26

HEALTH AND SAFETY

Keeping Everyone Healthy

Our health always seems much more valuable after we lose it.

—AUTHOR UNKNOWN

INTRODUCTION

A step-by-step approach to analyzing your business situation and developing written procedures for avoiding problems or reducing their damage should they occur includes consideration of environmental, health, and safety issues. Issues that affect the health and safety of your employees and the surrounding community are becoming much more high profile, as the investment community evaluates corporate sustainability reports with the same level of scrutiny as the financial reports. Environmental and safety disasters have the potential to cost much more than the immediate damages; these disasters can tarnish brand names, force closure of operations in a community because of distrust, or become the subject of every anti-industry blogger on the Internet. This chapter will help you identify the plans you may need to protect your employees and the public from hazards in the workplace.

PLANS ADDRESSING HEALTH, SAFETY, AND ENVIRONMENTAL ISSUES

The emergency action plan is the most basic plan that should be developed for any workplace. Health, safety, and environmental issues are the focus of many emergency plans. Multiple federal agencies require emergency plans. This plan should address fires, evacuations, and sheltering during natural disasters. It may also include plans for responding to workplace violence. The Occupational Safety and Health Administration (OSHA) has especially helpful eTools on its website to assist in the development of evacuation plans. Other OSHA emergency plans are needed when employees are exposed to certain chemical hazards or work in confined spaces or trenches. The Environmental Protection Agency (EPA) also requires the development of plans to prevent damage to the environment or harm to the public resulting from business activities. Its focus is primarily on the impact that chemicals will have once they escape the workplace and enter the environment. A nationwide response system is in place to respond to these disasters.

The plans required by these two agencies follow a common approach. The risk assessment phase focuses on identifying hazards that pose a risk. Some plans are required to have a formal evaluation of hazard rankings; in others, the ranking is implied by what you choose to include or exclude. Either way, a judgment is made regarding the potential of occurrence and the severity of the hazard. The severity of the hazard may be limited to estimations of physical damage or expanded to include public relations impacts. After risks are assessed, the plan will present measures taken to prevent or mitigate the hazard. A hierarchy of controls is employed: Eliminate the hazard, construct engineering controls to contain or reduce the hazard, implement administrative procedures to prevent or contain the hazard, and lastly, provide personnel protective equipment to protect individuals from the hazard. In addition, the plan may also include the recovery stages—how to get the business back to normal.

Since the attacks on 9/11, the Department of Homeland Security (DHS) was created and issued additional regulations that are designed to prevent chemical emergencies resulting from terrorist attacks. The rules require plans when companies store, use, or transport listed chemicals. Some chemicals on the list have no minimum threshold before a threat assessment report is required. After submitting a screen-level assessment, a full-blown security plan that details how you would prevent the intentional release or theft of your chemicals can be required by the DHS. While other plans may contain confidential business information, the DHS reports are developed with national security in mind. The contents, even the existence of the reports, is to be kept secret from anyone who has not received DHS and corporate approval.

Figure 26-1 lists some of the more common emergency plans required by OSHA and the EPA that apply to many companies. This list is not complete for all federal, state, and local requirements. Furthermore, if protecting the business from disasters is important, don’t wait for the government to require it.

A first step will be a review of the threshold requirements for each of these rules to see which ones are already required. Start with them. (OSHA rules are cited for general industry; comparable Department of Labor rules may exist for construction, longshoring, mining, etc.) To do this, you need to make an inventory of your chemicals, wastes, processes, and confined spaces.

FIGURE 26-1. Federal emergency planning regulations.

RISK ASSESSMENT

Risks that are assessed in various safety, health, and environmental plans include fire, natural disaster, workplace violence, and chemicals. The assessment must include a thorough examination of the business activities with respect to the specific plan. For example, a plan addressing chemical releases will inventory chemicals, quantities, containers, locations, and users. A natural disaster plan will identify structurally sound areas and areas to avoid. A workplace violence plan will describe potential means of entry by an assailant and probable target locations.

Some risk assessments may only include the identification of the risks without any formal evaluation or comparison of the probability or severity of the disaster. Simple emergency action plans may fall into this category; the responses are limited to evacuation or sheltering. However, many plans continue the assessment with a comparison of the potential results from the disaster. The probability of occurrence is one factor evaluated. The plan developer will consider the specific history of the site, the history of similar sites, and site-specific factors that are deemed important. The purpose is not to calculate a precise probability but rather to recognize the difference between almost certain events from occasional events to extremely rare events.

