Being Prepared! Being Responsive! - The auditing of emergency preparedness and response
By David Powley - DNV Certification

Gaining assurance of capability to manage emergency situations relating to undesired events has traditionally related to ‘the drill’ and how well it was conducted. David Powley of DNV Certification argues that although staged exercises and drills are important, they form only a part of a more holistic and reality-based approach that should be taken with regard to emergency situations. Based on experience, he offers a personal opinion and advice on how risk management principles and reality simulation should be used when auditing the regimes for emergency preparedness and response.

Organisations operating environmental management systems according to the international specification ISO 14001:2004 for environmental management systems (EMS) must attach importance to emergency preparedness and response (or EPAR). Clause 4.4.7 of the specification states “The organisation shall establish, implement and maintain procedures to identify potential emergency situations and potential accidents that can have an impact on the environment and how it will respond to them”. The specification goes on to say that these procedures should be periodically tested and reviewed according to the outcomes of tests as well as usage in real situations. The Chemical Industries Association, in concert with its European Federation CEFIC, has over the years developed and refined ‘Responsible Care’ for its subscribing members. This is a set of auditable elements within which are requirements for EPAR. In addition, the UK has significant legislation controlling the environment-risk industries, which gives pride of place to preparing for and reacting to emergency situations or undesired events. In the UK this includes the Control of Major Accidents and Hazards Regulations (1999) as well as the recognition given to EPAR in the Pollution Prevention and Control Act (1999) and in other circumstances the Environmental Protection Act (1990).

Thus far, both the internal and third party auditing of EPAR has been content to cover the mere availability of response regimes and that these are tested, often in a relaxed and non-threatened frame of mind. Is there a bigger picture? Is there a more systematic and realistic approach that could give more assurance? There is but it is worthwhile to firstly consider some principles.

Event risk (as opposed to condition risk) relates to:

a) The likelihood of the undesired event occurring and
b) The consequences of that undesired event occurring.

In addition, there are three qualitative requirement principles of the management of event risk. These are:

1.	Identify and assess the risk of undesired events. This should determine what events are likely, how likely (or foreseeable) the events are and finally what their consequences would be.
2.	Manage the risk of the events following a consideration of this risk assessment. This could mean a range of measures including hardware, software, systems, procedures and enhanced capability of people, put in place to minimise the likelihood of the event occurring and to mitigate the consequences should the event occur.
3.	Monitor the effectiveness of the management of the risk of the events. This is an overall consideration or review of the reliability and effectiveness of the measures mentioned in (2) in the light of experience gained through trial or reality and if necessary to re-evaluate the status of the risk assessment as provided by (1) and so on. The cycle could continue as appropriate (see Fig 1).

Although an auditor should cover the adequacy of the processes for risk assessment and monitoring of effectiveness of measures (principles 1 and 3 respectively), the focus for audit of EPAR should be the management of the risk. Within the management of event risk are the terms ‘preparedness’ and ‘response’ - these terms are significant, the former relating to controlling the likelihood and the latter being concerned with management of the consequences of the event (see Fig 1). The emphasis of the remainder of this article is on this aspect.

(In this article the term ‘event’ is used. Put simply this is the undesired situation which gives rise to the emergency. The identification of the potential event, its likelihood and possible consequences are determined at the risk assessment stage)

So how should an auditor react to all of this? Well, firstly a clear understanding of what constitutes preparedness and response would help. It is then a matter of adopting an audit approach to cover both of these equally important but separate aspects. Some example potential events may now be used to illustrate the auditing of preparedness and response. These are:

• A potential factory fire producing hazardous atmospheric combustion products.
• A potential road traffic accident involving a tanker carrying bulk hazardous fluid.
• A potential release of a pollutant to a natural watercourse.

Auditing emergency preparedness
Assuming that the auditor accepts the results of the risk assessment process and its comprehensiveness and that all possible undesired events are recognised, he would interrogate all that is in place to minimise the likelihood of the events. The activities and elements that an auditor could cover for the three potential events are given in table 1. Obviously this is a simplistic depiction to serve illustration. Other factors and circumstances may be appropriate depending on the situations.

Auditing emergency response
Again assuming the validity of the risk assessment, the auditor in this case would check whatever is in place to manage the consequences of the event should it occur. Table 2 presents the activities and elements that an auditor could cover for our three potential events. Once again, no apology is made for simplicity in this depiction.

Audit limitations
The auditing of emergency preparedness (EP) is relatively straightforward. An auditor checks that all is in place to lower the likelihood of an undesired event and in doing so looks for evidence of this usually by way of observation, interview and documentation. Little more can be done here. A similar approach is often taken for assessing emergency response (ER) e.g. the availability and integrity of devices and other hardware, the training, knowledge and awareness of people, the improvements arising from the report of the emergency drill etc. This is fine but the problem here is that one cannot truly assess how they will all work together in concert and in a real situation, or ‘under fire’ - so to speak. For example, personnel cannot really feel ‘under fire’ in the knowledge that they are involved in a drill. Introduction of some reality would give more assurance of responsiveness. The following very brief description of a simulation may encourage more thought in the auditing of ER.

An EMS audit case study for ER
One of the significant environmental aspects of an Argentine oil and gas operator was discharge of hydrocarbon fluid, into a fast flowing river, resulting from sudden leakage from an under-river transport pipe. The transport pipe was encased in a concentric pipe and the volume between them was accurately pressurised with nitrogen gas. The fluid leak detection system consisted of a sensitive pressure differential measuring device which monitored increases in gas pressure which denoted a fluid leak. The output measurement of the device was at a Telemetry room some 10km away. This pipe and its associated pumping station were periodically inspected through the day along with other oil field installations. Communications within the whole field were by radio.

An ISO 14001 audit was performed at the field and the audit team decided to test ER capability by introducing as much reality as possible. This was done by firstly seeking the approval and secrecy of the management and a few selected individuals to assist in the exercise. The idea was then to adjust the detection system at the river crossing such that the hardware, software and people were ‘fooled’ into believing that there was a real fluid leak. The 2-person audit team split such that one auditor was located in the field close to the river crossing and the other in the Telemetry room. The watches of the audit team were synchronised. The respective duties of the two auditors included but were not limited to the following:

Auditor in the field: Supervise the tamper of the detection system, listen to the radio traffic, note the time of arrival of an inspector, note the time the pump was turned off.

Auditor in the Telemetry room: Observe the screen indicators, the screen alarms, the audible alarms, listen to the radio traffic, note the time of instruction to turn off the pump, observe the mobilisation of the emergency plan.
Following the exercise the auditors met to discuss and compare all times and observations and come to a conclusion on the ER capability.

This exercise was as real as possible. The personnel involved thought that this was an emergency situation and at no time suspected another drill. Furthermore it tested how the people, software, hardware and people worked together ‘under fire’. In this particular example the organisation performed well.

Using this approach may be controversial for understandable reasons. It requires commitment and co-operation from the management of a company and not all companies have a culture that would condone, let alone facilitate it. However, once an exercise of this nature is completed, the audit team is usually appreciated whether good or bad performance is observed – particularly in the case of the latter.

In summary, emergency preparedness and response represent important lines of defence in event risk and the auditing of it should be inclusive so as to incorporate minimisation of likelihood and management of consequences. Furthermore, the audit process should incorporate simulation with as much reality as possible such that there is an evaluation of systems and people ‘under fire’. In this way, almost all deficiencies are detected with negligible or no loss.

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