Undivided attention

 

 

“Educate and inform the whole mass of the people. . . they are the only sure reliance for the preservation of our liberty.”

 

In large organisations it is easy for emergency planning to look good on paper but perform badly when tested in a real-life practical situation, often, in part, as a result of insufficient education and information provided for the workforce. The above quote from US politician Thomas Jefferson is therefore equally apt in describing the foundations for effective emergency planning and response — although, for “liberty”, substitute “lives”.

 

The law

 

The legal requirements for the production of on-site and off-site emergency plans for major-hazard sites are laid down in the Control of Major Accident Hazards Regulations 1999 (COMAH). These regulations, accompanied by extensive HSE guidance, specify exactly what an operator should do both on and off site. Of course, COMAH is, by its nature, site-specific. So, what of the vast majority of work activities that are not covered by these regulations and are enforced less strictly?

 

The Management of Health and Safety at Work Regulations (MHSWR) 1999 require duty-holders to establish and, where necessary, give effect to appropriate procedures to be followed in the event of serious and imminent danger to persons at work in their undertaking. In our experience, where an organisation’s undertaking is generally perceived to be low-risk and that organisation has an excellent safety record, it is easy for such procedures to gather dust on a shelf without regular testing, or review. While those named in procedures (whether by role, or otherwise) may understand what is required, it may be that they operate in silos without clear direction as to when they should act, or who takes the lead in the event of an incident.

 

Why integration?

 

It is often the case that first-aid, fire and spill teams are trained separately, with little or no knowledge of the other roles that constitute the life-safety programme for an organisation. This is reasonably understandable, as the skills for each role can vary greatly and often involve different training providers. 

 

When a life-safety incident requires the attention of more than one skills set, the importance of a cohesive and integrated response comes to the fore, in order to prevent escalation to a serious emergency event. Take the example of a chemical spill where an injured employee is in need of first aid: who is in control of the scene — the first-aider, or spill-team member(s)? Who is in control of the rest of the premises? What, if anything, is happening with regard to any liquid spillage that may have travelled further down the site?

 

Very quickly, an incident can impact on several elements, and, consequently, this can lead to involvement from multiple parties. In such a situation, should individual teams proceed without an integrated approach, the overall severity of risk increases. This leads to confusion and potential life-safety risks to both the victim and response teams. The solution is to combine all individual teams into one life-safety team, but effective integration will rely on three aspects: volunteers; communication; and the command and control structure.

 

 

When looking at life safety for business, employers are generally grateful for a list of employees who offer to volunteer to attend a first-aid, fire-warden, or spill-response course.

 

It is difficult to understand always the motivations of those who volunteer; for some, it will be to learn a life skill, while others may view it as a convenient distraction from ‘normal’ work. Unfortunately, it is often the case that those tasked with attendance on such courses are those who have been “volunteered” by their manager. A final group are those who have watched too many movies and fancy themselves as Bruce Willis — the ‘action hero’ sub-group.

 

Understanding the motivation of each volunteer is important in designing the initial training to engage with the attendees and to emphasise the need for a holistic approach.

 

When trying to integrate volunteers into one team some important practical and behavioural aspects should be considered: are all the volunteers familiar with the premises? Do you have enough volunteers to cover different shift patterns and locations? It is also worth considering that some volunteers may be from different hierarchical positions and, at the scene of the incident, the highest-ranking manager may not be the right person to lead the scene from a practical-skills point of view. 

 

When recruiting for volunteers for each element of life safety, ensure that the volunteer has an understanding of the potential types of scenarios they may encounter. A group discussion with a representative of each part of the life-safety team is advisable for “new recruits”. It is important to communicate to volunteers that their ‘normal’ role in the organisation has no bearing on the command and control of the scene, as this is governed by skill, and not rank. Finally, remove ‘action heroes’ from the team — there is no place for these dangerous risk-takers. Be on the lookout for those who demonstrate these characteristics in drills and live scenarios.

 

 

Communication is a critical factor throughout, from how the incident is initiated to post-incident analysis. Organisations will have problems when life-safety teams have only isolated methods of communication at their disposal. This means good protocols need to be put in place long before an incident occurs.

 

For instance, imagine a scenario in which contractors are attending a large site to carry out cleaning using solvents and acids, which they bring on site with them. The local contract manager is aware of the substances being used but does not communicate this more widely. After a day or two, there is an incident involving hot work, which creates a small fire near where the contractors are working. An incident team attends the scene but, because the team has no foreknowledge of the chemicals, they cannot respond properly — and may, in fact, put themselves and others in danger.

