Emergency planning at a major hazard facility

Transcription

1 Guidance Note Emergency planning Advice for operators of major hazard facilities on developing an emergency plan. April Introduction Features of a successful emergency plan Key concepts Key definitions 2 2. Planning and preparation Time scales Draft emergency plans 4 3. The emergency plan process Contents of emergency plans Planning for on-site emergencies Planning for off-site emergencies What range of scenarios 12 need to be considered? 3.5 Performance indicators 15 for emergency plans 3.6 Testing the emergency plan Review and update Compliance checklist Further reading Introduction The major hazard facility parts of the Occupational Health and Safety Regulations 2007 (OHS Regulations) set out legal duties for control of risks from operating a major hazard facility (MHF). They apply to the operator of a facility who is the employer with management or control of the facility. To obtain a licence to operate an MHF in Victoria, MHF operators are required to submit a Safety Case to Worksafe Victoria which sets out how the facility will be operated safely. This guidance note will assist operators of dangerous goods sites develop an emergency plan before applying for an MHF licence or prior to dangerous goods inventories reaching Schedule 9 threshold quantities. It covers preparation, implementation and testing of emergency plans required under part 5.2 of the MHF regulations. It will be of use to those responsible for emergency planning at a facility and those developing the facility s Safety Case. An effective emergency plan is an essential part of a comprehensive risk management approach for an MHF because the potential consequences of major incidents are severe, and it may not be possible to eliminate the risk of major incidents altogether. 1.1 Features of a successful emergency plan The following factors are critical to emergency planning and WorkSafe will expect these to be addressed: Development of an emergency plan that is appropriate to the hazards and risks of the facility and that mitigates these so far as is reasonably practicable. The emergency plan should be: documented well-structured and succinct specific to the facility and to the identified major hazards effective in addressing the on-site and off-site consequences of a major incident occurring GUI0134/01/02.11

2 understood by workers and other potentially affected parties subject to review, testing and update. The emergency plan needs to interface with, and be consistent with, the expectations, resources, communications channels, policies and procedures of the emergency services and the councils for potentially affected areas and of any adjacent MHF. Integration of the emergency plan into the Safety Management System (SMS), safety and property protection assessments and the Safety Case. Evaluation of emergency planning options and demonstration of adequacy of the adopted emergency plan as a control measure within the Safety Case. The emergency plan should reflect relevant studies (eg fire safety study and quantitative risk assessment). It should also be consistent with related plans (eg the State Emergency Plan). 1.2 Key concepts The operator of an MHF must prepare an emergency plan in relation to the on-site and off-site effects of any major incident that may occur at the facility. The emergency plan must be developed in conjunction with the emergency services and, in relation to off-site impact, with the municipal councils. This requires active involvement of these parties to reach agreement on how all three parties will respond to emergencies. A draft of the emergency plan for the facility must be submitted to WorkSafe along with the Safety Case outline within 90 days of registration. The Safety Case outline must include a detailed, time-framed program of activities, including those for finalisation of the emergency plan in compliance with the MHF regulations. The emergency plan must be treated as a control measure and a range of emergency planning provisions must be considered in the Safety Assessment. Reasons for selecting certain provisions and rejecting others must be documented; workers must have roles to assist the operator in this; health and safety representatives (HSR) and workers must be consulted; and the Safety Case must be sufficient to demonstrate the adequacy of the emergency plan. The contents of the emergency plan must be communicated to all persons who have a role within the plan. It should be comprehended and understood by these persons. The emergency plan must be fully tested at least every three years and the operator must take all reasonable steps to arrange participation of the emergency services in these tests. The emergency plan must be implemented immediately if there is a major incident or an uncontrolled event that could lead to a major incident. The operator must notify the emergency services immediately if a major incident occurs. The emergency plan must be reviewed and updated if WorkSafe directs, if there is a relevant change to the facility, if a major incident occurs, if a test shows deficiencies and every five years. Attributes of an emergency plan are that it is specific to the facility and hazards, linked to the Safety Assessment and the Safety Case, integrated within the SMS and linked to higher level plans (eg at state level). The emergency plan must include a strategy to manage the consequence of each major incident. Facilities may work in conjunction with emergency services organisations to develop these strategies, but the expectations of all parties must be clearly expressed and agreed. 1.3 Key definitions Control measure (control): Any system, procedure, process, device or other means of eliminating, preventing, reducing or mitigating the risk of major incidents at an MHF. Controls can include physical equipment, process control systems, management processes, operating or maintenance procedures, the emergency plan and key personnel and their actions. Hazard (related to an MHF): Any activity, procedure, plant, process, substance, situation or any other circumstance that could cause, or contribute to causing, a major incident. Hazard identification: The process of identifying hazards as described in the Worksafe guidance note Hazard identification. Major incident (related to an MHF): An uncontrolled incident, including an emission, loss of containment, escape, fire, explosion or release of energy that involves Schedule 9 materials and poses a serious and immediate risk to health and safety. Safety Assessment: A Safety Assessment process consistent with international risk assessment standards, including AS/NZS ISO Risk Management. A Safety Assessment involves an investigation and analysis of the major incident hazards and major incidents so as to provide the operator with a detailed understanding of all aspects of risk to health and safety associated with major incidents, including 2

