As we are experiencing the third Nor’easter in a short period of time, this should serve as a good reminder to keep emergency planning documents up to date. Various regulations stipulate requirements for emergency planning, including OSHA regulations, the Massachusetts Comprehensive Fire Safety Code, and hazardous waste regulations. More specific requirements are also stipulated in regulations such as 105 CMR 120, MA Department of Public Health Radiation Control Program’s regulation for the use of radioactive materials. The plans developed for your site need to be specific to the hazardous materials present, operations, and applicable regulations.
Emergency Action Plans and Contingency Plans should be reviewed anytime an incident requires the plan to be activated, as changes to your program occur, and at least annually. Rather than just developing these plans to check a box for regulatory compliance, be sure to customize your plans for your site specific hazards. The procedures established in the plans need to be implemented and reviewed with all employees so everyone is well versed in proper response procedures should an incident occur. Think about the last time you held a fire drill, mock spill response training, or training to remind all employees of the steps to take in an emergency situation, and ensure it was recent enough to prompt a smooth response.