Appendix C

Emergency Response and Emergency Preparedness

Emergency response is commonly conceived as providing an additional layer of protection that goes beyond engineered safety features (ESFs) such as water curtains and flare systems (CCPS, 2009). That is, the emergency response is intended to be independent of all ESFs so that it can perform even if those systems fail. Indeed, an effective emergency response involves linked onsite and offsite emergency response organizations that perform emergency assessment, hazard operations, population protection, and incident management actions. On the basis of federal guidance for nuclear and chemical emergency preparedness (USNRC/FEMA, 1980; NRT, 1987, 1988), Lindell and Perry (1992, 2006, 2007) defined emergency assessment as actions taken to define the nature and magnitude of an event by evaluating conditions in the facility and the surrounding physical environment—especially plant conditions, chemical releases, and meteorological conditions (McKenna, 2000). Hazard operations consist of preventive and corrective actions to control leaks, spills, fires, and stabilize containers (Lesak, 1999). Population protection includes the use of personal protective equipment and safe havens to protect facility personnel. In addition, it includes offsite actions such as warning people in potentially affected areas to shelter in-place or evacuate, providing evacuation transportation support and traffic management, establishing public shelters (congregate care facilities for those who lack the funds to pay for hotels/motels or nearby, and providing medical treatment for those who are injured (Perry and Lindell, 2007). Finally, incident management ensures that emergency assessment, hazard operations, and population protection actions are undertaken in a timely and effective manner and that responders have sufficient resources—including support staff, equipment, and facilities—to do their jobs. Effective incident management provides coordination between onsite and offsite



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Appendix C Emergency Response and Emergency Preparedness Emergency response is commonly conceived as providing an additional layer of protection that goes beyond engineered safety features (ESFs) such as water curtains and flare systems (CCPS, 2009). That is, the emergency response is intended to be independent of all ESFs so that it can perform even if those systems fail. Indeed, an effective emergency response involves linked onsite and offsite emergency response organizations that perform emergency assessment, hazard operations, population protection, and incident management actions. On the basis of federal guidance for nuclear and chemical emergency preparedness (USNRC/FEMA, 1980; NRT, 1987, 1988), Lindell and Perry (1992, 2006, 2007) defined emergency assessment as actions taken to define the nature and magnitude of an event by evaluating conditions in the facility and the surrounding physical environment—especially plant conditions, chemical releases, and meteorological conditions (McKenna, 2000). Hazard operations consist of preventive and correc- tive actions to control leaks, spills, fires, and stabilize containers (Lesak, 1999). Population protection includes the use of personal protective equipment and safe havens to protect facility personnel. In addition, it includes offsite actions such as warning people in potentially affected areas to shelter in-place or evacuate, providing evacuation transportation support and traffic management, establish - ing public shelters (congregate care facilities for those who lack the funds to pay for hotels/motels or nearby, and providing medical treatment for those who are injured (Perry and Lindell, 2007). Finally, incident management ensures that emergency assessment, hazard operations, and population protection actions are undertaken in a timely and effective manner and that responders have sufficient resources—including support staff, equipment, and facilities—to do their jobs. Effective incident management provides coordination between onsite and offsite 173

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174 USE AND STORAGE OF METHYL ISOCYANATE (MIC) AT BAYER CROPSCIENCE emergency response organizations through a mutually agreed emergency clas - sification system and standardized forms for continuing emergency assessments. In addition, coordination between onsite and offsite organizations is facilitated by mutual adoption of organizational structures such as the Incident Command System (DHS, 2008). People sometimes erroneously assume that major disasters are just larger versions of routine emergencies, and so available personnel can improvise a satisfactory response using available resources. In fact, major disasters involve both quantitatively larger and qualitatively different demands that arise from tasks that are not performed, and resources that are not available, during routine operations. Thus, emergency planners need to follow a systematic process that develops accurate assessments of incident demands and community capabilities, identifies the gaps between demands and capabilities, and develops a strategic plan for reducing this gap (Lindell and Perry, 2007). Specifically, they must use hazard/vulnerability analysis to identify, in advance, what are the abnormal inci - dent demands that should be expected and what are the novel emergency response functions that will need to be performed in response to these demands. In addi - tion, they need to identify the organizations that will perform these emergency response functions and the resources those organizations will need in order to perform their emergency response functions. Emergency operations plans and procedures can be developed by following guidance from the federal government (NRT, 1987, 1988; FEMA, 2010) and chemical industry (CMA, 1985), national standards (NFPA, 2010), and accredi - tation programs (EMAP, 2010). These documents are sometimes misinterpreted to suggest that the development of paper plans and procedures is a sufficient condition for adequate emergency preparedness. Instead, development of written plans and procedures should be considered to be a necessary, but not a suffi - cient, condition. At minimum, plans and procedures need to be supplemented by periodic audits to ensure that they are current (e.g., telephone numbers are up to date) and that equipment is properly maintained (e.g., portable instruments are charged and calibrated). In addition to developing emergency operations plans and procedures, emer- gency planners need to conduct training needs assessments to identify any tasks that are critical, infrequent, and difficult (Goldstein and Ford, 2002). Critical tasks are those that are essential to protecting the health and safety of facility personnel, offsite responders, and the offsite population. In addition, although some emergency response tasks are the same as ones performed during normal operations, it is important to identify which of them are performed infrequently and therefore provide few opportunities for emergency responders to practice and develop skilled performance. Finally, some tasks might be difficult to perform because of their cognitive, psychomotor, or physical demands. Effective emer- gency preparedness requires identifying these infrequent, critical, and difficult tasks, selecting the appropriate personnel for each position in the emergency

