One of the most heated debates in the process safety arena is… Do I have to have an emergency response team? EPA has worked to answer this question by designating facilities as “responding” and “Non-responding” facilities. Here is a nice flow chart to help…
Source: NC Department of Public Safety
| Requirement | Start Date | Citation | Program 1 | Program 2 | Program 3 |
|---|---|---|---|---|---|
|
All Facilities
|
|||||
| Facilities complete annual emergency response coordination with local responders | 03/14/2018 | §68.10(b) §68.93 |
X | X | |
| Facilities with toxic substances must be included in the community emergency response plan | Chemical onsite | §68.12(b)(3) §68.90(b)(1) §68.95(c) |
X | X | X |
| Facilities with flammable substances must coordinate with local fire department(s) | Chemical onsite | §68.12(b)(3) §68.90(b)(2) §68.95(c) |
X | X | X |
| Annual Notification Exercises | 12/19/2024 | §68.96(a) | X | X | |
|
Non-Responding Facility – Will not respond to accidental release
|
|||||
| Emergency Action Plan | Chemical onsite | §1910.38 | X | X | |
| Appropriate mechanisms are in place to notify emergency responders when there is a need for a response | Chemical onsite | §68.90(b)(3) | X | X | |
|
Responding Facility – Will respond to accidental release
|
|||||
| Implement an emergency response program (OSHA’s HAZWOPER standard 29 CFR 1910.120) | Chemical onsite | §68.95 §1910.120(q) |
X | X | |
| Emergency Response Exercise Program (written) Field and Table Top Exercises |
12/19/2023 | §68.96(b) | X | X | |
| Emergency Response Exercise Program – Report Exercises Completed | 12/19/2024 | §68.10(f) | X | X | |
| Table Top Exercises – Conduct | 12/21/2026 | §68.96(b)(2) | X | X | |