Module 3: Basics of Emergency Response, Contingency, and Recovery Plans
In this module, we introduce the mechanics of constructing a contingency plan with all of its elements, including the emergency response and recovery elements, thus providing a more complete introduction to the national and state emergency management plans than was provided in module 1.
Emergency planning is the generic work of preparing for one or more hazardous events that could harm people, property, the environment, or all of these. Businesses and agencies usually conduct such planning to address the types of emergencies that they think are most likely to occur, such as terrorist attacks, fires on business or agency property, or hackers getting access to the business or agency computer network, Web site, or parts of it.
Some emergency planning efforts address only the actions the emergency responders will take when they respond to an emergency call. A contingency plan, however, encompasses the emergency response plan, the evacuation procedures necessary for those who are not going to be emergency responders, and the recovery procedures to be followed after the emergency is over. A single contingency plan usually addresses all the potential emergency events the business anticipates. It might be organized by chapter for the different emergency events covered in the plan, along with the basic criteria for reporting events, notification of company staff, and other basic parts that would apply across all or most of the planned emergency events.
Two major national emergency management plans address particular types of emergencies to which the federal government is expected to respond by either participating independently or by assisting state governments.
The two plans are
1. the National Oil and Hazardous Substances Pollution Contingency Plan (National Contingency Plan)—operated by the National Response Team
2. the National Response Framework—maintained by the Department of Homeland Security (DHS)
Each of these plans is based on specific laws and Presidential Directives that have been enacted, issued, and amended over the last 20 years or so. These laws address areas where federal governmental resources could be made available to the state and local authorities or brought to bear on a specific type of emergency that concerns federal authorities, such as a terrorist event.
The federal government will, when requested, assist state and local emergency responders and authorities in handling the emergency itself as well as the recovery efforts after the emergency portion of the event is concluded. Federal authorities also can respond to and take control of an emergency scene for some types of emergency events if the on-scene federal official or officials believe the emergency is being handled improperly or if national security is involved.
We will describe each of the two plans below.
National Contingency Plan and National Response Team (NRT)
The National Contingency Plan (NCP) is the short title for the National Oil and Hazardous Substances Pollution Contingency Plan, introduced in module 1, which was established under the Clean Water Act of 1972 and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. The purpose of this plan was to ensure that the resources and expertise of the federal government would be immediately available for those very serious incidents that require a national or regional response. It would also promote overall coordination among the hierarchy of emergency responders and contingency plans.
As we mentioned in module 1, one of two federal regulatory authorities responds to these very serious incidents. The U.S. Coast Guard's (USCG) on-scene coordinators cover all spills on navigable waterways, and the EPA on-scene coordinators respond to hazardous materials spills not handled by the USCG. Because the USCG is part of DHS, it is now the principle cabinet-level agency involved with this federal emergency plan. For additional information on the USCG role, go to its Web site (see the Relevant URLs list in the Additional Information section of the syllabus).
The NRT ensures that the emergency response roles of federal agencies, as overseen by either the USCG for waterborne events or the EPA for all other events under this plan, are defined clearly in the NCP. After very serious incidents involving the federal regional response teams, the NRT carefully evaluates the effectiveness of the response. Using the information and data gathered from the evaluations and assessments, the NRT may make recommendations for improving the NCP or federal regional response plans and procedures.
The NRT also reviews the federal Regional Response Plans and Area Contingency Plans to determine whether they comply with current federal policies on emergency response. For more detailed information on the National Contingency Plan, go to the Code of Federal Regulations in 40 CFR 300.110 through 300.355 to see the key provisions.
Two of the committees under the NCP play major roles regarding emergency planning and training issues and help the NRT perform its work. They are:
1. The NCP Response Committee—Chaired by EPA, this committee addresses federal response operations, technology employment during response operations, operational safety, and interagency facilitation of response issues such as transboundary issues and policy/program coordination and capacity building.
2. The NCP Preparedness Committee—Chaired by the USCG, this committee addresses preparedness training; the monitoring of exercises and drills; and planning guidance, interoperability, and consistency issues. Training is the key federal strategy for preparing for oil spills and hazardous material releases at all levels of emergency response.
Laws such as the Superfund Amendments and Reauthorization Act (SARA) of 1986 further strengthened the role of the National Response Team and the National Contingency Plan. SARA laid the foundation in the Title III Emergency Planning and Community Right-to-Know Act (EPCRA) for placing responsibility for establishing organizations and preparing for emergencies at the state and local government levels through the State Emergency Response Commissions (SERCs) and the Local Emergency Planning Committees (LEPCs). EPCRA was also introduced in module 1.
The Clean Air Act Amendments of 1990 and the Oil Pollution Act of 1990 complemented the work begun under EPCRA. These laws require facilities and ship owners to improve their safety practices and the way businesses manage hazardous material risks. They all must work towards reducing hazardous material spills or releases on land and in waterways. Under these laws, EPA has a major role in regulating facilities, and USCG has a major role in regulating ship owners.
