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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.

For enterprise-wide response planning guidance, click here or the image below:

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

Facility Response Plan Audits Necessary in Mergers and Acquisitions

Posted on Mon, Mar 31, 2014

As companies merge, acquire facilities, or expand operations, applicable location-specific threats, risks, and regulations must be incorporated into response plans. Emergency preparedness programs and facility response plans need to be reviewed, at a minimum, on an annual basis to adequately reflect expanding operations. However, if an acquisition or merger occurs, it is essential to evaluate and align facilities and processes with corporate standards and applicable regulatory requirements.

Enterprise expansion requires environmental, health, and safety (EHS) managers to sharpen their location-based understanding of regulations, security needs, and associated response plan components specific to each location. As part of a company’s asset management program, engaging experienced personnel in response plan data review, safety and response audits, and response plan validation can highlight areas where the local knowledge is imperative.

The new response planning documents should include updates from various stakeholders and collaborating response groups. Open communications with internal and external responders will ensure plan and response procedures are current, and carried out in accordance with company protocols. Groups to consider in planning reviews include, but are not limited to:

  • Local responders (fire, police, emergency medical services, etc.)
  • Government agencies (LEPC, Emergency Management Offices, etc)
  • Community organizations (Red Cross, weather services, etc)
  • Utility Companies (Gas, Electric, Public Works, Telephone, etc.)
  • Contracted Emergency Responders
  • Neighboring Businesses

Whether a facility is domestically located or abroad, ensuring enterprise-wide compliance and employee safety requires streamlined, coordinated, and exercised response plans. A poorly managed and inadequate response can negatively affect a company’s reputation, operations, business interests, and relationship with key regulators, partners, and local entities.

Internal or external experts, as well as independent consultants can assist in response plan audits to ensure compliance, accuracy, and effectiveness. All response plans within the corporate enterprise should address site-specific facility details, appropriate response processes, standardized company-wide best practices, and maintain location-specific regulatory compliance.

The response plan audit process, followed by exercises, can minimize the “lessons learned” transfer process knowledge gap among incoming personnel. Important threat identification, operational site specifics, and response process and procedural details may have gone unnoticed in the transition, potentially compromising safety and emergency response.

After an audit, new or unidentified risks should be slated for possible mitigation measures and regulatory gaps should be documented. However, if the risks cannot be eliminated, new countermeasure processes and procedures must be implemented and response plans adjusted accordingly. Important threat identification, operational site specifics, and response process and procedural details may have gone unnoticed in the transition, potentially compromising safety and emergency response.

Other business units or divisions outside headquarters’ domain may present additional preparedness and response challenges. Audits should be inclusive of cultural differences, infrastructure challenges, or security priorities that may heighten preparedness priorities and planning efforts. As a result, an expanding company may be particularly vulnerable to crisis or emergency response situations.

Audits should verify that response plans have been effectively developed for each potential scenario. In additional to specific operational hazards and site specific regulations, response planning may incorporate, but is not limited to the following:

Natural Disasters: Each geographic location is saddled with specific potential natural threats. If historically applicable, plans should address

  • Earthquakes
  • Hurricanes/typhoons
  • Sand/wind storms
  • Tornados
  • Floods
  • Tsunami

Security Breach: A security breach can affect multiple aspects of a company, from business continuity to the physical safety of employees. Plans may include response processes for:

  • Computer hacking
  • Catastrophic IT failure
  • Facility security measures
  • Civil unrest
  • Personnel/employee security

Industry/Sector Issues: As industry specific equipment, regulatory requirements, and technologies evolve, preparedness efforts should adapt to include safety processes, continuity procedures, and best practices for.

  • Supply disruptions
  • Regulations
  • Plan maintenance
  • Plan accessibility
  • Employee training
  • Exercises

Though preparedness, companies can minimize the effects of costly crisis and emergency situations, as well are potential regulatory fines. Timely resolutions with limited impact to the facility, employees, the environment, reputation, and the financial bottom line will allow companies to better position themselves for growth, prosperity, and longevity.

