Every facility needs to have an emergency preparedness and response plan. A number of different safety and environmental regulations require them, and in many cases, the required planning elements for each plan are very similar.
Chances are good that each required plan needs to be reviewed and updated with some vague regulatory language like “regularly,” “periodically,” “on a regular basis,” “whenever something changes,” or, more specifically, “annually.” Whatever the frequency, plan reviews should be more than just a pencil-whip activity or a check in a box.
The point of reviewing emergency preparedness and response plans is to make sure that they are still accurate. It should also be a time to look for opportunities for growth as well as reviewing any new technologies that have become available since the last plan review. Here are some things to consider:
What changes have happened since the last update?
Big changes like the addition of a new production line or a warehouse expansion are obvious and usually have the attention of nearly everyone at the facility. However, many changes within a facility can be more subtle, such as staff changes or decommissioned equipment. These “little details” can creep up over time, and if plans aren’t reviewed regularly, they can add up to a lot of cleanup work. Check for:
- New chemicals that aren’t on the chemical inventory list
- Obsolete chemicals that are still listed in the plan
- New processes
- Obsolete processes or equipment
- Building changes, additions or demolitions
- Staff changes
- External contact information (fire, medical, police)
Plans with outdated information are an extremely common violation. If your plan has information about chemicals that you haven’t had onsite for ten years, or lists the name of a local fire chief who retired around the time you got rid of those chemicals, it’s time to take a closer look at your site maps, processes, chemical inventories and contact information in your plan to see what else has changed.
Do your SOPs include pollution prevention protocols?
Preventing a release is always preferable to responding to a release. Material handling, chemical use and waste disposal procedures should all reflect best practices intended to keep materials in their intended places. Employees should be trained to understand the importance of these measures and how they prevent spills and releases.
Some pollution prevention measures can be as simple as establishing good housekeeping practices. Not only do they keep the facility looking great, but they can also help to quickly identify something that is out of the ordinary or could cause a spill emergency.
Consider new technologies that have become available and are being used in facilities like yours. Even if it doesn’t make sense for them to be implemented in your facility at this particular time, note in the plan that they have been considered. Recording this information shows auditors that efforts are being made toward continual improvement. The information can also be a learning and time saving tool for future plan reviewers.
Are inspection findings reviewed regularly?
In some facilities, inspections are a full time job. Pipes, pumps, valves, fittings, tanks, containers, liquid levels, waste areas and treatment processes are just a few of the things that need to be inspected regularly.
Inspections are more than something to keep in a file. Done properly, inspections can provide insight into changes that have occurred but may not yet have been realized or communicated to other departments. They can also identify areas that may need some preventative maintenance or extra care so that they don’t become a problem or create an emergency.
Are secondary containment systems being utilized?
Several regulations specifically require secondary containment systems for certain types of tanks, containers and even piping. They’re also a great idea for other areas where containment isn’t specifically required, but would save in cleanup time and expense.
Secondary containment systems can buy you time. Yes, if whatever is inside of the system fails, you still need to clean it up, but at least it’s not headed to the drain, river or anywhere else off of your property. That gives you the option to choose the best, most affordable or practical way to recycle it or clean it up.
Is your preventative maintenance program adequate?
Like inspections, preventative maintenance can be a full time job. Most facilities view it as a necessary evil to prevent downtime. But, the same preventative maintenance that prevents downtime can also prevent tank, container, vessel, pipe, valve and fitting failures that create big spills and potential releases to the environment.
Are response supplies ready and appropriate?
If a 50,000-gallon tank fails and all you’ve got is a single bag of cat litter that is locked up in the supply room on the other side of the facility, it’s not going to be a good day. And, if your plan says that you have drain covers, backhoes, spill kits and 3,000 feet of containment boom that you don’t actually have, your day just got worse.
Local emergency response agencies rely on your plans, including the lists of supplies and resources available, being accurate and adequate. This is one reason why your plans should be coordinated with local fire departments, hazmat teams, medical services and hospitals. Each responding agency needs to know your capabilities so they can plan to help your facility, as well as the community, during an emergency.
Do you have adequate security?
Most facilities don’t need to go to the extent of having armed guards or concrete walls that are 3 feet thick and 40 feet high, but every facility does need to consider basic security measures. This is especially true for bulk storage tanks, equipment and containers that are stored outdoors.
Are employees properly trained?
Training needs to be ongoing. A common mistake is training employees when they are first hired and never again. Employees need to be re-trained when plans change so that they are aware of new processes, as well as obsolete ones. If nothing changes, refreshers are still an important way to gauge understanding. They can even be an opportunity to brainstorm and look for new and better ways to prevent pollution.
Does everyone understand the plan?
Your facility’s plan needs to be accurate and adequate. But, that doesn’t mean that it needs to be elaborate. A 500-page plan full of legal language that no one understands – and consequently, no one can follow – is useless.
Remember that the point of this plan is for everyone at your facility to be prepared and ready for emergencies. There is no minimum or maximum length that makes a plan “good.”
Everyone at your facility should be able to read and understand the plan and identify their roles in pollution prevention or an emergency. If everyone can do that, chances are good that your plan will do exactly what it intended to do. Training and regular drills will help to reinforce everyone’s knowledge. They can also help you to identify changes that need to be made to keep plans consistent, accurate and current.
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