National Response Framework
The National Response Framework (NRF) is administered by DHS, with the Federal Emergency Management Agency (FEMA) as the lead agency for natural disasters covered under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Public Law 93-288, as amended). This act authorizes the federal government to respond to natural disasters and other incidents, and to provide assistance to save lives and protect public health, safety, and property. For additional information on the role of FEMA under the Stafford Act and the NRF, go to the FEMA Web site and search for Stafford Act or NRF Resource Center (see the Relevant URLs list in the Additional Information section of the Syllabus).
The NRF is based on the fundamental assumption that significant disasters will occur that exceed state and local governments' abilities to respond effectively on their own to save lives and protect property. The NRF states that the federal government agencies' resources and expertise will be made available to help states that request such aid during a significant disaster.
Under the NRF, federal departments and agencies having various authorities and resources have been assigned primary and backup responsibilities for various emergency support functions. These departments and agencies have agreed to develop and maintain emergency response planning efforts to establish a coordinated federal response to assist states when requested.
The NRF describes the basic means by which the federal government will mobilize resources and conduct activities to augment state and local government efforts to respond to natural disasters. The NRF also addresses large-scale terrorist events and how the federal government is to interface with state and local law enforcement and response authorities. To facilitate federal assistance, the NRF groups the types of federal assistance a state is most likely to need into 15 emergency support functional areas. Each area is headed by a primary federal agency, based on the agency's responsibilities, resources, and capabilities in that area.
Other federal agencies have been designated as support or backup agencies for one or more of the functional areas based on their resources and capabilities to support the functional area. Federal assistance will be provided to the affected state under the overall direction of a Federal Coordinating Officer (FCO) appointed by the president.
The NRF has five basic components:
1. core document—describes the doctrine that guides the U.S. national response, roles and responsibilities, response actions, response organizations, and planning requirements to have effective federal emergency response to any activity or disaster that occurs
2. emergency support functional annexes—groups federal resources and capabilities into functional areas that are most frequently needed in national response operations; these would include, among others, annexes for transportation, communications, public health and medical services, search and rescue, energy, and public safety and security
3. support annexes—describe the essential supporting areas that are common to all incidents
4. incident annexes—describe the unique aspects of how federal agencies will respond to biological incidents, nuclear/radiological incidents, cyber incidents, and mass evacuations
5. partner guides—provides references describing key roles and actions at each level (local, tribal, state, federal, and private sector)
To activate the NRF during natural disasters, the governor asks the president to declare a major disaster or an emergency for the state, and the president issues a declaration based on the severity and magnitude of the emergency event. The president appoints an FCO, as stated earlier, to coordinate the overall activities under the declaration.
For certain situations, such as a terrorist attack, the president may declare an emergency with or without the governor's request. Under the law, the president may direct the provision of emergency assistance, either at the request of the governor or upon the determination by the president that an emergency exists for which the primary responsibility for response rests with the United States.
The National Incident Management System (NIMS) is a companion document to the NRF. This is discussed in detail in module 4.
Every governor has now appointed a state emergency response commission (SERC), as was mentioned in module 1. Each SERC has the following functions to perform under the EPCRA legislation:
· set up local emergency planning districts and appoint the members to the Local Emergency Planning Committee (LEPC) that is required to develop and implement a local emergency response plan
· supervise and coordinate the activities of the LEPCs within the state
· review the local emergency response plans the LEPCs submit to make sure they meet state and local needs for improved coordination between the LEPCs and adjoining states' planning districts
· along with the LEPC, receive and process required chemical information from affected facilities within the communities
· along with LEPCs, implement the community right-to-know portion of the law by providing information to planning district citizens about the chemicals and chemical hazards in the community (this information comes from the collected chemical information that facilities are required to report to the SERC and LEPC)
The LEPC will be composed of members from the local community and planning district. Thus, local government officials, business leaders, and the leaders of community volunteer organizations will be involved with responding to and helping with emergencies. Local hospital administrators are examples of those expected to participate in the local emergency planning efforts. The LEPC chairperson will be a local community leader.
Most SERC members will be state government officials, but some will be business leaders who, supposedly, have the whole state as a concern. The SERC chairperson will be a state government official. The SERC coordinates its state emergency planning activities with the federal regional response teams in their locale.
Area planning committees are similar to LEPCs except that forming them is a requirement of the Oil Pollution Act of 1990, as mentioned in module 1. Each of these committees is required to develop an area contingency plan for the port area or waterway area under its jurisdiction. For information on area contingency planning, go to the USCG Web site (see the Relevant URLs list in the Additional Information section of the syllabus).
An area planning committee is composed of members from federal agencies such as the USCG, state government officials, local business leaders involved in port or waterway commerce, local government officials, and others. All committee members will have responsibilities for water pollution issues, and the chairperson will be a federal on-scene coordinator from the USCG or EPA.
The territory covered by the area planning committee will be a subregional geographic area that is connected with the commercial activities on the waterway and at the ports. The USCG commandant for coastal zone areas and the EPA administrator for inland zone areas designate these territories, appoint the area committee members, and review and approve area contingency plans and related matters.
