Your Solution for SMART 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.


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

Compliance Tips for Industrial Emergency Management Exercise Programs

Posted on Tue, Jun 17, 2014

The National Preparedness for Response Exercise Program (PREP) is a unified federal effort established to provide a consistent set of guidelines that satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline and Hazardous Materials Safety Administration, and the Bureau of Safety and Environmental Enforcement in an economically feasible manner.

The intent is to create a workable exercise program which meets section 4202(a) of the Oil Pollution Act of 1990 amending section 311(j) of the Federal Water Pollution 6 Control Act, by adding a new subsection for spill response preparedness (33 USC 1321(j)(7)). Facilities and vessels required to adhere to these regulations must establish a compliant exercise program to ensure an adequate response to an oil spill.

Plan holders may develop a customized exercise program based on site operations or utilize the PREP exercise guidelines. The program must comply with the appropriate Federal oversight agency and regulatory exercise requirements. In order to maintain PREP compliance, all core components of a response plan must be exercised every three years. However, it is not required to conduct a major exercise every three years. PREP compliance can be obtained by exercising individual components within in a three-year cycle. The exercises must incorporate the following core PREP components:

  1. Notifications
  2. Staff mobilization
  3. Ability to operate within the response management system described in the Plan
  4. Discharge prevention/control
  5. Assessment of discharge
  6. Containment of discharge
  7. Recovery of spilled material
  8. Protection of sensitive areas
  9. Disposal of recovered material and contaminated debris
  10. Communications
  11. Transportation
  12. Personnel support
  13. Equipment maintenance and support
  14. Procurement
  15. Documentation

Exercises should be designed to test the aforementioned response plan components for effectiveness and accuracy. In order to satisfy the PREP requirement, plan holders must be able to document all operational and support aspects of a response, and provide detailed records of decisions and actions taken. Exercise requirements vary depending on operations. Vessels, unmanned barges, and certain identified facilities each have specific exercise requirements. Generally, the types of exercises required include:

1. Qualified Individual (QI) notification exercises: The purpose of the QI notification exercise is to ensure that the QI (or designee) listed in the response plan will respond as expected and carry out his or her required duties in a spill response emergency. Contact by telephone or electronic messaging must be made with the QI, and confirmation must be received from him or her to satisfy the requirements of this exercise. At least once per year, the QI notification exercise should be conducted during non-business hours.

2. Emergency procedures exercises: The purpose of the emergency procedures exercises is to ensure that personnel are capable of conducting the initial actions necessary to mitigate the effects of a spill. Specific regulations apply to vessels and unmanned barges. USCG and EPA Marine Transportation-Related Facilities have the option of conducting emergency procedures exercises. For the purpose of the PREP, emergency procedures for facilities are the procedures established to mitigate or prevent any discharge or a substantial discharge threat resulting from facility operational activities associated with cargo transfers. An unannounced emergency procedures exercise would satisfy the facility's requirement for the annual unannounced exercise.

3. Equipment deployment exercises: The purpose of equipment deployment exercises is to ensure response equipment is appropriate for the operating environment and that operating personnel are trained in its deployment and operation. It is not necessary to deploy every piece and type of equipment as long as all equipment is included in a periodic inspection and maintenance program. The inspection and maintenance program should ensure that the equipment remains in good working order.

4. Spill Management Team (SMT) tabletop exercises: At least one SMT Tabletop Exercises in a triennial cycle should involve a worst-case discharge scenario. If a response plan lists different types of SMTs for varying spill sizes (ex, a local SMT for small spills, a regional team for larger spills, and a national team for major spills), each team identified should be required to conduct an annual SMT tabletop exercise.

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

TRP Corp Emergency Response Planning Exercises

Tags: USCG, PHMSA, OPA 90, Training and Exercises

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

Managing Response Plans for Multiple Regulatory Agencies

Posted on Thu, Mar 20, 2014

The challenge of managing and ensuring compliant response plans for multiple facilities and multiple regulatory agencies is daunting. When audits reveal planning gaps, unless amended, enforcement mandates and costly non-compliance fines may result from the lack of an implemented, thorough, or effective regulatory compliance programs. By utilizing an enterprise-wide template approach to response plans, companies can satisfy multiple regulatory requirements through a cohesive, yet site-specific standardization of best practices.

In order for emergency plans to be timely, effective, and compliant, site-specific facility information and operational hazards must be addressed and included in a template plan. Off-the-shelf, generic response plan templates will not address every aspect required of an emergency plan. Utilizing generic templates often results in incomplete, ineffective, and non-regulatory compliant plans.

