BY ERIC G. BACHMAN
Many unknown circumstances will influence fire department operations and incident outcomes. Before taking the defensive, however, fire departments can take offensive measures that include gathering target hazard preincident information to reduce some of the unknowns. Do not be misled into believing that preplanning will reveal all incident unknowns. That is impossible. However, there are some factors that can be realized before an emergency occurs. Construction type, utility types and shutoff locations, water source disposition, and fire detection and suppression systems are a few common factors that can be identified before an emergency. Other site-specific aspects that may influence incident parameters and outcomes not mentioned above must also be ascertained.
The information-gathering phase of preplanning may yield a plethora of information. It can be overwhelming, but the information must be reviewed. Each aspect must be analyzed to determine how it may affect your operations. Other facets inherent to preplanning include facility tours and exercises. Each contributes to improving preincident preparedness and intelligence. Some facilities are complex and need comprehensive analysis to understand factors that will affect fire department operations. Other facilities may seem basic but nonetheless require thorough review. How well we prepare ourselves will greatly influence the outcome of an incident.
FACILITY PLANS
An aspect often overlooked during preincident information gathering is the review of facility emergency plans. This is a broad aspect because there are many types of emergency, preparedness, and contingency plans. Some plans are required by a legal authority. Others are discipline specific or independently compiled. Some may be comprehensive documents; others may be very basic. Reviewing these plans should be a part of preplanning, as they may reveal situations and circumstances that could hamper fire department efforts. From protecting facility occupants to incident action procedures, these items need to be reviewed and understood. Fire officials must analyze internal facility plans and determine how they may affect incident operations.
 (1) This comprehensive facility emergency response plan shows some of the sections and subjects covered. (Photos by author.) |
Plan titles are not consistent and will vary. Most internal facility plans are titled by the facility with no standard label. Common titles you may encounter include “Emergency Response Plan,” “Fire Action Plan,” “Emergency & Crisis Management Plan,” “Emergency Management Plan,” and “Disaster Plan.”
 (2) A laminated one-sheet spill procedures “plan” for a gas transmission station. |
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GENERAL ISSUES
Regardless of the plan’s name, certain information contained within the plans will influence fire department operations. Fire officials must review and study these aspects to determine how they may affect incident operations. When preplanning, ask to review internal emergency and preparedness plans. When reviewing plans, you may be surprised at what you find.
Following are common facility plan elements that should be reviewed before an incident to determine operational effects and other conditions that might impact incident circumstances.
Maintenance
When reviewing a facility emergency plan, be sure to look at the date it was developed or adopted and when it was last reviewed and updated. The last recorded date of review may be indicative of how current and reliable the information is. Questionable information, such as currency, should be addressed with the facility for clarification.
Emergency Contacts
Facility emergency plans often include a call-down list for after-hour emergencies. Some might provide an in-depth listing of contacts; others might list only one or two. Regardless, this list must be accurate. How many times have you gone to a facility, especially after operating hours, and attempted to contact a facility representative only to find that the list was drastically outdated? Contact information must be kept current.
Understanding the roles of the listed contact persons is also essential. A primary contact may be the president of the company, a corporate representative, or someone of high authority. Although they may be high on the corporate food chain, they may not be as intimately familiar with the facility or able to provide specific facility operational information as the head of maintenance or the operations manager.
Facilities that have multiple shifts may have varying time-specific emergency contacts. Large facilities may have emergency contacts for specific departments within the complex. Understanding this circumstance may reduce confusion over whom to call for assistance or guidance.
Chain of Command
The facility chain of command directs you to the individuals in the facility responsible for specific duties and responsibilities. (Current contact information so these individuals can be reached in an emergency must be available.) Most likely, the designation for the person in charge at the facility will not follow terminology outlined in the National Incident Management System (NIMS). Some references may include incident commander, emergency manager, coordinator, or chief. When the terminology is not consistent with the NIMS, facility management must be made aware of this, and you should ask that the plans be revised.
