By Andrew Perks
Last month we chatted about new legislation and how it affects us Last month we chatted about new legislation and how it affects us – both the good and bad.
More paperwork, more non-productive hours, but is it reality? If we are honest, the majority make good sense and are just there because there have to be enforceable rules. The other issue of course is who enforces them?
This month I want to talk about Emergency Response Planning. The old adage, ‘he who fails to plan, plans to fail’ still applies today. The new Major Hazardous Installations SANS 1514:2018 regulation applies. If the possibility of an emergency exists (can you tell me of any place where there is production or moving equipment where it doesn’t exist?), there is a need for a proper emergency plan. Sure, you have a plan on the wall that shows you the escape routes, but it is often out-of-date. And there’s always the more relevant plan of ‘run like hell’.
Ask the fire chief – it really doesn’t cut it. An emergency plan that is not exercised once or twice a year is not an emergency plan, but another load of paperwork taking up space in someone’s drawer or laptop. Or it could be that irritating exercise you do periodically at 2pm on a Friday when you could instead be going home an hour earlier.
If you work in some kind of construction industry, it’s difficult to do a completely random emergency drill. What happens to the production? Rest assured when you have an emergency it’s not going to happen at 2pm on a Friday. So, what is this new regulation all about?
It’s about trying to understand where the issues are and looking firstly to mitigate the risk, which is not always totally possible due to the human element, and secondly, having a documented procedure that everyone is aware of that kicks in as soon as the emergency is declared.
The recent incident I spoke of involving Jose Mata highlighted his company’s short fallings with their response procedure – nobody was the designated incident commander and as such nobody had the responsibility, and more importantly authority, to get the emergency plan operational so everybody was in charge. Sound familiar? One of our saving graces is that there are a lot of good people out there doing a good job and as such these emergencies are minimal. But one fatality is one too many.
Each emergency plan has a similar basic structure:
- There must be an overview of the on-site plan highlighting potential incidents and listing any other types of incidents;
- There must be objective pre-plans for a spill, fire or production incident;
- A list of management, site staff listing contact details and each one’s area of responsibilities detailing the structure for normal working hours, after hours and holiday periods;
- There must be a command structure organogram for a low-level emergency and for a high-level emergency;
- The organogram will indicate the command structure for the independent teams;
- There must be response-plan scenarios which are upgraded as the incident escalates;
- An organogram of key staff to be notified after the incident or whilst it is in progress;
- There must be a full facility layout drawing showing location of hazardous material, safety equipment, assembly points. There should be an area where information on hazardous material is stored, for example material safety data sheets (MSDS);
- There must be a scheduled procedure to deactivate any emergency plan that was activated for whatever reason and a site sign-off by the incident commander in conjunction with the fire chief prior to the facility restarting production operations;
- A full-blown investigation of what happened, commonly known as an incident critique, with a view to learn from the occurrence. Whilst it is not always humanly possible to cover all eventualities, we can at least learn from past ones; and
- The Department of Employment and Labour (DEL) must be notified within 72 hours and a full report submitted.
So, you can see an emergency plant covers a load of issues. The critical question you must ask yourself is: are you prepared? Are your systems geared for it? Do you have the correct PPE? Are your people trained? It’s too late to discover the shortfalls when it happens, because if that is the case and there is a fatality, it will get really nasty for all concerned.
I have been doing a bit of travelling around the country and came across an ammonia plant that is in a particularly sad/dangerous condition, and in the next issue, I’ll chat about these installations that are a danger to all those in the vicinity, and what can we do about it.