If templates are connected to a web-based database, site-specific information can be cross-referenced with regulatory requirements. As facilities are added or modified, operations are revised, or employees are re-assigned, each plan can be conveniently accessed and updated for accuracy and compliance.

The use of a consolidated emergency, or all-hazards response plan can be adapted to comply with multiple regulations. Annexed plans, such as fire pre plans or business continuity plans can be created to provide more specific and comprehensive response procedures. With a comprehensive, web-based response plan template, emergency managers can:

  • Reduce the need for multiple plans for a single facility
  • Minimize administrative costs
  • Simplify plan reviews
  • Minimize discrepancies across various plans
  • Streamline response directives from one source
  • More easily identify regulatory compliance gaps

The planning template must incorporate all local, state and federal regulations. The following questions may assist companies in determining site-specific information requirements for developing an emergency plan template.

1. How will the emergency be reported and response initiated?

  • Create notification procedures. Emergency notifications may include 911, National Response Center, and internal and/or external response teams
  • Identify alarms and how they will be activated.  Specific alarm signals may signal employee evacuation or shelter in place. Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in immediate response actions, as described in plan
  • Identify emergency classification levels to ensure appropriate response actions and resources

2. Who will be in charge of the Incident and who will conduct additional response duties?

  • Create Emergency Management Team organizational chart and activation procedures
  • Create Emergency Management Team roles and responsibilities checklists

3. What threats affect the facility or employees?

  • Perform a detailed hazard and risk analysis
  • Create response procedures for each identified threat
  • Create a process for incident documentation
  • Utilize appropriate ICS Form(s)
4. What incidents or classification level require evacuation/shelter in place
  • Create multiple evacuation routes
  • Determine criteria as to whether evacuation goes beyond facility borders
  • Identify the muster point(s) and head count procedures

5. How are response actions sustained?

  • Identify command post locations and equipment requirements
  • Identify response resources and equipment (both internal and external)
  • Create communications checklist and identify communications equipment available
  • Identify hazard control applicability and methods
  • Detail external communications and public relations policies

6. What is done after the incident is secured?

  • Create checklist for demobilization guidelines
  • Perform a post-incident review and debriefing
  • Identify  “lessons learned”, assign action items, and update response plan accordingly

In 1996, the National Response Team published the Integrated Contingency Plan (ICP) Guidance in an effort to provide companies with the means to comply with multiple federal planning requirements required by various regulatory agencies.  The ICP, based on the National Incident Management System (NIMS) and the Incident Command System (ICS), was intended to be used by companies to prepare emergency response plans for responding to releases of oil and non-radiological hazardous substances.

An industrial facility may use an ICP to incorporate one or more of the following applicable federal regulations:


  • Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements), 40 CFR part 112.7(d) and 112.20-.21
  • 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.
  • Risk Management Programs Regulation, 40 CFR part 68

Department of the Interior:

  • Bureau of Safety and Environmental Enforcement Facility Response Plan Regulation, 30 CFR part 254

Department of Transportation/Pipeline and Hazardous Materials Safety Administration:

  • PHMSA Pipeline Response Plan Regulation, 49 CFR part194
  • U.S. Coast Guard, Facility Response Plan Regulation, 33 CFR part 154, part 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

Facilities may also be subject to state emergency response planning requirements that are not included in the National Response Team ICP Guidance. Facilities are encouraged to coordinate development of their own ICP with relevant state and local agencies to ensure compliance with any additional regulatory requirements.

For a free Audit Preparedness Guide for Industrial Regulatory Compliance, click the image below:

Regulatory Compliance with TRP Corp

Tags: USCG, PHMSA, DOT, OSHA, Response Plans, EPA, OPA 90, Regulatory Compliance

USCG Oil Spill Planning and the Facility Response Plan

Posted on Thu, Sep 26, 2013

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

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

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

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

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

Prioritized notification procedures

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

Facility’s spill mitigation procedures

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

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

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

Sensitive Environments

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

Training and Exercises

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

Site Specifications

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

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

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


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

Energy Infrastructure Earns D+ : Preparedness Planning is Essential

Posted on Mon, Jun 24, 2013

Businesses rely on infrastructure for operational productivity and economic stability. Every 4 years, the American Society of Civil Engineers (ASCE) releases a “Report Card for America’s Infrastructure” that depicts the condition and performance of the United State’s infrastructure. Each type of infrastructure is assigned a letter grade, similar to a school report card. According to the 2013 report, the Energy sector infrastructure received a D+.

