Integrated Contingency Plan - The "One Plan" for Regulatory Agencies

For companies that have multiple facilities, having an integrated contingency plan is considered best practice.

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In 1996, the National Response Team published the Integrated Contingency Plan (ICP) Guidance in an effort to provide facilities with the means to comply with multiple federal planning requirements required by various regulatory agencies by consolidating them into one emergency response plan.

By creating a single comprehensive integrated contingency plan, emergency managers can;

  • Reduce the need for multiple plans
  • Minimize administrative costs
  • Simplify plan reviews
  • Minimize discrepancies across various plans
  • Streamline response directives from one source

An ICP does not exempt facilities from applicable regulatory planning requirements pertinent to releases of oil and non-hazardous substances. Multiple federal agencies endorse the use of an ICP as a means to incorporate statutes and regulations, include requirements for emergency response planning. A particular facility may use an ICP to incorporate one or more of the following applicable federal regulations:

  • EPA
    • Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements), 40 CFR part 112.7(d) and 112.20-.21
    • Resource Conservation and Recovery Act Contingency Planning Requirements, 40 CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52
    • Risk Management Programs Regulation, 40 CFR part 68
  • Department of Transportation/Pipeline and Hazardous Materials Safety Administration
    • RSPA Pipeline Response Plan Regulation, 49 CFR part 194
    • US Coast Guard, Facility Response Plan Regulation, 33 CFR part 154, Subpart F
  • Occupation Safety and Health Administration (OSHA)
    • Emergency Action Plan Regulation, 29 CFR 1910.38(a)
    • OSHA's Process Safety Standard, 29 CFR 1910.119
    • OSHA's HAZWOPER Regulation, 29 CFR 1910.120

Facilities may also be subject to state emergency response planning requirements that is not included in the National Response Team ICP Guidance. Facilities are encouraged to coordinate development of their ICP with relevant state and local agencies to ensure compliance with any additional regulatory requirements.

National Response Team is composed of 16 Federal agencies having major responsibilities in environmental, transportation, emergency management, worker safety, and public health areas is the national body responsible for coordinating Federal planning, preparedness, and response actions related to oil discharges and hazardous substance releases.

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