Interested in auditing response plans for effectiveness and compliance, download the "Audit Preparedness Guide for Industrial Regulatory Compliance".

Regulatory Compliance with TRP Corp

 

Tags: Response Plans, Regulatory Compliance, Emergency Management Program, Security plans, Safety

Pro Tip: The Role of Templates in Response Plan Compliance

Posted on Thu, Mar 27, 2014

Emergency response plan templates often include the basic fundamentals of response planning. They should be utilized as a general outline for developing emergency response plans and a guide for regulatory compliance. However, response plans must also reflect the unique nature of  every company, facility, and operation. Consideration of site-specific details of each operation is important to ensure regulatory compliance.

In order for emergency response plan templates to be effective, specific facility information and operational hazards, as well as local, state and federal requirements must be addressed and included in plans. Industrial operations are required by law to institute site-specific emergency response plans and train employees in the appropriate level and method of response. Utilizing generic procedures from basic templates may result in  ineffective plans that are not in compliance with regulatory requirements.

By utilizing a template as an outline, companies can begin the process of creating  emergency response plans. A generic plan template may not address every regulatory and/or site specification, so it is essential to evaluate site-specific variables and applicable regulatory requirements. Below are twelve basic template topics that should be evaluated for site-specific applicability and implementation.

  1. Local, State and Federal regulations
  2. Hazard identification and risk assessment
  3. Hazard mitigation procedures
  4. Resource management
  5. Response direction, control, and coordination
  6. Notifications and warning systems
  7. Operations and safety procedures
  8. Logistics and facilities infrastructure specifics
  9. Training
  10. Exercises, evaluations, and corrective actions
  11. Crisis communications
  12. Finance and administrative duties

A plan template should be supplemented, at a minimum, with the following information:

Description of Facility Infrastructure and Summary of Physical Site Attributes:  Emergency response plans should include the following site-specific details:

  • Facility Name
  • Address
  • Latitude/Longitude
  • Contact Numbers
  • Key contacts
  • Site operations and equipment
  • Products handled
  • Number of employees
  • Nearby waterways.
  • Site drainage.
  • Details of tanks, pipelines, utilities, and other major equipment
  • Site security features, including fencing, visitor access, and lighting

Plan distribution list: Include the names and addresses of personnel who have plan copies

Key contacts: Identify all primary and secondary key contacts that may be included in a response. It is crucial to routinely verify contact information for accuracy. Key contacts may include 911, National Response Center, and internal and external response teams. Response equipment  suppliers should be identified

Alarm Identification and Notification Process:  Identification of  alarms that may signal an emergency, evacuation, or shelter in place. It is imperative to perform exercises with alarms to confirm they are in proper working condition and employees react accordingly. Ensure employees are trained in and understand  required notifications.

Key Staff Roles and Responsibilities: Job-specific checklists and procedures detailing responsibilities from initial response actions through demobilization.  It is a good idea to  provide training to at least two people per position in case primary team members are not available. It s helpful to:

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

Response Actions: Response action checklists for  for each potential scenario.  .

  • Perform a detailed hazard and risk analysis
  • Create response procedures for each identified threat
  • Identify hazard control applicability and methods
  • Detail external communications and public relations policies

Response Equipment: Major on-site and external response equipment should be itemized. Equipment availability and applicable contact information should be reviewed and verified. The consequences of a supply chain failure during a response  can severely limit effectiveness. Transportation delays could affect response equipment delivery times. Plan and mitigate accordingly.

Documentation Process: Accurate and detailed records of a response are imperative. Regulatory authorities may require specific response documentation. The burden of proof typically falls on the responsible party  when making insurance claims.

  • Create process for incident documentation
  • Utilize appropriate ICS Forms

Emergency Operations Center Location(s): Include location, address, contact info, available equipment, and any necessary external equipment for effective response operations.

Visual Aids: Include plot plans, evacuation routes, maps, and any other graphic displays that may aid in a response.

