EPA Issues Guidance on Emergency Response Procedures
The EPA has issued guidance in relation to the Preparation of Accident Prevention Procedures and Emergency Response Procedures. The purpose of this guidance is to set out the minimum requirements for Accident Prevention Procedures (APP), Emergency Response Procedures (ERP), as well as guidance on incident notification.
The preparation of an Accident Prevention Procedure and an Emergency Response Procedure is a condition of most licences issued by the EPA. The purpose of which is to minimise the potential for accidents to occur, and to reduce impacts on the environment should they happen.
Requirements of an Accident Prevention Procedure (APP)
The EPA guidance recommends that, at a minimum, the preparation of the site specific APP should include:
- Identification of all hazards and risks on site and ensure the necessary measures are taken to prevent accidents;
- Review of site assessments to help identify possible risks and sensitive receptors. These documents may include; Seveso Assessments, Environmental Impact Statements, Baseline Reports, etc.;
- An accident investigation procedure which includes a review of the APP following any accident/incident to ensure it is still fit for purpose;
- Guidelines on incident notification, management and communication to the relevant authorities;
- Annual review of the APP, which should consider any incidents or accidents that may have occurred since the last review.
Requirements of an Emergency Response Procedure (ERP)
The preparation of a site specific ERP should, at a minimum, include:
- A risk assessment or scoping exercise to ensure that all potential emergency situations are identified and sufficiently addressed;
- Measures to minimise of the effects of any emergency on the environment;
- Measures to address ‘out of hours’ emergencies;
- Assign specific roles and responsibilities to Emergency Response Team personnel, including a nominated role with responsibility for co-ordinating with Emergency Services;
- Preparation for emergency events through mock exercises for more complex plans/sites;
- The ERP should provide for the assessment of the off-site impact on the environment/public during the emergency response and this should be communicated to the relevant bodies such as emergency services, EPA and any other agencies to ensure a coordinated response;
- An up to date chemical, product and waste inventory and associated MSDS;
- An inventory of all incident response and pollution prevention equipment available on site. A site plan showing the location of same and the main access routes for the emergency services.
Both the APP and the ERP should be available to staff and the public and easily accessible in the event of an accident or emergency. If the APP & ERP is covered by multiple documents, then an over-arching procedure shall be provided.
The ERP and APP must also link to the site incident notification, management and communication procedure. You should follow the EPA’s guidance on incident notification, management and communication to ensure that you comply with your licence. EPA guidance on notification of incidents is available through the link below.
The full text of the 2016 EPA guidance on the preparation of Accident Prevention Procedures and Emergency Response Procedures can be found through the link below.
December 2016