Many facilities have contract security at the access points into their facility. But many facilities also expect their security guards to play a role in a facility emergency and in even rarer cases play a role in the facility’s safe work practices. Last week I posted the 911 call involving the worker crushed by a forklift to demonstrate how things are NOT suppose to go during an emergency! In this article I want to touch on some ideas that may help identify gaps in the expectations and training of your security personnel.
Let’s assume for the sake of this article that your security guards are contractors.
Emergency Reponse Role
If your guards play absolutely no role in an emergency response at your facility, they will STILL need to be trained in the facility’s Emergency Action Plan. If they play no role, they still have to be accounted for during an evacuation. This is especially critical if your guards are tasked with “making rounds” which takes them deep into your facility, as they could be come victim to an incident!
Let’s look at the different activities I am custom to seeing security personnel play in an emergency response.
1) Shutdown traffic into the site. We should have written into our EAP and ERP that when an emergency alarm sounds that ALL traffic along roadways STOP. Personnel should be trained to pull their vehicle (includes forklifts) off to the side of the road, ensuring they do not block access to other roads, fire hydrants, fire hose huts, etc. They then walk to their nearest assembly area to be accounted for. The guards shutdown access to the facility; ONLY emergency response teams are permitted to enter and even this should be directed by the Incident Commander, as the last thing you want is a roadblock of response vehicles!. NOTE: if you will be calling in your own off-shift emergency response team (ERT) from off site to respond, you should have some means to identify your ERT members so they can gain access to the facility. This will be critical during major chemical releases, as the police will be shutting roads around the facility and if your ERT members do not have a means to be identified AND if the police are not trained in what this identification looks like, your responders will never reach the site! The guards should also have some idea as to who, what, and how many responders to expect and where they need to be directed to. REMEMBER…the first contact (e.g. first impression) of your business to your community responders WILL BE YOUR GUARDS! If they are lost in their duties, unorganized, or they abandoning ship…your facility’s first impression will NOT be favorable! A couple of tips: a) provide a full scale map of your entire facility at the main gate and any secondary gates that may be used for responders to gain access. This map should show ALL building/process areas, with some identifying method (e.g. building names, numbers, color coding, etc.). Then make sure ALL your buildings/process areas are CLEALRY marked with their identifier. I liked to label ALL FOUR sides of the building/processes. I put this map on a wall behind a sheet of plastic and hang several colored grease pencils next to it. b) build into your ERP that after employees are accounted at their assembly area, managers and supervisors will be utilized to help secure the facility. This means they will leave the assembly area after being accounted for, report into the Incident Command so that they may now be accounted for under the IC. NOTE: although these managers and supervisors will NOT fall under 1910.120(q), they WILL NEED to be trained in the very basics of Incident Command and their roles and responsibilities for the task they will be asked to do. I always like to have a senior level manager take over scene security once the headcount is completed rather than have a contractor in charge. This helps put a company face to greet incoming responders; of course this means your facility has to have evacuation down pat so that headcount can be completed within 5-7 minutes for this manager to be able to be at the gate when the first incoming responders arrive.
2) Provide Response Scene Security. Most facilities that I know of and have worked with, just shut down the gates and secure the perimeter of the facility and this does well for “scene security”; however, some larger sites that have units still operating while another unit is in an emergency mode will need to have more focused scene security. This means that the facility may have a multi layers scene security. The gates will stop traffic flow into the facility and someone will have to set up an more localized security perimeter around the unit in emergency mode. Unless the facility staffs the contractor security team to handle this multi-layered security then the facility will need to have written in their plan who they will use and how they will be trained. If your guards are going to respond to the unit BEFORE IC sets up Work Zones, you may need to have them trained to an Operations Level, for sure to an Awareness Level. If they respond after IC has set up work zones and they will NOT enter the warm zone, Awareness Level will be sufficient.
3) Manage Headcount Procedure. These days, computer systems are often used to account for personnel during an emergency. Often times it the guards who print out a list of personnel on site using the badge system, as well as they have the visitor and contractor sign-in/sign-out logs. Personnel at the assembly areas will radio/call in the names of the people they have at their location and the guards will check them off the master badge list or sign-in logs. If this is the way it is done at your facility, your guards will need to be trained in the headcount procedure, including how to call up the lists on the computer, how to print the list, and who will be calling them to report personnel. They MUST also be trained in how they play a role in the IC structure when personnel are unaccounted for.
PSM/RMP Safe Work Practices and Emergency Plans
If your facility falls under OSHA’s PSM or EPA’s RMP and your security staff are contractors and they play a role in your emergency response plan, do they fall under the contractor requirements for PSM/RMP? In other words, were they evaluated to ensure they have the right training and equipment to meet your needs. I for one FULLY believe that a contractor playing a role in a facility emergency reposne plan is a “PSM/RMP contractor” and they need to be evaluated just like the wrench turning contractors who work in, on and adjacent to the covered process. Could OSHA or EPA cite a facility if their ERP fell apart because the contractors were not properly trained or equipped to handle the emergency?
If your contractor security personnel make “rounds” through PSM/RMP process areas, even if these “rounds” are very rarely done, are they trained to the HAZWOPER Awareness Level? This is clearly an OSHA requirement, as I wrote about last week. But who pays for the training? This is something that should be a contract requirement that the security company can ONLY send personnel trained to the HAZWOPER Awareness Level and the facility will provide site orientation training on the chemicals on site, the guards roles and responsibilities in the EAP and ERP. Essentially, the guards training should EVRY MUCH mirror what every other contractor gets, AS WELL AS some very specific training on their role and responsibility within ERP and EAP. The guards training will usually be a couple of hours longer, since they may have some specific duties within facility procedures, where as other contractors just gather at an assembly point during an emergency. Unfortunately, we find more times than not, guards fall through the cracks and receive very little training. When we ask about this, the most common excuse is the turnover rate of the guards means that the facility would be training a new guard weekly and that is just not possible. But someone has to train them in the above items, so this needs to be spelled out in the security contract.
Do your security personnel make the “4-hour Fire Watch Inspection”? A lot of insurance companies require this 4-hour (or some other time period) follow-up before the hotwork permit is closed. If your guards are playing this role in your Hot Work program, are they trained to do this task? Are they equipped to do this task (e.g. PPE such as FRC to enter HAZLOC’s)? Keeping in mind that Hotwork is a PSM/RMP element, so if your guards are playing the role of the fire watch, you may want to seriously consider including them in your contractor safety program (e.g. evaluate them).
Last thing to think about in regards to your security guards…if your facility is a PSM/RMP facility, should they be included in your Management of Change procedure? I say YES, especially if they play a role in any of the tasks that I discussed above. Any change that would impact the EAP/ERP, Hotwork Program, Confined Space Entry Permit logs, etc. will need to be communicated to the guards and they may need training on the changes. In other words, if your security guards are expected to play any type of role in your safe work practices or emergency procedures, they will need to become part of the family and no longer “abandoned at the gate”!