Emergency Response Planning and Pre-Incident Planning
This domain tests whether you understand the plans, reports, and pre-incident surveys that make command decisions faster and defensible. Questions often test reporting thresholds or the contents of a pre-incident plan.
Regulatory drivers
- OSHA 1910.120(q) requires an emergency response plan, pre-emergency planning, drills, and medical surveillance for responders.
- EPCRA (SARA Title III) sets emergency planning and community right-to-know duties: Section 302 emergency planning notification for extremely hazardous substances, Section 304 release notification, Sections 311 and 312 for SDS and Tier II inventory reporting, and Section 313 for the Toxics Release Inventory.
- CERCLA sets reportable quantities, the National Contingency Plan, and release reporting under 40 CFR 300.
- Clean Air Act Section 112(r) requires Risk Management Plans at covered facilities.
Contents of a pre-incident plan
- Site layout, access routes, water supply, and hydrant locations.
- Chemical inventory with quantities, locations, and SDS.
- Exposures, drainage, topography, and prevailing weather.
- Command post locations, staging areas, and notification lists.
- Special hazards such as confined spaces, high-voltage equipment, and security controls.
Planning cycle
- Identify hazards, assess capability gaps, arrange mutual aid, exercise the plan, conduct an after-action review, and write an improvement plan.
Worked example
A facility stores anhydrous ammonia in a 30,000-gallon tank near a nursing home. Reasoning: the pre-incident plan records the tank location and quantity, identifies the downwind care facility as a priority exposure, maps two evacuation routes and a shelter-in-place option, lists mutual aid for additional technicians and a bus service, and names the command post upwind of the tank. The plan is exercised annually and updated after any change in inventory.
Traps
- Confusing Tier II thresholds: 500 lb for extremely hazardous substances and 10,000 lb for other hazardous chemicals.
- Mixing CERCLA reportable quantities with EPCRA planning thresholds.
- Maintaining a plan that has never been exercised or updated.
- Planning without identifying downwind special populations.