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1 Emergency Response and Accident Prevention Procedures PURPOSE This provides a description of the plans for the Management of Emergencies in accordance with the Emergency Plan (Ref 1.). Separate procedures describe how emergencies are responded to (Ref. 2, Ref. 3, Ref, 4). The purpose of the procedure is to ensure that for all potential major emergency scenario s identified there is a structure and plan in place to manage major emergencies, provide information and assist the emergency services. The activities taken to prevent and control Major Accidents are contained in the Major Accident Prevention Policy (C- EHS-POL-002, attached) SCOPE This procedure identifies the roles and responsibilities of key personnel, and the arrangements for contact & communications, both in planning for and in managing Major Emergencies. It details the process for conducting audits and review of Major Emergency Management arrangements. Incidents arising from terrorist or security breaches are not covered by this procedure. The Emergency Management organisational structure is detailed in Figure 1. A Major emergency is defined as: Large Uncontained Fire Explosion Significant Toxic Release Serious Injury or Fatality Significant Off-Site impact Any scenario likely to result in significant production downtime or product loss or which could adversely affect the company s reputation in any way. A major emergency may be precipitated by an outside force, such as a severe electrical storm, crashed aircraft, deliberate acts of arson, sabotage, civil strife or a serious off-site emergency which threatens to impact on the site either physically or operationally. The Major Emergency Management Team (MEMT) will provide any responses needed to: Government Departments and Regulatory Agencies requirements. BMS personnel The general public The Media For inspection purposes only. RESPONSIBILITIES PLANNING FOR MAJOR EMERGENCIES 1.1 General Manager When available, acts as Duty Emergency Commander (DEC) to the MEMT in a Major Emergency. Has overall responsibility for ensuring that adequate resources and structures are in place to deal adequately with major emergencies, including out-of-hours arrangements (Ref. 5) Ensures the MEMT is adequately trained and drilled to handle any major emergency scenarios identified. Ensures that the site Major Emergency Management arrangements are periodically tested and reviewed, in accordance with predetermined criteria in Table EHS Director Ensure that maps of the local area are available at the Emergency Control Centre to facilitate the Gardai or others in notifying local residents of any major problems which could arise. Ensures any fire, safety or rescue equipment and information are provided and maintained in the EPA Export :20:25:48
2 Emergency Operations Room (Wexford Room). To ensure that the Emergency Operations Plan and general documentation is up-dated as necessary to take account of changing circumstances Ensure all relevant drawings, procedures, information regarding storage and quantities of chemicals, etc. are available at the emergency control centre (Wexford room) and updated as necessary, and that key personnel are kept informed of what is expected of them. To ensure that all necessary equipment to deal with a spillage is available for emergency purposes. Consults, on an on-going basis with the local emergency services on site specific hazards, emergency response equipment and local emergency response and management issues. To head-up the follow-up investigation team. To compile and circulate notifications & report of incident to HSA, EPA, BMS CAS, BMS Worldwide Medicines Group EHS, Fingal County Council, where necessary, in a timely manner. Provides advice and direction in relation to major emergency management policy. Maintains an up-to date list of key contacts in an emergency. Ensures all major emergency scenarios are identified and assessed as described in the Major Accident Prevention Policy (Ref. 6). Ensures that adequate emergency management arrangements are provided for all scenarios identified for Major Accident Scenario Modelling (Ref 8.). Ensures that safe shutdown procedures (manual or automatic) are identified for all area operations in the event of a major emergency. Forms part of MEMT. Maintains the DEC rota. Facilitates and organises drills for the MEMT. 1.3 Duty Emergency Commander (DEC) Acts as Senior site Manager during a Major Emergency, until replaced by the General Manager Carry the Major Emergency bleeper and bag, and is available on call-out. Mobilises and Leads the MEMT in a Major Emergency Assigns any duties required by the MEMT. Is selected from the following group: - General Manager - Manufacturing Director - Security Director - Finance Director - EHS Director - Technical Services Director - MT Director For inspection purposes only. 1.4 Technical Services Director Acts as DEC on a rota basis. Ensure that any updates of Site Maps, Drawings etc. are provided to EHS to enable effective isolation of plant, storage tanks, gas mains, etc. 1.5 Manufacturing Director Acts as DEC on a rota basis. Participates in MEMT 1.6 Security Director Where available, directs security activities during an emergency Participates in MEMT Ensure that the security staff are trained and drilled in their duties in an emergency situation, and EPA Export :20:25:49