  • Identify multiple evacuation routes
  • Identify shelter in place areas
  • Identify the muster point(s)

Demobilization and Post-Incident Review: Specific demobilization guidelines provide organized and agreed-to procedures to help facilitate a more organized and expedited return to normal operating conditions, and help to minimize costs by standing-down response resources in a timely manner.

  • Create a checklist to identify demobilize gudelinesPerform a post incident review and debriefing
  • Document newly identified hazards and vulnerabilities
  • Identify  “lessons learned”  and action items
  • Update response plan accordingly

Templates should be populated with industry-specific, best practice response techniques. Once the initial emergency plan is completed, response plan audits, exercises, and consulting assistance may be required to confirm emergency plan compliance and effectiveness.

Interested in auditing response plans for effectiveness and compliance, download the "Audit Preparedness Guide for Industrial Regulatory Compliance".

Regulatory Compliance with TRP Corp

Tags: Testing, Resiliency, Response Plans, Regulatory Compliance, Emergency Response Planning, Safety

Response Planning Discussion Points: The Path to Preparedness

Posted on Mon, Feb 03, 2014

Through timely internal audits, facility assessments, attentive training and exercise programs, and best practices, response plans can be a working reflection of facility compliance and corporate preparedness. Necessary response documentation and plans established prior to an emergency allow for a comprehensive review of processes and procedures, and can result in an improved response to actual emergencies. The following questions, while not all-inclusive, can be used as planning discussion points to identify necessary response elements in order to develop or assess emergency response plans:

Compliance

  • What agencies and specific regulations apply to my location(s)?
  • If applicable, have material safety data sheets (MSDS) 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?

Risk Assessment

  • What are the current high-risk activities at the location?
  • Can high-risk tasks or conditions be mitigated? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Have environmentally sensitive areas been identified and potential consequences been assessed?
  • Did risk assessment utilize realistic scenarios to define spill and release volumes and locations?
  • Are employees made aware of hazards associated with specific workplace process, materials, or location(s)?

Supply Chain

  • Are processes in place to monitor internal and external supply chains?
  • Is external spill response support necessary and available?
  • Have response equipment needs been evaluated and defined?
  • How would a potential spill affect both internal and external resources?
  • Have back up suppliers been identified and communicated with?

Training

  • Are personnel appropriately trained for their allocated roles?
  • Have the plans been thoroughly exercised with realistic scenarios that test training comprehension?
  • Is the response management team structure clear and able to be communicated?
  • Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?
  • Are exercises utilized to identify effective efforts and inefficiencies in response to ever-changing and site-specific scenarios?
  • Does training include documenting and communicating response actions, management decision, and tracking of resources?

Response Elements

  • Are clear procedures in place to notify, assess, and initiate a response?
  • Are individual responders and their contact information verified for accuracy?
  • Can approved stakeholders easily access response plans?
  • Have response times and limitations been set?
  • Do response elements address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been identified?
  • Are communications backup systems available and described in the plan?
  • Are staff roles and responsibilities specified and communicated?
  • Have alternate strategies and response procedures been identified?
  • Are 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?
  • Do trajectory maps mimic local observations and historical tendencies?
  • Do trajectory estimates include potential weather scenarios?
  • Are sensitive sites prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes communicated?

Documentation

  • Have processes been established for updating planning information prior to an emergency and during a response?
  • Have plot plans and area mapping been integrated with GIS data and knowledge?
  • Are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
  • Has exercise feedback/lessons learned been incorporated into plan revisions?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible?
  • Are necessary Incident Command (ICS) forms and company paperwork readily available for response documentation?
For a free download of a Response Procedures Flow Chart, click the image below:
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Tags: Response Plans, Crisis Management, Facility Management, Emergency Response Planning, Safety, Disaster Response, Business Disruption

Top TRP Corp Emergency Preparedness Blogs of 2013

Posted on Mon, Jan 13, 2014

As we begin 2014, we would like to share our subscribers’ top ten TRP blogs from 2013.  While the topics vary, the goal of each blog is to provide resources to assist in developing effective emergency, crisis, and business continuity plans and programs. It is our hope that emergency and crisis managers, first responders, and safety professionals can utilize these blogs to advance their emergency management and business continuity efforts in 2014.

