Hazardous Waste Management

ICPs Should Help Expedite Emergency Response

Although the choice to create an ICP or One Plan is solely at the discretion of the facility owner/operator, it should be developed with the sole purpose of ensuring that emergency response activities can be undertaken quickly and effectively by all responders, both on-site staff and those from local, state or federal agencies. In the process, however, most facilities will also realize savings from “preparation, maintenance, submission, and updating” just one comprehensive plan rather than multiple plans for different agencies and regulations.

With that in mind, there are a number of requirements that should be considered so that necessary documents and other materials are identified and understood by all concerned. The NRT emphasizes that because the ICP format is designed to apply across different regulations and agencies, it is also necessarily less detailed than the actual regulations and thus facility staff “should continue to read and comply with all of the federal regulations that apply to them.”

From the start, plan developers should understand that the ICP must be written in such a way as to provide responders with the most applicable information in the least time. For example, the Introduction section must provide the facility and key contacts, as well as a statement of purpose and scope, a table of contents, and the contact information for those responsible for plan development and maintenance. However, the NRT Guidance also notes, “This section should contain a brief profile of the facility and its key personnel to facilitate rapid identification of key administrative information.” This sentiment is expressed repeatedly throughout the Guidance document, especially concerning the elements of the Core Plan, which will be the go-to document in the event of an emergency response.

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Another essential step is to assemble all current emergency response plans and their applicable regulations for cross referencing with “current regulatory requirements so that plan reviewers can verify compliance with these requirements.” The NRT Guidance does provide matrices for this purpose, but facilities are responsible for ensuring all of the regulations that apply to them are included in the ICP.

Whether it is decided that the facility’s ICP will incorporate by reference the National Interagency Incident Management System (NIIMS) Incident Command System (ICS) or another system, several requirements apply:

  • For NIIMS ICS use, the location and accessibility of all related documents must be defined; and
  • For other systems, a detailed explanation of the system or an explanation of how it differs from the NIIMS ICS must be provided.

In either case, the plan should also include:

  • An organization chart,
  • Specific job descriptions,
  • A description of information flow with the on-scene coordinator, and
  • A description of how the chosen response management system integrates with a Unified Command.

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In addition, the NRT allows referencing of other “external plans” such as those of the local emergency planning committee (LEPC) and area contingency plans, however, the Guidance states, “The use of references to information contained in external plans does not relieve facilities from regulatory requirements to address certain elements in a facility-specific manner and to have information readily accessible to responders.” This means that information that is critical to a timely response should be “presented for ready access in the ICP,” not just referenced. In fact, all referenced documents should be readily available and those that are not well known and recognized, unique to the facility or unlikely “to be in the possession of the reviewing agency,” should also be submitted with the ICP for review.

As mentioned yesterday, many states have additional or parallel programs addressing ICPs, LEPCs, area contingency plans, as well as local contacts and assistance available to help facilities develop a useful plan and maximize all available resources.

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