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How to Create an Integrated Contingency Plan

Posted on October 1,2018 by James Griffin, CDGP

Drum_Spill_1.jpgAn integrated contingency plan (ICP) is a plan to respond to contingencies that integrates the requirements of multiple government agencies into one combined document.

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.

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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.


What Mandates Does the ICP Integrate?

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:
 
  • 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
Each of these different programs has its own scope for who it applies to, what risks it protects against, and who it’s meant to protect. Each program has its own administrative requirements for recordkeeping, reporting, coordinating with local authorities, or certifying, reviewing, and amending the plan. Even things like what kind of equipment you need, or personnel training to respond to emergencies, can be different.
Hazmat_Tech_Entry_Team_Chlorine_Release_46326526.jpg
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.


How Do I Create an Integrated Contingency Plan (ICP)?

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

The main idea of this guidance is to proceed like so:
 
  1. Identify the scope of the plan’s coverage. What federal/state/local mandates is it intended to comply with?
  2. Establish a core plan, that addresses most of the requirements of most of the mandates as much as possible,
  3. Use Annexes to provide key supporting information, not in the core plan, for particular emergency response scenarios.

The 4 Stages of the Core Plan

The four stages of a "core plan" are as follows:
 
  1. Discovery—what actions should a person take to assess and recognize a problem, and whom should they notify and how
  2. 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
  3. Sustained Actions—after initial emergency response, additional care is not often needed. If it is, consult appropriate annex
  4. Termination and Follow-up actions—orderly demobilization and continuity with reporting or other administrative requirements.
 

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