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175 APPENDIX C response organization, and providing the levels of initial and refresher training needed to ensure emergency responders continuing proficiency. Like safety train- ing, emergency response training can be accomplished in a number of different ways that address workers’ abilities and performance motivation (Lindell, 1994). Because of the significant uncertainties about disaster demands, emergency plan - ners need to provide training that facilitates emergency responders’ ability to improvise so that they can develop incident action plans that adapt to the distinc - tive circumstances of each emergency (Ford and Schmidt, 2000; Mendonça and Wallace, 2004). Finally, effective emergency preparedness programs rely on methods such as drills, exercises, and minor incidents. Individual responder drills—as well as tabletop, functional, and full-scale exercises—need to be reviewed by qualified evaluators. Critiques of these drills and exercises can be used not only to identify needs for additional individual training but also can be used as opportunities for organizational learning. That is, these critiques can be used as the basis for revis - ing plans, procedures, and selection and training programs. DEVELOPING AND MAINTAINING EMERGENCY PREPAREDNESS To identify organizational and contextual factors associated with establishing and maintaining emergency preparedness, we conducted a search for articles on emergency preparedness at chemical facilities. This search yielded a number of scholarly articles on emergency preparedness but most of them provide recom- mendations for developing facility emergency preparedness rather than examining factors that influence its development and maintenance. Of the few articles that discuss changes in facility emergency preparedness, most examine the effects that major incidents such as Bhopal exert on subsequent laws and regulations with which chemical facilities must then comply (e.g., Belke and Dietrich, 2005; Joseph et al., 2005; Gerbec and Kontic, 2009). Only two studies have examined factors influencing emergency preparedness at chemical facilities. Quarantelli et al. (1979) found that larger companies had more extensive planning processes than smaller ones, and Lindell and Perry’s (1998) examination of hazardous materi- als—handling firms in Los Angeles, California, found that all facilities in the study were more likely to engage in hazard assessment and emergency preparedness measures than hazard mitigation measures in the year after the 1994 Northridge Earthquake. Moreover, they substantially increased their implementation of hazard mitigation measures such as plant site, plant design, process modification, exter- nal hazard protection, chemical substitution, and administrative controls during that time period. Surprisingly, however, there was no evidence of a relationship between experienced damage and implementation of these mitigation measures. A broader literature on organizational emergency preparedness reveals that businesses generally engage in limited levels of emergency preparedness (Mileti et al., 1993; Drabek, 1994a; Dahlhamer and D’Sousa, 1997). As was the case

