ERAP Readiness and Review

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ERAP Readiness and Review Copyright 2020

Transcript of ERAP Readiness and Review

Page 1: ERAP Readiness and Review

ERAP Readiness and Review

Copyright 2020

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ObjectivesAt the end of the Emergency Response Assistance Plan (ERAP) Readiness and Review, you will understand:

the history of the TDG Regulations and ERAPs

who is ERAC

the purpose and content of an ERAP

plan implementation, response tiers and reporting requirements

roles and responsibilities of the various stakeholders

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TDG History

1979: A train derails in Mississauga, ON, involving 11 LPG rail cars and 1 chlorine car; 250,000 people affected

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TDG History

Mississauga, Ontario – 1979https://www.youtube.com/watch?v=QwxyXdhM55c

https://www.youtube.com/watch?v=O8jFrHARjUo

https://www.youtube.com/watch?v=hEi2Do9tNPI

Formation of the Grange Commission, resulting in a report with recommendations for the transportation of dangerous goods

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Transportation of Dangerous Goods (TDG)

The TDG Act and Regulations are intended to promote public safety during the transportation of dangerous goods

TDG Act, 1980 is a result of the Mississauga derailment

Part 7 – ERAP regulations came into effect in 1985, resulting in the formation of ERAC by the Canadian Propane Association

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TDG History Repeats

July 6, 2013: a 73-car train carrying Bakken crude oil derailed in downtown Lac Mégantic, QC

47 people died

40 buildings destroyed

63 of the 72 tank cars derailed and caught fire immediately

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What is ERAC?

Emergency Response Assistance Canada (ERAC) is a not-for-profit, member-funded cooperative,

built by industry for industry

1986: ERAC is founded under the name LPG Assistance Corp. when the ERAP regulations come into effect

1997: Rebranded as LPG Emergency Response Corp.

2014: Begin operating under the trade name of ERAC

ERAC is a subsidiary of the Canadian Propane Association

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Who We Are16-member Board of

Directors

16 full-time staff

370+ Plan Participant members

26 response teams

34 specialists (TA/RMA)

Network across Canada

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UN1075 LPG

UN1978 Propane

UN1077 Propylene

UN1011 Butane

UN1012 Butylene

UN1969 Isobutane

UN1055 Isobutylene

and

UN1010 Butadiene 1.3 Stabilized

ERAP: Flammable Gases By Road/Rail

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ERAP: Flammable Liquids By Rail

UN3475 Ethanol and Gasoline Mixture, N.O.S.

UN3494, Petroleum Sour Crude Oil, Flammable

UN1987, Alcohols, N.O.S.

UN1170 Ethanol

UN1202 Diesel Fuel

UN1203 Gasoline

UN1267 Petroleum Crude Oil

UN1268 Petroleum

Distillates, N.O.S.

UN1863 Aviation Fuel

UN1993 Flammable Liquid, N.O.S.

UN3295 Hydrocarbons, Liquid, N.O.S.

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ERAC’s Responsibilities

As primary contractor, ERAC:• manages and administrates a program on behalf

of its Plan Participants to meet regulatory compliance with SOR/2019-101 (Emergency Response Assistance Plan), Part 7 of the TDG Regulations;

• provides a 24/7 ERAP telephone number;• trains, assesses and approves all response sub-

contractors listed in the ERAP;• provides technical advice by phone and on site

during an incident; and• mobilizes response resources as required.

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Plan Participant Members

Our Plan Participants are the members who fund ERAC’s preparedness and response services

The fees paid to ERAC to maintain your approved ERAP are based on volumes of product transported by either road or rail

The program ensures both small and large companies can access a quality program to meet regulatory compliance

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Plan Participant Responsibilities

Have you readand understood your ERAP?

Have you readand understoodyour Dangerous Goods Preparedness and Response ParticipationAgreement?

