Guidance Note
Emergency planning
at a major hazard facility
Advice for operators of major hazard facilities on developing an emergency plan.
April 2011
1.
Introduction
1
1. Introduction
1.1
Features of a successful emergency plan
1
1.2
Key concepts
2
1.3
Key definitions
2
2.
Planning and preparation
3
The major hazard facility parts of the Occupational
Health and Safety Regulations 2007 (OHS Regulations)
set out legal duties for control of risks from operating
a major hazard facility (MHF). They apply to the operator
of a facility who is the employer with management
or control of the facility.
2.1
Time scales
4
2.2
Draft emergency plans
4
3.
The emergency plan process
9
3.1
Contents of emergency plans
9
3.2
Planning for on-site emergencies
9
3.3
Planning for off-site emergencies
11
3.4
What range of scenarios need to be considered?
12
3.5
Performance indicators for emergency plans
15
3.6
Testing the emergency plan
15
3.7
Review and update
14
4.
Compliance checklist
15
5.
Further reading
To obtain a licence to operate an MHF in Victoria,
MHF operators are required to submit a Safety Case
to Worksafe Victoria which sets out how the facility
will be operated safely.
This guidance note will assist operators of dangerous
goods sites develop an emergency plan before applying
for an MHF licence or prior to dangerous goods inventories
reaching Schedule 9 threshold quantities. It covers
preparation, implementation and testing of emergency
plans required under part 5.2 of the MHF regulations.
It will be of use to those responsible for emergency
planning at a facility and those developing the
facility’s Safety Case.
An effective emergency plan is an essential part of
a comprehensive risk management approach for an
MHF because the potential consequences of major
incidents are severe, and it may not be possible to
eliminate the risk of major incidents altogether.
1.1 Features of a successful
emergency plan
15
The following factors are critical to emergency planning
and WorkSafe will expect these to be addressed:
• Development of an emergency plan that is appropriate
to the hazards and risks of the facility and that
mitigates these so far as is reasonably practicable.
The emergency plan should be:
documented
well-structured and succinct
specific to the facility and to the identified
major hazards
effective in addressing the on-site and off-site
consequences of a major incident occurring
GUI0134/01/02.11
Guidance Note Emergency planning
at a major hazard facility
understood by workers and other potentially
affected parties
subject to review, testing and update.
• The emergency plan needs to interface with,
and be consistent with, the expectations, resources,
communications channels, policies and procedures
of the emergency services and the councils for
potentially affected areas and of any adjacent MHF.
• Integration of the emergency plan into the Safety
Management System (SMS), safety and property
protection assessments and the Safety Case.
Evaluation of emergency planning options and
demonstration of adequacy of the adopted emergency
plan as a control measure within the Safety Case.
• The emergency plan should reflect relevant studies
(eg fire safety study and quantitative risk assessment).
It should also be consistent with related plans
(eg the State Emergency Plan).
1.2 Key concepts
• The operator of an MHF must prepare an emergency
plan in relation to the on-site and off-site effects
of any major incident that may occur at the facility.
• The emergency plan must be developed in
conjunction with the emergency services and,
in relation to off-site impact, with the municipal councils.
This requires active involvement of these parties
to reach agreement on how all three parties will
respond to emergencies.
• A draft of the emergency plan for the facility must be
submitted to WorkSafe along with the Safety Case
outline within 90 days of registration. The Safety Case
outline must include a detailed, time-framed program
of activities, including those for finalisation of the
emergency plan in compliance with the
MHF regulations.
• The emergency plan must be treated as a control
measure and a range of emergency planning provisions
must be considered in the Safety Assessment. Reasons
for selecting certain provisions and rejecting others
must be documented; workers must have roles to assist
the operator in this; health and safety representatives
(HSR) and workers must be consulted; and the Safety
Case must be sufficient to demonstrate the adequacy
of the emergency plan.
• The contents of the emergency plan must be
communicated to all persons who have a role within
the plan. It should be comprehended and understood
by these persons.
• The emergency plan must be fully tested at least every
•
•
•
•
three years and the operator must take all reasonable
steps to arrange participation of the emergency
services in these tests.
The emergency plan must be implemented immediately
if there is a major incident or an uncontrolled event
that could lead to a major incident. The operator must
notify the emergency services immediately if a major
incident occurs.
The emergency plan must be reviewed and updated
if WorkSafe directs, if there is a relevant change to
the facility, if a major incident occurs, if a test shows
deficiencies and every five years.
Attributes of an emergency plan are that it is specific
to the facility and hazards, linked to the Safety
Assessment and the Safety Case, integrated within the
SMS and linked to higher level plans (eg at state level).
The emergency plan must include a strategy to manage
the consequence of each major incident. Facilities
may work in conjunction with emergency services
organisations to develop these strategies, but the
expectations of all parties must be clearly expressed
and agreed.