There are some regional area planning committees, for example, the one created for the Great Lakes area of the United States and Canada. This regional area planning effort is in addition to the federal regional contingency plan that comprises only federal agencies involved in emergency response to spills and releases of hazardous materials. The area contingency plan that is developed must be coordinated with the appropriate LEPC and SERC plans to ensure there are no conflicts between the plans. (See the Relevant URLs list for this module and for module 1 in the Additional Information section of the syllabus for additional information on area planning committees.)
Targeted emergency response plans are those plans that are required by a specific federal or state regulation. We will address only two of the many examples to help you understand some of the additional rules and regulations that could affect the emergency planning efforts of the environmental management professional. The first targeted emergency response plan we will discuss is found in the Federal Pipeline Safety Regulations, and the second is from the Federal Water Pollution Control Act and the EPA-related regulations.
Federal Pipeline Emergency Plans
The Pipeline and Hazardous Materials Safety Administration in DOT administers, under 49 CFR 192.615, the requirements for emergency plans. Every interstate and intrastate pipeline operator or owner must have an emergency plan, and each operator must establish written procedures to minimize the hazard resulting from a gas pipeline emergency. Among other requirements, these procedures must
· establish and maintain adequate means of communication with appropriate fire, police, and other public officials
· provide for a prompt and effective response to each type of emergency, including gas detected inside or near a building, a fire or explosion near or directly involving a pipeline facility, and a natural disaster
· address the personnel, tools, materials, and equipment that may be needed at the emergency scene
· address actions to protect people first and then property
· address emergency shutdown procedures
· make safe an actual or potential hazard to life and property
· address the provision of copies of the plan to supervisors who are responsible for emergency actions
· provide the appropriate training to operating personnel
· verify that the training is effective
Federal Spill Prevention Control and Countermeasure Plan
The Spill Prevention Control and Countermeasure rule (SPCC) is required by the EPA regulations in 40 CFR 112, and it involves much more than just planning for emergency response. It covers oil of all types, from petroleum products to mineral oil to vegetable oil. The SPCC written plan must be developed by the owner or operator of a facility that has in the past spilled more than 1,000 gallons of oil in an incident; or has had two spill events (each of more than 42 gallons of oil) within the past 12 months that went into navigable waters or adjoining shoreline; or has above-ground oil storage capacity of more than 1,320 gallons of oil or more than 42,000 gallons of completely buried storage of oil, with a possibility of an oil discharge into or upon navigable waters of the United States or adjoining shorelines. The plan must be reviewed and certified by a registered professional engineer.
The SPCC plan must be submitted to the EPA regional administrator and the state agency in charge of water pollution control where the facility is located. A copy of the SPCC plan must be kept onsite for review
The SPCC written plan plan must include
· plan approval, certification of plan, and review
· facility diagram, including topographical maps, description of oil storage and potential discharge descriptions, and descriptions of cause or causes of actual spills
· oil storage containers, secondary containment, facility drainage, and oil spill controls
· inspections, testing, recordkeeping, personnel training, and discharge prevention procedures, including corrective actions and countermeasures to help prevent spills
· site security, emergency procedures, and notifications, including National Response Center (NRC) notification procedure
· SPCC spill reporting to be done within 60 days
· onshore facilities management (owner or operator) controls, including records of repairs or replacements of oil-related equipment
· loading and unloading rack requirements and procedures for tank cars and tank trucks, and other measures
Any amendments to the SPCC plan must also be reviewed and certified by a registered professional engineer. For additional information on SPCC and facility response plans, go to the EPA Region 3 Web site (see the Relevant URLs list in the Additional Information section of the syllabus).
EPA regulations intend that the SPCC plan address in detail the engineering controls and preventive spill systems such as dikes, berms, weirs, spill diversion ponds, and retention ponds. A strong oil-spill contingency plan should be part of the SPCC plan.
A number of lessons have been learned from the tragedies of 9/11/01. Before this infamous date, the approach taken for very tall buildings was to have none of the occupants evacuate a building when an emergency such as a fire occurred on a specific floor. Building designers intended for occupants in the danger or fire zone (the floor where the fire was located as well as the two floors above it and below it) to evacuate this zone but not the building. Those below the lowest floor evacuated for the emergency were to go down and those above the floors being evacuated were to climb up to a safe location. Everyone else in the building would remain where they were unless and until they were told differently. The designers thought that fire sprinklers and fire fighters could handle any problems. Thus, a hundred-story building would not be fully evacuated every time a fire occurred within it. Since 9/11, people are not sure this is the best procedure and are rethinking it.
It was believed that if the building's fire-structural integrity and sprinkler and smoke-control systems were designed properly, they would be sufficient to control the fire and prevent it from spreading. The fire department would clean up whatever small burning areas were left.
It was also thought that elevators should never be used to evacuate ambulatory people from their floors and that everyone should use the available exit stairways within the building to move to the lower floors. We learned from the 1994 bombing of the World Trade Center that it might take hours for all of the occupants to evacuate a very tall building, and so the idea of conducting building-wide fire drills was discouraged.
During the 9/11/01 event, many people on the upper floors of the second World Trade Center tower immediately took the high-speed elevators after the plane hit the first tower. They credit the high-speed elevators for getting them down and out of the second tower quickly before the second tower was hit and immediately afterwards. A number of survivors have said that they would never have made it down the exit stairs in time if that had been the way they were to have evacuated the building.
