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Identifying Sensitive Environments in the Path of an Oil Spill

Posted on Mon, Oct 17, 2011

While oil spills can effect the immediate area, migrating spills that extend beyond its containment measures can greatly affect the surrounding areas and possibly damage sensitive environments. A critical step in protecting sensitive resources is identifying the presence and types of resources that are in the likely path of an oil spill.

Analyzing possible spill trajectories through topographical features, wind speeds, and water flow rates allows planners to identify which areas are most likely to be impacted by a spill.  Once these resources have been identified, decisions need to be made as to the proper protection techniques for each locale and the priority for application of resources to each sensitive site.

Sensitive_Environments_TRP.jpgTypes of sensitive areas to evaluate include, but are not limited to:

  • Ecological: Examples of sensitive species include shore birds and other water fowl, seals and other marine mammals, shellfish, commercially important wildlife, and species with limited distribution or populations. Sensitive habitats range from protected bays with marshes and tidal flats to open coast areas used as marine mammal or bird breeding sites.
  • Cultural: Areas of direct importance to humans including, but not limited to native lands, historical land marks, waterfront parks, and recreational areas.
  • Economical: Populated areas that are highly valued because of their ability to generate income. Area’s include tourist sites, real estate developments, urban developments, marinas, parks and other locations.
  • Specific sensitive resources: Specific resources that are only available at that particular location, such as specialized suppliers, water sources, transportation systems, food sources.

Once the sensitive areas in the path of a potential oil spill are identified, tactical plans and processes should be developed to limit the duration of impact. Tactical planning provide site-specific focus to emergency response plans, and applies a response perspective with specific, short-term actions and responses. These plans provide details that allow responders to best access, assess, and quickly respond to off-site spills, limiting the effects of a spill on sensitive environments.


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Tags: USCG, Pipeline, OSHA HAZWOPER, Emergency Preparedness, SPCC, OPA 90, Oil Spill, Emergency Management Program, HAZWOPER

FEMA's Plan for the Future - Strategic Foresight Initiative

Posted on Mon, Jul 11, 2011

The Federal Emergency Management Administration (FEMA) released the Strategic Foresight Initiative in hopes to assist the emergency management profession better plan for the future.

The Strategic Foresight Initiative, derived from over 500 members of the emergency response community, addresses nine areas that will affect the future of emergency management:

1. Changing role of the individual in disaster preparedness
- Increased empowerment of the individual through availability of information
- Lack of trust in government authorities
- Changing definition of community from the traditional geographic community to a virtual community

2. Climate change
- Heightened weather patterns (ex: more flooding rains, intense storms, droughts)

3. Critical infrastructure
- Aging transportation, communication, energy, and health care infrastructure may create additional emergency situations

4. Evolving terrorist threat

- Availability of technical and scientific knowledge may increase terrorist access to “high consequence” weapons

5. Global interdependency
- Emergency managers may take on greater role in Emergency Management internationally
- A more global role for American emergency managers could have major resource and capability implications

6. Technological innovation and dependency
- Our communications, energy, and transportation infrastructure are all heavily dependent on technology
- This dependency creates a significant vulnerability to cyber-attack, particularly if our reliance creates single points of failure within our systems

7. Universal access to and use of information
- Access to real time information will continue to increase as social media and advances in technology create new patterns of communications
- Citizens are becoming both producers and consumers of information
- Legitimacy and accuracy of information must constantly be questioned and verified

8. U.S. demographic shifts
- Potential increasing populations, ethnic diversity, and larger percentage of senior citizens will create additional planning challenges

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

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Tags: USCG, PHMSA, OSHA, Emergency Preparedness, EPA, Facility Management, Emergency Management Program, FEMA

Storm Water Pollution Prevention Plans for Industrial Facilities

Posted on Fri, Mar 25, 2011

U.S. Environmental Protection Agency (EPA) issues “General Permits” for storm water discharges associated with industrial activity, under the National Pollutant Discharge Elimination System (NPDES) program (as defined in 40 CFR 122.21 and 40 CFR 122.26). Runoff that contacts industrial materials can transport pollutants into nearby water sources.  As a result, the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP) is required in order to obtain a general permit.  A SWPPP, and its required information, should be incorporated into a facility’s overall emergency management program.

The purpose of a SWPPP is to identify potential storm water pollution sources and reduce the potential for pollutants reaching nearby waterways.  Establishing procedures and controls is necessary to accomplish the following SWPPP objectives.