3 are capable of dealing with any problems which may arise. 1.7 Finance Director Ensures that finances are available to manage Major Emergencies Ensures alternative means of personnel & contractor payment are deal with all contingencies. Participates in MEMT 1.8 Major Emergency Management Team (MEMT) Participate in MEMT where mobilised and available. Respond to mobilisations and perform whatever duties assigned by the DEC. At least 8 MEMT members should be mobilised. The team is drawn from the following group: General Manager EHS Director Manufacturing Director/Managers HR Director/Manager TOG Manager Technical Services Director/Manager Utilities & Maintenance Managers Materials director/manager Facilities Manager IT Director & AIM Manager Q.C./Q.A. Director/Managers Safety/Environmental Manager RESPONSIBILITIES DURING A MAJOR EMERGENCY 1.9 Duty Emergency Commander (DEC) 1.10 General Responsibilities: For inspection purposes only. The Duty Emergency Commander assumes overall responsibility for all matters during a major emergency. This will be either the General Manager (where on-site) or in their absence a designated Senior Manager. Based on the availability, the DEC will appoint person(s) to carry out the duties functions in Sections 7-9. The Duty Emergency Commander (DEC) will direct, control and monitor all operations in the event of a serious emergency, so as to minimise injury, or death to people, or damage to property or the environment. They will ensure efficient liaison between Company personnel and external agencies and accurate dissemination of information. S/He will direct operations from the Emergency Control Centre (Security Building) or other area which he deems to be appropriate, depending on prevailing circumstances. Ensure key personnel and services are mobilised and notified as required. Mobilise the MEMT. Ensure that all evidence is preserved to facilitate any subsequent investigations, and that a contemporaneous record/log of events is maintained throughout, and photographs, video recordings taken as necessary. Maintain communications with outside Fire Brigade Officers and Gardai and provide any assistance which they may require including provision of details of the Fire Protection system. Handle media and public enquiries, and/or notify relatives if appropriate. EPA Export :20:25:49
4 1.11 Specific Responsibilities: Immediately upon notification of a serious emergency the DEC will go to the Emergency Control Centre (Wexford Room) and will consider the following: Assume overall control of the situation, and ensure that this procedure is put into effect. Secure access & egress to the site Activate alternative communication systems Ensure contact the neighbours and Management of adjacent Companies and inform them of the situation. Notify or instruct the any outside agencies, such as Gardai, Health and Safety Authority, Environmental Protection Agency, Fingal County Council. Initiate contact with the following BMS Groups: Worldwide Medicines EHS, European Vice President Technical Operations, Technical Operations Legal Counsel, Corporate Compliance Assurance Services. Ensure that adequate information is available & provided to the Chief Officers of the Fire Brigade and the Gardai, and that they are made aware of any effects which the emergency could have on areas or personnel outside the site. Ensure that the impact on the site production schedule is assessed and determine if suppliers I customers or insurers need to be notified. When the emergency has passed, decide when re-occupation may take place Human Resources Controller 1.13 General Responsibilities: In the event of a serious emergency the HR Director/Manager or in their absence, a designated member of the MEMT, will ensure that all possible efforts are made to alleviate hardship to the Company s employees and any other personnel on site. They will also ensure that only correct information is released to the media, if possible at a time when it will not have a distressing effect on relatives or friends of those involved. This would normally be the HR, Security or EHS Director Specific Responsibilities: Maintain a comprehensive listing of injured personnel on the site by liaising with the Eastern Health Board. If there are chemical injuries, ensure that any relevant Material Safety Data Sheets are transmitted with the injured for the attention of the hospital medical staff. For inspection purposes only. Ensure that next of kin of dead or seriously injured are notified of the situation as soon as possible. In this regard, assistance from the Gardai is likely to be necessary. Ensure that a hard copy list of all employees names, home addresses and next of kin is available in an emergency. Identify and attempt to alleviate any serious hardship caused to next of kin, where possible. Prepare draft information releases for the news media in conjunction with the Company Public Relations Company, for use in an emergencies, to cover all emergency scenarios identified (C-EHS-POL-004). Where the emergency is prolonged, arrange for relief of personnel, where possible, and provision of food and drink as necessary Technical/Process Controller 1.16 General Responsibilities: A designated member of the MEMT advises on technical, Process or site utilities and facilities. This would normally be the Manufacturing, Technical Services or MT Director EPA Export :20:25:49
