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Post Acquisition Response Planning Checklist for the Emergency Manager

Posted on Thu, May 22, 2014

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

handshaketrp.jpg 

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:

  1. Emphasize the basic and program-specific training and refresher requirements
  2. Designate a single point of contact to be responsible for training compliance
  3. Strengthen controls over the training process to ensure that credentials are only issued to those who demonstrate training requirement completion
  4. Identify specific training requirements applicable to positions and perform cyclical training audits
  5. Amend existing external cooperative agreements to require training compliance with response position descriptions
  6. 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
  7. Develop and implement a monitoring and oversight program to better manage and assess training requirements, reports, supervisory oversight, and compliance
  8. 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.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

 

Tags: Response Plans, Training and Exercises, Facility Management, Emergency Management Program, Workplace Safety

Consultants Combat Emergency Management Challenges: Oil and Gas Industry

Posted on Mon, Mar 24, 2014

According to the U.S. Department of Labor’s Bureau of Labor Statistics, the oil and gas extraction industry, as well as the petroleum and coal products manufacturing, accounted for the some of the lowest recordable occupational injury incident rates in private industry for 2011. But despite statistics, the industry’s public safety perception has been tested by highly publicized tragic incidents, increasing the pressures on emergency managers.

Preparedness planning and emergency management within the highly regulated energy industry requires expertise. Those who manage these programs face many challenges. Preparing for resilience requires planning, internal and external response coordination, training, and exercises. In addition to grappling with budget restraints, program managers are responsible for planning, regulatory compliance, and possibly responding to  emergencies. Implementing this level of company and facility resilience often requires external expertise or the services of specialized consultants.

Oil and gas emergency management program challenges may include:

  1. Maintaining multiple and complex response plans
  2. A lack of detailed site-specific response strategies
  3. Frequent personnel changes
  4. Evolving compliance requirements
  5. Regulatory audits
  6. Emergency management personnel who have other full-time responsibilities
  7. Minimal time available for training   
  8. Training
  9. Increased risk of regulatory penalties and fines
  10. Reduced budgets
  11. Gathering or verifying site-specific information for Oil Spill Response, Emergency Response, and SPCC Plans.
  12. Providing professional engineer certification for SPCC plans.
  13. Developing Oil Spill Tactical Plans for response strategies downstream of your facilities and pipelines.
  14. Developing response pre-plans for tanks, process units, and buildings,  and high angle and confined space rescue plans.
  15. Conducting emergency response assessments of personnel, response equipment, plans, and response contractors.

The ramifications of non-compliance or a hazardous incident can be exceedingly detrimental to oil and gas companies. As a result, many oil and gas companies utilize consultants to ensure their preparedness program levels match regulatory compliance requirements and best practice implementation. These specialized experts recognize that proven best practices and strict compliance reduces the inherent hazards associated with oil and gas operations.

TRP Corp - Oil and Gas Consultant

The costs associated with contracting consulting services are always in question. When hiring an external emergency management and preparedness consultant, oil and gas companies should evaluate the strategic cost of an incident and the tactical cost of safety compliance versus the consultant fee. The cost benefit of hiring a specialized, reputable consultant typically outweighs the financial impacts associated with non-compliance or a catastrophic incident.

A consultant can improve safety performance and reduce the strategic cost of an incident by:

  • Reducing the overall number of incidents
  • Improving the ability to respond effectively
  • Improving the casualty and harm conditions through expedited responses and accident avoidance
  • Proactively showing intent and safety investment through the media and public
  • Helping reduce downtime
  • Improving asset utilization

In addition, the tactical cost of compliance can be reduced if a competent and proven consultant is contracted. A consultant can improve the tactical cost of compliance by:

  • Simplifying and automating tracking, updating, and management
  • Facilitating a universal ability to update response management plans across all locations and facilities
  • Automating core compliance and response planning activities
  • Reducing the compliance and safety resource requirements
  • Enabling EHS workers to spend time planning and performing vs. complying and reporting
  • Optimizing and coordinating drills, exercises, and actual emergency responses

Consultants can also provide assistance in responding to incidents or non-compliance issues. With each occurrence, vital proactive measures, including procedural and preparedness efforts, can be implemented in order to safely minimize future mandates, fines, accidents, and/or catastrophes.