1.3 Key definitions
Control measure (control): Any system, procedure,
process, device or other means of eliminating, preventing,
reducing or mitigating the risk of major incidents at an
MHF. Controls can include physical equipment, process
control systems, management processes, operating or
maintenance procedures, the emergency plan and key
personnel and their actions.
Hazard (related to an MHF): Any activity, procedure,
plant, process, substance, situation or any other
circumstance that could cause, or contribute to
causing, a major incident.
Hazard identification: The process of identifying
hazards as described in the Worksafe guidance note
– Hazard identification.
Major incident (related to an MHF): An uncontrolled
incident, including an emission, loss of containment,
escape, fire, explosion or release of energy that involves
Schedule 9 materials and poses a serious and immediate
risk to health and safety.
Safety Assessment: A Safety Assessment
process consistent with international risk assessment
standards, including AS/NZS ISO 31000 – Risk
Management. A Safety Assessment involves an
investigation and analysis of the major incident hazards
and major incidents so as to provide the operator with
a detailed understanding of all aspects of risk to health
and safety associated with major incidents, including —
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Guidance Note Emergency planning
at a major hazard facility
(a)the nature of each hazard and major incident
(b)the likelihood of each hazard causing a major incident
(c)in the event of a major incident occurring –
(i) its magnitude, and
(ii)the severity of its consequences to persons
both on-site and off-site
(d) the range of risk control measures considered.
(e)the cost of eliminating or reducing the hazard or risk.
More information on key terms is found in other MHF
guidance material available from the WorkSafe website
and in the definitions of the OHS Regulations (reg 1.1.5).
2. Planning and preparation
So far as is reasonably practicable: To reduce risk
to a level so far as is reasonably practicable involves
balancing the benefit of a reduction in risk against factors
such as time, trouble, difficulty and cost of achieving that
reduction. This requires consideration of:
(a)the likelihood of the hazard or risk
concerned eventuating
(b)the degree of harm that would result if the hazard
or risk eventuated
(c)what the person concerned knows, or ought reasonably
to know, about the hazard or risk and any ways of
eliminating or reducing the hazard or risk
(d)the availability and suitability of ways to eliminate
or reduce the hazard or risk and
The operator must have a process for the development,
maintenance, communication, review and implementation
of the emergency plan for major incidents. The emergency
plan should be treated as a control measure under the
MHF regulations. The process must involve the relevant
emergency services in relation to all aspects, and the
relevant councils in relation to off-site aspects. The process
must also include consultation with HSR, and involvement
of workers in accordance with their safety roles developed
under reg 5.2.13.
The process of preparing and maintaining an emergency
plan is summarised in Figure 2.1. The emergency plan
has components which require preparation and review
in conjunction with other parties as well as links to other
processes and documents at a facility.
Figure 2.1 – The process of preparation and maintenance of an emergency plan
Safety Assessment
Preparation
Testing
Adopt as control measure
Review
Demonstrate adequacy
in Safety Case
Operator alone
Implementation
Operator in conjunction
with emergency services
and councils
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Guidance Note Emergency planning
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2.1 Time scales
Figure 2.2 – Example contents of draft emergency plan
The operator of an MHF must submit a draft emergency
plan to WorkSafe at the same time as submitting
the Safety Case outline required under reg 5.2.33
(see guidance note – Safety Case outline for a major
hazard facility) ie within 90 days of being informed that
the facility has been registered as an MHF.
(a)Site and hazard detail
(b)Emergency response command structure and personnel
(c)Notifications
(d)Emergency response resources
(e)Emergency procedures
The operator of a registered MHF has a period of 30
months to achieve full compliance with all the requirements
of the MHF regulations including any related to emergency
planning. At all times in this 30 month period, the operator
must comply with the duties under part 5.2, divisions 3,
5 and 10 so far as is reasonably practicable. Division 3
includes provisions related to emergency planning.
The Safety Case must also provide sufficient information
to demonstrate that the emergency plan is a suitable
and effective control measure which (in combination
with the other control measures) reduces risks so far
as is reasonably practicable. This will require the operator
to assess the emergency plan and consider options for
the plan within the Safety Assessment process.
Thus WorkSafe may expect the operator to achieve full
compliance with critical emergency planning requirements
in a lesser time scale than 30 months, particularly in cases
where there is a high hazard or risk, or in cases where
suitable emergency planning provisions are well known
and easily implemented.
Any deficiencies in the existing emergency plan should
be identified by the operator and noted in the draft
emergency plan or the Safety Case outline. The Safety
Case outline should detail how and when the deficiencies
will be corrected.
