines if a facility could cause significant and substantial harm to the environment by discharging oil into or on the navigable waters and adjoining shorelines. This is determined by factors similar to the substantial harm criteria, as well as:

  • The age of tanks;
  • Type of transfer operations;
  • Oil storage capacity;
  • Lack of secondary containment;
  • Proximity to fish, wildlife, and sensitive environments or drinking-water intakes;
  • Spill history and frequency of past discharges; or
  • Other information, including local impacts on public health.

The landscape of growth opportunities may be changing as the Department of Commerce recently announced a partial lift to the 1975 Energy Policy and Conservation Act ban allowing U.S. companies to export domestically produced crude oil to Mexico. However, despite the change or volatility of the oil industry, companies must ensure regulatory compliance remains across their enterprise.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: Facility Response Plan, Oil Spill

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

Company FRP and SPCC Compliance within Proposed 2016 EPA Budget

Posted on Thu, Jun 04, 2015

As part of the proposed $8.6 billion Environmental Protection Agency (EPA) 2016 budget, the agency is allocating $18.5 million for the Oil Spill Prevention, Preparedness and Response program. The program aims to protect U.S. environment by effectively preventing, preparing for, responding to, and monitoring oil spills.

According to the EPA’s Budget in Brief, the agency “will perform inspections of regulated high-risk oil facilities to better implement prevention approaches and to bring 60 percent of Spill Prevention, Control, and Countermeasure (SPCC) and Facility Response Plan (FRP) inspected facilities found to be non-compliant during the FY 2010 through FY 2015 inspection cycle into compliance.”

Oil spills can threaten human health, cause severe environmental damage, and create financial loss to businesses and the public. According to the EPA, there are currently over 600,000 SPCC-regulated facilities under the EPA’s jurisdiction, including a subset of roughly 4,300 facilities subject to FRP requirements. Rather than be susceptible to fines, penalties, and negative publicity, companies that are required to comply with SPCC and FRP regulations should ensure response plans are up-to-date and effective. Evaluating company operations and each facility’s site-specific information will determine necessary elements for regulatory compliance and response plan requirements.

Compliance monitoring is comprised of all activities that determine whether regulated entities are in compliance with applicable laws, regulations, permit conditions, and settlement agreements. In coordination with these governances, the EPA’s Compliance Monitoring program’s goal is to determine whether conditions exist that may present imminent and substantial threat to public health or welfare of the United States.

The 2016 proposed budget enables the EPA to have a greater emphasis on emergency preparedness, particularly through the use of unannounced drills and exercises. It is imperative that facilities and responders can effectively implement established response plans according to regulations. In FY 2014, the EPA was able to bring 79% of FRP and 72% of SPCC facilities into compliance due to the development of improved guidance and procedures. The compliance program will continue to focus resources on bringing non-compliant facilities into compliance.

EPA_OIl_Facility_ComplianceSource: EPA (Chart presents data as of end of FY2014. Data represent the percentage of facilities found initially compliant in a particular year and facilities previously found to not be in compliance that were brought into compliance out of the respective sets of facilities inspected. Therefore, the numbers do not total to 100 percent.)

Compliance monitoring activities include data collection, analysis, data quality review, on-site compliance inspections/evaluations, investigations, and reviews of facility records and reports.
The EPA ensures that the management and oversight of the compliance monitoring program is enhanced by the exchange of information from the FRP and SPCC data systems to the EPA’s Integrated Compliance Information System (ICIS). This exchange provides the EPA the opportunity to focus compliance monitoring resources on areas of highest risk, and increase transparency to the public of this enforcement, and compliance data. In addition, submitting information into ICIS electronically improves data coverage and quality.

The ability to streamline the regulatory submission process is advantageous for both industry and regulatory agencies. As opposed to paper plans, web-based planning is extremely beneficial for organizations that are subject to multiple applicable regulatory requirements. A web-based planning system with a regulatory tracking element can eliminate redundancies across converging compliance requirements, which maximizes informational consistency and administrative productivity. Many companies have embraced the benefits of streamlined web-based preparedness programs because of cost efficiency, information accessibility, and the ability to verify compliance. By advancing submission practices and raising industry standards, the EPA embraces a higher level of accuracy, availability, and consistency.

As part of the 2016 budget, the EPA states it will finalize the development and begin implementation of the National Oil Database including identifying requirements for electronic submission of Facility Response Plans (FRP) in order to create reporting efficiencies for the agency, states, local government and industry. The ICIS and database will support a more comprehensive analysis and better management of the FRP and SPCC compliance programs.

Note: FRP facilities are currently required to submit their plans to the EPA Regional Offices, while SPCC facilities maintain their plans onsite.

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, SPCC, EPA

Enterprise-Wide Contingency Planning & Regulatory Compliance

Posted on Thu, May 07, 2015

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

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

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

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

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

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

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

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

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

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

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

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

Common Response Plan Mistakes in Corporate Preparedness Programs

Posted on Thu, Mar 05, 2015

Response planning challenges are often exaggerated by corporate downsizing, reorganizations, mergers, or acquisitions. As companies reorganize and/or grow, response plans can quickly become outdated and non-compliant. Through internal audits, companies can identify regulatory compliance requirements and whether minimum corporate emergency preparedness criteria are met. However, audits also may reveal process or procedural inadequacies, contradictory plan formats, or inaccurate information.

