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.
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.
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