The Netherlands accommodates about 400 companies that fall under Seveso regulations according to their risk profile. The risks that these companies pose to their surroundings require special attention from both the companies themselves and the government.
The emergency services need to be able to rely on the quick availability of a company representative in case of an emergency – a representative with thorough knowledge of company processes, dangerous chemicals, the set-up of the company’s emergency response and a strong mandate to take decisions on the company’s behalf. For high-tier Seveso companies with appointed company fire services this ER role is mandatory.
Correctly fulfilling this key role demands specific knowledge and skills. Consultancy Kappetijn Safety Specialists and H2K, training provider for public and private fire services, have developed a basic training programme for company representatives. This was done in close cooperation with the Unified Industrial and Harbour Fire Service of Rotterdam, which performs municipal and industrial fire services in the Rotterdam harbour and knows the features and needs of Seveso companies like no one else.
The need to train company representatives (aka incident coordinators), focusing on their key role in crisis management, is clear: what you rarely do, you rarely do well. Crisis management is not the core business for company managers and their staff, and crisis management is not the same as regular company management with a little added time pressure and stress. In short, in real life the connecting link between the crisis management of the government and that of the company is often uneducated and scarcely trained. The position is generally covered by officials like the commander of the company fire brigade, the head of the company emergency services, the calamity coordinator or a senior team leader. In high-risk companies in the Netherlands, the position of company representative is often formalised based on Article 31 of the Safety Regions Act. This article in Dutch law regulates the size and tasks of the company fire brigade in companies that have been ordered to maintain a permanent company fire brigade and professional emergency service. In this setting, the position of the company representative has existed for about 20 years, but so far basic education and training to give these officials the necessary skills to act with decisiveness within the game of crisis management has been lacking. That situation is about to change.
Position in the chain of command
For external and public emergency services, incident control is a goal in itself. Incidents cause public disruptions, and the goal is to stabilise and normalise the situation as quickly as possible. The fire needs to be fought, the injured need to be saved and tended to, and chemical spills need to be stopped. Private organisations also have other goals and other interests. They need to restore the business continuity, limit financial consequences, secure product quality and delivery reliability and minimise image damage and liability. With these aspects of a larger incident, the company representative comes into view.
Initial action during incidents and calamities lies with the company emergency organisation, but as soon as the external emergency services are on site, they take the lead over the incident. They take decisions based on the common interest: stabilising the incident and creating a safe environment. It is important for the company representative to realise their position with regard to the leadership of the external emergency services. For the company, they have the mandate to take all the necessary decisions. For the public emergency services, they are the accepted company representative who provides all the important information but who ‘merely’ has an advisory vote in the choices regarding incident-control tactics. At the end of the day, the mayor is responsible for the course of incident control and consequence management, not the company representative nor the company crisis-management team.
In principle, no big (industrial) organisation can go without a company representative, a trained official who is on location, or available by phone and on call, and who can be present on site within 15 to 30 minutes after the alarm, day or night. The company representative fulfils a key position for the company with any calamity or crisis. They have crucial company knowledge and can disclose information that is important to the decisions of the emergency services, and they have the mandate to take decisions within the company, on behalf of the management. Their actions and decisions matter and decide the degree of impact on the company and the surroundings: the duration of disruption to business continuity, the long-term consequences for the environment, the gravity of the loss of image and also how the shareholders judge the handling of the incident by the company – has the enterprise acted professionally or not? Is the licence to operate at stake or not?
This role requires a decent basic education and focused training. An employee that performs well as a business manager is not automatically a good crisis manager. The chaos surrounding an uncontrolled incident or fire is totally different from a structured and controlled company process of which they are the leader. And there are other issues at stake. In their daily job, the manager can encounter small percentages more production or less costs. In a crisis situation, on the other hand, it may become a question of whether production will be halted for three days, three weeks or three months. The stress levels and the time pressure in a crisis situation are also different from those in a normal company routine and day-to-day work encounter.