Whether organizational changes are the result of new facilities or acquired through a merger or acquisition, ensuring preparedness, regulatory compliance, and employee safety requires a committed emergency management staff and a fundamental emergency management program with streamlined, coordinated, and exercised response plans. Although there are many complexities and costs associated with regulatory compliance, the regulations exist to protect public interest, the company, and surrounding sensitive environments. If staff, programs, and/or plans are insufficient for an effective response, the status quo of companies and communities may be compromised.

With so many operational components, it is critical that plans be audited to determine potential discrepancies and regulatory deficiencies. Once discrepancies and deficiencies are identified, adjustments can be made for to ensure compliance, efficiency, and effectiveness. Response plan audits often identify the following:

  • Personnel listed in plans are no longer employed with the company
  • Emergency response duties and responsibilities are not assigned to appropriate personnel
  • Inaccurate contact information for company personnel and external resources
  • Lack of detailed oil or hazardous material spill response procedures regarding
  • Lack of specific tank fire pre-plans and foam calculations
  • Training deficiencies
  • Inefficient documentation of training records
  • Inconsistencies with Area Contingency Plans and/or local regulations
  • Differing plan formats and versions resulting in varied information and disjointed composition
  • No efficient process for implementing lessons learned, changes in policies, or regulatory requirements

A dedicated regulatory intelligence team or the EHS manager may be responsible for the daunting task of sifting through the mountains of location-specific regulations, mandates, and guidelines in order to modify determined deficiencies.  In some instances following an external regulatory compliance audit, authorized agencies may demand deficiencies be addressed within a certain time frame. Agencies can impose fines and ultimately shut down operations for missed deadlines or ignored requisitions.

Those responsible for the emergency management program must remain vigilant to ensure plans are up-to-date and compliant in order to minimize financial penalties. When regulatory fines are assessed, companies can encounter additional collateral damage. Negative media exposure and antagonistic public opinion can quickly escalate when companies mismanage personnel safety or disturb environments that result from regulatory compliance failures.  Ineffectively planning for or responding to an oil spill, fire, or other incidents can lead to a company’s demise. In order to prevent escalating effects, response plan audits and reviews should be scheduled, at a minimum, on an annual basis

While companies may not need to “reinvent the wheel” when it comes to safety and response procedures, facilities need to confirm that best practices apply to their site-specific situation. Each facet of a company’s operations should be broken down to examine specific best practices for a particular action, material, scenario, or site circumstance. For example, safety and response 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

An effective compliance management process that includes regularly scheduled plan audits can result in an efficient and integrated program that optimizes the efforts of all company stakeholders and limits operational downtime. Effective technology can aid in managing response planning administrative duties associated with continually evolving personnel, operations, and regulatory requirements. Multi-facility operations should consider utilizing web-based technology to ensure enterprise-wide compliance on multiple government agency fronts.

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, Response Plans

Enterprise-Wide OPA 90 Plans: Standardize and Comply

Posted on Thu, Feb 12, 2015

Amidst the challenges of sustaining profitable operations, oil and gas companies must ensure that employees and work conditions are compliant with various regulations in order to manage innate risks, operational hazards, and minimize potential detrimental impacts. As a result, regulatory agencies require response plans and response exercises that adequately reflect the current operations and emergency response capabilities.

In the wake of the Exxon Valdez oil spill, emergency preparedness requirements were reassessed and the Oil Pollution Act of 1990 (OPA 90) was created to instill comprehensive prevention, response, liability, and compensation policies for vessel and facilities that could cause oil pollution to U.S. navigable waters. The law requires that regulated facilities and vessels develop and submit oil spill plans for approval. For facilities adjacent or nearby shorelines, OPA 90 requires compliant site-specific Facility Response Plans (FRP).

Yet, because of the rapid decline in the price of oil, emergency managers are, once again, being asked to “do more with less”. Reduced staffing levels and heightened personnel responsibilities due to budget constraints create various enterprise-wide challenges for environment, health and safety professionals. The mandate of managing and maintaining multiple emergency response plans and ensuring regulatory compliance and site specific accuracy can be a continual uphill battle.

Oil spill responses can be challenging dynamic scenarios with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. FRPs must provide procedures to quickly, safely, and effectively respond to these potential spills to prevent further damaging effects. This is challenging for a company that has multiple facilities that fall under the OPA 90 compliance requirements.

oilspill

FRPs require site-specific information and response details including, but not limited to:

  • Emergency Response Action Plans, which serves as both a planning and action document
  • Facility information, including  name, type, location, owner, and operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and analysis of potential spill hazards and spill history
  • Discussion of small, medium, and worst-case discharge scenarios and response actions
  • Description of discharge detection procedures and equipment
  • Detailed implementation plan for response, containment, and disposal
  • Description and records of self-inspections, drills and exercises, and response training
  • Diagrams of facility site plan, drainage, and evacuation plan
  • Security (e.g., fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)
  • Response plan cover sheet

An enterprise-wide response planning system can remove the uncertainties and challenges associated with managing multiple, regulation-driven response plans. A single web-based system can streamline the update process and simplify plan reviews, ensuring a consistent path toward compliance.  For companies with various facilities, advanced systems offer budget-friendly, advantageous response plan management opportunities, improve the overall planning system framework, and provide greater  accuracy of site-specific emergency response plans.

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

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

An enterprise-wide response planning system enables EHS departments to augment dwindling budgets, spend more time on preparedness planning, and maximize response efforts. The result is a more streamlined company emergency management program that reduces administrative efforts, non-compliance fines, and ineffective responses.

For a free white paper on standardizing response planning, click the image below:

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: Facility Response Plan, Emergency Preparedness, OPA 90, Oil Spill