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The Importance of Response Plan Training for the First Responder

Posted on Thu, Jan 22, 2015

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

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

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

Initial Response Actions:

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

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

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

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

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

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

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

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

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

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

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

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

  • Ability to identify the hazardous substances, if possible

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

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

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

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

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

  • Basic hazard and risk assessment techniques

  • How to select and use proper personal protective equipment

  • Basic hazardous materials terms

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

  • How to implement basic decontamination procedures

  • The relevant standard operating procedures and termination procedures

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

TRP Corp Emergency Response Planning Exercises

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

Key EPA Required Elements of a Facility Response Plan

Posted on Thu, Dec 04, 2014

As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, certain facilities that store and transport oil are required to develop, maintain, and submit a  Facility Response Plan (FRP). Maintaining regulatory compliance and an up-to-date FRP is an ongoing process.  As company operations evolve, and equipment and employees change, adjustments need to be incorporated into the FRP to ensure accuracy, compliance, and effective response capabilities.

Facility Response Plan: A detailed plan which must be prepared in accordance with 40 CFR 112.20 by facilities which may cause "substantial harm" to the environment or exclusive economic zone. The plan must contain an emergency response action plan (ERAP) and demonstrate that a facility has the resources to respond to a worst-case scenario discharge.- Oil Pollution Prevention Glossary

FRP development enables an owner or facility operator to develop a response organization capable of responding to an oil spill. The plan development and assessment process initiates the evaluation of:

  • Potential hazards
  • Response resources (i.e., response equipment, trained personnel)
  • Mitigation opportunities and discharge prevention measures
  • Response processes and procedures
  • Local and regional response capabilities

A regulatory compliant FRP should demonstrate that the appropriated response resources are available in a timely manner, thereby reducing impact and severity of an oil spill.

According to the EPA, an FRP must be:

  • Be consistent with the National Contingency Plan and applicable Area Contingency Plans
  • Identify a qualified individual having full authority to implement removal actions, and require immediate communication between that person and the appropriate federal authorities and responders
  • Identify and ensure availability of resources to remove, to the maximum extent practicable, a worst-case discharge
  • Describe training, testing, unannounced drills, and response actions of persons on the vessel or at the facility
  • Be updated periodically
  • Be resubmitted for approval for each significant change


The Environmental Protection Agency EPA’s 33 CFR part 112, Oil Pollution Prevention, describes response procedure requirements for oil discharges of all types, whether the cause is accidental, man-made, natural, or deliberate. While Part 112.21 of the 40 CFR regulation contains requirements for the development and implementation of a facility training program and drill/exercise program, Part 112.20 addresses the FRP requirements, which include, but are not limited to:

  • Notifications: The emergency response action plan portion of the FRP must include an accurate emergency phone list with information for the Qualified Individual, facility response personnel, response organizations, and local responders.
  • Evacuation: The FRP requires detailed evacuation plans for the facility, including primary and secondary evacuation routes, centralized check-in area, and references to community evacuation plans.
  • Vulnerability assessment: The FRP must include a detailed site diagram, hazard evaluation, and vulnerability assessment. The assessment in the FRP examines outcomes and potential effects of an oil spill, such as the shutdown of downstream water intakes.
  • Discharge Planning Scenarios: Site-specific scenarios and response resources must be addressed for small, medium, and worst-case spills. Most spill scenarios would likely be contained in specified areas or by specialized equipment, unlikely to travel off site. However, if the scenario created could potentially result in oil traveling off site, its migration pattern, potential traveling distance, and specifically identified locations should be detailed. A smaller facility may only need to plan for two scenarios or a single scenario if its worst-case discharge falls within one of the specified ranges for small or medium discharges.  The worst case planning quantity shall be the larger of the amounts calculated for each component of the facility. Discharges are categorized by the following volumes:
    • 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

Appendix F of the Oil Pollution Prevention regulation (40 CFR 112) includes a model Facility Response Plan. Key elements include:

  • Emergency Response Action Plan, which serves as both a planning and action document and should be maintained as an easily accessible, stand-alone section of the overall plan
  • 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 (e.g., fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)
  • Response plan cover sheet

For a free download on preparing for your next incident, click here or the image below:

Preparedness and Emergency Management - TRP Corp


Tags: Facility Response Plan, EPA, Regulatory Compliance

Maintaining Regulatory Compliance in an Oil Industry Acquisition

Posted on Thu, Oct 30, 2014

Oil companies are not stagnant entities.  Every year, the industry experiences acquisitions, mergers, and systemic transformations. The dynamic nature of the energy sector requires environmental, health, and safety departments, as well as facility managers, to periodically review and adjust their approach to emergency management and regulatory compliance.

