Emergency response plans should be reviewed annually, at a minimum. However, when facility acquisitions occur, companies must initiate the process of developing site-specific emergency response plan(s). Newly acquired facilities must be analyzed for operational hazards, site-specific risks, response capabilities, and regulatory requirements as soon as possible. A post acquisition checklist should include emergency management components that ensure new facilities are able to effectively respond in case of an emergency.
At a minimum, a post acquisition checklist should incorporate the following five emergency management components:
1. Response Plan Audit
Audits should verify that response plans have been effectively developed for each potential scenario and satisfy all applicable regulatory requirements. Whether conducted by in-house professionals or experienced consultants, audits can often reveal mitigation opportunities, response inadequacies, plan inconsistencies, and gaps in regulatory compliance.
All regulatory requirements should be met. These are typically based on location(s), industry, operations, and hazards. At a minimum, an audit of newly acquired facilities should include:
- Evaluation of operations for compliance
- Checking accuracy of plan content
- Identification of required training and confirm necessary documentation
- Review of plan approval and submittal process
2. Response Team Details
Forming a response team and assigning responsibilities is one of the crucial steps in emergency response planning. Individuals should be selected based on authority level and experience, and should be trained for their expected, site-specific tasks. The more knowledgeable individuals are of their response team roles and responsibilities, the better prepared a team can be to implement a streamlined response in the event of an emergency. At the minimum, response team implementation should:
- Identify Incident Commander and other response team members
- Verify the new response team organizational chart
- Identify site-specific response team activation measures
- Create response team roles and responsibilities checklists
3. Contact Information Verification
Confirming the accuracy of response plan notifications is critical. Unfortunately, the contact verification step is often neglected. When new plans are developed, it is essential that contact numbers be verified for accuracy. When response time is of the essence, a response should never be prolonged because of inaccurate or out of service contact information. If companies utilize an automated call out system, important information may not be received if contact information is incorrect.
Contact verification procedures should be implemented to solidify the accuracy of all contact information, including email addresses, cell phone numbers, and land lines for all stakeholders listed in the plan.
4. Response Training Requirements
When new facilities are acquired, a training evaluation can highlight established or necessary response training programs, and reveal inadequacies, mitigation opportunities, and misaligned objectives. The following can be used to evaluate and implement training program priorities:
- Emphasize the basic and program-specific training and refresher requirements
- Designate a single point of contact to be responsible for training compliance
- Strengthen controls over the training process to ensure that credentials are only issued to those who demonstrate training requirement completion
- Identify specific training requirements applicable to positions and perform cyclical training audits
- Amend existing external cooperative agreements to require training compliance with response position descriptions
- Correct limitations in the Emergency Management system, such as populating the system with a complete list of training requirements and enabling certificates to be uploaded into the system
- Develop and implement a monitoring and oversight program to better manage and assess training requirements, reports, supervisory oversight, and compliance
- Confirm documentation methods
5. Exercise the Response Plan
A true test of an emergency plan is best conducted through emergency drills and exercises. Designing and conducting exercises is time consuming, but valuable for training, assessing the state of your program, and identifying gaps and deficiencies that should be addressed prior to experiencing an actual emergency. The following criteria should be evaluated when exercising the effectiveness and accuracy of a response plan and corresponding processes:
- Prevention or Deterrence: The ability to detect, prevent, preempt, and deter incidents or emergencies.
- Infrastructure Protection: The ability to protect critical infrastructure from site-specific threats and hazards.
- Preparedness: The ability to plan, organize, and equip personnel to perform assigned response missions under various conditions and scenarios.
- Emergency Assessment/Diagnosis: The ability to achieve and maintain a common operating structure, including the ability to detect an incident, assess impact, and initiate notifications.
- Emergency Management/Response: The ability to control, collect, and contain a hazard, minimize its effects, and conduct environmental monitoring. Mitigation efforts may be implemented before, during, or after an incident
- Incident Command System (ICS): The ability to direct, control, and coordinate a response; manage resources; and provide emergency public information with the direction of an Incident Command System.
- Evacuation/Shelter: The ability to provide initial warnings to the at-risk population, notify people to shelter-in-place or evacuate, provide evacuation and shelter. support; confirm headcount, and manage traffic flow to and from the affected area.
- Victim Care: The ability to treat victims at the scene per training, arrange for transport patients, and handle, track, and secure human remains. Provide tracking and security of patients’ possessions, potential evidence, and manage mental health.
- Investigation/Apprehension: The ability to investigate the cause or source of the incident, and/or cooperate with local authorities for any man made emergencies
- Recovery/Remediation: The ability to restore essential business units and/or operations, cleanup the environment and render the affected area safe, provide necessary services to victims and/or the public; and restore a sense of well-being at the facility.
Challenged with managing response plans for multiple facilites? Download TRP's best practices guide on response planning for large organizations with multi-facility operations.