Fight or Flight: Emergency Action vs Response Planning | Blog No. 113
- Ryan Bray
- 6 hours ago
- 7 min read
Planning for an emergency at a refrigeration facility can be a daunting task, particularly
when deciding whether to prepare an Emergency Action Plan (EAP) or an Emergency
Repose Plan (ERP). Choosing the best option depends on several factors, including the
placement of responsibility for response, the facility’s desire to maintain trained
responders onsite, the financial burden for training, and whether the local fire authority
can provide timely incident response. In truth, the arguments for each plan are as varied
as refrigeration facilities themselves. The decision to select an EAP versus an ERP
depends on a combination of facility characteristics, company resources, and the
capabilities of local first responders.
Introduction
More than 100 years ago, physiologist Walter Bradford Cannon first described the
physiological reaction demonstrated by animals in response to the threat of attack
known as the Fight-or-Flight Response. Whether acting out in aggression against a
predator or choosing to retreat to safety, Canon observed how the balance of power and
physical ability influenced how animals responded to hazardous situations. Within the
Ammonia Refrigeration Industry, the United States Environmental Protection Agency
(EPA) and the Occupational Safety & Health Administration (OSHA) has placed the local
facility in a similar situation. Available resources, skilled personnel, and the ready
availability of local authorities plays a vital role in the determination of whether to “fight” the
impacts of a hazardous material release with an Emergency Response Plan (ERP) or
choose “flight” with an Emergency Action Plan (EAP) outlying procures for an organized
evacuation.
Just as an animal might size up its opponent, local facilities need to consider what
resources are at its disposal before determining what type of emergency plan will
provide the best protection for its personnel, the community, and encourage economic
resiliency.
“Flight”
As described in the Code of Federal Regulations, Title 29, Subtitle B, Chapter XVII, Part
1910, Section 1910.38(a) [29 CFR §1910.38(a)], the EAP focuses on the immediate
actions to be taken directly following a hazardous event. The term “action” in this
instance infers that no “response activities” will be undertaken by facility personnel.
“Response”, in contrast, refers to any intentional action taken to reduce or eliminate the
threat of a hazard that might require personnel to enter a hazardous environment. In
the case of the EAP, this type of activity is never authorized. Rather, onsite personnel
may be assigned to take any of the following actions while allowing local authorities to
take management of the emergency and any response tactics.
Calm and orderly facility evacuation
Notification of local authorities
Gathering of critical information to provide to local authorities upon arrival
If en route to the exit, the system may be powered down to prevent a situation
escalation.
In order to accomplish these four objectives, a plan must be developed that includes
written procedures. These procedures should include, but not be limited to, facility
evacuation, emergency reporting guidance, employee accountability, responsibility
assignments, and a protocol or system for employee emergency notification. This plan
must include an outline for training requirements for each position and maintenance
cycles to ensure the plan is continually evaluated.
In addition to good planning, the EAP must be coordinated with local authorities to
ensure first responders are aware of the chemicals at the facility, there is an established
onsite contact, and drills are conducted with local responder representatives present.
Utilizing this plan type, the facility acknowledges that no personnel will take aggressive
action against a hazard event. With a focus on encouraging life safety, facility personnel
will be instructed to evacuate to a safe staging area. The EAP embodies the “flight.”
aspect of Cannon's observation. Just asan animal might realize it does not have the skill or
brute strength to overcome a threat, the local facility accepts that its personnel have not
been provided the training, tools, and/or resources to effectively subdue a significant
hazardous event.
“Fight”
The ERP, as described in the Code of Federal Regulations, Title 29, Subtitle B, Chapter
XVII, Part 1910, Section 1910.120(q) [29 CFR §1910.120(q)], requires more intense
planning and training efforts, but will allow personnel to respond to hazardous situations
upon discovery. Under the ERP, trained onsite personnel will follow pre-established
emergency operations guidelines to protect life safety and stabilize the hazardous
situation.