The inventory is followed by the evaluation of the resulting harm. Harm, like probability, should be categorized into relative categories from lethal or catastrophic loss of property to serious, moderate, and mild levels. Various approaches may also take into consideration the ability or speed of detecting the problem and the public relations impacts. Usually these are combined in some form of a mathematical equation to yield a score for comparing each of the cataloged items. You can use the risk assessment forms from Chapter 3 to help prioritize these risks.

Chemical Hazards

OSHA, EPA, DHS, and other agencies require emergency plans for various chemical activities. If you are already filing a Tier II report to the EPA, you may have most of the information at your fingertips. If not, use the Material Safety Data Sheets (MSDS) for each chemical to determine if the product contains any of the chemicals referenced in items 1 to 4 in Figure 26-1. You should develop a data table that includes the product name or part number, chemical ingredients of concern, quantity used annually, quantity stored at one time, and the locations stored. From this list you will be able to determine if certain prevention or response plans may need to be developed.

One of the most fundamental questions you need to ask yourself is, “Why do I have all these chemicals anyway?” The best control plan is to plan not to have the chemicals. If this isn’t feasible, then consider substituting a less dangerous chemical or reducing the quantities stored onsite. Property protection insurers look to the size of the container as a measure of risk. Bigger containers mean bigger risks even if the same quantity of chemical is stored.

As an example, a chemical inventory conducted at your facility shows that you have a 1,000-gallon gasoline tank and a 5,000-gallon diesel fuel tank for your fleet of vehicles, a paint booth that uses 3,800 gallons per month of paints containing no EPA-listed solvents, and seven drums per month of methyl ethyl ketone (MEK), which is used as a paint thinner and cleanup solvent. The cleanup solvent and scrap paint yield six drums per month (about 2,500 pounds) of liquid waste.

Based on this information, you determine that EPA requires a Spill Prevention Control and Countermeasures (SPCC) plan and a Hazardous Waste Contingency plan. In addition, you realize that an accidental release of 5,000 pounds of MEK would need reporting to various local, state, and federal agencies.

Another kind of chemical release is one that you have control over: operational releases. Say you have a catastrophic failure to an air pollution control device that is required by your operating permits. Due to a lightning strike or fire, the only damage at the facility is this piece of equipment. Your ability to operate the business is unhindered except that you would be out of compliance with your environmental permits. Is this a disaster? You bet! Many air pollution control devices are built to order. Lead times may be months. Many permits are federally enforceable so that even the state does not have the authority to grant waivers. Your only course of action may be to shut down the process for several weeks until you shift production elsewhere or to operate in violation of the law unless you have a plan. What’s worse is that activist environmental groups mine data at the EPA looking for facilities that have operated during malfunctions and bring citizens’ lawsuits against them. The laws do not preclude criminal prosecution of a plant manager for operating outside of permitted limits of an air pollution or wastewater discharge permit. It is critical to know the details of your permit; some things to think about when getting your permit include:

Try to get flexible terms.

Know the malfunction laws.

Know the political landscape.

Know to whom you need to talk if there’s a problem.

Know to whom you can switch production in an emergency, and have contracts ready.

Know what it takes to replace critical equipment.

Have business interruption insurance that specifically addresses the issue.

Employee Fatalities or Multiple Hospitalizations

In addition to the chemical plans, OSHA requires plans that protect people from hazards in the workplace. These include the response to fires, to chemical emergencies (Hazwopper), and to emergencies in confined spaces. All of these plans require the same basic elements of identifying the hazards and developing plans to prevent or to mitigate the unwanted outcomes.

Whether or not you identified regulatory requirements for emergency planning, you need to notify OSHA immediately when there has been an occupational or workplace violence fatality or multiple hospitalizations in the workplace (29 CFR 1910.39). An investigation may begin within a few hours and may continue for weeks. Some manufacturing operations or pieces of machinery may be shut down until the investigation is completed.

A plan to protect employees and the business starts with the identification of these hazards. This includes the labeling of all electrical disconnects, storage tanks, and pipes and making sure that documentation of processes is available in an emergency. Next is the development of engineering controls, administrative procedures, and employee/contractor training. Numerous occupational hazards can result from confined spaces; sources of energy that require energy control, protection, and lockout; fall hazards; machine guarding around presses; robots, shears, and gears. Several of these hazard categories are required to have specific written control plans. A carefully developed plan may be just the tool to identify a hazard that must be abated; otherwise, the hazard may kill a valued employee and shut down your business.