  • Identify pollutants that may come in contact with stormwater.
  • Establish measures to prevent pollutants from coming in contact with storm water.
  • Establish controls to reduce or eliminate the potential for contaminated storm water being released to the environment.

Annual site compliance evaluations are also required by the general permit and must be conducted by a qualified or SWPPP trained personnel.  Evaluations must include the following:

  1. Inspect storm water drainage areas for evidence of pollutants entering the drainage system.
  2. Evaluate the effectiveness of Best Management Practices (i.e. good housekeeping measures, preventive maintenance, spill prevention and response, etc.).
  3. Observe structural measures, sediment controls, and other storm water best management practices to ensure proper operation.
  4. Revise the plan as necessary within two (2) weeks of the inspection, and implement any necessary changes within twelve (12) weeks of the inspection.
  5. Prepare a report summarizing inspection results and actions items, identifying the date of inspection and personnel who conducted the inspection.
  6. Sign the report and keep it with the plan.
  7. If the annual review does not identify any action items, it will certify that the facility is in compliance with the Permit.

Completed site compliance evaluation checklists must be retained for a period of one year after expiration of the General Permit.

According to the EPA, a general permit is an NPDES permit that covers several facilities that have the same type of discharge and are located in a specific geographic area. A general permit applies the same or similar conditions to all dischargers covered under the general permit.

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

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Tags: USCG, Emergency Preparedness, EPA, Regulatory Compliance, Emergency Management Program, Chemical Industry

Regulatory Compliance - It's the Law!

Posted on Fri, Mar 11, 2011

An organization can have numerous locations that cross county, state, and/or country borders. Despite operating within the same industry, each site may need to comply with specific applicable local, state, and/or federal regulatory mandates.

Organizations must comply with an ever increasing number of regulations. For example, one specific industrial facility in Louisiana has to meet as many as 700 individual requirements. Non-compliance can cost organizations thousands of dollars, yet documenting and managing these mandates within day to day operations can be a daunting task. 

The implementation of a tracking management system that can eliminate redundancies across converging compliance specifications is extremely beneficial for organizations that have multiple applicable regulatory requirements.

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

  • Operational category: 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.
  • Applicable Regulation Level:  Regulations should be further broken down to Federal, state or local regulation categories. 
  • Last update: Date that each regulation was last updated.
    Compliance Task:  Tasks that needs to be completed for compliance.
  • Compliance Feedback:  Applicable notes.
  • Industry Standard:  Industry standards or best practices that apply to the specific  regulatory requirement
  • Cross reference: Itemize list of additional regulations that may be applicable to the information provided.
  • Facility Compliance responsibility: Person(s) responsible to maintain compliance for each regulatory requirement.
  • Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and persons 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.

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

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Tags: USCG, DOT, CFATS, Emergency Preparedness, Crisis Management, SPCC, EPA, Regulatory Compliance, Emergency Management Program

Feb 14, 2011 USCG Message to Marine Transportation Related Facilities

Posted on Tue, Feb 15, 2011

On Feb. 14, 2011, the USCG National Strike Force Coordination Center sent a message to Oil Spill Removal Organizations (OSROs) regarding the implementation of the new facility regulations that affect aerial oil tracking capabilities and facility response plans.

Currently, Captain of the Ports (COTPs) are reaching out to marine transportation related facilities to advise them that they ARE NOT REQUIRED to submit plan amendments related to aerial tracking requirements found in 33 CFR 154.1045(j) at this time.

33 CFR 154.1045 (j) states "The owner or operator of a facility handling Groups I through IV petroleum oil as a primary cargo must identify in the response plan, and ensure the availability through contract or other approved means, of response resources necessary to provide aerial oil tracking to support oil spill assessment and cleanup activities. Facilities operating exclusively on inland rivers are not required to comply with this paragraph."

The term "inland rivers" is not defined within 33 CFR 154 and is leading to confusion as to which facilities fall under the requirement to provide aerial tracking resources. The term "inland rivers" is a critical factor in determining applicability to 33 CFR 154.1045(j). A determination must be made regarding the term "inland rivers" as used in 33 CFR 154.1045(j), and until this is done, the Coast Guard does not want facilities pursuing changes to their FRP when they may not be required to do so.

This direction is only applicable to aerial tracking resource requirements pertaining to facility response plans.

