Challenges and Issues to Prepare for and to Manage a Large-Scale Environmental Emergency

The following explores common challenges and issues to be prepared for a large-scale an emergency such as a spill, flood or fire.  The are largely “institutional” challenges and therefore difficult to remedy.  These challenges are common both in industry and government - worldwide.

Operational Guideline on the Incident Command System
OP Guide - ICS Process.pdf
Adobe Acrobat Document 16.1 MB

Ensuring Government and Company Executives Understands their Role as an “Agency Executive” Also referred to: Crisis Management Team or Policy Group

 

A government and company (for spills) executive need to function as an “Agency Executive/Policy Group” during a major emergency.  Training is also required so the executive knows their response capability as well as technical and institutional gaps that may be encountered, such as described below.

 

Dealing with Divergent Response Paradigms.

 

Some governments and most large industries have adopted the Incident Command System (ICS) emergency management structure and the unified command process therein. Some agencies and companies have not adopted the ICS or have significantly modified it. Those agencies with leadership mandates that do not use ICS may negatively result in achieving a strategic command position and could potentially impede govt/industry response integration. Establishing a common national and international response management organization,such as the ICS, builds both capability and capacity.  The latter is achieved by having a large pool of trained responders for assistance.  During an emergency is not the time to learn another approach or modified an established system.

 

Training on Response Plans and  Guidelines for Incident Management Team (IMT) members and Technical Specialists 

 

Government agencies for emergency delivery and companies require response plans and guidelines for all scales of emergencies and responder functions - i.e. 1st responders,Incident Management Teams, and Technical Specialists. Response (contingency) plans should be strategic and organizational in nature, whereas operational guidelines as separate documents provide more specific detail around response delivery - both organizational and technical. Preparing operational guidelines becomes an on-going emergency preparedness process.

 

Recognizing the Limited Spill Preparedness Mandate of Government sanctioned and industry spill response regimes

 

It is important to understand the scope and limitations of spill response organizations  - whether government sanctioned (marine oil spills) or industry-based (inland spills cooperatives).

 

Achieving Strategic placement for an International (cross-border) spill 

 

Generally under ICS/unified command, government integrates first and foremost with the Responsible Party when there is a major spill within their jurisdiction. For international spills, the agency or Responsible Party might have to send their response team members to a Command Post located across a border or alternatively establish liaison between to Command Posts on each side of the border. Each arrangement requires executive understanding, support and leadership in this area - as well as supported by the response team members.

 

Addressing a Fragmented Private-sector Response Capability for a Major Spill

 

The transportation and manufacturing sectors often rely on small, specialized contracted response companies for spill response. This raises several issues related to a potentially fragmented response by spill contractors.  Establishing response organizations (cooperatives) to pool resources (people and equipment) mitigates this fragmentation.

 

Integrating Local Government and First (Tribal) Nations into Incident management at the Command Post.

 

Under ICS, integration of all jurisdictions and the Responsible Party occurs at the Incident Command Post (site) – this reflects shared responsibility and working together as a team.  Other than fire departments, the focus of local governments has been on establishment of supporting Emergency Operations Centres (EOC), and not providing or staffing an Incident Command Post at the site-level.  First (Tribal) Nations have little or no understanding under the ICS on how to attain a strategic position in command, provide technical information, or provide other response services.  This challenge can leave government or a company with the full responsibility of driving an integrated response to a large spill. 

 

Migrating from Emergency, to Protracted Work Project, to an Impact Monitoring

 

Spill incidents transform from an emergency situation (e.g. threat or mobile product mitigation), to a work project (cleanup/remediation) to impact monitoring (assessing long-term consequences). Understanding and transferring through these stages is often awkward that therefore results in misunderstanding of the types and levels of resources required. Stakeholders often misconstrue that government, the Responsible Party, or both are abandoning them during the impact monitoring phase.

 

Managing Complex, Geographically wide-spread Emergencies such as Earthquakes, Floods, Severe Storms

 

The most common response plans and practices are generally designed for singular, geographically confined events - railway accident,vessel grounding, truck roll-over. Though ICS can address complex emergency situations - such as floods - there is little fundamental understanding in government or industry on how the ICS approaches are applied. For example, most local government efforts are at the supporting EOC levels and not at the site/field level of response where 90% of the organization and accountability resides. Most local governments don’t know when or where Incident Command Posts will established or located during a wide-spread event. The lack of strategically establishing Incident Command Posts  and the management structure therein to bridge EOCs support and tactical field operations is called the “Katrina” effect.

 

Building Synergy regarding the Convergence of Business Continuation and Emergencies

 

Where both business continuation and emergencies converge is at the supporting Emergency Operations Centre (EOC) and the Agencies or Companies Executive levels. There is poor understanding that during a major emergency the EOC functions include both supporting the IMT at the Incident Command Post as well as protecting the business of the agency or company.  Generally, for business continuation the focus has been staffing an EOC, but little understanding of the relationships at the site level response during an internal event – e.g. building fire, flooded room, IT failure, etc.  There is opportunity for synergy between business continuation and external emergencies.

 

Mitigating Financial Vulnerability from a Major Spill

 

Spill related emergency programs are generally founded on polluter-pay, reasonable actions and reasonable cost. However, this does not guarantee the prospect of government incurring substantial unrecoverable costs. The government and industry must understand the financial arrangements, striving for reasonable actions/cost and mitigate this risk.

 

Escalating Response from the First Responder to an Incident Management Team under the ICS process

 

The first competent responder to an incident assumes all the responsibility of an IMT until additional resources arrive on-scene.  This applies to all initial responders from local, regional, national government agency or industry functioning under an ICS protocol. The first responder requires confidence that an IMT – or portions thereof – will arrive on-scene in a timely and ready state.  Furthermore for a large escalating spill, the first responder acting as the Incident Commander under ICS needs a high degree of discipline to undertake three critical steps: 1) ensure initial tactical resources are deployed safely 2) gather as much situation information as possible 3) facilitate the establishment of an Incident Command Post and the ICS process.  Roving Incident Commanders in the tactical area (field) are not doing a service to incident management.

 

Building Leadership in the Development and Care of an Emergency Management Program

 

The traditional model of emergency preparedness for spills, fires, floods, fosters recognition of risk, but does not drive emergency preparedness per se. Having an IMT generally viewed as a future value for a distant event.  The immediate value of emergency preparedness is that there are opportunities within the agency/company to build institutional/corporate wellness by team building such as: 1) tangible proof and positive messaging to internal staff and external stakeholders that people, property and the environment are being cared for; 2) engaging staff from different classifications, disciplines and genders toward meeting a common mission (breaking down “silos”) 3) expanding skills sets of IMT/Technical specialists, and  4) enabling and empowering members to use their specialities in a new, dynamic setting.

 

Increasing R&D and Innovation in Emergency Response

 

There is a general  lack of R&D in emergency response for large events that requires creative solutions to problems.  For example, for a major oil spill, there is a lack of innovation in the management of large amounts of oily waste.

 

Building Capacity and Confidence in Response that Reflects Industrial Growth and Increased Risks to People, Property and the Environment.

 

Where there is substantial industrial development in a region it increases risk. Industry generally focusses on infrastructure development with no incremental resources applied to spill prevention, preparedness, mitigation or response.  There is often a lack of government and industry messaging on what the risk mitigation as well as spill preparedness standards should be and when, where and how they should be implemented.

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