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Plan Participant Responsibilities

Review, monitor and submit your ERAP application through the Transport Canada ERAP Online Services (EOS) system

Understand Part 7 of the ERAP regulations, including but not limited to, plan implementation

Ensure your ERAP Reference Number & the ERAP telephone number are listed on all required shipping documents

Keep your organization’s primary and emergency contacts up-to-date with ERAC

Answer your phone when called to implement an ERAP

Approve ERAP implementation to an appropriate tier level

Provide safety data sheet(s) (SDS) at time of ERAP implementation

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ERAP Regulatory Changes

In 2019, Transport Canada released changes to the Transportation of Dangerous Goods (TDG) Part 7 Regulations, published in the Canada Gazette Part II, Vol. 153, No. 9

• These changes came into force on June 1, 2019

The regulations will be enforced as of March 1, 2020; the 9-month period allows for appropriate balance between achieving safety objectives and accommodating the implementation of the new regulatory requirements

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What is an ERAP?An emergency response assistance plan (ERAP)

describes what to do in the event of a release or anticipated release of certain higher-risk dangerous goods while they are in transport

Each plan is specific to certain: • dangerous goods• modes of transport (air, rail, road or marine)• means of containments (containers or packaging)

used to hold the dangerous goods• geographical areas in which the dangerous goods

will be transported

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What are ERAPs For?To assist emergency responders or carriers

ERAPs list specialized personnel and equipment needed for responding to an incident

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Who Needs an ERAP?

Persons with ERAPs are involved in the transportation of certain dangerous goods above the quantity specified in the Transportation of Dangerous Goods (TDG) Regulations

• Flammable gases: ERAP required >3000 L

• Flammable liquids: ERAP required (tank cars) >10,000 L

They are often producers, manufacturers or importer of dangerous goods

• In special cases, persons who aren't required to have an ERAP may still have an approved plan

Find out if you need an ERAP

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Applying for an ERAP

To get approval for an ERAP, you must apply to Transport Canada. Transport Canada will review your application to ensure the ERAP can be implemented and will be effective in responding to a release or anticipated release of dangerous goods

You are required to apply for approval of:• a new ERAP• changes to an ERAP, according to section 7.5 of

the Transportation of Dangerous Goods (TDG) Regulations

• renewal of an ERAP

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How to Apply for an ERAP

Apply online

You must apply for approval of an ERAP using ERAP Online Services (EOS)

• Transport Canada no longer accepts PDF forms, nor can you make changes by email or phone

Guide to apply for approval of an ERAP

ERAC will work closely with you through the application process to ensure your ERAP needs are met

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Delegated ERAP Writer

Once you have registered your company, you must appoint ERAC as a Delegated ERAP Writer in EOS

ERAC will then be able to assist you:

• Write your ERAP and/or potential incident analysis (PIA)

• Complete certain sections of an ERAP application on your behalf

• Prepare and include supporting documents in your ERAP application

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Next Steps

Once you have registered on EOS and designated ERAC as your ERAP Writer, the approximate time for the approval of your ERAP is 20 business days

Once your ERAP application has been approved, Transport Canada will send you an ERAP approval letter with your reference number, description and conditions of approval

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ERAP Content

The ERAP describes the specialized response capabilities, equipment and actions that will be used to support a response to incidents involving dangerous goods

The plan also addresses roles and responsibilities, plan implementation, responder training, response exercises, equipment and other criteria

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Maintaining Your ERAP Approval

While your ERAP is valid, you must ensure it can be implemented and will be effective at responding to a release or anticipated release

ERAC, on behalf of the Plan Participant, will ensure the ERAP is maintained and conduct response location assessments to ensure the ERAP always meets regulatory requirements

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Competency is Required of All ERAC Responders

We Train We Assess We Approve

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Training and ExercisesAs part of its program, ERAC conducts the training,

assessment and approval of all responders named in the ERAP. This is done through:

• ERAC Learning Management System (20 modules)

• annual Regional Training and Assessment (live transfers)

• annual equipment assessment

• National Training Forum every two years

• development and sharing of procedures

• quarterly responder newsletter

• Safety Bulletins (e.g., lessons learned, etc.)

