Testing Emergency procedures in real life.

[db]

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?

A quick answer is he was. That is why he is there. If I were to make a list of all known significant threats to society, I would put his name on the list. I would also annotate that he is currently in custody. Agencies do not have to spend any resources looking for this guy.

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?

We use similar things. Although "control" isn't one of them, we do look at the probability of release.

Now, if I were auditing you, I doubt that I would write a nonconformance on the way you determine your significant aspects (based on the 1996 edition). I might ask a few questions about any emergency plans you have concerning the oil storage. I would also ask about the emergency plans that are not part of your EMS. But even then, I'm not certain I have sufficient evidence for any nonconformances. Perhaps an observation or two.

 

[Gusman - 2005]

Thanks db.
I think this was a very valuable discussion from my perspective...it should change the way we evaluate our aspects as we are currently evaluating them.
Gus

 

[Wilf from Sask]

Test vs. drill

Late spring we received a minor N/C for not testing the emergency response plan - which was true.

Our corrective action plan was to conduct a test in the summer (with a deadline) as the majority of activities are outdoor seasonally based. The auditor accepted this corrective action plan.

Our test was to conduct several unannounced spot inspection for forest fire fighting equipment and spill kits in our vehicles and quiz the staff on our EMS procedures for fire fighting and dealing with a spill. About 10% of our staff and vehicles were inspected and quizzed

It sounds like we are likely going to be written up during our external surveillance audit (it will be over later this week)

The auditor is concern that our test was not with our highest risk people, who are those who work for us under contract and actually handle fuel and are most likely to come across a forest fire.

I agree that we did not conduct a test with the contractors. – However, we did do a test of the emergency response procedure. Our staff knowledge was good and we discovered one vehicle had some deficiencies in emergency equipment.

Excuse the vent… …

My emergency response question is: does the standard differentiate between a drill and test?

Our auditor is hinting he likes mock simulations rather than a knowledge testing and equipment checks.

...Wilf

 

[db]

Our test was to conduct several unannounced spot inspection for forest fire fighting equipment and spill kits in our vehicles and quiz the staff on our EMS procedures for fire fighting and dealing with a spill. About 10% of our staff and vehicles were inspected and quizzed.

I'm not too certain this meets the requirements, even if you did 100%. Perhaps it is the way you worded it, or perhaps the way I read it, but it sounds more like you auditing rather than testing. I would think a test might be along the lines of you do an unannounced burn simulation to see how the group(s) respond. The important thing is to see if your emergency response system works, not to see if they have the equipment.

 

[Wilf from Sask]

Good point.

I would have to agree that asking someone if they know how to use a shovel isn’t the same as using a shovel. It is quite possible that some individuals would not know that creating a mineral guard to prevent fire spread is usally a better method than covering a fire with dirt as the roots can smoulder for a long time.

 

[db]

I'm not an expert in fighting forest fires, but I have worked a bit with emergency response. Another factor to consider is response time of each step in the process. How much time does it take from the event to initial notification? How much time from initial notification to initial response? How much time from initial response to arrival? Typically, the more time each step takes, the greater the impact.

Odd question, how does one minimize the impact of a fire?

 

[Randy]

Odd question, how does one minimize the impact of a fire?

Get rid of the fuel source?

Change the path?

Put it out?


BTW...If your auditor has concerns tell him to show his butt up when a fire is going on to see if the procedures work.

 

[db]

Get rid of the fuel source?

Change the path?

Put it out?

Okay, but that might limit size, but what about the severity (thinking FMEA here)?

BTW...If your auditor has concerns tell him to show his butt up when a fire is going on to see if the procedures work.

I think this is more of a test of your auditor. There are a few (you and I, I think) that would not hesitate to jump in and grab a shovel. I do wonder how many would run...run far and run fast.

 

[Randy]

Okay, but that might limit size, but what about the severity (thinking FMEA here)?

QUOTE]

That would go with limiting the access to fuel. Severity could also be limited by altering the path from high value areas like residential or improved locals.

Of course it would boil down to how severity is measured.

 

[little__cee]

excellent link for more info.

This is a great link for those of you who want to 'test' your plan without actually shutting down operations and going outside for a drill:

http://www.fema.gov/library/biz1.shtm