Many people died in the elevators, however, because once the planes hit the towers, the impact severed many of the upper-floor elevator cables. Although the elevator-car safeties stopped the elevators from falling, the flammable fuel came down the open elevator shafts and destroyed the trapped elevators.
The impacts of the planes into the two towers severed the fire-sprinkler systems and just about everything else. The emergency responders did not think that a tower, once hit by a plane, would actually collapse in on itself as it did. When the first tower collapsed, there was an intense effort to get everyone out of the second tower as quickly as possible. There is now an ongoing debate about the use of elevators for ambulatory persons in emergency evacuation planning for very tall buildings.
The National Institute for Science and Technology (NIST), which is part of the U.S. Department of Commerce, along with many other organizations, has been studying the structural collapse of the Twin Towers. They indicate the steel fireproofing material was not applied uniformly on all of the structural steel members. Gaps in coverage would have allowed the steel to be heated much faster, and it would have lost its strength more quickly than previously thought.
Because of the World Trade Center tragedy, attention is being focused on the whole area of communications. In that unprecedented event, neither the fire department nor the police department was able to communicate effectively by radio with their alarm centers. New York City fire officers had to use their cell phones to get messages back to their fire-alarm center because their portable radios did not work well within the building. When the cell phone lines became overloaded, they were no longer an effective way to communicate among various emergency response organizations. For more information on the New York City Fire Department, go to its Web site (see the Relevant URLs list in the Additional Information section of the syllabus).
The result of this communication failure was poor coordination among the New York City Police Department, the Port Authority Police Department, and the New York City Fire Department. Furthermore, neither tower had been provided with radio communication repeater equipment, although equipment had been provided that would allow cell phones to work throughout both towers. Radio repeaters might have helped emergency personnel to communicate better. An effective communication system is essential for good coordination in an emergency incident.
The emergency planning of all the different levels of government affects how you will develop an effective contingency plan for the lowest level. Any business that is going to develop a contingency plan must understand the authority and role of the different levels of government in emergency planning and must also know which agency the business contingency plan must interface with to make it as effective and practical as possible.
The levels of emergency planning, from the highest to the lowest, are shown below.
international level federal level various regional contingency planning committees state level LEPC and area committees
local government agency facility owners vessel owners vessel operators
The international level involves adjoining countries developing mutual assistance agreements to handle emergencies along their shared borders This will be discussed in more detail in module 6.
This hierarchy of contingency planning requires good coordination between the different levels of government and places a burden on the facility or vessel owner at the lowest level. The facility owner must consider the contingency plans of the local or higher level of government emergency planning that address the area where the facility is located. This will be discussed in more detail in module 5. The owner must develop a facility contingency plan that recognizes the potential impact these government contingency plans will have on the facility's preparedness and emergency response capabilities all the way up the hierarchy, including the federal level, which would include the international treaty obligations along the borders.
A facility owner must do the following three things when creating and implementing a facility contingency plan:
1. determine where there are serious hazards in the facility and the potential for an emergency to develop from each one and analyze the risk for each hazard (see section VII of this module for more details)
2. take the steps necessary to prevent an emergency situation from occurring for each of the noted hazards at the facility
3. develop a hazard-mitigation strategy to protect the facility, its people, and the adjacent environment if and when an emergency results from any of the noted hazards
Chemical Facility Anti-Terrorism Standards
DHS has issued risk-based performance standards for the security of selected chemical facilities that contain specific chemicals at or above the screening threshold quantity in pounds (6 CFR 27, April 2007), as mentioned in module 1. Each of the covered chemical facilities are required to prepare Security Vulnerability Assessments, which identify facility security vulnerabilities and then must develop and implement Site Security Plans. These DHS rules were issued with specific deadlines that facilities must meet. DHS officials are authorized to conduct inspections and audits of the covered facilities.
These DHS standards are to protect human life or health, national security and critical economic assets of the United States. They are targeted to potential terrorist attacks involving chemical facilities that could result in significant adverse consequences. This rule does not cover Department of Defense facilities, Department of Energy facilities, facilities covered by the Nuclear Regulatory Commission, those under the Maritime Transportation Security Act and specific facilities under EPA rules and regulations such as Safe Drinking Water Act, Federal Water Pollution Control Act and others.
Hazard mitigation is the effective use of available resources to minimize the impact of a given natural or man-made hazard. These resources can be obtained and used by households, businesses, communities, and all levels of government. Some resources are used for one specific hazard, and some are used for more than one. An example of a hazard-mitigation resource is a fire truck. A community can buy a fire truck to respond to fire incidents, but it can also be used to respond to hazardous material or transportation crash incidents to carry tools and equipment for clean-up and rescue operations.
Hazard mitigation resources can be grouped into the following categories:
· prediction, forecast, and warning systems
· codes and standards
· engineering resources
· management programs and procedures
· insurance programs
· tools and equipment
We will now discuss these categories.