TRP’s Top Ten 2013 Blogs include:

10. Managing Multiple Incidents Through ICS: Managing a single incident can be challenging. Managing multiple incidents demands an organized, coordinated, and thoroughly exercised response plan. This blog explore the use of the Incident Command System (ICS), a common organizational structure designed to aid in incident management activities, and core concepts that can greatly assist in the overall response of a multiple incident or crisis event.

9. Office Building Emergency Management and Emergency Action Plans. In order to prioritize safety, office building management should include a customized Health, Safety, and Environmental (HSE) program that complies with pertinent regulatory requirements, and includes site-specific safety and evacuation procedures. This blog specifically highlights common office building health and safety hazards, and emergency action plan components required by OSHA.

8. Success, Failure, and the Emergency Response Exercise: Prompted by a LinkedIn discussion on the effects of specifically designing an exercise to match response capabilities, this blog identifies suggested exercise objectives that participants should comprehend and demonstrate during the course of an exercise.

7. Emergency Management Planning and Social Media: This blog discusses the ever increasing and merging communications applications that are creating a new outlet within emergency management. With pertinent information readily available through various sources, the decision-making process and applicable response can be accelerated, potentially minimizing the effects of the incident. However, companies must develop processes for monitoring social media content during an incident in order to collect accurate real-time intelligence and respond accordingly.

6. The Incident Action Plan Begins with Incident Command: This blog details the benefits of incorporating the Incident Command System (ICS) into an emergency management program and highlights Incident Commander response priorities and responsibilities. At the onset of an incident, Incident Commanders can utilize ICS elements to develop incident-specific strategic objectives and facilitate necessary response procedures.

5. Twitter Hashtags in Emergency Management: With the surge of social media usage, companies are engaging in and utilizing the boundless information available from interactive platforms such as Twitter. This blog highlights the use of the Twitter hashtag tool (#), which allows readers to connect to specific topics or incidents, and identifies some of the most popular hashtags used for emergency management related issues.

4. The Tabletop Exercise and Emergency Response Plan: Tabletop exercises can often reveal shortcomings in preparedness planning and responder knowledge. The blog identifies the minimum components necessary for a tabletop exercise and ways to utilize its results to improve the effectiveness of a preparedness program.

3.Extended Power Outages Require Business Continuity Planning: As active weather patterns continue to course across the United States, residents and businesses in the path of these extreme storms are often plagued with power outages. This blog discusses the need for specific response plans and emphasizes the urgency to evaluate Business Continuity Plans.

2.Ten Safety Training Videos to Bolster Emergency Management: Companies often use safety training videos to supplement required instruction for specific industries, roles, or equipment usage. This blog offers a sampling of free videos available to supplement safety training. (As with any free safety resource available on the Internet, information should always be verified for accuracy.)

1.. Smartphone Apps for Emergency Managers and First Responders: With pertinent information readily available, the decision-making process can be improved and the response can be accelerated, potentially minimizing the effects of the incident. This "Smart Phone Apps" blog highlights a variety of free and low-cost smartphone apps that can assist EHS managers and first responders.

For a free download of a generic Response Procedures Flow Chart, click the image below:

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Tags: Power Failure, Response Plans, Training and Exercises, Safety, Social Media, BCM

OSHA Requirements that Support Emergency Response and Planning

Posted on Mon, Dec 16, 2013

OSHA provides a wide range of general industry regulations. The following OSHA requirements are aimed at supporting Emergency Response and Preparedness measures.  These site-specific OSHA requirements include the following: (NOTE: Site-specific operations may require additional compliance measures per industry regulations. 

