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The Value of Realistically Testing Your ERP
Weather radios are a common household item in my neck of the woods. I live in "tornado alley" and, every Wednesday, the National Weather Service conducts a test of the Emergency Broadcast System to ensure the alert system is working properly and ready for a real emergency. When Midwesterners hear the broadcast, "This is a test. This is a test of the Emergency Broadcast System," we understand the importance of testing and retesting; perhaps you remember the EF5 rated tornado that demolished Joplin, Mo., in 2011.
1. When was the last time your Emergency Response Plan (ERP) was tested?
While it is not feasible to conduct a test weekly like the National Weather Service, testing your ERP should be scheduled annually at a minimum. There are many components to an ERP, so you will want to make sure your test includes a quality plant-wide drill that evaluates your plan, your emergency response team (ERT), your crisis management team (CMT), and the NIMS/ICS system.
Most Emergency Response Plans read well on paper but have gaps that typically come to light only when a plant-wide drill is conducted to test the plan. To identify and measure the gaps in your ERP, the drill must be as real as possible. Planning, coordinating, and facilitating a realistic plant wide drill enables you to address any issues and make improvements or changes to the plan. The results of annual testing will help you ensure that your employees, contractors, and your community are kept safe in the event of a real emergency.
2. There is no "off the shelf" realistic plant-wide drill.
Each facility has its own emergency response specifics, as well as geographical area of Mother Nature disasters. When planning your plant-wide drills, write drills that test the different type of events that can happen at your facility: chemical release or spill, fire, explosion, tornado, hurricane, earthquake, workplace violence, high-angle/confined space rescue, etc. Often drill writers try to include too many emergency types in the drill, making it unrealistic. Including several of these in one drill is not a good idea; instead, pick the top three to five that are most likely to happen at your facility and plan a drill on one of those first.
3. A realistic plant-wide drill should average two to four hours.
Many times, companies conduct plant-wide drills that are over in 30 minutes to an hour. A plant-wide drill does not mean you have to stop plant production for two to four hours. For example, let's say your drill is a tornado; once everyone rallies at the tornado shelter and an accountability call is completed by your ERT, the employees not involved in the rest of the drill can go back to work. They may be involved for only 15 to 30 minutes of the drill. And you will keep certain employees in place to run the plant while the drill is in process so production time is not lost.
4. Emergency response drills need to be facilitated with realistic timelines.
Drill facilitators and evaluators should be in the plant in the Incident Command post and in the Emergency Operations Center (crisis management team area). These facilitators will give their inputs (details) of the scenario to the different teams involved. The facilitators in the Incident Command post and EOC will follow the drill script and give input as necessary according to the timeline of the drill script, such as when EMS, fire, and/or police have arrived, as well as other pertinent information.
Many drills require the ERT team to locate the injured (patients), treat their injuries, and, if needed, prepare the patients to be transported by ambulance. Because the incident is mocked, the facilitators have to communicate the scenario to the ERT and describe what they are seeing in terms of the emergency (fire, chemical spill, tornado, etc.) and report the number of patients. Once they start treating the patients, they need to relay details to the ERT—what is wrong with the patient, their vitals, and all other pertinent information that may be needed to make the incident as realistic as possible.
Because the ERT is dealing with mock patients, these response actions may take only one to two minutes. This is not realistic and fails to test the plan and ERT. A realistic plant-wide test drill should require physical action and ideally would have real people pretending to be injured.
5. Emergency response drills need to include crisis management.
Plant-wide drills test the ERT, accountability process, and notification process, but rarely do they include the Crisis Management Team (CMT). Due to a 24-hour news cycle and social media, it is integral that the information flow from the ERT to the CMT be released correctly and in a timely manner. For example, the ERT lead will inform the Incident Commander, typically the plant manager or their designee, of the details of the emergency—size, scope, impact on the plant, potential impact on the community, and what actions are being taken by the ERT to mitigate the incident.
The Incident Commander will work alongside the CMT to help them handle calls from the public and media, monitor what is said on social media, develop statements to issue to the media and post on company social media accounts, and work with local emergency management on how to notify the public of the incident if needed. When necessary, the CMT also will coordinate with local fire, police, EMS, or other emergency management any actions that need to be taken outside of the plant (for example, chemical release or smoke plume leaving the site). It is important to remember that the ERT relays the incident information to the CMT and the CMT releases the information to social media and news outlets. Your CMT should be included in your plant-wide drills.
6. Emergency response drills need to be evaluated.
This step is critical to identify gaps and discrepancies so changes can be made to your ERP. I evaluate test drills for many companies, and some have conducted a basic 30-minute drill; others have spent the time and effort to conduct a realistic plant-wide drill. We always find gaps that need to be addressed to better reflect how the actual response should be handled; however, the short, non-realistic drills may not identify issues with the ERP, ERT, CMT and notifications.
7. Employees may not have the expertise or time to commit to writing detailed drills.
It is important to consider engaging an experienced third-party company to work with a plant representative to write, facilitate, and evaluate the drills. A third party that specializes in emergency response and crisis management brings a wealth of expertise to help conduct and evaluate the facility's drill response and, more importantly, identify ways to improve, training gaps, or ways to adapt based on their experience with other companies. I always say, "You don't know what you don't know," meaning, if you don't use someone with more experience to facilitate and evaluate, you may never learn what you don't know. Having a third-party company with a wider base of experience help write, facilitate, and evaluate your drills is paramount to learning new ways to do things, as well as providing more credibility to your drills and training should OSHA come knocking at your door.
As I mentioned in the beginning, the frequency of the National Weather Service alert test may not be feasible, but the goal of the test is the same: keeping your employees, responders, and the public safe. It may take time and a financial investment, but the best realistic test of the Emergency Response Plan is a plant-wide drill, conducted at a minimum annually, that challenges your plan, response teams, and employees. A real emergency incident is not the time to test or learn whether your ERP works.
Warning! This is a test. This is a realistic test of the Emergency Response Plan.
This article originally appeared in the December 2017 issue of Occupational Health & Safety.
Chris Koester is the owner of Priority One Safe-T, LLC, an emergency response services and rescue training firm for industrial and manufacturing companies. He is also a captain with the Springfield, MO Fire Department and has 21 years of experience as a volunteer and career firefighter. He holds numerous firefighting and instructor certifications, and is an adjunct instructor for the Northeast Technology Center, and University of Missouri Fire and Rescue Training Institute. Koester has been a Hazardous Materials Technician for over 15 years and is a member of the Southwest Missouri Incident Support Team, the Hazardous Materials Training and Research Institute (HMTRI), the Partnership for Environmental Technology Education (PETE), the Community College Consortium for Health & Safety Training (CCCHST), the National Institute of Environmental Health and Safety (NIEHS) and the American Society of Safety Engineers (ASSE).