Emergency/Crisis Management Planning needs vary with the industry, type of operations, and regulatory applicability; however, the following guidelines can be used for any situation:
WHAT ARE YOUR HAZARDS?
The first step is to Identify vulnerabilities and hazards associated with your operation. No one understands your operation better than you. Ensure that emergency, business continuity, and security issues are considered and use this analysis to prioritize your plan development efforts.
- You should consider the following topics, at a minimum:
- What are your vulnerabilities to natural disasters? Depending on the geographic scope of your operation, you may be subject to hurricanes, earthquakes, tornadoes. floods, ice storms, or all of these.
- How would your company continue to operate in the midst of a pandemic situation?
- What are the hazards introduced by your operation, and who may be impacted from a fire, release of hazardous material, oil spill, or explosion? Consider various events involving similar types of operations involving other entities, not the fact that it may have never happened in yours.
- In the event that your primary or corporate office becomes uninhabitable due to a fire, flood, hurricane, earthquake, power failure or other event, could your company to operate?
- What are your security vulnerabilities?
WHAT TYPE OF PLANS SHOULD BE DEVELOPED AND AT WHAT LEVEL?
The next step is to use the results of the Hazard Analysis performed above, and determine what plan types should be developed, and which should be developed on a facility level or corporate/enterprise-wide level. For instance, site-specific fire pre-plans may be valuable for buildings and storage tanks that contain flammable contents; business continuity plans may be applicable at the corporate level.
Example programs may include the following:
FACILITY LEVEL PLANS
- Emergency Response Plans (industrial operations), Emergency Operations Plans (hospitals, schools and universities), Emergency Action Plans (office building) describing site-specific initial response and activations procedures for potential hazards.
- Fire Pre-Plans for buildings and process equipment, if applicable.
- SPCC, OPA 90 Plans, RCRA Contingency Plans, SWPPP and other regulatory plans for facilities that store oil.
- Crisis Management Plans describing corporate procedures for supporting operational emergencies, and for responding to corporate crises, including security, product liability, financial and other reputation issues.
- Business Continuity Plans for corporate and regional offices
- Pandemic Plans (often included as a subset of Business Continuity Plans)
HOW SHOULD THE PLANS BE ORGANIZATION AND WHAT IS THE APPROPRIATE LEVEL OF DETAIL?
Identify applicable regulatory requirements and ensure that your program addresses them, but remember that the primary purposes of the plans are to enable your company to respond effectively, and in the process, to ensure compliance. A common mistake is to organize plans specifically to meet the order of the regulations, when in fact, this may not result in the most logical or user-friendly format. Keep in mind that some regulations require a specific plan format or order of content, however, in many cases there is flexibility to organize the plan differently, as long as a regulatory cross-reference is provided and clearly identifies where each requirement is addressed.
Develop plans in a logical format that will be intuitive to responders who may not have had time to review them or training. A good test is to provide the plan to someone outside the organization and find out how long it takes for them to find key response information.
Ensure that plan content is comprehensive enough to provide tools needed for a response but is not so detailed that it reduces the effectiveness of the plan and results in more plan maintenance than necessary. Consider providing references and/or hyperlinks to detailed technical or regulatory information that may be needed but is too detailed to include in the plan.
Develop the content in a streamlined format with the goal of reducing the time required to read it. Bullet points and checklists are favorable to paragraphs of information.