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Improvised Planning Is Costly: 7 Regulatory Compliance Tracking Factors

Posted on Thu, Aug 20, 2015

"It's not what happens to you, but how you react to it that matters." - Epictetus

Despite best mitigation efforts, emergencies and disasters occur. Although emergency managers can relate to Epictetus’s antidote, it has been proven by the abundance of regulatory fines and fees that responses should not be improvised. Numerous government agencies require that responses be planned for, exercised, and compliant across multiple fronts.

While organizations may see compliance efforts as challenging, the purpose of regulations is to shape practices to limit harm and protect communities and the surrounding environment. However, every month, companies across the nation receive regulatory enforcement mandates.

Regulatory non-compliance is expensive, time consuming, and potentially dangerous to company employees and the surrounding communities. For example, a Seattle area marine terminal that transfers large quantities of ethanol fuel and grain from rail cars to tanker trucks was fined more than $420,000 by Washington’s Department of Labor and Industries for numerous non-compliance issues. Additionally, the agency placed an immediate order to restrain the company’s ethanol transfer operation because of inadequate emergency response planning. Compliance costs are typically lower than the expenditures associated with non-compliance fines, litigation, reputational risk, and government mandated shutdown of operations.

Many industrial facilities must comply with multiple regulations sanctioned by various government agencies. For example, one specific industrial facility in Louisiana has to meet as many as 700 individual requirements. In order to ensure optimal compliance capabilities, companies should have an effective compliance management process in place that can enhance efforts, and limit the potential for fines and operational downtime.

In recent years, advanced technology has allowed an increasing number of companies to automate emergency preparedness, response processes, as well as regulatory compliance. One of the most important aspects of maintaining compliance is ensuring that required response plan and associated revisions are submitted to the proper regulatory agencies in a timely manner. The various agencies have different submission requirements regarding initial and plan revision compliance.

A company must associate each regulatory requirement with applicable mandatory submission requirements and tasks for each facility. From a corporate standpoint, incorporating a regulatory requirements tracking system can ease the complicated exponential challenges associated with managing multiple regulatory requirements for numerous locations. A regulatory compliance tracking system can eliminate redundancies that typically occur across converging compliance specifications

A methodological tracking system should itemize applicable federal, state, and local regulations, and include categorical information that satisfies that regulation. A tracking system should, at a minimum, contain the following components:

  1. Operational categories: Categories can range from air quality and hazardous materials, to construction safety and general safety and health. Depending on the detail required by the regulations, further breakouts by subcategories may also be required.
  2. Applicable Regulation Level: Regulations should be further broken down to Federal, state or local regulation categories.
  3. Time/Date Stamping: The time and date that each regulation was last updated.
  4. Compliance Feedback: Applicable notes regarding compliance or non-compliance.
  5. Industry Standard: Apply best practices related to compliance with specific regulatory requirements, when practical to do so.
  6. Facility Compliance responsibility: Identify contact assigned to maintain compliance for each regulatory requirement.
  7. Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and person(s) assigned. Reports should have filters to customize queries as required by the users.
The results of an effective compliance tracking system is an efficient and integrated program that optimizes the efforts of all stakeholders and allows for optimum compliance.

Tags: Response Plans, Regulatory Compliance, Facility Management

Enterprise-Wide Contingency Planning & Regulatory Compliance

Posted on Thu, May 07, 2015

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

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

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

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

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

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

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

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

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

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

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

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

High Petroleum Supplies Advocate Oil Spill Response Plan Reviews

Posted on Thu, Apr 16, 2015

According to the March 27th U.S. Energy Information Administration's weekly status report, the petroleum supply continued to rise in the first quarter of 2015. Bloomberg Energy suggested that oil inventory is approximately 25% above its 5-year average. Many petroleum storage facilities are handling near capacity volumes and should evaluate preparedness measures and oil spill response plans to ensure the hazards associated with increased oil storage volumes are accurately and effectively addressed.

Operators of oil storage facilities should review their oil spill response plans to ensure that response procedures are consistent with local topography, sensitivities, and other site-specific details. This is especially critical when tank volumes and potential spill impacts are increasing. If properly planned, exercised, and executed, plans can protect lives, communities, and the environment, and reduce the financial impact associated with an oil spill.