2.2 Draft emergency plans
A draft emergency plan for the MHF must be submitted
with the Safety Case outline. This can be based
on an existing emergency plan as required by the
Dangerous Goods Storage and Handling Regulations
2000 (DG (S&H) Regulations), providing the existing plan
is based on the current level of knowledge of hazards and
risks and that it contains the basic elements of a robust
and workable plan. The operator should consider the
information included in the dangerous goods manifest.
This typically includes information on inventories and
locations and provides a useful input to the emergency
plan. The draft plan in the Safety Case outline should
include a description of the program of work required
to bring the emergency plan into full compliance with
the MHF regulations, if it is not already.
The emergency plan must achieve full compliance with
the requirements of the MHF regulations. The plan must:
• include all information required by Schedule 11
of the OHS Regulations
• address on-site and off-site consequences
of major incidents that could occur on the facility
• be developed in conjunction with the emergency
services and the local councils.
2.2.1 Development of the emergency plan
The operator must prepare an emergency plan addressing
the on-site and off-site consequences of major incidents
that could arise at the facility and, by implication, all
uncontrolled events that could lead to a major incident.
The plan must be prepared in conjunction with the
emergency services and also, for off-site effects,
in conjunction with the relevant councils. The operator
must, if practicable, consult with HSR and workers
in developing and reviewing the emergency plan.
The operator must also develop roles for workers to assist
the operator in this activity. Active participation of the
emergency services, councils, HSR and workers is required
to ensure that agreement is reached on the roles of each
party in responding to emergencies. The various parties
need to determine that the proposed arrangements are
workable, that the communication lines and command
structures are integrated and that equipment and
supplies are compatible where necessary.
When developing the plan, the operator will often develop
a plan, try it and then refine it. Response objectives and
goals of the emergency response arrangements (see
next page for examples) are often refined at this point.
These goals and objectives should be set in conjunction
with the emergency services, councils and workers,
and also (if appropriate) with the operators of adjacent
or connected hazardous facilities. However, involvement
of councils does not need to include events where
consequences are limited to within the site boundary.
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Guidance Note Emergency planning
at a major hazard facility
Examples of emergency plan goals, objectives
and performance standards
• All non-emergency response workers will be
evacuated to a safe assembly area within X minutes
of alarm being issued.
• All major incidents identified in the Safety Case will be
represented in the emergency plan and specific tests
carried out to determine effectiveness of response
to each incident within Y years.
• All evacuation and response pathways will have
defined primary and secondary routes for movement
of personnel and equipment.
• Protection levels for assembly areas will be set based
on consequences of major incidents.
• Maximum personnel exposure levels during evacuation
will be set according to consequences assessed for
major incidents.
• Initiation of the site or plant emergency alarms will
be planned out for all identified major incidents and
uncontrolled events able to lead to major incidents.
Personnel will be trained in the use of these.
• Notification of the emergency services and set-up
of the emergency response centre will be carried
out within Z minutes of a potential major incident
being identified.
• On-site emergency response teams will have first
priority to protect themselves from exposure to specific
consequence levels defined in the Safety Assessment.
Their second priority will be to search for and rescue
missing persons. The final priority is property protection.
• No emergency response team will be exposed above
certain levels of consequence while fighting fires.
• There will be a total of X trained emergency
coordinators and Y trained emergency response
commanders on-site or on call at all times.
• Workers will be involved in setting, training
and testing performance standards for their
own roles in emergency response in order to ensure
arrangements are workable.
• Firefighting water will be contained on-site by
use of an effluent diversion pond to ensure
environmental protection.
• Fire protection reserves will be held at Z%
of maximum predicted demand levels.
During the development of the plan the operator should
also consider the following matters:
• The necessary emergency response arrangements
must, in combination with other control measures, either
eliminate risks or reduce them so far as is reasonably
practicable. Continuous improvement of the emergency
response arrangements is achieved by conducting
test exercises. As a starting point in this process,
the operator may choose to use the current emergency
response arrangements or an ‘industry standard’.
These evaluations must be performed as part of
the Safety Assessment.
• The arrangements should include the procedures,
roles and resources (hardware and software) that are
required to achieve the response. They should identify
all individuals and organisations with a role to play
and the expertise and capabilities relevant to the
required response.
• The required emergency response capabilities are
performance standards for the control measures
that comprise the emergency plan. See left for
some examples.
• When defining arrangements, it is necessary
to determine how responses will be coordinated,
and to allocate responsibilities. It may be necessary
to identify situations where the routine procedures
and resources are not sufficient and develop
contingency plans for these.
• Facilities will plan to respond to a range of
emergencies including major incidents, smaller
incidents, environmental spills, power/utilities failure,
extreme weather, personal injury etc. While the
requirements under the MHF regulations relate only
to emergency plans for major incidents, WorkSafe
expects operators will develop a single, integrated
emergency plan for all types of emergency.
