ISO 14001-Clause 4.4.7 Emergency Preparedness and Response
ISO 14001 Requirements
The organization shall establish, implement and maintain a procedure(s) to identify potential emergency situations and potential accidents that can have an impact(s) on the environment and how it will respond to them.
The organization shall respond to actual emergency situations and accidents and prevent or mitigate associated adverse environmental impacts.
The organization shall periodically review and, where necessary, revise its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations.
The organization shall also periodically test such procedures where practicable.
ISO 14001-Clause 4.4.7
Despite an organization’s best efforts, the possibility of accidents and other emergency situations still exits. Effective planning and preparation can reduce injuries, protect employees and neighbors, reduce asset losses and minimize production downtime. An effective emergency preparedness and response program should include provisions for assessing the potential for accidents and emergencies, preventing incidents and their associated environmental impacts , plans / procedures for responding to incidents, periodic testing of emergency plans / procedures and, mitigating impacts associated with these incidents. Consistent with your organization’s focus on continual improvement, it also is a good idea to review emergency response performance after an incident has occurred. This review can help determine if more training is needed or if emergency plans / procedures should be revised.The Standard requires that three components be addressed by the organization:
- Establish and maintain procedures to identify the potential for, and the response to, accidents and emergency situations, in order to prevent and mitigate the environmental impacts that may be associated with them.
- Review and revise the importance of learning from incidents. Obviously corrective actions will be taken and results of audits will be considered after the occurrence of accidents or emergencies or even ‘near misses’.
- Testing of emergency plans should be planned and the Standard indicates that periodic testing of such procedures should be carried out where practicable.
Establish and maintain procedures
An organization is well advised to draw up an ‘Emergency Plan’ and to consider different levels of disaster – including the worst-case scenario. The worst-time scenario should also be evaluated which can occur at times of shift change, weekends and holiday periods when staff may be reduced. The emphasis of such a plan will be placed upon ensuring that the business survives – that there will be the minimum of disruption of service, or supplies of product, to customers. Safety of individuals, staff and others will naturally be paramount but of course the environmental impact must be considered to address ISO 14001-Clause 4.4.7 The two factors safety and environmental impact can of course be interrelated for eg large volumes of toxic gases will cause environmental damage whilst posing a safety hazard at the same time. A suitable plan could cover:
- Identifying critical assets – usually major items of plant
- Defining the disaster team and describing responsibilities
- Emergency services – how to contact them
- Enforcement agencies – how to contact them
- Listing communications – including out-of-hours phone numbers
- Holding regular exercises – to test the system
- Setting up a media response team – details of who is responsible for contacting the media
Examining the function of the media response team further is worthwhile. It is tempting in the event of an environmental incident to offer no comment to the press. However, other parties, who may be hostile to the organization, will comment. This could be disgruntled neighbours, competitors and others who will take the opportunity to repeat rumours or provide media with exaggerated accounts of the incident. The media will find out, despite efforts to deter them. An attempt to hide issues will usually be uncovered later and will ultimately reduce the credibility of future communications. If, for example, there is a large spillage to a local stream or river with a high amenity value and the organization does not control the media input, the information any interested party receives may be inaccurate at best and hostile at worst. This could influence future relationships with the media. The news-gathering media work to strict deadlines and information is required from whatever source. It is best, therefore, that this source is the organization itself. Possible emergencies will most certainly have been identified during the preparatory environmental review and suitable responses formulated. At the simplest level of response, this may include a list of competent personnel who can be contacted with alternatives in the event of an emergency situation. Provision should also be made for off-site availability of the information needed to contain the disaster in case access to the site is denied on the grounds of safety. The main objectives of the fire service are to control the fire and/or chemical spillage and save lives. They may cordon off the site and prevent access to staff who require telephone numbers to make contact with other personnel, access to records or emergency procedures, etc. It is worthwhile noting that even if a fire situation is handled correctly by the fire service, environmental problems can be caused by contaminated water used by the fire services. Such water, contaminated by combustion products, may enter canals, streams and drains, and emergency plans should take this into consideration. It is also important to remember that just because risks are low, it does not mean that emergency plans are unnecessary. Without an emergency plan, minor incidents can escalate into major ones.
Review and revise the importance of learning from incidents
In the case of near misses it is important that such potential incidents are recorded and reviewed and not hidden away or merely forgotten. Such incidents indicate areas of risk which on other occasions may turn into
Testing of emergency plans
There may be situations where full-scale testing is not practical and thus consideration should be given to desk-top exercises that can be played out. Examples of such testing include:
- Can key individuals be contacted in an out-of-hours situation?