 

First-aiders and spill-responders are called to the scene to make one of two choices: to treat the victim/spill, or to escalate the incident to the emergency services.

 

Isolated communication channels give rise to the risk of common oversight and lack of governance on decisions made at the scene, which can result in:

 

It is vital that the whole team is continuously aware of each other’s presence, requirements and any decision to escalate, or stand down. A good way to achieve this is for all members to carry a two-way radio and to have received training in its use. While this is likely to be the most expensive solution, it minimises the risk of untimely or inaccurate communication, which can be surprisingly common during live training scenarios and real events.

 

 

An incident controller should establish control of the premises as an incident unfolds. Normally, this person remains at the hub of communications for the organisation — i.e. a security gatehouse or reception, where any call to the emergency services is made. This is a role for an experienced member of the life-safety team and someone who can process the information from the scene, while simultaneously looking to the horizon for site challenges and solutions.

 

Introduce a hierarchy of reporting, whereby the scene controller reports to the incident controller in order to explain the planned response and the relevant resource requirements. Where there is more than one incident, or numerous casualties, the first-aider should never be the scene controller. More than one scene controller will be required where there are disparate parts of the premises involved in one incident pattern. Again, in this situation, each scene controller will need to liaise with the other(s). 

 

First-aiders should be reliant on advice from fire wardens/spill-responders as to when they can attend to casualties. The risk of responders getting into trouble themselves is not uncommon and has resulted in some tragic cases.

 

In addition to effective integration, there are some other key points that an organisation should consider — notably, training provision, regular review of the planning procedures, and dealing with the aftermath of an incident.

 

 

In a multi-disciplined life-safety team, initial and refresher training — in both theory and practical knowledge — are vital to ensure competency of skills and confidence in response.

 

A ready-made course for your organisation is unlikely to exist and on-site bespoke training should only be provided following an audit, so that the site risks can be properly reflected during the instruction. If using different providers for training and audit work, it is advisable to hold an in-house group session to instil your own arrangements for life safety and not those perceived as fit for purpose by a remote, contracted training provider.

 

Ensure all elements fit neatly together. Training may start as a classroom exercise and move into ‘live’, controlled-scenario training. This enables a team to test vital elements, such as PPE placement across the organisation, expected response times, and to experience the pressures of a real situation.

 

Training should be refreshed at regular intervals and scenarios should vary on each occasion, based on a risk-based approach, to give staff the best chance of familiarising themselves with a situation in ‘safe’ conditions.

 

 

If a life-safety programme does include a command structure for managing the on-site response, it is vital that key personnel are identified by name and that the plan is regularly reviewed to remain up-to-date, as employees change jobs, or leave companies altogether. Indeed, there have been situations in which either virtually all of the persons identified in a plan have moved on, or mobile telephone numbers no longer work: the aftermath of a major incident is not a good time to find this out!

 

Also, consider some of the more pragmatic issues: does the security hut contain a mobile-phone charger, for instance? Many people rely on modern smart phones to keep all their important contact details, but batteries drain quickly.

 

 

When the incident is serious it is inevitable there will be, at the very least, an internal investigation that may or may not be instructed by external legal counsel. There may also be a regulatory investigation led by either the Police, Environment Agency, HSE, or a Local Authority, depending on the type/location and severity of the incident.

 

While the preservation of life is obviously the most important priority in any scenario, it is wise to explain to the life-safety team after an incident that they will likely be required to assist the investigation by describing what they saw when they attended the scene and what they did when they dealt with the situation. Such ‘first person’ accounts can be of vital use to any investigator in trying to understand what happened.

 

 

The lengths to which some workers go to create risks should also not be overlooked. For instance, to minimise dust, dry sweeping is banned in certain industries, with some companies prohibiting the use of sweeping brushes. As a result, some workers may bring in their own domestic stiff brush to by-pass the system.

 

 

Integration of skills to form a single life-safety team is the most effective method to deal with life-threatening events. An isolated approach can not only present harm to individuals involved, but could lead to an escalation of the event and unnecessary damage to the wider organisation. 

 

Although there may be internal resistance to the group sessions necessary to ensure the team can function, as well as the introduction of an incident controller and the cost of new communication tools, the benefits of working together will soon be realised and will, in turn, increase the effectiveness of the organisation should the worst happen.

 

Reference

 

1 See also: Spillage could have ignited during recovery process and Coordination and communication absent in toxic gas fatality

 

 

Chris Lea is senior group leader for H, S and E at UCB Pharma, and Paul Verrico is a principal associate in the Eversheds litigation team.