INTEGRATED CONTINGENCY PLANS - A COST EFFECTIVE APPROACH TO ADDRESSING ENVIRONMENTAL AND ACCIDENT PREVENTION PLANNING REQUIREMENTS

摘要

Colleges and Universities may be required to draft emergency response plans; oil spill prevention countermeasure and control (SPCC) plans; hazardous waste contingency plan; and/or hazard communication plans. These rules apply because a College or University uses and stores chemicals and petroleum products, generates hazardous waste, has ancillary operations that could discharge pollutants to water and has employees that work with chemicals. Typically, Colleges and Universities have either developed separate plans to satisfy each applicable law, resulting in shelves filled with plans that are never used and gathered dust, or, more commonly, have not complied with one or more applicable planning rule. Most planning regulations have overlapping, and sometimes contradictory requirements making compliance costly, confusing, and complicated. However, with the advent of the Integrated Contingency Plan (ICP), and the regulatory support it has gained since 1996, more and more Colleges and Universities are opting for the one-plan approach. The ICP approach is also the federally preferred method for facilities to meet their emergency response planning obligations. An ICP addresses all applicable emergency response and contingency plan requirements in a single, easy to understand, and concise document. The goal of an ICP is to satisfy several complex requirements from different regulating agencies, while improving a facility's ability to respond to a crisis. Addressing all emergency response plan requirements in one integrated plan can save a College or University time and money, increase the institution's ability to handle potential emergencies, and satisfy all overlapping state and federal emergency response planning requirements. This paper provides the regulatory background of ICPs and an overview of the various environmental and accident prevention planning requirements that can be addressed in an integrated plan. It also suggests ideas for drafting a user-friendly ICP which will provide effective guidance to a student discovering a spill at night, and an incident commander directing response activities during an emergency, while meeting all applicable plan requirements.