The primary objectives of oil spill response plans are to:

  • Allow response personnel to prepare for and safely respond to spills
  • Ensure an effective and efficient response despite 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

tanks-resized-600

Through facility assessments, best practices, and responder input, effective plans should incorporate a variety of aspects and perspectives of a response. As inventories increase, it is imperative that risks and threats be re-evaluated. The following 30 questions can be used as planning discussion points to develop or review oil spill plans:

  1. Have high-risk activities been identified, assessed and, if possible, mitigated?
  2. Have sensitive areas been identified and potential consequences been assessed for the current tank volumes?
  3. How would a potential spill with current tank volumes affect external resources?
  4. Did previous risk assessments utilize realistic scenarios, current oil volumes, and potential release locations?
  5. Have trajectory estimates been completed for a variety of tank volumes, and do they include potential weather scenarios?
  6. Do trajectory maps mimic local observations and historical tendencies?
  7. Have trajectory-timing estimates and recovery location points been included in oil spill planning process?
  8. Have Safety Data Sheets been updated per OSHA regulations, and are hazardous material properties been included in the planning process?
  9. Have processes been established for updating planning information, tank volumes, and required response resources?
  10. Have plot plans and area mapping been integrated with GIS data and knowledge?
  11. Are sensitive sites prioritized for protection?
  12. Have response times and limitations been set?
  13. Have alternate strategies and response procedures been identified because of increased potential spill volumes?
  14. Is there an agreement over response strategies and priorities between personnel and responders?
  15. Does the planning process incorporate best practices ecological risk assessment principles?
  16. Have response equipment needs been re-evaluated and defined?
  17. Is appropriate external spill response support available and are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
  18. Are staff roles and responsibilities specified and communicated?
  19. Are personnel appropriately trained for allocated roles?
  20. Do plans include specific criteria for provisional tiered responses?
  21. Have the plans be thoroughly exercised with realistic scenarios?
  22. Is the response management team structure clear and able to be communicated?
  23. Is there an internal and external communication method established?
  24. Is exercise feedback incorporated into plan revisions?
  25. Are clear procedures in place to notify, assess, and initiate a response?
  26. Are communications backup systems available and described in the plan?
  27. How is information accessed during a response to determine size, shape, type, location, and movement of the oil?
  28. Are procedures in place for monitoring spill size, shape, type, location, movement, and impact
  29. Are waste management and demobilization processes in place and communicated?
  30. Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?
As oil storage volumes fluctuate, companies must utilize collaborative efforts in developing, evaluating, and exercising oil spill response plans. Worst case discharge collaborative planning among companies, responders, and the community provides opportunities for all entities to develop the teamwork and interpersonal relationships that can result in an effective, functional, and timely oil spill response.

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Response Plans, Oil Spill, Disaster Response

Oil Spill and Contingency Planning in an Industry Downturn

Posted on Thu, Apr 09, 2015

In March 2015, Brent crude oil prices hovered around $50 per barrel, while West Texas Intermediate (WTI) crude fell to nearly $40 per barrel. The drastic price decline continues to pressure oil-related companies to re-evaluate operating expenses, administer headcount reductions, and rationalize budget cuts. The combination of pricing, demand, and production levels has inventory levels at their highest levels since May 1985 (US Energy Information Administration). With infrastructures at capacity and potential budget cuts aimed at stretching operating costs, EHS departments, safety managers, and response experts cannot afford to sacrifice oil spill contingency planning and preparedness elements that address a worst case spill scenario.

commercialcrudeinventories

The benefits of oil spill contingency planning, preparedness, and response process optimization far outweigh the risks and costs associated with non-compliance or a worst case discharge. EHS departments must prioritize planning and response exercises, as they are necessary to satisfy applicable regulatory requirements, protect the environment, and ensure the best possible safety scenario for responders and employees.

Responding to a worst case spill is a dynamic scenario with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. Yet, all plans related to oil spills, regardless of the volume, have one common thread: to minimize impact. As profits margins are stressed, companies must ensure that risks and hazards remain mitigated through compliance, preparedness, and effective response planning.

Local, state and federal regulatory agencies often require varied site information depending on particular oil-related operations and locations. This information may be required in the form of a site-specific oil spill contingency plan. Contingency planning 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. Contingency planning should provide procedural details, or a “game plan” that addresses various spill scenarios and situations.