5 1.17 Specific Responsibilities: Be available at the Emergency Control Centre (Wexford Room) to advise the DEC on relevant matters. Provide advice/assistance on stored chemicals and site utilities. In consultation where necessary with the DEC, Manufacturing, Technical Services and the Incident Controller, ensure safe shutdown of plants, utilities and other necessary precautionary measures. Ensure that Maintenance goes to the fire pumphouse, and verify the normal operation of the fire protection system, pumps and the fire water system. Ensure that any updates to Site Maps, Drawings etc. are provided to EHS to enable effective isolation of plant, storage tanks, gas mains, etc. Ensure that operations at the pumphouse are maintained in that area to enable those in attendance to act in the most effective manner. When the emergency is brought under control, assess the possibility of further problems (e.g. Utilities) which might affect personnel on being allowed to return to work. Provide advice/assistance on stored chemicals and site utilities Environmental Health and Safety Controller 1.19 General Responsibilities: A designated member of the MEMT who advises on regulatory matter and liaises with the ERT and the Emergency services. This would normally be the EHS or Security Director Specific Responsibilities: Provides advice and assistance in relation to regulatory notifications and compliance Maintain communications with the Incident Controller/ERT so that full and correct information is available at all times available. Advises the DEC on regulatory aspects/requirements of the emergency. Acts as point of communication with the emergency services Monitors emissions and provides safety/environmental data where required Verify any spillages and fire water are fully contained and routed to appropriate contained areas. Provides assistance to the fire and rescue services on site layout, stored chemicals, location of utilities Where appropriate, visit the scene of the emergency in order to assess the seriousness of the situation at first hand, and thus be better equipped to advise the DEC regarding action required. Set up the Emergency Control Centre (Conference Room). Organise for any on or off site environmental monitoring to be carried out if required. Carry a radio. For inspection purposes only. Notify Health and Safety Authority, Environmental Protection Agency, Fingal County Council, etc. Notify BMS Worldwide Medicines Group EHS and Compliance Assurance Services (CAS). To advise the DEC on various aspects of Health, Safety and Environment, as may be appropriate, depending on the nature of the emergency. To ensure that resetting of any alarms is carried out as soon as it is practicable. To head-up the follow-up investigation team. Seek and provide advice on likely health effects, chemical reactions, and specific spill control requirements. EPA Export :20:25:49
6 1.21 Security Controller 1.22 General Responsibilities: A designated member of the MEMT advises on security matters during a major emergency who will be to control access and ingress to the site; direct enquiries or communications to the MEMT; participate in evacuations. This would normally be the Security, Technical Services or EHS Director Specific Responsibilities: Assume responsibility for the control of traffic onto and off the site. Provide any keys required. Preserve the scene for investigation Record in real-time all details of the emergency, names of emergency services personnel involved, the chronology of events etc., and organise for any photo s to be taken. When the emergency is brought under control, assess the possibility of further problems (e.g. Utilities) which might affect personnel on being allowed to return to work. Sets up and operates the emergency telephone system Manage site communications issues. PROCEDURE 1.24 General Where an incident develops into a Major emergency, this section of the Emergency Plan is brought into action Duty Emergency Commander (DEC) From 5.00 pm on a Monday, until the following Monday morning designated Senior managers will on a rota basis, act as DEC Mobilisation of Major Emergency Management Team (MEMT) Where an emergency occurs, the Security Centre will be manned by the Incident Controller (IC), and the Security Officer(s) on duty (Ref 9). If the IC considers the incident serious enough, the IC will notify the DEC who will decide whether or not to mobilise the MEMT Major Emergency Management Team 1.28 Declaring a Serious Emergency The authority to declare a major emergency rests with the DEC, normally the General Manager or a senior Manager who assumes the role of DEC. The Security Building will be used as the Incident Response centre. Major Emergencies are controlled from the Administration room, or if not possible on site, in Swords. All the information and equipment needed to manage a Major Emergency will be located in a mobile cabinet located in the Wexford Room Mobilising MEMT and Key Services For inspection purposes only. Where a major emergency is declared during Office hours (normal working), designated MEMT Managers will report directly to the Emergency Control Centre (Conference room) or off-site as appropriate. Depending on who is available, the DEC will designate the various controllers identified in section 4 of this procedure. On shift, the Fire Brigade and other emergency services will be notified by the Incident Controller or the DEC. On shift at the direction of the DEC, MEMT members are to be contacted by telephone by the Incident Controller and/or Security. Announcements may be made via the PAVA system. The DEC will decide whether to notify the Fire Brigade, Ambulance Service and Gardai if not already on site. EPA Export :20:25:49
