Emergency planning is essential for all organizations. This applies whether you are a major manufacturer using large quantities of potentially hazardous materials or an organization that only employs office workers. This is because even those organizations that have no potentially hazardous materials, processes or wastes need a plan for fire, severe weather and other events requiring evacuation.
What is important is to have an idea of what the potential emergencies and disasters might be. Planning flows from this point. In this article, I will review a risk assessment approach to emergency and disaster planning with that concept in mind.
What can make emergency and disaster planning complicated is that they are regulated under a variety of different rules by a number of federal and state government agencies. The majority of the regulations on emergency planning reside within the jurisdiction of EPA and OSHA.
EPA has jurisdiction over the Resource Conservation and Recovery Act (contingency plans), the Clean Air Act (risk management plans), the Clean Water Act (spill prevention control and countermeasures plan), the Superfund Amendments and Reauthorization Act (emergency planning and community right-to-know plans) and others.
OSHA has jurisdiction over hazardous waste operations and emergency response, process safety management, and requirements under the hazard communication rules. In addition, OSHA has separate requirements for emergency action planning and fire prevention planning for essentially all organizations within its range of authority.
My assumption is that your organization has done some emergency planning, because most of these rules have been around since the 1980s. Nevertheless, now might be a good time to review your plans to see if they will really work. For those of you who routinely have your plans audited or audit others, you may wish to re-evaluate your audit criteria using a holistic approach (e.g., an integrated plan). In this regard, I will review a general philosophy and approach to emergency planning followed by a brief discussion of some particulars that can lead to implementation of an effective plan. Paraphrasing Murphy's Law, "If everything seems to be going well, you have obviously overlooked something!"
The best place to start is the beginning (a purposeful redundancy). By that, I mean having a logical scheme for developing emergency and disaster plans.
This starts with establishing a complete inventory of potentially hazardous materials received or stored in quantities that might present a significant risk (e.g., bulk storage of solvents, gases and fuels). Identify processes that could present inherent hazards. Recognize potentially adverse events (e.g., bad weather, natural disasters, power failures, chemical spills and fire) that could occur and involve the materials or processes listed in the inventory.
Conduct a risk assessment for the identified adverse events based on the expected frequency and potential impact (severity or consequence) of the event to include information generated by any history of near misses or adverse events. Establish an integrated plan to mitigate the effects of those events established as presenting high risk (severity and frequency). Identify the resources necessary to carry out those plans.
Provide personnel with the training necessary to recognize these potential hazards and to understand their role in the emergency response/disaster planning programs. Establish a means to develop and enhance skills and knowledge in emergency response and disaster planning to be able to effectively and efficiently carry out the integrated plan that is developed.
I Don't Plan to Have Any Emergencies
No one plans a real emergency or disaster. Fortunately, they are rare events, but not unforeseeable. It is impossible to identify every eventuality, but it certainly is possible to identify the potential for major adverse events.
Using an analogy, it would be foolhardy to build a home within a 100-year flood plain and not buy flood insurance or consider this in the construction of your home. This identification phase of emergency and disaster planning is probably the most critical part of the planning process, because everything follows from this initial work.
The first step in our process is to examine all potential inherent hazards of the operation and things that could go wrong. Generally, this is best accomplished by taking inventory of all Department of Transportation-labeled materials (e.g., flammable, corrosive and reactive) as well as others that might present a problem. Next, expand the inventory by including all processes that may have inherent hazards. This would include machinery that could present a problem due to loss of power, cooling processes, high-pressure devices, high-temperature processes (e.g., molten metals) and batch reactors. Once this listing is completed, the fun begins.
This is the time to find a small group of the most creative and technically competent workers, supervisors and managers available who know about plant operations. Gather them into a room for a free-spirited, open discussion on all things that could go wrong.
The facilitator for this brainstorming session sets the scenario and pace. Again, a creative touch is beneficial. Examples of natural disaster scenarios could include earthquake, tornado, hurricane, flood, ice storm, fire or loss of power. Examples of accidental events include the likelihood and consequences from the process of too much, too little, too fast, too slow, etc. (guide words from a hazard and operability study work well here). This group-think should also encompass seemingly obscure events such as vehicle accidents, plane crashes, civil unrest and terrorism.
