FM Issue: Manage The Challenge
By Bascombe J. Wilson, CEM and Howard F. Pierpont, CORM, CBM, CBCP, CRP
Published in the January 2010 issue of Today’s Facility Manager
It is a challenge every facility manager (fm) faces: How can a limited staff handle pressing demands for maintenance, construction, and repairs while still giving adequate attention to contingency planning and comprehensive emergency preparedness? Emergency preparedness for a facility is indeed a major challenge. However, it is a manageable one given the right strategy and process tools.
While every facility has specific considerations, a recommended starting point for creating a new plan or revising an existing one is to obtain senior executive support. A preparedness program should have three major goals outlined by comprehensive program elements or tasks. Following such a template provides both a starting point and a compass for the preparedness effort.
Goal: Mitigate hazards and activities that pose risks to life and health.
Key program elements:
1. Analyze adverse event history of facility, including events that were “close calls.”
2. Assess event history of neighboring facilities and similar facilities elsewhere.
3. Perform a vulnerability assessment on the facility, looking for security and safety issues.
4. Develop a hazard mitigation and risk management action plan based on the severity and likelihood of adverse events.
5. Obtain senior executive buy-in on the assessment and action plan.
6. Execute the plan, and perform frequent reassessments based on changing conditions.
Goal: Ensure compliance with laws and regulations regarding facility operations, contingency planning, community right-to-know provisions, and emergency response/reporting regulations.
Key program elements:
1. Conduct a comprehensive self assessment in the following areas and develop compliance plans:
a. Occupational safety and health
b. Environmental protection
c. Licensing and use permits
d. Emergency response/reporting
2. As a top priority for the organization, undertake a “get well” program to repair all deficiencies and to establish an ongoing compliance review process.
Goal: Develop a viable Emergency Action Plan and a Continuity of Operations Plan (more on these later).
Key program elements:
1. Focus on credible events (e.g., flood, weather, fire, malicious damage, infrastructure disruption).
2. Assess the costs and benefits of various preparedness and response strategies such as losing the facility and ceasing operations temporarily or moving staff and operations to another facility.
3. Develop a comprehensive Emergency Action Plan that provides for occupant emergency evacuation, personnel accountability, and an incident management structure.
4. Develop a Continuity of Operations Plan based on specific needs of the organization.
5. Obtain senior executive buy-in on the assessments and plans.
6. Execute the plans and conduct exercises, tests, and reassessment.
Identifying Hazards And Risks: Getting Started
Frequently, even facility professionals can be blind to hazards and risks in a familiar environment. One of the best ways to get started and glean a fresh perspective is to seek candid input from employees in all areas of the facility. In some cases, a full safety and security audit by credentialed specialists might be warranted.
Also, considerable information about hazards and vulnerabilities can be obtained from the fire department that supports the facility, the city/county office of emergency management, or the local emergency planning committee. These groups may be eager to assist.
Key Elements Of Emergency Action And Continuity Plans
In creating Emergency Action and Continuity of Operations Plans, there are certain components that should be considered typical. The table below outlines these components.
Comprehensive facility plans will incorporate most, if not all, of these elements while being tailored to local considerations. The Federal Emergency Management Agency (FEMA) provides several planning resources for business (www.ready.gov/business/index.html).
Legal And Regulatory Compliance
Legal and regulatory compliance issues can be complex, and certain situations require particular attention. For instance, in a facility where chemicals are stored or processed—even if it is only battery acid in backup power supplies, chlorine for swimming pools, or ammonia for refrigeration units—the facility may be governed by federal regulations as well as the state and local environmental, health, and safety rules that are in place.
The Emergency Planning and Community Right-to-Know Act (EPCRA), enacted in 1986, requires fms in many facilities to report the types and quantities of chemicals they store or use and to develop viable emergency response plans. The U.S. Environmental Protection Agency (EPA) provides guidelines for compliance with EPCRA at www.epa.gov/superfund/contacts/infocenter/epcra.htm.
EPA also regulates water and air pollution, and many facilities are fined each year for unwitting violations and unplanned releases during emergencies. In 2008 alone, 2,084 facilities were fined $38 million in administrative penalties and $88.4 million in civil prosecution penalties, while EPA obtained 319 criminal convictions resulting in $63.5 million in fines and prison terms for managers and executives.
Another source when dealing with compliance issues is the U.S. Occupational Safety and Health Administration (OSHA). The Administration provides a variety of facility compliance and workplace safety materials at www.osha.gov/dcsp/compliance_assistance/index.html. The OSHA Compliance Assistance Quick Start Tool is particularly valuable.
Testing And Evaluating Facility Emergency Plans
It is not enough to have a great plan sitting on the shelf. People need to know how to implement the plan in an emergency, and fms need to know of any weaknesses in the plan, so they can be fixed. The best way to accomplish this is to test the plan through exercises.
Exercises do not have to disrupt operations or cost a lot of money. The first exercise or two of a new plan can be as simple as a tabletop walkthrough of procedures with managers and supervisors focused on a discussion of how the plan would deal with various contingencies. After key staff members are familiar with their emergency response duties, the fm may elect to have a functional exercise in which various departments conduct a mix of actual and simulated activities in response to a scenario event.
In some cases, a full scale exercise may be warranted, which would involve nearly everyone in the organization. Full scale exercises often include supporting agencies, emergency responders from the community, and others who might be impacted by the simulated emergency. Full scale exercises usually take many months to plan, but they are useful for identifying and resolving organizational boundary issues, questions of jurisdiction, and other limitations that often do not come to light until the actuality of a crisis.
Putting It All Together
It may take a few weeks, or possibly many months, to put together emergency plans for a facility, but the process does not need to be painful. By encouraging all departments within the facility to participate in the planning process and to identify their vulnerabilities and needs during an emergency, an fm can serve to strengthen the internal support system and resiliency of the organization even before the first page of the plan is written. Completion of a simple to use planning document followed up with drills or exercises will help an fm establish an exemplary preparedness program.
Wilson (firstname.lastname@example.org) is a Certified Emergency Manager who serves as the Community Preparedness Program director for the Disaster Emergency Response Association (DERA), a nonprofit professional association and disaster support network (www.disasters.org). He recently retired from the Federal Emergency Management Agency (FEMA), where he was responsible for hazardous materials programs and related national preparedness projects.
Pierpont (email@example.com) is president and CEO for the Preparedness Institute (www.preparedness.org), a nonprofit research and educational arm of DERA. He is a Certified Business Continuity Professional and a Certified Organizational Resilience Manager. He is retired from Intel Corporation, where he was a Business Continuity Coach responsible for the worldwide engineering business continuity program office.