3 (a) the nature of each hazard and major incident (b) the likelihood of each hazard causing a major incident (c) in the event of a major incident occurring (i) its magnitude, and (ii) the severity of its consequences to persons both on-site and off-site (d) the range of risk control measures considered. So far as is reasonably practicable: To reduce risk to a level so far as is reasonably practicable involves balancing the benefit of a reduction in risk against factors such as time, trouble, difficulty and cost of achieving that reduction. This requires consideration of: (a) the likelihood of the hazard or risk concerned eventuating (b) the degree of harm that would result if the hazard or risk eventuated (c) what the person concerned knows, or ought reasonably to know, about the hazard or risk and any ways of eliminating or reducing the hazard or risk (d) the availability and suitability of ways to eliminate or reduce the hazard or risk and (e) the cost of eliminating or reducing the hazard or risk. More information on key terms is found in other MHF guidance material available from the WorkSafe website and in the definitions of the OHS Regulations (reg 1.1.5). 2. Planning and preparation The operator must have a process for the development, maintenance, communication, review and implementation of the emergency plan for major incidents. The emergency plan should be treated as a control measure under the MHF regulations. The process must involve the relevant emergency services in relation to all aspects, and the relevant councils in relation to off-site aspects. The process must also include consultation with HSR, and involvement of workers in accordance with their safety roles developed under reg The process of preparing and maintaining an emergency plan is summarised in Figure 2.1. The emergency plan has components which require preparation and review in conjunction with other parties as well as links to other processes and documents at a facility. Figure 2.1 The process of preparation and maintenance of an emergency plan Safety Assessment Preparation Adopt as control measure Testing Review Demonstrate adequacy in Safety Case Implementation Operator alone Operator in conjunction with emergency services and councils 3

