Environmental Emergency Regulations, 2019: Environmental emergency plan simulation exercises
The Environmental Emergency Regulations, 2019 require that a facility prepare and exercise an environmental emergency plan (E2 Plan). The E2 Plan must be created within six months, and implemented within one year of the facility becoming subject to the Regulations. The first annual simulation exercise must be completed within the first year of the E2 Plan implementation.
What are the different types of E2 Plan exercises
There are two main types of simulation exercises: the annual simulation which is administrative in nature, and the full-scale simulation which is action-based and must occur within five years of the E2 Plan implementation. All exercises must be site-specific and follow specific criteria depending on the type of exercise.
Annual simulation exercise – This is an exercise that simulates the response to an environmental emergency that involves the release of one Schedule 1 substance from each of the hazard categories present at the facility. Examples that fulfill the requirements include:
- Drills – These are supervised activities that allow emergency response team members to validate a specific operation or function, usually focused on one or two key skills such as shutdown procedures or valve operation. Drills can also be used to determine if plans can be executed as designed, to assess whether more training is required, or to reinforce best practices.
- Tabletop exercises – This type of exercise is presented by a facilitator in an informal setting with no hands-on practice or fieldwork. This type of exercise is intended to generate discussion about various issues regarding a hypothetical, simulated emergency. Tabletop exercises can boost general awareness, validate plans and procedures, rehearse concepts, and/or assess the types of systems needed to guide the prevention of, protection from, mitigation of, response to, and recovery from a defined incident.
- Functional exercises – These exercises provide a more realistic simulation of an emergency compared to a tabletop exercise. They are typically conducted in “real-time” in a classroom setting or a designated site for a Command Post. The Command Post Team “takes action” – making decisions, simulating the deployment of resources, and responding to new developments. In comparison to a full-scale exercise, a functional exercise involves fewer participants and the movement of personnel and equipment is simulated.
Full-Scale simulation exercise – This is an action-based simulation exercise requiring the deployment of personnel, resources and equipment. The scenario must involve at least one Schedule 1 substance located at the facility. Full-scale exercises are typically the most complex and resource-intensive because they are staged in a realistic field environment with equipment deployment and involve many participants performing assigned tasks in real-time. Full-scale exercises give the team an opportunity to practice and validate their plans, policies, and a wide variety of the skills covered in response team training. Volunteers may play the role of victims and mock injuries can be staged. These exercises may involve other agencies, although role-players representing other agencies can be used if desired.
When must the E2 Plan be exercised
Annual simulation exercise
- The first annual simulation exercise must be completed within one year of the E2 Plan being brought into effect (as per Section 6 & 7(1)(a))
- For an annual simulation exercise, if your facility has Schedule 1 substances from more than one of the six hazard categories, you must simulate one environmental emergency from each hazard category. For example, if you have substances from three hazard categories, you must test all three during the annual simulation exercise
- If your facility has more than one Schedule 1 substance from the same hazard category, you must simulate one environmental emergency identified in the E2 Plan for one substance in that hazard category. A different substance should be selected each year
- The E2 Plan must then be exercised at least once every 365 days from the day the plan was brought into effect. A different environmental emergency scenario must be exercised each subsequent year so that all of the environmental emergencies identified in the E2 Plan have been simulated
- Notices are not required for annual simulations, however, records need to be maintained at the facility for the previous seven years starting from the day the Regulations apply to a facility
Full-Scale simulation exercise
- A full-scale simulation involving deployment of equipment and resources must be completed within five years of the E2 Plan being brought into effect (as per Section 7(1)(b)
- Only one Schedule 1 substance at the facility is required to be part of the full-scale simulation exercise. This substance can be from any of the six hazard categories
- Once the full-scale exercise is completed, a Notice Regarding Simulation Exercises Conducted in Relation to an E2 Plan (Schedule 5) must be submitted
- The annual simulation exercise is not required in the same year a full-scale simulation is conducted
When should the E2 Plan be updated
The E2 Plan must be reviewed annually to determine its effectiveness and updated to address any shortcomings or update information (as per Section 10). The lessons learned during E2 Plan exercises should result in regular plan updates and improvement.
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