For example, you begin the development of a confined spaces entry plan. You inventory spaces that meet the OSHA definition for confined spaces and realize that pits under your presses, chemical storage tanks, a boiler, and the wastewater sewer line all meet the definition of a hazard. The most likely entry scenarios are identified as well as any unusual ones. Perhaps the normal entry in the chemical storage tank is cleaned with water, during which no hazardous vapors are generated. However, once every 10 years the tanks are lined with an epoxy coating that is applied by hand spraying. This liberates large quantities of potentially dangerous vapors. An employee is overcome. The attendant outside the tank rushes in to help and immediately succumbs to the same vapors. Two are now dead.

Many rescuers have died in confined spaces because they did not have a plan or failed to follow it. The unidentified, invisible, or odorless hazards that placed the first entrant in danger will do the same to the rescue team that is unprepared. For this reason, OSHA requires a written plan and training to the plan. OSHA prefers rescue from outside the space via a retractable lifeline. Whenever this option is feasible, it should be used. It requires identifying the spaces where it can be used, making equipment available, and training employees on how to use the equipment.

Workplace violence and acts of terrorism are an increasingly common form of disaster. Multiple shootings, letters containing anthrax, bomb threats, and other incidents are occurring with greater frequency. The two most important elements of a security program are the creation of a physical barrier to unauthorized entry and a procedure to identify people as they enter the premises. After these two steps are achieved, then higher levels of security can be developed as specific risks are identified.

Off-Site Hazards

One result of the Risk Management Plan (RMP) regulation mentioned in item 4 of Figure 26-1 is that off-site consequences must be considered and some of this information is publicly available. As a result, you can assess some chemical hazards that could occur off your property that may have disastrous effects on your business. Although the federal government elected not to put detailed information on the Internet, you can quickly find out if an address of interest to you could be affected by a chemical accident at another facility. The most common scenarios are clouds of toxic chemicals or explosions with the ability to cause damage over a great distance. The EPA website has a Vulnerable Zone Indicator System (VZIS) that can be used to determine whether your address may be in the vulnerable zone of a facility that submitted a Risk Management Plan (www.epa.gov/rmp/forms/vulnerable-zone-indicator-system). Major transportation arteries should be considered a risk for hazardous material incidents with the potential of large-scale evacuations. Whether it is a tanker overturned on an icy interstate or a train derailment, when large quantities of chemicals are involved the emergency management authorities will not hesitate to order an evacuation of all downwind and at-risk areas. Other off-site hazards that can invade your property include floodwaters (which can easily bring in contamination from outside sources), wildfires, and various chemical releases by air, surface or subsurface.

For these off-site-initiated incidents, you need to develop plans for a safe and orderly shutdown of the business in the event an evacuation is ordered. This plan may be the same one you would use for a hurricane or any other incident requiring evacuation. The primary considerations during an evacuation are to protect the people evacuating, to protect anyone reentering the building by shutting down potentially dangerous equipment, and to protect your investments as time permits.

Another off-site incident can be the loss of potable water due to accidental or deliberate contamination of public water supplies or other problems that shut down a municipal water treatment works. How is water used in your facility? How much is used? What quality is required? The answers to these questions may cause you to consider placing contracts for water to be trucked in from another municipality in the event of an emergency. If the neighboring communities all receive water from the same body of water, you may consider having a contract with a company that can get its water from another source, such as a private well or a different lake or river.

Indoor Air Quality Problems

Because indoor air quality problems have become more prevalent in recent years, a programmed response to these complaints may contain many of the same elements of your emergency plans. The scenarios are different but the results are similar. Something has invaded the building that makes it uninhabitable for people. People begin to complain of respiratory illnesses. They compare notes on everyone they know who has worked here and has cancer or emphysema or asthma. Pretty soon an attorney is involved. Sometimes the sources can be found and controls installed in the heating and ventilation system to eliminate the problem—radon gas, formaldehyde from carpets and pressed wood, volatile chemicals from copier machines, office chemicals, industrial chemicals, and vehicle exhausts.