In order to accomplish a successful response, the ERP should include the following;
Pre-emergency planning and coordination with outside parties, including, but not
limited to, fire, police, and remediation and clean-up service providers as
applicable
Pre-assigned personnel roles with documented responsibilities, lines of authority
and communication with training opportunities for each identified role
Guidelines for recognizing an emergency that will require facility-wide emergency response
organization or even outside aid and prevention considerations
At least two established staging (evacuation) areas are to be used, depending on the
wind direction and other weather conditions as necessary
Documented site security and control protocols to ensurethe members of the public
The media cannot enter hazardous areas
Evacuation routes and standard evacuation procedures
Easily accessible decontamination equipment
Emergency medical treatment and first aid
Emergency employee alerting system
After-incident critique of response protocol and follow-up procedures
Procedures to keep personal protective equipment (PPE) and emergency
equipment in working condition
Comparative Benefits and Risks of Each Plan
Emergency Action Plan: The EAP is undoubtedly the most common choice in my
experience. Particularly in urban areas, local authorities can often respond to an
emergency within the first 5 minutes of notification. On-site personnel would be hard-
pressed to accomplish any sort of response action in that amount of time. So many feel
the efforts and costs associated with response planning simply do not make economic
sense. The EAP requires little specialized training and equipment since on-site
Personnel are not authorized to perform response activities, so the economic benefits
stack up quickly.
The EAP does have certain drawbacks. For instance, local authorities have been
trained, and rightly so, to consider public safety and incident stabilization first. Property
protection, while included as part of emergency training, is not necessarily a top priority.
Fire department personnel may take actions to protect the community or neighboring
facilities at the expense of the facility. This makes sense from a community perspective.
However, this leaves the local facility with no voice when it comes to the protection of
the facility or process equipment. Whether or not onsite personnel could provide the
information to stabilize a release without damaging facility property, local authorities
may not provide the opportunity for input, leaving the facility with considerable potential
damage and an inability to return to normal operations.
The local facility must consider both the costs and the benefits of the EAP. Described
above is the worst-case scenario where business owners are powerless to save a
facility in an emergency response, but it is not necessarily the case. If local authorities can
respond quickly, they may be able to take control of the emergency before considerable
damage is done. If the potential for major damage is minimal, it may make sense to rely
on fire personnel for emergency operations and develop an EAP for the facility.
Emergency Response Plans: As mentioned above, the costs of plan development,
maintenance, and training generally do not make the ERP an appealing option for many
companies in terms of resources. However, if a facility is in a rural area where first
responders cannot travel in a timely manner, the facility may need to prepare to manage
emergency operations internally. In contrast to the EAP, the ERP allows the local facility
to act, to a degree, independently of local authorities, to restore operations utilizing
personnel that are intimately familiar with the system. This knowledge and familiarity
could potentially minimize the impact of an emergency on personnel and property.
The cost associated with emergency planning is often a deterrent when choosing this
option. However, the cost of an accident at a refrigeration facility can run into the
millions. Even if a small facility were to sustain $2,000,000 in damages following an
incident, while the annual cost of maintaining response capabilities totaled $100,000 (an
arguably exorbitant amount for small to moderately-sized facilities), it would take 20
years before the costs of maintaining response capabilities equalized with the cost of
the incident. While this scenario is hypothetical, it is a valid argument for local facilities
to seriously consider the costs involved in preparing for emergency response. The
upfront costs and efforts may actually prevent injury and economic loss in the future.
There is an old adage that says, “One dollar spent in prevention is worth six in recovery.”
It is with that mindset that emergency planners should be encouraged to consider the
possibility of utilizing the option for emergency response.
Conclusion
The threat of a hazardous material release is the perceived danger. As an
emergency planner, a decision must be made whether to “fight” or “fly”. Driven by
available resources, local emergency operations support, and personnel, emergency
planners can decide whether the costs of training staff and acquiring the necessary
equipment to respond to a potential emergency outweigh the benefits of standing back
and allowing local authorities to take charge of emergency management. Would a
facility be empowered by the ability to respond, or is the responsibility of emergency
management a burden better left to the local Fire Department? The information above
can be a starting point for the local facility to make the best decision to protect life and
property.
Thank you for reading! Visit the Macha PSM website for more!
For a comprehensive training on Anhydrous Ammonia, click here for our PSM Academy Ammonia Awareness training, to learn and earn a certificate of completion. Training is in English and Spanish. Use code SDS20 for a 20% discount on the entire purchase. For more information, email us at academy@machapsm.com.For a comprehensive training on Anhydrous Ammonia, click here for our PSM Academy Ammonia Awareness training, to learn and earn a certificate of completion. Training is in English and Spanish. Use code SDS20 for a 20% discount on the entire purchase. For more information, email us at academy@machapsm.com.
Comments