Despite complexity and varied nature, a well-designed contingency plan should be easy to follow. Facilities must ensure that their spill contingency plan outlines the necessary procedures for before, during, and after an emergency. 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

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 a 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.

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 socio-economically sensitivities 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

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.

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 spill response and contingency planning. Without the full participation of personnel, responders, contractors, and government entities, a plan may lack validity, credibility, and effectiveness.

TRP Corp Emergency Response Planning Exercises

Tags: Tactical Response Planning, Response Plans, Oil Spill, Regulatory Compliance

Common Response Plan Mistakes in Corporate Preparedness Programs

Posted on Thu, Mar 05, 2015

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

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

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

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

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

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

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

  • Pre-incident planning
  • Training
  • Exercises
  • National Incident Management System
  • Security
  • Fire brigades
  • Rescue
  • Hazardous materials handling/response
  • Fire loss prevention
  • Evacuation

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

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, Response Plans

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

Make 2015 "The Year of Response Planning and Preparedness"!

Posted on Thu, Jan 08, 2015

While it is more cost efficient and less complicated to learn from other's response experiences and emergency management mistakes, every emergency scenario, exercise, or training endeavor can be used to improve the outcome of the next response. As we begin 2015, facility and emergency managers should draw from personal experiences, staff knowledge, and industry-wide lessons learned to improve their preparedness and response program.

The following discussion points, while not all-inclusive, can be used to spur emergency management program improvements and response planning reformations for 2015:

Compliance

  • What agencies and new or impending regulations apply to my location(s)?
  • Have budgets been allocated for necessary compliance mitigation resolutions?
  • If applicable, have Globally Harmonized System (GHS) Safety Data Sheets (SDS) been updated and have their properties been included in the planning process?
  • Has an inspection taken place, and if so, have non-compliant issues been mitigated?
  • Will an internal compliance audit(s) be conducted?
  • Is personnel training up-to-date and compliant with site-specific requirements?
  • Are required exercises scheduled?

Risk Assessment

  • What are the new high-risk, medium-risk, and low risk-activities or circumstances, and are how will these scenarios relate to planning?
  • Can high-risk tasks or conditions be mitigated with the current budget? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Are there additional environmentally sensitive areas that need to be addressed in the response plan?
  • Does the risk assessment utilize realistic scenarios to define potential spill volumes and downstream locations?
  • How will employees be made aware of hazards associated with specific workplace process, materials, or location(s)?

Supply Chain

  • When will response equipment needs be re-evaluated and defined?
  • Are there new technologies or equipment that will better suit your program's equipment needs?
  • Will current vendors have predefined supplies or equipment available in the event of an operational disruption or emergency scenario, or do new suppliers need to be evaluated?
  • Are processes in place to monitor internal and external supply chains and their response time?
  • Is additional or alternate external spill response support necessary and available?
  • How would a spill affect both internal and external resources?
  • Are back up suppliers identified, and when will their availability be confirmed?

Training

  • Are current personnel appropriately trained for their allocated roles?
  • Are new employees being trained effectively?
  • Do new training measures need to be implemented?
  • Will training comprehension be tested with realistic exercise scenarios?
  • Is the response management team structure clear and able to be communicated?
  • Will external responders included in plan preparations and exercises receive a copy of the current plan?
  • Have post exercise review mitigation measures been applied to current training and preparedness measures? If not, when will these tasks be completed?
  • Should training include any new resource tracking documentation methods, software, or amended response communication actions?

Response Elements

  • If an incident were to occur today, would your response plan minimize impacts and be a guide for an effective and coordinated response effort?
  • Is a process established for individual responders to verify their contact information to allow for timely responses? If not, can verification process improvements be made to ensure accuracy?
  • Are clear initial response action procedures in place to notify, assess, and initiate a response?
  • Can approved stakeholders easily access response plans? Have you researched innovative technology that allows for improved plan access?
  • Have response times and limitations been confirmed? Have they changed from the previous plan revision?
  • Does the current response plan address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been upgraded? If so, have these changes been addressed in the plan.
  • Are new or additional communications backup systems available and described in the plan?
  • Are there new staff roles, personnel, or modified internal or external responsibilities that need to be specified in the plan, and communicated to responders?
  • Are there alternate strategies and response procedures that need to be included in the plan?
  • Are updated processes and procedures identified in the plans to assess and monitor size, shape, type, location, and movement of a spill or release?
  • If applicable, have tactical response details been included in the planning process for incidents that expand beyond the confines of the facility? Are there any changes that need to be incorporated?
  • Do trajectory maps and estimates mimic local observations and historical tendencies?
  • Are sensitive sites prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes communicated?