The aging electrical grid, some of which originated in the 1880s, and pipeline distribution systems are becoming more susceptible to failure. The report stated, “Ongoing permitting issues, weather events, and limited maintenance have contributed to an increasing number of failures and power interruptions”. Over the next five years, nearly 17,000 miles of new high-voltage transmission lines, as well as additional oil and gas pipelines are scheduled for construction. Despite plans, new construction is slow and expensive, leaving established infrastructure vulnerable until mitigation efforts are complete.

For companies, this potential for infrastructure failure highlights the importance of securing supply chains and assessing response plans. When extended power failures occur, companies operations can endure significant challenges and potential financial losses. “If the electricity goes out, businesses will shut down for the day,” said Gregory E DiLoreto, P.E.,President of ASCE.  “They will send their workers home. Goods and products don’t get made (and) profits are lost.”

Identifying critical utility and technology related operations is the first step in mitigating the potential threat of an extended power outage. Possible critical utility and technology involved in business operations include, but are not limited to:

  • Utilities including electric power, gas, water, hydraulics, compressed air, municipal and internal sewer systems, wastewater treatment services
  • Security and alarm systems, elevators, lighting, life support systems, heating, ventilation and air conditioning systems, electrical distribution system.
  • Manufacturing equipment, pollution control equipment
  • Communication systems, both data and voice computer networks
  • Transportation systems including air, highway, railroad and waterway

Once utility and technology related operations are identified, the following planning considerations should be taken into account in order to safeguard critical systems and develop an effective business continuity plan:

  • Determine the impact of service disruptions and mitigate if possible (generators, fuel, relocating inventory, back up suppliers etc.)
  • Ensure that key safety and maintenance personnel are thoroughly familiar with all building systems, such as alarms, utility shutoffs, elevators.
  • Establish company-wide computer security, download, and backup practices in order to secure technologies and communications networks.
  • Establish procedures for restoring systems.
  • Establish preventive maintenance schedules for all systems and equipment.

But energy infrastructure is not limited to power sources. Both the input and output supply chain associated with energy transmission must be secured. Despite corporate and regulatory inspection efforts and equipment evaluations and retrofits, oil and gas pipeline companies must be prepared for potential structural failures that inhibit overall energy operations and potentially affect the environment. Utilizing facility response plans and tactical response plans can address emergency response obstacles associated with pipeline failure.

Facility response plans are required by regulatory agencies for facilities that could potentially cause substantial harm to the environment by discharging oil into or on navigable waters. These plans present processes and procedures for mitigating additional harm to personnel, the facility, and the environment in the event of an incident. Tactical plans are beneficial in responding to pipeline incidents that can occur across various impact zones. It is typically not practical for Pipelines to utilize secondary containment, which eliminates a factor of safety often utilized for tanks and other equipment. Tactical plans deliver location-applicable response information across multiple pipeline zones. This short-term, site-specific information informs responders how to best access, assess, and respond to offsite spills.  At a minimum tactical response plans should:

  • Allow response personnel to prepare for and safely respond to spill incidents at sensitive locations  
  • Ensure an effective and efficient response despite geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response at the location
  • Outline response procedures and techniques for responding to a spill at a specific location
  • Improve regulatory compliance efforts through a more complete response plan

While companies continue to mitigate and rectify aging infrastructure issues that can cause disruptions and potential destruction, response planning and preparedness must be prioritized in order to sustain operations, potential profitability, and overall economic growth.

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Tags: Emergency Preparedness, Crisis Management, OPA 90, Oil Spill, Emergency Management Program

The Oil Spill Response Plan and Contingency Planning

Posted on Mon, Feb 11, 2013

Oil spill response planning and preparedness are necessary to satisfy applicable regulatory requirements, protect the environment, and ensure the best possible safety scenario for responders and employees. Local, state and federal regulatory agencies may require varied site information depending on particular oil-related operations and locations. Yet, all plans related to oil releases have one common thread: to minimize the impact of the spill.

The primary objectives of spill response plans, regardless of whether a facility is a production, storage, or a transport facility, are to:

  • Allow response personnel to prepare for and safely respond to spill incidents
  • Ensure an effective and efficient response that highlight and account for geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response
  • Outline response procedures and techniques for combating the spill at a specific location
  • Improve regulatory compliance efforts

According to the Environmental Protection Agency (EPA), an oil spill contingency plan should be a set of instructions that outlines necessary procedures for before, during, and after an emergency. “A contingency plan looks at all the possibilities of what could go wrong and, “contingent” upon actual events, has the contacts, resource lists, and strategies to assist in the response to the spill.”

