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August 6, 2018

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Emergency Preparedness

Avoiding the ‘Example Rule’ in Emergency Preparedness

Hannah Stewart from Pro-Sapien discusses emergency preparedness and ways safety managers can improve this.

As North America heads into the depths of hurricane season, it’s a good time as any to consider emergency preparedness and response to any disaster or accident that may occur.

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 organisations 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.”

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 organisations 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

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

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.

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