Learn why Audits can minimize non-compliance, what documents should be reviewed, how they can imprive HSE programs: Download your Audit Preparedness Guide for Industrial Regulatory Compliance (click the image below):

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Tags: Choosing a Consultant, Facility Response Plan, Emergency Management, OPA 90, Emergency Response Planning, Workplace Safety

The Facility Response Plan Annual Review

Posted on Mon, Feb 10, 2014

A facility response plan is only as effective as the information it contains and the comprehension of those utilizing the plan. As facility specifics change, response plans must change accordingly. Fundamental regulatory compliance, inherent site-specific safety issues, human resource factors, and a company’s reputation obligate specific response planning requirements for a facility. Cyclical plan maintenance is essential in order to capture multiple moving parts that impact an emergency management program.

The response plan should be reviewed annually, at a minimum. Plans should evolve as lessons are learned, new information and insights are obtained, and operational priorities are updated. Utilizing a web-based, database driven planning system simplifies the update process, despite location of influential parties. An annual review enables practical opportunities to minimize or eliminate incidents, the ability to provide “mission accomplished” in the event of an incident, and mandated regulatory compliance. The planning review cycle typically corresponds to the criteria laid out by the associated regulatory agencies; however, internal corporate policy may dictate multiple reviews throughout a fiscal year.

Decision-makers directly involved in the plan review process can determine its effectiveness and efficiency by its adequacy, feasibility, and acceptability, along with responders’ understanding of plan requirements. The plan review can also address present and future risks, and define potential response costs. According to FEMA, there are five commonly used criteria to determine the effectiveness and efficiency of response plans.

Adequacy: Emergency managers should apply their experience, judgment, intuition, situational awareness, and discretion to ensure a plan is adequately suited for a facility’s identified hazards. FEMA defines a plan as adequate if:

  1. The scope and concept of planned operations identify and address critical tasks effectively
  2. The plan can accomplish the assigned mission while complying with guidance
  3. The plan’s assumptions are valid, reasonable, and comply with guidance.

Feasibility: The established response procedures should be rigorous enough, yet standardized, to minimize subjectivity or interpretation, and preclude oversights in order to accomplish the assigned mission and critical tasks. This should be accomplished by using currently available resources within the minimum time frame set forth by the plan. Available resources include internal assets and those available through mutual aid, private contractors, or through existing state, regional, or Federal assistance agreements.

Acceptability: The plan meets the requirements driven by a threat or incident, goals set by decision makers, budgetary restraints, response time limitations, and abides by applicable law(s).

Completeness: The plan includes all applicable and effective emergency procedures with estimated response times, required capabilities, needs of the population, and identified success criteria. All information, including contact information, should be updated and accurate.

Compliance: The plan should comply with all internal and external guiding doctrine within the boundaries of the presiding law(s). Failure to comply with regulations can result in additional financial burdens resulting from fines, negative public perception, and possibly government-mandated shutdown of operations.

According to FEMA’s Comprehensive Planning Guide, there are six key steps in developing effective response plans. An annual review can incorporate these steps to verify the five commonly used criteria to determine the effectiveness and efficiency of emergency plans. At each step of the review, emergency managers should consider the impact on required training, exercises, and equipment costs and availability.

Step 1: Collaborative Teamwork

  • Identify and verify the facility response planning team. Typically this includes an emergency manager or security manager, a hazard mitigation expert, local jurisdictions, and any additional available planning experts.
  • Engage essential personnel in the review process to identify changes in capabilities and resources.

Step 2: Understand Potential Situations

  • Identify any new or altered threat and/or hazard: Geographic and facility hazards and risks can be broken down into four areas:
  1. Natural Hazards
  2. Technological Hazards
  3. Chemical Hazards
  4. Human Hazards
  • Assess Risk: Assign probability values to new or altered threats and hazards for the purposes of determining priorities, developing processes and procedures, and allowing for informed decision-making.

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Step 3: Determine Goals and Objectives

  • Identify Altered Operational Priorities: Specify goals and objectives desired for emergency responders, employees, and facility, and define a success for each operation.