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Training Based on NFPA Standards

ERAC’s training program was designed to meet national industry standards, with the support of industry and national firefightingagencies

ERAC’s training meets or exceeds all applicable NFPA (58, 472), CSA and CPAstandards

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Shipping Documents

Once your ERAP is approved and valid you can use your ERAP reference number and the ERAP telephone number on a shipping document. 3.5(1)(f) of the TDG Regulations also requires a 24-Hour Number be on the bill of lading (BOL)

The consignor should ensure this information is correct and not misleading

ERAP Telephone Number 1-800-265-0212

ERAP Reference 2-0010-XXX OR 2-1933-XXX

24-Hour Number 1-XXX-XXX-XXXX

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ERAP vs. 24-Hour Number

The ERAP Telephone Number, formerly known as the ERAP activation telephone number, is an emergency number at which technical and/or emergency response advice is provided by ERAC as soon as possible

The 24-Hour Number is the number at which the consignor can be reached immediately for technical information about the dangerous goods in transport, without breaking the telephone connection made by the caller (paragraph 3.5(1)(f) of the TDG Regulations)

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ERAP Telephone Number

ERAC provides technical advice through the ERAP telephone number in cooperation with STARS Emergency Link Centre in Calgary

This number is monitored and answered 24/7

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24-Hour Number

You can register online to use CANUTEC's free, 24-hour emergency telephone number on your dangerous goods shipping documents

If you need more information or have questions, please contact CANUTEC Registration Services at 613-947-5048 or [email protected]

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During an Incident

In an incident, an event that causes an actual or anticipated release of the dangerous goods in the course of their handling or transporting and endangers or could endanger public safety, we must:

• gather information about the incident (ERAC Home Base Coordinator (HBC)),

• determine the actions you will take to respond (jointly by HBC and Plan Participant), and

• implement your plan (Plan Participant).

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Release of Dangerous Goods

Examples of a release:

rollover of a highway tanker with dangerous goods spilling from the manway

overfill of a means of containment, causing a spill to the ground

a bottom outlet valve that was not secured, causing a spill to the ground

a load-shift of dangerous goods, causing a spill to the ground

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Anticipated Release of DG

Examples of anticipated release:

a tanker has rolled over in a ditch and the means of containment is not in its intended orientation, with all four sides not visible

a rail car has been involved in a sideswipe

a means of containment is exposed to a fire or unusual temperatures

a faulty or damaged gasket or valve

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Duty to Take Reasonable Emergency Measures

A person who has the charge, management or control of a means of containment (often the carrier) has a duty to respond under section 18 of the TDG Act

This includes a duty to report and to take reasonable emergency measures

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Duty to Report an Incident

The person who has the charge, management or control of a means of containment must make an ERAP incident report to the person at the ERAP telephone number, required to be included on a shipping document

This report is intended to inform the person who holds the ERAP that a release or anticipated release has occurred, so that they can respond based on the tiered approach

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ERAP Incident Report

Through the ERAP telephone number (1-800-265-0212), the ERAC Home Base Coordinator (HBC) receives and records the ERAP incident report

The HBC also provides technical and emergency response advice by phone during this process on your behalf

The HBC calls the Plan Participant once the ERAP incident report is made

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Home Base Coordinators and Technical AdvisorsAll trained in, but not limited to:

NFPA 472 – Hazmat Technician

NFPA 472 – Tank Car Specialist

NFPA 472 – Intermodal Specialist

NFPA 472 – Highway Transport Specialist

NFPA 472 – Employee Specialist A (LPG/FL)

NFPA 472 – Flammable Liquids firefighting

NFPA 1001 / 1081 – Firefighter

Crude by Rail – Firefighting

Incident Command System (ICS) Level 300

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ERAP Incident Evaluation

During the ERAP report, the HBC will ask 5 preliminary assessment questions:

1. Is there a release or anticipated release?

2. Is there damage to means of containment?

3. Is a transfer required?

4. Is the public in danger or in potential danger?

5. Is the caller asking for assistance?

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Implementing Your ERAP

As soon as you are made aware of an incident involving your dangerous good, whether by the ERAP incident report or other means, you must decide how you will respond to the release or anticipated release

The ERAP must be implemented in response to a release or anticipated release

Should the ERAP not be implemented, Transport Canada may revoke the approval of the plan