Documentation

  • Are sufficient processes established for updating planning information prior to an emergency and during a response?
  • Have plot plans and area mapping been integrated with the latest GIS data and knowledge?
  • Are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), updated and in place? Are there new MOUs or contracts that need to be established or finalized?
  • Do stakeholders have a copy of your most up-to-date plans?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible to auditors?
  • Are necessary Incident Command (ICS) and company-specific forms readily available for documentation?

By analyzing the past, monitoring the present, and evaluating the “potentials” of 2015, companies can reinforce their commitment to emergency management while establishing a culture of preparedness. Executing plan enhancements and reinforcing preparedness across an enterprise strengthens a company’s resolve, ultimately creating a more resilient organization.

 

Ensure preparedness and compliance! Download this free guide by clicking the image below:

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Management, Response Plans, Oil Spill, Event Preparedness

SMART Response Planning in an Era of Advanced Communications

Posted on Thu, Nov 20, 2014

Within the past few years, technology has allowed for an increasing number of companies to automate emergency preparedness and response processes. However, in an era of instantaneous information, effective communications is still one of the greatest logistical problems during an emergency.

Without clear and effective communications, first responders may:

  • respond to the wrong location
  • be unable to effectively coordinate resources  
  • misunderstand the severity of a situation
  • be ill-equipped for the actual situation
  • find themselves in danger for which they are unprepared  

Advanced technology for emergency preparedness and response has included everything from gas-leak sensors and drones, to social media integration and sophisticated emergency management software. The ability to automate a myriad of emergency response activities, including expediting communications with local first responders, safety officials, and those affected by an incident enables companies to potentially minimize the impacts of an emergency on individuals, facilities, and the community.

Through pre-planning, a communication plan can be fully integrated into the overall response plan. Companies must be certain that response plans are accessible in a variety of formats in order for necessary process and procedures to be implemented. If the plan is not accessible, prepared information cannot be conveyed and responses may be inadequate. Best practices should be continual reviewed in order to improve optimal communication methods for each scenario. Communication pre-planning should include, but is not limited to, the following:

1. Notification and Activation methods: Meet with employees and responders to discuss notification and activation methods.  Do not assume that responders identify with current company communication policies, context of emergencies communications, or the crisis communication plan. Ensure employees are aware of applicable alarms, muster requirements, implications of various situations, and response expectations. Through communication, employees can comprehend the safety measures necessary to limit exposures and prevent unnecessary harm. With company-approved protocols in place, engaging in social media for emergency communications can allow for:  

  • Speed: Direct communication between informants and those who need information enables responders to react faster, minimizing the duration of the emergency.
  • Relevance: Disseminate the right message to the right audience
  • Accuracy: Ensure information is correct, confirmed by company sources, and backed up by facts or direct observation. Multiple informants can confirm accuracy or inaccuracies.

2. Contact Verifications: Primary and secondary contact information should be verified for personnel, responsible agencies, and contracted responders. Verification should be conducted on a periodic basis in order to maintain accurate and applicable information. Communication equipment, such as hand held radios and satellite phones, should be functionally tested periodically, to ensure they are available when necessary.

3. Strategic Considerations: Emergency managers should establish a strategic response planning framework, with checklists and response criteria that will guide the communications decision-making process to allow for an effective response. Communications should:

  • Identify internal and external methods and procedures
  • Confirm emergency contact information
  • Identify multiple forms of communication methods (text, e-mail, cell phones)

4. Stabilization: Effective communications is the bridge to stabilizing an emergency situation. The stabilization phase may include media/public relations and a crisis communication plan. In this 24/7 information age, a communications plan should include informational jurisdiction decisions about what to release, by whom, and when. Information MUST be accurate and timely in order to diffuse rumors.