Prediction, Forecast, and Warning Systems
Predictions and forecasts can be made and warnings can be issued for a number of natural and man-made hazards. Predictions are useful when budgeting funds for internal emergency preparedness and response resources. Historical data and models are the basis for predictions. Based on the historical data regarding chemical spills over the past 10 years, for example, one can predict that X number of chemical spills will occur in 2008. Prediction techniques are available for most natural and man-made hazards except terrorist attacks.
Forecast techniques are used mainly for natural hazards such as earthquakes, floods, hurricanes, and tornadoes. Data obtained from the use of advanced radar, satellite, and seismological systems are input into models to develop long-range forecasts.
The three levels of warning systems are
2. community based
3. facility based
They can be used for most natural and man-made hazards including terrorism. The National Weather Service warning system, which is operated by the National Oceanic and Atmospheric Administration (NOAA), and the Emergency Alert System are examples of national warning systems. They are designed to warn the public of a weather event emergency or other potential catastrophic events. For more information on the National Weather Service warning system, go to the NOAA Web site and click the Weather icon (see the Relevant URLs list in the Additional Information section of the syllabus).
Warnings issued by the National Weather Service for weather-related hazards are examples of regional or community-based warning systems. These warnings are usually broadcast on radio and television for the
Fire alarms are examples of facility-based warning systems. In recent years, they have been designed not only to alert building occupants through the use of bells, flashing lights, and sirens, but also to have voice recordings that inform occupants of proper procedures for evacuating the building or sheltering in place or other helpful information.
Prediction, forecast, and warning systems can save lives and property by alerting people to a potential hazard that could occur within minutes or hours. Some warnings or alerts may also last up to months in duration. Warnings should be issued early enough for people to prepare to protect themselves.
Codes and Standards
Codes and standards can also be used to mitigate most natural and man-made hazards and can be either mandatory or recommended. Codes and standards that have mandatory requirements usually have a legal basis for their requirements. For example, a state adopts a building code so its requirements are legally mandated.
Building codes and standards can also be written to prevent various hazards. The typical building code addresses several hazards related to both natural and man-made causes. For example, a building code can specify both hazardous-material storage requirements and the snow-load criteria for roofs. It can also mandate various fire-protection elements based on the size of the building and the type of occupancy.
Mandatory codes and standards usually indicate the minimum level of protection that a building occupant or owner is expected to meet. A recommended practice has design concepts the design professional can use to provide some level of safety above and beyond the mandatory code requirements. For example, the insurance company that insures a facility may give its clients design guidelines. These guidelines are not mandatory but rather recommended practices.
There are three nationally recognized consensus standards-writing organizations, which also develop guidelines to supplement their standards. They are:
1. The American National Standards Institute (ANSI) in New York City
2. The National Fire Protection Association (NFPA) in Quincy, Massachusetts
3. The American Society for Testing and Materials (ASTM) in Philadelphia
Government agencies sometimes adopt standards documents from these organizations and make them mandatory. These organizations also develop documents that can be used as guidelines for good building practices or other emergency safety practices. An example is the ASTM F 1656 Standard Guide for Health and Safety Training of Oil Spill Responders in the United States. This guide summarizes the course components to be included in training programs for oil-spill response personnel. Its purpose is to assist trainers in developing curricula that address the health and safety risks associated with oil-spill response.
A number of insurance companies also write standards to prevent or mitigate the hazards caused by a variety of natural and man-made events. Because insurance companies pay the costs for an insured event (less the deductible), they have a vested interest in developing guidelines on best practices for hazard mitigation.
Several other organizations write codes and standards to promote safe designs and equipment and machinery maintenance and inspection practices that prevent or mitigate hazards. Below are a few examples of organizations and the codes they develop.
· NFPA develops codes and standards aimed at preventing the loss of life and environmental and property damage caused by fire.
· ANSI develops standards for products, machine processes, and occupational safety subjects. The Occupational Safety and Healthy Administration has adopted ANSI, NFPA and ASTM standards to protect employees from various occupational hazards.
· EPA develops standards to protect the environment from different types of hazards.
· DOT develops standards that protect the various transportation modes and routes from a number of different hazards for public safety and health, as well as to protect transport workers.
Engineering offers another means for mitigating natural and man-made hazards. Two engineering methods that are appropriate for natural hazards are emergency shelters and dams for flood control. Emergency shelters can be built into commercial and other facilities and even homes. For example, an emergency shelter for a tornado might be a room built beneath a house to keep people safe from the effects of damaging winds, whereas an emergency shelter for a hurricane would not be built below ground because of the possibility of flooding. As you can see, emergency shelters should be designed and built for the specific natural or manmade hazard that is common to the region or the facility.
Fire-protection and containment systems are other engineering resources used to mitigate man-made hazards. Fire-protection systems vary based on the type of fuel causing the fire. Below are some examples of such systems.
· Fire sprinkler systems are used for many different fuel hazards. A typical office building is an example of a facility that is protected by a fire sprinkler system.
· Gaseous fire-protection systems using carbon dioxide are appropriate for a flammable or combustible liquid fuel source. One might install such a system in a flammable-liquid storage room.
· Foam fire systems are usually used on fuel-oil storage tanks.
