As North America heads into the depths of hurricane season, it’s a good time to consider emergency preparedness and response. In the wake of Harvey, Irma and Maria in 2017 thousands of emergency plans were put to the test across the southeast US and Caribbean, as the region experienced some of its strongest hurricanes ever recorded. However, psychology suggests that as time goes by, we may again underestimate the risk of such a catastrophe recurring.
Our perception of risk is a funny thing. Before September 2017, the Atlantic hadn’t seen such a weather alignment since twelve years prior, so you’d be forgiven for thinking it was unexpected. But risk managers know otherwise: that in fact, the risk had been building for some time.
Emergency preparedness is a diverse field that EHS managers are often responsible for, but struggle to find time for. To understand a bit more about why natural disasters catch us off-guard, and thus inform how we may better prepare, we can draw some insight from some psychology.
The Example Rule – our perception of risk
After a major earthquake in, say, California, sales of earthquake insurance surge. Over time investment drops off as the effects of the natural disaster become a distant memory. Simultaneously but contrastingly, after a major earthquake the chances of another occurring drops way down; and over time it gradually increases again. How easy something is to recall affects how our brains perceive the risk of repeat today – this is called the Example Rule and it’s something that many businesses across the southern United States perhaps felt the consequences of in September 2017.
The Example Rule is the theory that the easier someone can think of examples of something, the more common they judge that thing to be. Therefore, as time marches on, it is easy to underestimate the importance of having an up to date emergency plan for natural disasters.
Insurance company FM Global carried out a survey to assess the impact of recent hurricanes on companies with operations in Texas, Florida or Puerto Rico. The results support the hypothesis of the Example Rule. Of those impacted, 62% admitted they were “not completely prepared” to deal with the effects. Other conclusions include:
- 68% of respondents expect to make changes to their risk management strategy
- 57% of those affected by Harvey, Irma and Maria say they will put in place or enhance disaster recovery plans
The next test will be whether these organizations are still investing in risk management and emergency preparedness in another twelve years’ time.
Perception of workplace EHS risk also reduces over time
And it’s not just large-scale events that are affected by the Example Rule. EHS managers, including Industrial Safety Manager at the US Army David W. Folk Ph.D, report that following an incident, safety suddenly becomes the primary focus of everyone – before complacency creeps back in after several months.
“In all my years of private industry and enforcement experience, no employer has been able to maintain the accident prevention efforts trend at the peak level found immediately following a major accident. However, with the knowledge that this gradual decline is inevitable, the safety professional should strive to obtain top management's commitment to maintaining a level of accident prevention efforts just below the peak performance level.” – David W. Folk, Ph.D on OHS Online
Folk recommends adopting an aviation pilot’s mindset in order to sustain a high level of dedication to safety, learning from an industry we’ve written about in the past as being a strong example of safety standards.
Preparing for emergencies is not achieved overnight
Exxon Mobil, Shell and Anadarko Petroleum all shut operations and evacuated offshore production platforms in the Gulf of Mexico in preparation for Harvey at least 24 hours before the storm was due.
However, especially in organizations with mid- to high-risk operations such as Oil & Gas, preparing for emergencies is something that starts long before the emergency is on the horizon.
The Example Rule at Arkema in Crosby, Texas
An August hurricane in Texas is not necessarily a surprise – it was the flooding that caught Texans off-guard in 2017, especially in the city of Houston. The head of FEMA, Brock Long, described the devastating impact of Harvey as something unprecedented that we “could not draw [up]”. In just one example, a series of explosions were set into motion by flooding at a chemical plant owned by Arkema, previously identified as one of the most hazardous in the state.
In Crosby, Arkema did not “anticipate having six feet of water in our plant,” resulting in the failure of refrigerators that kept chemicals cool and stable. In the days following, questions were raised over whether Arkema could have done more to prevent the blasts that produced harmful smoke sending 15 safety officers to hospital.
Companies certainly can’t put countermeasures in for everything, and some level of risk must be tolerated. However, taking heed of risk assessment findings is a sensible response, and one that may have prevented the explosions in Crosby. An investigation by the Chemical Safety Board found that Arkema did “not document any flooding risk” in their assessments of the area where chemicals were stored. And again, unfortunately, we see the Example Rule at play:
“Although the Arkema Crosby facility had a history of flooding over the past 40 years, long-term employees could not recall floodwater occurring higher than two feet before Hurricane Harvey. As a result, Arkema did not consider flooding of its safety systems to be a credible risk,” – Organic Peroxide Decomposition, Release, and Fire at Arkema Crosby Following Hurricane Harvey Flooding, CSB (2018)
Harnessing a combination of data sources
Ultimately, how you prepare for an emergency will influence the effectiveness of your response. Being ready involves knowing the risks onsite, which can be achieved through proper management of Safety Data Sheets (SDSs), Risk Assessments, and Inspections. Information gathered from incident investigations and safety observations may also be useful in informing EHS managers on what to expect in emergency circumstances.
