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Read our latest Risk Factor Newsletter:

3/29/2021 - Odor Surveys and Assessments - 2021

If you ever had an odor or indoor air quality issue within your facility you can appreciate the difficultly in identifying the sources or causes and responding to questions from employees.

The Risk Factor 1st Quarter 2006

Sunday, January 15, 2006
The Risk Factor 1st Quarter 2006

Emergency Response Planning

What you need to know to be prepared

Historically, Emergency Response Planning has been focused on major events such as fires, floods, explosions, power outages, and chemical spills. Although they can certainly be significant, they are not the most significant with regards to the impact on occupant safety and health. In recent years, facilities managers of offices, retail establishments, schools/universities, healthcare and other non-manufacturing facilities have become aware of additional unwanted or unplanned events. Unfortunately, specific plans to respond to these events often are never developed, and as a result, facilities managers find themselves unprepared to respond to the needs of management.

Emergency Response Plans (ERPs) should be very concise and address varied conditions. The first step in the development of your ERP is to conduct a standard GAP analysis that identifies predictable risks and events. Each predictable risk or event will have consequences that can be used to establish a response plan. The other very important part of understanding predictable risks and events is that doing so will permit the development and implementation of controls that will minimize or eliminate their occurrence. A side benefit of understanding and eliminating predictable risks is a reduction in insurance costs associated with workers’ compensation and property loss.

Examples of predictable risk or events to evaluate in the GAP analysis include:

  • Asbestos and lead release incident
  • Blood, vomit, and other body fluids incident
  • Chemical spill incident
  • Construction activity incident
  • Domestic water release incident
  • Domestic water contamination incident
  • Fuel oil/gasoline spill
  • Indoor air quality incident
  • Legionellosis or other environmental disease incident
  • Odor incident
  • Outdoor air incident
  • Pesticide and herbicide application incident
  • PCB release incident
  • Post-fire response
  • Skin/rash/dermatitis incident
  • Sewage spill release incident
  • Storm and flood water incident
  • Visible mold growth response

The second step is to develop the various scenarios and conditions that can lead to predicable risk events based on the GAP analysis. This information will assist planners and responders in better understanding conditions during an event, ensuring a more effective response.

The third step is to develop a list of site- and incident-specific responses for each predictable risk event. At a minimum, this list should include:

  • Contact names and numbers, in order of importance
  • Specific, immediate action steps to limit loss and business interruption
  • Specific response steps to begin remediation and restoration efforts
  • Development of communication to inform building occupants
  • Plan to document effectiveness of response
  • Sampling assessment to document levels of contaminants or microbiological organisms

The final step is training personnel in each of the ERPs to ensure that the plans are effective in responding to an incident. Training must be documented and conducted on an annual basis.

Please contact Chris Schneider, CIH, at 610.524.5525 extension 14 or  email to discuss emergency response plans for your facility.

Accident and Illness Prevention Programs – A Formula for Success

The Commonwealth of Pennsylvania requires insurers, individuals who are self-insured, and group self-insurance funds to develop and maintain accident and illness prevention programs (AIPP) in order to provide workers’ compensation coverage. Failure to do so may mean the removal of the right to provide such coverage.

Why are these programs required?

Prior to implementing this requirement and other workers’ compensation reforms in the mid-1990s, Pennsylvania employers were experiencing very high injury and illness rates, losses, and increased premiums. They were losing money and jobs to other states! Something had to be done, and AIPP was part of the solution.

What is required, and how can you make AIPP compliance a formula for success?

There are two sets of requirements: those for required accident and illness program elements (A-O elements) and those for work environment procedures (P elements).

The A-O elements must be present within the AIPP that was developed, implemented, and monitored by the self-insured employer. These elements are required by the Pennsylvania Bureau of Workers’ Compensation. Each element has descriptive language stating the requirements. For example, the following is the description for the Safety Program Policy Statement:

“A written statement regarding the Accident and Illness Prevention Program that contains the employer’s philosophy regarding accident and illness prevention. The Safety Program Policy Statement is the foundation for all program activities. The statement is signed by a Chief Executive Officer and is communicated to all employees in the organization.”

The P elements are written work environment procedures that must be developed, implemented, and maintained if you have those exposures. Each of those elements also has descriptive language stating the requirements.

Implementing an effective AIPP-compliant program can have significant positive impacts. Examples of the success achieved by some winners of the 2003/2004 Governor’s Award for Safety Excellence are:

  • Centocor: A biopharmaceutical company located in Malvern, Pennsylvania, their OSHA recordable rate dropped from 1.65 in 1996 to 0.59 in 2001.
  • Grove Worldwide: A manufacturer of mobile hydraulic cranes and aerial platforms located in Shady Grove, Pennsylvania, their OSHA lost workday incident rate dropped from 3.7 in 1998 to 1.0 in 2002, a 72.9 percent reduction.
  • EME Homer City Generation L.P.: One of the largest coal-fired power plants in the mid-Atlantic region, it is located in Homer City, Pennsylvania. They exceeded over 2 million hours without a lost-time injury.

On a final note, the Pennsylvania Bureau of Workers’ Compensation conducts random and planned audits of ALL businesses, schools, hospitals, etc., that are required to have an AIPP program. Depending on the outcome of the audit, they have the authority to suspend the self-insured status of an organization.

To learn more about AIPP compliance, how to achieve it, the benefits it provides, and auditing procedures, please contact Colin J. Brigham, CIH, CSP, CPE at 610.524.5525 ext 24 or email.


A-O Elements
a. Safety Program Policy Statement
b. Safety Coordinator Designation
c. Safety Program Responsibility Assignment
d. Hazard Identification Methods
e. Industrial/Occupational Health Services
f. Industrial Hygiene Services
g. AIPP Training
h. Emergency Action Plan
i. Employee Safety Suggestion Program
j. Employee Involvement Methods
k. Safety Rule Enforcement Procedure
l. Accident Reporting and Investigation
m. Availability of First Aid and CPR
n. Program Evaluation Methods
o. Program Goals and Objectives


p. Elements

1. Electrical and Machine Guarding
2. Personal Protective Equipment
3. Hearing Conservation Program
4. Vision Conservation Program
5. Lockout/Tag Out Program
6. Hazardous Materials and Waste Program
7. Confined Space Entry Program
8. Fire Prevention & Protection Program
9. Bloodborne Pathogens Exposure Control
10. Pre-Operational Process Review
11. Substance Abuse Awareness & Prevention