Testing Emergency procedures in real life.

[Claes Gefvenberg]

Yep, real life *is* the best drill

I think that if the company did have a drill / testing schedule, then you are right, Dave, there was nothing to 'get away with' and they did meet the requirements (as long as they evaluated the effectiveness of the response). The fear is that they were relying on real life emergencies to test their system. I don't think any of us would want to count on live emergency situations to see how our system works.

Amen to that....

Yep, real life *is* the best drill. If they had a drill scheduled, cancelled it after the real emergency and then went on to evaluate it and implemented the actions decided on that basis... then I think all is well... As I said I don't have that information, but it's certainly a topic worth discussion, because this won't be the last time this happens.

/Claes

 

[db]

A little clarification

The use of "real" emergencies in lieu of “test” emergencies can be a bit tricky. After reading Dean’s response:

The fear is that they were relying on real life emergencies to test their system. I don't think any of us would want to count on live emergency situations to see how our system works.

I can see where he is going, and I agree. My comments were more from the standpoint that if a test was scheduled for Tuesday, and we had an emergency on Monday, then we have met the requirements for Tuesday's test. I must make this clear... at NO TIME would I suggest using real emergencies as the only method! But if a real emergency does occur, I think you can count it as a "test".

As far as registration before you can demonstrate the EMS works, may it never be! But Alas...

 

[Dean P.]

Agreed, Dave, and hopefully in that situation we always pass the test!!

 

[Gusman - 2005]

A few questions regarding emergency preparedness and response procedures...not sure if it belongs in this thread, but will post it here anyway.
1. Are emergency preparedness procedures only required for significant aspects?
1a. For example, if we have drums of oil on the loading dock as an aspect, but have determined them insignificant because our current control measures eliminate the possiblity of any environmental impact, do we need an emergency response procedure?
2. What if we do have emergency procedures in place that do not apply to significant aspects, s hould those be included within our EMS?

 

[Dean P.]

My answers:

1. Emergency procedures are required for any potential emergencies, not sig. aspects. There is a relation there, as an emergency (i.e. a spill) could create a significant aspect, but the procedures should be focusing on the emergency itself, not whether or not an aspect is involved.

1a. On your shipping dock, you may have control measures which reduce the potential of an emergency, but there is still some potential for a spill into the environment, so you should have procedures in place. The potential may be very low, but is still there. And I would think that, even though your drum storage area is not deemed significant as is, a spill would probably create a significant aspect.

2. Other emergency procedures (such as injury response, machine entrapment, etc.) may not be a part of your EMS, but it would be useful to include them into this program, if only for the fact that it formalizes the procedures and brings them under document control.

Hope this helps.
Dean

 

[db]

A few questions regarding emergency preparedness and response procedures...not sure if it belongs in this thread, but will post it here anyway.
1. Are emergency preparedness procedures only required for significant aspects?
1a. For example, if we have drums of oil on the loading dock as an aspect, but have determined them insignificant because our current control measures eliminate the possiblity of any environmental impact, do we need an emergency response procedure?
2. What if we do have emergency procedures in place that do not apply to significant aspects, s hould those be included within our EMS?

Excellent questions! Although the standard revolves around your “significant” aspects, I think you would not have an effective EMS, if you only included accidents and emergencies that relate to your significant. I think the reason that the standard does not specify accidents and emergency situation that do not involve significant aspects it this. If you have an accident, say, you spill your cup of coffee. A several questions arise:

1) What is the impact of the spill?
2) Would this fall into the category of an “emergency”?
3) Do need to respond to the spill?
4) How should you respond?

Any accident or emergency situation that would result in a “crisis”, should deal with a “significant” aspect. Now, by crisis, I do not mean that you have to get a change of clothes.

As far as your drums of oil, should something run into them, and rupture a few, would that create a “significant” aspect? The level of control shouldn’t dictate whether they are significant. Their potential impact should.

As far as emergency plans that are not associated with significant aspects, I would encourage you to include them. If they are important enough to have a plan, then they should be important enough to audit and ensure they are capable.

-----added----------

Wow! Dean. You posted, as I was writing, and we kinda ran along parallel lines. Man, has your credibility just taken a hit!

 

[Gusman - 2005]

Good, quick answers.
I understand that the potential for an impact requires consideration in significance and emergency preparedness (which are totally unrelated),
but now have a follow-up question.

The level of control shouldn’t dictate whether they are significant. Their potential impact should.

Our current significance rating procedure incorporates control measures into the process. My thoughts are "if there are control measures in place to avert the potential for impact and these measures are 'fail-safe,' then is the aspect truly significant?

Is this a correct/acceptable procedure?

 

[db]

Our current significance rating procedure incorporates control measures into the process. My thoughts are "if there are control measures in place to avert the potential for impact and these measures are 'fail-safe,' then is the aspect truly significant?

Is this a correct/acceptable procedure?

My quick answer is no. The fact that you dealt with the aspect doesn't change its potential severity. If you think of an FMEA (provided you know what an FMEA is), we can make sure the failure does not occur, and we can increase the ability to detect it before it occurs, but should it occur, we probably can't do a lot about the severity. Significance is like that. I can do everything possible to contain the oil that is in the drum, but what if it gets out? What is the impact.

Now, before you go nuts. Just because you now call the oil significant, does not mean you have to do ANYTHING different! You have the controls in place, and you might be able to leave it at that, provided you adhere to the controls. Audits would confirm this.

My take anyway. Dean..anything to add?

 

[Gusman - 2005]

To be honest, this conflicts with my understanding of how significance determination works...

I understand your line of reasoning concerning the potential impact - what if it does get out? - but the potential for this happening is so miniscule...(we have not only operation controls, but curbing and slopes to eliminate the impact to the environment). I'm not sure I can succumb to the thought that it is significant because it is there.

On a parallel line (and kind of off subject) is a prisoner in a maximum security prison, chained to his bed, guarded by dogs, electrical currents, and rifles and significant threat to society just because he is there?

 

[Gusman - 2005]

To continue my original thought,
our significance determination process takes into consideration more than just potential impact. We consider
1. the concern of interested parties,
2. Regulatory Risk,
3. Severity,
4. Frequency, and
5. Control.
What do you think of this?