“Give me six hours to chop down a tree and I will spend the first four sharpening the axe.”
The (Often Unsung) Heroes
When it comes to risk-based planning in a community, emergency managers weigh the likelihood of the threat verses the potential for harm to the environment and human life. Certain threats may pose significant potential for loss to life and property but may have such a small likelihood of occurring that it is simply not worth spending the resources to prepare for that specific threat (e.g., nuclear disaster). Communities face different threats depending on geographic location, major industries, climate, or proximity to neighboring countries. However, there is one common threat facing all communities in the country: Hazardous materials (Hazmat) releases.
The (often unsung) heroes working to prepare our communities across America for Hazmat incidents are members of the Local Emergency Planning Committee (LEPC). To combat the growing threat of Hazmat incidents in the U.S., Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986. The EPCRA required each state to form a State Emergency Response Commission (SERC) to enforce the requirements of the EPCRA in their respective states. Each SERC determined the best way to divide the state into LEPCs, giving each LEPC the responsibility of building Hazmat preparedness and response capabilities in their communities.
You don’t have to look far for case studies of Hazmat incidents and how they affect communities. The recent fire at the Chemtool Hazmat facility in Rockton, Ill. on June 14th is a good example of how residents, businesses, first responders and neighboring cities are all impacted by one Hazmat incident. With billowing smoke rising into the air from the chemical plant, first responders quickly evacuated everyone within a 1-mile radius of the facility due to the potential for Hazmat being released into the air. Schools were used as evacuation centers. One Hazmat incident put life, work, and school on hold for thousands and the lives of first responders in danger.
More recently, the impact on the environment and communities quickly became apparent after Hurricane Ida swept through Louisiana. An Exxon Mobile Corp. refinery in Baton Rouge released sulfer dioxide and hydrogen sulfide as Ida charged through. A broken pipeline poured crude oil near a bayou that flows into the Gulf of Mexico. In some areas, chemicals mixed with raw sewage released from chemical treatment plants that lost power. Wilma Subra, an environmental scientist with the Louisiana Environmental Action Network, was quoted saying, “We are totally not prepared for these types of events. We should be, however we are not.” One major natural disaster caused a chain reaction of Hazmat incidents across multiple communities. The stakes are high and far reaching.
As LEPCs have been working hard to “sharpen the axe” in preparation for potential Hazmat incidents through the years, many have faced significant challenges. In this blog, we highlight four challenges facing LEPCs with recommendations to follow as they work to build sustainable preparedness capabilities in their communities.
4 Challenges Facing LEPCs
1. Key Stakeholder (un)Involvement
LEPCs are meant to represent the community and involve key stakeholders from both the private and public sectors. However, LEPCs get more involvement from the public sector players (elected officials, Police Chief, Fire Chief, etc.) while many private sector businesses opt out. If a facility is classified as an EHS facility (storing Extremely Hazardous Substances in quantities greater than the corresponding threshold planning quantities), they are required to participate in emergency planning. This is accomplished by participating with the LEPC in the planning processes to provide information about their on-site resources, ensure they know what to do in case of an accidental release, have clear communication channels with Emergency Responders, and have sufficient on-site resources for initial response in case of an incident. LEPCs should gather this information from EHS facilities and develop pre-incident action plans to enhance responder situational awareness.
2. Outdated Plans
LEPCs are required to develop Hazmat Emergency Response Plans (ERPs) for their communities and update them annually. With the passing of the America’s Water Infrastructure Act (AWIA) of 2018, the EPCRA requirements were amended to include planning for Hazmat risks to drinking water sources. However, in our years of working with Emergency Managers and LEPCs, we have seen that community preparedness plans like the Hazmat ERP, Evacuation Plans, Hazmat Shelter-in-Place Plans, and Pre-incident Fire Plans (to name a few) are either outdated or lack sufficient detail to be effective. This is often due to a shortage of human and/or financial resources needed to maintain and annually update the required plans. Personnel turnover and transitions in leadership across the various industries are also contributing factors. LEPCs generally meet monthly or quarterly, and receive Tier II reports from EHS facilities in the Spring of each year. This is the optimal time to begin updating LEPC ERPs with current hazard information.
3. Where to Begin?
Many LEPCs struggle to know where to begin in the planning process or are overwhelmed by the scope of the EPCRA requirements, especially in larger regions/communities with more EHS facilities. These LEPCs tend to have outdated plans and lack the human resources to effectively tackle the process of revising the plans and encouraging new stakeholder involvement in the planning process. A thorough Hazard Risk Assessment is required to identify and prioritize EHS facilities and their associated hazards in the community. An updated ERP will provide a roadmap to preventing, mitigating, responding, and recovering from hazmat incidents, responder roles, resources from among the whole community, and procedures to execute the plan. Many LEPCs leverage the expertise and experience of emergency management consultants to enhance their risk analysis and improve their planning to include increasing stakeholder participation. This can be funded through PHMSA HMEP grants which are widely available through subawards from the State or Territory’s Hazmat grant manager.
4. Lack of Drills and Exercises
Henry Ford once said, “If everyone is moving forward together, then success takes care of itself.” LEPCs that train together will build trust, and that trust will lead to community-wide resilience. If training and drills that include both public and private sectors do not exist within a community, there is no platform to practice navigating high-stress incidents while collaborating with multiple parties. This is essential to managing a Hazmat incident efficiently. A great way to facilitate building trust within an LEPC is to run a Tabletop Exercise (TTX) each year to ensure all key stakeholders understand how to use the ERP, their roles and responsibilities, and what to do if a Hazmat incident happens at their facility or elsewhere in their community. Drills and exercises also reveal areas of improvement that the LEPC can address over the next year. If your LEPC hasn’t implemented an annual drill or exercise program to validate your updated ERP, now is the perfect time to start. Documentation of the annual training and exercise program is a required element of the ERP.
For LEPCs that experience some of these challenges, we encourage you to begin “sharpening the axe” and building a culture of preparedness in your communities that will last by implementing the recommendations listed under each challenge.
ASG has been at the forefront of building community-wide emergency preparedness capabilities for over 16 years, having conducted over 85 all-hazards, risk-based emergency response plans for organizations and communities around the globe. ASG has supported LEPCs through developing and implementing Hazmat ERPs. This process results in increased engagement with public and private stakeholders. By conducting the annual updates, we are able to continuously improve preparedness and establish LEPC goals for outreach and enhancing resilience. These efforts have helped LEPCs update their ERPs to comply with the new AWIA requirements and formulate strategies for ensuring the protection of vulnerable and underserved populations.
For a practical next step, we recommend all stakeholders in LEPCs take our Whole Community Engagement for Hazmat Planning course. We can provide the course through an in-person, live (virtual webinar) or online (flexible delivery through our online learning management system). We can provide customized pricing options based on your LEPC or state’s needs.
Here is what recent participants in this live webinar shared:
“Course was informative and well written considering the online application”
“Great course. I am going to recommend we get you to provide this course in other states”
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