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SHEEN INDIA PRIVATE LIMITED

(APPLICABLE TO SHEEN & ITS ALL SISTER CONCERNS)

EMERGENCY

&

DISASTER PREPAREDNESS PLAN

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Table of contents

1. Emergency Preparedness Plan 1.1. Introduction 1.2. Policy 1.3. Purpose 1.4. Structure 1.5. Scope 1.6. Definitions 1.7. Communication

1.8. Emergency Preparedness & response plan 1.9. Training of personnel in emergency procedures 1.10. Evacuation procedure a) Immediate b) Planned c) Evacuation Areas 1.11. Performance standards 1.12. Annual Evaluation

1.12.1 Evaluation of objectives of the plan 1.12.2 Evaluation of scope of the plan

1.12.3 Evaluation of Emergency Preparedness Training 1.12.4 Evaluation of the performance of plan

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1.12.5 Evaluation of the effectiveness of the plan

1.12.6 Conclusion & recommendations for the next year. 2. Hazard vulnerability analysis

3. Emergency preparedness procedure & response plan 3.1 Introduction

3.2 Emergency preparedness procedure & fire

3.2 emergency preparedness plan & natural disaster 3.4 Emergency preparedness plan & spills

3.5 Emergency water supply 3.6 Emergency electrical supply

3.7 Emergency preparedness evacuation 3.8 Emergency preparedness staff training 3.9 Emergency preparedness plan drill

3.10 Emergency preparedness activation - Evaluation Form 4. Chief compliance officer & CMT

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1

. EMERGENCY PREPAREDNESS PLAN

1.1 INTRODUCTION

This emergency response plan has been developed for the company to comply with OSHA standards. It will be used in all emergency situations which may occur in this facility. Generally this plan will cover emergencies such as fires, medical emergencies, accidents, chemical, natural disasters and other

emergency situations requiring the orderly evacuation of this facility etc.

This plan is reviewed annually & updated as necessary.

A full evacuation drill covering all facility employees will be held once in a year.

All new employees will be thoroughly instructed about this plan & its procedures at the time of inductions.

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EMERGENCY PREPAREDNESS PLAN

1.2 POLICY

SHEEN will establish & maintain an Emergency Preparedness Program designed to manage the consequences of natural disasters or other emergencies that disrupt the factory to provide care.

1.3 PURPOSE

Uncertainties’ are always there. To conduct business normally, it is important for the company to have a strategy on preparation for such emergencies or uncertainties. This plan must provide a organizational structure so that the SHEEN can effectively prepare for both internal & external disasters that can negatively affect its environment.

1.4 STRUCTURE

SHEEN

with the enactment & adoption of this policy is ready to assist as needed in case of any emergency, and as appropriate integrates its Emergency Preparedness Plan with community disaster plans, as appropriate, to support the response to a disasters or any contingencies. SHEEN will train its

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1.5 SCOPE

The scope of this plan, both external and internal, will determine the role of the SHEEN its personnel in responding to an emergency. SHEEN will conduct at least two emergency preparedness drills per year as required by JCAHO standards.

The compliance team will tailor the factory specific Emergency Preparedness Plan using the corporate template.

This plan contains process for preparedness, response, mitigation and recovery in the event of an emergency. Mitigation activities are those an organization undertakes in attempting to lessen the severity & impact a potential disaster or emergency may have on its operation while preparedness activities are those an organization undertakes to build capacity & identify resources that may be utilized should a disaster or emergency occur.

The first step in preparing an effective emergency plan is to preparedness plan is to prepare HAZARD VULNERABILITY (HVA). This analysis assists the organization in determining where it is most vulnerable to emergencies. Completion of the HVA is the organizations first step in the development of mitigation strategy.

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1.6 DEFINITIONS

EXTERNAL DISASTER: A civil catastrophe, either manmade or caused by an ACT OF GOD. This condition can occur as a result of fires & explosions, storms, civil disorders, multiple injury accidents, military action or may be other causes.

INTERNAL DISASTER: An event such as a fire or explosion resulting in internal causalities or circumstances. If the situation requires the evacuation of employees, such evacuation will be coordinated with emergency service

personnel from the fire & police agencies.

It is the responsibility of the Factory Manager/ Compliance Team/ or SA Representatives to activate the Emergency Preparedness Plan.

