Emergency and response planning are often impacted by organizational changes and growth, with corporate downsizing, reorganizations, mergers and acquisitions posing significant challenges for companies. As companies reorganize and grow, emergency management programs and plans can quickly become outdated and non-compliant. Response plans for newly built and acquired facilities often exist in different formats and are harder to update, review, and use. Further, when companies grow, the number of staff dedicated to maintaining response plans does not grow with it.
Streamlined, coordinated and exercised response plans are essential to effective emergency management programs. Given their importance in ensuring preparedness and employee safety, response plans must be regularly reviewed as organizations undergo changes to determine inconsistencies and deficiencies, address compliance issues, and confirm that plans follow best practices.
Audit and Identify Response Plan Deficiencies
Due to the many operational components involved, response plan audits are critical for determining potential discrepancies, regulatory deficiencies and whether minimum corporate emergency preparedness criteria are being met. Audits may also reveal process or procedural inadequacies, contradictory plan formats, or inaccurate information.
Response plan audits often identify:
- Personnel listed in response plans who are no longer employed with the company.
- Emergency response duties and responsibilities not assigned to appropriate personnel.
- Inaccurate contact information for company personnel and external resources.
- Lack of detailed response procedures.
- Lack of specific fire pre-plans.
- Training deficiencies.
- Inefficient documentation of training records.
- Inconsistencies with Area Contingency Plans and local regulations.
- Differing plan formats and versions resulting in disjointed information.
- Lack of processes for implementing lessons learned, policy changes or regulatory requirements.
Once discrepancies and deficiencies are identified, adjustments can be made to ensure compliance, efficiency and effectiveness. A dedicated regulatory intelligence team or the Environmental Health + Safety (EH+S) manager will likely be responsible for sifting through the mountains of location-specific regulations, mandates and guidelines to modify determined deficiencies.
Ensure Plans are Updated and Compliant
Although regulatory compliance involves many costs and complexities, the regulations exist to protect the public interest, the company and the surrounding environment. Ineffectively planning for or responding to an emergency, fire, or other hazardous incident can severely impact the organization and surrounding community, possibly leading to the company’s demise.
Following an external regulatory compliance audit, authorized agencies may, in some instances, demand deficiencies be addressed within a certain time frame. Agencies can impose fines and shut down operations for missed deadlines or ignored requisitions. Moreover, negative media exposure and antagonistic public opinion can quickly escalate when regulatory compliance failures result in companies mismanaging personnel safety or disturbing environments.
To help minimize potential financial penalties and adverse social impact, those responsible for emergency management programs must remain watchful to ensure emergency plans are up-to-date and compliant with standards and regulatory requirements. Annual audits and reviews can be scheduled to help prevent noncompliance and facilitate effective response plan implementation.
Review Safety and Response Best Practices
While companies may not need to “reinvent the wheel” when it comes to safety and response procedures, facilities do need to confirm that best practices apply to their site-specific situation. Each facet of a company’s operations should be broken down to examine best practices for a particular action, material, scenario, or site circumstance. The following areas often require review:
- Pre-incident planning
- Training and exercises
- National Incident Management System (NIMS)
- Security
- Fire brigades
- Rescue and evacuation
- Hazardous materials handling and response
- Fire loss prevention
Manage Response Plans with Digital Technology
Web-based solutions like Jensen Hughes’ SmartPlan can help facilitate effective compliance management during periods of organizational change. By managing administrative duties associated with evolving personnel, operations and regulatory requirements, these technologies can help streamline response planning across facilities, regions and divisions, ensuring enterprise-wide compliance on multiple government agency fronts. The result is an efficient and integrated program that minimizes operational downtime while safeguarding employees, property, and the organization’s reputation.