Environment / Food Safety / Quality / Safety
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The most effective way to respond to an emergency is to properly plan for it before it happens. That’s precisely why so many federal, state, and municipal laws and regulations require many facilities to develop and implement some sort of Emergency Response Plan (ERP).
Effective Emergency Response
An ERP is intended to outline the steps an organization needs to take in an emergency—and after—to protect workers’ health and safety, the environment, the surrounding community, and the business itself. The requirements developed by various agencies are important, as they establish the components that must be included in an ERP to comply with regulations and respond effectively.
Most ERPs contain the same basic information. However, it can get complicated when a facility is subject to more than one regulation requiring an ERP, because even though the various regulations share many similarities, they also contain important differences (e.g., command structures, training requirements, equipment needs, operating protocols). Often, facilities end up creating a different ERP to respond to the different regulatory requirements. In an actual emergency, this can create inconsistencies or, worse yet, an implementation nightmare trying to figure out which ERP to follow.
Importance of Integration
The solution lies in integration. For example, consider an integrated management system that allows organizations to align standards, find common management system components (e.g., terminology, policies, objectives, processes, resources), and add measurable and recognizable business value. The same can be done with the various ERPs required within a facility.
It shouldn’t come as a surprise that in 1996, the U.S. National Response Team (NRT) published initial guidance for consolidating multiple ERPs into one core document. The Integrated Contingency Plan (ICP or One Plan) is a single, unified ERP intended to help organizations comply with the various emergency response requirements of the Environmental Protection Agency (EPA), U.S. Coast Guard, Occupational Safety and Health Administration (OSHA), Department of Transportation (DOT), and Department of Interior (DOI). The ICP Guidance does not change any of the existing requirements of the regulations it covers; rather, it provides a format for consolidating, organizing, and presenting the required emergency response information.
While the ICP does not currently incorporate all federal regulations addressing emergency response, it does establish a basic framework for organizations to pull in ERPs for any applicable regulations. And the benefits of doing so are many:
- Streamlined planning process. A single document simplifies the planning, development, and maintenance process. When plans are integrated, it minimizes duplication of effort, eliminates discrepancies and inconsistencies, and helps the organization identify and fill in gaps.
- Improved emergency response. It is much easier—and faster—for emergency responders and employees to navigate one plan rather than multiple separate ones. One plan allows for a single command structure with defined roles rather than potentially conflicting responsibilities. This all allows responders to act quickly and decisively to minimize potential disruption to the organization and public.
- Greater compliance. An integrated ERP provides improved visibility to all parts of the organization’s emergency response and helps reveal gaps that could prove costly and/or dangerous. This is especially important for organizations that must comply with several regulations.
- Potential cost savings. Streamlined and simplified planning reduces the resources required to build the plan. An integrated ERP may also help eliminate regulatory fines and minimize the need for and associated costs of emergency response/cleanup efforts.
Find Your Format
The goal of an integrated ERP is not to create new requirements but to consolidate existing concepts into a single functional plan structure. Regardless of what the plan looks like, it should start with:
- An assessment of the facility’s vulnerabilities to various emergency situations.
- An understanding of the various applicable emergency planning laws and regulations to determine which specific requirements must be incorporated. For example, food emergency response has different implications that must be integrated, particularly when it comes to recovery. A food production facility that is ordered or otherwise required to cease operations during an emergency may not reopen until authorization has been granted by the regulatory authority. Food facilities also have strict guidelines to follow for salvaging, reconditioning, and/or discarding product.
With this understanding, the ERP should then comprise step-by-step guidelines for addressing the most significant emergency situations. The core plan should be straightforward and concise and outline fundamental response procedures. More detailed information can be included in the annex. Most ERPs should include the following basic elements:
- Facility information. Consolidate common elements required in various plans, including site description, statement of purpose, scope, drawings, maps, roster of emergency response personnel, emergency response equipment, key contacts for plan development and maintenance, etc.
- Steps to initiate, conduct, and terminate a response. Outline essential response actions and notification procedures, with references to the annex for more detailed information. Provide concise and specific information that is time-critical in the earliest stages of the response and a framework to guide responders through key steps to deliver an effective response.
- Designated emergency responders. Develop a single command structure for all types of emergencies. Assign qualified, high-level individuals who are familiar with emergency procedures to fill emergency roles. In addition, list the appropriate authorities for specific emergencies, as well as their contact information.
- Evacuation plan/routes and rally points. Clearly mark evacuation routes and identify rally points where employees should meet upon exiting. Do not allow employees to leave designated rally points until it has been documented they have safely left the building.
- Data and information backup technology. Develop provisions for data backup to secondary/off-site systems, as well as alternate options for communications and power.
- Designated plan for communication. Outline who is communicating what, when they are communicating it, and how it is being communicated. This includes internal communication, as well as communication to customers/clients/suppliers/vendors that may be impacted, the media, and the appropriate regulatory authorities.
- Supporting materials. The annex should provide detailed support information based on the procedures outlined in the core plan and required regulatory compliance documentation. Importantly, facilities should create a table that cross-references individual regulatory requirements with the plan to ensure there are no gaps and to demonstrate compliance.
The goal of emergency response planning is to minimize impacts to the environment and workers’ health and safety, as well as disruptions to operations. An integrated ERP has the potential to significantly reduce the number of decisions required to respond in an emergency, eliminate confusion and disagreement regarding roles and responsibilities, and enable a timelier, more coordinated response.
That all being said, an integrated ERP will only be effective if it is thoroughly and consistently communicated to all employees. These best practices will help ensure that the integrated ERP functions not only on paper, but also in practice:
- Periodic training is vital to ensure employees understand the ERP and are fully aware of emergency response procedures. It is especially important in an integrated ERP that first responders are trained to handle all potential emergencies rather than more narrowly trained on response for a single regulation.
- Routine drills significantly improve understanding of the ERP, clarify employee roles, test procedures to ensure they work, and diminish confusion during an emergency.
- Posting an abbreviated version of the ERP throughout the plant provides easy access to all employees if an emergency occurs. This summary version of the ERP should highlight the most vital information for quick response: recognized hazards, high-level emergency procedures, evacuation routes, and key contacts.