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View Full Version : ISO 14001 Emergency Preparedness & Response Plan Requirement


June Ang
22nd March 2002, 10:29 PM
Help!!! I'm currently preparing the Env Emergnecy Preparedneee & Response Plan for my company. I could only come out with a very general procedure. I'm not satisfied with this procedure as it doesn't stating the real action that we are going prevent and response to the emergency situations.

Anyway, can i have your comments on this?
My OP is as below:

1. The Project Manager is overall responsible to response and mitigates the environmental incident or emergency situations that occurred as the consequences of the project’s activities.

2. Potential environmental incidents and emergencies likely to occur at the Shimizu worksite shall be identified by the Emergency Planning Committee.

3. Refer to OHSMS/OP11/EPR – Emergency Preparedness and Response for the incidents and emergencies likely to occur in a construction site.

4. The methods to respond to, mitigate and prevent environmental emergencies shall be established and maintained by the Emergency Planning Committee. The decisions of the Emergency Planning Committee shall be translated into actions by the respective Emergency Action Committee.

5. Roles and responsibilities for communications within the organization and for obtaining outside support services shall be established and maintained via the emergency plans.

6. The environmental emergency methods and communications shall be tested at least annually. The ECO shall maintain the records of these tests. Methods to respond to, mitigate and prevent environmental emergencies shall be amended as required based on the results of these tests.

7. Following an environmental emergency, the cause of the emergency and corresponding emergency methods shall be reviewed. Corrective and preventive actions will be identified and undertaken by implementing the EOP 14 – Corrective and Preventive Action. Methods to respond to, mitigate and prevent release that arise as a consequence of an environmental emergency shall be amended as required.

---end---


I'm now trying list out the potential emergency cases and plan for the response action. Is any have example can be shared?

Any help is very much appreciated.

Brandon Kerkstra
23rd March 2002, 11:17 AM
June,

The Michigan State Police have posted a handbook on how to create a complete Emergency Plan on the web. I have attached the pdf file below. Unless you are a very large organization it is more than you need, but a great starting point. It does have a sample plan at the end of the document.

As for the companies I work with, we typically put together the plan, add the procedure requirements and control it. So in the end it contains both the Procedure requirements (Who, What, When) and Work Instruction (How - or the actual Plan)

I hope this helps.


Brandon

Randy
23rd March 2002, 04:58 PM
1st of all go by the regulatory requirements of your government(s).

2ndly the requirements (if any) of your industry.

3rdly the requirements of organizations you voluntarily belong to.

4thly use "Common Sense". Evalute the actual and perceived potential of an event.

Always base your plan on "Worst Case Scenario". Bring in your local emergency organizations to assist you, and involve your local community if there is a possibilty of off-site encroachment or danger.

If Union Carbide had done this Bophal may not have been as bad as it was.

June Ang
23rd March 2002, 11:33 PM
Thanks a milion for all your opinions. I'll try to work on the plan based on your comments. Anyway, what are the most common potential emergencies could be happended on a costruction site?

(1) spillage/ leakage of chemicals/ hazardous substances
(2) explosion
(3) soil movement/ slope failure
(4) ????

Randy
24th March 2002, 12:24 PM
It depends upon what you are constructing and what methods are being used. This is where you need to be involved with the engineers, construction manager and all that. An EMS is a TEAM EFFORT and not just an individual just writing stuff down.


Hey marc the #2 I told him was industry standards. Duh:rolleyes:

Claes Gefvenberg
25th March 2002, 02:52 AM
I would guess that many of us in the process of setting up an EMS already have emergency plans set up? I know we did.

After all, the risks must have been there before we decided to go for EMS, and those risks will in many cases have been adressed by law in our respective countries. So: Make certain that you look through what you already have before you start writing something new.

/Claes

June Ang
25th March 2002, 03:19 AM
Yup, I 100% agree that an EMS is a team effort. I did try to disseminate the drafted operational procedures to them and ask for their feedback. But because of the schedule is too tight, i do not have time to go through the OP one by one with them. Finally, only one or two of them were feedback to me.

I know this is where the problems exit. I'm trying to take the "corrective action" now.

I do not know how other company start to take the first step in ISO 14001. Frankly, i'm just a new comer to this field and this company. I do not familiar with the operations of this big company (certified with iso 9001) but i quite familiar with environmental knowledge and constuction activities. I thought i was hired to help them in specific environmental related tasks like identify the aspect, impacts and propose control measures. But in fact I have to complete the whole EMS documents within 4 months from knowing nothing (or only 5%) about the company and ISO 14000 and with my own effort. And after complete the documents, i still need to think of the implementation programme.

I think they are over estimate on me. I'm only a "small" staff here. But what they want me to do is not a "small" task.

Anyway, after 3 months effort, i know how is a good EMS shall be functioned. But, will it a bit late????

No matter how, all i can do is only try my best!!!
:bonk:

Randy
25th March 2002, 04:13 AM
Remember..there is no shame in failing. The shame is never trying.