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1.7 COMMUNICATION

All communication, both within & outside the units, will be coordinated through the hr department or as directed by the management or compliance team. For this purpose different ways are used like telephones, alarms etc.

RADIOACTIVE OR CHEMICAL ISOLATION AND DECONTAMINATION If an occurrence involves radioactive materials or hazardous chemical spills requiring outside assistance, the Chief Compliance Officer & crisis management team will contact the licensed & certified waste contract provider. State

radiation safety authorities will also be contacted in accordance with state law. DISRUPTION OF SERVICES AND MANAGEMENT OF SPACE, SUPPLIES, COMMUNICATIONS & SECURITY

If the portion of the effected unit is incapable of employee care but total evacuation is not required, the following procedure will be followed:

Space allocation: Employee will be settled in unaffected areas of the unit that are able to safely provide services.

Supplies: The factory manager or his team will be immediately notified of any situation that necessitates an increased level of supply items. The existing supply areas will be automatically used to provide supplies to the extent possible.

Communications: Both the phone system & cell phone will be used to provide communications between the effected units & outside agencies. Security: needs that might exceed the capability of units will be relayed to the local police department or contracted security service.

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1.8 EMERGENCY PREPAREDNESS PROCEDURES & RESPONSE:

This is an important step while planning. An employer must have an emergency procedures & response plan for an emergency that may require the rescue or evacuation of workers.

DISASTER PROCEDURES FOR STAFF/WORKERS MEMBERS In the event of either internal or external disaster, the Chief Compliance Officer, or the crises management team can initiate the disaster call list. On arrival at the units staff members will report to their respective supervisors to log in and be assigned to whatever tasks are required: in preparing for evacuation, or other assignment.

If a regular work shift ends during the declared emergency period, all staff members will stay at their respective assignments until officially relieved by order of the designee. All staff members will report changes of address & telephone numbers, as well as their response time to the unit, to the Chief Compliance Officer as soon as change becomes effective. The personnel coordinator will continually update the Disaster Call List. & provide it to the Factory Manager, Chief Compliance officer, and other designees.

The manager, in charge or designee will verify that personnel are assigned to call the staff members listed on the Disaster Call List expediently.

These assignments will be conducted by identified staff members available for this task until the emergency ends.

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MANAGEMENT OF EMPLOYEES/WORKERS IN DISASTER SITUATIONS If a disaster or an emergency involves there staff members/workers, all less-than-essential services will be temporarily modified or discontinued until the situation allows for resumption of full program ability.

The chief compliance officer or his or her designee will determine whether these less-than- essential services are to be effected and, if so, when.

Staff members normally involved in provision of services determined by the factory manager or compliance officer to be less than essential will make themselves available for other duties. These duties may include helping move injured from the affected area of hospital or to an unaffected section.

1.9 TRAINING OF PERSONNEL IN EMERGENCY PREPAREDNESS PROCEDURES

For the quick response, All SHEEN personnel are made familiar with the disaster, fire, and emergency plans & procedures during the induction or orientation processes. This helps the personnel to react accordingly.

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1.10 EVACUATION PROEDURE

a) IMMEDIATE EVACUATION

First move employees and others who are closest to the danger. Separate an emergency area from people by a fire door.

Move company records with employees, if possible. – In event of fire, do not use elevators. Lead employees to exit using the evacuation plan posted in the area.

Move disabled and helpless employees down evacuation route by means of emergency carries.

Notify the local police, fire department, hospital etc. depending upon nature of emergency

b) PLANNED EVACUATION

Planned evacuation will be initiated by the Factory Manager or Crisis Management Team only. The telephone operator or a runner will notify the modalities or services of need, extent & timeframe of the evacuation.

c) EVACUATION AREAS

The area already marked as assembling area lot will be designated evacuation area except that in inclement weather or that area been unsafe the Chief Compliance Officer or Crisis Management Team will indicate a secondary evacuation area.

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STAFF/WORKER & THEIR FAMILY SUPPORT ACTIVITIES

This plan acknowledges that the staff of this organization its greatest asset. If staff/workers or their fairly members are directly impacted by a community emergency or disaster, the SHEEN leadership will be sensitive to this and attempt to ameliorate this. Support of impacted staff & families may include referrals to disaster relief organizations & referrals for incident stress debriefing, The Factory manager will be available to discuss any staff/workers or family needs based on family impact on community emergency or disaster.

