How to Create an Integrated Contingency Plan
A contingency can be a spill, release, fire, earthquake, oil spill, pipeline leak, traffic accident, or any other emergency condition that threatens the environment, public safety, employees in a workplace, or other specified subjects; and that would require an emergency response of some kind.
Catch expert-led RCRA training trusted by EHS professionals nationwide this month in Milwaukee, Cleveland, Pittsburgh, Detroit, Nashville, Atlanta, Orlando or Charlotte and Houston.
Integrating multiple mandates means that instead of having one emergency response plan for Fires in the inventory, and another for oil spills, and another for mechanical failures in waste storage; you have one plan that catalogs all the possible hazardous conditions, the risks, and what to do in case of various emergency conditions.
The ICP concept was created by the government’s National Response Team in 1996. Even at that early date, the authorities recognized that they had already overloaded the regulated community with too many emergency plan mandates, including but not limited to:
What Mandates Does the ICP Integrate?
- Spill Prevention Control and Countermeasures (SPCC) for oil spills [40 CFR 112]
- Pipeline Response Plans [49 CFR 194]
- Risk Management Plans [40 CFR 68]
- Process Safety Management (PSM) [29 CFR 1910.119]
- Emergency Action Plans [29 CFR 1910.38]
- Hazardous Waste Operations and Emergency Response [29 CFR 1910.120]
- RCRA Contingency Planning for hazardous wastes [40 CFR 264 Subpart D, 265 Subpart D, 279.52]
- and others
But, these different plans also overlap a great deal. Once you’ve got a plan in place to deal with potential releases of flammable liquids from raw material stored in tanks, it takes only a little more work to address potential releases of flammable liquids from hazardous waste storage tanks, for instance.
If you’re doing quarterly evacuation drills for the county fire marshal to meet fire safety mandates; who says that can’t count that towards your OSHA PSM mandated annual evacuation drill for poison gas leaks? Either way, you’re evacuating to protect employees from danger. If you’re installing secondary containment to prevent oil spills, it may only need a new coat of paint to also prevent releases of industrial caustic.
These are only a few examples.
In 1996, the US EPA and other public safety authorities published some guidance on how to put together a One-Plan. You can find a copy here https://www.osha.gov/laws-regs/federalregister/1996-06-05-0
How Do I Create an Integrated Contingency Plan (ICP)?
The main idea of this guidance is to proceed like so:
- Identify the scope of the plan’s coverage. What federal/state/local mandates is it intended to comply with?
- Establish a core plan, that addresses most of the requirements of most of the mandates as much as possible,
- Use Annexes to provide key supporting information, not in the core plan, for particular emergency response scenarios.
The 4 Stages of the Core PlanThe four stages of a "core plan" are as follows:
- Discovery—what actions should a person take to assess and recognize a problem, and whom should they notify and how
- Initial response—Notify the relevant authorities, establish a response system, asses the situation, protection of the vulnerable (public, workers, infrastructure), followed by mitigating and containing releases, and deploying resources throughout
- Sustained Actions—after initial emergency response, additional care is not often needed. If it is, consult appropriate annex
- Termination and Follow-up actions—orderly demobilization and continuity with reporting or other administrative requirements.
Online Now: 20+ Hours of EH&S Manager Training Managing site compliance with the many complex EPA programs that affect your business—from the Clean Air and Clean Water Acts to TSCA, EPCRA, CERLCA, and more—is a major challenge. If you’re new to the field or need an update on changing EPA rules, the Complete Environmental Regulations Online Course will help you quickly build in-depth expertise.
Master EPA Compliance Anytime, Anywhere
JOIN US LIVE! The 2018-19 nationwide schedule for the Complete Environmental Regulations Workshop is now available. Collaborate with other managers to identify the requirements that apply to your facility, ask the right questions, and make optimal decisions about EPA compliance.
Tags: emergency, hazardous materials management, hazardous waste, ICP, PSM, response
Find a Post
These are the best commercial course references I have seen (10+ years). Great job!
EHS & Facility Engineer
The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!
The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.
Principal Industrial Hygienist
More thorough than a class I attended last year through another company.
Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!
This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.
This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.
Waste Management Professional
Amazing instructor; real-life examples. Lion training gets better every year!
I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!
Hazardous Waste Technician
I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective.
Download Our Latest Whitepaper
Some limited quantity reliefs are reserved for specific modes of transport. Use this guide to identify which reliefs you can capitalize on, and which do not apply to your operations.