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Emergency Preparedness and Response a Management System and Legal Requirement

Emergency Preparedness and Response a Management System and Legal Requirement

Introduction
 
Everyday we read in the newspapers about tragedies having occurred because there was not enough equipment, materials or people to do something which would reduce the losses/prevent the injuries.
 
Everyday we go about our daily routines expecting all will be normal.  Yet, we do not go out into the world unprepared.  We take our raincoats if a storm is threatening.  We take sunscreen when we go to the beach.  We take along an extra person when we have heavy work to do.  In other words, we anticipate and prepare for the demands of daily living.  We look at the probable occurrences that could take place during the day as indicated by our sources of information, newspapers, radio and television, and then make informed decisions on the materials, equipment, personnel needed to reduce our chances of loss.
 
Industries and countries does likewise.  However, their preparations take on a grander scale as the magnitude of their losses far exceeds any we might experience.  With this greater loss potential, it behooves industry to be better informed and better prepared.  Indeed, regulators are now demanding those industries meet minimum, specific, emergency preparedness requirements.

 
Latest world’s serious and worst incidents 
  1. Fukushima- Nuclear Reactor Japan 11 March 2011.
  2. The Deepwater Horizon oil spill BP Gulf of Mexico April 20, 2010
  3. Pike River Mine disaster New Zealand November 2010
 
 
Recently:  The Pike River Mine disaster was a coal mining accident that began on 19 November 2010 in the Pike River Mine, 46 kilometres northeast of Greymouth, in the West Coast Region of New Zealand's South Island. A first explosion occurred in the mine at approximately 3:44 pm (NZDT, UTC+13). At the time of the explosion 31 miners and contractors were present in the mine. Two miners managed to walk from the mine; they were treated for moderate injuries and released from hospital the next day. The remaining 16 miners and 13 contractors were believed to be at least 1,500 metres (4,900 ft) from the mine's entrance. 
 
Following a second explosion on 24 November at 2:37 pm, the 29 remaining men were believed by police to be dead. Police Superintendent Gary Knowles, officer in command of the rescue operation (Operation Pike) said he believed that "based on that explosion, no one survived". A third explosion occurred at 3:39 pm on 26 November 2010, and a fourth explosion occurred just before 2 pm on 28 November 2010. 
 
The Pike River Mine incident ranks as New Zealand's worst mining disaster since 43 men died at Ralph's Mine in Huntly in 1914.
 
Industrial accidents have cost billions of dollars and left many workers dead or seriously injured.  Petroleum plant explosions and fires are the most spectacular when viewed on the evening news and also result in the highest damage losses.  Losses of containment incidents, such as the Bhopal India incident, kill and debilitate thousands.  
 

Recently:  Japan The Fukushima I nuclear accidents are a series of ongoing equipment failures and releases of radioactive materials at the Fukushima I Nuclear Power Plant, following the 9.0 magnitude Tohoku earthquake and tsunami on 11 March 2011. The plant comprises six separate boiling water reactors maintained by the Tokyo Electric Power Company (TEPCO). Experts consider it to be the second largest nuclear accident after the Chernobyl disaster, but more complex as all reactors are involved. last week elevated the crisis at the Fukushima Nuclear Reactor site from a Level 5 to Level 7, the highest level incident. This establishes Fukushima as the most serious nuclear event since Chernobyl. The ongoing release of radioactivity rather than the amount of radiation released necessitated the elevation. Officials announced that 10,000 Terabequerels per hour of radiation were emitting from the plant for a period of hours. 
 
Other environmental incidents such as the escape of hazardous chemicals from a Swiss industry into the Rhine River threatened millions of people, killed the flora and fauna in that river in two European countries and resulted in some of the most stringent anti-pollution legislation the world has seen.
 