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Guidance Note Emergency planning
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Examples of arrangements in emergency plan
• Command structure between operator and
emergency services in event of major on-site incident.
• Command structure between operator, emergency
services and councils in event of major incident
with potential to spread off-site or with actual
off-site effects.
• Communications channels for all parties
involved or requiring information.
• Backup contingency plans for all of the above,
including any mutual aid agreements and associated
deployment procedures.
• Pre-incident plans for specific actions and
arrangements for specific scenarios.
• Training and rostering schedules for emergency
coordinators and general workers.
• The analysis of emergency response arrangements
should consider all potential major incidents that could
occur at the facility, as well as all the hazards that could
cause or contribute to causing a major incident if these
can affect the nature of the incident and the means
of response to it (see Figure 2.3). However it should
be possible to develop the emergency plan based on
a representative cross-section of incident types so
that it is not necessary to incorporate every single
major incident identified for the facility. The analysis
should use the results of safety and property protection
assessments, and should feed back into those
assessments as necessary.
Figure 2.3 – Examples of major incident scenarios included
in an emergency plan
• When the emergency plan, its performance standards
and contingency arrangements have all been defined,
personnel will need to be trained in its content and the
local community informed of the relevant components.
This aspect is covered later and in the guidance note –
Consultation and the role of HSR
• The emergency plan must be properly incorporated
within the overall facility SMS and Safety Case as a
control measure subject to the same regime as all other
control measures (see the guidance note – Control
measures). The development of the emergency plan
therefore needs to include processes for testing,
review, training and informing.
• General approaches to emergency planning are
presented in a number of key documents from
external agencies (see section 3).
• Detailed emergency firefighting and operational
response plans and procedures developed via
approaches such as pre-incident planning should
be incorporated (as appropriate) in the overall
emergency plan for the facility.
• All aspects of the emergency plan need to be realistic,
workable and agreed to by the relevant parties.
This includes assumptions regarding actions
required, timing, effectiveness of detection methods,
decision-making processes and number of people
on-site day shift/night shift. The emergency plan
should be robust and take into account the less
than ideal conditions that may prevail in a real
emergency which often make it difficult to
achieve ideal responses in practice.
Figure 2.4 summarises the possible processes for
formulating an emergency plan.
Rim seal fire
Single tank roof fire
Full or intermediate bund fire
Spill and fire from transfer pipe
Pump area fire
Road tanker loading spill and dispersion
Process unit explosion and missiles
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Guidance Note Emergency planning
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Figure 2.4 – Flow chart for development of an emergency plan
Hazard and
consequences analysis
Define objectives
for emergencies
Involve workers,
emergency services
and councils
Set emergency
response objectives
Define a set of existing
or proposed emergency
response arrangements
Analyse the emergency
response arrangements
Set emergency response
system goals
Do arrangements meets
system goals?
Reduce/remove the hazard
or modify the emergency
response arrangements
No
Yes
Are risks eliminated
or reduced so far as
reasonably practicable?
No
Yes
Set detailed
performance standards
Monitor performance
to ensure risks are
eliminated/reduced
Train personnel
and inform community
Include in Safety Case
and SMS
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Guidance Note Emergency planning
at a major hazard facility
In developing the emergency plan it is important
to recognise the relationships between different
types of emergency management documents. These
include the site information folder, the pre-incident plan,
the pre-incident response plan, the municipal emergency
plan and the site emergency plan. These are summarised in
the table below and the relationships shown in Figure 2.5.
Table 2.1 – Documents for emergency management
Documents for emergency management
Site information folder
Site specific information required by the first attending fire brigade personnel.
Includes the site dangerous goods manifest.
Site plans including general layout, fire protection facilities and utilities.
Schedule 11 requirements.
Pre-incident plan
Specific action plans that are additional to the site emergency plan.
Included as part of the procedures to be undertaken at a specific site.
Generally an addendum to the site emergency plan.
Pre-incident response plan
Specific to the emergency services.
Planning process for emergency services response to an identified hazard.
Includes escalation responses.
Relies on the site identifying hazards, event types and impact areas, control measures available,
site command structure, resource needs and control strategies.
Municipal emergency plan
Identify how the municipality will respond to emergencies.
Relies on the site to identify hazards, event types and impact areas where there is an off-site
consequence (refer section 3.3).
