In case of emergency

• By Ellen Moyer
• Sep 01, 2000

Emergencies, by definition, occur suddenly and without warning. Seldom however, are they completely unforeseen. Many of us recognize the potential hazards associated with chemical transportation, storage and usage, as well as with natural hazards such as earthquakes, floods and tornadoes. The recognition of these potential hazards allows us the opportunity to design effective mitigation and response plans to help counter the impacts of these hazards.

Dealing with disaster

Planning is one of the most important phases of emergency management. The purpose of planning is to document the specific actions to be taken when an emergency event occurs. Planning is designed to reduce the uncertainty associated with potential emergencies. It facilitates understanding of the response process, helps to improve coordination and operations and helps to establish guidance for the monitoring of the effectiveness of the operation. All of this results in reducing the adverse impact of an emergency

Despite its importance, the planning stage is often overlooked or minimized. Budgetary and time constraints are the usual culprits. Planning is often seen as a distraction from "core" operations and therefore simply not done. The subsequent effects of this non-action are magnified when a disaster does strike. The simple act of traveling is used to illustrate the point. How many of us pay full attention to the briefing by flight attendants regarding the location of emergency exits? How many of us actually count the number of rows to that exit? What about in a hotel — do we routinely identify where the fire stairs are located in reference to our room? Although we acknowledge the existence of hazards and the potential for disaster, we fail to adequately plan for that possibility.

A basic emergency
response plan outline

General information Emergency operations plan Initial action plan Safety actions Follow up actions Notification protocols Internal External Regulatory Risk evaluation Hazard identification and quantification Vulnerability analysis Priority ranking Resource evaluation Capability assessment Additional resource needs

Organization Incident command system (ICS) Emergency operations center (EOC) Communications Information management Training Maintenance 1.1 ANNEXES: Hazard specific procedures Worst-case scenario 1.2 APPENDICES: Supporting information Diagrams, charts and maps References

Regulatory requirements

As with many aspects related to the health and welfare of the public, there are regulations regarding emergency planning and the associated documentation. A few of these regulations have come on the heels of some notable disasters, such as the incident that occurred in 1984 when the Union Carbide plant in Bhopal, India, had an accidental release of methyl isocyanate, which caused the deaths of more than 2,000 people and adverse health effects in more than 170,000 others. The Bhopal incident galvanized U.S. citizens' groups to lobby for greater protection of the public from chemical emergencies. Consequently, the Emergency Planning and Community Right-to-Know Act (EPCRA) was enacted in 1986.

Another example is the Oil Pollution Act of 1990 (OPA '90) that was enacted after the Exxon Valdez incident. The 1989 accident spilled more than 11 million gallons of oil off the Alaskan coastline. The costs incurred by Exxon were staggering: $2.8 billion in cleanup costs, third party claims totaling approximately $5 billion and more than $900 million in compensation to government agencies for damaging Alaska's wildlife and other natural resources.

Some of the required plans are more preventative in scope, such as Spill Prevention, Control and Countermeasure (SPCC) and stormwater plans, while others are targeted more towards contingency and response (i.e. facility and pipeline response plans). Collectively they are all considered "preparedness" plans.

With a multitude of prevention and response plans required for most facilities, it has become burdensome and expensive for owner/operators to develop and maintain all of the federal and state mandated plans. In 1996, the U.S. National Response Team — composed of members from the U.S. Environmental Protection Agency (EPA), U.S. Coast Guard, U.S. Occupational Safety and Health Administration (OSHA), U.S. Department of Transportation (DOT) Office of Pipeline Safety and the Department of Interior (DOI) Minerals Management Service — published a guidance document for the Integrated Contingency Plan (ICP) concept, also know as the "One Plan" to address some of the federal requirements. The ICP is not a required regulatory plan, but rather a suggested alternative, designed to consolidate and simplify the required contingency and response plans for a facility. The ICP is cross-referenced to facilitate the coordination of specific parts that are applicable to sections of each of the required plans.

Steps of preparation

Regardless of the exact type of preparedness plan required, there are a few general phases common throughout the planning process.

Plan development. In the plan development phase, you must first determine exact needs. From an emergency management point of view, this requires a hazard assessment. The hazard assessment helps to identify the potential hazards, the probability of their occurrence and the degree of impact to the exposure or asset. The latter two issues are part of the vulnerability analysis that assists in quantifying the potential loss. After these parameters are determined, the next step is a capability assessment in order to determine if the resources available are sufficient to handle a worst-case scenario. If they aren't, then there is a need to find the appropriate resources and to make they are available for at the time of an emergency.