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It is also important to ensure that the facility appoint a liaison to assist the fire department. After a recent review of a facility emergency coordinator’s (EC) duties at a manufacturing facility, none provided for coordination with the fire department. The EC was responsible for many aspects including accountability and radio communication with department leaders. However, there was no defined function to meet with and coordinate actions with the fire department. This could cause confusion and result in the duplication of or opposing efforts with the fire department. When the question was posed to facility leaders, they realized they had not thought about it; they subsequently revised their plans for emergencies and joint exercises.
Discovery
Also outlined in emergency plans are the methods in place for discovering an emergency. This can be critical: A delay can cause the incident to quickly escalate or be well developed before the fire department is notified. It is necessary to determine the means of discovery. Mechanical or automated systems will signal an emergency in the early stages, but if the method relies on a person’s senses, there may be a delay in discovering an emergency. If the facility is not staffed 24 hours a day, the fire department should expect that it might find an advanced problem when it arrives.
Notification
Along with the discovery issue are the questions of how and when the fire department should be called to respond. There is a definitive line between when an emergency is discovered and when the fire department should be notified. Do not be unduly confident because an automated system is in place. Automatic systems may be monitored locally on-site and may not transmit a signal to a central monitoring station. The fire department may be notified only after the emergency has been verified. You must understand the procedure that exists between automated discovery and verification. In some facilities with detection systems in place, such as a water-treatment plant, the activation of the system is reported only to an on-call representative. That person then has to travel to the site and investigate the alarm. A request for off-site assistance is then made after an emergency situation has been verified. This results in a delayed notification.
 (4) A wastewater treatment plant that typically uses an on-call alarm activation dialer system. |
Similar procedures may be in place for large facilities as well. A signal may be transmitted locally to a site location such as a guard shack or control room. The alarm is then investigated. Depending on how large the facility is and the staffing levels, the situation must be verified before notification is made.
Another important notification aspect is reviewing the off-site emergency notification contact number list. It may have errors, including the incorrect fire department jurisdiction. I have reviewed plans that listed the wrong fire department; this could cause notification delays. Consider the following: What contact numbers are used to notify the fire department? Is there a 911 center to contact? Does the fire department have a staffed radio room for receiving calls? Is the fire department volunteer, and does the plan list the fire station’s business phone number as the emergency notification number? Most volunteer fire departments are not staffed; thus, the phone would go unanswered. These factors affect the receipt of notifications of emergencies.
Protective Action
Of great significance are the protective actions taken during emergency situations. In a commercial or an industrial setting, what are the procedures for employees? Do they evacuate immediately or only when instructed to do so? If they are to evacuate, where are they to report? In line with the chain of command element, what facility representative is responsible for employee/occupant accountability?
Where are the safe areas of refuge for occupants? In a plan I recently reviewed, the safe area was the main parking lot, right where the fire equipment would be placed and equipment deployed. The safe areas must take into account fire department access and operations to prevent additional risk to the employees/occupants.
Understanding employee actions in other occupancies, such as special care facilities including hospitals (photo 5), or special needs facilities, such as personal care homes (photo 6), is also necessary. What are they doing or expected to do in an emergency? What measures are they taking to protect occupants with little or no self-preservation abilities? Employees will be required to take certain measures. At one facility, the plan required the staff to first close all patient doors, evacuate residents close to the room of origin, and then call the fire department. Depending on the scenario, staffing, and the size of the facility, what can the fire department expect to find on arrival?
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When reviewing the staffing aspect of an emergency plan, real-time information must be taken into account. What are the realistic staffing levels of these facilities? What is the employee-to-resident ratio, especially during the late-night hours? And what can the fire department expect on arrival? Potentially, a well-developed fire and a compromised life hazard. The fire department’s initial assignment and staffing must be reviewed. A limited response coupled with limited facility staffing can lead to tragedy. How many people does it take to evacuate a person with special needs? Have you practiced evacuation in addition to other fireground tactics? The bottom line is determining how well you are prepared to deal with a timely large-scale evacuation before an emergency.
