Six Steps To Hazardous Material Emergency Response Planning

Planning for emergencies is one of the most critical elements of the emergency response effort. However, planning involves more than drafting a written document.

Planning is a dynamic, constantly changing process, not a static one-time operation. Planning is a process. It is the first and most important part of emergency response. Without planning we have no communication, and without communication there is no cooperation – the essential element in the planning process. Without planning we have no direction.

A plan is a blueprint of the outcome we expect at the conclusion of an emergency. If we do not have or follow the blueprints, we may not like the outcome. Unfortunately in recent years emergency planning has become compliance driven. The weight or size of the plan should not be the only criterion for an acceptable emergency plan. Big plans do not assure success. Planning should be action oriented, performance driven. It is about the people planning not the plan. As Dwight David Eisenhower said, “Planning is more important than the plan.”

Good plans are very complex. They must be comprehensive enough to cover the entire spectrum of emergencies but specific enough to guide the responders to a successful outcome. Comprehensive plans must be flexible. They must be based on sound information and they must be simple to operate. Remember, the author of the plan does not usually initiate the emergency plan. It is usually the worker or the first line supervisor who does this.

There is a pattern of six specific elements in all successful plans. If these elements are addressed, there is a good chance the plan will succeed. These six steps of the planning process are as follows:

• Policy
• Prevention
• Preparedness
• Procedures
• Performance
• Practice

Policy

The first important planning element is policy. Someone in authority has to say that planning will happen and there must be a solid commitment to create a workable plan. An often-used phrase applies here: “Safety begins at the top”. Those in charge must demonstrate a strong desire to assure that emergency planning will get done properly. Remember, you can delegate the planning to someone else, but you cannot abdicate the responsibility that it will be done right. Safety planning always starts at the top. The Organisation of Economic Cooperation and Development’s Guiding Principles for Chemical Safety states, – “There is a clear correlation between safely run installations and well managed operations.”

“there is a clear correlation between safely run installations and well managed operations”

Major safety programmes throughout the world start with an effort to create a positive safety culture from the top all the way down to the new employee. Positive preventive attitudes are always better than any response models. Any manager who has had to say “I never want this to happen again!” is creating a strong policy, but is it a proactive or reactive message?

Prevention

It isn’t by accident (no pun intended) that prevention follows policy. Prevention must be included in any planning process more so than response. Odd? No. Imagine an earthen dam with millions of gallons behind the dam and the small town below the dam in the valley. What keeps that town safe, response or prevention? Prevention is the answer in the form of inspection and maintenance. Have you ever seen a truck in a small house at the base of the dam with a sign reading “Dam Response Team”?

Prevention is the true measurement of an organisation’s desire to accomplish the emergency response effort. In the fire service there is an old proverb: “There is no honour in fighting a fire that could have been prevented.” Sprinkler protection is a response action that has had its birth in prevention. Fires start small. Sprinklers react early while the fire is in the incipient stage. When sprinklers fail to put out the fire, there usually has been some problem with inspections or human errors, such as deactivating the system.

So should it be with chemical safety. Analysis of the problem is the first step of prevention. Review existing systems. Examine the facility operations with regard to production and safety as an interfaced process, not separate issues. Examine all the possibilities for an emergency. Recently, there has been major emphasis on prevention. In the United States the OSHA Process Safety Standard and the EPA Risk Management Plans require extensive prevention elements. History has taught us well that most of our major disasters could have been prevented!

“analysis of the problem is the first step of prevention”

Throughout this prevention process, we begin to develop an opinion of which potential events we could respond to and, based on our preliminary exercises, we can even prioritise them. Finally, we will have identified severe problem areas or the “worst case scenario”. We should not be preparing to respond to the worst case scenario. We must focus our effort on preventing such scenarios in the first place.

We must spend considerable time and effort to prevent these last events. Can safety features be constructed to keep a spill or release from escalating? Have we examined the integrity of equipment, reviewed all methods of construction, and managed any change in operations? Should we engineer, build and construct systems that will prevent the chemical from being released or contain spills after an incident? These actions help to prevent the problem or keep it from escalating. Prevention is the essential element of process safety. But process safety is a highly technical procedure, and volumes are written about it. Nevertheless, we concentrate on all events with an eye to the most important message in safety:-

“ALL ACCIDENTS ARE PREVENTABLE!”