Recently: The Deepwater Horizon oil spill (also referred to as the BP oil spill, the Gulf of Mexico oil spill, the BP oil disaster, or the Macondo blowout) is an oil spill in the Gulf of Mexico which flowed for three months in 2010. The impact of the spill continues even after the well has been capped. It is the largest accidental marine oil spill in the history of the petroleum industry The spill stemmed from a sea-floor oil gusher that resulted from the April 20, 2010 explosion of Deepwater Horizon, which drilled on the BP-operated Macondo Prospect. The explosion killed 11 men working on the platform and injured 17 others.
 
 
Industry is now on the verge of even stricter, more demanding regulatory requirements.  Standards , such as OHSAS 18001, BCM 25559, and ISO 14001 try to encourage industry to have a management system in place to minimize the potential for failures resulting in losses.  Regulators are demanding proper preparedness to minimize the outcome of emergency incidents impacting their constituents. 
 

System Requirement Element 4.4.7 - Emergency Preparedness and Response    ( BS- OHSAS 18001: 2007 and ISO 14001
 
The company shall establish, implement and maintain a procedure(s):
  • To identify the potential for emergency situations;
  • To respond to such emergency situations.
The company shall respond to actual emergency situations and prevent or mitigate associated adverse SHE consequences.
 
In planning its emergency response the company shall take account of the needs of relevant interested parties, e.g. emergency services and neighbors.
 
The company shall also periodically test its procedure(s) to respond to emergency situations, where practicable, involving relevant interested parties as appropriate. The company shall periodically review and, where necessary, revise its emergency preparedness and response procedure(s), in particular, after periodical testing and after the occurrence of emergency situations.
 
 
How Can You Plan?
 
What must industry do to properly meet the threats presented by unplanned, emergency incidents?  What processes, equipment, emergency teams and materials must be available?  We need to focus on practical preparation methods, and some common codes and regulatory requirements.  We will refer to codes and requirements that will apply to most of our readers, realising those jurisdictional requirements are so varied.  There are a few basic requirements of an emergency plan that apply to virtually all types of emergencies.  These requirements are shown in Figure A
 
Emergency planning requirements fall into three distinct categories; Pre-Incident Planning, Incident Response and Post-Incident Action.
 
 
Pre-Incident Planning
 
Identify Emergency Scenarios – This activity requires a group effort to ensure all possible emergencies are considered.  Engineers, environmentalists, operators, maintenance, office staff, managers and janitors, all have a role to play in this process.  Each member of the group brings a unique perspective to bear on the potential emergencies that occur at the plant.  Using a questionnaire that stimulates consideration of what might happen, can make identifying these scenarios easier.  
 
 
Basic Requirements Of Emergency Planning
  • Communicate the plan to all employees
  • Review company operations and identify probable emergency scenarios.
  • Assign a probability of occurrence and a potential severity to the outcome.
  • Assess the risk, (the product of the probability and severity mentioned above).
  • Determine the regulations regarding planning for these incidents.
  • Determine the regulations regarding response capabilities.
  • Determine the local response time.
  • Prepare for response by dealing with the highest risks.
  • Develop your plan.
  • Select and train your response team(s).
  • Conduct drills and exercise your plan and your team(s).
  • Implement recovery and re-start operations
  • Evaluate your effectiveness and improve your plan.

Your incident history can provide insight into the frequency and severity of the type of emergencies likely to occur at your site.  Industry experience, if available, can also provide valuable information. 
 
 
General requirement 
 
The company should assess the potential for emergency situations that impact on Safety Health and the Environment (SHE) and develop a procedure(s) for an effective response(s). This may be a stand-alone procedure(s) or be combined with other emergency response procedure(s). The company should periodically test its emergency preparedness and seek to improve the effectiveness of its response activities and procedure(s).
 
NOTE Where the procedure is combined with other emergency response procedure(s), the company needs to ensure that it addresses all potential SHE impacts and should not presume that the procedures relating to fire safety, or environmental emergencies, etc., will be sufficient.
 
 
Identification of potential emergency situations
 
Procedures to identify potential emergency situations that could impact on SHE should consider emergencies that can be associated with specific activities, equipment or workplaces.
 
