Contained Response: Environmental Emergency Planning

Article excerpt

Responding to an environmental crisis can pose a serious challenge for any organization. Research has revealed that less than 50 percent of U.S. companies hit by a disaster recover. Of the total, only 20 percent have complete disaster response and recovery plans in place.

There is little doubt that risk managers need to be involved in the emergency planning and response process. Risk managers must perform the vital analyses and identify the necessary steps to help their organizations respond effectively. Even if the organization believes it has appropriate plans, it is important for every risk manager to review its emergency policies and procedures to ensure that they continue to meet current needs.

Natural disasters and acts of terrorism have heightened awareness of the importance of emergency planning, and effective response plans are especially important for coping with environmental disasters. Plants that either produce hazardous materials or generate toxic byproducts must be prepared for potential disasters ranging from spills that can be contained quickly to fires or leaks that can affect the surrounding community.

In fact, disaster plans are mandated in the United States. The Emergency Planning and Community Right-to-Know Act (EPCRA) spells out a structure that emergency plans must follow. According to the regulations, the following elements must be included:

* identification of facilities and transportation routes that contain hazardous substances

* emergency response procedures to be used on the site and surrounding areas

* identification of personnel designated as the community and facility coordinators responsible for implementing the plan

* procedures for notifying authorities and potentially affected parties

* methods for determining when a release has occurred and the probable area (and population) that could be at risk

* descriptions of the emergency equipment and facilities available in the community

* plans for evacuating facilities and potentially affected areas

To ensure that all regulatory requirements are fulfilled, periodic environmental compliance audits should be conducted at key facilities. Through the use of third-party environmental engineering firms or in-house risk management expertise, these audits will either confirm compliance or indicate areas that need to be corrected. The risk manager can then work with facility management to develop action plans for resolving any compliance issues.

Community Notification

The EPCRA regulations, also known as Title III of the Superfund Amendments and Reauthorization Act (SARA), are designed to aid emergency planning efforts at state and local levels. Title III provides a legal platform that helps residents and local governments obtain information about possible chemical hazards in their communities.

The act has three subtitles that deal with local emergency response planning; disclosure of information on hazardous chemicals on a site-specific basis; and general provisions regarding trade secret protection, enforcement, citizen lawsuits and the public availability of information. SARA's reporting requirements for hazardous chemicals can be considered "right to know" information: who has chemicals, what those chemicals are, where they are stored and what potential effect they can have on the public health.

Under the act's Subtitle A, a facility using hazardous substances must identify, itself to the environmental protection commission of the state in which it is located and provide government representatives with information about the facility's emergency response plan. In addition, the organization must designate a "facility emergency coordinator," who is required to report any relevant changes to the commission.

Section 304, titled Emergency Notification, addresses the need for communities to be warned about chemical emergencies. …