Emergency Response

Having an established emergency response plan (ERP) is a critical component for maintaining facility occupant safety during an emergency event. Document management facilities can be dangerous environments that pose a risk of serious fire and, like other facilities, are subject to many other emergency events. Fire risk is an unavoidable consequence in the records and information management (RIM) business, but mitigating that fire risk and other potential life safety hazards should be a top priority for facility managers.

An ERP is at the core of workplace safety. Not only is this document an essential part of reducing the risk of injury or death within a facility, it may be required by the Occupational Safety and Health Administration (OSHA). If an emergency event occurs, it is of paramount importance that the plant operators know how to react and where critical information can be found.

What Is An ERP?
Several items are required to be included in an ERP as a minimum, but every emergency response plan should be tailored specifically for events that could affect the local facility or its processes. Clear, specific and detailed information should be provided, and the document should be easily accessible to everyone in the facility. The minimum requirements to be included in a facility’s ERP as stated by OSHA are:

• Procedures for reporting a fire or other emergency – For fire, this can be as simple as activating a pull station located adjacent to an exit door during an evacuation. For other emergencies, such an act of nature (i.e., a tornado or hurricane) a more detailed notification procedure may be required to ensure all employees are notified. Communication is a key component in emergency management and should be detailed in the plan. The use of intercoms, radios, telephones or alarm signals needs to be coordinated.
   
• Procedures for emergency evacuation, including evacuation type and exit route assignments – A drawing of the building is of great value here. Exit routes, illustrated on a building plan, and a walk through the facility with a new employee can be sufficient to satisfy this requirement for fire. Some facilities, however, may require a more in-depth evacuation explanation because of security requirements and, in some weather-related events, evacuation to the outside may be inappropriate. All potential emergency scenarios should be considered and a corresponding evacuation or response should be described.
   
• Procedures to be followed by employees who remain to perform critical plant operations before they evacuate – The development of an emergency response team that assigns specific responsibilities to designated plant personnel is required for ERP implementation. Responsible individuals and their backups should be listed by name or title. Some emergency response team members may be required to conduct a plant shutdown sequence or to tend to specific tasks, such as verifying certain areas of the plant are evacuated, prior to their exiting the building. Who must perform particular tasks should be covered for every scenario.
   
• Procedures to account for all employees after evacuation – The employee assembly point should be stated. The person or people who are responsible for roll call should be named, and they should have access to accurate data as to which employees are present in the facility during the evacuation. In the event the primary assembly point is inaccessible, a secondary assembly point should be named.
   
• Procedures to be followed by employees performing rescue or medical duties – If employees are specifically trained and are responsible for medical or rescue duties in the event of an emergency, their operating procedures and the limit of their responsibilities should be stated in the ERP and understood by the employee. If employees are trained to use hose lines for fire, this should be stated. If employees are not permitted to use fire suppression equipment and are expected to immediately evacuate, this also should be stated. Will a defibrillator be in the area, and are all employees expected to operate it?
   
• The name or job title of every em-ployee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan – Employees may request additional information, so designated individuals should be identified. If weather conditions cancel work for the day, how are employees notified? Managers’ cellular telephone numbers should be provided. Some facilities may consider nonresidents notifying all higher level managers as part of standard emergency procedure as well.

When Should An ERP Be Used?
Clearly, an ERP is developed for use in the event of an emergency, but at the time of emergency, it should be expected that the facility occupants are familiar with the appropriate procedures. The development of an ERP is critical, but ensuring occupant familiarity with it permits the mitigation of the effects of possibly harmful or catastrophic scenarios through a planned response. It is not the employees’ responsibility to read the document when the emergency is occurring.

Conducting fire and weather drills and putting the ERP into action regularly is critical. The key to any emergency plan is to drill, drill and drill until it is second nature to facility staff.

OSHA requires the ERP be reviewed with each employee when the plan is developed and when an employee is initially placed in a new position with the company. If the employee’s responsibilities under the ERP change or if the ERP is revised, the plan must be reviewed again.

In the document storage and destruction business, important issues need to be considered in an ERP that are unique to the industry and facility function. The security of the information entrusted to document management companies by the customer cannot be compromised. This responsibility must be emphasized in the planned emergency response procedures stated in the facility’s ERP.

During a fire event in a shredding plant, the risk of documents blowing away during the fire-fighting process is increased. What actions can be taken to contain debris during fire-fighting operations?

Many emergencies in records storage facilities will require evacuation, but how will customers’ privacy be protected when everyone is required to leave the building?

The development of an ERP may bring to light actions that can be taken by a facility’s employees to reduce the possibility of a security breach occurring in an emergency situation.

Not all scenarios will have a simple solution. In some cases, priorities may need to be compromised to protect the health and safety of staff. Preplanning helps managers make those decisions that are in the best interest of business continuity and occupant safety. Being aware of the trade-offs and decisions required during an emergency, prior to an event, facilitates proper handling of a situation and can help minimize the negative impact of the incident.

Beyond the ERP
While regular review of the ERP is important to ensure a proper emergency response by the facility’s staff, a proactive approach to a facility’s emergency systems is required to maintain a safe and code-compliant workplace. For instance, inspection, testing and maintenance (ITM) of fire and life safety systems are essential to providing a safe work environment and to limiting the risk of a large loss event within any facility. Every facility manager should provide the due diligence required to verify that his or her facility is reasonably safe and code compliant. Some essential risk reduction items’ importance cannot be overstated and are mentioned below.

Contracts for quarterly ITM of fire sprinkler and fire alarm systems based on National Fire Protection Association (NFPA) 13 and 72 should be in place. The contact information for the contractors responsible for providing these services should be readily available in case a repair is required. Even if these life safety systems are being tested quarterly by contractors, facility managers should learn to visually inspect these systems daily.

The presence of portable fire extinguishers with current tags within 75 feet of all areas of the plant should be verified. The presence of and easy access to these devices could be the difference between a small incident at a facility and a major loss. Be sure that facility employees are familiar with the use of these important fire protection devices.

Emergency lighting and exit sign adequacy and functionality should be reviewed at least annually. This responsibility can be included in your life safety ITM contracts or it can be handled in house by facility staff. However, records and checklists should be maintained if an in-house program is adopted.

A very important but often overlooked example of a proactive risk reduction approach is housekeeping. All of the facility’s exit paths must remain unobstructed and be free from debris at all times. Be sure a diligent and ongoing cleanup process is enforced. A clean facility often can make the difference between an emergency and a nonevent.

If your facility does not have an ERP in place, OSHA offers an online tool designed to help streamline the process for creating such a document. Visit www.osha.gov/SLTC/etools/evacuation/expertsystem/default.htm# to begin the ERP planning process.

The author is a senior fire protection engineer with The Fire Protection International Consortium Inc., www.the-fpi.com. He has assisted many document management companies in the development of ERPs.