1. Personal Protective Equipment (General requirements)

  • 29 CFR 1910.132: Personal protective equipment (PPE), including PPEs for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.
  • 29 CFR 1910.132(d)(2): The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
  • 29 CFR 1910.132(h):  PPEs should be provided by the employer at no cost to employees in order to provide basic protection covered under 29 CFR 1910.132. However, the employer is not required to purchase certain non-specialty items if the item can be worn off the job site. Those items include, but are not limited to:
    • Non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots)
    • Non-specialty prescription safety eyewear
    • Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots
    • Ordinary clothing, skin creams, or other items used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen 
2. Respiratory Protection
  • 29 CFR 1910.134: The primary objective is to mitigate occupational diseases caused by breathing contaminated air by preventing atmospheric contamination and respiratory protection. Respiratory protection shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials) or through respirator distribution.
  • 1910.134(c)(1):  In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. 

3. Air Contaminants

  • 29 CFR 1910.1000: An employee's exposure to any substance in 1910.1000 Table Z-1 shall at no time exceed the exposure limit given for that substance. If instantaneous monitoring is not feasible, then the ceiling limit shall be assessed as a 15-minute time weighted average exposure, which shall not be exceeded at any time over a working day.
  • 29 CFR 1910.119: This regulation focuses on preventing or minimizing consequences from a catastrophic release of toxic, reactive, flammable or explosive chemicals. Processes are covered by this standard when they involve quantities of highly hazardous chemicals equal to or greater than those listed in Appendix A, they involve flammable liquid or gas quantities greater than 10,000 pounds, or they involve the manufacture of explosives or pyrotechnics. 

4. Bloodborne Pathogens

  • 29 CFR 1910.1030: An employer having an employee(s) with reasonably anticipated skin, eye, mucous membrane, or potential contact with blood or other potentially infectious materials that may result from the performance of an employee's duties shall establish a written Exposure Control Plan designed to eliminate or minimize employee exposure. 

5. Hazard Communication

  • 29 CFR 1910.1200: This OSHA standard aligns with the UN Globally Harmonized System of Classification and Labeling of Chemicals and ensures that the hazards of all chemicals produced or imported are classified. It is required that information concerning the classified hazards is transmitted to employers and employees. For more information on the Hazard Communication Standard, see Phased Compliance of the Hazard Communication Standard Begins Dec 2013.
 
For a free download of best Practices for designing a Crisis Management Program, click the image below:
TRP Corp - Emergency Response Planning Crisis Management

Tags: OSHA, Regulatory Compliance, Emergency Response Planning, Safety, Workplace Safety

Resilience and Preparedness for Threats, Hazards, and Risks

Posted on Thu, Dec 12, 2013

Over the past decade, there has been an exponential increase in human and material losses from disaster and catastrophic events worldwide. These manmade and naturally occurring incidents have ranged in scope, severity, and impact. As a result, a heightened sense of vulnerability has spurred an urgency for resilience and preparedness within governments and corporations. However, efforts to prepare for, manage, or mitigate risks are often shelved by constrained resources, profit margins, politics, or alternative goals.

To manage workplace risks, each facility should be analyzed for potential threats, hazards, and risks. The 2011 Presidential Policy Directive-8 (PPD-8) called for the establishment of a “national preparedness goal” which “will be informed by the risk of specific threats and vulnerabilities and include concrete, measurable, and prioritized objectives to mitigate that risk.”

Site-specific threats, hazards, and risks with the potential to cause injury, damage facilities, or adversely affect the environment should be identified through assessments and incorporated in subsequent emergency planning procedures. These vulnerabilities may be presented in the form of unsafe acts, unsafe conditions, or operational or geographical proclivities. Once recognized and evaluated, hazards, threats and risks should be eliminated or controlled through procedural planning. A risk management program should include, but is not limited to, the following mitigation processes:

Threats, Hazards, and Risk RECOGNITION:

  • Comprehend the three main type of threats and hazard:
    • Natural Hazards- ex: tornado, wildfire, earthquake, hurricane
    • Technological Hazards- ex: power failure, hazardous release, infrastructure failure
    • Man-made incidents - ex: cyber attack, violence, chemical attack, explosive attack
  • Inspections, audits, and employees can reveal hidden risks
  • Consult with local or online sources that have pre-identified risk based on site operations and location
  • Eliminate potential threats and hazards by likelihood of incident and the significance of effects