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

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Tags: USCG, Emergency Preparedness, Oil Spill, Regulatory Compliance, Emergency Management Program

Regulatory Compliance Management

Posted on Fri, Feb 11, 2011

Managing regulations for industrial facilities can be a daunting task.  Industrial facilities must operate profitably, yet comply with a complex array of federal, state and local regulations. 

To ensure regulatory compliance, companies must establish an effective method of tracking and documenting actions items required for compliance.

Companies are always searching to reduce the costs and efforts required to manage compliance, so they can focus budgets within their core business.  However, lack of compliance can result in additional financial burdens resulting from fines, negative public perception, and possibly government mandated shutdown of operations.

Technology can be a useful, and relatively inexpensive tool for companies to monitor continually evolving regulatory requirements. The use of Excel spreadsheets is a common way to manage these requirements and may be effective for small operations. However, as companies grow and numbers of facilities increase, spreadsheets can become overwhelming, ineffective, and time consuming. Larger operations should consider utilizing database technology to ensure that compliance can be effectively managed on an enterprise-wide level.

Key concepts for managing regulatory compliance from a corporate perspective include, but are not limited to:

  • Use of Database Technology - This allows association of each regulatory requirement to applicable facilities. Updating evolving regulatory information can be effectively managed across multiple facilities with the use of a database.
  • Available Expertise - Identify corporate resources or outsource compliance expertise, and leverage that knowledge enterprise-wide.
  • Identify Facility-Specific Regulations -  Highlight mandatory submission requirements and tasks for each facility associated with each regulatory requirements.
  • Tasking -  Assign compliance tasks, frequencies, due dates, persons responsible, and document completion actions.
  • Identify Best Practices -  Apply best practices related to compliance with specific regulatory requirements, when practical to do so.
  • Organize Compliance Information - Utilize a database to limit duplication of tasks generated when multiple agencies have regulations that are related to the same subject matter.
  • Search Functionality - Create the ability to search database for key words and phrases associated with regulations.

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

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Tags: USCG, DOT, CFATS, Emergency Preparedness, EPA, OPA 90, Regulatory Compliance, OSHA HAZWOPER standard training

Procuring Emergency Responders

Posted on Tue, Jan 18, 2011

In a residential setting, one would call 911 for assistance during an emergency, which would summon the Police, EMS or Fire Department. But in an industrial setting where hazardous materials are involved, specialized resources are likely to be required.  In the United States, the National Response Center is the 911 for spill related emergencies.

According to the National Response Center (NRC), its “primary function is to serve as the sole national point of contact for reporting all oil, chemical, radiological, biological, and etiological discharges into the environment anywhere in the US or its territories.”.

In addition to the federal assistance from the NRC, contracting with specialized local response resources are imperative. If a company does not own the necessary quantities of specialized response equipment, or requires additional equipment and personnel to control a worst case discharge spill scenario, U.S. Coast Guard certified  OSROs (Oil Spill Removal Organizations) can provide equipment and additional personnel. Companies need to establish contracts with OSROs to provide necessary resources to assist in responding to a significant spill.  

Other resources should also be identified and listed in your plans. These include, but are not limited to:

  • Medical Services
  • Caterers
  • Hotels
  • Waste management companies
  • Equipment suppliers
  • Environmental consultants
  • Construction equipment

Internal and external corporate numbers, as well as any additional responders’ contact information should be included in your emergency response plan.  In addition, a systematic approach to verifying external available equipment and contact information should be an ongoing process for those responsible for maintaining these plans.

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

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Tags: USCG, Emergency Preparedness, Oil Spill, Emergency Management Program

Facility Response Plan Submittal Requirements for EPA, DOT and USCG

Posted on Fri, Nov 05, 2010

One of the most important aspects of maintaining your facility response plans is ensuring that plan revisions are submitted to regulatory agencies in a timely manner. The EPA, PHSMA, and the USCG have different requirements for when revisions need to be submitted.

  • EPA :  According to 40 CFR 112.20, each time there is a material change at a facility, the response plan must be resubmitted for approval within 60 days.
  • DOT/PHMSA:  According to 49 CFR Part 194.121, each operator shall review its response plan at least every 5 years from the date of submission and modify the plan to address new or different operating conditions or information included in the plan.
  • U.S. Coast Guard (USCG): According to 33 CFR Part 154.1065, facilities must review their plan annually. Any review should include revisions to the plan, including listings of fish and wildlife and sensitive environments identified in the Area Contingency Plan in effect 6 months prior to plan review. For an MTR facility identified in § 154.1015(b) as a “substantial harm facility” this review must occur within 1 month of the annual anniversary date of submission of the plan to the COTP. The COTP may require a facility owner or operator to revise a response plan at any time as a result of a compliance inspection if the COTP determines that the response plan does not meet the requirements or as a result of inadequacies noted in the response plan during an actual pollution incident at the facility.