The newest problems are biological in nature and therefore are more difficult to control because these tiny organisms may remain hidden and reproduce only to strike again. “Toxic mold” is the name given to many assorted molds and mildews and bacteria that grow on or in building structures. Biological attacks such as the anthrax spores in the Capitol offices are another example. Both can require extensive decontamination and may result in the abandonment of a building.

Indoor air quality concerns may be the result of outside factors, such as the anthrax letters, pollution from a neighboring business, or the contractor who is patching the asphalt roof of your building where you didn’t turn off the fresh air intake. Or, indoor air quality concerns may be the result of your building design, housekeeping, or processes. Although the causes are many, the symptoms and therefore the plans share many similarities. Generally people are worried about being exposed to something in the air they breathe. Address these issues as they occur quickly and with concern. Prevent. Investigate. Mitigate. Control it before it controls you.

EVACUATION

According to OSHA, people should be evacuated to a safe area of public access. Local fire codes will dictate how many exits are required from rooms and buildings based on the occupancy, construction, and other hazards present. Exit routes need to be well marked, even in the event of a power outage. This can be accomplished with battery-powered backups on exit lighting, emergency standby generators, or glow-in-the-dark signage. Some of the problems encountered by OSHA or fire code inspectors are unmarked exits, exits blocked inside or outside, aisles blocked, and evacuation routes not up to date with changes to building layouts. Equipment is only usable if it is maintained. Alarms, emergency lights, battery backups, smoke detectors, and exit lights all need to be tested regularly and verified that they still perform. Failure to maintain emergency equipment places lives at risk.

A roll call to account for people may be one of the more difficult tasks, especially for large facilities or those where people frequently come and go. However, as soon as possible after disasters that may have the potential for loss of human life (e.g., fire, tornado, and explosion), you need to get a headcount. If Joe isn’t there, is it because he wasn’t at work, he left for a doctor’s appointment before the explosion, he is on the rescue team and stayed behind as directed, or he is among the casualties? The quicker this can be determined, the quicker the emergency scene will be brought under control and potential danger to other rescuers reduced. Employees need to know they should not leave the property after a disaster until they have been accounted for and dismissed. Employees who left or called in sick might be asked to call in to an emergency number. There have been cases where the missing were presumed casualties and rescue workers continued to search for them, only to find out the person was safe at home. Other less obvious disasters that require employees to check in include company travelers after a disaster, man-made or natural.

There are many ways to conduct a headcount. The most basic requires all people to go to a standard location or muster area, much like schoolchildren practice. At this location someone takes a roll and compares it to a list of those known to be present at that time. Communication between muster areas is needed at larger locations. At least two means of communication should be identified because the emergency may render one of the systems unusable. For example, following large-scale disasters like 9/11, cell phone systems were overloaded. A key element of the accountability procedures is that every employee knows they need to keep trying until contact has been made, even if it takes hours or days.

MITIGATION

Dealing with environmental emergencies often means that some chemical has escaped its desired container or location. You must quickly determine how to stop the ongoing release, assuming some remains, and how to prevent the release from spreading and causing harm. If you have developed a good working relationship with local police, fire and emergency response agencies, they will be better prepared to respond to emergencies at your location and limit the final impact. One best practice is to invite them in once a year for a tour or luncheon.

The health and safety of the people responding is always the greatest concern of professional emergency responders. You should consider the health and safety of your response team in the development of your plans. Proper qualifications, initial and refresher training, development of procedures, and identification of tools and personal protective equipment need to be addressed. Ancillary hazards such as electrocution when the floor is wet, inhalation of smoldering smoke, or contact with toxic chemical residues such as asbestos or mold may also need to be considered.

The EPA may require engineering controls for certain situations; for example, containment dikes that hold 110 percent of the capacity of the largest tank. However, many chemicals are legally stored outside of containment dikes. Other engineering controls include designating storage locations that are not susceptible to damage by forklifts and are placed away from floor drains.

Spill response equipment must be purchased and placed in strategic locations to effectively contain a chemical spill. Determine the types of response equipment required and whether you need to stop leaks in drums or tanks and slow the flow of chemicals across the floor, in a sewer, or down a creek. Ensure that the spill control materials you select are appropriate for the chemicals you need to control. Some supplies are selective to petroleum products, others to aqueous products. Non-sparking brass tools are needed when responding to spills of materials that may ignite or explode. Acids or bases may react adversely with some metals or rubber.