Threats, Hazards, and Risk EVALUATION:

  • Evaluate accident probability for each process, procedure and handled material and its resulting level of potential severity if an accident were to occur
  • Evaluation should take into account the time, place, and conditions in which threats or hazards might occur
  • The probability and severity of a risk should determine the priority level for correcting the hazard. The higher the probability and severity of risk, the higher the emphasis should be on corrective action

TRP - Risk Assessment Chart(Image provided by Ready.gov: http://www.ready.gov/risk-assessment)

Threats, Hazards, and Risk ELIMINATION or CONTROL

  • Targeted effort should be made to isolate and eliminate the root cause
  • If root cause cannot be eliminated, changes in process and procedure should be made in order to reduce risk:
    • Implement risk reducing engineering controls, when applicable
    • Implement proactive administrative controls or work place practices
    • Establish process to identify inoperable or malfunctioning equipment and machinery through systematic inspections
    • Establish processes to minimize the effects of naturally occurring hazards
  • Ensure regulatory compliance

Threats, Hazards, and Risk COMMUNICATION

  • Apply the results of analysis through planning and exercises. Employees should be made aware of hazards associated with any workplace process, materials, or location.
  • Accident prevention signs should be posted to remind occupants of the presence of hazards
  • Establish and communicate emergency response plans to employees and appropriate emergency response teams. This includes up to date contact information and notification procedures
  • Calculate, specify, and communicate resource requirements and operational capacities for each targeted scenario to internal and external responders
  • Counteract onsite response deficiencies for each scenario by implementing coordinated interoperability communication

By analyzing threats, hazards, and risks, companies can implement processes, procedures, and mitigation efforts to reduce potential impacts of specific scenarios and maximize operational productivity.

For a free sample of an emergency procedures flow chart, click the image below:

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Tags: EHS, Resiliency, Safety, Workplace Safety, Hazard Identification

Phased Compliance of the Hazard Communication Standard Begins Dec 2013

Posted on Thu, Nov 07, 2013

The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The first phase for compliance begins on December 1, 2013. At that time, the HCS will require employees to be trained on the new label elements and the updated Safety Data Sheets (SDS) format.

The revised HCS will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. The goal is to improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals.

Hazard Communication Standard Updates

Two significant changes contained in the 2012 HCS include the revised labeling elements and the standardized format for SDSs, formerly known as the Material Safety Data Sheets (MSDSs). Employees may have already been exposed to the new labels and SDSs on the chemicals in their workplace during the transition phase. However, to ensure workplaces are compliant with the new regulations, it is critical that employees understand the new label and SDS formats.

OSHA requires the following training criteria to be in place prior to December 1, 2013.

Label training must include:

  • Product identifier: The chemical may be identified by the name, code number or batch number. The manufacturer, importer, or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS.
  • Signal word: DANGER and WARNING are the two classes utilized on the labeling. The word DANGER is used for the more severe hazards and the word WARNING is used for the less severe hazards.
  • Pictogram: OSHA has designated eight pictograms to be associated with a hazard category.

OSHA_HCS_pictogram_download.jpg

  • Hazard statement: The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.
  • Precautionary statement: Describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
  • Contact information: Name, address and phone number of the chemical manufacturer, distributor, or importer.
  • Workplace label use: Describes proper storage requirements and first aid procedures
  • Element integration: For chemicals that have multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class. When there are similar precautionary statements, the one providing the most protective information will be included on the label.
 