Figure 2.5 – Emergency planning relationships
Municipal
emergency plan
Site emergency plan
Identification
of potential
community impact
• Event type and size
• Control measures
• Command structure
• Resources
Site information
folder
DG manifest
• Site emergency philosophy
Pre-incident plan
• Procedures
Event specific
• Contact details
Addendum to site
emergency plan
Pre-incident
response plan
Fire service
delivery for site
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Guidance Note Emergency planning
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3. The emergency plan process
Site and hazard detail
(a)Name, location, address and nature of operations
(b) Detailed map of the facility and surrounding area
(c) Inventory of Schedule 9 materials
(d) Maximum/minimum number of persons expected at the facility, day shift/night shift
(e) Infrastructure likely to be affected by a major incident
(f) Emergency planning assumptions
(g) Description of measures to control the consequence of each hazard and major incident
Command and structure
and personnel
(h) Command philosophy and structure for emergencies
(i) Details of emergency contact personnel
(j) Allocation of personnel for implementing the plan
(k) Arrangements for ‘mutual aid’ between adjacent facilities
Notifications
(l) Procedures for providing early warning of a major incident
(m)Details of on-site and off-site warning systems
(n) Contact details for the emergency services
(o) Details of on-site communications systems
Resources
(p) Details of emergency resources on-site
(q) Arrangement for obtaining additional external resources
Procedures
(r) Procedures for safe evacuation and muster of personnel
(s) Details of control points and procedures for essential services
(t) Procedures for containment of any incident
(u) Procedures for decontamination following an incident
3.1 Contents of emergency plans
The required contents of the emergency plan are
specified in Schedule 11 of the OHS Regulations and
are summarised above. Although the plan must contain the
items specific in Schedule 11, there may also be additional
items not specified that are required for the plan to be
workable/functional.
3.2 Planning for on-site emergencies
The emergency plan must address on-site consequences
and on-site response in relation to major incidents, and
these aspects must be prepared in conjunction with the
emergency services. The emergency plan should include
provision for incidents that may be controlled within the
facility boundary, using either on-site resources alone,
or on-site resources plus external assistance. In most
circumstances, the emergency plan should provide for
a sufficient on-site response (including personnel and
resources) to control incidents such that they do not
cause off-site effects. The plan should also cater for
different conditions, eg out of hours manning, limited
water availability or adverse weather conditions.
The plan should address incidents that may occur relatively
frequently (eg uncontrolled events which could lead to
a major incident or smaller-scale major incidents) but
should also address extremely rare events with serious
consequences such as major incidents, unless these can
be shown to be so unlikely or so extreme that planning
for them is unrealistic (eg meteorite impact). An example
of included incidents is shown in Figure 3.1.
On-site emergency planning must be conducted in
conjunction with the emergency services, even for
incidents where effects are minor and confined within the
boundaries of the facility, as the emergency services would
attend all such incidents. The operator and emergency
services would need to agree on what responsibilities they
will each take in different situations. If appropriate, the
operator may also consult with WorkSafe, the Environment
Protection Authority and with councils for adjacent areas.
The on-site activities would need to be planned to occur in
an integrated and effective manner whereby the operator
and emergency services are working together with
compatibility between people and equipment.
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Guidance Note Emergency planning
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Figure 3.1 – Example of emergency plan information for on-site issues
Storage area fire scenarios
•
•
•
•
Initial event: pump area fire
Detection arrangements and timing
Escalation event: single tank roof fire
Consequences: equipment damage and
personnel injury zones for initial and
escalation events
• O
perational response plan: actions to limit
operations and shutdown equipment
• On-site emergency response plan: assess,
mobilise, search and rescue, firefighting
• On-site command arrangements: notification,
evacuation etc
• Emergency services attendance plan
• Post-incident actions
3.3 Planning for off-site emergencies
The expectation is that response to major incidents
or uncontrolled events aims, wherever possible, to limit
the effects to on-site. The operator should also plan for
situations where a major incident results in far-reaching
consequences which could impact off-site locations.
This is required for all facilities unless the operator can
justify that the facility has no potential to cause harm
to health and safety or damage to property beyond
the boundary. The emergency plan must address any
off-site consequences and off-site response in relation
to major incidents and these aspects must be prepared
in conjunction with the relevant emergency services
and councils.
The operator must work with the emergency services
and the relevant councils on developing the off-site
planning aspects, which may include DISPLAN as prepared
under the Emergency Management Act 1986 (EM Act).
The parties need to agree on both the on-site and off-site
planning arrangements for any incident having both on-site
and off-site effects. For such a plan to work effectively,
the three parties need to clearly define areas of joint
cooperation and areas where individual parties take sole
responsibility. The MHF regulations do not prescribe how
responsibilities should be allocated between the parties;
it is necessary however to demonstrate to all parties that
the plan is workable, is clearly defined in terms of roles
and responsibilities and provides for an integrated and
effective response. This includes issues such as command
and communication channels, compatibility of equipment
and informing off-site populations (see Figure 3.2).
It may also be appropriate to involve adjacent industrial
facilities, particularly if these are also MHFs, if there would
be benefits from ‘mutual aid’ arrangements.