Contracts should be in place or a ready list of contractors available for services ranging from removing water from carpets, to patching a hole in the roof, to moving your critical equipment. Remember that in a large natural or man-made disaster, the demand for local services will exceed the supply of contractors available. Have contracts in place with local companies and national companies that can bring in the help you need.

Notifications to government agencies are required by various rules. Determine which rules require you to notify whom. Notification should be done as soon as it is practical. Notifications definitely should be within minutes if a spill is reaching a public waterway or is off the property or has the potential to harm the environment or people. In all cases, notifications should be made within the work shift when it occurred. The order of notification should be local, then state, then federal. This corresponds with their ability to mobilize in response to the incident.

Not all personal protective equipment (PPE) is created equal. Some may be effective in responding to one chemical or hazard and totally ineffective for another. Check the manufacturers’ data for respirators, gloves, and chemical-resistant clothing to determine the exact requirements for the potential hazards you might encounter.

DEVELOPING A PLAN

As you review those categories required by the EPA and OSHA, you may discover the focus of the EPA is off-site environmental impacts and the focus of OSHA is employee impacts. You must decide for your operation where the business impacts intersect with these regulatory categories. In some cases, the regulatory threshold will be sufficiently protective; if you do what is required by the rules, you may deem nothing else is required. Other times, you realize that the regulatory minimum is not enough and that the plan should include more than the EPA or OSHA would require.

What can happen here? Tanks leak, containers rupture, incompatible chemicals are mixed, valves are left open, alarms fail, and containment systems leak. Or is the problem people-related? There’s a new worker, a new procedure, or something changed and somebody was not informed. The contractor’s employees couldn’t read the warning signs or instructions, either because they could not read or were not fluent in English. These are some of the common scenarios you must consider when developing your plans. What happens once a chemical release begins? Which way will it go? Will it cause an explosion, kill the fish in the creek, or upset the city wastewater treatment plant? Do the neighbors need to be evacuated? Who needs to be evacuated? Let’s take a few of these in more detail.

Planning for Chemical Hazards

GASES: Releases of chemicals can be in the form of solids, liquids, or gases. Gases will disperse the fastest, so plans must take this into account. There will be no time to make decisions on the spot if the potential releases could cause explosions or if they are toxic. Evaluate the most likely fault scenarios and make the changes now that will reduce their likelihood. Develop engineering controls such as protective barriers. Create administrative procedures such as using only trained employees and sign-offs. Provide readily available leak detection equipment. Prominently display on the cover of the plan whom to call immediately. Two special notes for gases: Some gases are heavier than air and seek the lowest levels and may travel long distances at floor level unnoticed until finding a pit, basement, or other lower space. Those gases that are lighter than air rise and disperse. These require different placement for leak detection.

LIQUIDS: Releases of liquids are the next priority. Again, the characteristics of the specific materials will dictate the response actions. Liquids flow downhill, which means sumps and dikes can be effective means to prevent the spread of a release so that leak detection equipment can be placed in fewer places. Depending on the liquid, it may or may not evaporate quickly and result in both a gaseous and a liquid release.

SOLIDS may not be thought of as a particularly hazardous physical state. Consider, however, that fine dusts created from grain and grinding operations can create explosive atmospheres. In addition, spills of solid materials may wash into a drain during a rain event and be quickly transported off the property.

ACTION STEPS FOR YOUR PLAN

Here are things you will need to write your plan. They are in no special order and, of course, you can tailor these items to meet the needs of your site.

Begin with your standard plan format. Keep in mind that regulatory requirements may drive the development of your plan to include many things beyond your standard format. Your audience includes the late-shift security staff, but you may also designate specific persons under the law who act as emergency coordinators or incident commanders and who have the full support of management to do whatever it takes to bring the emergency under control. This person may be onsite or on-call, depending on the specific regulatory requirements and your individual circumstances.

You need the names of your primary and secondary support people who work at this site, plus the primary and secondary support people you can call on from another company site. You may make an arrangement with a professional emergency response team to send people during a disaster. In many cases, their arrival will be hours away, so you may need some onsite ability to keep the problem from getting worse before they arrive.

Your plan should include chemical maps. Use a floor plan generated using computer-assisted design (CAD) software to indicate all the main chemical storage, use, and waste locations on the property and the storm and floor drains. Indicate the direction of flow in drains and for the surface around major chemical storage locations. Note the presence of lower levels where liquids or vapors could migrate.