4 2.1 Time scales The operator of an MHF must submit a draft emergency plan to WorkSafe at the same time as submitting the Safety Case outline required under reg (see guidance note Safety Case outline for a major hazard facility) ie within 90 days of being informed that the facility has been registered as an MHF. The operator of a registered MHF has a period of 30 months to achieve full compliance with all the requirements of the MHF regulations including any related to emergency planning. At all times in this 30 month period, the operator must comply with the duties under part 5.2, divisions 3, 5 and 10 so far as is reasonably practicable. Division 3 includes provisions related to emergency planning. Thus WorkSafe may expect the operator to achieve full compliance with critical emergency planning requirements in a lesser time scale than 30 months, particularly in cases where there is a high hazard or risk, or in cases where suitable emergency planning provisions are well known and easily implemented. 2.2 Draft emergency plans A draft emergency plan for the MHF must be submitted with the Safety Case outline. This can be based on an existing emergency plan as required by the Dangerous Goods Storage and Handling Regulations 2000 (DG (S&H) Regulations), providing the existing plan is based on the current level of knowledge of hazards and risks and that it contains the basic elements of a robust and workable plan. The operator should consider the information included in the dangerous goods manifest. This typically includes information on inventories and locations and provides a useful input to the emergency plan. The draft plan in the Safety Case outline should include a description of the program of work required to bring the emergency plan into full compliance with the MHF regulations, if it is not already. The emergency plan must achieve full compliance with the requirements of the MHF regulations. The plan must: include all information required by Schedule 11 of the OHS Regulations address on-site and off-site consequences of major incidents that could occur on the facility be developed in conjunction with the emergency services and the local councils. Figure 2.2 Example contents of draft emergency plan (a) Site and hazard detail (b) Emergency response command structure and personnel (c) Notifications (d) Emergency response resources (e) Emergency procedures The Safety Case must also provide sufficient information to demonstrate that the emergency plan is a suitable and effective control measure which (in combination with the other control measures) reduces risks so far as is reasonably practicable. This will require the operator to assess the emergency plan and consider options for the plan within the Safety Assessment process. Any deficiencies in the existing emergency plan should be identified by the operator and noted in the draft emergency plan or the Safety Case outline. The Safety Case outline should detail how and when the deficiencies will be corrected Development of the emergency plan The operator must prepare an emergency plan addressing the on-site and off-site consequences of major incidents that could arise at the facility and, by implication, all uncontrolled events that could lead to a major incident. The plan must be prepared in conjunction with the emergency services and also, for off-site effects, in conjunction with the relevant councils. The operator must, if practicable, consult with HSR and workers in developing and reviewing the emergency plan. The operator must also develop roles for workers to assist the operator in this activity. Active participation of the emergency services, councils, HSR and workers is required to ensure that agreement is reached on the roles of each party in responding to emergencies. The various parties need to determine that the proposed arrangements are workable, that the communication lines and command structures are integrated and that equipment and supplies are compatible where necessary. When developing the plan, the operator will often develop a plan, try it and then refine it. Response objectives and goals of the emergency response arrangements (see next page for examples) are often refined at this point. These goals and objectives should be set in conjunction with the emergency services, councils and workers, and also (if appropriate) with the operators of adjacent or connected hazardous facilities. However, involvement of councils does not need to include events where consequences are limited to within the site boundary. 4

5 Examples of emergency plan goals, objectives and performance standards All non-emergency response workers will be evacuated to a safe assembly area within X minutes of alarm being issued. All major incidents identified in the Safety Case will be represented in the emergency plan and specific tests carried out to determine effectiveness of response to each incident within Y years. All evacuation and response pathways will have defined primary and secondary routes for movement of personnel and equipment. Protection levels for assembly areas will be set based on consequences of major incidents. Maximum personnel exposure levels during evacuation will be set according to consequences assessed for major incidents. Initiation of the site or plant emergency alarms will be planned out for all identified major incidents and uncontrolled events able to lead to major incidents. Personnel will be trained in the use of these. Notification of the emergency services and set-up of the emergency response centre will be carried out within Z minutes of a potential major incident being identified. On-site emergency response teams will have first priority to protect themselves from exposure to specific consequence levels defined in the Safety Assessment. Their second priority will be to search for and rescue missing persons. The final priority is property protection. No emergency response team will be exposed above certain levels of consequence while fighting fires. There will be a total of X trained emergency coordinators and Y trained emergency response commanders on-site or on call at all times. Workers will be involved in setting, training and testing performance standards for their own roles in emergency response in order to ensure arrangements are workable. Firefighting water will be contained on-site by use of an effluent diversion pond to ensure environmental protection. Fire protection reserves will be held at Z% of maximum predicted demand levels. During the development of the plan the operator should also consider the following matters: The necessary emergency response arrangements must, in combination with other control measures, either eliminate risks or reduce them so far as is reasonably practicable. Continuous improvement of the emergency response arrangements is achieved by conducting test exercises. As a starting point in this process, the operator may choose to use the current emergency response arrangements or an industry standard. These evaluations must be performed as part of the Safety Assessment. The arrangements should include the procedures, roles and resources (hardware and software) that are required to achieve the response. They should identify all individuals and organisations with a role to play and the expertise and capabilities relevant to the required response. The required emergency response capabilities are performance standards for the control measures that comprise the emergency plan. See left for some examples. When defining arrangements, it is necessary to determine how responses will be coordinated, and to allocate responsibilities. It may be necessary to identify situations where the routine procedures and resources are not sufficient and develop contingency plans for these. Facilities will plan to respond to a range of emergencies including major incidents, smaller incidents, environmental spills, power/utilities failure, extreme weather, personal injury etc. While the requirements under the MHF regulations relate only to emergency plans for major incidents, WorkSafe expects operators will develop a single, integrated emergency plan for all types of emergency. 5