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HBC Recommendation

After the ERAP report is made and the preliminary assessment questions documented, the HBC, in cooperation with the Plan Participant, will implement the ERAP to either a tier 1 or tier 2 response based on the situation and request of caller

The Plan Participant has final approval as to which level the ERAP will be implemented

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Implementing a Tiered Response

Implementing the plan does not necessarily mean that emergency response resources found in your ERAP must be sent to the site of the release or anticipated release

An ERAP can be implemented to tier 1 or tier 2

ERAC will assist you to determine to which tier you need to implement your ERAP, based on the actions that need to be taken

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Tier 1 Response

Tier 1 means that you are responding, generally by telephone, by remotely monitoring the response to the release or anticipated release

None of the emergency response resources found in your ERAP are brought to the site of the incident

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Remote Monitoring

Definition: To monitor the release

or anticipated release while not

being on site. Despite not being at

the site of the release or anticipated

release, you should be actively

involved in the conversations and

decisions that involve the dangerous

goods and/or the means of

containment.

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Tier 2 Response

Tier 2 means that you are responding by monitoring the response to the release or anticipated release on site or remotely, and bringing ERAP emergency response resources to the location of the release or anticipated release

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Emergency Response Resources

Definition: People and/or

equipment found in the

ERAP that can be used to

respond to a release or

anticipated release

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Emergency Response

Once the Plan Participant approves implementation to tier 2 response, the HBC mobilizes resources that are found in ArcGIS ERAC Resource locator

If the Plan Participant cannot be reached, the HBC will implement the ERAP on their behalf

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ERAC Resource Locator

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ERAP Implementation Report

In accordance with section 8.22 of the TDG Regulations, each time an approved ERAP is implemented to tier 1 or tier 2, an ERAP implementation report must be made as soon as possible to CANUTEC

The HBC will make the implementation report to CANUTEC by phone once the Plan Participant approves to which tier the ERAP is implemented

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ERAP Implementation Report

Tier 1: implementation report must be made as soon as possible after a request for technical or emergency response advice is addressed, if ERAP emergency response resources are not needed at the site of the release or anticipated release

Tier 2: implementation report must be made as soon as possible after a request for technical or emergency response advice is addressed and emergency response resources are mobilized

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Response Actions

technical advice

site safety

containment

confinement

flaring and purging

transfer

fire suppression support

ERAC provides the following services during an incident:

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During an Incident

The HBC will receive updates from technical advisors or remedial measures advisors in the field and update the Plan Participant by phone or email on the activities taking place at the scene

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After an Incident

Once an incident is over, ERAC writes a summary report for the Plan Participant and conducts an after action review, which includes debriefs with various stakeholders involved in the response

The summary report is provided for your records

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Post-Incident Debrief

Final report with recommendations and lessons learned

Follow-up with involved parties

Apply learnings to future training

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How We Do It…

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Pillars of Service

Dangerous Goods

Response Plans

ERAC Responder

Training

First Responder

Training

Dangerous Goods

Emergency Response

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Dangerous Goods Response Plans

We develop emergency response plans, including emergency response assistance plans (ERAPs), environmental emergency (E2) plans and spill contingency plans

We can also develop drills and exercises for these plans

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ERAC Responder TrainingERAC trains, assesses and approves a network of over 300 responders• 26 teams• 28 RMAs• 6 TAs • 5 HBCs

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First Responder Training

LPG Firefighting

• Awareness (online)

• Level 1 Operations Firefighting Training

Flammable Liquids Firefighting

First responder training at TransCAER events

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Dangerous Goods Emergency Response

ERAC responds to incidents, and manages, advises and protects the safety of Plan Participant products, people, equipment and reputations

We do this day or night, coast to coast, 24 hours a day, 365 days a year

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Summary

Operating for 32 years, incident free

Proven national ERAP preparedness and response

program

Equitable access to a quality program

Excellence in training

Focus on continuous improvement

Collaborating with industry and first responders for

safer communities

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Copyright 2020

Contact Information

If you have any questions, feel free to contact us:

By email at:

[email protected]

Visit our website at:

• www.erac.org

Phone us at:

• 403-543-6501