Our emergency response employees in both the U.S. and Canada have adopted and fully implemented the Incident Command System (ICS) at all levels. ICS is a comprehensive and practical system widely used nationally and internationally by both government and industry sectors to manage emergencies. It is a standardized, on scene, management system used for all types of emergency and non-emergency events. Using ICS, Plains engages employees, first responders, regulators, response organizations and contractors in a significant number of emergency response training exercises annually to test the effectiveness of our plans and procedures. We work closely with first responders in the communities where we operate to share information about our pipelines, terminals, trucking and rail, and to enlist their assistance in reducing risks related to possible emergency situations.
Industry-wide Preparedness Efforts
We strive to be an industry leader in emergency response. We actively participate on multiple emergency preparedness committees through trade associations, including the Association of Oil Pipelines and the American Petroleum Institute. Together, we develop standards, educate emergency responders and strengthen programs throughout the United States and Canada. Plains employees also participate on area contingency planning committees, local community emergency preparedness committees and other committees across North America. In addition, we engage with members of the communities within our operations to keep them informed of our activities and ensure their safety.
Training and Exercises
Because safety is such an integral part of our culture, we have stringent training programs for our employees. Training and exercises take place on an annual basis to make sure Plains responders including personnel from our operating areas to leadership in our corporate offices are capable of responding to an incident or emergency.
In 2020, over 3,000 employees completed training dedicated to health, safety and the environment. Key areas addressed through training include hazard management, incident prevention, fall protection, personal protective equipment, process safety management and emergency response. Employees also received training related to the COVID-19 pandemic and safely returning to the workplace.
Our HSE Emergency Response and Security Management team of dedicated emergency response professionals focuses on providing employees with proper training and develops response strategies and other processes to effectively manage and mitigate emergency situations, should they arise. The Emergency Response and Security Management team ensures employees are trained to utilize ICS so they can work effectively within the Unified Command structure, alongside federal, state, provincial, Indigenous and local responders.
We train our employees how to respond to emergencies through regulated full-scale and table-top exercises, which allow us to practice and assess our preparedness to a variety of scenarios in all seasons and weather conditions in a safe and controlled setting. Scenarios may involve issues such as leaks and fires caused by various impacts, including tornados, flooding or wildfires, or third-party line strikes to our infrastructure. Plains will use and physically deploy spill response equipment on land and on water to simulate a response to a hypothetical product release. These regulated exercises are required for each Emergency Response Plan (ERP) annually.
Exercises are opportunities for us to practice the procedures outlined in our ERPs and identify areas for improvement. These exercises are also an opportunity for us to invite and practice responses to various scenarios with local first responders, local authorities, Indigenous Communities and other stakeholders. Regulatory officials representing the jurisdictions in which we operate participate in our exercises and evaluate our employees on their response efforts. The lessons learned from these training exercises allow us to continuously improve our emergency response efforts and minimize potential impacts to the environment, the communities in which we operate, and our customers.
Stakeholder Engagement and Continuing Education
Communication with the public, first responders, Indigenous Communities, local authorities and government agencies is a critical component of our EMP. We communicate with these stakeholders annually during the development and maintenance of our ERPs in order to confirm roles and responsibilities, and to ensure key contact information is up-to-date in the event of an emergency. Consultation and public outreach also allows us an opportunity to provide information surrounding our operations and take area-specific considerations into account when developing and maintaining ERPs.
Continuing education is critical to ensuring everyone who is potentially involved in an emergency understands the various safety procedures that are in place. In order to ensure first responders can respond to emergency situations safely and effectively, the following information through continuing education sessions:
- Company operations and specific area operations information applicable to the audience.
- Details surrounding our emergency management program including ERPs, equipment, training and exercises, spill control points (if applicable) and the public consultation program.
- Product hazard awareness information associated with an emergency related to our operating assets.
- Practices and procedures to be followed in event of an emergency including details for roles, responsibilities and capabilities as well as communications protocols.
Emergency Management Program
Our Emergency Management Commitment Statement indicates that we are prepared to manage all emergencies. Our Emergency Management Program (EMP) is focused on considering all hazards when identifying and mitigating risks, and personnel are ready to respond quickly and safely to an unplanned event or incident.
Our EMP meets or exceeds all applicable federal, state and provincial regulatory requirements in addition to our internal standards, and is governed by our Operations Management System (OMS).
The Emergency Management Program is built on four integrated pillars:
Prevention and Mitigation – Identify and manage hazards to avoid incidents or minimize their impacts.
Preparedness – Train personnel and other responders on the tools necessary to perform their responsibilities.
Response – Help employees respond safely and effectively in the event of an emergency.
Recovery – Assist with the recovery of the environment, communities and operations
Purpose of the Emergency Management Program
Our Emergency Management Program is built on the integrated foundations of the four pillars listed above and will:
- Meet or exceed all regulatory and legal requirements
- Consider all hazards when identifying and mitigating risks
- Ensure employees have appropriate emergency preparedness, response training and resources, including spill response equipment and emergency response service providers
- Ensure emergency response is coordinated with regulators, first responders, government agencies and Indigenous Communities and to promote Unified Command
- Ensure the set objectives are consistently met during every response
- Integrate and align with corporate commitments, processes, programs and procedures as part of the Operations Management System
- Continue to improve through lessons learned
Emergency Response Plans
All Plains Emergency Response Plans (ERPs) and first responder activities for our regulated pipelines and facilities are coordinated through the overarching Emergency Management program.
We have federal-, state- and provincial-governed ERPs and have established site-specific plans for our areas of operation.
Emergency responses are guided by our ERPs which are required by regulation and include the following components:
- Immediate actions to protect worker and public safety
- Criteria for assessing emergency situations, including information about potential hazards
- Procedures for mobilizing personnel and other responders
- Information about stakeholders in order to immediately notify anyone who may be potentially affected by the incident
- Methods for establishing communication and coordination between Plains and other responders
Our ERPs have established emergency planning zones (EPZ) or a calculated Worst Case Discharge (WCD). For Canadian Operations, an EPZ is determined by using approved methodology set out by the Alberta Energy Regulator (AER), the Canadian Association of Petroleum Producers (CAPP). Our risk management protocols include the engagement of key stakeholders to identify hazards, assess risks and develop controls to ensure protection of the public and the environment. For US Operations, the WCD is determined by our Integrity Risk program, Risk Intelligence Platform (RIPL) which uses the approved methodology set out by regulators, PHMSA & EPA.
How to Use the Emergency Response Plans for our Canadian Assets
Our emergency response plans are in line with the Canada Energy Regulator (CER) issued order MO-006-2016 which requires CER-regulated oil and gas pipeline companies to publish emergency response plans. The public’s desire to have more information about emergency management is in line with our commitment to clear communications and transparency to stakeholders. Please click here for more information regarding our ERPs for our Canadian assets.