Examples of possible emergencies, which vary in scale, can include:
  • Incidents leading to serious injuries or ill health,
  • fires and explosions,
  • fall of ground
  • release of hazardous materials/gases,
  • explosives and explosions
  • natural disasters, bad weather,
  • loss of utility supply (e.g. loss of electric power),
  • pandemics/epidemics/outbreaks of communicable disease,
  • civil disturbance, terrorism, sabotage, workplace violence,
  • failure of critical equipment,
  • theft critical equipment
  • criminal activity
  • traffic interaction and accidents.
 
When identifying potential emergency situations, consideration should be given to emergencies that can occur during both normal operations and abnormal conditions (e.g. operation start-up or shutdown, construction or demolition activities).
 
Emergency planning should also be reviewed as a part of the ongoing management of change. Changes in operations can introduce new potential emergencies or necessitate that changes be made to emergency response procedures. For example, changes in facility layout can impact emergency evacuation routes.
 
The company should determine and assess how emergency situations will impact all persons within and/or in the immediate vicinity of workplaces controlled by the company. Consideration should be given to those with special needs, e.g. people with limited mobility, vision and hearing. This could include employees, temporary workers, contract employees, visitors, neighbours or other members of the public.
 
The company should also consider potential impacts on emergency services personnel while at the workplace (e.g. fire-fighters). Information that should be considered in identifying potential emergency situations includes the following:
  • the results of hazard identification and risk assessment
  • activities performed during the SHE planning process
  • legal requirements, the company’s previous incident (including accident) and emergency experience,
  • emergency situations that have occurred in similar companies,
  • information related to accident and/or incident investigations
  • posted on the websites of regulators or emergency response agencies.
 
Establishing and implementing emergency response procedures
 
Emergency response should focus on the prevention of ill health and injury, and on the minimization of the adverse Health and Safety consequences to a person(s) exposed to an emergency situation.
 
A procedure(s) for responding to emergency situations should be developed and should also take into account applicable legal and other requirements.
 
The emergency procedure(s) should be clear and concise to facilitate their use in emergency situations. They should also be readily available for use by emergency services. Emergency procedure(s) that are stored on a computer or by other electronic means might not be readily available in the event of a power failure, so paper copies of emergencies procedure(s) ought to be maintained in readily accessible locations.
 
Consideration should be given to the existence and/or capability of the following, in developing emergency response procedure(s):
  • inventory and location of hazardous materials storage, numbers and locations of people,
  • critical systems that can impact on SHE, the provision of emergency training,
  • detection and emergency control measures, medical equipment, first aid kits, etc.,
  • control systems, and any supporting secondary or parallel/ multiple control systems,
  • monitoring systems for hazardous materials,
  • fire detection and suppression systems,
  • emergency power sources, e.g. Cable theft is a serious concern in South Africa
  • availability of local emergency services and details of any emergency response arrangements currently in place,
  • legal and other requirements,
  • previous emergency response experience.
 
When the company determines that external services are needed for emergency response (e.g. specialist experts in handling hazardous materials and external testing laboratories), pre-approved (contractual) arrangements should be put in place. Particular attention should be paid to staffing levels, response schedules and emergency service limitations.
 
Emergency response procedure(s) should define the roles, responsibilities and authorities of those with emergency response duties, especially those with an assigned duty to provide an immediate response. These personnel should be involved in the development of the emergency procedure(s) to ensure they are fully aware of the type and scope of emergencies that they can be expected to handle, as well as the arrangements needed for coordination. Emergency service personnel should be provided with the information required to facilitate their involvement in response activities.
 
Emergency response procedures should give consideration to the following:
  • identification of potential emergency situations and locations,
  • details of the actions to be taken by personnel during the emergency (including actions to be taken by staff working off-site, by contractors and visitors),
  • evacuation procedures, responsibilities, and authorities of personnel with specific response
  • duties and roles during the emergency (e.g. fire wardens, first-aid staff and spill clean-up specialists),
  • interface and communication with emergency services,
  • communication with employees (both on-site and off-site),
  • regulators and other interested parties (e.g. family, neighbours, local community, media),
  • information necessary for undertaking the emergency response
  • (plant and mine layout drawings, identification and location of emergency response equipment, identification and location of hazardous materials, utility shut-off locations, contact information for emergency response providers).
 