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Tags: USCG, DOT, Emergency Preparedness, EPA, Emergency Management Program, Deadline Approaching

Facility Security Plans and the Maritime Transportation Security Act

Posted on Fri, Sep 24, 2010


Certain industrial and municipal facilities are vulnerable to breaches in security and associated threats. Those vulnerabilities vary according to the location and characteristics of the sites; however, the main goal of assessments are to identify and limit security risks to your facility, equipment, and personnel. Being able to identify and quantify risks allows you to establish policies and procedures that can minimize the risk and consequences of security threats, and provide increased safety.

Marine Transportation Security Act requires “any structure or facility of any kind located in, on, under, or adjacent to any waters subject to the jurisdiction of the United States to conduct a vulnerability assessment and prepare and submit a security plan to the Secretary of Homeland Security based on the assessment.”

The following topics should be considered in developing security plans:
  • Internal and external risks, and vulnerability assessment of those levels of risks.
  • On-site and/or off-site security oversight organization and specific duties and responsibilities.
  • Detailed list of security personnel and Facility Security Officer training, exercises and drill procedures.
  • Security of facility record keeping and documentation procedures.
  • Procedures for implementing MARSEC Level security measures, within 12 hours of notification of an increase.


  • Specific standard internal and external communications procedures, and alternate communication procedures (ex: Interfacing with Vessels, Declaration of Security (DoS)).
  • Security measures for access control in general and restricted areas for employees, contractors and outside parties for each MARSEC Level.
  • Identify alternate security measures if initial systems fail.
  • Identification of on-site and off-site security command center.
  • Evaluation and identification of procedures and security measure for deliveries of hazardous and/or non-hazardous materials, and delivery of vessel stores and bunkers.
  • Identification of potential ignition sources and security control procedures.
  • Detailed site-specific incident security and monitoring procedures.
  • Identification and evaluation of security procedures for auditing and updating security plans
  • Facilities must be able to present a Facility Security Assessment (FSA) Report and Facility Vulnerability and Security Measures Summary (Form CG-6025).
  • If these items are not included in the Facility Security plan, the plan will not be approved by Coast Guard Inspectors.


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Tags: USCG, CFATS, Emergency Preparedness, Security plans

USCG Mandates Vessel Response Plan Compliance by Feb 22, 2011.

Posted on Fri, Aug 20, 2010

The U.S. Coast Guard’s new regulations to improve pollution-response preparedness for vessels carrying or handling oil upon the navigable waters of the United States goes into effect February 22, 2011.

This final rule, applicable upon all navigable waters of the U.S. including the exclusive economic zone and adjoining shorelines, updates Coast Guard requirements for oil-spill removal equipment associated with vessel response plans and marine transportation-related facility response plans.  

The new rules directly regulate vessels carrying oil in bulk and marine transportation related (MTR) oil facilities that are required to have an oil response plan under the current Vessel Response Plan rules. These regulatory updates add requirements for plan holders to use new response technologies and revise methods and procedures for oil spill response. Vessel Response Plan holders must ensure dispersant service providers meet regulatory response requirements. Instead of detailed equipment lists, plan holders can reference OSROs that provide dispersants if USCG classified and whose availability has been ensured by contract or other approved means.

The following additional American Society for Testing and Materials (ASTM) are applicable to vessels:

  • ASTM F1413–07, Standard Guide for Oil Spill Dispersant Application Equipment: Boom and Nozzle Systems, incorporation by reference approved for §155.1050.
  •  ASTM F1737–07, Standard Guide for Use of Oil Spill Dispersant-Application Equipment During Spill Response: Boom and Nozzle Systems, incorporation by reference approved for §155.1050.
  • ASTM F1779–08, Standard Practice for Reporting Visual Observations of Oil on Water, incorporation by reference approved for §155.1050.

