Review of Emergency Procedures After an Incident
But what does this mean to us, the auditor and what should we look for at a company on an audit after they have had, shall we say, an event.
This ‘Event’ could be anything ranging from Fire, Flood, Gas Release etc. Let us say the company we are auditing is a printer, obviously they will have plenty of items in use that could spill and need to be cleaned up. What should they have in place?
The company could follow the simple five step rule:
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Step 1: Identification (you must identify the specific potential accident related to your circumstances and type of activity)
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Step 2: Prevention
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Step 3: Emergency plan
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Step 4: Training and drills (testing for training effectiveness)
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Step 5: Evaluation and improvement
If this is the case the auditor should be able to review various documents that will explain what to do in an event. In preparing a response to an emergency, has consideration been given to the initial environmental impact that can result and any secondary environmental impact that can occur as a result of responding to the initial environmental impact.
For example, in responding to a fire, the potential for air pollution should be considered. When preparing a response to reasonably foreseeable emergency situations, special attention should be paid to start-up and shutdown and abnormal operating conditions.
Has the company clearly identified and is prepared for different types of situations, such as small-scale spillages of chemicals, failure of emission abatement equipment, or serious environmental situations endangering humans and environment to a broad extent?
Has the company clearly documented that they are prepared for each type of reasonably foreseeable emergency? A few questions we may want to look at on review of an incident.
First off, we need to look at whether they have clearly identified the issue, normally this ties in with the Aspects & Impacts identified by the company and by what the company does.
An effective emergency preparedness and response program could also be in use, this should include provisions for assessing the potential for accidents and emergencies, preventing incidents and their associated environmental impacts, plans/procedures for responding to incidents, periodic testing of emergency plans/procedures and, mitigating impacts associated with these incidents.
Emergency response plans, including facility layouts. Emergency responders must be familiar with facility layouts and potential hazards and must be adequately trained to prevent and mitigate a variety of human and environmental impacts.
If this is OK, we could then look at the reporting from the incident, this, hopefully, is clear in a company process/procedure, this is what we should follow to ensure that the steps undertaken are being followed.
We should hopefully see how they would contain the spill i.e. spill kits appropriate to the spill risk, containing mats, granules etc., a report with what happened, time, area, who was involved, actions taken, who it was reported to.
We would also like to see a review of the incident undertaken by senior management, which will include a root cause of the issue and then further comments where needed as to how things can be improved, monitoring of the area to ensure that the same incident does not reoccur, staff are fully trained in all emergencies identified, with possible ongoing refreshers such as first aid etc. and of course any further testing to ensure process in place will still be effective in controlling emergency issues and response to them.
To ensure that they are complying to ISO 14001:2015. But remember, all companies are different and may have a different interpretation of what is required. It is our jobs as Auditors to be pragmatic in our approach to a company’s management system, and gentle push them in the right direction to improve what they have.
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This blog is authored by: Toby Hyde, NQA UK regional Assessor