Managing Compliance: Understanding the Basics of Chemical Emergency Response Management

Oct. 28, 2011
A stellar record of safety and compliance in demanding fields such as chemical emergency response is not easily obtained or managed. Successful programs are strategically developed, well defined, data-driven, process oriented, tactically deployed, implemented at all levels of the organization, well funded, routinely audited and revised and facilitated by experienced and dedicated professionals.

Preparation, planning, process and persistence are the keys to a successful chemical emergency response program. A broad range of factors and information should be taken into account. Many components of a chemical emergency response plan are intuitive. Some integral pieces, however, often are overlooked or not sufficiently developed. These can include defining, documenting and assigning roles and responsibilities; impact research and analysis; resource assessment; and management of change.

Defining, documenting and assigning roles and responsibilities – This component routinely is underdeveloped. Often, team concepts are not established, back-up designations are not fully assigned and individual responsibilities are not documented, signed and maintained in employee training records. Often, one department may assume another department is responsible for this requirement. Direct, significant and recurring responsibilities should be included in job descriptions, and organizational charts and process plans should include names, titles and responsibilities. In times of crisis, no one should be unclear about who is supposed to do what.

Impact research and analysis – This may be the most complex component of a comprehensive chemical management and safety program, simply because there are many moving pieces and interrelated data, most of which impact one another. During this phase of preparation and planning, it is critical to thoroughly research regulatory requirements, analyze the applicability of best practices and industry standards, apply existing information and conduct a hazard analysis (to include health and physical risks, chemical risks and risks to workers, community and environment). The Chemical Safety Board (CSB) estimates that close to 90 percent of chemical incidents could be avoided or significantly diminished if appropriate corrective actions had been applied. This component requires time, expertise and access to a steady stream of accurate and current data.

Resource assessment – In this phase, the plant safety team should assess availability of internal and external resources, as well as ensure warning systems and early detection/preventative action plans are up to date. Resource assessment and management goes far beyond safety team capabilities. The proactive distribution of important information and recommended emergency actions will increase the preparedness of local officials to respond to an incident and the surrounding community to take appropriate measures.

Management of change – Finally, since circumstances and conditions rarely remain the same, organizations must have effective methods of implementing, communicating and documenting change. This includes changes related to new tasks and operational processes, upgraded equipment and systems, revised and expanded regulations, improved PPE, new technology and automation, new chemical substances, revised formulations and changes in known hazards.

Effective change management offers a collaborative workflow designed to systematically manage changes in regulated materials, compliance requirements, technology, equipment, facilities or procedures. It also provides an accurate and comprehensive means to implement change organization-wide. Enterprise implementation reduces administrative overhead of assigning, tracking, reporting and soliciting and following-up on approvals, tasks, checklists, action items and training required to implement changes in regulated and non-regulated processes. Equally as important, it also provides a historical reference of all changes.

Perhaps the most critical component of a well-rounded chemical emergency response program is a comprehensive and effective strategy for responding to spills and other emergencies. This is essential, since the potential for chemical spills exists anywhere these materials are stored, used or transported.

Laying the Foundation for Safety

A successful emergency response strategy should encompass facility operations – an overview, area map and description – and a detailed list of hazards covered in the plan. Facility identification also should also be provided, with address, owner/operator information and emergency and environmental contact data, including local responders. Other considerations include:

Hazard and impact analysis – This analysis helps companies prepare for incidents that result in hazard to human health and the environment. It involves analyzing the types and quantities of materials that may be involved, as well as modeling the direct and indirect effects of a release, fire or explosion, as well as an evaluation of the surrounding area.

EOC structure – The primary function of the structure is to ensure that proper training has been administered for those in both traditional roles (command and control), as well those in adjacent functions (PR, agency liaisons, etc.)

Employee response capability – Conduct an initial identification and assessment, and establish immediate action and protocols. Proactively follow hazcom fundamentals in non-emergency environments.

Establish and follow emergency procedures – Written emergency procedures should be followed by facility personnel in case of emergencies and other adverse incidents. They should account for multiple scenarios (explosion, fire, release into the community, etc.), and include procedures to be carried out by employees who remain to operate critical plants ops prior to evacuation. They should include instructions on how to deploy the EOC, as well as guidelines on how to document all communications and actions, and references to the business continuity and disaster recovery plan (when applicable).

Internal and external notification procedures should be defined. Incident commanders and their support teams should be well versed in when agencies must be notified, which agencies must be notified and what information must be reported. Engage local response groups or community advisory panels to ensure the public is up to speed on warning systems, evacuation and sheltering procedures in the event of a chemical release.

Include sustained actions and termination procedures for managing the transition from the initial emergency to the sustained action. Document all actions and communications related to the incident and include discoveries and lessons learned. The plan should be reviewed and updated annually and after each adverse incident, and should be updated whenever there is a change in operations.

EHS and CSR Initiatives

EHS compliance no longer is just a reactive exercise. Proactive chemical emergency response strategies must move forward hand-in-glove with corporate social responsibility initiatives. Here are some proactive strategies:

First, enhance employee involvement. The most effective safety programs and emergency response plans significantly are impacted by employee involvement and feedback. The benefit of ivory tower, senior-level management lip service or safety theory is of minimal value in time of crisis.

Second, ensure employees are trained to follow a plan or fulfill a checklist. They should be actively involved in safety training, planning and decision-making. When they are, they will take ownership and demonstrate leadership when action is required.

Finally, enable a quality process approach. Provide a coherent, consistent and documented structure. People are invaluable, and so is the foundation that their safety is built on. If you want to exceed the letter of the law, here are six steps that will help make your vision a reality:

1. Stay informed through involvement with professional associations for access to accurate, updated data new methodologies and approaches.

2. Maintain compliance with recognized standards.

3. Provide superior training programs.

4. Perform rigorous, regularly scheduled internal audits.

5. Develop agency relationships and participate in voluntary programs.

6. Establish community outreach and be transparent.

Just like anything else, construction of a chemical emergency response plan from the ground up or a re-work of an ineffective existing system can seem like a daunting task. Build a solid foundation, arm yourself with good information from trusted sources, lead by example and never tire of going the extra mile.

Kami Blake is a solutions engineer with 3E Co., providing technical expertise to assess regulatory requirements, information management technology and analysis of existing hazmat programs to develop compliance solutions. Oscar Jimenez leads the team responsible for delivering 3E’s spill, release, emergency planning and response and hazmat transportation services.

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