Step 4: Plan Update

  • Develop and analyze procedural options based on current best practices, lessons learned, and regulatory updates.
  • Participants should add necessary supporting information, graphics, and/or photos taking note to comply with local, state and federal regulations.
  • Identify current internal and external resources necessary to fulfil requirements, response obligations, and assignments.
  • Emergency managers should identify any changes or updates to the information necessary to drive response decision-making and trigger critical response actions.

Step 5: Plan Approval and Distribution

  • Senior management and, in some cases, associated regulatory agencies typically grant emergency plan approvals.  Once changes are approved, the plan should be distributed to appropriate individuals/ organizations.
  • A record of the individuals/ organizations that received a copy (or copies) of the plan should be maintained.

Step 6: Plan Implementation & Maintenance

  • Exercise the updated plan: Evaluating the effectiveness of plans involves a combination of training events, exercises, and real-world incidents to determine whether the goals, objectives, decisions, actions, and timing outlined in the plan can lead to a successful and effective response.
  • Planning teams should evaluate the process for reviewing, revising, and distributing the plan. A web-based, database driven planning systems eases the administrative burden and applicable costs associated with implementing, maintaining, and distributing response plans. Plan maintenance should be an ongoing and recurring activity.

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Regulatory Compliance with TRP Corp

 

Tags: Facility Response Plan, Emergency Preparedness, Response Plans, Facility Management, Emergency Response Planning, Workplace Safety

Fire Pre Plan Forms - Success is in the Details!

Posted on Mon, Jan 06, 2014

Safeguarding businesses from fire and subsequent losses should begin with pre-planning, effective mitigation measures, employees training, and local responder coordination. Fire pre-planning should be used to bolster overall EHS objectives subjected to regulatory requirements. However, according to the National Fire Protection Associations (NFPA), between 2006 and 2010 fire damage cost industrial and manufacturing facilities an estimated $951 million each year.

Many industrial facilities contain unique hazards and obstacles, making it more difficult to manage an effective response to a fire.  By removing uncertainties and hazards associated with a company’s facilities, included emergency response strategies and tactical decision-making processes can empower responders to react expeditiously and potentially limit damage to buildings. Through coordinated efforts, local responders can enter into an emergency situation conscious of existing factors and minimize unnecessary risk, while giving the responders every possible advantage in responding effectively to a fire. 

Site-specific information is the foundation of an effective fire pre plan. Fire pre plans generally include information that will be used by decision makers at the incident. The following key fire pre plan components should be common to most fire pre plans: The plan must:

  • Be in writing
  • List major site hazards
  • Include a plot plan
  • Have current information

Establishing company-wide pre-plan templates ensures information is recorded in a uniform manner. However, pre plans are only effective if accurate and pertinent information is included. Depending on the company’s operations, pre-plan templates can range from the simple to complex. Below is a compilation of insightful fire pre plan helpful hints from various first responders and fire departments:

  • Update plans and communicate with external responders and fire departments often! Include status updates of new buildings construction and renovations being performed.
  • Implement a means of easily accessible pre plan storage and retrieval.
  • Make forms easy to read! Responders may be reading these plans at night, in periods of limited light, and in inclement weather. The easier to read, the better it is for all responders.
  • Separate large complexes into color-coded quadrants. Response strategies can be developed for each quadrant, making it much easier to respond to fires in large complexes.
  • Update external responders on perimeter gate entry codes whenever changes are made.
  • Identify location of alarm panel locations, key box locations.
  • Specify location and identity of stored hazardous materials
  • Coordinate response exercises with fire department training drills
  • Implement lessons learned and new firefighting tactics into response plans

Responders continually verify the importance for fire pre plan simplicity, clarity and accuracy. From the initial information-gathering phase to a pre plan application during the response; crucial response information must be communicated effectively. Despite the response situation or circumstances, a fire pre plan form should include, but is not limited to the following:

  • Building/site layout information
  • Fire suppression information
  • Hazards locations
  • Utility information
  • Exposure information
  • Water supply
  • Evacuation needs
  • Occupancy information
  • Special procedures for handling, storage and control of items that have been identified as major fire hazards
  • Mutual aid resources
  • Strategies

Companies with numerous locations and/or vast corporate complexes can greatly benefit from web-based fire pre planning, Responders can utilize mobile devices to search fire pre plan for specific data within seconds, access web cams for real time information, and/or download planning information for future reference. Companies that strive to maintain a large amount of pre planning information, , and struggle with consistency and secured plan accessibility should consider web-based technology.