6 Examples of arrangements in emergency plan Command structure between operator and emergency services in event of major on-site incident. Command structure between operator, emergency services and councils in event of major incident with potential to spread off-site or with actual off-site effects. Communications channels for all parties involved or requiring information. Backup contingency plans for all of the above, including any mutual aid agreements and associated deployment procedures. Pre-incident plans for specific actions and arrangements for specific scenarios. Training and rostering schedules for emergency coordinators and general workers. The analysis of emergency response arrangements should consider all potential major incidents that could occur at the facility, as well as all the hazards that could cause or contribute to causing a major incident if these can affect the nature of the incident and the means of response to it (see Figure 2.3). However it should be possible to develop the emergency plan based on a representative cross-section of incident types so that it is not necessary to incorporate every single major incident identified for the facility. The analysis should use the results of safety and property protection assessments, and should feed back into those assessments as necessary. Figure 2.3 Examples of major incident scenarios included in an emergency plan When the emergency plan, its performance standards and contingency arrangements have all been defined, personnel will need to be trained in its content and the local community informed of the relevant components. This aspect is covered later and in the guidance note Consultation and the role of HSR The emergency plan must be properly incorporated within the overall facility SMS and Safety Case as a control measure subject to the same regime as all other control measures (see the guidance note Control measures). The development of the emergency plan therefore needs to include processes for testing, review, training and informing. General approaches to emergency planning are presented in a number of key documents from external agencies (see section 3). Detailed emergency firefighting and operational response plans and procedures developed via approaches such as pre-incident planning should be incorporated (as appropriate) in the overall emergency plan for the facility. All aspects of the emergency plan need to be realistic, workable and agreed to by the relevant parties. This includes assumptions regarding actions required, timing, effectiveness of detection methods, decision-making processes and number of people on-site day shift/night shift. The emergency plan should be robust and take into account the less than ideal conditions that may prevail in a real emergency which often make it difficult to achieve ideal responses in practice. Figure 2.4 summarises the possible processes for formulating an emergency plan. Rim seal fire Single tank roof fire Full or intermediate bund fire Spill and fire from transfer pipe Pump area fire Road tanker loading spill and dispersion Process unit explosion and missiles 6

7 Figure 2.4 Flow chart for development of an emergency plan Hazard and consequences analysis Define objectives for emergencies Involve workers, emergency services and councils Set emergency response objectives Define a set of existing or proposed emergency response arrangements Analyse the emergency response arrangements Reduce/remove the hazard or modify the emergency response arrangements Set emergency response system goals Do arrangements meets system goals? Yes Are risks eliminated or reduced so far as reasonably practicable? Yes Set detailed performance standards No No Monitor performance to ensure risks are eliminated/reduced Train personnel and inform community Include in Safety Case and SMS 7

8 In developing the emergency plan it is important to recognise the relationships between different types of emergency management documents. These include the site information folder, the pre-incident plan, the pre-incident response plan, the municipal emergency plan and the site emergency plan. These are summarised in the table below and the relationships shown in Figure 2.5. Table 2.1 Documents for emergency management Documents for emergency management Site information folder Pre-incident plan Pre-incident response plan Municipal emergency plan Site specific information required by the first attending fire brigade personnel. Includes the site dangerous goods manifest. Site plans including general layout, fire protection facilities and utilities. Schedule 11 requirements. Specific action plans that are additional to the site emergency plan. Included as part of the procedures to be undertaken at a specific site. Generally an addendum to the site emergency plan. Specific to the emergency services. Planning process for emergency services response to an identified hazard. Includes escalation responses. Relies on the site identifying hazards, event types and impact areas, control measures available, site command structure, resource needs and control strategies. Identify how the municipality will respond to emergencies. Relies on the site to identify hazards, event types and impact areas where there is an off-site consequence (refer section 3.3). Figure 2.5 Emergency planning relationships Municipal emergency plan Site emergency plan Identification of potential community impact Event type and size Control measures Command structure Resources Site information folder DG manifest Site emergency philosophy Procedures Contact details Pre-incident plan Event specific Addendum to site emergency plan Pre-incident response plan Fire service delivery for site 8