Unfortunately, during the height of an incident, bleak realities and raw emotion may alter communication agreements and promote misinformation. Avoid public power struggles and confusion by establishing a clear and exercised understanding of communication responsibilities before a situation occurs.

5. Recovery: The lines of communications need to remain open to return to a “business as usual” level. In order for a full recovery, communication should include:

  • Accurate damage assessment reports
  • Response personnel reports
  • Demobilization techniques
  • Employee reentry procedures
  • Lessons learned debriefings

Be prepared for your next incident, download TRP Corp's free white paper, "A Step-by-Step Guide: Be Prepared for Your Next Incident".

Preparedness and Emergency Management - TRP Corp

Tags: Response Plans, Communication Plan, Disaster Response

Crude by Rail: Cooperative Preparedness Planning and Training

Posted on Thu, Oct 23, 2014

CSX, a North American leading supplier of rail-based freight transportation, recently hosted a crude-by-rail (CBR) incident response training session at the Security and Emergency Response Training Center (SERTC) in Pueblo, Colorado. The training consisted of 40 first responders representing 12 states.  According to CSX, “The three-day training session focused on preparation for and emergency response to railroad incidents involving crude oil, and included an overview of the history of crude oil extraction, chemical and physical properties of different types of crude oil currently being transported, incident site and damage assessment, and tank car design and construction. Participants also practiced specialized response techniques and incident command scenarios during mock derailments.”

According to the Association of American Railroads’ October 4, 2014 Weekly Report, petroleum and petroleum products shipped by rail was up 12.8% from the same time frame in 2013 (1). As CBR shipments continue to increase, companies must prioritize response and safety training, as well as coordinated planning and preparedness efforts. Because a single incident can have a significant or catastrophic impact, it is imperative that pre-planning and training be incorporated with coordinated response efforts.

In May 2014, the Department of Transportation (DOT) mandated initial coordination by instituting an emergency order for railroads to communicate specific information to each State Emergency Response Commission (SERC). The notifications must provide information regarding the estimated volumes and frequencies of train traffic implicated. Rail companies that transport 1,000,000 gallons or more of Bakken crude oil must adhere to the emergency order.

Specifically, the emergency order dictated that the notifications must: 

  1. Provide a reasonable estimate of the number of trains expected to travel, per week, through each county within the state
  2. Identify and describe the petroleum crude oil expected to be transported in accordance with 49 CFR part 172, subpart C
  3. Provide all applicable emergency response information required by 49 CFR part 172, subpart G
  4. Identify the routes over which the material will be transported.

Communication and cooperative pre-incident planning provides a tool for railroad companies and response agencies to begin the collaborative process of preparedness. This endeavor should be a coordination of overall response strategies that are made part of CBR response plans, training, drills, and exercises. A derailment that includes crude may require mutual aid efforts and a clear, yet robust Incident Management System.

In order for an incident management system to be effective, specific situational checklists should be created.  Rail employees, and local incident responders must be trained in applicable emergency procedures, communications cycles, and documentation requirements.  Rail incidents should be managed through clearly identified and communicated objectives. These objectives may include, but are not limited to:

  • Establishing specific and step-by-step incident objectives
  • Developing strategies based on incident objectives
  • Developing and issuing assignments, plans, procedures, and protocols
  • Establishing specific, measurable tactics or tasks for various incident management functional activities, and directing efforts to accomplish them, in support of defined strategies
  • Documenting results to measure performance and facilitate corrective actions

Maintaining an accurate and up-to-date picture of resource utilization is a critical component of incident management and emergency response. This may be especially challenging on select high or low density rail routes.  Each real-time incident management status update should include the following information in order to clarify response status:

  • Time of update (timestamp)
  • Incident or event name
  • Elapsed time of incident from initiation
  • Name/position of responder making status updates
  • Current planning phase and/or specific status update
  • Tasks assigned, both internally and externally, and resources used or required
  • Emergency Operations Center location and contact information

Improving rail car emergency response training, reactive decision management, timeliness of an ongoing response, and swift implementation of recovery strategies can limit resulting effects of any CBR emergency situation. As the shipments of CBRl continue to increase, it is imperative that companies, in conjunction with local responders prioritize well-coordinated preparedness initiatives.

