Safety Message: Emergency Management Plans (EMP)

1. Updating the EMP after making changes

Changes to railway operations can impact the EMP. For example, adding an emergency release handle to rolling stock doors may result in changes to the types of foreseeable emergencies as well as the methods to mitigate those emergencies. Unfortunately, updating the EMP as part of a change is often not undertaken.

Good practice for updating the EMP when making a change includes:

• Management of change procedures that also consider impacts on the EMP – see Safety Message – Management of Change (link at bottom of page)
• Roles and responsibilities of those accountable for updating the EMP being clearly defined in systems and procedures.
• Implementing systems and procedures to maintain the EMP so the EMP remains current e.g. in accordance with section s113(2)(c) of the RSNL.
• Scenarios, situations or events where the EMP requires review being clearly defined e.g. such as reviewing the EMP as part of the SMS review – see section 102 of the RSNL and Regulation 17 RSNLNR.

2. Consulting on the EMP

Consultation on the EMP improves communications, increases coordination and reduces risk. However, consultation on the EMP is often inadequate e.g.

• Not consulting the right people or organisations.
• Consulting too late e.g. not providing stakeholders sufficient time to provide input to the EMP.
• Consulting too little e.g. only consulting on part, rather than all, relevant aspects of the EMP.

It should be noted that consultation involves more than communication. Consultation means seeking input before a decision is made regarding the EMP. When preparing the EMP, section 113(2) of the RSNL requires consultation with the following entities or organisations who are either affected by the EMP or may be required to assist in implementing the EMP:

• Emergency services (fire, ambulance, police).
• Government agencies with emergency management functions.
• Other rail transport operators that may be affected.
• Utilities and telecommunications service operators e.g. water, sewerage, gas, electricity, pipeline operators, and telephone and telecommunications operators.
• Public transport providers.

For emergency services expected to attend in the event of a significant incident, there are additional consultation requirements e.g.

• Preparing the EMP in conjunction with emergency services.
• Determining, in conjunction with emergency services, how often to test the EMP.

3. Undertaking emergency tests and exercises

Testing the EMP through drills and exercises helps assess its effectiveness. Often, however, such testing is inadequate e.g.

• Testing the EMP too infrequently resulting in the operator being ill-prepared when a real emergency happens.
• Using an overly simple or small emergency scenario which does not effectively test the EMP.

Good practice for testing the EMP includes:

• Testing the EMP following significant changes to railway operations and/or the EMP.
• Testing and exercises undertaken in conjunction with emergency services.
• Clearly defining frequency of testing in the EMP.
• Tests or exercises undertaken are reviewed with any identified EMP deficiencies addressed – see Clause 11 Corrective Action of Schedule 1 of the RSNLNR.

4. Defining the documents that form part of the EMP

EMPs are often composed of several systems, procedures, processes, and documents. There is no requirement for the EMP to be contained in a single document.

However, not defining the systems or procedures which form the EMP can lead to increased risks to safety e.g.

• Certain key systems or procedures that are part of the EMP are missed or not activated during an emergency.
• Key personnel are not notified or informed, or critical information is not communicated.
• Controls are not implemented, or only implemented after significant delays.

Good practice for defining documents that form part of the EMP includes:

• Listing or referencing in the EMP all systems or procedures that form the EMP.
• Cross-referencing documents, if relevant, so all EMP systems and procedures can be easily identified.
• Training staff so they know the relevant systems and procedures that together form the EMP.

5. Making the EMP comprehensible and accessible

An EMP that is comprehensible and readily accessible allows it to be easily understood and quickly activated. Often, however, EMPs do not make sense or cannot be easily accessed because:

• Multiple versions of the EMP exist or are still in draft so it is not clear which is the current version.
• The EMP is poorly drafted or ambiguous.
• The EMP is stored electronically but in a location that is difficult to find.

Good practice for ensuring the EMP is comprehensible and accessible includes:

• Checking that the people required to use the EMP during an emergency can easily understand it – see RSNLNR Regulation 20(6).
• Ensuring the EMP is quickly and easily accessible at the location or time where it would be used or activated.
• Ensuring the EMP is readily accessible at all times to:
  • employees or contractors who would need to implement it;
  • emergency services (fire police ambulance);
  • other rail transport operators that may be affected by it;
  • other entities or organisations who are either affected by the EMP or may be required to assist in implementing the EMP e.g. government agencies with emergency management functions, utilities and telecommunications service operators, public transport providers.

6. Defining communication methods or processes

Communication is critical during an emergency and is required by Regulation 19 of the RSNLNR. However, often EMPs do not define communication methods or processes e.g.

• The EMP does not define the critical information that is to be communicated during an emergency.
• The EMP does not identify who the information is supposed to be communicated to, including the type of information provided to emergency services.

Good practice for defining the communication methods or processes in the EMP includes:

• Procedures in place for liaison with relevant emergency services, including information about the circumstances in which emergency services are to be immediately contacted.
• Procedures to ensure that emergency services are provided with all the information that is reasonably required to enable them to respond effectively to an emergency.
• Procedures for effective communications and cooperation throughout the emergency response.

7. Applying a systemic approach

An EMP needs to deal seamlessly and systematically with an emergency. However, information in the EMP is often disparate, isolated or not interlinked e.g.

• Controls listed in the EMP are not linked to the corresponding type or class of emergency.
• Types or classes of emergencies (e.g. fire, derailment, collision) are listed- but the actions that need to be taken in response are not.
• Personnel (e.g. wardens, chief wardens) and their contact details are provided but not their responsibilities or accountabilities.

Good practice for applying a systemic approach includes:

• The EMP applying a risk management approach i.e. identifies and assesses the potential classes, types and risks of emergencies, and then defines the controls to manage those emergencies.
• Clear traceability or links exists between:
  • the types or classes of emergencies;
  • risk assessments of those emergencies;
  • the corresponding controls;
  • key personnel responsible for managing and implementing those controls.

8. Putting in place systems and procedures to ensure compliance

Systems and procedures to ensure the EMP is managed and maintained are required by Clause 26 of Schedule 1 of the RSNLNR. Not having such systems or procedures in place is often the primary cause for the issues listed above.

Good practice for such systems and procedures includes the following:

• Systems and procedures that set out how the EMP will be monitored to ensure compliance with section 113 of the RSNL.
• Systems or procedures that define how the EMP is managed, maintained, updated, reviewed, tracked and monitored.
• Clear definitions of who is responsible and accountable person for maintaining the EMP.