Your facility's experienced a spill, a gas leak or some other kind of environmental disaster. The first 48 hours are critical. Clearly you need to get on top of it and understand what sort of safety procedures need to be put in place and how to deal with the environmental management of it – without, of course, making things worse. There are five key steps that you'll be going through.
First of all it's important to have those safety and environmental management responses worked out in advance; you can't just do it as it happens. It's important to have thought through the possibilities and make sure that you've got a management plan in place that can be activated.
Once those measures are in place the next thing that's going to occur will be a requirement to report; you'll need to report to the government, you may need to report to the community and you'll certainly have to report up to senior management. How those reports are formulated, what their content is, and how quickly they need to be produced are all key factors in responding to this incident.
Once the reporting occurs there's likely going to be an internal investigation. Senior management are certainly going to want to know why the incident occurred and how to avoid it in the future. Being clear on individuals' roles and responsibilities in that investigation process will make it smoother and will result in useful information.
Of course along with an internal report there may very well be an external investigation. Government agencies may want to know what happened, why it happened and if there is any culpability. Managing that external investigation from the internal side is critical.
Understanding what documents need to be provided, where they're to be provided, who's to be made available for interviews and how that can be run, again smoothly and efficiently, is important to managing that whole process and then of course through an investigation it's important to support the employees; those people that might be asked to be witnesses, those giving evidence.
It's important to understand that when an environmental incident happens the investigators have very wide-ranging powers – they can come on site, they can take samples, they can take away electronic records, for example. So managing that process, understanding how to respond and ensure that the right information is being provided is again critical to the success of managing the incident itself.
To help you through this Clayton Utz has developed the CU Safe App which outlines in a logical step-by-step process managing the exercise. For more information please contact us.