Oil spill contingency planning should provide site-specific procedural details that address various spill scenarios and situations. Despite complexity and varied nature, a well-designed contingency plan should be easy to follow. Although the plans can be vastly different, they typically have four major elements in common:

  1. Hazard identification
  2. Vulnerability analysis
  3. Risk assessment
  4. Response actions
Oil Spill - TRP Corp

1. Hazard Identification - Numerous varied criteria, such as location, climate, severe weather potential, operations, logistics, equipment, spill trajectory, or facility dynamics, can create situations that can affect the ability of response personnel to contain and clean up an oil spill. These hazards should be identified and processes put in place to counteract challenges caused by each specific situation.  It may be possible for certain identified hazards to be mitigated, essentially eliminating the hazard altogether.

According to the EPA, the following information is usually collected as part of the hazard identification:

  • Types of oils frequently produced at, stored in, or transported through that area
  • Locations where oil is stored in large quantities
  • Mode of transportation used to move the oil, such as pipelines, trucks, railroads, or tankers
  • Possible extreme weather conditions
  • The location of response equipment and trained response personnel

2. Vulnerability Analysis: It is critical to identify and provide detailed information regarding area social, natural, and economic resources that may be compromised or destroyed if a spill were to occur.  This information regarding these non-facility related entities in the path of a spill or response, should guide response personnel to make reasonable, well-informed response actions to protect public health and the environment. Vulnerability analysis information should include the following:

  • List of sensitive facilities such as schools, nursing homes, hospitals, etc and individual point of contact for each facility
  • Lists of public safety agencies/officials in adjacent and nearby communities
  • Lists of large gathering or recreational areas, such as campgrounds, parks, malls, etc.
  • Calendar lists of special events and point of contact
  • Identification of parts of the environment that are particularly susceptible to oil or water pollution such as water sources, beaches, farms

3. Risk Assessment: This assessment quantifies the hazards and the vulnerabilities to address the potential impact of a spill on its surroundings. The contingency plan should address best possible spill containment measures, how to prevent certain populations or environments from exposure to oil, and what can be done to repair the damage done by the spill.

4. Response Actions: Employees and responders should train for and exercise their assigned spill response actions in order to minimize the hazards to human health and the environment. Stakeholders and applicable levels of government and industry should be consulted and incorporated in oil spill response and contingency planning. Without the full participation of personnel, responders, contractors, and government entities, a plan may lack validity, credibility, and effectiveness.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

Exercises - TRP Corp

Tags: OPA 90, Oil Spill, Training and Exercises, Regulatory Compliance, Facility Management

The Common Regulatory Requirements between the EPA and USCG

Posted on Mon, Aug 27, 2012

Many U.S. facilities, such as marine transfer facilities with aboveground storage tanks, are regulated by both the Environmental Protection Agency and the U.S. Coast Guard (USCG). Certain EPA-regulated facilities that are located adjacent to U.S. waters, or on company property adjoining a marine-transportation-related facility, may be also held accountable by USCG regulations. The marine transportation security aspects regulated by the USCG covers the entire facility, not just the oil transfer or “dock” area. Although the USCG’s 33 CFR part 105 105 mandates the details of facility security planning and the EPA’s 40 CFR part 112  pertains to oil spill prevention and response planning, there are several overlapping provisions.

EPA’s 33 CFR part 112 requires Facility Response Plans (FRP) that describe the response procedures for oil discharges of all types, whether the cause is accidental, man-made, natural, or deliberate. EPA’s FRP requirements address responses to worst-case discharges, which can damage the facility, disrupt waterborne commerce, and cause substantial economic or environmental damage.  The USCG’s 40 CFR part 112 on maritime security aims to prevent the consequences of a worst-case discharge. Specific provisions that may overlap in the two sets of requirements include, but are not limited to the following:


  • Part 112: The FRP must include an emergency response action plan, which summarizes key response information from the FRP, including emergency contact information for the Qualified Individual, facility response personnel, response organizations, and local responders. 
  • Part 105: The Facility Security Officer must have a means to effectively notify facility personnel of changes in security conditions at a facility. Transportation security incidents are 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 authorities with security responsibilities, including the police, security control, and the emergency operations center.
Fencing and monitoring:
  • Part 112: The FRP must describe facility security, as appropriate, including fencing, guards, and lighting. The SPCC Plan must also describe facility security measures to restrict access to the oil handling, processing, and storage areas. The SPCC also requires adequate lighting to prevent discharges caused by vandalism.
  • Part 105: The Facility Security Plan must describe security measures to prevent unauthorized access to cargo storage areas, including continuous monitoring through a combination of lighting, security guards, and other methods.


