This is very carefully not a change in regulations, but more of an explanation of how PHMSA intends interpret the current regulations concerning the sharing of operator emergency response plans with local responders. The most important part of the actual Advisory Bulletin is contained in the last sentence:
“PHMSA intends to evaluate the extent to which operators have provided local emergency responders with their emergency plans when PHMSA performs future inspections for compliance with relevant requirements.”This still doesn’t deal with the issue of producing effective emergency response plans that coordinate the notification and response of emergency personnel from both the operator and local emergency response agencies. Not that this is really PHMSA’s responsibility to effect that change; it will require significant legislative changes to the emergency response planning framework. Those changes will have to move the current weak emergency planning requirements beyond just the necessity of having an emergency response plan, to putting into place a mandated methodology for coordinating, reviewing, approving, and exercising such plans.
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Emergency response planning can be of limited value in protecting at-risk populations from releases from facilities or transportation. The US
army and US GAO use a more valuable standard regarding the seven US Chemical Stockpile Emergency Preparedness Program communities -- "reliable, tested capabilities" must be in place, not just plans. Asking "capabilities for what (release)?" leads to demands for tough Worst Case Scenarios, often omitted in current emergency planning.
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