Organisations need to know there is a consistent high level of Incident Management Team (IMT) capability in place, ready to respond should an emergency situation occur on site. The link between a successful tactical-level response and positive outcomes for the organisation is easy to see. Rapid action to protect people, environment and assets is vital if the organisation is to fully recover. The case for a well-trained and regularly exercised IMT is therefore not only made in terms of meeting regulatory requirements but also in terms of commercial priorities. A demonstrably effective IMT, with a systematic and auditable approach to training and competence assurance, should be sufficient to address the question of regulatory compliance. However, the case for investing in training and exercises is strengthened when you consider the cost of a poor emergency response that could lead to damaged plant and equipment, costly repairs, lengthy recommissioning, and potentially losing business to competitors whilst the plant is inoperable. And that’s not to mention the negative impact on reputation.
The requirements of the Control Of Major Hazards (2015) Regulations are clear. Organisations need to have nominated personnel in place with the overall responsibility for directing operations if an emergency situation occurs on site. Managing an emergency on a complex COMAH site is a broad remit and is usually most effectively delivered in practice by a team (the IMT) led by the Site Main Controller (SMC). The SMC is usually a manager or director with a good overall knowledge of the site. This is the structure we see most often in client organisations.
The IMT members represent a range of functional roles including operations, logistics and humanitarian, and can be scaled up or down depending on the nature and scope of the emergency. We recommend that organisations develop a pool of competent individuals with the relevant skills and training sufficient to cover each IMT role, as a minimum requirement. We also recommend additional personnel are given the same training, so they can easily provide backup cover when required. This approach represents good practice in line with the guidance on COMAH Regulations and can easily be achieved at little extra cost beyond that of a basic level of compliance.
Making full use of secure, auditable, robust processes increases both the effectiveness and consistency of the IMT. Often working under pressure, the team needs to be able to analyse information coming from the scene, consider the impact on often complex site processes, make safety-critical decisions to protect their people and coordinate the activities of everyone on site. Managing stress is a crucial skill for the IMT. Having tried-and-tested processes that provide structure and direction are invaluable in stressful situations and are key to IMT effectiveness. Using these processes means the context and rationale for all decisions and actions gets recorded, along with all stakeholder communications. This is important for any internal or external investigations after the event.
We deliver high quality IMT exercises using tried and tested techniques alongside innovative methods, in order to get the best value from our time with your people. Our immersive IMT exercises are designed to quickly develop knowledge, skills and behavioural response patterns and closely replicate the relevant organisational context and response capabilities. We recommend organisations implement a regular IMT exercise programme to maintain familiarity with the core processes and maintain a demonstrably high level of response capability. Relying on a single annual exercise is simply insufficient to keep skills fresh and provide the right level of assurance.
Regular exercises also test the IMT facilities. It seems straightforward, but we often make recommendations following exercise sessions about insufficient facilities, including lack of availability of documentation, up-to-date maps at an appropriate scale, that can be marked up, and a suitable well-supplied operating space. Investment in appropriate IMT facilities is one example of where the best organisations stand out from the rest.
What makes the difference?
Eddistone Consulting have drawn together a team of specialists who have extensive collective experience, coming from industry, the emergency response services, the multi-agency response community, health & safety and education backgrounds, to develop and deliver a competency-based training and exercise framework with identified performance deliverables to measure effectiveness and assure competence.
We use a proven systematic approach that explores how to respond. We have core methodologies for each response level of Emergency, Incident and Crisis (Operational, Tactical and Strategic) management. The credibility and reality of our exercises, experienced in a safe environment where real learning takes place, is always valued by our customers.
How we can help
We recognise that many of our clients, especially in the COMAH-regulated sector, are under pressure to maintain mandated emergency management capacity. We are committed to providing you with emergency management support wherever possible throughout this pandemic. This is important to ensure that you do not fall behind with your scheduling backlog and to maintain the required capacity, despite the impact of absence and illness on safety-critical roles. We have two strategies to help you achieve this:
1. We have developed remote methods for training and assessment, coupled with remote mentoring for the development of key roles. This facilitates accelerated learning and makes the best use of technology and advanced learning practices.
2. We have a pool of experts ready to provide direct support, both remotely and in person, to reinforce capacity and mentor your existing capability. Our team of experts is ready to stand alongside your key emergency response personnel.
Contact us to discuss how we can help you.