7 A list of emergency contacts for Key Personnel and Services is maintained (Ref 10.). Once the MEMT has assembled, from the Managers available the DEC will nominate MEMT members to act as Technical Services, EHS, Security and HR controllers and others as appropriate, to perform the duties identified in Section Rescuing and Treating Casualties All rescue efforts will be made by members of the ERT and the first aid teams until the external emergency services such as Fire Brigade and ambulance personnel arrive (Ref.11). Upon direction from the Incident Controller, ERT members will search affected areas to make fire damage assessments, identify any other hazards and search for casualties. All casualties are to be removed to an appropriate safe area (normally canteen) for first aid and then by the emergency services for further medical treatment or examination, or removal to hospital, as required. Priority for transportation to hospital will be determined by degree of injury, at the discretion of the emergency services in charge. Appropriate information should be provided to accompany any casualties going to hospital Contact with Emergency Services The EHS controller to liaises with the Emergency Services/Fire Officer. If a fire, explosion or spill involving chemicals occurs, and hazardous gases or large emissions of hazardous/flammable gases occur, local residents and schools/businesses which may be affected are to be notified. The MEMT will request the Emergency Services to inform those thought likely to be affected, as a matter of urgency. If there is danger of explosion, the same measures may need to be taken. In the case of emission of hazardous gases, local people may have to be evacuated to a safer area. However in most cases it is more suitable to ensure closing of windows and doors and warning people to stay indoors for a period of time. Portable environmental monitoring equipment will be maintained capable of detecting airborne concentrations of gases and or acid/solvent vapours The DEC will decide if neighbouring businesses and companies need to be advised of the situation, and asked to take appropriate measures to safeguard their personnel. Key Emergency Contact details are maintained (Ref.10). All non-essential personnel should be evacuated off site, and persons arriving at the site may need to be redirected. If there is the possibility of a deterioration of the situation or prolonged unsafe conditions, the DEC may decide to evacuate to a more suitable area off site base Minimising Damage to Property and the Environment All possible efforts should be made to contain the emergency within the site, and to prevent environmental pollution. Major spillages of chemicals should be dealt with in accordance with the Company procedures (Ref. 9) or in consultation with the EHS or Chemical Controllers. Spillages of hazardous materials should be routed to containment areas, and every effort should be made to ensure that no spillage is allowed to drain to surface water Regulatory Notifications In the event of a serious emission the Environmental Protection Agency and Fingal County Council are to be immediately informed by the EHS Controller. The Health and Safety Authority will be informed of any notifiable incidents, in accordance with Site procedures (Ref. 7) Containing and Controlling the Emergency For inspection purposes only. Every opportunity should be availed of to contain the emergency within a specific area. Where a clear assessment of the overall position is possible, after the search team has reported back, the DEC will make every effort to minimise damage and contain the emergency. EPA Export :20:25:49
8 The DEC may have to order a fall-back position in order to prevent danger to the lives or health of ERT or first aiders Notifying Relatives The HR Controller will liaise with the Emergency Services to compile lists of injured, and to contact next of kin Allowing Personnel back to Affected Areas In a serious emergency, the DEC will determine when/if a safe reoccupation of affected areas is possible, based on personal examination and after due consultation with the MEMT and any appropriate emergencies and third parties Preserving the Evidence To facilitate investigation of the incident, the scene of the emergency may need to be preserved as far as possible by the Security Controller. Items of plant and other equipment in the area are to be left undisturbed, except by rescue personnel or to extinguish a fire. The effected area should be cordoned off and entry restricted. All records relevant to the affected area, such as Maintenance records, EHS, Production, and Safety Inspections, etc., are to be gathered and maintained with the Emergency Control Centre records of the emergency Releasing Information To ensure that authoritative and correct information only is released to the news media, the HR Controller shall be the only person authorised to release such information. EMERGENCY CONTROL CENTRE 1.39 Key Materials & Information to be maintained: The following materials, equipment & information will be maintained by EHS at the Emergency Control Centre (Wexford room): Drawings of the site showing the location of buildings buildings, storage tanks, drum storage areas; fire hydrants/fire pumps/fire water system, spillage containment areas, drainage arrangement, air emission vents, etc. Fire fighting equipment and materials Detail of assembly points and casualty