NOTE: SERTC was established in 1985 to train railroad officials to safely handle accidents involving tank cars carrying hazardous materials. Because the initial endeavors were so successful, hands-on training courses were extended to serves the public sector emergency response community, the chemical industry, government agencies, and emergency response contractors from all over the world.  

(1)   Association of American Rail Traffic Weekly Rail Traffic Report, Oct. 9, 2014.

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Tags: Response Plans, Oil Spill, Training and Exercises, Safety, Crude by Rail

Ten Reasons for Companies to Invest in Incident Management Programs

Posted on Thu, Sep 25, 2014

Incident Management programs shouldn’t be created for IF an incident happens...but for WHEN an incident happens.

Regulatory compliance mandates, a history of incidents, or an awareness of potential crises typically trigger companies to fund preparedness initiatives. At a minimum, preparedness endeavors and response capabilities should be audited, tested, and updated on an annual basis. Budgeting efforts should be aligned with initiatives in an effort to improve incident management and preparedness capabilities.  Below are ten “best practice” reasons why companies should prioritize funding to advance preparedness initiatives and associated response programs:

#10. Streamline and standardize improved response methods:  A consistent company-wide emergency response management system can deliver site-specific details and management endorsed response processes.  Standardization allows employees and responders to conceptualize their roles and responsibilities across an enterprise, creating a common understanding of intended actions. Streamlining response methods can assist responders in assessing, prioritizing, and responding to incidents.

#9. Optimize drills and training: Employee training, emergency response drills, and applicable exercises identify deficiencies in emergency response planning programs. Incorporating appropriate response training and testing response plans with detailed scenarios will improve response capabilities and coordination, as well as reduce response times.

#8 Improve regulatory compliance: Costly non-compliance fines result from the lack of implemented, thorough, and compliant programs. By systematically aligning response plans and their components with corresponding regulations, companies can identify and amend plan deficiencies that may result in fines and potential government mandated shutdowns.

#7. Simplify and automate response plans: Maintaining response plan can be an administratively taxing endeavor. Continual administrative duties associated with personnel contact information, assignments, training records, exercises, and continual plan updates may be inadequate to sustain an optimal program. Maximizing efficiency through advancements in technology can minimize time associated with maintaining incident response plans.

#6. Improve asset utilization: Companies must utilize employees, responders, equipment, and budgets effectively in order to minimize the effects of a crisis or disaster. Realigning current tangible assets (equipment and/or personnel), mitigating current inefficiencies, and/or budgeting for additional response training or improved equipment will improve the overall effectiveness of an emergency management program.

#5. Demonstrate a commitment to safety:  Companies should proactively affirm the safety of employees and surrounding communities, and protection of the environment, by establishing proven countermeasures to potential threats and associated risks. Prioritizing emergency preparedness initiatives demonstrates a company’s commitment.

#4. Improve conditions:  Harmful conditions pose a risk to occupants, the environment, infrastructures, and/or the surrounding communities. By eliminating or mitigating potentially adverse conditions, unsafe activities, or ineffective responses, companies can reduce the potential for and effect of emergency situations. The risk assessment process can be used to identify potential threats or harmful conditions that can lead to incidents.

#3. Reduce Incidents:  By identifying potential threats and risks, mitigation and preventative measures can be taken to curtail the likelihood of an incident from occurring or reduce its impacts. Mitigation measures may include a variety of tactics including, but not limited to training for employees, updating safety processes and procedures, or securing or purchasing updated equipment.

#2. Reduce downtime:  Operational downtime and production loss reduces revenues. By optimizing and implementing the most effective and functional incident management program possible, incidents can be promptly managed and rapidly demobilized, thereby reducing response-related costs and downtime.  The repercussions from an incident can include detrimental relationships with customers, the surrounding community, and stakeholders.

#1. Cost savings:  Proactive compliance efforts, safety initiatives, training and exercises, and response and resiliency planning are typically less expensive than regulatory fines, sustained response efforts, and overall repercussions resulting from an incident.

Implementing a technologically advanced enterprise-wide emergency management system offers opportunities to increase the effectiveness of planning and preparedness efforts. Gathering lessons learned from various site managers, performing site regulatory gap analyses, and implementing new proven concepts will ensure the best possible functionality and processes within a program.

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Tags: Emergency Management, Emergency Preparedness, Response Plans, Incident Management, Training and Exercises, Emergency Management Program