Safety Data Sheet Format

SDS format and information training must cover the following topics:
  • Standardized 16-section format including the section numbers, the headings, and associated information:
    • Section 1: Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
    • Section 2: Hazard(s) identification includes all hazards regarding the chemical; required label elements.
    • Section 3: Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
    • Section 4: First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
    • Section 5: Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
    • Section 6: Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
    • Section 7: Handling and storage lists precautions for safe handling and storage, including incompatibilities.
    • Section 8: Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
    • Section 9: Physical and chemical properties lists the chemical’s characteristics.
    • Section 10: Stability and reactivity lists chemical stability and possibility of hazardous reactions.
    • Section 11: Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
    • Section 12: Ecological information*
    • Section 13: Disposal considerations*
    • Section 14: Transport information*
    • Section 15: Regulatory information*
    • Section 16: Other information, includes the date of preparation or last revision 

*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15 (29 CFR 1910.1200(g)(2)).

Preparedness and Emergency Management - TRP Corp

Tags: HAZCOM, Training and Exercises, Emergency Management Program, Safety, Workplace Safety, Chemical Industry

PREP for Corporate Regulatory Compliance

Posted on Mon, Oct 07, 2013

Industry-specific regulations often require response exercises for compliance. The National Preparedness for Response Exercise Program (PREP) is designed to facilitate the periodic testing of oil spill response plans for certain vessels and facilities, and provide companies an economically feasible mechanism for exercise compliance.

This unified federal effort provides a consistent set of guidelines that satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline Hazardous Material Safety Administration (PHMSA) , and the Bureau of Safety and Environmental Enforcement (BSSE). Completion and documentation of the PREP exercises satisfies all OPA 90 mandated federal oil pollution response exercise requirements.

Exercises must be designed to test responder competencies, and response plan components for effectiveness and accuracy.  In preparation for these exercises, companies should develop exercise-planning documents and participant packages that contain exercise objectives, scenarios, ground rules, and in some cases, simulated injects. Through exercises, responders gain an understanding of the site-specific Emergency Response Plan framework. Exercises provide a mechanism to test participants’ knowledge and understanding of how to mobilize an appropriate response, execute communications and decision-making processes, and effectively manage a worst-case spill response. Effectively planned and executed exercises typically result in improved communication and multi-agency response capabilities in the event of an actual spill.

Common exercise objectives include, but are not limited to:

  • Practice application of National Incident Management System (NIMS) and the Incident Command System (ICS)
  • Improve understanding of the Emergency Response Team and Incident Management Team organizations.
  • Improve understanding of the internal and external response capabilities, associated responsibilities, and expectations of the company.
  • Practice documenting and communicating response actions, management decision, and tracking of resources, using standardized Incident Command System (ICS) forms and the Oil Spill Response Plan.
The following 15 PREP components must be exercised during a three years period  in order to fulfill PREP requirements:

Organization

1. Notifications: Test the notification procedures identified in the Area Contingency Plan (ACP) and the Spill Response Plan.

2. Staff mobilization: Demonstrate the ability to assemble the spill response organization identified in the ACP and the Spill Response Plan.

3. Operate within response management system. Including:

  • Unified Command: Demonstrate the ability of the spill response organization to work within a unified command.
  • Response management system: Demonstrate the ability of the response organization to operate within the framework of the response management system identified in their respective plans.

Operational Response

4. Source control: Demonstrate the ability of the spill response organization to control and stop the discharge at the source.

5. Assessment: Demonstrate the ability of the spill response organization to provide initial assessment of the discharge and provide continuing assessments of the effectiveness of the tactical operations.

6. Containment: Demonstrate the ability of the spill response organization to contain the discharge at the source or in various locations for recovery operations.

7. Recovery: Demonstrate the ability of the spill response organization to recover, mitigate, and remove the discharged product (includes mitigation and removal activities).

8. Protection: Demonstrate the ability of the spill response organization to protect the environmentally and economically sensitive areas identified in the ACP and the respective industry response plan.

9. Disposal: Demonstrate the ability of the spill response organization to dispose of the recovered material and contaminated debris.

Response Support

10. Communications: Demonstrate the ability to establish an effective communications system for the spill response organization.

11. Transportation: Demonstrate the ability to establish effective multi-mode transportation both for execution of the discharge and support functions.

12. Personnel support: Demonstrate the ability to provide the necessary logistical support of all personnel associated with response.