Containment is another engineering method for mitigating hazardous-materials incidents. Three containment methods are summarized below.
1. Dikes are walls made of concrete or other material that are built around liquid-filled tanks or containers to hold the contents, such as oil, in the event of a leak. A dike holds the contents until they are removed to a safe vessel.
2. Double-hull oil tankers are used by the oil industry. If an accident damages the exterior hull, the interior hull will still contain the oil and prevent a spill.
3. Double-wall piping is commonly used in industrial facilities. It is a pipe within a pipe that is often used to transmit hazardous liquids and gases. Should either wall of the piping become damaged or leak, the hazardous liquid or gas will not be released into the area in which the pipe is contained. The pressure contained in both of the void spaces is constantly monitored. Any changes in pressure could indicate a pipe leak.
Management Programs and Procedures
Some management programs and procedures used to mitigate natural and man-made hazards are contingency plans, evacuation plans, fire-protection plans, safety programs, and security procedures. Facility-based evacuation plans can be used either to evacuate occupants from a facility because of a fire or to relocate them to a safe area because of a flood or tornado. Community-based evacuation plans can be used to evacuate people in vehicles from an area that is under a hurricane warning, for example.
Fire-protection plans can be categorized according to the functions of facility personnel.
· Plans for the operations group involve the emergency response team and describe the duties of and resources for emergency responders.
· Plans for the maintenance group address the maintenance, testing, and servicing of the fire-protection systems. A number of mandatory standards require periodic inspection and testing of various fire protection systems to keep them in serviceable condition.
Safety programs are usually categorized according to the job being performed and the hazards involved. Some examples are fleet safety programs, construction safety programs, confined-space entry procedures, hazardous-materials handling and storage procedures, fall-protection programs, and industrial-hygiene programs.
Security procedures have become an important part of facility planning efforts for handling emergencies. Security procedures are used to
· secure an area where emergency response or recovery operations are occurring
· prevent entry by undesirables into a facility
· protect the public from being injured during an ongoing emergency response incident
· protect a facility from terrorism
By preventing emergency events, these procedures help minimize the use of valuable emergency response resources.
Management must ensure the use of appropriate materials storage and handling practices to mitigate hazardous materials-related hazards. Good storage practices are segregation and physical damage protection of the containers. Segregation of incompatible materials is an appropriate and necessary method to prevent fires, explosions, and undesirable chemical reactions. Protection of hazardous material containers from physical damage by using barriers or reinforced storage areas prevents accidental leaks, spills, and releases.
Examples of good handling practices are providing proper labeling, following safety data sheet instructions on handling and storage, using appropriate personal protective equipment, and following the manufacturer's recommendations. Proper labeling and reading the safety data sheet can help prevent fires, explosions, and chemical reactions from accidentally mixing unknown chemicals. Following the manufacturer's handling recommendations on such items as personal protective equipment helps to prevent injury to personnel.
Tools, Equipment, and Supplies
Facility management will provide various tools and equipment to
· prevent hazardous events
· be used by those responding to such events for mitigation purposes
· protect and sustain those being evacuated or sheltered in place
To prevent hazardous events, management might provide safety-release devices such as safety valves, pressure gages, and automatic dump valves. For use in hazardous events, management might supply personal protective equipment, fire extinguishers, and hand and portable power tools for use in rescuing personnel. Finally, facility management might stockpile foodstuffs and drinking water in case evacuations, shelter-in-place conditions, or relocations resulting from a hazardous event necessitate extended stays by employees or members of the general public.
Insurance is a method of financially protecting a business or individual from the effects of natural and man-made hazards. Insurance policies usually contain the following items, which determine the amount of coverage a business has, based on the natural or man-made hazards:
· insuring agreement—states the basic duties of the insured and the insurer
· deductibles section—describes the amount of the loss that the company must pay before the insurance company begins coverage
· definitions section—glossary of terms used in the policy
· declaration section—provides information such as the name and address of the insured, the time and date when the policy becomes effective, and the types and amounts of coverage provided
· exclusions section—lists the types of losses not covered by the policy
· conditions section—defines specific rights and duties of the insurer and insured
· endorsements section—lists any additional coverage the policy provides to address specific needs of the insured
Facility emergency management plans usually are made at the facility level, however, they may be made at the corporate level if the corporation has multiple plants around the country or the world.
The facility emergency management plan is the overall plan to protect the business. It will include the contingency plan as well as elements of hazard-mitigation plans that facility management consider appropriate for protecting the business, its employees, and the adjacent environment.
The facility emergency management plan will include the insurance policy coverage, the interface with any corporate-level policies that affect emergency management, and the interfacing assignments for facility personnel with government contingency plans such as those of the LEPC and the area committee that covers the facility location.
The facility emergency management plan will address the recordkeeping and reporting obligations the facility has if an emergency were to occur on facility property. Decisions must be made as to which types of hazards are to be planned for in case of an emergency. A methodology must be established to classify and prioritize the hazards that could result in an emergency on facility grounds. One useful method is vulnerability analysis, which can be used for natural, man-made, and terrorist event emergencies.