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Guidance Note Emergency planning
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Figure 3.2 – Example of emergency plan information for off-site issues
Storage and process fire scenario
Light industry
Main road
• Initial event: process unit explosion and missiles
• Detection arrangements and timing
• Escalation event: intermediate bund fire
• Consequences to people and property
• Operational response plan
• On-site command arrangements
• On-site command arrangements
• Emergency services attendance plan
• Emergency services off-site action plan
• Council action plan
• Post-incident actions
3.3.1 Using the Emergency Management
Manual, Victoria
In Victoria, planning for emergencies with off-site
consequences that may have an impact on the general
community, is carried out under the EM Act. Requirements
are outlined in the Emergency Management Manual,
Victoria which details responsibilities for the management
of emergencies, where ‘management’ is taken to include
planning, response and recovery. Operators of MHFs
should be familiar with these requirements, and take
account of them in their emergency planning.
The following is an outline of the provisions of the EM Act:
• Local incident management is provided at the scene
of the emergency. Management of consequences of
emergencies impacting on the wider community has
multi-layered support from a municipal level through to
regional, state and national level support as required.
• Coordination at each level within Victoria is the
responsibility of Victoria Police. The Municipal
Emergency Response Coordinator (MERC,
a nominated officer of Victoria Police) is responsible
for ensuring that planning is adequate for the risks
faced by the community.
• Councils have a large involvement in emergency
response, in that they provide equipment, facilities,
services and personnel to support the combat
agencies (emergency services). Councils also have
the prime responsibility for community recovery
from an emergency. To this end, each municipality
has a nominated Municipal Emergency Resources
Officer (MERO).
• Planning for consequences of emergencies affecting
the community is carried out by the Municipal
Emergency Planning Committee (MEPC) which
comprises representatives of the council and its
emergency services and is normally chaired by
the MERC.
• Incidents with off-site consequences should, if possible,
be planned for in consultation with all the necessary
agencies, personnel and committees. For the MEPC
to effectively plan for off-site impacts of potential major
incidents at an MHF, the operator would need to provide
adequate information to each person or group,
to enable appropriate planning to be undertaken.
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Guidance Note Emergency planning
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• Emergency services likely to be involved in the
response to any incident need relevant information to
enable them to pre-plan their response, based on the
types of event that are possible. Emergency services
also need to plan for an escalation of events to provide
the appropriate level of resources and management
for the maximum potential consequences. Issues that
require agreement between the operator and the
emergencies services include:
t ypes of equipment and materials to be used on-site
should be compatible with the equipment/materials
brought to site by the emergency services eg foam,
hose fittings. This compatibility should cover issues
such as water supply pressures (eg mobile pump
performance versus ring main design pressure).
Consultation with the water supply company may
also be needed
reporting structures and authorities need to be
agreed for cases when site and emergency services
personnel are working together to combat an
incident. This should include processes for hand
over of responsibilities and roles upon arrival
of the emergency services
expectations of the operator regarding emergency
services performance and vice versa. This should
include response time, numbers of available
emergency personnel, competence and realistic
expectations of what can occur during the
emergency etc
the need to inform the public about incidents that
may occur, how they will be notified of incidents if
they occur, and what to do in that event. In particular,
they should be informed about who they should
accept instructions from during an emergency.
In some locations there may also be a need to interface
the emergency plan under the MHF regulations with plans
required by other legislation. Examples are coastal sites
where there may need to be plans for management of
marine spills and wharves and jetties where there may
need to be interfaces with the emergency plans
of the port authority.
3.4 What range of scenarios need
to be considered?
The MHF regulations require the definition of ‘local
community’ and the scope of the emergency plan to
correspond to the area around the facility within which
the health and safety of people could be adversely
affected by a major incident. For the majority of facilities,
there is a spectrum of potential major incidents of varying
nature, likelihood and severity, each of which could lead
to different emergency planning.
The emergency planning process needs to consider the full
spectrum of incidents, and also uncontrolled events which
could lead to major incidents, so that the plan can be put
into effect for any major incident or uncontrolled event,
as required by reg 5.2.11. One approach is to base the
emergency plan on the ‘worst case scenario’ and a range
of other scenarios to represent the full spectrum. See the
guidance note – Hazard identification for more information
on the worst case scenario.
It may be appropriate (subject to meeting all of the
requirements in reg 5.2.9 and Schedule 11) to select other
ranges of major incident scenarios as the primary basis for
the emergency plan, if it can be shown that these scenarios
are the most appropriate for planning purposes.
This may require consideration of factors such as the level
of risk for which other types of emergency plans are made,
the nature of the overall risk profile in the area, the cost of
planning for extreme events and the need for meaningful
information and dialogue with the community.