13. Equipment maintenance and support: Demonstrate the ability to maintain and support all equipment associated with the response.

14. Procurement: Demonstrate the ability to establish an effective procurement system.

15. Documentation: Demonstrate the ability of the spill response organization to document all operational and support aspects of the response and provide detailed records of decisions and actions taken.

For a free download on "TIPS on CONDUCTING an EFFECTIVE EXERCISE", click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: USCG, PHMSA, EPA, Training and Exercises, Safety

EHS Training of Basic Emergency Response Communication Details

Posted on Thu, Sep 19, 2013

Emergency planning is an ongoing process. Preparing for every unknown site-specific contingencies is potentially unrealistic. Yet, planning for every all-inclusive identified incidents is daunting and time consuming. Despite scenario specifics, the need to communicate detailed site information remains constant. While every effort should be made to include processes and procedures for the most likely and applicable emergency scenarios relevant to your operations, training employees on the basic site-specific response facts is fundamental in emergency management.

The need to swiftly communicate accurate and pertinent information is common to each emergency scenario. Detailed information should be readily available to ensure all emergency managers, response personnel, and applicable agencies are quickly notified in the event of an incident. Information, at a minimum should include:

  • Location
  • Type of incident (medical, fire, oil spill, etc.)
  • Casualties or injured parties

There is a fine line between comprehensive details and overwhelming information. Developing a summary of key facility details will enable initial responders to quickly relay features of the facility and its operations. Although the structure of a company’s emergency response team can vary, personnel should have basic knowledge of the following site-specific incident response information:

  • Location of Emergency Response Plan
  • Location of Response Pre-Plans
  • Overview and contact information for on-site Security
  • Instructions on who to contact and how to activate alarms, if applicable
  • Identification of on-site Incident Commander
Individuals who demonstrate a clear understanding of their response team role(s) and responsibilities are better prepared to implement a streamlined and effective response. Response plans with detailed site information provide the necessary foundation for a response team to build from. However, a short summary of approved response procedures, in addition to a full-scale emergency response plan, can assist non-response team members in performing initial response efforts. Response plan contents should include, at a minimum, the following general information:
  • Facility Name
  • Address
  • Latitude/Longitude
  • Contact Number
  • Contact Person (and/or facility manager)/contact number(s)
  • Site Description, including detailed information such as operations, products handled, number of employees, and any specific physical attributes
  • Summary of Physical Site Attributes
    • Identification of waterways in the vicinity
    • Summary of site drainage properties
    • Site topography
    • Site security features, including fencing, visitor access, and lighting

Companies can expand upon facility specific information by incorporating and sharing fire pre-plans with response groups. Fire pre plans provide useful, site-specific information for responding to fires in schools, office buildings, hospitals, hotels, apartment buildings, shopping centers, laboratories, and other structures. Identification of pertinent emergency response information and up-to-date photographs can greatly assist firefighters in understanding the hazards and best strategy for rescues, and reducing potential for injuries and property damage.

The information listed in a fire pre-plan, such as floor plan(s) and details of on-site hazardous material(s), are required by multiple agencies (OSHA, DOT, EPA, USCG) as part of an overall emergency response plan.  However, other specific fire fighting information, such as construction details, hydrant, and utility valve locations may be useful to responders if highlighted in a stand-alone format and shared with responders prior to an emergency. Information to include when developing fire pre plans are as follows:

  • Building Information
  • Emergency Procedures
  • Alarms/Emergency Lighting
  • Fire Protection Equipment
  • Special Hazards
  • Building floor plans/photographs
  • Photographs

Making site-specific facility information and response procedures available to employees, internal response teams, and local first responders improves the potential for a successful response. The faster responders can identify, locate, assess, access, and mitigate the emergency, the sooner an incident can be contained. Expediting response efforts through preparedness and response training can minimize the harmful effects of an incident.

For a free download of a Response Procedures Flow Chart, click the image below:

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Tags: Response Plans, Incident Management, Training and Exercises, Communication Plan, Safety, Notification Systems