treatment areas Lists of employees by area for wardens A map of the surrounding area showing access points to the facility and the locations of houses, schools, other companies, environmental features etc. Drawings of individual buildings showing access points to utilities (gas, electricity, water, stored chemicals) A list of all employees addresses and telephone numbers and next of Kin. Note pads and pens. Evacuation checklists for all Company personnel. Copies of all Emergency Plans and Procedures. Hard copies of Material Safety Data Sheets. Details of bulk tank contents and drum store inventories. Manufacturing and Tech. Services process flow sheets. Key Personnel List/Contact Numbers & Key Emergency Telephone Numbers. ERT/First Aiders Registers. For inspection purposes only. Details of fire water retention pond and drainage systems Copies of Emergency Response Procedures EPA Export :20:25:49
9 Site plans that can be marked up to show the development of an incident and the deployment of emergency response resources, areas evacuated and other related information. Log book to maintain a record of all messages sent and received Fully charged Mobile Phone Camera and Camcorder 1.40 Alternative Emergency Control Centre: In case the Conference Room is damaged or unusable, the Waterford Room will be used as an alternative Emergency Control Centre. Should both of these be unsuitable, the Main DEC will decide what alternative course to follow e.g. relocation to Swords laboratories. AUDIT & REVIEW The testing, monitoring and auditing of this Procedure and arrangements is the responsibility of the General Manager. The Procedures will be tested and reviewed at least annually against the criteria listed in Table1. Table 1. CRITERIA TO BE INCLUDED IN MAJOR EMERGENCY RESPONSE TESTS AND REVIEWS Type of Test Content Criteria for success Carried out by: 1. Simple data verification. 1. Administrative check of the information contained in emergency plans, and documentation held in the Emergency Management Centre. 2. Detailed incident scenario. 2. Make amendments to the information as necessary. 1. Planned scenario exercise with predetermined objectives. (The scale of the exercise to be determined - may sometimes involve external stakeholders). 2. The exercise is reviewed by participating personnel, observers and MEMT and lessons learnt identified & communicated. 3. Real Incidents. 1. A review of the response to the incident by the participants led by EHS function. 1. The information is accurate and up to date. 1. Demonstration that staff are available to respond promptly and the site communications network works. For inspection purposes only. 2. Evidence that staff make decisions in accordance with the Emergency response and management Plans, policies & procedures. 3. The objectives set are achieved and performance standards met. 4. Any lessons learned are built into the system to improve future performance. 1. The incident results in a response that puts into practice the major emergency arrangements. 2. Demonstration that staff are available to respond promptly and the communications network General Manager or designated MEMT personnel. 1. Exercise planned and conducted by General Manager, EHS Director & Security Director. 2. Review of performance by MEMT & participants. 1. EHS Director. EPA Export :20:25:49
10 Type of Test Content Criteria for success Carried out by: is operational. 3. Evidence that staff make decisions in accordance with the Major Emergency Procedures and plans. 4. Any lessons learned are built into the system to improve future performance. For inspection purposes only. EPA Export :20:25:49
11 FIGURE 1. MEMT ORGANIZATION CHART Duty Emergency Commander (DEC) Regulatory Agencies, Emergency Services ERT Leader ERT Incident Controller Security Major Emergency Management Team (MEMT) For inspection purposes only. Public, neighbours, Media, Insurers, Corporate EPA Export :20:25:49
12 PROCESS MAP EMERGENCY PLANS Alarm is raised 2.2 Emergency Response Procedures Incident Occurs Deviations Reponse is logged No Is ERT required? Yes Incident Report Incident Controller/ERT mobilised 2.3 No Genuine Emergency? Yes Area(s) evacuated as required Yes Is the situation under control? No Major Emergency? Yes Yes Site evacuation Emergency services notified For inspection purposes only. No ERT respond and assess situation List of personnel onsite generated and used to check staff DEC & MEMT Mobilised Further action needed? Yes No Major Emergency Management Procedures ERT performs action Emergency resolved Deviations Incident report EPA Export :20:25:49
13 REFERENCES 1. C-EHS-POL-005, Emergency Plan 2. C-EHS-SOP-020, ERT Management 3. C-EHS-SOP-036, Emergency Response Procedures, ERT 4. C-EHS-SOP-089, Emergency Response Procedures, Incident Controller 5. C-EHS-FORM-048, Public Enquiry & Complaint Form. 6. C-EHS-POL-004, Major Accident Prevention Policy 7. C-EHS-SOP-009, Government Agency Inspections, Incident Notifications 8. Major Accident Scenario Modelling and Risk Assessment, PM Doc Ref RP C-EHS-SOP-045, Spill Control procedure 10. C-EHS-RGT-007, Key Contacts in an emergency. 11. C-HR-SOP-007, Care of Injured Employees ABBREVIATIONS / GLOSSARY Phrase EHS SOP DEC MEMT ERT Explanation Environmental Health and Safety Department Standard Operating Procedure Duty Emergency Commander Major Emergency Management Team Emergency Response Team For inspection purposes only. EPA Export :20:25:49
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