- If staff are injured can relatives be contacted?
- Are keys to certain areas (for example, solvent stores) available out of hours?
- Are vacations or absence due to sickness covered by alternative personnel?
- Can emergency services access the site – day or night?
- If there is ice on the road during winter would this prevent heavy vehicle access – fire-fighting equipment for example?
- Do the organization’s fire hydrants function correctly? Are they maintained and tested? Does the fitment on the hydrant fit the fire services hoses?
- Toxic gases may be released during a fire. If so, what are these gases? In which direction is the prevailing wind? What is the likely area that will need to be evacuated for safety as well as environmental reasons? What information will be given to the local police in such an event?
Test emergency scenarios at the shift change from day to night shift for example. During such shift changes there is an overlap as incoming staff come in early so that the outgoing staff may brief them as to events that have happened etc. Thus, for a short period of time, there could be double the number of people on site, causing extra congestion of roads, and lines of command may become blurred during this period. Some organizations ban the use of cellular phones during normal operations because of safety issues. Would staff be able to use them in an emergency?
If so, this should be written into the emergency procedure. Some organizations have wind direction indicators on site so that in the event of an emergency (fire or noxious fumes escaping), staff can move away in the safest direction. Test scenarios should ascertain whether such indicators can be seen visually from all points of the site. Some organizations have an incident centre that would reasonably be expected not to be influenced by a disaster i.e. underground or remote from flammable areas. Test scenarios should check whether this isolation is still valid.The time to put an emergency plan to the acid test and seek the answers to the above is not the day of the real event. Therefore, an organization should evaluate its risks of environmental emergencies and evaluate the extent to which it should carry out testing of its procedures.
Several environmental and health and safety regulatory programs require emergency plans and/or procedures. Look at what you have in place now and assess how well it satisfies the items discussed above. One area where additional work is often needed is on identifying the potential for accidents and emergencies. A team of site personnel from example from engineering, maintenance and Environmental Health and Safety) can identify most potential emergencies by asking a series of “what if” questions related to hazardous materials, activities, and processes employed at the site. In addition to normal operations, the team should consider start-up and shutdown of process equipment, and other abnormal operating conditions. Does everyone including new employees know what to do in an emergency? How would contractors or site visitors know what to do in an emergency situation? Communicate with local officials (fire department, hospital, etc.) about potential emergencies at your site and how they can support your response efforts.Mock drills can be an excellent way to reinforce training and get feedback on the effectiveness of your plans / procedures. Post copies of the plan (or at least critical contact names and phone numbers) around the site and especially in areas where high hazards exist. Include phone numbers for your on-site emergency coordinator, local fire department, local police, hospital, rescue squad, and others as appropriate.
- Has your organisation established, implemented and maintained a procedure(s) to identify the potential emergency situations and potential accidents that can have an impact on the environment?
- Are significant environmental aspects considered in the emergency preparedness and response procedure(s)?
- Does the procedure(s) cover how the organisation will respond to these situations?
- How do these procedures allow for the prevention and mitigation of the adverse environmental impacts that may be associated with actual emergency situations and accidents?
- How does the organisation periodically review and revise its emergency preparedness and response procedures, particularly after the occurrence of accidents or emergency situations?
- Have you periodically tested such procedures (where practicable)?
- Does your Emergency Preparedness and Response plan describe the potential emergency situations such as fires, explosions, spills or releases of hazardous materials, and natural disasters?
- Does your Emergency Preparedness and Response plan describe the hazardous materials used on-site and their locations?
- Does your Emergency Preparedness and Response plan describe the key organizational responsibilities including emergency coordinator?
- Does your Emergency Preparedness and Response plan describe the arrangements with local emergency support providers?
- Does your Emergency Preparedness and Response plan describe the emergency response procedures, including emergency communication procedures?
- Does your Emergency Preparedness and Response plan describe the locations and types of emergency response equipment?
- Does your Emergency Preparedness and Response plan describe the maintenance of emergency response equipment?
- Does your Emergency Preparedness and Response plan describe the training / testing of personnel, including the on-site emergency response team (if applicable)?
- Does your Emergency Preparedness and Response plan describe the testing of alarm / public address systems?
- Does your Emergency Preparedness and Response plan describe the evacuation routes and exits (map), and assembly points?
|Example of Procedure for Emergency preparedness and response|
Implementation document ( Not mandatory but helps in fulfillment of requirement):
|Example of EMERGENCY PREPAREDNESS PLAN|
|Example of Mock drill report|
|Example of Emergency Preparedness and response requirement matrix|
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