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176 USE AND STORAGE OF METHYL ISOCYANATE (MIC) AT BAYER CROPSCIENCE in the Quarantelli et al. (1979) study, the most reliable indicator for predicting organizational emergency preparedness is organizational size (Drabek, 1991, 1994a,b; Dahlhamer and D’Souza, 1997; Perry and Lindell, 2007). In addition, some studies have found evidence of a positive relationship between disas- ter experience and business emergency preparedness (Dahlhamer and Reshaur, 1996; Dahlhamer and D’Souza, 1997; Webb et al., 2000). Finally, some studies on organizational emergency preparedness have found that other characteristics, including business age, scope (local vs. national) and type may correlate with degree of emergency preparedness, but at this time, the findings are inconsistent across studies. There has been a substantially smaller amount of research on the conditions that facilitate community emergency preparedness (Lindell and Perry, 2001, 2007). An analogue of management support, support from senior elected and appointed officials, as well as the wider community, is an important element in community emergency preparedness but other elements are also important (Lindell and Perry, 2006, 2007). These include hazard exposure/vulnerability, community resources, extra-community resources, routine staffing/organization, and the type of planning process adopted. In addition, EPA performed a sys - tematic study of community preparedness for chemical accidents and found that there was often poor coordination between plants and communities as well as few communication protocols in place for emergency response (Rogers and Sorensen, 1991; Sorensen and Rogers, 1988). All of these factors directly or indirectly affect individual outcomes for those participating in the community emergency preparedness system (job satisfaction, organizational commitment, organizational attachment, and organizational citizenship), as well as organizational outcomes such as the quality, timeliness, and cost of products such as hazard/vulnerability analyses, community capability assessments, emergency plans and procedures, training programs, and risk communication programs. SUMMARY Effective emergency response requires pre-incident emergency preparedness to ensure that onsite and offsite emergency response organizations have adequate staffing, training, and resources. There is extensive guidance available for devel - oping and maintaining emergency preparedness, but the level of organizational emergency preparedness is generally modest. It appears that a major impediment is that many organizations underestimate the demands of a major incident, or overestimate their ability to improvise an effective response, or both. Additional impediments to the development of effective emergency preparedness programs are perceptions that emergency preparedness is “an intractable problem and that disaster reduction policies lack clear and measurable performance objectives” (Waugh, 1988). These problems are exacerbated by the disparity between the costs and benefits of effective emergency preparedness programs; such programs

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177 APPENDIX C have substantial short-term costs but only “pay off” in the long term. The limited amount of existing research suggests that organizational emergency preparedness is usually determined by factors such as organizational size and disaster experi - ence, but other factors also need to be examined (Lindell and Perry, 2007). ISP strategies can avoid some of the shortcomings of organizational emer- gency preparedness programs by reducing the toxicity of the chemicals being used or produced, the quantity of the chemicals being stored, and the conditions under which they are being stored. However, chemical facility designers need to consider the potential for ISD strategies to transfer risks from communities surrounding fixed-site facilities to those on transportation routes where the lower quantities released are likely to be at least partially offset by lower levels of emergency preparedness. REFERENCES Belke, J. C., and D. Y. Dietrich. 2005. The post-Bhopal and post-9/11 transformations in chemical emergency prevention and response policy in the United States. J. Loss Prevent. Proc. Ind. 18:375-379. CCPS (Center for Chemical Process Safety). 2009. Inherently Safer Chemical Processes: A Life Cycle Approach, 2nd ed. Hoboken NJ: John Wiley & Sons. CMA (Chemical Manufacturers Association). 1985. Community Awareness and Emergency Response: Program Handbook. Washington, DC: CMA. Dahlhamer, J. M., and M. J. D’Sousa. 1997. Determinants of business-disaster preparedness in two U.S. metropolitan areas. Int. J. Mass Emerg. Disasters 15:265-281. Dahlhamer, J. M., and L. M. Reshaur. 1996. Businesses and the 1994 Northridge Earthquake: An Analysis of Pre- and Post-disaster Preparedness. Newark, DE: University of Delaware Disaster Research Center. DHS (U.S. Department of Homeland Security). 2008. National Incident Management System. Wash- ington, DC: DHS. Drabek, T. E. 1991. Anticipating organizational evacuations: Disaster planning by managers of tourist- oriented private firms. Int. J. Mass Emerg. Disasters 9:219-245. Drabek, T. E. 1994a. Disaster Evacuation and the Tourist Industry. Boulder, CO: University of Colo- rado Institute of Behavioral Science. Drabek, T. E. 1994b. Risk perceptions of tourist business managers. Environ. Prof. 16:327-341. EMAP (Emergency Management Accreditation Program). 2010. EMAP Standard. Lexington, KY: EMAP. FEMA (Federal Emergency Management Agency). 2010. Developing and Maintaining Emergency Operations Plans, Comprehensive Preparedness Guide (CPG) 101, Ver. 2.0. Washington, DC: FEMA. Ford, J. K., and A. Schmidt. 2000. Emergency preparedness training: Strategies for enhancing real- world performance. J. Hazard. Mater. 75:195-215. Gerbec, M., and B. Kontic. 2009. Implementation of the Seveso II Directive in Slovenia: Survey of implementation and opinions of operators regarding its safety benefits. Saf. Sci. 47:561-568. Goldstein, I. L., and J. K. Ford. 2002. Training in Organizations: Needs Assessment, Development and Evaluation, 4th Ed. Pacific Grove, CA: Brooks/Cole. Joseph, G., M. Kaszniak, and L. Long. 2005. Lessons after Bhopal: CSB a catalyst for change. J. Loss Prevent. Proc. Ind. 18:537-548.

