What's the Plan?

• By Aaron Michalove
• Sep 01, 2001

Emergency management is the practice of driving the risk of doing business as close to zero as possible. An emergency can strike any time, without warning. The best way to manage an emergency is to plan for it, practice response procedures and take precautions to avoid dangerous situations. When incidents occur, respond to that emergency efficiently and effectively, perform root cause analysis and modify contingency plans, starting the cycle over again. The goal is to respond to an emergency with minimal impact to human health, the environment and company assets (be they public perception, physical assets or dollars from expenses and fines).

Emergency response planning -- contingency planning -- is the first step of the emergency management process. Planning has a ripple effect on a corporation's ability to respond to an emergency. Poor contingency plans lead to ineffective response, which increases the impact of the emergency, and may prevent root cause analysis. However, with effective planning, corporations -- from single site manufacturing operations to global enterprises with round-the-clock activities -- can build and efficiently maintain integrated and consolidated contingency plans. With thorough planning, a company can provide proper training for response personnel, and reduce the time it takes to access critical information and procedures for effective response. Not only is this information vitally important during an emergency, but it also allows for more effective and rapid analysis after the fact, to determine root cause and update planning and training procedures.

Emergency response planning is important to a wide variety of industries, such as energy, utilities, consumer goods, automotive and transportation, petroleum, chemical, pharmaceuticals, forestry and pulp and paper. These industries generate more than 800,000 shipments of hazardous substances per year, with nearly 33,000 reportable releases in 2000.¹ Worksite accidents also cost corporations an estimated $28,000 per injury for the 3.8 million disabling injuries in 1999 and an estimated $1 million for each of the 5,100 tragic deaths that same year.² Effectively managing impact to the environment, human health and associated corporate image is possible when companies use the right tools to plan and manage risks.

If planning is the first step in effectively responding to an emergency, why do many corporations still follow outdated or ineffective emergency response plans? The problem is that contingency plans are often kept in large sets of three ring binders or electronic equivalents. Until recently, the tools available to manage contingency plans have been little more than word processors. The plans can be laborious to update and many environmental health and safety (EHS) professionals simply do not have adequate resources to maintain them on a regular basis. The result is a shelf full of outdated and incomplete contingency plans, which are seldom referenced, even during a response.

Another issue is the number of contingency plans required, especially for companies with facilities distributed globally. Maintaining a single plan without the proper tools can be difficult enough, but many governments around the world also recognize the importance of emergency management and require companies doing business within their borders to comply with one or more regulatory standards. In the United States, there are no fewer than 12 major regulatory standards regarding emergency management. Among the agencies responsible for these standards are:

• U.S. Environmental Protection Agency;
• U.S. Department of Transportation;
• U.S. Coast Guard;
• Occupational Safety and Health Administration; and
• U.S. Department of the Interior.

Until recently, each agency has held strict and individual requirements on the emergency response plans corporations must maintain.

Response plans do not typically outline each party's responsibilities, making it a challenge after an event to alert all the necessary personnel beyond first responders. Corporate legal departments, public relations, even plant managers may not be apprised of an incident until regulatory reporting deadlines have passed, resulting in fines or negative public perception.

Even with a contingency plan for each regulatory agency updated and complete, accessing this information during a response has been historically difficult. These plans are organized by regulation, not by response role. Knowing which regulations apply to a particular incident comes down to an individual EHS professional's expertise.

Ensuring proper data collection is another hurdle for response plans. Just as contingency plans must be updated, data collection forms must be updated to ensure all necessary data for regulatory reporting and internal reporting are collected. Standard forms must sometimes be completed. Many times, departments that need specific information must interview first responders or response supervisors after the fact, when details can become less clear or impossible to acquire.

Generating reports after the data collection is complete can also be a major undertaking. Not only are outside agencies involved, but depending on the impact of the event, internal departments need specific details. These reports take a great deal of time to complete and, with the low reportable release thresholds, many companies must generate numerous reports each month. For example, in 2000, 86 percent of Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), also known as Superfund, releases were less than 1000 pounds and 95 percent of petroleum releases were less than 1000 gallons.³ The National Response Center's database lists many regulatory filings for spills amounting to tablespoons of transmission fluid or leaking oil. Corporations need a way to quickly and effectively report on such incidents.

Today, software companies have applied technology to enhance all aspects of emergency response planning.

The first issue addressed was plan maintenance. A company's emergency response plans include information specific to the roles and responsibilities of response personnel and outside agencies. If any information changes, the response plans must be quickly and accurately updated. This process previously required hours of flipping through pages to find each reference to the changed information. Now, software systems use databases to store this information, from contact numbers to standard operating procedures (SOPs). Data can be changed in the database one time, and updated seamlessly throughout the contingency plan. Electronic updating not only represents significant savings in labor, but also dramatically increases the accuracy of updates, ensuring valid references to the most up-to-date information possible.

In recent years, the federal government has reduced the number of contingency plans required. In 1996, the National Response Team, in conjunction with the five agencies mentioned earlier, created a new standard, the Integrated Contingency Plan, also referred to as the "One Plan." The plan was created in response to the overhead of maintaining so many similar yet unique response plans and the complexity of responding to emergencies while complying with all of the applicable plans. Today's software systems help companies maintain individual plans or create Integrated Contingency Plans, offering them the flexibility to migrate to plans that are easier to maintain at their own pace.

With plans updated and easily managed, the issue of response looms. During an emergency, no software replaces the training and instincts of the first responders. But during the discovery stages, new response software can automatically alert responsible parties to an incident by e-mail or pager, based upon the response plan. System generated alerts ensure timely notification of all parties according to the plan.

Once responders are alerted to an incident, software helps them determine when they have completed their responsibilities. Software now supplements training by assigning response roles to sections of emergency response plans and then assigning personnel to those roles. When individuals log into the system during a response, the system recognizes their roles and that a response is in progress. The system then compiles and presents the procedures applicable to their specific roles for the incident. This functionality eliminates searching through binders for the procedures, and ensures no procedures are overlooked. Software that supplements training is invaluable during a response, when the tensions of responding to an emergency can cause personnel to forget procedures that are normally second nature.

Software also associates data collection forms for regulatory reporting or internal purposes, such as root cause analysis to response roles in the emergency response plan. The forms are then presented online to the appropriate personnel during a response. This ensures that the response is not completed until all the needed information has been collected and entered into the system.

Lastly, software today allows corporations to predefine reports so that when an incident occurs, the data is not only collected, but automatically populates incident reports or custom management reports. The result is that these reports are instantly available, without the use of extra labor to generate them, leading to more timely regulatory reporting and internal analysis.

Emergency response planning is the first step to a complete emergency management program. Today's software simplifies plan maintenance, because it centralizes data, follows new regulatory One Plan guidance, alerts personnel to response tasks, generates response procedures based on response roles, collects data in standardized forms and generates reports automatically. The result is a more efficient system for managing contingency planning and response, leading to a safer company and a more protected environment.