1.11 PERFORMANCE STANDARDS

Performance standards for this plan will include:

Emergency preparedness knowledge and skill for staff. Completion of one emergency preparedness drills.

The level of staff participation in emergency preparedness management. Monitoring and inspection activities which include Emergency & incident reporting procedures that specify when and to whom reports are communicated.

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1.12 ANNUAL EVALUATION

An annual evaluation of the Emergency Preparedness Plan undertaken at the units will include performance measures, using the previous year’s quarterly reports; recommendation from the corporate governance; and input from staff and other relevant sources of safety outcome safety. This evaluation will include statistical trends. These reports will be presented to and or discussed with the management.

The SHEEN leadership will prioritize opportunities for improvement in this function.

Annual evaluation of the Effectiveness of the Emergency Preparedness Plan Instructions:

The Chief compliance officer and or CRISIS MANAGEMENT TEAM facilitate an interdisciplinary team of subject matter experts in evaluating the effectiveness of this plan during the past year.

The report will be made on the fact finding or the qualitative analysis to support its conclusions. The report should be completed within 30 days of the beginning of the year. It should be submitted within 45 days of the beginning of the year to the top management for approval.

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1.12.1. EVALUATION OF THE OBJECTIVES OF THE PLAN

Effectiveness of the Emergency preparedness Plan has been decided through comparing actual findings with the objectives. Objectives of the Emergency Preparedness Plan are:

Objective A: Establish an Emergency Management Program to provide an effective response to disasters or emergencies affecting the environment.

Objective B: Drills are conducted once in a year.

1.12.2. EVALUATION OF THE SCOPE OF PLAN:

Did the scope of the plan effectively include all the operations of the unit or units including implementation of procedures in response to disasters: role with communitywide emergency preparedness efforts: notifying external authorities; assigning personnel; managing space, supplies, and security; evacuation, if needed; alternated sites for care; managing employees; operating the backup communication system; and orientation and education of staff.

1.12.3 EVALUATION OF STAFF EMERGENCY PREPAREDNESS TRAINING List types of Emergency Preparedness Training that occurred, number & percentage of staff who received training, specific outcome scores of post-testing, and supervision observations after training.

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1.12.4. EVALUATION OF PERFORMANCE OF PLAN

How successful was the unit in meeting its emergency preparedness related performance standards for the year?

What was the most significant safety accomplishment of the plan last year?

1.12.5 EVALUATION OF EFFECTIVENESS OF PLAN

How effective was the plan in preparing the units for internal & external disasters?

1.12.6. CONCLUSIONS & RECOMMENDATIONS FOR THE PLAN FOR THE NEXT YEAR

What are the most important recommendation areas of emergency preparedness for the plan to address during the next year?

Have any financial resources been asked for or committed to any of these recommendations?

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2. HAZARD VULNERABILITY ANALYSIS

This analysis prepared before the survey to support the design of the emergency preparedness plan).

Evaluate every potential event in three categories:

Probability: Includes known risk, historical data etc.

Risk: damage or failure possibilities, threat to life, disruption of services,

etc.

Preparedness: status of current plan, insurance, training status,

awareness etc.

MULTIPLY THE RATINGS FOR EACH EVENT IN THE AREAS OF PROBABILITY, RISK & PREPAREDNESS. THE TOTAL VALUES IF COMES UNDER THE CATEGORY OF HIGH THE MOST IN NEED OF FACTORY & RESOURCES FOR EMERGENCY PLANNING.

HIGH MED LOW NONE PROBABILITY RISK PREPAREDNESS TOTAL NATURAL EVENTS

HIGH: ABOVE 20 MED: ABOBE 10

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LOW: ABOVE 05

3. EMERGENCY PREPAREDNESS PROCEDURES

& RESPONSE

3.1 INTRODUCTION

An employer must have an emergency procedures & response plan for an emergency that may require the rescue or evacuation of workers. The plan establishes what the employer must do until emergency services personnel arrive.

How to react or response in emergency situation is the purpose of such plans & effectiveness of such plan depends on the responsiveness of people.

At Sheen, emergency preparedness plan hedge against such contingencies or uncertainties.

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3.2 EMERGENCY PREPAREDNESS & RESPONSE PLAN & DRILLS

These DRILLS are conducted once in every month. The drills may involve evacuations caused due to false fire alarm or any other such alarm to check the alertness of the employees.

