Prior to conducting an oil transfer operation, the driver must be confident that, in the event of an incident, appropriate actions will occur.
A contingency plan prescribes specific actions to be taken in the event of accidental discharges and is essential for an efficient and effective response. Such a response is intended to safeguard human health, the environment and property, in that order. A contingency plan should be backed up by a clear Company policy statement of the actions the company will commit to in the event of an emergency.
A contingency plan is of particular importance during truck to vessel oil transfers because the driver may:
- Not have local knowledge of the environmental, recreational and other resources at risk
- Not have local knowledge of available help, both manpower and equipment
- Be entirely reliant upon a third party for provision and deployment of countermeasures equipment
- Not have an adequate number of staff for assistance and there may be limited alternate personnel available in isolated areas
- After a spill, regulators will focus not only on the cause and impacts of the spill but also on the reactions of the responsible party. A functioning contingency plan will effect a good response and, in turn, help establish due diligence.
Communication with Company management, off-site resources and regulatory agencies must be maintained. These lines of communication must be available at all times throughout the oil transfer operation. Trucks should have portable telephones or radios.
All electrical equipment used in hazardous areas must meet appropriate safety requirements.
10.2 Initial Steps
The contingency plan must include a brief listing of the first steps to be taken in the event of a spill or other emergency. The focus of these steps should be:
- Personal safety
- Stopping the flow of oil
- Protection of the environment
- Containment and recovery of the spilled product
10.3 Notification Requirements
Notification plans must include:
- Statutory requirements
- Marine Communication & Traffic Services (MCTS), formerly VTS, 1 800 889-8852.
- Provincial Emergency Program in B.C. at 1 800 663-3456.
- Appropriate contact numbers for other jurisdictions.
- Municipal responders, e.g. Fire Departments etc.
- Internal reporting and notification to your own company management
- Call-out of pre-arranged resources, both personnel and equipment
The local Harbor Master, Wharfinger and Fisheries Officer should also be contacted as they may be able to coordinate local resources for an immediate response.
10.4 Contact Lists
Contact lists to support the above notification plans must be:
- Comprehensive, providing 24 hour contact numbers
- Up-to-date information. Amended, at least, annually
- Tested regularly enough so that notification plan will reach the proper parties.
10.5 Equipment Lists
Equipment lists will provide information on what equipment is available, where it is located, and how to access and transport the equipment to the site. The lists will include the following:
- Local equipment depots
- Industry depots, if available
- Company equipment
- Other equipment sources
10.6 On-Site Response Equipment
Equipment available on site during the transfer, as a minimum, must include the equipment required by CPPI The Petroleum Products Professional Driver's Manual. Additional equipment should be on hand depending on the specifics of the operation, taking into consideration factors such as size of the transfer, remoteness of the location, etc. The amount of equipment is to be commensurate with the risk associated with this activity and is necessary to ensure that an appropriate response can be conducted.
All drivers and appropriate company personnel must be trained in emergency response procedures. The training must be adequate to provide them with the skills necessary to execute those portions of the contingency plan for which they are responsible. These might include:
- Notification and callout procedures
- Emergency shut-down procedures
- Fire prevention and fire-fighting
- Spill containment and cleanup
- Use of personal protective equipment
Exercising a contingency plan is the only way that any problems with the plan or its implementation can be identified. The plan should be exercised at least once each year. The exercise should be documented, along with all problems identified, lessons learned and solutions. Required modifications to the plan should be made immediately.
There are a number of documents available to assist in the development of a contingency plan.
- Emergency Planning for Industry - A National Standard for Canada (CAN/CSA-Z731 - M91) is available from the Canadian Standards Association.
- Guidelines for Industry Emergency Response Contingency Plans (ISBN 0-7726-1539-X) can be obtained, free of charge, from the B.C. Ministry of Environment, Lands and Parks.
As well, the B.C. Coastal Marina Facility and Operating Standards is a document intended to aid in the design and operation of land-based marina installations. It's contingency planning section may be helpful in designing a plan for mobile operations, see Appendix B at the end of this document.
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