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EMERGENCY PREPAREDNESS: TEN QUESTIONS YOU SHOULD ASK
Since the tragedies of September 11th, corporate property owners and managers have a legitimate and pressing concern regarding the vulnerability of their assets. All of a sudden, the “worst case scenario” can no longer be viewed in the hypothetical. Environmental managers have been preparing for this scenario for more than a decade due to environmental catastrophes such as the one that occurred in Bhopal, India. As a direct result of Bhopal, and other toxic releases, the United States has enacted comprehensive laws concerning community awareness and emergency planning. In the wake of September 11th, property managers of all types are looking at environmental emergency planning techniques as a template for non-industrial facilities such as offices, warehouses and commercial buildings. In this article, we have developed ten questions that property managers, in-house lawyers and corporate executives should ask themselves to ascertain whether their facilities are prepared for the worst-case scenario.
As the dust settles and tears dry from the tragic events of September 11th, many managers of industrial, commercial and office properties are asking themselves – could it happen here? Thankfully, in most cases the answer is a resounding “no.” Nevertheless, property managers are legitimately concerned that their real property assets are now vulnerable to the “worst case scenario” as a result of an attack, sabotage or emergency shut-down. Over the past decade, environmental managers have been required by the government to consider the “worst case” scenario as a direct result of the deadly release of chemical gases in Bhopal, India that killed scores of people. This type of contingency planning can be expanded to offices, warehouses and other non-industrial facilities to take into account all types of catastrophic scenarios including sabotage, terrorism and the resultant shut-down of a facility. As a direct result of September 11th, preparing for the worst case scenario can no longer be viewed in the hypothetical. Accordingly, many property managers are looking to environmental emergency planning as a template for non-industrial facilities such as offices, warehouses and commercial buildings. Here are ten questions we developed based on environmental emergency planning principles to ascertain whether your facility is prepared:
1. Does My Facility Have a Written Crisis Management Plan?
A written crisis management plan should address the who, what, where, when, how and why associated with a crisis. The plan should be a soup-to-nuts guide on exactly how a crisis will be managed, what resources will be called upon to deal with the crisis, and how information is to be obtained and disseminated to those who need it. After the crisis management plan is prepared, it should be drilled on a regular basis. The crisis management plan should have a number of sub-plans contained in it such as a emergency coordination plan, community relations plan, media relations plan, and a medical response plan. The crisis management plan should also contain a regulatory inspection plan because governmental personnel are likely to descend on your facility after the event looking for answers as to why the crisis occurred in the first place.
2. Who Is My Lead Emergency Coordinator?
Coordination with the various emergency teams that will respond to an incident is critical to managing the crisis as a whole. The coordination should come from one person within your organization with a back-up person, in case the lead person is prohibited from acting. The lead emergency coordinator must be knowledgeable of all aspects of your facility including fire control, engineering, building construction and industrial processes.
3. Who is My Company Spokesperson?
The person in this position will play a critical role in any emergency. The spokesperson should not be the same person as the emergency coordinator who will be far too busy managing the crisis to respond to questions from the media, local officials and the community. One of the spokesperson’s jobs will be to act as a gatekeeper to maximize the amount of reliable information that is released and minimize speculation. As we learned from the tragedy of September 11th, the public will be hungry for information no matter how reliable or unreliable that information is. The corporate spokesperson will come under intense pressure to provide information about the event. The spokesperson must overcome the desire to release information that is unreliable. Inaccurate and incomplete information may lead to confusion, speculation and possible panic. The company spokesperson must maintain that critical balance between providing important information to the public while suppressing unreliable information.
Who gets the spokesperson job depends on the severity of the situation. In many cases, a CEO or other high executive is not he best choice for a spokesperson. However, in cases where there is a loss of life or another critical condition, the CEO may be the only acceptable spokesperson. Can you imagine a deputy mayor being the chief spokesperson for New York City on September 11th? Thus, the appropriate spokesperson depends on the gravity of the situation.
4. What Is The Emergency Chain of Command?
A well-designed crisis management plan should contain an organization chart that specifies the chain of command during an emergency. For corporations, such a chart is somewhat daunting. Unlike the government or the military, where the chain of command is usually well-established, corporations do not normally have a chain of command for emergencies. Nevertheless, an organizational chart that specifies the chain of command will be invaluable should an emergency occur.