Safety Data Sheets
Safety Data Sheets are a good starting point for an entire EHS program, providing information on the various chemicals present onsite.
Having SDSs stored online within a resource that can be accessed at remote locations is crucial as company locations may become inaccessible during an emergency. With a searchable library you will be able to provide emergency responders the information they need in a timely manner.
However, SDSs can be very complex documents traditionally made for occupational hygienists. Maintaining an SDS dashboard that shows pertinent information in columns is a simple way of giving users the information they need in an emergency, fast.
Risk Assessments should also be used to inform your emergency preparations. There are various types of assessment, including Job Safety Analyses (JSAs) which are task-based; organizational Risk Assessments reviewing overall operations; and Vulnerability Assessments which focus on the impact that an event, typically an emergency, would have on the business.
Keeping track of the Risk Assessments that have been carried out across your sites is essential for effective emergency preparedness. Understanding the hazards present – including those posed by chemicals as detailed by SDSs – will influence what actions are taken in an emergency.
For example, in the case of Arkema at Crosby, workers knew to bring organic peroxides from the warehouse into refrigerated trailers to be moved to a high elevation area. However, some trailers were unable to be moved thus they eventually became flooded and failing. This may have been avoided had the company conducted more extensive risk assessments and follow ups after their insurance company flagged a flood risk in 2016.
Collecting information such as nonconformances, concerns of workers and evaluating the effectiveness of safety practice through workplace inspections is another part of the emergency preparedness puzzle.
An inspection will collect information such as an accurate diagram of the area, equipment inventory, chemical inventory, and ensuring that all hazardous products are labelled appropriately according to WHMIS requirements. This knowledge should be recorded electronically and is pertinent for both emergency planning and response.
Getting creative with Murphy’s Law
Remember Murphy’s law? What can go wrong, will go wrong. It’s a fool-proof driver of emergency preparedness.
In that respect, harnessing the creative minds of workers by getting them to come up with disaster scenarios can be extremely valuable – some ideas may be downright crazy, but that’s part of the fun; others will be worth planning for.
All in all, preparing for emergencies requires a combination of data from various sources and is something that should be revisited regularly. Although disruptive, you may also consider organizing drills which will certainly help instill emergency procedures into everyone’s brains and stave off the effects of the Example Rule.
Emergency response and communicating the right information
The response to hurricanes Harvey, Irma and Maria was an impressive coordination of agencies, businesses and civilians.
In responding to an emergency, organizations will feel the effectiveness of their preparations. Although the EPA has mobile assets to gather data post-disaster, for example ASPECT, PHILIS, and TAGA, the information that businesses can provide about site hazards is golden. Have chemicals been labelled properly? Were appropriate hazard controls put in place before the disaster? Were corrective actions fulfilled from the most recent site inspection? All providing helpful pointers on how to respond.
Lessons from Katrina and even more from 2017
The journey of emergency management has been a reactive one. There have been numerous events throughout history that have advanced our efforts to control risk and respond to disaster. The National Response Framework (US) was established in 2008 following a series of disasters – operating on the premise that effective incident response is the shared responsibility of government, the private sector, NGOs and citizens.
With every catastrophic event comes lessons, and we will never stop learning. Those responding to US hurricanes in 2017 were able to draw upon the country’s previous experience of Hurricane Katrina, with improvements such as:
- Better plans and more training
- Coordination of federal and local responders, now working off the same guidelines
- Preplanning and stocking of emergency supplies
- Actively enlisting the public’s help
From Irma, one aviation specialist analyzing the response highlights the value of both old and new technology: in Florida, cell towers were out of service with many emergency responders left without the means for quick communication, but landlines in the Keys continued to work, and walkie talkies alike. On the other hand, drones were used by Oil & Gas and Railroad companies to spot damage to structures. Considering these types of tech could help your organization better cope with disaster.
Emergency preparedness takes a lot of time and effort and relies on communication between several parties within and external to the business. Therefore, planning and response is largely underpinned by a robust EHS software platform that houses relevant, up to date information in one place.
Most EHS solutions today provide functionality for Risk Assessment, Inspections, Safety Data Sheets, Incidents and Safety Observations, as well as for task management and business intelligence reporting, which are all extremely helpful for effective planning.
As the depths of hurricane season are upon us, now is a topical time to make sure you have emergency plans in place – but preparedness should start long before it’s required in order to prove the Example Rule wrong.