In January 2004, a fire occurred at a Tennessee nursing home. At the time of the late-night fire, only one staff member was on duty; that member was responsible for 15 residents. This contributed to the loss of three residents. Limited staffing plus limited fire resources compromise residents’ protection. No matter what the facility, understanding protective actions is important.
CONTRIBUTING FACTORS
The list of emergency plan items to consider or be wary of is endless. Every facility has its unique circumstances and factors to consider. The key is to analyze facility plans to determine the effects they may have on your operations. Some elements may be helpful; some may be harmful to fire department operations. You won’t know unless you include facility plan reviews in preplanning. Analyzing plans will help you to identify the capabilities and limitations of the facility and the fire department. You can plan for shortfalls and contingencies only when you know they exist. The best time to learn about contingencies that are needed is before an emergency.
RESOURCE IDENTIFICATION
A benefit to reviewing a facility’s emergency plans is that you will determine what resources exist or can be made available. A fire department can compare the facility’s resource needs with the emergency service resources available. In the case of an incident at a special-care facility, for example, if an evacuation were necessary, where would you place the residents? You cannot just put them outside. Extreme weather conditions should be considered. Where is there an alternate site to house them? How do you get them there? These are important issues that must be addressed and planned for in advance.
On the emergency service side, what are your resources? In a nursing home incident in Virginia in 1989, 34 ambulances were used to transport residents to area hospitals and other sites. Thirty-four ambulances are not readily available everywhere. From where would you have to pull resources? What is the depth of your resource list? How long would it take the resources to arrive?
OPERATIONAL ACTIONS
Some plans may prescribe fire department actions for certain circumstances. This could cause misunderstandings during an actual event. The facility may have certain expectations or assumptions of the fire department as a basis for the plan it developed (without fire department involvement).
Fire officials must actively be involved in the planning process. Business and industry do not know how a fire department works and vice versa. Cooperative preplanning is a learning experience on both sides. A facility needs to understand fire department concerns, and the fire department must understand facility concerns. A cooperative effort will promote a positive working relationship before, during, and after an incident.
Sometimes, however, we are our own worst enemy. A bulk storage facility was in the process of developing a Fire Action Plan (photo 7). The facility invited the local fire department to tour the facility. Only one member from the local volunteer fire department showed up. The facility requested assistance from the fire department to develop the plan. The fire department showed little interest and provided no input. The facility continued its work on a draft plan. The completed plan included a detailed site plan with tank specifications, topography considerations, water supply locations, and foam application calculations (photo 8). Within the plan, a fire involved each tank individually and identified the water source to be used as well as where the fire apparatus was to be positioned.
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On completion of the plan, the facility again invited the fire department to attend a meeting to review the plan and to address any unmet needs or other issues. Again, the fire department did not participate. This facility went to great lengths to assist the fire department in preparing for an emergency at this unique and challenging target hazard. Unfortunately, by not cooperating with the facility, the fire department will not be well-prepared and will not have a good rapport with the facility. Had the fire department worked with the facility, it might have identified and corrected some limitations that would have enhanced the effectiveness of the plan. The plan addressed only extinguishing a single tank and did not cover other issues such as multiple tank fires, exposure control, and environmental issues. So how do you think things will work at an actual emergency?
After reviewing already prepared plans, the fire department must go back to the facility, discuss concerns, and resolve issues. The benefits of preincident meetings will be realized during an actual incident.
PLAN TYPES
There are many varieties of facility emergency plans. Some are well-structured and detailed, addressing natural and man-made emergencies. Others, meanwhile, may be simple and vague. Regardless of their thoroughness, they need to be reviewed. Certain plans may be mandated by an authority and must include specific elements. It is important to remember, however, that plans have specific purposes and may address only certain situations. You must understand the purpose and limitations.
SOME PLAN TYPES
It would be impossible to review every plan type developed for every industry. Listed below are some sample plans you might encounter relative to facilities that use, store, or manufacture hazardous materials. Fire officials must survey their facilities and review the plans that are in place.
