The modern industrial society in which we live and work imparts on all of us the potential to come in contact with a wide variety of hazardous substances – substances that under normal conditions are controlled and pose no threat to human life and the environment. Within daily commerce these materials can be found in transport via trucks, trains and ships or in storage and use within industrial facilities. However, when these substances enter the environment through an accidental release, they can contaminate the land we use, the water we drink, and the air we breathe, with potentially disastrous results.
The U.S. Environmental Protection Agency (EPA), as well as state and local governments, have established programs to help ensure that facilities and organizations take steps to prevent oil spills, chemical accidents, and other emergencies; implement planning and preparedness requirements; and respond to environmental emergencies. First and foremost, the regulated community must abide by emergency management program requirements and EPA enforcement through the development and implementation of emergency response plans. The specific requirements for the content of these plans depends upon the hazardous substance of concern as well as the regulating authority requiring that emergency preparedness measures be in place.
In their simplest form, these documents are considered to be contingency plans that describe the information and processes for responding to EPA enforcement and hazardous substance emergencies. Other names, as dictated by the overriding regulatory requirement, include: Facility Response Plans (FRP), Spill Prevention, Control and Countermeasure (SPCC) Plans, Preparedness, Prevention and Contingency (PPC) Plans, Discharge Prevention, Containment and Countermeasure (DPCC) Plans and Risk Management Plans (RMP). Although each of these unique plans is the requirement of an individual regulatory statute, it is sometimes possible to streamline emergency preparedness planning to meet the requirements while creating a program and procedures that will be effective and meaningful for the facility.
EPA Enforcement Consulting and Emergency Plan Assessments
ESC works with our clients by supplying EPA enforcement consulting in order to appropriately and effectively meet the applicable regulatory requirements. In addition to plan development and certification, our staff’s broad background within industrial and petro-chemical manufacturing will allow us to assist you in conducting training and exercise programs as part of the overall emergency plan assessment activities. We look forward to assisting you.
* This figure presents a portion of the flowchart concept discussed at the US EPA National Response Center (NRC) website detailing the functioning of the National Response System. When a release or spill occurs, if the amount of a hazardous substance release or oil spill exceeds the established reporting trigger, the organization responsible for the release or spill is required by law to notify the NRC.
The following links provide you access to emergency planning rules and guidance.