  • Part 112: The FRP requires detailed evacuation plans, including primary and secondary evacuation routes, centralized check-in area, and references to community evacuation plans.
  • Part 105: The owner or operator must identify the location of escape and evacuation routes and assembly stations to ensure that personnel are able to evacuate during security threats.


  • Part 112:  The FRP required a detailed site plan diagram, hazard evaluation, and vulnerability assessment. The assessment in the FRP examines potential effects of an oil spill, such as the shutdown of downstream water intakes.
  • Part 105: The Facility Security Assessment requires description of the layout of the facility, and response procedures for emergency conditions, threat assessment, and vulnerabilities, with a focus on areas at the facility that may be vulnerable to a security threat, such as utility equipment and services vital to operations.

For information about SPCC Plans, download TRP Corp's free SPCC and FRP Inspections guide.


Tags: USCG, Dock Operations, EPA, OPA 90, Oil Spill

Identifying Small, Medium, and Worst-Case Discharge Scenarios

Posted on Thu, Aug 02, 2012

Responding to an oil spill can be complex with many factors involved. As a result of the Oil Pollution Act of 1990 (OPA 90), marine vessels and certain land-based facilities that handle, store, or transport oil are required to have response plans detailing response actions. This regulation mandates that owners or operators of applicable facilities prepare and submit response plans for responding to a worst-case discharge.

The Environment Protection Agency (EPA) states that site-specific scenarios and response resources must be addressed for small, medium, and worst-case spills. 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.

Note- “Owners or operators of marine-transportation-related facilities with animal fats and vegetable oils must plan for a worst case discharge and an Average Most Probable Discharge (the equivalent of a small discharge in the EPA rule). The response plan requirements differ primarily because EPA -regulated non-transportation-related facilities generally are much larger than the USCG-regulated marine transportation-related (MTR) facilities and often have a potential for worst case discharges that are greater by an order of magnitude or more.” -Environmental Protection Agency

TRP COrp - Oil Spill

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

The source of a small, medium, and worst-case discharge may stem from various facility operations and corresponding equipment components.  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 would likely be contained in specified areas or by specialized equipment, and are 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.

Any spill response, despite the size of the spill, should respond to these types of incidents in the same manner as a worst-case discharge, incorporating 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.

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

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Tags: EPA, OPA 90, Oil Spill, Disaster Response

Informative Videos for EHS Professionals and Emergency Managers

Posted on Mon, Feb 20, 2012

Below are a various informative videos that may assist professionals in emergency response planning.
Note: These video are meant to be informative, and do not replace mandated training.

OSHA Construction Hazard Prevention videos: These based on actual event series of videos demonstrate work site incidences that resulted in an employee injury or death. Corrective actions for preventing these types of accidents are discussed.

How to Use a Portable Fire Extinguisher Training Video: This video was created by the Fire Equipment Manufacturers' Association to train viewers on how to assess a potential fire situation and use a portable fire extinguisher in the event of a fire emergency.

Oil Spill 101: Blocking with boom: National Oceanic and Atmospheric Administration video on how boom contains an oil spill, including the four main types of boom used

2012 Emergency Response Guidebook (ERG): The 2012 Emergency Response Guidebook contains the latest dangerous goods lists from the United Nations Recommendations, as well as from other international and national regulations. The 2012 ERG is designed for emergency responders to quickly and accurately access a HAZMAT incident.

Exxon Valdez: 20 Year later: Detailed video of the historical events regarding the Exxon Valdez spill that resulted in the passing of the Oil Pollution Act of 1990 (OPA 90 ).

Incident Command System: Positions & Responsibilities: With the Salvation Army as the backdrop organization, this video highlights the roles and responsibilities of key positions within the Incident Command System.

Sorting Out SPCC: Video that details the EPA regulated SPCC plans.  Video is directed at new farm regulations, however, the it provides an overview of the EPA's Oil Spill Prevention, Control and Countermeasure Program.

Iron in the Fire: U.S. Chemical Safety Board reviews of chemical dust fires in 2011.

For a sample Emergency Response Checklist, download our helpful and informative guide.

Tags: NOAA, Fire Preparedness, Emergency Management, Incident Management, SPCC, OPA 90, Oil Spill, Video