Add in the emergency response equipment inventory list with the description for each item. Prepare a checklist of your monitoring, testing, and alarm equipment that includes their location and how to test them. You may need to preplace some supplies and equipment for use on short notice. Also, in your checklist, include detailed instructions on how to check the devices for use on the spot. Validate the checklist by using someone unfamiliar with it.

Identify the personal protective equipment (PPE) required to respond to emergencies. Determine the sizes required for your response team, the quantities required, and the location(s) where they will be stored. Include PPE inventory status on a scheduled inspection. Some equipment may have a limited shelf life. Make sure to rotate supplies so that they are effective when needed most.

Communication with media, employees, and especially government contacts is critical. If the emergency generated activity on police and fire scanners, then the local news crews can be expected to know of the situation and a phone call or visit onsite will likely come soon. Establish who will be the primary and secondary media contact. This should NOT be your emergency coordinator. You do not want your coordinator pulled away from other duties to answer questions from the media. It is best to have someone who is not a technical expert but rather someone who can handle themselves well in front of a camera or with a reporter. To that end, a response of “I don’t know but I can find out” is better than your technical personnel speaking off the top of their head without preparation and providing information that is played up negatively by the media.

After a Disaster

There are several things you should do after the disaster to make sure you have covered all the bases and are better prepared for the next disaster.

Follow up with an incident debriefing. Ask yourself many questions. What were the lessons learned? Could the incident have been prevented? Did the emergency detection and notification systems work? Did the company follow the plan? Were the supplies available? Was anyone hurt? Did the company have trouble finding out the properties of the chemicals involved? Ask the local emergency responders who were involved for their input as well. Maintain a copy of this report with the incident report. Regulatory agencies want to see that you have learned from the past and are taking precautions to make sure it doesn’t happen again. If you fail to learn, history may repeat itself—and it may even be worse the next time.

Follow up the reports to the regulatory agencies as required. Some of the federal and state laws require a written follow-up once a release has been reported.

Update the written emergency plans. Again, some of the federal regulations require plans to be updated following an event where the plan was determined to be inadequate. Usually the updates are expected within six months. Even if nobody requires an update of the plan, the value gained is being better prepared for the next time. It is hard to imagine any plan that was perfect or perfectly executed.

Testing

Will the plan be executed in the manner you wrote it? Will people remember what is in the plan or even remember there is a plan? These are some of the reasons plans need to be tested. Testing a plan provides the opportunity to learn what might go wrong or what might be done more efficiently. Many professionals who have worked hard to develop the plan are often disheartened to find out how many people never open the plan in a drill; they attempt to do everything by memory and experience. A good plan will be an indispensable reference during an emergency, not just a training guide before the emergency. Drills are also useful in identifying changes that have not been documented since the last plan update.

Drills can take several different forms. All tests don’t have to be live; they can also be simulated. A Table-Top drill can be developed with “what if” scenarios that are scripted but require those responding to make decisions and consider their consequences. These drills compress time so that an eight-hour exercise may be reduced to just two or three hours and do not require mobilization of people or equipment. Table-Top drills are often used as a first-time drill to familiarize key leaders with a plan or with seasoned professionals who have experienced many live action emergencies, just to keep them fresh. Live drills can be as simple as a fire or tornado drill or may include a multiagency drill with lots of equipment and manpower. The key to a successful drill is determining what learning outcomes are desired and planning the exercise to meet those outcomes. Surprise drills are like the real thing except that they are scripted but do include physically going through the motions required in the plan.

Where possible, include your emergency service providers—the local HazMat response team, fire department, or contract service providers. Having someone play the role of the “Live at 6:00” TV news reporter is also valuable since the greatest damage may be to the corporate image. What is said, how it is said, and whom it is said by during the first interviews after an emergency begins will create a public opinion for the good or the bad of your organization.

Debrief and incorporate the suggestions into the plan where appropriate. If the drill ends with the drill, then the most important opportunity to improve has been lost. A debriefing after the drill will identify what was done well and what could be improved. Some of the opportunities will require portions of the plan to be changed; others will require more education or just more practice.

Conclusion

As safety and environmental issues become a greater part of the public conscience, protecting the health and safety of your employees and the surrounding community has become mainstream in many organizations. It is more than just “the right thing to do.” Preparing your organization for disasters in safety and environmental issues will be a competitive advantage when disaster strikes. Failure to plan may lead to bankruptcy, or worse.