Vulnerability analysis is a systematic method of assessing the impact of various emergencies on employees and corporate assets. FEMA's Emergency Management Guide for Business and Industry describes how to conduct such an analysis.
The first step in performing a vulnerability analysis is to list all potential emergencies that could affect a facility. One source of information on such hazards is historical data about past emergencies. Another source is data about the geographical aspects of a facility. For example, is the region susceptible to hurricanes or earthquakes?
Determining the potential hazards for the type of occupancy of a structure is also helpful. For example, retail stores are susceptible to electrical fires, so one can deduce that a building that is used as a store is vulnerable to this type of emergency.
The level of vulnerability of the facility to a terrorist attack also can be evaluated using the vulnerability analysis method. The level of vulnerability of a specific type of facility or industry can be determined by reviewing loss data supplied by the insurance company for the facility or the industry category that is pertinent to the facility.
The second step in performing a vulnerability analysis is to evaluate the probability of each potential hazard. Probabilities can be obtained through historical, industry, insurance, and government-agency loss data. Historical weather-event data are available for the various parts of the United States from the National Weather Service.
Probabilities are rated on a scale of one to five, one being the lowest probability of occurrence and five being the highest probability of occurrence. Below is the vulnerability analysis chart that appears in the Emergency Management Guide for Business and Industry.
Type of Emergency
High = 5 Low = 1
High Impact = 5
Low Impact = 1
High Impact = 5
Low Impact = 1
High Impact = 5
Low Impact = 1
Weak Resources = 5
Strong Resources = 1
Weak Resources = 5
Strong Resources = 1
Source: Federal Emergency Management Administration. Emergency Management Guide for Business and Industry. Washington, D.C.: Author, 1996.
The third step is to evaluate the potential human impact. This step requires environmental management personnel to evaluate the potential for death, injury, or illness from the effects of the listed hazards. Again, the probabilities are rated on a scale of one to five, one being the lowest and five being the highest.
The fourth step is to evaluate the potential for property damage from the effects of the listed potential hazards. Rating a potential hazard on a scale of one to five, the evaluator uses one for slight property damage and five for complete loss of corporate property.
The fifth step is to evaluate the potential business operation's impact. Using the scale of one to five, one being the lowest impact on business operations and five being the highest impact, rank the emergency's impact on the business.
When evaluating the impact of emergency events on business operations, time to clean up the facility and time to restore operational processes are two considerations. For example, consider the impact of an oil leak that remains in the containment area. Because the cleanup is relatively quick and easy and no repair is necessary, this oil leak is rated as "1" for lowest impact on business operations.
The sixth step in a vulnerability analysis is to determine the availability of internal and external emergency-related resources. These resources are any facility- or community-based personnel, facilities, supplies and materials, policies, procedures, and organizations that can be used in the event of an emergency.
Examples of internal resources are fire-brigade members, hazardous-material response team members, fire-protection equipment, fire-suppression equipment, communications equipment, first-aid supplies, emergency supplies, internal training personnel, and evacuation plans.
Examples of external resources are the local fire department, local hazardous materials response organizations, hospitals, local and state police, community service organizations, and emergency equipment suppliers. Many of these will become known when facility personnel familiarize themselves with the local contingency plans from the LEPC or area committee and on up the hierarchy of contingency plans and emergency response plans discussed earlier.
Assign a score based on the availability of these resources. This evaluation should be rated on a scale in which the lower the score the better the result.
The final step is to total the scores for each hazard. The higher the rating received for a given hazard, the higher the potential for an emergency event to occur based on this hazard.
The information derived from the vulnerability analysis gives the environmental management professional a ranking of the potential hazards and their impact. This ranking will ensure that the professional focuses resources and planning efforts on the more probable potential hazards that will create emergencies that must be addressed.
Emergency Response and Contingency Plans
The emergency response plan is that part of the contingency plan that addresses the scope of coverage for the types of emergencies that will be responded to and the emergency response procedures, resources, practices, and policies that will be followed by facility personnel when they respond to an emergency.
The contingency plan includes the emergency response plan, the evacuation plan, and a series of relevant alternative measures or contingencies that facility management will consider and use at the appropriate times for the anticipated situations or conditions and will include what recovery steps and procedures the facility management expect to follow. These plans must be formulated following a structured planning process.
Emergency planning is the generic work done by facility management to address emergency events that could occur in their facility. Emergency response planning is one part of emergency planning, and it is made a part of the facility contingency plan. The contingency plan is the main plan created during emergency planning and includes the topics mentioned above in the contingency plan.
According to FEMA's Emergency Management Guide for Business and Industry, the following four steps are used in the emergency planning process:
1. establish a planning team—Include input from all functional areas of the organization. Select a team leader to coordinate the planning activities and establish a schedule of activities and a timeline for the various steps in formulating the plan.
2. analyze capabilities and hazards—Perform and evaluate a vulnerability analysis. In developing a plan, the team must establish its basic contents and gather the information necessary to write a draft.
3. develop the plan—Draft the plan and then review it, identify challenges, prioritize activities, and include emergency management elements and emergency response procedures. Then develop a final plan and establish a training schedule. Continue to coordinate with outside organizations and seek final approval of the plan from facility management.