For example, the local area emergency plan may be based
around natural disasters that could happen between once
per year and once every 100 years (see Figure 3.3). It may
be meaningless to develop an emergency plan around a
scenario not likely to occur in 1000 years but appropriate
for a less severe and more likely major incident, and
then include contingency plans, mutual aid agreements,
practical deployment procedures etc to assist in managing
a worst case scenario. For example, a realistic spill to a
bund for a full rupture of a 100 mm pipe, given installed
detection, remotely operated valves etc is say, 150 m3
an hour. The worst case scenario is a total tank loss
and full bund fire.
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Guidance Note Emergency planning
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Figure 3.3 – Scenarios to be used to formulate the local emergency plan
Multiple injury road accident
Frequent event
Small fire on-site
Major fire in area
Serious flood
Rare event
Major toxic release
Worst case MHF scenario
Extremely rare
Few injuries
MHF emergency scenarios
Multiple injuries
Other types of emergencies
The operator, involved workers, emergency services
and local councils should discuss the appropriate
range of scenarios for emergency planning purposes,
based on the results of the hazard identification and
Safety Assessment, and taking into account the above
considerations. The Safety Assessment may indicate
the appropriate scenarios to select by the shape of the
distribution of incident severity and likelihood. For example,
if the distribution is relatively ‘flat’ (different scenarios all
have roughly similar likelihood), this may indicate that the
appropriate range of scenarios for the emergency plan
needs to include the worst case scenario (see Figure 3.4).
The selection of scenarios on which to base the
emergency plan will influence how the local community
is defined and what information will be provided to them.
Hence care is required in making the appropriate selection,
and WorkSafe expects the operator to document and be
Far-reaching, multiple
injuries, escalation
to other sites
able to justify this selection in the Safety Assessment.
It may be appropriate to discuss with the wider community
before finalising these issues.
In considering which of the spectrum of scenarios are
most appropriate for the emergency plan, the operator
needs to bear in mind that the plan needs to incorporate
the potential effects on people both on-site and off-site.
Clearly, a significant scale event needs to be featured
in the emergency plan to reflect potential off-site effects
and to ensure the emergency plan is robust and credible.
The operator should consider the incident history, both
at the facility and within similar facilities, in arriving at
a justified selection of relevant scenarios for planning
purposes. It would be inappropriate to base emergency
plans on an event of a lower scale than is indicated
by industry accident history.
Figure 3.4 – Effect of severity-likelihood distribution on selection of emergency scenarios
Frequent event
Flat distribution:
use worst case scenario
Rare event
Curve distribution:
use range of scenarios
Extremely rare
Few injuries
Multiple injuries
Far-reaching, multiple injuries,
escalation to other sites
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Guidance Note Emergency planning
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Once the operator (in conjunction with the involved
workers, emergency services and the MEPC has selected
the appropriate emergency plan scenarios, the plan should
contain information and actions explicitly related to those
scenarios. This should include, for example, the means
of informing the community within the area if an incident
occurs, the nature of its effects and the appropriate
actions the community should take (shelter
in place, provisions for evacuation and treatment
of injured persons etc). However, it should also be robust
enough to be applicable to other potential scenarios not
specifically used in developing the plan.
3.5 Performance indicators
for emergency plans
The emergency plan, and the personnel and resources
that it calls upon, must be treated as control measures
under the MHF regulations. Clause 7 of Schedule 10
requires the operator to set performance indicators for
the effectiveness of the adopted control measures and
hence also for the emergency plan, including tests of the
effectiveness of the control measures, indicators of failure,
reporting of any such failures and corrective actions
to take.
Examples of performance indicators
• The number, training and competency/capability
of the on-site emergency response team.
• The time from raising an alarm to successful evacuation
of on-site personnel to a secure muster point.
• The maximum time for mobilisation of the on-site
emergency response team, to defined levels.
• The maximum time for attendance of the emergency
services, to defined levels (first response etc).
• The time taken to alert the local community in the
event of a major incident, and to take necessary steps
to evacuate from, and control access to, any seriously
impacted areas.
• The type, quantity, capacity and reliability of equipment
and supplies that may be used.
3.6 Testing the emergency plan
The MHF regulations (reg 5.2.10) require the emergency
plan to be tested at least every three years. If it is not
practicable to test all parts of the plan simultaneously,
several tests may be needed during the three year
period, at least one of which should be a major exercise
involving the emergency services, and possibly also
adjacent facilities, the local council and nearby residents.
The systems should be shown to function correctly
under simulated emergency conditions and not simply
during routine ‘off-line’ tests. Tests of the emergency
plan should be used to confirm that the following aspects
continue to function as required:
• ability to implement on-site and off-site emergency
responses effectively and according to goals
• alarm and communications systems
• call-out of internal/external emergency personnel
• critical emergency equipment.
