Challenges in Emergency Response Planning in the Oil + Gas Industry

Steven Bassine

Ensuring preparedness and employee safety requires a committed emergency management staff and program

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One of the most common response planning challenges in the oil and gas industry is when corporations downsize, reorganize, or acquire other companies. As companies reorganize or grow, response plans can quickly become outdated and non-compliant. Often, plans for newly acquired facilities are formatted differently or are in multiple formats. These plans are harder to update, review, and use, and may not contain the necessary level of detail.

Internal audits may identify gaps in regulatory compliance requirements and minimum corporate emergency preparedness criteria. However, audits may also reveal process or procedural inadequacies, contradictory plan formats, or inaccurate information. Also, when companies grow, the number of staff dedicated to maintaining response plans may not grow with it.

Ensuring preparedness, regulatory compliance, and employee safety requires a committed emergency management staff and a fundamental emergency management program with streamlined, coordinated, consistent and exercised response plans. Regulatory compliance can be complex and costly for oil and gas companies; however, the regulations protect the public interest, the companies, and the environment. If staff, programs, and/or plans are insufficient for an effective response, these companies and potentially their communities may be severely impacted.

With so many operational components, response plans must be audited to determine potential discrepancies and regulatory deficiencies. Once discrepancies and deficiencies are identified, adjustments can be made to ensure compliance, efficiency, and effectiveness.

Response plan audits often identify the following:

  • Personnel listed in response plans who are no longer employed with the company
  • Emergency response duties and responsibilities that are not assigned to appropriate personnel
  • Inaccurate contact information for company personnel and external resources
  • Lack of detailed oil or hazardous material spill response procedures
  • Lack of specific tank fire pre-plans and foam calculations
  • Training deficiencies
  • Inefficient documentation of training records
  • Inconsistencies with Area Contingency Plans and/or local regulations
  • Differing plan formats and versions resulting in varied information and disjointed composition
  • No efficient process for implementing lessons learned, changes in policies, or regulatory requirements

A dedicated regulatory intelligence team or the EH+S manager may be responsible for the daunting task of reviewing many regulations, mandates, and guidelines to ensure that correcting identified deficiencies meet compliance requirements. In most cases, agencies require deficiencies to be addressed within a certain time frame following an external compliance audit. Agencies can impose fines and ultimately shut down operations for missed deadlines or ignored requisitions.

While companies may not need to “reinvent the wheel” regarding safety and response procedures, they need to confirm that best practices are applied to each site-specific response plan. All company operations should be evaluated to ensure that best practices are in place for each potential scenario and product. For example, safety and response best practices exist in the following areas:

  • Pre-incident planning
  • Training
  • Exercises
  • National Incident Management System (NIMS)
  • Security
  • Fire brigades
  • Rescue
  • Hazardous materials handling/response
  • Fire loss prevention
  • Evacuation

An effective compliance management process should include regularly scheduled plan audits, which can result in an efficient and integrated program that optimizes the efforts of company stakeholders and limits operational downtime. Effective technology can aid in managing response planning administrative duties associated with continually evolving personnel, operations, and regulatory requirements. Multi-facility operations should consider utilizing web-based technology to ensure enterprise-wide compliance on multiple government agency fronts.

About the author:

Based in Houston, Texas, Steven Bassine is Vice President, Strategy and Business Development, Digital at Jensen Hughes and Product Owner for SMARTPLANTM. Steve is an expert on response planning with years of experience in multiple industries.

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