Emergency Response Planning
Your most effective approach to preventing or reducing the adverse impact of terrorist attacks and other disasters

Introduction

The tragic events of September 11, 2001, clearly demonstrate that terrorism and other catastrophic events can severely disrupt, damage or even destroy American businesses. One of the most prudent precautions a company can adopt to reduce the adverse impact of such events is the adoption of a well thought out emergency response plan that deals with a variety of emergencies, including the potential risk of terrorist attacks.

The PMA Insurance Group believes that taking steps to prepare your organization for a disaster, including possible terrorist or similar events, may reduce the potential adverse effects on your employees, business and operations if a disaster should occur. Although advance planning cannot prevent emergencies from occurring, it can reduce the resulting damage.

Experience has shown that actions taken during emergency situations are much more effective if planned in advance, because the longer it takes to react effectively, the greater the potential for loss. Indeed, organizations unfamiliar with proper emergency response procedures may inadvertently exacerbate already unfavorable situations. Consequently, we suggest that you periodically review and if necessary revise your existing emergency response plans. If your organization does not have a plan in place, you should begin to develop one immediately, both as a matter of business prudence and because emergency response plans are required by OSHA for most employers.

Emergency Response Plans - basic considerations

All emergency response plans ("ERPs") should address certain basic procedures which are needed to handle anticipated emergencies at your work site. Although ERPs are not meant to be all-inclusive, they should provide appropriate guidance on what to do in an emergency. A sound disaster response plan should include:

• Clearly written policies that designate a chain of command, listing names, duties and emergency contact information of people (or departments) who are responsible for making decisions, monitoring response actions and recovering back to normal operations.
• Names of those who are responsible for risk and damage assessment who should be notified for various types of emergencies.
• Facility evacuation procedures, including a designated meeting site outside the facility and a process to account for all employees after an evacuation.
• Specific instructions for shutting down critical operations, equipment, production processes and business activities.
• Specific training and practice schedules and equipment requirements for employees who are responsible for rescue operations, medical duties, hazardous responses, fire fighting and other responses specific to your work site.
• The preferred means of reporting fires and other emergencies.

Since your ERP should try to address all emergencies that can be reasonably expected to occur in your particular workplace, your company should perform a hazard assessment to determine what emergencies are likely to arise. In performing that evaluation, you should consider not only hazards that arise out of the type of business activities in which your company engages, but also whether other nearby facilities may pose a hazard. (For a list of nearby facilities' possible hazards, contact your local emergency response agency, which must provide such lists under the SARA Title III Act.)

Based on your hazard assessment, your ERP should then be written to contemplate how various emergency situations may affect your particular workplace, including consideration of floor plans or workplace maps that clearly show the emergency escape routes and safe areas.

Next, all employees must be told how to respond to these identified potential emergencies. Appropriate elements of the ERP should be reviewed with all employees when the ERP is adopted, when employees' responsibilities outlined in the plan change, and when the plan itself changes. A copy of the ERP should be kept in an easily accessible location that's convenient to all employees or, better yet, provided to each employee during training and new-employee orientations.

Emergency Response Plans - terrorism specific considerations

The risk of a terrorist attack is something that no company would have thought necessary to specifically address several months ago, but recent events have made it an appropriate consideration. Terrorism poses a special challenge in developing an ERP, because the risk of terrorism is so hard to evaluate. In the material that follows, we have tried to address items specific to terrorism that you may want to consider while reviewing or developing your plan.

Risk Evaluation: The first and possibly most difficult step in revising or developing your plan is to evaluate the risk that terrorist events may impact your organization. Though the nature of actual events is impossible to predict, certain types of operations, facilities and areas have already been identified as potentially more likely targets by terrorism experts. These include:

If your business involves an identified risk or is located near one or more of these identified risk areas, it is more likely to be involved in any additional terrorist incidents that take place, and you should take steps to mitigate the potential risk. (Again, for a list of nearby facilities containing possible hazards, contact your local emergency response agency, which must provide such lists under the SARA Title III Act.)

