Integrated Contingency Plan

For Environmental Managers, Safety Managers and Emergency Response Personnel

Integrate All of Your Plans into One Document

Background

Emergency Response Plans are required by several environmental and safety regulatory programs.

• All companies using hazardous chemicals must have an Emergency Response Plan under OSHA's Right-To-Know (RTK).
• Hazardous waste generators need a RCRA Contingency Plan.
• Large oil storage systems must have an OPA 90 Facility Response Plan.
• OSHA's Process Safety Management (PSM) regulations require an Emer-gency Response Plan.
• EPA's Risk Management Program (RMP) requires yet another Response Plan.

These regulations have overlapping, and sometimes contradictory requirements, which make compliance costly, confusing, and ineffective.

Challenges

Emergency Response Plans for industrial facili-ties are often multi-volume complex documents containing extensive information about spill notification and reporting, response actions, cleanup, mitigation, training, etc. The plans are prepared with emphasis on regulatory compli-ance with little regard for implementation. As a result, they are often quite bulky and not usually user friendly. The Plans remain on a bookshelf and are not used by response personnel. Faced with the need to react quickly to a spill, a response team does not have the time to review a six-inch binder to determine the proper course of action.

Further complicating many response programs is the presence of several different and often conflicting Response Plans. As facilities com-plied with RTK, RCRA, Oil Pollution Prevention Regulations, PSM, RMP, etc., they developed separate, overlapping and conflicting response plans to address the specific requirements of the regulation. With this multi-plan approach, each response plan is developed, audited and updated independent of the other plans. With several large, complex plans at the same facility, effective implementation is difficult.

Solution

In an effort to implement effective Emergency Response Programs, facility managers and regulators have considered ways of simplifying Response Plans and integrating all of the different regulatory requirements into a single, user-friendly plan. In response, EPA, OSHA and other government agencies which require response plans issued guidance for integrating all existing regulatory requirements into a single plan called the "Integrated Contingency Plan" (ICP). The major advantages of the EPA, OSHA and DOT recommended ICP are:

• Easier to use;
• Quick and effective response guidance;
• Less expensive and easier to develop, maintain and audit;
• Clearly defines training and drill require-ments.

Case History

A cogenerating facility in northwest Washington had separate response plans for RCRA, OPA90, PSM and RMP. These plans were developed separately by outside contractors with the primary goal of regulatory compliance and little concern for implementation. The result: four lengthy and complicated plans with many different and overlapping requirements. Although the plans meet the regulatory requirements, they have simply remained on a bookshelf because they were conflicting and too complicated for easy use.

The facility contacted Universal Dynamics in 1999 and asked if we could assist them in developing a single Emergency Response Plan that complied with all the regulations and could be effectively implemented by plant personnel. Using the ICP guidelines, Universal Dynamics combined the four existing plans into a user friendly, Integrated Contingency Plan that was half the size of any one of the other plans.

As a result, the facility is now able to train their response staff and effectively respond to acci-dental releases. Universal Dynamics has since been contracted by the parent company to develop Integrated Contingency Plans for other plant locations.

Universal Dynamics Services

Universal Dynamics provides comprehensive Emergency Response Planning (ERP) services including:

• Development of new Emergency Response Plans (ICP, ERP, FRP, SPCC, and Contingency Plans);
• Updating existing Emergency Response Plans;
• Preparing Integrated Contingency Plans.

For further information on Emergency Planning, please contact our nearest office.