For a free fire pre plan guide, click the image below:

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Fire Pre Plans, Emergency Response, Fire Preparedness, Workplace Safety

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

National Incident Management System: 15-Question Quiz to test your knowledge!

Posted on Mon, Dec 09, 2013

The National Incident Management System (NIMS) is the consistent emergency management structure that has been adopted by countless companies to create a more effective, coordinated emergency response. According to FEMA, NIMS provides “a consistent nationwide template to enable Federal, State, tribal, and local governments, the private sector, and nongovernmental organizations to work together to prepare for, prevent, respond to, and recover from domestic incidents, regardless of cause, size, or complexity, including acts of catastrophic terrorism.”

With properly trained employees, many emergency situations can be handled on-site without external responders. However, if an emergency has the potential to exceed the scope of employee training, a unified incident management approach enables multiple entities to respond with one accepted management system. Adopting NIMS facilitates the ability for internal and external responders to collaborate through common operating principles, terminology, and organizational processes to improve response interoperability. The goal, and typical result of NIMS, is a coordinated, faster, and more effective resolution.

Company emergency preparedness personnel, as well as any emergency responders or teams (fire brigade/EMS), can adopt NIMS training programs. The Department of Homeland Security has developed Frequently Asked Questions regarding NIMS.  Below is a sampling of those questions in quiz form to determine your NIMS proficiency.

1. Which is NOT a component of NIMS?
a. Preparedness
b. Communications and Information Management
c. Response Plan
d. Command and Management  

2. Without ICS in place, which of the following often exists?
a. A lack of accountability
b. Poor communication
c. Neither a nor b
d. Both a and b  

3. Which factor encourages jurisdictions to implement NIMS:
a. Federal funding eligibility
b. Pension eligibility
c. Tax exemptions
d. Training exemptions  

4. Which of the following is NOT one of the three primary components of national incident response?
a. NIMS
b. EOP
c. ICS
d. NRF  

5. Which of the following describes NIMS?
a. A set of preparedness concepts and principles for all hazards
b. A response plan
c. Specific to certain emergency management/incident response personnel
d. Reserved for large-scale emergencies  

6. Which is NOT one of the three primary implications of the evolving nature of the NIMS, implementation, and compliance?
a. Dedicated resources must for NIMS implementation must be retained on an ongoing basis
b. A new incident commander must be named at the beginning of each fiscal year
c. Compliance demands implementation on prior activities even when new regulations are put forth
d. From year to year, structures and processes that jurisdictions have implemented may change, or even be eliminated

7. Which of the following FEMA directors was the first to have had prior emergency management experience? 

a. John Macy
b. Louis Guiffrida
c. General Julius Becton
d. James Lee Witt  

8. ICS is designed to
a. Meet the needs of incidents of any kind or size.
b. Provide a site-specific response plan
c. Provide logistical and administrative support to operational staff
d. Both A and C
e. Both A and B  

9. True or False - Private industry must comply with NIMS requirements in order to receive federal tax incentives.
a. True
b. False  

10. Which of the following is an ICS concept states that personnel report to only one supervisor, and maintain formal communication relationships only with that supervisor.
a. Unity of Command
b. Unified Command System
c. Singular Command Structure
d. Mono-command

11. State governments also maintain mutual aid contracts with other states, called:
a. Emergency Management Assistance Compacts (EMACs)
b. Collaborative Support Systems (CSSs) 
c. Intrastate Emergency Management Contracts (IEMCs)
d. None of the above  

12. According to NIMS, all functions of response and recovery are dependent upon ____________ and ___________.
a. Logistics and budget
b. Public perception and reputation
c. Communication and coordination
d. Stakeholder input and stock valuation  

13.  Transfer of Command occurs when:
a. A more qualified person assumes command
b. There is normal turnover of personnel on extended incidents
c. The incident response is concluded and responsibility can be transferred to the home agency, company or, facility
d. All of the above  

14. The Secretary of Homeland Security, through the ________________, publishes the standards, guidelines, and compliance protocols for determining whether a Federal, State, tribal, or local government has implemented NIMS.
a. National Intelligence Council (NIC)
b. National Integration Center (NIC)
c. Incident Command System (ICS)
d. Implementation Coordination System (ICS)  