There are three critical elements for chain of command organization- command, control and resources. People with direct control over resources should be given direct lines of access to the parties in control of the emergency. Therefore, engineers, risk managers, plant managers and human resource managers who may not have key roles in the corporate chain of command should have key positions in the emergency chain of command. Additionally, information and communication are critical in the chain of command. Special positions such as an chief information and communication coordinator should be specially created for emergencies in addition to the positions for lead emergency coordinator and corporate spokesperson.
5. Do I Have An Inventory of Hazardous Substances Located in My Facility?
Somewhat surprisingly, non-industrial facilities such as commercial buildings, warehouses and even offices contain a significant amount of hazardous substances. In the event of a fire or explosion, hazardous substances may be released causing health and safety problems for rescue workers, employees and emergency coordinators. Certain federal and state environmental programs require companies to keep track of their hazardous substances and notify employees and local authorities of their presence. Thus, a critical part of any emergency preparedness plan is to know what hazardous substances are in your facility and where they are located. Every facility should maintain an inventory list of their hazardous substances including raw materials, hazardous wastes and ancillary hazardous substances such as cleaning solutions and solvents. These substances should also be kept in fire proof areas or cabinets to prevent their release during an emergency. Hazardous substances are also contained in many building materials. Even though to is difficult to control the release of these substances during an event, every effort should be made to identify hazardous building materials that exist in your facility. Hazardous substance inventory lists should be regularly updated to make certain that they accurately reflect the types, quantities and locations of hazardous substances that are present at your facility.
6. What Back-Up Systems Are In Place?
A catastrophic loss of a facility may impact a corporation well beyond the duration of the crisis. These impacts will be compounded if critical data and information are not backed up. Some industries such as banking and insurance have back up systems that are mandated and regulated by law. Other non-regulated industries may need to create back-up systems from scratch. Ideally, back-up systems should be set up that allow immediate access to information that is needed during an emergency such as hazardous substance inventories, personnel records, right to know reports, shipping manifests and security records. Other information that should be accessible over the longer-term include information that will be needed to continue the business after the event is over. Remember that even if your facility is not directly impacted by an emergency, security and/or health and safety perimeters may prevent you from accessing your facility for weeks or even months after the event. Thus a back-up system at an off-site location is preferably if not essential.
7. What Is My Relationship With Local Government and Services?
Many companies go out of their way to make sure that they never interact with the local authorities unless it is absolutely necessary. In times of an emergency, this may prove to be a critical mistake. In a crisis situation, the local fire , rescue and police are not only the first line of defense but are often the only line of defense. Thus, maintaining a good working relationship with local authorities is essential. The more information these entities know about your facility, the better prepared they will be during an emergency. Therefore, every effort should be made to send hazardous substance inventories, building plans and lay-outs and personnel records to local authorities. Local authorities should be included in facility drills to assure proper coordination in the event of an emergency.
8. Who Are My Key Backup Personnel?
In addition to systems that back-up critical information , essential personnel should have back-ups as well. As we saw on September 11th, key emergency personnel were lost during the first few hours of the catastrophe. Without back-up personnel in the chain of command, the rescue effort would have come to an abrupt halt. On a smaller scale, there is a real possibility that the loss or absence of one or two key people may severely hamstring the response efforts and possibly prolong or exacerbate the emergency. Therefore, every position on your emergency organization chart should have a back-up. The back-up personnel should participate in all training and drills as if they were in the primary position.
9. What Are My Risk Management Policies?
Believe it or not, many companies incorporate their risk management personnel into their emergency preparedness chain of command. For one reason, these personnel are usually knowledgeable of the potential hazards associated with a facility. Secondly, managing potential risk issues from the point of inception may be critical to the rebuilding process in the aftermath of an emergency. In some cases, on-site risk managers have settled prospective property damages claims on the spot. They also have contributed to humanitarian causes on behalf of the company. Both policies create good will among the community. This good will may substantially improve a company’s ability to continue operations in a community especially in the wake of a crisis.
10. Do I Have a Unified Front?
Even the most effective crisis management plan will be rendered useless if the personnel in the chain of command are not willing to perform their responsibilities in a concerted and unified manner. An emergency is no time for employees to air their grievances about the company or for labor unions to use the event as leverage for their next contract negotiation. A key element of the crisis management plan is to identify personnel that can be relied on during a crisis. These people should be knowledgeable of the plan and supportive of the emergency coordinator. The most effective way to assure this is to choose your personnel carefully and prepare them for their roles by drilling them on the elements of the plan. Team building exercises will enhance team work and help create the unified front that is so critical during an emergency.
From gibbonslaw.com
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