Internal Audit

An internal audit identified that a company’s EHS program:

  • Did not meet the minimum corporate standards for emergency preparedness
  • Did not meet regulatory requirements at numerous facilities

The EPA demanded certain issues and deficiencies be addressed or fines would be assessed. Additionally, if EHS program issues were not mitigated, the company was at increased risk for personnel safety issues, damage to company and neighboring property, negative public perception, and lawsuits. In keeping with its emphasis on compliance and safety, company management deemed corrective measures a high priority. Specific findings were as follows:

  • Several personnel listed in plans were no longer with the company
  • Several personnel no longer had responsibilities in the plan
  • Contact information was not accurate for company personnel and external resources
  • Offsite oil spill response procedures were not detailed enough
  • Lack of specific tank fire pre-plans and foam calculations
  • Lack of personnel training or documentation of training records
  • Inconsistencies with Area Contingency Plans
  • Differing plan formats

No efficient process for implementing lessons learned or changes in policies on a corporate basis. The company was unsure if the plans covered all of their operations, which plans were approved, and even if these plans were the latest versions. TRP has considerable experience with just this scenario, and is exactly the reason we developed the SMARTPLAN™ Software System.



Below are scenarios that TRP has experienced: 

Scenario 1:  A non-TRP client acquired properties from a company who already utilized TRP’s Web-Based system for all their plans. TRP worked with the new client to:

  • Re-brand the previous plans to align with the acquiring company’s specifications
  • Incorporate new plans for 33 facilities within 60 days. 

After less than one year of using the system, the company elected for TRP to incorporate all of their plan types into our system.

Scenario 2:  An existing TRP client acquired a large number of new properties. TRP worked with the current client to:
  • Add all new plans for the acquired properties to the system utilizing their templates already established.
  • Identify and address gaps in these plans that were needed to meet regulatory requirements

Since the client had customized template formats already in place, the process of adding the acquired properties was swift and straightforward.

Scenario 3:  A non-TRP client acquired a number of properties, resulting in a much larger operation. Plans from current and previous acquisitions were in multiple formats and varying levels of regulatory compliance. TRP worked with the new client to:

  • Streamline plan formats for enterprise-wide consistency
  • Identify gaps needed to meet regulatory requirements
  • Develop company plan standards and unify corporate expectations
  • Define response roles and responsibilities
  • Identify site-specific infrastructure and security challenges, and response equipment availability
  • Develop training expectations
  • Incorporate all plans into the SMARTPLAN™ system

Acquiring one or more new facilities typically present challenges that are complicated by generic or static response plan templates. Failure to incorporate site-specific details may result in incomplete, ineffective, and costly non-compliant plans.

Corporate Reorganization

A major reorganization required a non-TRP client to significantly revise all of their plans. TRP worked with the new client to:

  • Define preparedness objectives to eliminate ambiguity and confusion
  • Establish customized, enterprise-wide plan formats for standardization and site-specific applicability
  • Identify applicable site-specific regulatory compliance needs
  • Define response roles and responsibilities
  • Establish updated training and exercise parameters
  • Initiate a process for identifying lessons learned, policy revisions, and regulatory requirement changes

Regulatory Changes

A Fortune 500 Company had compliance initiatives following major changes to SPCC Regulations. TRP worked with the new client to:
  • Develop Enterprise Templates in TRP’s Web-Based System to meet new SPCC requirements
  • Develop other templates for SWPPP, RCRA, and other plan types for their operations
  • Populate plans for more than 80 manufacturing plants across the company
Ensuring preparedness, regulatory compliance, and employee safety requires a committed emergency management staff and a fundamental emergency management program with streamlined, coordinated, and exercised response plans. With over 20 years of planning expertise, TRP understands the intricate challenges associated with Response Planning.