Amidst the business of sustaining profitable operations, oil and gas companies must ensure that work conditions are safe. Oil and gas operations have innate risks, hazards, and, in the event of a release or spill, potential detrimental impacts. As a result, regulatory agencies require response drills and exercises that adequately reflect the current operations and emergency response capabilities.
The National Preparedness for Response Exercise Program (PREP) is designed to facilitate the periodic testing of oil spill response plans for certain vessels and facilities, and provide companies an economically feasible mechanism for exercise compliance. This unified federal effort provides a consistent set of guidelines that satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline Hazardous Material Safety Administration (PHMSA), and the Bureau of Safety and Environmental Enforcement (BSSE). Completion and documentation of the PREP exercises satisfies all OPA 90 mandated federal oil pollution response exercise requirements.
Drill frequency and specific requirements vary depending on operations, vulnerabilities, facility location, and site hazards. However, documentation of oil and gas emergency preparedness drills and exercises is mandated by various regulatory agencies. Thorough documentation also:
- Identifies deficiencies and mitigation opportunities
- Provides a historical record of the event
- Engages management in preparedness efforts
- Serves as a legal instrument, if necessary
- Ensures training accountability
- Accounts for preparedness efforts and plan maintenance cost
In order to satisfy the PREP requirement, oil and gas companies must be able to document all operational and support aspects of a response, and provide detailed records of decisions and actions taken. An exercise tracking system that is integrated into an overall response planning system can minimize the documentation efforts associated with drills and exercises. A tracking system should:
- Improve regulatory compliance with thorough documentation
- Provide a tool for scheduling exercises, and documenting PREP objectives, exercise objectives, lessons learned, scenarios, and action items
- Provide a tool for developing exercise final reports and a method of assigning and tracking outstanding action items to improve follow-up
- Provide a reporting mechanism to track PREP objectives completed during any 3 year cycle, outstanding action items, and a summary report by facility that indicates progress in meeting PREP exercise requirements
- Provide a “snapshot” of exercises completed for the year for every facility via a summary report
To ensure employees and identified essential response personnel are prepared to respond to an incident in an efficient and effective manner, oil and gas companies should establish minimum exercise guideline requirements. Management should ensure that:
- All aspects of response plans are exercised at least once per year with the appropriate response, incident management, and support teams taking part
- Notification exercises for Qualified Individuals are conducted on a quarterly basis. This exercise should involve unannounced checks of the communication processes, and systems
- National and local training and exercise requirements should be used to assess the overall integrated preparedness of a response with the authorities
If not physically present during a drill and/or exercise, the final documentation from the events can be submitted to local responders or fire marshals for review. If a web-based planning system is utilized, drill and exercise documentation can be securely shared and accessed by approved stakeholders. In the event of an actual incident, the lessons learned from these drills and exercises can minimize impacts and prevent further consequences.