How Ready Are You for an Emergency?

The Plans, Policies, & People You Should Consider

Bad things happen to good companies and to their employees. Since September 11, 2001, U.S. businesses large and small have focused much more on emergency-response planning than perhaps ever in our history. But nearly 7 years after the tragic attack on the World Trade Center and other sites, questions remain. Is business responding appropriately? Do people know what to plan for, and how to do it? Should there be national standards for emergency planning? This Compliance Report addresses these and other issues.

Preparing for emergencies in order to reduce the potential for employee injury or death is a large and complex topic. This article breaks it down by reviewing OSHA requirements and recommendations, offering views of consultants in the field, and detailing best practices used by a business with a mature response plan in place.

What OSHA Requires

For most employers with more than 10 employees, OSHA requires a written emergency action plan (EAP) whose purpose is "to facilitate and organize employer and employee actions during workplace emergencies." According to OSHA, a well-developed plan and proper training will decrease the number and severity of injuries and help reduce structural damage to a facility during an emergency. "A poorly prepared plan," says the agency, "likely will lead to a disorganized evacuation or emergency response, resulting in confusion, injury, and property damage." At workplaces with 10 or fewer employees, the plan can be communicated orally.

The EAP should include at least the following components:

• Means of reporting fires and other emergencies,
• Evacuation procedures and emergency escape route assignments,
• Procedures to be followed by employees who remain to run critical plant operations before they evacuate,
• Procedures to account for all employees after an emergency evacuation has been completed,
• Rescue and medical duties for employees who are expected to perform them,
• Names or job titles of persons who can be contacted for further information or explanation of duties under the plan, and
• Review of the EAP when it is developed or an employee is initially assigned to a job; when the employee's duties under the plan change; and when the plan changes.

OSHA also recommends including the following:

• A description of the alarm system used to notify employees, including those with disabilities, to evacuate and/or take other action. The alarms used for different actions should be distinctive, such as horn blasts, sirens, or public address systems.
• The site of an alternative communications center to be used in the event of a fire or explosion.
• A secure on- or off-site location to store originals or duplicate copies of accounting records, legal documents, emergency contact lists, and other important records.

If you're wondering how well prepared you are, OSHA suggests evaluating your workplace in the following areas, all of which are covered by OSHA standards at 29 CFR 1910:

• Design and construction requirements for exit routes,
• Maintenance, safeguards, and operational features for exit routes,
• Emergency action plans,
• Fire prevention plans,
• Fixed fire extinguishing systems,
• Fire detection systems, and
• Employee alarm systems.

What a Consultant Recommends

Bob Coffey is a 20-year safety veteran who has worked in the pharmaceutical, chemical, manufacturing, and paper industries. As a consultant (WRCSafety.com), he frequently assists clients with emergency planning. Coffey offers several observations and related guidance. His first point is that employees need to be trained not just on what they're supposed to do, but on the why behind the action. The result, he says, is better understanding and compliance.

An example is the typical action plan that requires employees to gather outside at the flag pole, or other high-visibility location, in case of an emergency. But why? The common belief is that this gives the employer an easy way to account for personnel.

But beyond that, the purpose is to help protect firefighters on scene responding to the fire or other emergency. If firefighters believe that there are people inside the building, several may suit up and enter a burning building to find and rescue those inside. But if everyone is accounted for, firefighters may construct a defensive perimeter and fight from the outside.

Coffey offers another example that also relates to the gathering place. Many employees become frustrated or anxious, and just wish that they could get in their cars and drive home.

But the issue isn't simply that the person in charge doesn't wish to release people. According to Coffey, it's the need of the incident commander to get as much control as possible over the scene. "When employees don't understand what people on the ground are facing, they become frustrated," and understanding why something is required can reduce that frustration.

A hazmat spill provides a third example of Coffey's point. "Many people don't realize that you don't want to evacuate automatically in the case of a hazmat spill," he states. That's because of the possibility that in running away from the spill, one is actually running into a cloud of escaping chemicals.

Alternately, in the case of a spill, one might be safer in the center of a building, where heat and air conditioning units that circulate the chemicals can be turned off, rather than outside the building where residue is gathering.

Coffey also believes that in order to be effective, employee training should not overly burden employees. "If you throw more than three to five things at adults, you're likely to lose them," he recommends. He believes instruction and drills should focus on just a handful of requirements, but that these should be well understood and well practiced.

What a Business Does

The Lubrizol Corporation is a specialty chemical company that makes lubricant additives for engine oils, other transportation-related fluids and industrial lubricants, and fuel additives for gasoline and diesel fuel. The company also produces additives for personal care products and pharmaceuticals. Although the global headquarters in Wickliffe, Ohio, is not a major manufacturing site, Lubrizol's strong commitment to emergency readiness is in evidence at the 90-acre location.

