Your FRP: Is it just a plan, or effectively leveraged to support your communication plan?

This year, in particular, I’ve made a point to visit as many of the Local Emergency Planning Committees (LEPC) meetings as I can for two reasons. First, for the events at ITC and TPC, as well as other recent meetings, I thought it was important to learn what industry, the public, as well as agencies are doing and talking about so I can share important information with my clients. Also, to the extent possible, be a contributing part of these recent discussions. Second, my goal was to gain more exposure for Witt O’Brien’s, given that incident management and crisis communication are our expertise. We help companies prepare for a crisis, and then, when crisis strikes, help them navigate and recover from the incident. I have learned that the main themes coming from most of the LEPC meetings and other events are related to crisis communication and preplanning.

Recently, one of our crisis communication experts asked me if I know of any clients who have incorporated the information available in their Facility Response Plans (FRP) (Oil Pollution Act of 1990 regulations (OPA90)) into their crisis communication plans. I paused for a moment, as I am not an expert in crisis communication. I had in fact seen this to a certain extent but was curious to learn what he meant exactly.

He asked me for a copy of an FRP that had been recently approved so he could review it and said he’d circle back around with me. A week later he came back with a detailed analysis of the FRP, including over 80 regulated or recommended Plan actions that he’d recommend the company incorporate into their crisis communication plan. The goal is simple: Be sure that what will be said to the public is congruent with what the FRP says will be done. Any comprehensive FRP contains a significant amount of information that will help build a robust crisis communication plan.

Keep in mind, this FRP had recently been approved by the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA). Meaning, it was regulatory sound, and sufficient to support an effective physical response. Investing in a comprehensive FRP pays off not only in regulatory approval but also in ensuring the most effective and safest incident response strategies and tactics. 

The next logical step? Companies should maximize their FRP investment by incorporating the result into their crisis communication planning. The purpose is logical: Create a quality FRP to be sure your organization is responding effectively – now make sure you're communicating effectively with a waiting and watching public.

If after reading the information below, you’d be interested in seeing if your Crisis Communication Plan supports your FRP, Witt O’Brien’s can provide you a free “cold-eye” review - a two-hour high-level report based on an initial analysis of your Crisis Communication Plan's congruence with your FRP.

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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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Maximize your investment: Is your FRP well-integrated with your Crisis Communication Plan?

Multiply the benefits from your planning process: Your Organization's FRP contains plans for an effective response; these plans will help facilitate rapid and effective stakeholder communications.

Why is this important?

Today's 24/7 media environment, with instant awareness and concern, requires rapid and effective public communication to concerned stakeholders. There are multiple reasons for this:

• Someone will share information about your response if you don't: They will have their interests at heart, not yours. Their message may be inaccurate, even skewed.
• Public awareness immediately impacts your reputation: An effective response may develop gradually, but public concern erupts instantaneously upon awareness and continues far beyond your response efforts.
• Slow communication is no communication: If you don't speak quickly and clearly, someone else's voice will supplant yours as the 'authoritative source' of good information. Stakeholders neither forget nor forgive a failure to communicate.
• Reputation is hard won but easily lost: Years or decades of building a good reputation with regulators and neighbors can be lost overnight – or faster.
• You must protect your organization's value! An Economist Magazine study estimated “looked at the eight most notable corporate crises since 2010 and found that while the companies had survived, they were, on average, worth 30% less today than they would have been based on a comparison with a basket of their peers.”
• Safety and effectiveness of your response depends on stakeholder trust: Stakeholders that trust and accept response actions won't impact them. Stakeholders that don't trust or accept your actions can easily disrupt them, leading to unsafe actions or hindrances to effective response.

How can your FRP help effective stakeholder communication?

An effective response plan includes key communication resources, including protocol for immediate notification, incident evaluation criteria, key facility information, response actions requiring key messaging, initial stakeholder (notification) lists, reporting requirements, escalation and de-mobilization plans, and much more.

What does 'Cold-Eye' review consist of?

A two-hour Communications Plan review will serve to ensure coordination within your FRP and Crisis Communication Plan, identify Crisis Communication Plan gaps and provide a Crisis Communications Plan readiness score. Key measurements include:

1. Notification process: Does it include communicators?
2. Does it address incident evaluation for severity of event and communication needs?
3. Facility information: What content is available for immediate use?
4. Messaging: Are Initial Templates and key messaging prepared
5. Approval process: Who must approve content? What can be used with pre-approval?
6. Distribution process: Who receives updates? How do you maintain contacts?
7. Escalation process: How do communication efforts grow to match the response?
8. Unified Command integration: How do you integrate with Unified Command?
9. Response to Recovery: What changes with content and strategy?
10. Training: How do you keep communicators ready to respond?

Below is a snapshot of a few of the more than 80 points found in the above referenced FRP:

Be aware: Communication planning and preplanning are hot topics. Considering recent industry incidents, it is increasingly obvious that every company must be considering integration of Response Plans and Communication Plans. FRPs don’t have to be just a document you submit to check off a regulatory requirement -- but should be utilized as robust all-in-one response and communications plans. An FRP, by requirement, has a portion dedicated for communication planning, so the bridge between the two is a short one.

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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