Emergency response equipment
 
The company should determine and review its emergency response equipment and material needs. Emergency response equipment and materials can be needed to perform a variety of functions during an emergency, such as evacuation, leak detection, fire suppression, chemical/biological/radiological monitoring, communication, isolation, containment, shelter, personal protection, decontamination, and medical evaluation and treatment. Emergency response equipment should be available in sufficient quantity and stored in locations where it is readily accessible; it should be stored securely and be protected from being damaged. This equipment should be inspected and/or tested at regular intervals to ensure that it will be operational in an emergency situation. Special attention should be paid to equipment and materials used to protect emergency response personnel. Individuals should be informed of the limitations of personal protective devices and trained in their proper use.
 
The type, quantity and storage location(s) for emergency equipment and supplies should be evaluated as a part of the review and testing of emergency procedures.
 
 
Emergency response training
 
Personnel should be trained in how to initiate the emergency response and evacuation procedures 
 
The company should determine the training needed for personnel who are assigned emergency response duties and ensure that this training is received. Emergency response personnel should remain competent and capable to carry out their assigned activities.
 
The need for retraining or other communications should be determined when modifications are made that impact on the emergency response.
 
Periodic testing of emergency procedures
 
Periodic testing of emergency procedures should be performed to ensure that the company and external emergency services can appropriately respond to emergency situations and prevent or mitigate associated SHE consequences.
 
Testing of emergency procedures should involve external emergency services providers, where appropriate, to develop an effective working relationship. This can improve communication and cooperation during an emergency.
 
Emergency drills can be used to evaluate the company’s emergency procedures, equipment and training, as well as increase overall awareness of emergency response protocols. Internal parties (e.g. workers) and external parties (e.g. fire department personnel) can be included in the drills to increase awareness and understanding of emergency response procedures.
 
The company should maintain records of emergency drills. The type of information that should be recorded includes a description of the situation and scope of the drill, a timeline of events and actions and observations of any significant achievements or problems. This information should be reviewed with the drill planners and participants to share feedback and recommendations for improvement.
 
NOTE Standards, specifies that emergency response procedures shall be periodically tested “where practicable”. This means that such testing has to be performed if it is capable of being done.
 
 
Reviewing and revising emergency procedures
 
Standards require the company to review its emergency preparedness and response procedure(s) periodically.
 
Examples of when this can be done are:
  • on a schedule defined by the company,
  • during management reviews,
  • following changes in the company,
  • as a result of management of change, corrective action, or preventive action ,
  • following an event that activated the emergency response procedures,
  • following drills or tests that identified deficiencies in the emergency response,
  • following changes to legal and other requirements,
  • following external changes impacting the emergency response.
 
When changes are made in emergency preparedness and response procedure(s), these changes should be communicated to the personnel and functions that are impacted by the change; their associated training needs should also be evaluated.
 
 
Summary
 
The aim of this process is to ensure that the Companies Business Continuity Program identifies and evaluates all risks to its assets and operations, maintains prevention procedures and protection and mitigates the effects of unforeseen losses by having in place processes of continuity and recovery which are regularly audited, tested and updated. The Emergency Plan caters for descriptions of Emergency Response, Crisis Management and Business Recovery Protocols, dealing with notification procedures and internal / external interfaces, training requirements and auditing of plans and procedures.
 
Emergency response planning is a risk control activity.  It is a contingency plan against the outcome of accidents.  Incidents may be caused by failures of the systems, equipment, materials or processes internal to the operation.  Or, they may be caused by, or result from, natural phenomena.
 
Emergency response plans only work when they are well known through the operation.  All employees should be trained in the plan and provided with an opportunity to provide input into improvements.  The personnel who participate as emergency responders require the full support of management if they are to perform their roles efficiently and effectively.
 
Prepared for Mining Safety by Johan Taljaard Founder Member Istec safety 
 

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