A 2002 investigation of the response to the 9/11 attacks identified deadly flaws.
For example, it was discovered that while the fire department was leading the response, they were not on the same radio channel as the police department. The investigation also concluded that the fire department had little formal planning at the operational level.
During a crisis, there’s little to no time to mull over what could be done. You have to jump to action on what needs to be done.
And knowing what needs to be done takes planning.
There are things to be learned about the 9/11 attack that are relevant to the management of equipment breakdowns at your facility, since any equipment breakdown generates the need for a series of responses within the facility.
SCAQMD Rule 102 defines a breakdown as “…a condition caused by an accidental fire or nonpreventable mechanical or electrical failure.”
If such a situation were to happen at your facility, do you know what you need to do to comply with the SCAQMD’s rules? Or are questions such as these racing through your head?
- Do I need a variance to continue to operate the process?
- Am I in violation because my equipment is broken?
- Does this situation require us to notify the SCAQMD?
If you have these or similar questions immediately after an equipment breakdown, you weren’t properly prepared.
While a breakdown at your facility might not be life-threatening (although it could be), you still need to be prepared for such an emergency. And the best way to do so is to ensure that those at the operational level are prepared to respond to a breakdown.
A lot happens during the seconds immediately following any facility breakdown or crisis:
- Concern for human safety
- Concern for environmental impacts
- Concern for the larger process
Which means there probably isn’t time to Google the SCAQMD rulebook to get a better understanding of a regulation or permit condition.
Breakdown Emergency Preparedness
Before a crisis hits, make sure you have a plan of action, and that all involved parties are aware of the steps to take. Make it your priority this week — or better yet, today — to make sure you’ve covered all of the following:
1. Know what events (specific to the equipment at your facility) require a notification to the SCAQMD.
Because facilities have different pieces of equipment, which events require a notification to the SCAQMD will differ. It’s your responsibility to know which situations require that you notify the agency.
For example, if equipment A fails because of reason Z, is the event considered a breakdown, a deviation, or an emergency? (This is important since the steps for each situation are different.)
2. Know what events require an emergency variance.
Some breakdown events require that a variance be prepared and submitted in order to remain in compliance. Depending on the complexity of the operation and the business, this may even require the involvement of a lawyer, so make sure you’ve discussed such situations with your legal team so that you each understand when the variance will be needed and what information will be needed. You might even want to have a variance petition drafted ahead of time.
3. Be sure that upper management approves — ahead of time — any emergency procedures involved in an equipment breakdown.
Sometimes communications with a regulatory agency will need to be reviewed by the upper management ahead of time. If this is the case at your facility, be sure that upper management understands that there will be times where immediate notifications will need to be made to the agency. Have a plan in place so that you’re not asking for approval during a breakdown event.
4. Work with the regulatory agency to get feedback and buy-in on your breakdown procedure.
Getting feedback from the regulatory agency on your approach will not only show that you have systems in place to manage breakdowns, but it also increases rapport and communication between the agency and your facility.
5. Practice the response.
There is no doubt that practice makes perfect. So, once you have a plan laid out to respond to equipment breakdowns, practice until the response become second nature. Then practice again. And again.
You can’t foresee or prevent all breakdowns, but proper preparation can help mitigate the stress and damage they cause. So do your Boy Scout best and be prepared!