Can emergency responders play a role in prevention safety? Yes. It can be as easy as a reality check. Emergency responders have seen the results of misguided intentions and good or bad programmes. They are silent witnesses to the fallacy of “fool proof ”, “fire proof,” systems failing. Experience is a positive teacher. Have you ever wondered when dikes around chemical tanks were invented? I don’t know either. But I can tell you what happened the week before they were invented!

Preparedness

The fact that preventive and protective systems will fail and all emergencies may never truly be eliminated is the reason we must prepare for the worst. The essence of preparing for emergencies is to anticipate them and expect that they will occur. Cooperation powered by communication is crucial in emergency preparedness planning. Communication is critical. It must be a group activity. It is why one person cannot write a good plan. The best group is the local community. Everyone has a stake in the plan’s success. The local community planning group is the heart of successful preparedness. Evaluation by the local planning unit should ask the following tough questions:

• What’s the worst thing that can happen?
• Are we ready?
• What do we need?
• Where can we get it?
• What do we do?

“there are two situations with every chemical that require two types of procedures; normal and emergency”

Locally preparing for the worst-case situation will prepare us if prevention fails. But it will also better prepare us to respond to lesser emergencies more effectively. We should also prepare to escalate our actions in any small emergency to deal with a largescale event. In effect, we are preparing our organisation to act according to the overall plan in an emergency.

Procedures

Procedures are an established course of actions. They can be routine or emergency in nature. Procedures are generally what should be done or accomplished in an emergency. The standardisation of these activities is important to ensure continuity during the response and to achieve the planned result in an emergency response. The key with managing chemicals is that there are two situations with every chemical that require two types of procedures; normal and emergency. Normal procedures may not be adequate or appropriate in an emergency. Ultimately, emergency procedures must be achievable and simple. From experience, the more complex the procedure becomes, the sooner it will be discarded in the crisis of an emergency. And as an emergency planner, do you really want your employees functioning solely on their own initiative?

Performance

The true test of emergency response lies in how the response effort is carried out or performed by the employees. A responder must perform adequately in order to accomplish the established procedures. Even the best procedures are doomed to failure if the employee cannot perform the procedure properly. To perform properly the employees must be trained. If procedures are what supervisors expect employees to perform in an emergency, then training is how we ensure that procedures are accomplished. Remember, if someone says, “I didn’t know I was supposed to do it,” there has been a breakdown in procedures. But, if someone says, “I don’t know how to do it,” there has been a failure in training.

One of the most important issues in emergency planning training is recognising that many employees wait too long to declare an emergency because they fear getting in trouble for acting improperly and causing the emergency. Performance is also the true measurement of attitude. Poor performance will usually have its roots in a bad attitude or a poor training programme. The measurement of performance training is not a letter grade of “A” or “B” but a pass-fail system of competency. If employees are not competent to perform the procedures, the response and ultimately the plan will fail.

Practice

Finally, in order to be good at anything one must practice. Good performance is always linked to practice. Practice can come in two ways; actual emergency experience or drills and exercises. Obviously, the latter is always preferred over the former. But in order for drills and exercises to be a truly effective practice, they must be realistic and stress the limits of the responder and the emergency plan. The primary reason to exercise the emergency plan is to determine if the plan has any flaws – not to choreograph a success for the boss.

The final part of a good practice is to conduct critiques. It does not matter if there was a real emergency or an exercising of the plan. The response plans, procedures, and actions must be discussed and reviewed for changes. We must honestly look at our performance after any event or practice. If we do not analyse our response effectively, we are doomed to repeat the disaster. In these critiques or review sessions we should not focus on fixing blame but on addressing the problems and how they can be fixed, solved, or overcome. Then revise the plan, with appropriate changes.

Summary

Effective planning does not end with a submission of a written document. Planning is a dynamic living process that is always changing. The driving force in planning is a positive attitude that planning will benefit the organisation. Belief in the plan will create a culture towards planning. When the organisation feels the plan won’t work, a negative attitude results and the planning process will grind to a halt. Therefore, the core of every successful plan is a positive attitude. These six P’s are a way to remember what makes a good plan work. Forget, ignore, or trivialise any of these six basic elements and the planning process is critically flawed and probably doomed to some level of failure.

Published: 01st Jan 2003 in Health and Safety International