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, including SPCC's and facility response plans, within the corporate enterprise should address site-specific facility details, applicable and tested response processes, and standardized company-wide best practices while maintaining location-specific regulatory compliance. A customizable response plan template can enable the development of a streamlined, site-specific preparedness program that consistently delivers company-standard guidelines and practices while providing a medium for rapid assimilation of merging or acquired facilities.

Industrial operations are required by law to institute site-specific emergency response plans, and train employees according to their response roles and pertinent response methods. Acquiring one or more new facilities typically presents challenges that generic or static response plan templates do not account for. Failure to incorporate site-specific details may result in incomplete, ineffective, and costly non-compliant plans.  Companies with multi-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.

Integrating response plans under one centralized format enables consolidated preparedness and response objectives. 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 that may be applicable to the new facilities. It is critical to define preparedness objectives, response roles, and responsibilities in order to eliminate ambiguity and confusion.  Responsible parties must apply new data, site assessments, and validated information into cohesive, compliant, and effective response plans for the new enterprise.

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 may be particularly vulnerable to crisis or emergency response situations.

Regulatory compliance - TRP Corp

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 and how will it be organized?

  • 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 to draw from?

  • 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 new facility and its employees?

  • Perform a detailed hazard and risk analysis
  • Verify or create response procedures for each identified threat
  • Identify 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
  • Identify site-specific alarms 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 designated 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

  • Establish 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
For a free Audit Preparedness Guide, click the image below:
Regulatory Compliance with TRP Corp
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Tags: Facility Response Plan, SPCC, Oil Spill, Emergency Management Program

The Facility Response Plan Assessment

Posted on Thu, Aug 07, 2014

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

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

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

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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

Yes _____ No_____

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


Self-Assessment Scoring

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

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

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

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

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

Helpful hints:

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

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

TRP Corp Emergency Response Planning Exercises 


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

3 "Best Practice" Concepts for Managing Established Response Plans

Posted on Mon, May 05, 2014

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

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

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

  1. Identify
  2. Review
  3. Verify

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

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

  • What risks and hazards may result in an incident?
  • What processes are put in place to limit the exposures to risks and hazards?
  • What community/environmental sensitivities exist?
  • Who will respond when an incident occurs?
  • How will responders respond (processes and procedures)?
  • How will individuals/employees respond to secure their safety?
  • What training will responders need to respond, counteract impacts, and restore to pre-incident levels
  • What tools/equipment are necessary to respond to an incident and who will provide these necessities?
  • What local, state, and/or federal organizations should be consulted?
  • What regulations apply?
2. Review: The preparedness process and response plans must be adjusted to accommodate newly identified variables. Reviews of response procedures, mitigation opportunities, best practices, response objectives, and operational requirements are necessary to ensure preparedness and effective response measures are in place. Reviews should include, but are not limited to:
  1. Data and computer needs: Review the procedural details of computer backups, data restoration methods, and the minimum program needs to re-establish critical business processes.  Companies should examine current data center outsourcing or other alternatives to ensure continuity and accessibility.
  2. Notification lists:  Response plan administrators must be certain that newly-assigned personnel are included in the plan, as necessary, and that notifications are being delivered to accurate e-mail addresses and/or phone numbers. Review contact lists to ensure all necessary information is correct.
  3. Communication needs: Clear and effective communication channels must remain available in order to disseminate information to employees, assess and relay damage, and coordinate a recovery strategy. Evaluate current communication equipment and/or mass notification systems to communicate to key individuals, company employees, or an entire client base, as each scenario deems necessary.
  4. Supply Chain: As a company’s needs change and new suppliers come online, potential suppliers should be evaluated and plans should be updated to reflect any changes. Alternate resources should be reviewed to ensure availability, delivery, and continued operations in the event primary suppliers are not available when needed.
  5. Essential Personnel: Ensure necessary minimum staffing levels are acceptable to remain operational.  Review individual responsibilities and recovery time objectives with staff, contractors, and suppliers.
  6. Equipment needs: Review availability of necessary equipment and establish processes for response, recovery, and continued operations, in order to minimize downtime and additional recovery efforts. .