Once these steps have been taken, it is time to write the plan. This is the documentation phase of the planning process. It is highly recommended that various people who are familiar with various sections of the plan be given the opportunity to either write the appropriate sections or given a chance to edit them.

Plans covered under the ICP:

Agency	Regulation)	Required plan
EPA - OPA '90	40 CFR 112.20 & .21	Facility response plans
EPA - Clean Water Act	40 CFR 112.1 - .7	SPCC plans
EPA - Clean Air Act	40 CFR 68	Risk management plans
EPA - RCRA	40 CFR 264 & 265	Contingency plans
DOT Office of pipeline safety	49 CFR 194	Facility response plans
U.S. Coast Guard	39 CFR 154	Facility response plans
DOI Minerals Management Service	30 CFR 250 & 254	Facility response plans
OSHA	29 CFR 1910.38a & 165	Emergency action plans
OSHA	29 CFR 1910.119	Process safety management plans
OSHA	29 CFR 1910.120	Hazwoper

Testing. Once a significant draft of the plan has been written, the testing phase follows. For this phase, it is recommended that a tabletop exercise be performed. The purpose of the exercise is to identify any potential coordination issues such as procedural gaps and/or duplications of effort. Communication during an emergency is critical. Information flow should be smooth and effective. All involved should clearly know what their tasks and responsibilities are. Revisions should be made to the plan to rectify any problems.

Distribution. The fourth phase in the planning process is distribution and orientation. All too often, emergency response plans sit on a shelf and are not looked at once the final version has been completed. Once the plan is finalized it must be distributed to the appropriate individuals and must be reviewed by all parties that will be involved in its execution. It is imperative that the content and context of the plan be understood. Equally important is knowing how to use the plan. This includes being familiar with the format of the plan, particularly where the specific information such as the initial action plan and the notification procedures, is to be found.

Training. Preparedness is an ongoing concern and therefore needs to be addressed on a periodic basis. The fifth phase of the planning process is training. Training includes classroom exercises and drills to continually refresh and familiarize the team with the elements of the plan. The team has a chance to understand each element of the plan, as well as how each element interfaces with the other. Training exercises are great ways to uncover coordination issues, duplications of effort and omissions.

For most regulatory required plans, there is a training and drill component to the plan implementation. A notification exercise is more than just telephone number verifications. Its purpose is to ensure that the key team members and their designees can be reached during an emergency. Tabletop exercises aid in getting the various team members, both internal and external, to familiarize themselves with the plan and to work together. Finally, drills are actual deployment of equipment and personnel. This can be for specific parts of the operation and does not have to be for the entire organization.

For facilities that are regulated under the OPA '90, the National Preparedness for Response Exercise Program (PREP) Guidance is a voluntary program designed to assist companies in complying with the regulatory requirements for mandated periodic testing.

Maintenance. Plans are meant to be dynamic and so a periodic review of various elements in the plan should be an ongoing part of the planning process. This is the maintenance phase. A variety of factors can change with time, including:

• Situational updates. Many times new processes or chemicals have been introduced;
• Personnel updates. Periodic verification of your personnel resources; and
• Capability updates. If you provide for your own emergency response operations, it is very important to determine the state of your equipment, materials, etc. Materials may have been used and not replaced, and equipment needs to be checked and maintained. If you outsource your emergency operations, you need to verify that the contractor has the resources and personnel available.

Evaluation and alteration

Regular reviews of training exercises and drills will enable an emergency manager to evaluate the effectiveness of portions and/or the entire plan. Following such drills and exercises, members of the emergency team should meet and evaluate their performance and the effectiveness of the plan. The planning process is more than just an isolated task to develop a document. It is part of an on-going and dynamic process, designed to enhance preparedness for an entity and to reduce the adverse impacts to that entity in the event of an emergency

e-sources

U.S. National Response Team — www.nrt.org
U.S. Environmental Protection Agency Superfund Division — www.epa.gov/superfund
U.S. Department of Transportation — www.dot.gov
Natural Hazards Center at the University of Boulder — www.colorado.edu/hazards
Pacific Emergency Management Center — www.cyberg8t.com/simeon
Chemtrec Hazmat Emergency Communication Center — www.cmahq.com/chemtrec.nsf
Emergency Net News — www.emergency.com

This article appeared in Environmental Protection, Volume 11, Number 9, September 2000, Page 36.

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This article originally appeared in the 09/01/2000 issue of Environmental Protection.