IIAR

Are you prepared? I think most of us think we are LESSON prepared, at least to deal with whatever we expect to happen. The trouble is that often what we come up against is not something we expected – therefore we are not prepared to deal with it. For ammonia refrigeration whether a system has 400 lbs. or 40,000 lbs. (or more) we should do pre-emergency planning and training. Having people, training, equipment, etc. in place and properly functioning before the emergency can greatly reduce the impact of an incident.

In the RMP Amendment, published in 2017, Section §68.93 “Emergency preparedness coordination activities” paragraph (b) says in part, “… coordination shall also include consulting with local emergency response officials to establish appropriate schedules and plans for field and tabletop exercises required under § 68.96(b).” Doing field and tabletop exercises in this RMP Amendment is focused on “responding” facilities. However, doing field and tabletop exercises can be a valuable method in order to be prepared for an emergency for any size of system.

The majority of people do not consider their preparation for an emergency, and only seriously think about what they should do after the emergency occurs. I say that with great confidence having been a volunteer for Search & Rescue for over 20 years. For example: how many people that are lost have a map? Answer: Almost none. Here’s another, how many people with a GPS device know how to work that device and/or know what the coordinates mean? Answer: not very many.

Doing tabletop or field exercises is practicing and learning appropriate actions before a real emergency occurs. This is pre-emergency preparedness. These exercises can help a facility find what works or doesn’t work in their emergency plan (action or response), and can also find small, yet crucial details that need additional clarification or options in your emergency plan. The purpose of these exercises is to both improve your emergency plan and the function of your emergency team, so the outcome is better.

Let me assume that you have never done these types of exercises. It helps if it is pre-determined who is going to function in what position(s) in the exercise, and it can be valuable to have persons involved who have specific experience and knowledge relevant to the type of emergency being prepared for. Also, decide who is going to be in charge (Incident Commander). You need a team to deal with emergencies. Trying to be the “Lone Ranger” in an emergency will very likely lead to undesirable outcomes.

TABLETOP DRILLS

Tabletop drills are a discussion-based session where team members meet in an informal, classroom type setting, to discuss their roles during an emergency and their responses to a particular emergency situation. It can be helpful to have outside persons involved in a tabletop, such as someone from the local Fire Department or Hazmat Team, a representative from a refrigeration contracting company, the president of the Local Emergency Planning Committee, etc. Having people from outside the organization involved in an exercise should improve overall coordination for when an actual emergency occurs.

For the tabletop drill someone pre-determines a realistic emergency scenario at the facility. For example, a refrigerant line gets hit, or a relief valve releases, or maintenance is being done and a release occurs. The scenario should not give realistic specific/detailed information about exactly what or how something happened. Asking and understanding the situation and figuring out what to do is part of the learning process that the team needs to go through as they work to understand the emergency and to determine the best actions. There should be a facilitator to guide the team through their discussion of the scenario.

In addition to allowing the team to practice their response in real-time, the value in tabletop exercises is that they can help identify weaknesses and gaps in an organization’s response before a real emergency happens. Confusion about responsibilities, poor decisions, lack of understanding of what could occur, inadequate training or equipment, identifying new vulnerabilities, and finding weak points in the processes don’t indicate failure; rather, these are precisely what tabletop exercises are designed to weed out.

Once the scenario is presented the team starts determining what should be done to deal with the emergency using their present emergency plan. The team should have clear objectives in mind. They may be as simple as, Life Safety (onsite and offsite); Facility/Product protection; Environmental. The facilitator should help the team with suggested considerations, not solutions. If the team discussion is going well, the facilitator may just listen and take notes for discussion after the exercise.

After the exercise, it’s essential for the team to explain what their actions were and discuss any shortcomings in the response. It should be documented what worked as well as what didn’t so vulnerabilities are identified and recommendations for improvement are determined. These recommendations can improve the emergency plan; help the next exercise run more smoothly; and ensure more effective actions of the team when an actual emergency happens.

FIELD EXERCISES

Field exercises can be simple or complex, but these exercises are the real “boots on the ground” type of practices. These exercises mimic reality as close as possible in both the use of personnel and equipment.

A simple exercise might be an evacuation or shelter-in-place. This exercise might only involve facility personnel.

A more complex exercise could involve facility personnel, and Fire Department responders and equipment. If your Fire Department has a Hazmat Team that will respond to ammonia releases, involve them and see how facility personnel and the outside responders work together to address a pre-determined scenario. For example; I have been involved in several exercises where the machine room was “smoked” (using a smoke generating machine), the Fire Dept. and Hazmat Teams were pre-alerted to the exercise (only responding to the site when notified by their dispatch), an ambulance service was pre-alerted to the exercise and responded as the exercise unfolded, and the facility personnel practiced their evacuation and shelter-in-place plan. Such exercises also involved calls to the National Response Center (NRC), the State, and the local LEPC. All being first informed that “This is a drill not a real emergency”.

The somewhat complex exercises don’t take much time to coordinate, but you do have to find a time and date that works best for all involved (Facility and Fire Department).

A very complex exercise would involve multiple groups outside of the facility. Such emergency exercises are typically “mass casualty incidents” or “MCI’s”. In these exercises there are multiple victims so that the multiple groups of responders can be actively involved, testing and practicing their own responses. These events take time to organize and develop, usually many months. Such exercises might involve the Fire Department, Law Enforcement (State Patrol, Sheriff, Police), Ambulance Service (land and air), Hospital(s), State Hazardous Response Team, State Emergency Management, Media, Local Emergency Planning Committee, Public Works, Department of Transportation, etc. All of these groups are very professional, knowledgeable, and experienced in what they do. If you have ever heard of the saying, “herding cats”, you will have an idea of the effort needed to put a very complex emergency exercise together. The challenge with such large events is how beneficial this field exercise will be for facilities personnel. To determine that you must be involved and participate in the entire development process for the event. If you are not, you could be side-lined to a lesser involvement than you planned, still this will be a learning experience.

The lesson learned is, you should do exercises, table-top and field, and you should coordinate with your local groups. Doing the exercises on a regular basis, at least annually, will have your team much more prepared for when an emergency happens, and it will happen.

Coordinating with your local groups who would be involved in emergencies will prepare you to better understand what your various local groups can do, who they are, and how you might be able to work with them. If you practice and coordinate, do pre-emergency planning and training, the result will be knowing you were much better prepared to do the best you can.