• A Spill Prevention Control and Countermeasure (SPCC) plan is a requirement of the Environmental Protection Agency Oil Pollution Prevention regulation 40CFR part 112. This plan identifies containment and countermeasures for preventing spills into navigable waterways for regulated facilities such as tank farms. Other contingency plans, such as a Preparedness, Prevention and Contingency (PPC) Plan, may be required for facilities that do not provide secondary containment for commodities on-site. The provisions in these plans are important to understanding how to avoid duplicating efforts and wasting resources. These plans, too, are limited in the nature of the emergencies they address.
Each plan provides essential information on facility resources and outline discovery and notification mediums. Understanding these elements is crucial for effective incident management.
• Title III of the Superfund Amendments Reauthorization Act (SARA) of 1986 established planning criteria for the planning of off-site releases of extremely hazardous substances including anhydrous ammonia, chlorine, and sulfuric acid. An Off-Site Emergency Response Plan is required for facilities that use, store, or manufacture Extremely Hazardous Substances (EHS) at or above a Threshold Planning Quantity (TPQ), such as a cold storage facility for anhydrous ammonia (photo 9).
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These plans primarily address public safety and protection issues for off-site release. They may not contain a comprehensive analysis of the entire facility, but they may contain important site-specific information such as building construction, general layout, occupancy, and identification of chemical-specific characteristics. This plan addresses only extremely hazardous substances and may not provide guidance for other on-site emergencies or emergencies involving chemicals not listed as an EHS. Other beneficial aspects, however, may include how a leak or spill is detected. Is it human or mechanical? A key point to remember with an off-site plan is that its purpose is to address off-site public protection issues rather than on-site emergency actions.
The EPA also has a Risk Management Program (RMP) that includes development of plans for facilities that use specific regulated chemicals such as propane or ammonia at or above certain quantities. These plans contain important information related to chemical inventories, their locations, as well as a consequence analysis that identifies vulnerability distances.
Other plans may be required for specific industries as well as for specific chemicals. Each plan has information that must be contemplated before an incident. Each plan also has limitations on what is included. Again, a plan may be developed for a specific purpose and may not include other incident types or influencing measures.
CONFIDENTIALITY
It is important to be sensitive to the confidentiality of the information contained within a facility emergency plan. Sensitive issues such as security and phone numbers as well as delicate information including internal communication mediums should not be published. Certain information should be available only to those with a need to know. Do not misuse or release any information the facility deems confidential.
CRITIQUE
The most important part of reviewing a facility emergency plan is determining what is going on before and during your response. Identifying issues that will hamper your efforts is essential. Educating the facility on aspects that will affect incident operations before, during, and after an emergency is also crucial. Whether a perceived small issue, such as consistent position titles, or a concern that could affect how you would operate at an emergency, such as discovery and notification procedures, each need has to be addressed and resolved. What you do or don’t do before an incident will have long-lasting effects and repercussions. Your level of preincident preparedness will directly reflect on the incident’s outcome.
Emergency plans are an important element of a facility’s preparedness and can provide fire officials with valuable information that can be applied during an emergency at the facility. However, you must review the plans before an incident occurs to identify aspects that may be inaccurate or may compromise your emergency response effort. If, after reviewing a plan, you identify situations that may be counterproductive to your operations, address them immediately. If you do not correct these issues before an emergency occurs, you are doing a great disservice to the facility, your department, and the community.
ERIC G. BACHMAN, a 24-year veteran of the fire service, was formerly fire chief of the Eden Volunteer Fire/Rescue Department in Lancaster County, Pennsylvania. He is the hazardous materials administrator for the County of Lancaster Emergency Management Agency and serves on the Local Emergency Planning Committee of Lancaster County. He is registered with the National Board on Fire Service Professional Qualifications as a fire officer IV, fire instructor II, hazardous materials technician, and hazardous materials incident commander. He has an associate’s degree in fire science and earned professional certification in emergency management through the state of Pennsylvania. He is also a volunteer firefighter with the West Hempfield (PA) Fire & Rescue Company.
