An integrated contingency plan (ICP) consolidates all of a facility's emergency response plans into one document and can eliminate overlapping information between multiple federal and state agencies, programs, and regulations. Having an ICP can offer advantages, such as streamlining emergency planning and training, reducing the time necessary to update and revise documents after a change occurs at your facility, and improving consistency in maintaining compliance with all programs applicable to your facility. Although switching from individual plans to an ICP at your facility can require investments of time, money, and other resources, there may be advantages for your environmental program management.
Maintaining individual emergency response plans (SPCC, SWPPP, groundwater protection plan (GPP), hazardous waste contingency plans, etc.) can also be advantageous to your program. For example, during inspections by regulatory agencies, the inspectors will only see the plan requested instead of all plans incorporated into the combined ICP document. Additionally, the agency may be on site less time during inspections as the plan would be more streamlined to the individual regulatory requirements as required by the program (i.e., RMP, SPCC, etc.). With plans that require a professional engineer (P.E.) certification (i.e., SPCC), having a P.E. certify to only the sections required by regulation is another positive reason to maintain an individual plan.
The bottom line is there are advantages and disadvantages to both an ICP and keeping plans individual or separate. Discuss your needs with your local Trinity consultant today on which approach best suits your facility, an ICP or individual emergency response plans. Please reach out to Anita Evenson in the Covington office at 859.341.8100 x116 for more information.