Planning For Things You Hope Never Happen
Planning for Things You Hope Never HappenI recently had a phone call from a friend and former colleague in which she described to me a harrowing weekend she had just spent managing a release to air of a chemical vapor at the facility where she is the EHS manager.
Her story brought back to me my own memories of addressing a release to atmosphere that occurred at one of my former employers' manufacturing facilities.
While in both cases we were able to respond effectively and either minimize or quickly remediate the effect on the surrounding community we agreed there were lessons to be learned. Both our organizations recognized activities we had undertaken prior to the events that were helpful as well as some we wish we had taken but hadn't.
Regardless of its exact nature, experiencing an incident that goes beyond the bounds of the facility and into the surrounding community is the stuff of bad dreams for EHS professionals. It is not something that most will experience. However, if you do every weakness in your Incident Response System will be exposed. Each of those weaknesses will become an opportunity for the incident, you find your self managing, to spin out of control.
Here are some tips on things to have in place prior to and things to do immediately during an incident that will help you get through those moments.
An EHS Incident Command StructureAn Incident Command Structure is the first component of an Incident Command System (ICS)/Unified Command (UC). Federal, regional and local response agencies as well as private response companies are all trained in the basics of ICS/UC. The structure they establish while responding to an incident involving your facility will follow the standard and mirror yours if you have followed the standard as well. OSHA offers an on line e-tool at http://www.osha.gov/SLTC/etools/ics/index.html to assist organizations in developing an ICS/UC. The structure proposed here is addresses the structure adopted by the HAZWOPER (29 CFR 1910.120) regulations.
A typical Incident Command Structure for a facility or corporation might look like this:
EHS Incident Command Structure
Each team member should be aware of their role, how it best fits into the Response Plan. Additionally, they should be aware of the overall Response Plan and the roles and responsibilities beyond theirs. The structure should have some redundancy built into it so absences can be covered.
The Incident Command Structure should be tailored if necessary to correspond to the size of the facility, the nature of its operations and the availability of staffing resources. If your facility does not have adequate resources for each role you might consider assigning the responsibility of multiple roles to a single person.
An External Communication PlanIf you have set up an incident response plan and have an Information Officer there may be a feeling that is sufficient. However, it is critical that everyone in an organization understands how communications involving an incident are to be handled.
The outside responders will need to be clear on who coordinates with them and gives them information, typically the Liaison Officer not the Information Officer. It may be helpful depending on the size and magnitude of the incident to provide external support for the Information Officer from companies trained in media response and management. Additionally, there may be a need to have counsel internal and/or external involved in preparing communications to regulatory agencies, media, the community etc.
People should be trained prior to an incident occurring on what they should say. This statement will be dependent on the image your company wants to convey. Generally it is desirable to demonstrate that you are:
- Knowledgeable and in control of the situation
- Being open and honest
Coordination with Local Public Sector Response OrganizationsIf invited most local responders (particularly the local fire department) are willing to visit with you and review your facility operations. This allows them a chance to understand the conditions and type of materials they are likely to encounter during a response. It also gives you an opportunity to review with them any special considerations caused by the nature of the chemicals in use at the facility.
A Contracted Private Response Service ProviderThe time to understand the capabilities of your contracted first responder company is before you have the incident. It is important to know that they can actually respond to the range of incidents you might have. Every time I have found the contracted response company cannot respond to the range of incidents that might happen I have been in the midst of the incident. Post incident reviews determined that the facility personnel hadn't anticipated ever having the type incident that occurred.
I personally recommend periodically reviewing and if necessary revising the contract terms with the selected responder. Contracts, even ones with automatic renewal clauses can get out of date. Company mergers and acquisitions can also cloud contractual documents.
Access to Material Safety DataIf the only copies of your MSDS and vendor provided safety data and chemical inventory service information are in a section of building you cannot access because of the emergency your ability to respond safely will be compromised. This is also true if everything is electronic and there is no power available at your site.
Consider a number of alternatives including:
- Contracting with a company for offsite electronic storage of this information.
- Put a copy in a secure location on the outside of the facility.
- Provide a copy (paper or electronic) to your local first responders and/or your contracted response company.
- Give members of the incident response team a copy on a removable drive or “thumb drive” that they keep offsite.
Build a Strong Relationship with the CommunityDuring an incident that has gone beyond the bounds of your facility into the community it is helpful that the community have previous experience with your company as a positive community member. A demonstrated belief that a corporation views the community as important and sees itself as part of the community is very helpful. When a good relationship already exists the community is likely to come together to be supportive of the corporation when the facility is in "crises".
Practice Responses and Keep the Response Plan CurrentOften though the response plan is created it is not studied and there are generally no drills conducted and the plan is distributed and placed on a shelf. Too often when I have audited plans I have discovered that contact information is not current or that people no longer with the company are assigned roles on the response team.
If at all feasible it is advisable to run through a few response drills. If this isn't feasible then bringing the team together for desktop drills in which your team responds to a number of written scenarios will help keep everyone's roles fresh in their minds as well as identify weaknesses in the system.
Keeping the Response Plan current should be an included step in your facility's management of change process. In addition there should be a mechanism in place to insure that only the latest final versions are in circulation.