We learned about Lubrizol's best practices for emergency response in a conversation with three safety leaders: Chuck Bartel, a volunteer firefighter and the company's emergency response supervisor; Steve Manchook, risk management specialist; and Jim Ruttinger, health, safety, and security manager.

They explained that the Wickliffe site, located just northeast of Cleveland, serves as a laboratory and pilot plant for testing new processes, as well as an administrative hub for the company, which operates 60 facilities worldwide. About 1,000 people are employed at the site.

Best-Laid Plans

A now-legendary story at Lubrizol comes up quickly in a discussion on emergency planning strategies. A routine training drill (large-scale drills that simulate various possible scenarios are held annually) was scheduled for September 11, 2001. This was to be a mock train derailment, and it would also inaugurate the company's new emergency media center. Until that time, Lubrizol had no dedicated communications command center, and an empty conference room had been permanently converted for the purpose.

Chuck Bartel recalls: "As I was preparing things in the center, a technician called and told me to turn on the television because a plane had run into the World Trade Center. I did, just in time to see the second tower get hit. Our full-scale emergency drill, which was to have included representatives from city and county agencies, was cancelled because everyone was hunkering down where they were."

The scuttled drill was rescheduled for March 22, 2002. This time, the simulated incident was to be a collision of a cargo van with a railroad car. Emergency planners had obtained containers of simulated chemicals and wrecked vans, which were placed on the railroad track that runs through the Lubrizol property. As was planned for September 11, local agencies including the local Red Cross were scheduled to participate.

On the morning of September 22, rain began to fall, but it soon turned to heavy snow and would not let up. The chemical barrels and other equipment amassed for the drill were buried under feet of snow and the rescheduled drill could not go on as planned. The story not only underscores Lubrizol's commitment to meaningful drills, but also reinforces the element of the unexpected in emergencies, and in emergency planning.

Drills are highly planned affairs using either "tabletop" strategy (performed in a conference room or office) or large-scale simulation of a variety of changing disasters, such as an auto accident, chemical release, or tunnel fire. The plant has invited a life-flight service to conduct a mock helicopter rescue, and the Red Cross has participated in victim response.

"The purpose of the exercises," says Manchook "is to keep our teams proficient, especially in interacting with the many agencies we would come in contact with, such as our city fire department, county hazard intervention team, and hospital." The question every drill asks is, "Is our training commensurate with the type of work we are expected to do?"

Right People in Place

At Lubrizol, two groups are critically important in emergency planning. The first is a team of 55 highly trained emergency responders, including fire-fighter/hazmat technicians and 25 EMTs. The responders, all volunteers, comprise an internal fire brigade that has a very close working relationship with the county fire department.

Explains Steve Manchook: "We have a very dedicated force. There is at least one responder per shift, and they are trained in incident command system (a standardized, on-scene management protocol)." Although there are typically more responders on first shift when more employees are duty, every shift is staffed.

Asked why the company chooses to fund and train its own internal brigade, Bartel explains, "We are the experts with the materials we work with." He says strong management commitment is another big advantage of a strong internal response program. Members participate in monthly training and, each summer, several travel to Texas A & M University, where Bartel is an instructor. They take a rigorous, 40-hour National Fire Protection Association (NFPA) certification course. Every year, Lubrizol invites a member of the local fire department to join its personnel for the course.

An important component in Lubrizol's response capability is the partnership between the response team and the site's security operation.

Asked to describe that relationship and why it's so important, Bartel says: "If we have to evacuate the building, we can count on security to be monitoring the cameras at their command center to verify, for example, if there is any smoke showing or if there's anyone who needs rescuing at the top of a building."

Also, during the practice drills, security personnel are invited on scene, and members of the emergency response team are posted at the security command center to observe the role of security in an emergency. This type of interface can make a significant difference during a "real" emergency, say the Lubrizol managers.

Another group that plays an equally significant role in preparedness is Lubrizol's emergency management team. This is a group of about 60 people-30 members and a backup for each-representing each of the facility's departments. Distinct from the emergency responders who actually answer the calls when something goes wrong, this is a team made up primarily of managers who lead other aspects of the response.

The team is divided into two primary functions-one is the management of technical aspects of the emergency, and the second is communications, including internal notifications and keeping media, families, and the community informed. Like the emergency responders, the management team is involved in drills and simulations. The group has its own operating manual; the plant manager chairs the group.

The commitment to readiness at Lubrizol is part of the company's overall risk management culture. Says Bartel: "All of this planning costs the company money, but they want us to maintain our emergency response capability, and they want us properly trained and equipped."

Got Some Work to Do?

Devoting time and resources to the anticipation of events that simply may never happen can be a tough sell to management in a tight economy. But the experts interviewed for this article concur that the return on investment is high, and the peace of mind is considerable when your business is best prepared for facing the worst.

Source: OSHA Compliance Advisor.

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