Even if your business is not one of the types specified, it still may be the subject of attack. Certain indicia which may indicate the appeal of given targets from a terrorist perspective include population density, ease of access, infrastructure criticality (to everyday life), access to hazardous substances, economic impact, and symbolic value. Evaluation of these indicia may assist you in determining the appropriate nature and extent of your preparations. For example, if your operations involve the use highly flammable or potentially toxic materials, you should ensure that there are adequate security measures and inventory control practices in place that would prevent terrorists from employing such materials in a terrorist attack.

Preparedness: After you have made your evaluation regarding the risk profile of your business with respect to terrorist attacks, you should determine what steps to take to protect your employees, business and operations from such attacks. Because of the unpredictable nature of terrorist attacks, you should try to make your plan as fluid and able to quickly adapt to emerging events such as mail-borne anthrax and other potential biological hazards as practicable. In effect, this will require you to revisit and possibly revise your plan whenever new information regarding terrorist strategies emerges; and whenever new procedures are implemented, they should be communicated to all affected
employees, and training should be considered to reinforce established procedures.

Some elements of an anti-terrorism response plan will remain constant. These include:

• Controlling visitor access to your building;
• Alerting employees to be conscious of and report all unfamiliar people or objects in and around your facility;
• Developing procedures for dealing with phoned in threats;
• Ensuring that all access points to your facility are secure and well lit; and
• Establishing and communicating procedures for contacting emergency authorities.

You should contact your local emergency management authorities to find out whether they have established procedures or recommendations for dealing with terrorist events. The Federal Bureau of Investigation (FBI), Center for Disease Control (CDC), United States Postal Service (USPS) as well as other federal agencies and local emergency response organizations are a good source for obtaining current information on dealing with emerging events. All of these organizations have web sites that are updated on a daily basis so the information available will berelevant to the situation at hand.

Response: Terrorist attacks can take many forms and your business may or may not receive advance warning. However, some warning signs that might (depending upon your workplace) warrant the implementation of your emergency response plan may include:

• The receipt of explicit threats;
• The presence of suspicious persons or vehicles;
• Low-lying clouds or fog unrelated to weather, or unusual fumes or odors;
• Unusual numbers of dead birds, insects or animals;
• Unusual metal debris, abandoned or unusual spraying devices, spent fuel canisters, or other suspicious assemblies;
• Sudden and unusual illnesses among employees in a particular location.

An appropriate response to terrorist events requires maintaining defined procedures for evacuation and notification of emergency management authorities. Wherever possible, actual mitigation of a terrorist event should be left to emergency responders; however, your employees may need to isolate or shut down critical operations, processes and building utilities in order to minimize the potential for further destruction or contamination.

Recovery: Cleanup and repair after a terrorist event will likely be a costly and time-consuming process. Maintaining and adhering to a well-developed contingency plan is the best way to minimize the damage caused by a terrorist attack.

Obviously, one of the main goals of any business following a terrorist attack or other disaster is the quick resumption of business operations. Three keys to quickly restoring business operations include making sure that:

• Vital business records are kept intact and damage-free, and that backup copies are readily available.
• Key production equipment is quickly restored or replaced.
• Alternate locations can be provided where operations can take place, if necessary.

In addition, businesses should develop plans for the recovery work that will be needed once the immediate crisis is over. Arrangements should be made with appraisers, vendors, contractors, and specialty equipment restorers for assessing damage to structures and assets, performing temporary repairs to structures, performing maintenance or salvage on exposed equipment, separating out damaged from undamaged goods, etc. Management should consider the possibility of having to move operations, equipment and supplies to temporary off-site storage or operating facilities in the event that extensive damage occurs.

Many decisions have to be made quickly, and the required personnel may not always be available when a crisis is occurring. Advance planning is necessary to make sure that nothing important is forgotten and that steps are done in priority order.

Conclusion and Additional Sources of Information

To many Americans, the workplace now seems more uncertain and frightening than it did prior to September 11, 2001. Employees look to their management for some reassurance that their workplace is safe. The best reassurance management can provide to their employees is a sense of preparedness for events that may occur. Good emergency response planning is the best way to convey that sense of preparedness.

Please contact your local PMA Risk Control Consultant if you would like assistance in developing or revising your plan or if you require guidance on procedures to deal with specific threats. You may also obtain information from the following web sites.

This bulletin was prepared as a customer service by The PMA Insurance Group - because it's that kind of relationship