4. implement the plan—Implementation requires that employees be trained in the use of the plan. During these training exercises, obstacles to implementing the plan may emerge. These obstacles should be identified and brought to the attention of the planning team for evaluation. Revisions to the plan may be necessary. Critiques of the training exercises need to be conducted in order to discuss what went well and what did not work well, and what needs to be changed to make it work better the next time. Such critiques are required in the OSHA HAZWOPER standard 29 CFR 1910.120(q)(2)(x), which was presented in modules 1 and 2.
For more information on this planning process, go to FEMA's Emergency Management Guide for Business and Industry (see the Relevant URLs list in the Additional Information section of the syllabus).
The plan should include the following components:
I. Purpose of the plan
II. Regulations addressed by the plan
III. Responsibilities of facility personnel
A. Organization and personnel responsibilities
B. Plan update
C. Plan distribution
1. General information
0. Facility description
0. Glossary of terms
0. Emergency supplies or resources
0. Facility safety inspections and audits
0. Vulnerability analysis
1. Emergency response actions
0. Emergency notifications
0. Regulatory notifications
0. Evacuation procedures
0. Incident handling procedures
0. Facility shutdown guidelines
0. Site security and control
0. Media relations policy
0. Emergency medical treatment and first aid
1. Terminating the incident
0. Recovery operations
0. Damage assessment
0. Post-emergency activities
1. Incident debriefing
0. Incident investigation
0. Training procedures
0. Frequency of drills and exercises
The OSHA HAZWOPER rule requires some facilities to have an emergency response plan, as was mentioned in modules 1 and 2. EPA requires some facilities to have a contingency plan for hazardous waste storage sites. Management at each kind of facility must look at their legal obligations and their business needs and develop the contingency plan that will meet all of their needs and protect their employees, their business and property, and the environment.
Emergency Action Plan
OSHA uses a unique term—emergency action plan—to refer to a plan that sets forth the criteria for emergency evacuation of employees and related matters. OSHA requires in its Process Safety Management Standard that every facility covered by this standard—that is, every facility that has hazardous materials above the threshold quantity level—must develop and implement a written emergency action plan. This plan must include the following:
· facility reporting procedures that employees must use for a fire or other emergency
· procedures for emergency evacuation, including the exit pathways to be used out of the building or structure (building floor plans can be used in meeting this requirement)
· procedures to be followed by those employees who remain behind after the evacuation order is given to help shut down the process or perform other duties before they can evacuate the building or area
· procedures to be used to account for all employees after completing the evacuation
· procedures to be followed by employees who are to provide first aid, medical aid, or rescue
· name or job title of the person the facility management has designated to be available to provide additional information or to explain the emergency action plan
In addition to these requirements, the facility management must provide training about the plan for all employees under the plan. Management must also provide the means for sounding the alarm or alerting employees so that all are notified that an emergency has occurred and that the building must be evacuated (29 CFR 1910.38).
Other Types of Emergency Plans
Businesses use several other types of plans to help them handle or recover from emergencies. These include business continuity plans and disaster recovery plans, both of which are aimed at getting the core business services functioning again as quickly as possible after the emergency or disaster.
Good planning in advance of an emergency or disaster is all-important for prompt business recovery and business continuity. A number of factors that must be addressed in such planning efforts are discussed below.
Determining the Costs
The true cost of downtime for a business must be accurately determined. Lost revenue and lost productivity are obvious costs, but other costs are intangible, such as lost opportunity cost for new customers, lost employees, and possibly some legal costs. The recovery of business-critical systems could take weeks or months, and the speed with which these systems return to operational status may determine whether the business survives the emergency or not.
Communication among the key members of a business during and immediately following the emergency is essential to get the recovery underway promptly and effectively. Planners must consider that landline phone service will not be reliable for emergencies caused by earthquakes or other major nature-caused disasters. Cell phone service may also be overloaded, as happened in the World Trade Center disaster discussed earlier.
Some companies, by surveying their employees, have found that some are amateur radio operators and could serve as a useful backup to facilitate effective communications among the various business officials and departments.
All key people must have alternates that others can go to for information and decisions if the key people are unavailable.
Developing a Worst-Case Scenario
In developing the planning basis for disaster-recovery and business-continuity plans, it is important to focus on a worst-case scenario. By doing so, the business will be in a better position to make a prompt recovery, especially if the emergency is less severe than the worst case.
Protecting Computer Data, Records, and Networks
Business data and records must be protected by being backed up. The backups must be in a separate, secure location and should themselves be backed up. With cyber terrorism a possible risk, the business network as well as data must be maintained in a backup mode, ready to use if hackers or terrorists take down the primary systems.
Plan Organization and Timeliness
The plan should be organized so that information can be found quickly in an emergency. It should not be too generic or too detailed and should be kept up to date. An outdated plan with old phone numbers is of no use. There must be a continuous process of validating the contact information and keeping the plan current.
Code of Federal Regulations. U.S. Department of Labor, Occupational Safety and Health Administration, 29 CFR 1910.38 Emergency Action Plans. July 1, 2003.