 The following are some of the additional updated requirements for vessels. A detailed list of the new requirements can be found at:

  • § 155.230 Emergency control systems for tank barges- Each operator of the system should wear a safety belt or harness secured by a lanyard to a lifeline, drop line, or fixed structure such as a welded padeye, if the sea or the weather warrants this precaution. Each safety belt, harness, lanyard, lifeline, and drop line must meet the specifications of ANSI A10.14
  • 155.235 Emergency towing capability for oil tankers- An emergency towing arrangement shall be fitted at both ends on board all oil tankers of not less than 20,000 deadweight tons (dwt), constructed on or after September 30, 1997. For oil tankers constructed before September 30, 1997, such an arrangement shall be fitted at the first scheduled dry-docking, but not later than January 1, 1999. The design and construction of the towing arrangement shall be in accordance with IMO resolution MSC.35(63)
  • 155.1035 Response plan requirements for manned vessels carrying oil as a primary cargo-

o     The format and content of the ship-to-ship transfer procedures must be consistent with the Ship-to-Ship Transfer Guide (Petroleum) published jointly by the International Chamber of Shipping and the Oil Companies International Marine Forum (OCIMF).

o     For vessels that handle, store, or transport Group I through Group V petroleum oils, the appendix must also separately list the resource providers identified to provide the salvage, vessel firefighting, and lightering capabilities.

o     For vessels that handle, store, or transport Group II through Group IV petroleum oils, and that operate in waters where dispersant use pre-authorization agreements exist, the appendix must also separately list the resource providers and specific resources, including appropriately trained dispersant-application personnel, necessary to provide, if appropriate, the dispersant capabilities required in this subpart. All resource providers and resources must be available by contract or other approved means.

o     The appendix must also separately list the resource providers and specific resources necessary to provide oil-tracking capabilities required in this subpart.

  •  155.1040 Response plan requirements for unmanned vessels carrying oil as a primary cargo-

o       The appendix must include a separate listing of the resource providers identified to provide the salvage, vessel firefighting, and lightering capabilities.

o       The appendix must include a separate listing of the resource providers and specific resources necessary to provide, if appropriate, the dispersant capabilities.

o       The appendix must include a separate listing of the resource providers and specific resources necessary to provide oil-tracking capabilities.

  • 155.1050 Response plan development and evaluation criteria for vessels carrying groups I through IV petroleum oil as a primary cargo.

o       The owner or operator of a vessel carrying groups II through IV petroleum oil as a primary cargo that operates in any inland, nearshore, or offshore area with pre-authorization for dispersant use must identify in their response plan, and ensure availability through contract or other approved means, of response resources capable of conducting dispersant operations within those areas.

o       The owner or operator of a vessel carrying groups I through IV petroleum oil as a primary cargo must identify in the response plan, and ensure their availability through contract or other approved means, response resources necessary to provide aerial oil tracking to support oil spill assessment, and cleanup activities. Vessels operating on inland rivers are not required to comply with this directive.

o       Aerial oil tracking resources must be capable of arriving at the site of a discharge in advance of the arrival of response resources identified in the plan for tiers 1, 2, and 3 Worst Case Discharge response times, and for a distance up to 50 nautical miles from shore (excluding inland rivers).

o       The Coast Guard will continue to evaluate the environmental benefits, cost efficiency and practicality of increasing mechanical recovery capability requirements. This continuing evaluation is part of the Coast Guard's long-term commitment to achieving and maintaining an optimum mix of oil spill response capability across the full spectrum of response modes. As best available technology demonstrates a need to evaluate or change mechanical recovery capacities, a review of cap increases and other requirements contained within this subpart may be performed.

  • Appendix B to part 155 Determining and Evaluating Required Response Resources for vessel Response Plans-

o       If the required capacity exceeds the applicable cap, then a vessel owner or operator must contract for at least the quantity of resources required to meet the cap, but must identify sources of additional resources as indicated in §155.1050(p). For a vessel that carries multiple groups of oil, the required effective daily recovery capacity for each group is calculated and summed before applying the cap.

o       A vessel owner or operator must plan either for a dispersant capacity to respond to a vessel's worst case discharge (WCD) of oil, or for the amount of the dispersant resource capability as required by §155.1050(k)(3) of this chapter, whichever is the lesser amount. When planning for the cumulative application capacity that is required, the calculations should account for the loss of some oil to the environment due to natural dissipation causes (primarily evaporation).

Affected plan holders should review the final rules and take all necessary measures to ensure that an updated response plans are submitted by February 22, 2011 and in compliance.

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Tags: USCG, Emergency Preparedness, Deadline Approaching