3. Verify: The overall emergency response program readiness must be verified for effectiveness and accuracy, regardless of the threat or hazard. Training and exercises are valuable verification tools that can confirm effective response planning and preparedness efforts. Verification should include, but is not limited to:

  • A system for assessing emergency scenarios and prioritizing incident responses
  • Thresholds and procedures for activating the Incident Management or Crisis Management Team
  • Notification information (If maintaining accurate contact information is challenging, consider opting for a e-mail notification verification system that enables each contact to verify their own information. Companies can also offer incentives, such as drawings or prizes, to encourage all personnel to register for notifications.)
  • Roles and responsibilities of the Incident Management or Crisis Management Team members
  • Communication and notification procedures to facilitate interaction among responders and Incident Management Team
  • Guidelines and checklists to facilitate an effective and organized response
  • Verification of on-site hazardous materials details, response equipment, and response times

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

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

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD


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

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

Expert Insight: Managing Multiple Response Plans

Posted on Thu, Apr 10, 2014

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

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

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

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

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

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

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

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

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Preparedness and Emergency Management - TRP Corp

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

Consultants Combat Emergency Management Challenges: Oil and Gas Industry

Posted on Mon, Mar 24, 2014

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

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

Oil and gas emergency management program challenges may include:

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

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

TRP Corp - Oil and Gas Consultant

The costs associated with contracting consulting services are always in question. When hiring an external emergency management and preparedness consultant, oil and gas companies should evaluate the strategic cost of an incident and the tactical cost of safety compliance versus the consultant fee. The cost benefit of hiring a specialized, reputable consultant typically outweighs the financial impacts associated with non-compliance or a catastrophic incident.

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

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

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

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

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

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

Regulatory Compliance with TRP Corp


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

How HSE Audits Can Address Gaps in your Regulatory Plans

Posted on Mon, Mar 03, 2014

Regulatory requirements are designed to prevent injuries, releases of hazardous materials, and ensure adequate responses are in place if and when an incident occurs. However, companies often find themselves scrambling to fill identified gaps in processes, procedures, and response plans after a response or audit is completed. If these gaps are left open, companies can face fines, lawsuits, shutdowns, and/or reputational risk.

Fortunately, audits, whether conducted by in-house professionals or experienced consultants, can often reveal the same deficiencies and opportunities for improvement as regulatory agencies. Some companies address response plan gaps only after an incident or audit occurs. With an objective eye, a gap analysis can bolster an overall emergency management program and minimize the potential for an incident, fine, or inadequate response.

Regulatory requirements must be identified in order for gaps to be identified.. In order to maintain consistent compliance, facility managers and company health, safety, and environmental professionals should become familiar with regulations applicable to their area of responsibility and operations. If necessary, outside consults can be utilized to identify all applicable regulations based on company location(s), industry, operations, and hazards.


After an incident or audit, new or unidentified risks or regulatory gaps may be identified that were not previously included in response plans. Upon recognition, every effort should be made for mitigation. However, if the risks cannot be eliminated, new countermeasure processes and procedures must be implemented and response plans adjusted accordingly in order to eliminate potential gaps. If audits identify that applicable regulatory requirements are not met, specific content, and/or processes must be implemented and/or documented to satisfy those requirements.

The following concepts can assist in addressing gaps in regulatory plans:

  • High probability and operational risks should be cross-referenced with potential regulatory requirement(s).
    • Evaluate accident probability for each process, procedure, handled material, and their resulting levels of potential severity if an accident were to occur.
    • The probability and severity of a risk should determine the priority level for correcting the hazard. The higher the probability and severity of risk, the higher the emphasis should be on corrective action.
  • If accidents or incidents occur, isolate, eliminate, or mitigate the root cause, and identify any/all linking regulatory requirements.
    • Response plan documentation should include processes and procedures applicable to the accident or incident. If a gap was identified during the response, amendments must communicated, incorporated into training, and documented in the response plan.
  • If audits reveal regulatory gaps, changes in processes and/or procedures should be made in order to become compliant with regulatory agencies.
    • Process or procedural amendments must communicated, incorporated into training, and documented in the response plan.
    • Implement and document any risk reducing engineering controls
  • Proactive administrative controls or work place practices can reduce the potential of gaps in response plans, training, and/or exercises.
  • Accident prevention signs should be posted to remind occupants of the presence of hazards and applicable regulations
  • Establish and communicate emergency response plan content  to employees and appropriate emergency response team members. Provide a mechanism for workplace process feedback and regulatory implementation.
  • Implement web-based, database driven response plans.
    • Advanced technology allows for an audit “checklist”, specifically linking specific requirements to applicable content within the plan.
    • Provides the ability to duplicate recurring facility information to satisfy multiple agency requirements.
    • Eases the administrative time by easing the ability to update content and ever-changing regulations, minimizing the opportunity for regulatory implementation delays.


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Regulatory Compliance with TRP Corp

Tags: PHMSA, OSHA HAZWOPER, Facility Response Plan, EPA, Regulatory Compliance, Emergency Management Program

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.


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