9 3. The emergency plan process Site and hazard detail Command and structure and personnel Notifications Resources Procedures (a) Name, location, address and nature of operations (b) Detailed map of the facility and surrounding area (c) Inventory of Schedule 9 materials (d) Maximum/minimum number of persons expected at the facility, day shift/night shift (e) Infrastructure likely to be affected by a major incident (f) Emergency planning assumptions (g) Description of measures to control the consequence of each hazard and major incident (h) Command philosophy and structure for emergencies (i) Details of emergency contact personnel (j) Allocation of personnel for implementing the plan (k) Arrangements for mutual aid between adjacent facilities (l) Procedures for providing early warning of a major incident (m) Details of on-site and off-site warning systems (n) Contact details for the emergency services (o) Details of on-site communications systems (p) Details of emergency resources on-site (q) Arrangement for obtaining additional external resources (r) Procedures for safe evacuation and muster of personnel (s) Details of control points and procedures for essential services (t) Procedures for containment of any incident (u) Procedures for decontamination following an incident 3.1 Contents of emergency plans The required contents of the emergency plan are specified in Schedule 11 of the OHS Regulations and are summarised above. Although the plan must contain the items specific in Schedule 11, there may also be additional items not specified that are required for the plan to be workable/functional. 3.2 Planning for on-site emergencies The emergency plan must address on-site consequences and on-site response in relation to major incidents, and these aspects must be prepared in conjunction with the emergency services. The emergency plan should include provision for incidents that may be controlled within the facility boundary, using either on-site resources alone, or on-site resources plus external assistance. In most circumstances, the emergency plan should provide for a sufficient on-site response (including personnel and resources) to control incidents such that they do not cause off-site effects. The plan should also cater for different conditions, eg out of hours manning, limited water availability or adverse weather conditions. The plan should address incidents that may occur relatively frequently (eg uncontrolled events which could lead to a major incident or smaller-scale major incidents) but should also address extremely rare events with serious consequences such as major incidents, unless these can be shown to be so unlikely or so extreme that planning for them is unrealistic (eg meteorite impact). An example of included incidents is shown in Figure 3.1. On-site emergency planning must be conducted in conjunction with the emergency services, even for incidents where effects are minor and confined within the boundaries of the facility, as the emergency services would attend all such incidents. The operator and emergency services would need to agree on what responsibilities they will each take in different situations. If appropriate, the operator may also consult with WorkSafe, the Environment Protection Authority and with councils for adjacent areas. The on-site activities would need to be planned to occur in an integrated and effective manner whereby the operator and emergency services are working together with compatibility between people and equipment. 9

10 Figure 3.1 Example of emergency plan information for on-site issues Storage area fire scenarios Initial event: pump area fire Detection arrangements and timing Escalation event: single tank roof fire Consequences: equipment damage and personnel injury zones for initial and escalation events Operational response plan: actions to limit operations and shutdown equipment On-site emergency response plan: assess, mobilise, search and rescue, firefighting On-site command arrangements: notification, evacuation etc Emergency services attendance plan Post-incident actions 3.3 Planning for off-site emergencies The expectation is that response to major incidents or uncontrolled events aims, wherever possible, to limit the effects to on-site. The operator should also plan for situations where a major incident results in far-reaching consequences which could impact off-site locations. This is required for all facilities unless the operator can justify that the facility has no potential to cause harm to health and safety or damage to property beyond the boundary. The emergency plan must address any off-site consequences and off-site response in relation to major incidents and these aspects must be prepared in conjunction with the relevant emergency services and councils. The operator must work with the emergency services and the relevant councils on developing the off-site planning aspects, which may include DISPLAN as prepared under the Emergency Management Act 1986 (EM Act). The parties need to agree on both the on-site and off-site planning arrangements for any incident having both on-site and off-site effects. For such a plan to work effectively, the three parties need to clearly define areas of joint cooperation and areas where individual parties take sole responsibility. The MHF regulations do not prescribe how responsibilities should be allocated between the parties; it is necessary however to demonstrate to all parties that the plan is workable, is clearly defined in terms of roles and responsibilities and provides for an integrated and effective response. This includes issues such as command and communication channels, compatibility of equipment and informing off-site populations (see Figure 3.2). It may also be appropriate to involve adjacent industrial facilities, particularly if these are also MHFs, if there would be benefits from mutual aid arrangements. 10