15. Which is NOT one of the seven strategies for emergency operations
a. Mobility
b. Rescue
c. Ventilation
d. Containment

ANSWERS
1). c
2). d
3). a
4). b
5). a
6). b
7). d
8). d
9). b
10). a
11). a
12). c
13). d
14). b
15). a

For a free download on how to conduct an effective emergency exercise, click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: DHS, Incident Management, Training and Exercises, Department of Homeland Security, Workplace Safety, NIMS

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

The EOP: Adapting a Comprehensive Corporate Response Plan

Posted on Mon, Oct 28, 2013

Comprehensive response planning is quintessential for budget-minded, dynamic business environments. Corporate expansion and site consolidations, along with varying hazards, response procedures, and personnel are a continually fluctuating element of business. Ensuring compliance and promoting streamlined, company protocols through a comprehensive emergency operations plan (EOP) provides facilities with a solid preparedness foundation. Comprehensive EOPs should be consistent with t the National Response Framework, a collaborative system “built upon scalable, flexible, and adaptable coordinating structures to align key roles and responsibilities.”

However, site-specific details and response activities must be integrated into an EOP. To enhance site level preparedness, site managers should invoke cooperative efforts with local emergency management, planning, and response groups. When companies apply manageable frameworks, technologies, processes, and procedures, individual sites can develop, modify, and implement a multi-hazard emergency management program to effectively respond to an on-site incident, while remaining aligned with corporate HSE policies.

The purpose of an EOP is to ensure an efficient, coordinated, effective response to minimize an incident’s impact on people, infrastructure, and the environment. An EOP encapsulates hazard identification, preparedness, response, and recovery. The following are core operational considerations of emergency management that need to be included in an EOP:

1. Leadership: Site leadership, or a qualified individual, should be in charge in an emergency. The response protocols should include a system for leadership to manage resources, analyze information, and make decisions in an emergency situation. Industrial facilities with specialized hazards may possess their own fire team, emergency medical technicians, and/or hazardous materials team. Smaller companies or facilities may need to rely on mutual aid agreements for response assistance. Leadership may need to consolidate response positions and combine responsibilities. Tenants of office buildings or industrial parks may be part of an emergency management program for the entire facility.

2. Communications: Communications are essential to any emergency response operation. The ability to diversely communicate information within a context understandable to responders and the affected community allows managers to successfully navigate through a disaster, potentially minimizing the effects of the hazardous situation. Site leadership should ensure employees are aware of communications methods and equipment, 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.

3. Employee Safety: Every effort should be made to include processes and procedures for the most likely and applicable emergency scenarios relevant to your operations. Additionally, training employees on the basic site-specific response actions is fundamental in protecting the health and safety of individuals at the facility. At a minimum, the following safety aspects should be evaluated and included in a comprehensive response plan:

  • Evacuation planning
  • Evacuation routes and exits
  • Assembly areas and accountability
  • Shelter
  • Training and information

4. Property Protection: The ability to identify and quantify critical infrastructure functions that, when not functional, may hinder the ability to operate, is a critical stage in emergency operation planning. Minimizing infrastructural effects, limiting environmental impacts, and maximizing safety is essential to restoring operations and can allow for a more viable company in the aftermath of an incident.  

  • Planning considerations
  • Protection systems
  • Mitigation opportunities
  • Facility shutdown
  • Records preservation
  • Protecting vital records

5. Community Involvement: Site leadership should maintain a dialogue with community leaders, first responders, government agencies, community organizations and utilities, and the media in order to consolidate response efforts. Your relationship with the community may influence the ability to protect personnel and property. By actively participating in these partnerships, companies can improve their capabilities in emergency management by sharing best practices and joint training. Partnering opportunities may include:

  • Mutual Aid Agreements
  • Public Information
  • Media Relations

6. Recovery and Restoration: Business recovery and restoration directly affects a company's bottom line. The quicker the incident is resolved, the faster operations can resume. Leadership should identify critical operations and prioritize plans for bringing those systems back on-line. Consider making contractual arrangements with vendors for such post-emergency services as:

  • Records preservation
  • Equipment repair
  • Earthmoving
  • Engineering reviews

7. Administration and Logistics: Maintain complete and accurate records at all times to ensure a more efficient emergency response and recovery. Certain records may also be required by regulatory agencies, insurance carriers, or may prove invaluable in the case of legal action after an incident.