3.7 Review and update
As the emergency plan is a control measure and
also a part of the SMS for the facility, the MHF regulations
(reg 5.2.12) require it to be reviewed and updated
in certain circumstances, including:
• if WorkSafe directs
• before a modification to the facility
• after a major incident at the facility
• when a test indicates a deficiency
• a change in the circumstances that formed the basis of
the Property Protection Assessment under reg 5.2.36
• if an HSR requests a review
• at least every five years.
The purpose is to ensure that the emergency plan is
updated if there is any reason to believe that it is no longer
fully appropriate to the facility, or no longer fully effective.
There is no explicit requirement in the MHF regulations
to update the emergency plan when there are changes
external to the facility, such as at adjacent hazardous
facilities or within the emergency services. However, there
is an obligation to review control measures to ensure that
the adopted measures continue to comply with reg 5.2.8.
Hence the emergency plan would need to be updated
in such circumstances, if the changes impact on the
effectiveness of emergency planning control measures.
Further, any agreements with third parties concerning
mutual aid arrangements, such as provision of additional
foam stocks and associated deployment procedures,
should be periodically verified.
A person should be nominated to have responsibility
for maintenance of the plan.
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Guidance Note Emergency planning
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4. Compliance checklist
The following checklist highlights the regulatory
requirements relating to emergency planning.
Table 4.1 – MHF regulations relating to emergency planning
Section
Requirement
Reg 5.2.9, 5.2.10
and 5.2.11
The operator must prepare an emergency plan addressing both on-site and off-site consequences of major
incidents, and including all matters specified in Schedule 11. It must be prepared in conjunction with the
emergency services having responsibility in the area of the facility, and (in relation to off-site consequences)
in conjunction with the council/s. Copies of the plan must be kept at the facility and forwarded to the emergency
services. The plan must be put into effect without delay if there is a major incident, or an uncontrolled event that
could be expected to lead to a major incident. In this event, the operator must immediately notify the emergency
services. The operator must test the plan at suitable intervals, not exceeding three years, taking necessary
steps to ensure participation of the emergency services.
The operator must notify the emergency services immediately of the occurrence of a major incident.
Schedule 11
Matters to be included in the emergency plan include details of the facility and its hazards, the command
structure and site personnel, notifications required, resources available, and procedures for safe evacuation,
containment and decontamination.
Schedule 12
The Safety Case must include a description of the emergency plan.
Reg 5.2.55
A draft of the emergency plan must be submitted to WorkSafe in the Safety Case outline
(see the guidance note – Safety Case outline for a major hazard facility).
Reg 5.2.9(2)
The emergency plan must be included among the control measures adopted under reg 5.2.8 ‘Risk control
measures adopted’, hence the emergency plan must comply with all provisions relating to control measures
(see guidance note – Control measures). This includes obligations to consult HSR and workers,
and to develop worker roles to assist the operator.
Reg 5.2.24
The operator must ensure that the local community is provided with information about the safety of the MHF,
including the means by which the local community will be notified of a major incident, and the action that
members of the local community should take.
5. Further reading
Standards Australia/New Zealand Standards HB76,
DG Initial Emergency Response Guide.
NSW Department of Urban Affairs and Planning (1993),
Hazardous Industries Planning Advisory Paper (HIPAP) #1,
Industry Emergency Planning Guidelines.
Queensland Chemical Hazards and Emergency
Management (CHEM) Unit and Queensland Fire
Service (1996), Emergency Plans: Guidelines for
Major Hazard Facilities.
UK HSE (1999). Emergency Planning for Major Accidents,
Control of Major Accident Hazards Regulations (HSG 191) .
UK HSE Buncefield Reports – Recommendations on the
emergency preparedness for response to and recovery
from major incidents.
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Guidance Note Emergency planning
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Further Information
Contact the WorkSafe Victoria Advisory Service on
1800 136 089 or go to worksafe.vic.gov.au
Related WorkSafe publications
Guidance note – Revision of a Safety Case
for a major hazard facility
Note: The information presented in this Guidance Note is intended for
general use only. It should not be viewed as a definitive guide to the law,
and should be read in conjunction with the Occupational Health and
Safety Regulations 2007. Whilst every effort has been made to ensure
the accuracy and completeness of the Guidance Note, the advice
contained herein may not apply in every circumstance. Accordingly,
the Victorian WorkCover Authority cannot be held responsible, and
extends no warranties as to the suitability of the information for any
particular purpose or actions taken by third parties as a result of
information contained in the Guidance Note.
Guidance note – Hazard identification
Guidance note – Consultation and the role of HSR
Guidance note – Control measures
Guidance note – Safety Case outline for
a major hazard facility
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