Just take one step at a time.....get others on your bandwagon....and go for it.

kalehner
25th March 2002, 11:11 AM
I am not sure that you really need a detailed documented procedure for emergency response. I believe this is one area that is better addressed through training than specific documented procedures for emergency response. Imagine the size of a document that tries to cover every permutation of potential emergencies at a facility. I believe that it is better to have a brief emergency plan that includes things like general notification and alarm procedures and rely on training to ensure that people know how to respond to an emergency

Marc
25th March 2002, 11:23 AM
Whether or not you need an emergency response plan depends upon numerous aspects of your business, processes and product.

Marc
25th March 2002, 11:31 AM
Originally posted by Randy
Hey marc the #2 I told him was industry standards. Duh :rolleyes:As an old man, not only are my sight and hearing going, but I have my 'Senior Moments' (I think that's what James calls them) or the 1960's lag is setting in. You're right - you had it as your #2... :thedeal:

June Ang
25th March 2002, 09:13 PM
We have general emeregency response in place which cover both safety and environmental emergencies based the severity of events as following;

(a) incident
(b) emergency
(c) crisis

We have defined the meanings and give exmaple of cases for each one. With appropriate training, i believe that the workers will know who should they inform.

We also have a few specific action plan for :-

(1) Fall from height
(2) Fire / explosion
(3) structural collapsed or loss of stability

But for those emergencies didn't included here, the emergency committee have to plan during that time.

Randy
26th March 2002, 10:22 AM
You need to test your plan to see if it works. You should have both scheduled and un-scheduled tests, and be sure to document them.

Randy Stewart
26th March 2002, 11:06 AM
This may be the auditor but I'd like to hear your opinions.
We were issued an NC on our 14000 audit due to not having results of our Emergency Response Plan test. The standard doesn't say I have to have documented results, just that I should periodically test. I argued this point but lost. Now I know it would not be good business practice not to test the procedure, however, if I show a schedule for testing and it complys with all other requirements (state, locale, etc.) how am I in non-compliance even if I schedule it for once every 5 years??? Once again I'm not saying it should be done this way, I was upset for the NC. We had just updated the procedure because we brought in an outside firm for security (union issues) and it hadn't been tested.
:confused:

Randy
26th March 2002, 11:23 AM
The term is "Objective Evidence". You may not have had enough to satisfy the auditor.

If a procedure is only tested every 5 years there may be more issues than just a noncomformance, especially in some industries (petrochemical for example).

I know what you are getting at but then again maybe Union Carbide (Bhopal) had good intentions too and tested their plan every 2 or so years.

The spirit of the law (so-to-speak) is that emergency planning be accomplished, affected personnel are trained and informed (on and off site types), and that the plan be tested for validity.

The word periodically may be construed by some to mean at least annually.

Randy Stewart
26th March 2002, 11:38 AM
I agree with you Randy. If it was me IMO I would probably look at 4.4.2 (c) because the people in security hadn't been trained in the new procedure. I thought it was a cheap hit, we only had 1 other NC and that was because I didn't show every element being audited internally. I carried over the Management Review and Corrective Action audit (shared procedures) from my QS/TE audit. The results didn't point at an ISO-14000 audit.:confused:
I have to be honest, I enjoy the challenge of a good argument/debate! (who am I trying to kid????) :bigwave:

kalehner
26th March 2002, 11:38 AM
Did you or did you not test the emergency response plan? If so how long before the audit was the plan tested? Less than 1 year. 1-5 years ? > 5 years?

Randy Stewart
26th March 2002, 11:41 AM
It had been about a year. The schedule is for every 6 months (city requirement).

kalehner
26th March 2002, 11:45 AM
Does your internal emergency response procedure perscribe a testing frequency?

Randy Stewart
26th March 2002, 11:55 AM
Yes, it was scheduled for 6 month intervals and the procedure was updated (increased frequency) to meet the city requirements 4 weeks prior to our audit. I showed the change and the last test result. We are low profile, our "most" significant aspects were battery disposals (pagers, speakers, Hi-Lo etc.) and waste oil from the presses.

kalehner
26th March 2002, 12:27 PM
It sounds like you weren't following you own procedure for frequency of testing. I would probably have written a minor nonconformance or observation not because you did not document it but because you did not test it when you were supposed to as outlined in your own procedure. I would probably write it to 4.4.7. (no test as required by your procedure). If you then dropped to the floor kicking, screaming and pounding fists I would offer the option of writing it to 4.4.6 for not following your own procedure. Remember, there is nothing wrong with getting a nonconformance. Finding that you had not tested the emergency response procedure as required was a good thing right? Organizations that believe any nonconformance represents failure have the wrong attitude about the process and will not get as much out of their EMS as mature (ready) organizations that understand, good news is no news, no news is bad news and, bad news is good news. Hope this helps!

Randy Stewart
26th March 2002, 12:53 PM
I wasn't kicking and such, just held a gun to my head - it still didn't work. No we were not in violation of our procedure it had just been updated to increase the frequency. I'm not saying what we did was good practice. I just didn't agree with the write up. :bigwave: