When emergencies strike your facility, are you prepared? Have you thought of the repercussions of not being prepared? Will you be prepared in the future?
What emergencies could happen?
Emergencies come in large and small events. Hurricanes, floods, water inundation, dangerous gas leaks, explosions, and everything in between occur daily in the United States and across the world. A minor equipment failure or chemical release can quickly develop into a catastrophic failure.
In the past year, there have been numerous examples of large-scale emergencies that required coordination of multiple agencies and stakeholders. Some of the most notable crises in the nation’s history include the Exxon Valdez and the Deepwater Horizon Incident. Both events activated Unified Command, a structure under the National Contingency Plan (NCP) that oversees a response plan by coordinating personnel and resources from several agencies (the responder, the government, private industries, and stakeholders) to mitigate the risk of a potential national threat.
While the Exxon Valdez and Deepwater Horizon are seared into our memories, every year many smaller events occur that trigger the NCP. In the last year alone, we witnessed events like the Intercontinental Terminal Company fire, the Kirby Barge spill in the Houston Ship Channel, the Enbridge Michigan Pipeline Spill and the capsized tanker emergency off the coast of Georgia.
When emergencies occur, the central questions (ultimately answered inside or outside of court) are the same: Were we ready? How prepared were we? Are we ready in the event of another emergency? These questions are posed repeatedly by parties such as the Environmental Health and Safety (EHS) manager, the CEO, and neighboring residents and the public stakeholders at large.
What these questions really mean:
Were we ready?
- How was the response effort?
- Would more training have improved the response effort?
- Would more resources have improved the response effort?
- Are the federal and state agencies pleased or upset with our level or quality of preparation?
- Were we pleased with the assistance we received from our contracted providers?
- What went well and what could be improved?
- What were the repercussions of the emergency?
How prepared were we?
- Were our plans adequate, updated, and effective?
- Do we need more, or different responders?
- Are we able to access necessary resources in our moment of need?
- Were we up-to date on our required compliance and permitting?
- Was the agency more upset than expected?
- Will we receive more fines than just the response?
- Is the issue systemic? Were there failures beyond this specific event?
- Does the public feel negatively towards us because they think we did not effectively prepare or respond?
Are we ready in the event of another emergency?
- Do we currently have plans in place to execute emergency response (SPCC, FRP, Contingency Plan, etc.)?
- Do we have response training available, and is it updated?
- Do we have responders on-Site or on contract to respond?
- Do we have the resources on-Site or in place to respond?
- Do we have the infrastructure to sustain an emergency of national significance?
Emergency events cause widespread reflection and their stigmas can follow a company for years after the event; especially if public stakeholders feel that the company was not prepared or did not employ adequate safeguards to prevent or lessen the severity of the incident.
After the KCMO chemical plant fire in Houston in early 2019, it was reported that neither the Harris County Fire Marshal’s Office nor the Houston Fire Department knew about the chemicals on-Site before responding to the incident. Neither agency had KCMO’s Tier II reports or were included in KCMO’s emergency planning committee. “We didn’t know anything prior to our arrival” said HFD District Chief.
The KCMO fire is not unique and after almost any event of national significance, scrutiny will be placed on the company’s records, training and preparation. The questions we come back to are: Are we prepared? Were we well trained? Was our permitting and compliance in order before the event? Or is this event tied to a systemic failure of the company’s emergency preparedness plans?
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