Emergency Response Procedures

Detailed emergency response procedures, call plans and call trees, and other emer-gency response actions are included here. Though business continuity is related to emergency management, those business continuity actions and activities that have safety implications are also included here.

4.4.3 evALuATing conTrAcTorsAnd suBconTrAcTors

A June 28, 1993, explosion and flash fire occurred during a resin reactor building main-tenance project…Two of those hospitalized were plant employees, two were contract workers…A major oil company is currently implementing settlement terms reached regarding OSHA citations alleging that the company did not periodically evaluate its contractors’ performance…A major petroleum company is contesting an OSHA cita-tion resulting from an explosion that killed a contract worker…According to OSHA, the oil company had not developed safe work practices to control hazards during hot work operations (Roughton, 1995).

No matter which way you look at it, employers can be (and are being) held liable for injuries and accidents on their premises. OSHA may cite the employer even if his or her own employees are not exposed to the hazard, but contract employees are.

The three major OSHA standards most frequently cited to employers regarding contractor safety are Process Safety Management of Highly Hazardous Chemical (29 CFR 1910.110), Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147), and Hazard Communication Standard (29 CFR 1910.1200). These regulations per-tain to the hiring of outside contractors and subcontractors to perform repair work, plant modification, equipment maintenance, etc. Many countries around the world have their comparable standards.

Contracts written to outside firms should specify that the contractor meet cer-tain minimal safety and health requirements. Contractor system safety should be included in the construction process from prebid to project acceptance. The contract

should also require that the contractor enforce an effective safety and health pro-gram. Bid solicitation documents should require that safety costs be included in the actual bid. Sometimes, you may wish to even enumerate specific hazards that con-tractors must control. Also, it is critical to emphasize to bidders that evaluation of their written safety and health program will be part of the buyer’s evaluation of the bid proposal. Because the buyer is still responsible for what occurs on his property and under his supervision, it is important to ensure that contractors and subcontrac-tors have adequate safety programs.

Some of the aspects you should study in evaluating a bidder’s safety program are the following:

• Past safety record—Examine contractors’ workers’ compensation and OSHA experience.

• SMS—Does the contractor even have one, is it formal, and what does it look like?

• Safety management structure—Who is responsible for safety and health, and how are policies communicated and enforced?

• Work procedures used and how safety is incorporated into the procedures.

• System for reporting accidents.

• Process used to identify and control workplace hazards.

• Safety requirements for subcontractors.

• On-site safety representative—The individual who will enforce compliance of safety procedures.

• When and how employee safety meetings are conducted—Contractors should hold a safety briefing before each hazardous operation starts.

• Formal safety program—Description of the contractor’s safety program (this should be their SMS description).

There are almost endless ways to evaluate contractor safety—of course, evaluation of contractor safety programs is totally dependent on the actual operations. Every industry (e.g., construction of petrochemical refineries or operations of subways) does it a little differently, but almost all have similar content. If the contract is large and long term, the company should ensure that the contractor develops and imple-ments a comprehensive safety program similar to the SMS described in Section 4.3.2. If the contractor is transient, contracting for less than 1 year, then an adapted program can be used. What is the most important is that the company designs their contractor/subcontractor safety program evaluation process specifically to company operations and in compliance with the company SMS and of course local and federal laws, regulations, and best practices. Though a contractor safety program may not be as involved as a company SMS, it must not violate any company SMS safety poli-cies. Table 4.7 shows how NASA evaluates outside transient industrial contractors (National Aeronautics and Space Administration, 1985). Though the form is old and is specific for occupational safety and health (not to be confused with managing the operations of NASA launches), it is an example of some of the concepts that should be considered.

TABLE 4.7

Evaluation and Effectiveness Criteria Checklist for Safety Programs

Satisfactory/

Unsatisfactory Comments Program Elements

1. Written policy, purpose, scope 2. Statement of objectives H. Mishap/near-miss records and reports I. Fire/explosion safety

J. Emergency preparedness

K. Procurement and subcontract safety L. Safety representatives on-site

6. Implementation of supplemental requirements A. _____________________________

B. _____________________________

C. _____________________________

Program Implementation 1. Hazard analyses on record 2. Risk priorities stated 3. Measurable results defined 4. Self-evaluation performed 5. Modifications effected Program Accomplishments 1. Hazard analyses and surveys

A. Near-miss investigations, causes corrected

B. Hazardous operations, materials, permits surveyed and documented C. Regular inspections documented

2. Changes and deviations analyzed and modifications documented 3. Trend analysis

A. Uncorrected vs. corrected discrepancies for the period B. Lost-time injuries and illnesses

C. Severity of injuries and illnesses D. Performance compared to other periods

E. Performance compared to other companies, same industry, or similar operations

4. Employee involvement

A. Safety meetings and on-site safety briefings B. Inspections, evaluations, job hazard analyses C. Training and certification