11 Figure 3.2 Example of emergency plan information for off-site issues Light industry Main road Storage and process fire scenario Initial event: process unit explosion and missiles Detection arrangements and timing Escalation event: intermediate bund fire Consequences to people and property Operational response plan On-site command arrangements On-site command arrangements Emergency services attendance plan Emergency services off-site action plan Council action plan Post-incident actions Using the Emergency Management Manual, Victoria In Victoria, planning for emergencies with off-site consequences that may have an impact on the general community, is carried out under the EM Act. Requirements are outlined in the Emergency Management Manual, Victoria which details responsibilities for the management of emergencies, where management is taken to include planning, response and recovery. Operators of MHFs should be familiar with these requirements, and take account of them in their emergency planning. The following is an outline of the provisions of the EM Act: Local incident management is provided at the scene of the emergency. Management of consequences of emergencies impacting on the wider community has multi-layered support from a municipal level through to regional, state and national level support as required. Coordination at each level within Victoria is the responsibility of Victoria Police. The Municipal Emergency Response Coordinator (MERC, a nominated officer of Victoria Police) is responsible for ensuring that planning is adequate for the risks faced by the community. Councils have a large involvement in emergency response, in that they provide equipment, facilities, services and personnel to support the combat agencies (emergency services). Councils also have the prime responsibility for community recovery from an emergency. To this end, each municipality has a nominated Municipal Emergency Resources Officer (MERO). Planning for consequences of emergencies affecting the community is carried out by the Municipal Emergency Planning Committee (MEPC) which comprises representatives of the council and its emergency services and is normally chaired by the MERC. Incidents with off-site consequences should, if possible, be planned for in consultation with all the necessary agencies, personnel and committees. For the MEPC to effectively plan for off-site impacts of potential major incidents at an MHF, the operator would need to provide adequate information to each person or group, to enable appropriate planning to be undertaken. 11

12 Emergency services likely to be involved in the response to any incident need relevant information to enable them to pre-plan their response, based on the types of event that are possible. Emergency services also need to plan for an escalation of events to provide the appropriate level of resources and management for the maximum potential consequences. Issues that require agreement between the operator and the emergencies services include: types of equipment and materials to be used on-site should be compatible with the equipment/materials brought to site by the emergency services eg foam, hose fittings. This compatibility should cover issues such as water supply pressures (eg mobile pump performance versus ring main design pressure). Consultation with the water supply company may also be needed reporting structures and authorities need to be agreed for cases when site and emergency services personnel are working together to combat an incident. This should include processes for hand over of responsibilities and roles upon arrival of the emergency services expectations of the operator regarding emergency services performance and vice versa. This should include response time, numbers of available emergency personnel, competence and realistic expectations of what can occur during the emergency etc the need to inform the public about incidents that may occur, how they will be notified of incidents if they occur, and what to do in that event. In particular, they should be informed about who they should accept instructions from during an emergency. In some locations there may also be a need to interface the emergency plan under the MHF regulations with plans required by other legislation. Examples are coastal sites where there may need to be plans for management of marine spills and wharves and jetties where there may need to be interfaces with the emergency plans of the port authority. 3.4 What range of scenarios need to be considered? The MHF regulations require the definition of local community and the scope of the emergency plan to correspond to the area around the facility within which the health and safety of people could be adversely affected by a major incident. For the majority of facilities, there is a spectrum of potential major incidents of varying nature, likelihood and severity, each of which could lead to different emergency planning. The emergency planning process needs to consider the full spectrum of incidents, and also uncontrolled events which could lead to major incidents, so that the plan can be put into effect for any major incident or uncontrolled event, as required by reg One approach is to base the emergency plan on the worst case scenario and a range of other scenarios to represent the full spectrum. See the guidance note Hazard identification for more information on the worst case scenario. It may be appropriate (subject to meeting all of the requirements in reg and Schedule 11) to select other ranges of major incident scenarios as the primary basis for the emergency plan, if it can be shown that these scenarios are the most appropriate for planning purposes. This may require consideration of factors such as the level of risk for which other types of emergency plans are made, the nature of the overall risk profile in the area, the cost of planning for extreme events and the need for meaningful information and dialogue with the community. For example, the local area emergency plan may be based around natural disasters that could happen between once per year and once every 100 years (see Figure 3.3). It may be meaningless to develop an emergency plan around a scenario not likely to occur in 1000 years but appropriate for a less severe and more likely major incident, and then include contingency plans, mutual aid agreements, practical deployment procedures etc to assist in managing a worst case scenario. For example, a realistic spill to a bund for a full rupture of a 100 mm pipe, given installed detection, remotely operated valves etc is say, 150 m 3 an hour. The worst case scenario is a total tank loss and full bund fire. 12

