Testing Emergency Response Procedures – what is required?

Many clients struggle with knowing when and how to “test” emergency response procedures. ISO 14001:2015 element 8.2(d) (previously 4.4.7) requires organizations to “periodically test the planned response actions, where practicable…..”.  The word periodically should not be interpreted as “whenever we feel like it” but means to be completed over a specified period of time.

Emergency preparedness can be broken down into three (3) distinct phases – planning phase, training phase and testing phase.  The planning phase is where we identify potential emergencies that can impact the environment and develop “planned response actions” or procedures.  Procedures identify responsibilities, available resources, and planned activities.  Typical emergencies may include chemical spills, fire, equipment malfunction, or power outages.

The training phase is where we communicate to personnel their responsibilities should the event occur and an orientation to the available resources – spill kits, alarms, etc. This training should also be completed on a routine basis and records of training maintained.

The “testing” phase is where things become a bit ambiguous. The goal of testing emergency procedures is to determine the EFFECTIVENESS of the planning and training phases and to determine if personnel with respond appropriately. To the extent possible, the testing should be independent of planning and training. Each type of procedure should be tested.  So simply doing an evacuation drill does not satisfy this requirement.

Methods of testing spill response procedures can vary greatly and the method selected should be in proportion to the spill risk at the facility. A facility whose largest likely spill is 55 gallons of oil may test their procedures differently than a site with 10,000-gallon isocyanate tanks or 50,000 pounds of ammonia.

Low risk sites may do something as simple as random interviews with employees and spill responders to determine their awareness of procedures and responsibilities.  Or impromptu deployment of spill responders to a likely spill location and reviewing a spill scenario with the team. Each year a different scenario could be reviewed. If you are relying on an outside response contractor you should contact them on a regular basis to verify that they would indeed respond to an emergency at your facility.

At higher risk sites with trained HAZWOPER trained spill teams more complex full deployment drills mat be warranted.  These types of drills may be done as part of your annual 8-hour refresher training and may include dawning PPE, spill cleanup, and decontamination.

These tests need to be documented.  The documentation should describe the spill scenario reviewed, team members present, the teams approach and performance cleaning up the spill, and any changes needed to emergency response procedures or equipment. Common findings are the evacuation alarms cannot be heard in all areas of the plant or the spill response materials are not maintained.

In addition to testing regular inspections of response equipment is needed to insure readiness.  This can include spill kits, personal protective equipment, shut off valve, drain covers, and alarms.

The overall goal is that in the event of an emergency the safety of personnel is protected and environmental impact are minimized.  Well-developed emergency preparedness can insure that both of these goals are achieved.

written by:
James Charles, PE
Senior ISO Consultant
James.Charles@ISO 14001-Training.com
(616) 666-5490

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