POTENTIAL EMERGENCY FIRE EMERGENCY

PROCEDURE In the event of a fire occurring within or affecting the work

site, the security guard(or deputy) decides and ensures the appropriate key steps are taken:

pull the fire alarm to alert the nearest fire station and initiate all fire alarms within the building

evacuate all persons to a safe point in the staff parking lot and account

Appointed person will ensure that whole persons had left the affected area.

EMERGENCY EQUIPMENT Fire alarm Fire extinguisher Fire hose reel

EMERGENCY RESPONSE TRAINING REQUIREMENT

TYPE OF TRAINING FREQUENCY Practice Fire drills

Training regarding use of fire extinguishers.

ONCE IN A MONTH ONCE IN A MONTH

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Feedback concerning any type of drill conducted will be reviewed by the crisis management team for necessary actions.

For each drill, preparedness & employee management will receive specific attention to evaluate the effectiveness of the policy & implementation of policy by personnel.

3.3 EMERGENCY PREPAREDNESS & RESPONSE PLAN & disaster management

POTENTIAL EMERGENCY NATURAL DISASTER

EMERGENCY

PROCEDURE In the event of a NATURAL DISASTER occurring within or affecting the worksite, EMPLOYEE/WORKERS ensures the appropriate key steps are taken:

BEFORE

Make sure that you have disaster plan.

Give your factory an earthquake checkup.

Practice drills with employee.

Familiar yourself with the warning signs. Listen to emergency radio, news.

DURING

Be alert

Get Under Something Sturdy or Find an Open Space

Shield yourself or take shelter under sturdy furniture

If you're indoors, try to stay clear of obvious hazards like windows, hanging fixtures, shelves, or

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anything that's already loose and might collapse. If you're at your desk, get under it.

"Unless you feel your current location is particularly hazardous, don't attempt to move to another room or evacuate outdoors,"

EMERGENCY EQUIPMENT

EMERGENCY RESPONSE TRAINING REQUIREMENT

TYPE OF TRAINING FREQUENCY

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3.4 EMERGENCY PREPAREDNESS & RESPONSE PLAN & spills

POTENTIAL EMERGENCY SPILLS EMERGENCY

PROCEDURE In the event of a SPILLS occurring within or affecting the worksite, responsible person decides ensures the appropriate key steps are taken:

Hazardous work in the all areas will be shutdown until the area is safely restored.

Get information or identified Is anybody injured?

Type of material that has spilled.

Whether this involved fire. In that case: Take immediate actions

Eliminate all possible source of ignition.

Immediately set up a barrier to alert unauthorized personnel to keep out, if evacuation is not occurred.

Use personnel protective equipment. Use firefighting equipment.

Remove injured personnel & provide medical treatment

EMERGENCY EQUIPMENT Hand gloves mask

Fire extinguisher

Personnel protective equipment

EMERGENCY RESPONSE TRAINING REQUIREMENT

TYPE OF TRAINING FREQUENCY

Chemical handling & usage training

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3.5 EMERGENCY WATER SUPPLY DRINKING WATER

If the unit’s drinking water supply is contaminated or unavailable, the Chief Compliance officer determines that it is appropriate for the units to remain open or open for just the day, additional bottled water will be available.

3.6 EMERGENCY ELECTRICAL POWER

If the units electrical power supply is compromised or unavailable, the Chief Compliance officer, its designee, maintenance will determine whether units should remain open or should open for just the day. The first option in unavailability of electricity is diesel generator.

Here, AT SHEEN we have facility of generators which have a big capacity.

3.7 EMERGENCY PREPAREDNESS EVACUATION PROCEDURE

When evacuation of employees from threatened or affected areas of the unit is required, safety of lives is the primary concern. Therefore the evacuation must be carried out as quickly & efficiently

Practice Fire drills Training regarding use of fire extinguishers.

Once in a month Once in a month

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Authority to evacuate

Authority to order evacuation is vested to the Chief Compliance Officer & Crisis Management Team.

The chief compliance officer or CMT or his/ her designee is responsible for shutting down the Air Conditioning, Heating, and other utilities to all or part of the facility.

Reasons of Evacuation

All employees will be evacuated in the event of Disruption or discontinuance of services. Fire

Power outage or other calamity that causes damage to the facility or threatens the safety & welfare of employees.

