EPA requires that the FRP must include an ERAP that is maintained in the front of the FRP or as a separate document accompanying the FRP.
The ERAP must include:
- Qualified Individual Information
- Emergency notification phone list
- Spill response notification form
- Response equipment list and location
- Facility response team
- Evacuation plan
- Immediate actions
- Facility diagram
Facility Name and Location
During an emergency, even the easiest questions are often difficult to answer. Make sure that the ERAP lists the correct facility name, address, and phone number. In addition, make sure that employees know the EPA region in which the facility is located.
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Emergency Response Coordinator
When there has been a spill at your facility, an employee’s first responsibility is to contact the emergency coordinator. Make sure employees know the name of the emergency response coordinator for the entire facility. Provide employees with the name and number of the emergency coordinator.
Make sure employees know whom to contact in the event of a spill and who is responsible for operating response equipment.
The facility should keep the FRP along with the quick reference ERAP together in binders strategically located throughout the facility. Employees should be kept informed of the locations of the binders.
Spill Control and Response Equipment
Provide a description of the facility’s response equipment and its location. Where appropriate, identify the amount of oil that emergency response equipment can handle and clarify any limitations.
Response equipment drills should be conducted to ensure that the equipment is operational and the personnel who will operate the equipment in a spill response are capable of deploying and operating it. Only a representative sample of each type of response equipment needs to be deployed and operated for training purposes.
If there is a shutdown of the facility’s operations because of a spill, or if some employees are required to shut their operations down, they need to know what is expected of them. Make sure employees understand their duties in the event of a shutdown.
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Based on the analysis of the facility, a facility-wide evacuation plan must be developed. Make sure employees are aware of the facility’s plan. Provide facility diagrams and explain evacuation routes. In addition, explain any plans to evacuate parts of the facility that are at a high risk of exposure in the event of a spill or other release. Discuss some or all of the following when explaining evacuation plans:
- Locations of stored materials
- Hazards imposed by spilled material
- Spill flow direction
- Prevailing wind direction and speed
- Water currents, tides, or wave conditions
- Arrival route of emergency response personnel and response equipment
- Evacuation routes
- Alternative evacuation routes
- Transportation of injured personnel to nearest emergency medical facility
- Location of alarm/notification systems
- The need for a centralized check-in area for evacuation validation
- Selection of a mitigation command center
- Locations of shelter at the facility as an alternative to evacuation
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