13 Figure 3.3 Scenarios to be used to formulate the local emergency plan Frequent event Multiple injury road accident Small fire on-site Major fire in area Rare event Serious flood Major toxic release Extremely rare Worst case MHF scenario Few injuries MHF emergency scenarios Multiple injuries Other types of emergencies Far-reaching, multiple injuries, escalation to other sites The operator, involved workers, emergency services and local councils should discuss the appropriate range of scenarios for emergency planning purposes, based on the results of the hazard identification and Safety Assessment, and taking into account the above considerations. The Safety Assessment may indicate the appropriate scenarios to select by the shape of the distribution of incident severity and likelihood. For example, if the distribution is relatively flat (different scenarios all have roughly similar likelihood), this may indicate that the appropriate range of scenarios for the emergency plan needs to include the worst case scenario (see Figure 3.4). The selection of scenarios on which to base the emergency plan will influence how the local community is defined and what information will be provided to them. Hence care is required in making the appropriate selection, and WorkSafe expects the operator to document and be able to justify this selection in the Safety Assessment. It may be appropriate to discuss with the wider community before finalising these issues. In considering which of the spectrum of scenarios are most appropriate for the emergency plan, the operator needs to bear in mind that the plan needs to incorporate the potential effects on people both on-site and off-site. Clearly, a significant scale event needs to be featured in the emergency plan to reflect potential off-site effects and to ensure the emergency plan is robust and credible. The operator should consider the incident history, both at the facility and within similar facilities, in arriving at a justified selection of relevant scenarios for planning purposes. It would be inappropriate to base emergency plans on an event of a lower scale than is indicated by industry accident history. Figure 3.4 Effect of severity-likelihood distribution on selection of emergency scenarios Frequent event Flat distribution: use worst case scenario Rare event Curve distribution: use range of scenarios Extremely rare Few injuries Multiple injuries Far-reaching, multiple injuries, escalation to other sites 13

14 Once the operator (in conjunction with the involved workers, emergency services and the MEPC has selected the appropriate emergency plan scenarios, the plan should contain information and actions explicitly related to those scenarios. This should include, for example, the means of informing the community within the area if an incident occurs, the nature of its effects and the appropriate actions the community should take (shelter in place, provisions for evacuation and treatment of injured persons etc). However, it should also be robust enough to be applicable to other potential scenarios not specifically used in developing the plan. 3.5 Performance indicators for emergency plans The emergency plan, and the personnel and resources that it calls upon, must be treated as control measures under the MHF regulations. Clause 7 of Schedule 10 requires the operator to set performance indicators for the effectiveness of the adopted control measures and hence also for the emergency plan, including tests of the effectiveness of the control measures, indicators of failure, reporting of any such failures and corrective actions to take. Examples of performance indicators The number, training and competency/capability of the on-site emergency response team. The time from raising an alarm to successful evacuation of on-site personnel to a secure muster point. The maximum time for mobilisation of the on-site emergency response team, to defined levels. The maximum time for attendance of the emergency services, to defined levels (first response etc). The time taken to alert the local community in the event of a major incident, and to take necessary steps to evacuate from, and control access to, any seriously impacted areas. The type, quantity, capacity and reliability of equipment and supplies that may be used. 3.6 Testing the emergency plan The MHF regulations (reg ) require the emergency plan to be tested at least every three years. If it is not practicable to test all parts of the plan simultaneously, several tests may be needed during the three year period, at least one of which should be a major exercise involving the emergency services, and possibly also adjacent facilities, the local council and nearby residents. The systems should be shown to function correctly under simulated emergency conditions and not simply during routine off-line tests. Tests of the emergency plan should be used to confirm that the following aspects continue to function as required: ability to implement on-site and off-site emergency responses effectively and according to goals alarm and communications systems call-out of internal/external emergency personnel critical emergency equipment. 3.7 Review and update As the emergency plan is a control measure and also a part of the SMS for the facility, the MHF regulations (reg ) require it to be reviewed and updated in certain circumstances, including: if WorkSafe directs before a modification to the facility after a major incident at the facility when a test indicates a deficiency a change in the circumstances that formed the basis of the Property Protection Assessment under reg if an HSR requests a review at least every five years. The purpose is to ensure that the emergency plan is updated if there is any reason to believe that it is no longer fully appropriate to the facility, or no longer fully effective. There is no explicit requirement in the MHF regulations to update the emergency plan when there are changes external to the facility, such as at adjacent hazardous facilities or within the emergency services. However, there is an obligation to review control measures to ensure that the adopted measures continue to comply with reg Hence the emergency plan would need to be updated in such circumstances, if the changes impact on the effectiveness of emergency planning control measures. Further, any agreements with third parties concerning mutual aid arrangements, such as provision of additional foam stocks and associated deployment procedures, should be periodically verified. A person should be nominated to have responsibility for maintenance of the plan. 14