Natural disaster of such magnitude or threat that it endangers the safety & welfare of staff/workers.

Procedure for Evacuation of Employees

Technologists, under the direction of the employees or his or her designee, will supervise aids in preparing employees to be evacuated. Employees will be evacuated to an area of safety by whatever means are available, and provision will be made for employees comfort or safety.

Announcement has been done for evacuations.

An Evacuation route and assembling place are same as that for fire evacuation. The fire evacuation routes as designated by maps posted throughout the building will be followed.

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3.8 EMERGENCY PREPAREDNESS STAFF TRAINING POLICY

All employees will receive specific training at least annually in their individual during either external or internal disasters.

PROCEDURE

The CMT is responsible for the emergency preparedness training for the workers/employees or other trainings related to emergency.

The CMT is responsible for the content of the training to ensure that all employees know their roles as outlined in the Emergency Preparedness Plan. It is the responsibility of the CMT & Hr Department to ensure that this training covers all employees annually and to obtain appropriate document.

Training will include following things

Safety, roles & responsibilities during emergencies.

The information & skills required to performed duties during emergencies. The backup communication systems used during disasters & emergencies.

How supplies & equipment are obtained during disasters & emergencies. Other trainings:

Fire training

First- Aid training.

Evacuation training & use of personnel protective equipments. Chemical handling & usage training.

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3.9 EMERGENCY PREPAREDNESS PLAN DRILLS

Implementation of the Emergency Preparedness plan will be conducted once in a month. Either in response to an emergency or as a plan drill. Otherwise fire drills are conducted in every month.

PROCEDURE

The chief compliance Officer, CMT & HR department has the responsibility to develop the scenario & disseminate the necessary information to employees. The time & other details concerning the disaster will be controlled by the CMT. All emergency preparedness drills or actual occurrences will be critique by the Chief Compliance Officer & CMT and reviewed & evaluated at the meeting.

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3.10. EMERGENCY PREPAREDNESS PLAN ACTIVATION – EVALUATION FORM

PURPOSE:

The integrity of the Emergency Preparedness Plan requires the units experienced during drills or actual disasters to be analyzed & opportunities for improvement are identified.

PROCEDURE:

The CMT will complete an Emergency Preparedness plan Activation- Evaluation Form for drill.

The CMT will present to Chief compliance officer to permit identification of immediate opportunities for improvement. If opportunities are identified, the Chief compliance officer will implement them.

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EMERGENCY PREPAREDNESS ACTIVATION – EVALUATION FORM

Date: Time: Disaster Type:

Activation of Emergency

Preparedness Plan was activated: How was the plan activated?

Where were the following areas located? First Aid

Communication with outside agencies: Police:

Fire:

Method of communication: Damage Assessment:

Was a damage assessment made? Injury Assessment:

Was anyone within the facility injured? If yes, explain:

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4.

CHIEF COMPLIANCE OFFICER

&

CRISIS MANAGEMENT TEAM

CHIEF COMPLIANCE OFFICER: Ms. Vibha Pandey

Following are the members of Crisis Management Team:

Mr. N.S. RANA Mr. NIKHILESH Mr. VASEEM Ms. SWATI RAWAT Ms. SONU JOSHI Ms. SEEMA RANI

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5. EMERGENCY NUMBERS (आऩातकारीन नम्फय)

Chief Compliance Officer (भुख्म अनुऩारन अफ़सय): 09910149337 HR Department (भानव संसाधन ववबाग): 111, 112, 113, 114, 115 Mr. Nikhilesh (श्री ननखिरेश): 0965427603 Sh. Munish श्री भुनीश (ससक्मोरयटी इंचार्ज): Police helpline (ऩुसरस हेल्ऩराइन): 100 Ambulance (एम्फुरेंस): 102 Fire (पामय): 101

Police station sector 20, sector 18 (ऩुसरस स्टेशन सेक्टय 20, सेक्टय 58): 2523102/ 2580412/2514750

Bomb Disposal Squad (फभ डिस्ऩोर्र स्क्वाि): 2522340

ESI Hospital (इ. एस. आई. अस्ऩतार, सेक्टय 11) 2411338/ 2411350 प्रकाश अस्ऩतार स्स्ित आऩातकारीन िॉक्टय: 2505264

References

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