Because there was no education available for the position of company representative, Kappetijn Safety Specialists and H2K have joined forces to launch a basic training programme, a course that is expected to fulfil a great need within company life, partly in light of the reinforcement of the Dutch Seveso guidelines in 2015. As a result of the new guidelines, Dutch Seveso companies have to monitor a larger risk profile. And companies with an appointed fire brigade will be inspected more intensively, partly on the correct education of people with a role within the emergency response organisation. Companies will be compelled to examine their internal emergency service critically, and to invest in an adequate liaison between corporate crisis management and external services. The developers of the education programme found a partner in the Unified Industrial and Harbour Fire Service (UIHFS) in Rotterdam while adjusting the contents of the course material to the specific needs of the companies of the Rotterdam harbour and industry area. The UIHFS has 65 industrial member companies, mainly in the Seveso categories including five refineries. In all industrial emergency response organisations, the position of company representative is of the upmost importance.
The training programme runs over five days, the last of which is at a training centre, and has already been performed for four companies: MSD/Aspen (Pharma production, Seveso, two sites), RWG (Container logistics, Seveso & ISPS), NRG (Nuclear facility) and Avebe (Potato starch production, Seveso, two sites).
Following modern standards, the education and training programme should be certified according to an independent quality hallmark, e.g. Joiff. The certification and quality guarantee should cover the structure and content of the training programme, the professionalism of the instructors, the facilities used and the embedding of the training programme in all layers of the company’s emergency-response and safety-management system. This guarantee gives companies the reassurance that they are not investing in a paper tiger with this training but in a professional and quick-witted connecting link, on whom the company can rely in an emergency situation.
‘It’s about expectations: large responsibilities call for solid training’
Avebe is a production, enhancement and development company in the field of potato starch with facilities in the Netherlands, Germany and Sweden. Avebe derives starch and protein from potatoes and brings these to food, animal and industrial markets. Facilities in the Netherlands and Sweden fall under Seveso legislation because of the use of large amounts of hazardous chemicals in the production process. Because of more stringent legislation and company growth, Avebe updated and modernised the set-up of the Dutch emergency response structures, starting on the production site at Foxhol (Groningen). Instead of different teams on site for firefighting, chemical response, first aid and evacuation, the company has combined the first response in a team of First Responders with guaranteed availability on site, 24/7. Next to this ‘concentration of tasks’ in one FR team, the availability of the company representative (at Foxhol: de Calamity Coordinator) was guaranteed. This means that in case of an on-site emergency for which a duty officer of the external fire services is alarmed, there is always a representative of the site management available with site-specific information about people and contractors on site, chemicals in process and storage, business and logistic processes, available response capabilities, planning and so on.
The position of company representative at Avebe is fulfilled by members on middle-management level. The group comprises four members and will grow to six or seven. Availability is guaranteed 24/7 through a duty roster, and the response time to get to the site during evenings and weekends is 60 minutes.
Sandy de Bies is head of the HSEQ department. She comments on Avebe’s decision to choose the education and training programme for the crucial position in the emergency response set-up: ‘We are a 24/7 business with a high hazard risk profile. We aim for 100% prevention of incidents but must prepare for them to happen. Incidents not only happen on Tuesday morning during regular work hours, with nice weather and all people available on site. Incidents can also happen on Saturday night during bad weather in winter, with only production teams on site. As employer we promise to our workers, staff, contractors and guests that there will be sufficient emergency response capabilities on site. The availability of the Company Representative is part of that promise. Part of such a promise is that people are prepared for their tasks with equipment, transport, PPE, planning and procedures but most of all with proper education and training. First Responders are trained for their operational tasks to a modern standard, based on the risk profile of the site. The same goes for Company Representatives: we expect them to be there to support the first responder team, to connect to the external fire and rescue services and to think and act in the best interests of the company. We put business continuity dilemmas in the hands of the Company Representative. With such expectations we have to offer proper education and training programmes.’