(Continued)

4.4.4 eMergency prepAredness progrAMs

Even though we hope we never have to respond to accidents or other emergencies, it is important (and mandated by OSHA and EPA regulations and local laws in the United States) to have emergency preparedness plans. The emergency preparedness plan is an outgrowth of the system safety process. After conducting hazard analy-ses, the company-planning group (in concert with local authorities, such as police, fire, and emergency medical services) should take steps to prevent accidents, com-municate risks to the public, and develop an emergency plan. Once the system has been well analyzed, the company can take that information and develop emergency response plans to mitigate any mishaps that could create hazardous situations to people and the environment. The emergency preparedness plan is exactly what it states—a plan of action developed a priori to any emergency to detail exactly what is to be done in the event of different accident scenarios. The plan is a stand-alone document, but its process is part of the system safety process. If the system safety process has changed, then the plan should be reviewed and appropriately updated.

A typical emergency response plan should include 1. Introduction

2. Policies and interorganizational agreements 3. Emergency telephone list

4. Response functions 5. Containment and cleanup 6. Documentation

7. Procedures for testing and updating plan 8. Summary of safety analyses

9. Resources and references 10. Emergency procedures

a. Preparation b. Initial response TABLE 4.7 (Continued)

Evaluation and Effectiveness Criteria Checklist for Safety Programs

Satisfactory/

Unsatisfactory Comments 5. Motivational and promotional projects/participation

A. Awards and recognition B. Seasonal campaigns C. Bulletins and newsletters D. Management communications 6. OSHA compliance

A. OSHA citations, serious violations, penalties B. OSHA log, poster

Source: National Aeronautics and Space Administration, Johnson Space Center safety manual, JSCM 1700D, National Aeronautics and Space Administration, Houston, TX, 1985, 1-13-4.

c. Assessment/response by emergency response personnel d. Decision-making aids

e. Hazard control f. Support operations g. Emergency care h. Extrication

i. Evacuation j. Debriefing

k. Restoring normal operations

Usually, companies publish under separate cover the actual emergency procedures that employees are to follow in the event of an accident. These are step-by-step instructions that employees are to follow in order to respond safely to the emergency.

The emergency procedures are located at the worksite and should be practiced at least annually, and the entire emergency program should be reviewed every 3 years.

PRACTICAL TIPS AND BEST PRACTICE

Some important ideas to remember when developing an emergency prepared-ness plan are the following:

• Include not only plant engineers but also public officials and local community representatives in your planning.

• Document the entire emergency planning process.

• Review and update periodically.

• Contact local equipment rental agencies to have the necessary type of cleanup equipment accessible at a moment’s notice.

• Develop a clear line of authority for handling the emergency response, cleanup, and return to normal operations.

• Develop a quick phone list of emergency contact phone numbers (including home phone numbers) for emergency response units, com-pany officials, state and federal regulatory agencies (e.g., EPA), and plant engineering managers.

• Practice and test the emergency procedures and conduct self-critiques on a regular basis.

• Contact other plants near you that may be affected by any accident you may precipitate and, likewise, any accident they may cause that could impact you.

• Develop your emergency response plans together, sharing resources whenever possible.

• Review emergency power systems and communication systems to ensure that if utility services are lost you are still in a safe situation.

• Include public information and community relations in your planning.

• Review the plan to ensure that there are adequate protective actions in place for the public.

Remember, if you have not conducted a methodical safety analysis of your process, it is impossible to be sure that you have an adequate response to the most likely types of emergencies.

It is important to mention that many companies have started to implement busi-ness continuity management programs. These programs are to help the company prepare, respond, and recover through significant business disruptions including accidents. The ISO 22301, Business Continuity Management Standard, is designed to help companies recover vital business functions during or after a crisis. Obviously, emergency response plans for safety would be a subset of business continuity. ISO 22320:2011, Societal Security—Emergency Management—Requirements for Incident Response, is an international standard of how to respond to any kind of emergency—terrorist, natural disaster, or accidental.

4.4.5 c^Ase s^Tudy: h^oWA L^eAding g^LoBAL p^ersonAL c^Are p^roducTs c^oMpAny c^reATedA B^esT p^rAcTice s^AfeTy p^rogrAM

Share price was high, the company was respected, the corporation took safety seri-ously, and had a decent safety record. Then an accident occurred in one of the fac-tories, and corporate leadership was shocked that it could even occur. Luckily, no one was killed, though several were severely injured. The global company took the wake-up call seriously and decided to act upon it. In brief, this is their story.