15 4. Compliance checklist The following checklist highlights the regulatory requirements relating to emergency planning. Table 4.1 MHF regulations relating to emergency planning Section Reg 5.2.9, and Schedule 11 Schedule 12 Reg Reg 5.2.9(2) Reg Requirement The operator must prepare an emergency plan addressing both on-site and off-site consequences of major incidents, and including all matters specified in Schedule 11. It must be prepared in conjunction with the emergency services having responsibility in the area of the facility, and (in relation to off-site consequences) in conjunction with the council/s. Copies of the plan must be kept at the facility and forwarded to the emergency services. The plan must be put into effect without delay if there is a major incident, or an uncontrolled event that could be expected to lead to a major incident. In this event, the operator must immediately notify the emergency services. The operator must test the plan at suitable intervals, not exceeding three years, taking necessary steps to ensure participation of the emergency services. The operator must notify the emergency services immediately of the occurrence of a major incident. Matters to be included in the emergency plan include details of the facility and its hazards, the command structure and site personnel, notifications required, resources available, and procedures for safe evacuation, containment and decontamination. The Safety Case must include a description of the emergency plan. A draft of the emergency plan must be submitted to WorkSafe in the Safety Case outline (see the guidance note Safety Case outline for a major hazard facility). The emergency plan must be included among the control measures adopted under reg Risk control measures adopted, hence the emergency plan must comply with all provisions relating to control measures (see guidance note Control measures). This includes obligations to consult HSR and workers, and to develop worker roles to assist the operator. The operator must ensure that the local community is provided with information about the safety of the MHF, including the means by which the local community will be notified of a major incident, and the action that members of the local community should take. 5. Further reading Standards Australia/New Zealand Standards HB76, DG Initial Emergency Response Guide. NSW Department of Urban Affairs and Planning (1993), Hazardous Industries Planning Advisory Paper (HIPAP) #1, Industry Emergency Planning Guidelines. Queensland Chemical Hazards and Emergency Management (CHEM) Unit and Queensland Fire Service (1996), Emergency Plans: Guidelines for Major Hazard Facilities. UK HSE (1999). Emergency Planning for Major Accidents, Control of Major Accident Hazards Regulations (HSG 191). UK HSE Buncefield Reports Recommendations on the emergency preparedness for response to and recovery from major incidents. 15

16 Further Information Contact the WorkSafe Victoria Advisory Service on or go to worksafe.vic.gov.au Related WorkSafe publications Guidance note Revision of a Safety Case for a major hazard facility Guidance note Hazard identification Guidance note Consultation and the role of HSR Guidance note Control measures Guidance note Safety Case outline for a major hazard facility Note: The information presented in this Guidance Note is intended for general use only. It should not be viewed as a definitive guide to the law, and should be read in conjunction with the Occupational Health and Safety Regulations Whilst every effort has been made to ensure the accuracy and completeness of the Guidance Note, the advice contained herein may not apply in every circumstance. Accordingly, the Victorian WorkCover Authority cannot be held responsible, and extends no warranties as to the suitability of the information for any particular purpose or actions taken by third parties as a result of information contained in the Guidance Note. 16