For tips on conducting effective emergency response exercises, click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: Emergency Preparedness, Response Plans, Crisis Management, Emergency Management Program, Workplace Safety

Global EHS Response Planning, Preparedness, and Challenges

Posted on Thu, Aug 22, 2013

As companies expand operations and become more global, applicable location-specific threats and risks must be identified and incorporated into preparedness measures. Enterprise expansion requires environmental, health, and safety (EHS) managers and corporate regulatory teams to sharpen their global understanding of regulations, security needs, and associated components of emergency response plans and strategies specific to location of operations.

Whether a facility is domestically located or abroad, ensuring compliance and employee safety requires a streamlined, coordinated, and exercised response plan. All response plans within the corporate enterprise should address site-specific facility details, appropriate response processes, standardized company-wide best practices, and should maintain compliance with local, state, and federal regulations.

A poorly managed and inadequate response, whether an emergency on non-emergency incident, can negatively affect a company’s reputation, business interests, and relationship with key regulators, partners, and local entities. However, global branches outside headquarters’ domain may present additional preparedness and response challenges. Cultural differences, infrastructure challenges, or security priorities may heighten preparedness priorities and planning efforts. As a result, a multinational company may be particularly vulnerable to crisis or emergency response situations.

High-level crisis management responses may stem from either emergency or non-emergency situations. While necessary emergency responses likely affect the safety and health of employees and/or the facility infrastructure, non-emergency situations can arise that potentially impact company reputation and operational longevity. Response plans should be developed for each potential emergency or non-emergency scenario that could cause significant damage to local operations or company-wide. Crisis management or emergency response planning may incorporate, but is not limited to the following:

Environmental Stewardship: Disparity in international, country, state, county and corporate environmental standards.  Environmental regulations may vary regarding:

  • Facility or site requirements
  • Transportation
  • Hazardous spills
  • Equipment safety
  • Fire-fighting method
  • Gas releases

Natural Disasters: Each geographic location is saddled with specific potential natural threats.

  • Earthquakes
  • Hurricanes/Typhoons,
  • Sand/wind storms
  • Tornados
  • Flooding
  • Tsunami

Employee issues: While every facility must prepare for potential employee issues, global companies must pay specific attention to the following:

  • Cultural differences
  • Language barriers
  • Labor relations challenges
  • Workplace discrimination or harassment
  • Disgruntled workers
  • Health and safety disparagements
Marketing: Global markets and unethical business practices can create non-emergency scenarios resulting in the need for crisis management:
  • Price gouging
  • Supply availability
  • Recalls
  • Deceptive business practices

Security Breach: A security breach can affect multiple aspects of a company, from business continuity to the physical safety of employees.

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

Corporate Governance: Corporate changes can initiate unrest, disrupt operations, and company reputation:

  • Mergers
  • Organizational restructuring
  • Downsizing
  • Facility closings
  • Management successions/promotions
  • Financial reporting integrity

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

  • Supply disruptions
  • Punitive regulations
  • Equipment advancements

Illegal Activity: Faults in humanity may be intensified by location specific conditions, supply and demand, and/or greed. Preparedness measures should include business continuity and crisis management procedure for the following circumstances:

  • Extortion
  • Bribery
  • Fraud
  • Malfeasance
  • Criminal Investigation

Political/Social issues: As companies strive to be profitable, political and social issues can interfere with daily operations. Situations that may affect productivity include, but are not limited to:

  • Human rights
  • Terrorism
  • War
  • Political or social unrest
  • Economic disparity
  • Discrimination

Though preparedness, companies can minimize the effects of costly crisis and emergency situations. 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 prosperity and longevity. Additionally, strategic preparedness and a response focus across global entities can propel international EHS best practices and bolster worldwide economic stability.

To assist in Global EHS crisis management planning, click here for our free download.

TRP Corp - Emergency Response Planning Crisis Management

Tags: Social Unrest, Crisis Management, Facility Management, Emergency Management Program, Security plans, Political Instability, Media and Public Relations, Workplace Safety