From this chaos, there is a reasoned approach so that those in the group who are most creative do not get too far afield. This is the estimating of the likely frequency and consequence of each event. The frequency is affected by whatever controls are in place or will be put in place. Obviously, redundancy and failure of the control systems must be considered.
While there are a number of ways that frequency can be expressed, two routine approaches are to express this value in terms of chance ranging from very unlikely to very likely or as a once-in-one-year to a once-in-1,000-years event. Those scenarios that fall within an estimated frequency of very unlikely or once-in-1,000-years will not generate enough of a risk profile to merit further consideration. This eliminates the further consideration from the left-brained participant in the group asking about the consequences of a 747 falling from the sky onto your facility.
The second part of the risk equation is the estimation of consequence. This can also be done using a relative scale. It can be expressed as a range of very minor to very severe or done with cost or injury as the criteria (from first aid and less than $1,000 damage to multiple deaths and millions of dollars in damage). Again, minor consequences will not need to be considered further.
From these factors, a relative risk matrix can be built. Use of a 6-by-6 or an 8-by-8 matrix increases the sensitivity of your analysis; however, there are limits because the results are based on informed guessing (the art of estimation).
From the results of where each scenario falls within the risk matrix (the group can decide on the risk level threshold requiring further emergency response and disaster planning), you can proceed to the next phase of work. Planning for the emergencies identified in the brainstorming session can also be used to reduce risk. A simple extension of the exercise is to include those controls or measures that will reduce the risk to an acceptable level. Again, this can be performed as a group exercise. This approach is very similar to that performed during a hazard analysis under process safety management rules.
Not a Time to Diversify
Unlike your retirement or stock portfolio, planning for emergencies is not a time to diversify. For regulated industries, there are minimum requirements for establishment of written plans and programs. Nevertheless, it is very beneficial to have an overall plan to address all contingencies, as long as it does not become a tome. In other words, have volumes of information (as desired) but no more than 10 to 20 pages of instructions for those who need to take action.
This action plan should include flow charts for what needs to be done by the type of emergency (e.g., fire and evacuation, internal and external reporting, and outside responders). For disaster planning, a good technique is to identify what must be done based on time to the event (where this is possible, such as for hurricanes). In all cases, detailed evacuation plans are necessary.
There are a number of other key elements in emergency and disaster planning that should be addressed. These include emergency shut-down procedures for critical operations, medical evacuations, procedures for return to normal operations, legal and insurance needs, and neighborhood coordination and planning. One more important area that I frequently see missing is practicing what you have devised.
Practice Makes Perfect
When was the last time you actually did an evacuation, disaster or response drill involving the general work force? If it has been more than a year, you may have personnel who are unclear on their roles and responsibilities, points of assembly and other important information.
While I recognize drills can disrupt the flow of work in any organization, it is important to ensure that everyone knows what is expected of them. There is no way to accomplish this other than practice. This can also be used to test the effectiveness of alarm systems, emergency equipment and other resources. Involving outside agencies is also quite beneficial. As the old saying goes, actually having them do it is much more effective than telling or simply showing them what to do.
Murphy's Law says, "Whatever can go wrong will go wrong." I believe Murphy's Law underscores the need to plan for emergencies and practice much more eloquently than I can. Please have a safe and uneventful day.
The Planning Process
There are many diverse legal and business requirements for emergency response and disaster planning. Here is a logical sequence for developing an integrated plan:
- Identify the potential or inherent hazards from materials, processes and adverse events, including weather, geological and civil.
- Develop an integrated plan, using a risk assessment approach, to mitigate the effects of those events established as presenting a high risk (severity and frequency).
- Identify the resources necessary to carry out those plans.
- Provide personnel with the training necessary to recognize these potential hazards and to understand their role in the emergency response/disaster planning programs.
- Develop and enhance skills and knowledge to be able to effectively and efficiently carry out the integrated plan that is developed.
Contributing Editor Zack Mansdorf, Ph.D., CIH, CSP, QEP, has more than 25 years of technical and strategic experience in safety and health management. He is a past president of the American Industrial Hygiene Association and a director of the Board of Certified Safety Professionals. He can be reached via e-mail at [email protected]