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178 USE AND STORAGE OF METHYL ISOCYANATE (MIC) AT BAYER CROPSCIENCE Lesak, D. M. 1999. Hazardous Materials: Strategies and Tactics. Upper Saddle River, NJ: Prentice-Hall. Lindell, M. K. 1994. Motivational and organizational factors affecting implementation of worker safety training. Pp. 211-240 in Occupational Medicine State of the Art Reviews: Occupational Safety and Health Training, M. J. Colligan, ed. Philadelphia: Hanley and Belfus. Lindell, M. K., and R.W. Perry. 1992. Behavioral Foundations of Community Emergency Planning. Washington, DC: Hemisphere Press. Lindell, M. K., and R.W. Perry. 1998. Earthquake impacts and hazard adjustment by acutely hazard - ous materials facilities following the Northridge earthquake. Earthquake Spectra 14:285-299. Lindell, M. K., and R. W. Perry. 2001. Community innovation in hazardous materials management: Progress in implementing SARA Title III in the United States. J. Hazard Mater. 88:169-194. Lindell, M. K., and R. W. Perry. 2006. Onsite and offsite emergency preparedness. Pp. 1959-1971 in Encyclopedia of chemical processing, S. Lee, ed. New York: Marcel Dekker. Lindell, M. K., and R. W. Perry. 2007. Planning and preparedness. Pp. 113-141 in Emergency Management: Principles and Practice for Local Government, 2nd Ed., K. J. Tierney and W. F. Waugh, Jr., eds. Washington, DC: International City/County Management Association. McKenna, T. 2000. Protective action recommendations based upon plant conditions. J. Hazard. Mater. 75:145-164. Mendonça, D., and W. A. Wallace. 2004. Studying organizationally-situated improvisation in response to extreme events. Int. J. Mass Emergencies and Disasters 22:5-29. Mileti, D. S., J. D. Darlington, C. Fitzpatrick, and P. W. O’Brien. 1993. Communicating Earthquake Risk: Societal Response to Revised Probabilities in the Bay Area. Fort Collins, CO: Colorado State University Hazards Assessment Laboratory and Department of Sociology. NFPA (National Fire Protection Association). 2010. NFPA 1600: Standard on Disaster/Emergency Management and Business Continuity Programs. Quincy, MA: NFPA. NRT (National Response Team). 1987. Hazardous Materials Emergency Planning Guide. NRT-1. Washington DC: NRT. NRT. 1988. Criteria for Review of Hazardous Materials Emergency Plans. NRT-1A. Washington DC: NRT. Perry, R. W., and M. K. Lindell. 2007. Emergency Planning. Hoboken, NJ: John Wiley & Sons. Quarantelli, E. L., C. Lawrence, K. J. Tierney, and Q. T. Johnson. 1979. Initial findings from a study of socio-behavioral preparations and planning for acute chemical hazard disasters. J. .Hazard. Mater. 3:79-90. Rogers, G. and Sorensen, J. 1991. Adoption of Emergency Planning Practices for Chemical Hazards in the United States. Journal of Hazardous Materials. 27:3-26. Sorensen, J. H. and G. O. Rogers. 1988. Local Preparedness for Chemical Accidents: A survey of U.S. Communities. Industrial Crisis Quarterly 2:89-108. USNRC/FEMA (U.S. Nuclear Regulatory Commission/Federal Emergency Management Agency). 1980. Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. NUREG-0654/FEMA-REP-1. Washington, DC: USNRC/FEMA. Waugh, W. L., Jr. 1988. Current policy and implementation issues in disaster preparedness. Pp. 111- 125 in Managing Disaster: Strategies and Policy Perspectives, L. K. Comfort, ed. Durham, NC: Duke University Press. Webb, G. R., K. J. Tierney, and J. M. Dahlhamer. 2000. Business and disasters: Empirical patterns and unanswered questions. Nat. Hazards Rev. 1:83-90.