Leveraging your FRP: Coronavirus: Is your Pandemic Plan up to date?

Last week I wrote the following article: Your FRP: Is it just a plan, or effectively leveraged to support your communication plan? The article focused on thinking outside of the box, and leveraging one’s Facility Response Plans (FRP) (Oil Pollution Act of 1990 regulations (OPA90)) to be more than just an oil spill response plan meeting a regulatory need. It highlighted how an FRP can be the baton between a facility and one’s crisis management group, as so much of what is needed for crisis management communication is already part of the OPA90 regulations, and with a little effort one could build a robust integrated plan. Similarly, in times of an external crisis one needs Pandemic Plans.

What is a Pandemic Plan? A pandemic plan should lay out how a business will continue to provide essential services through a sustained period with significant employee absenteeism. The plan should also specify measures for "non-pharmaceutical intervention," which means, essentially, how the business will minimize the risk of contagion among employees.

Here at Witt O’Brien’s, many of our clients already include these as part of their FRPs; however, very seldom do we see companies review and update them. Moreover, many of these were written many years ago, and have not been reviewed in quite some time. No time like the present, today is a perfect time to ensure these plans are up to date, have current procedures, correct contact information and align with your organization as it stands today.

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Witt O'Brien's will be hosting Troy Swackhammer, Mark Howard and Chris Perry, EPA Region 6 Spill Prevention Control and Countermeasure (SPCC) Plan and Facility Response Plan (FRP) Coordinator in Houston for an all-day Free SPCC Plan and FRP workshop on June 11th, 2020. Click here to RSVP.

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Why this topic today? Well, let’s be honest, this is the predominate topic in today’s news. 

Current events: CDC is responding to an outbreak of respiratory disease caused by a novel (new) coronavirus that was first detected in Wuhan City, Hubei Province, China and which has now been detected in 50 locations internationally, including cases in the United States. The virus has been named “SARS-CoV-2” and the disease it causes has been named “coronavirus disease 2019” (abbreviated “COVID-19”).

On January 30, 2020, the International Health Regulations Emergency Committee of the World Health Organization declared the outbreak a “public health emergency of international concernexternal icon” (PHEIC). On January 31, 2020, Health and Human Services Secretary Alex M. Azar II declared a public health emergency (PHE) for the United States to aid the nation’s healthcare community in responding to COVID-19.

Read more here.

If your company has not developed such a plan, current events highlight the importance of such a document to protect employees, minimize workflow disruptions and ensure proper procedures are in place to manage events as they occur.

A great resource is the CDC’s Pandemic Influenza Preparedness, Response, and Recovery Guide for Critical Infrastructure and Key Resources Cdc-pdf. Section 5.6.1 in particular provides great checklist for organizations to consider.

Stuck on how to start? Here’s some helpful steps getting your plan off the ground:

Step 1 - Establish a Pandemic Planning Committee with the responsibility to develop, maintain and put into action a pandemic preparedness and response plan.

Step 2 - Determine the potential impact of a pandemic outbreak on your organization’s usual activities and services.

Step 3 - Develop contingency plans for the performance of all critical functions of your organization during a pandemic.

Step 4 - Develop plans to extend timely and factual information about the pandemic to your staff, organizational members and people in the communities.

Step 5 - Develop plans for crisis communications during a pandemic. Develop tools to communicate information about pandemic status and your organization’s actions.

Step 6 - Identify people with special needs (e.g., elderly, disabled, limited English speakers), and include their needs in your response and preparedness plan.

Step 7 - Develop plans to coordinate your pandemic preparedness and response plans with external organizations and agencies. This includes working with public health agencies, emergency responders, local health care facilities, and other community organizations.

Step 8 - Share information about your pandemic preparedness and response plan with staff, organizational members

These steps should help to start the process forward. A quick google search will generate a large handful of blank templates as well. Here at Witt O’Brien’s, we have experience in creating entire state pandemic Plans (i.e., Hawaii) as well as ones for large and small organizations.

Very seldom do we see companies exercise these pandemic plans; as with every part of preparedness, this should be part of the regular rotation – and again, no time like the present.

For a complete listing of archived blogs and compliance insights, click here. Past blogs cover training requirements, clarification on additional confusing elements within the above rules, and much more.

We are here to help solve your compliance questions and challenges. Need some compliance assistance, or just have a question? Please email John K. Carroll III ([email protected]) Associate Managing Director - Compliance Services or call at +1 281-320-9796.

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