As we have mentioned before in postings on this website, there are many lessons to be learned from this unfortunate oil spill in the Gulf of Mexico. 

It is important for our readers and your organizational crisis management team members to find meaningful lessons from this tragic incident,  and, to observe both the strengths and weaknesses in the emergency response plan now being implemented by BP.  We do not believe that this means that your organization has to be part of the oil industry in order to find those meaningful lessons – nor does the learning process limit itself to only environmental compliance issues.

In this posting, we would like to focus on what we believe to be one of those lessons to be learned– i.e. be aware of the potential outcomes from writing a less than complete or realistic crisis management and emergency response plan for your organization, and, open your scope of considerations for potential company specific and relevant risk events that will affect both the business continuity plans for your organization, as well as,  the potential relevant  impact such an event will have on the community and environment surrounding that organization.

To that point we would like to point your attention to a recent article in USA Today, where Rick Jervis wrote that the 582-page document submittal from British Petroleum, (BP), titled “Regional Oil Spill Response Plan — Gulf of Mexico,” was approved in July by the federal Minerals Management Service (MMS). The report offers technical details on how to use chemical dispersants and provides instructions on what to say to the news media, but it does not mention how to react if a deep-water well spews oil uncontrollablyRead Richard Jervis’s article in full…..and remember to utilize some of the useful links in that article leading you to more timely information on this event.

Additionally, this emergency response plan prepared by BP mentions almost none of the techniques recently attempted by BP to contain the spewing well in that plan.  

A statement that seems to sum the lack of readiness in BP’s emergency response plan comes from Representative Nick Rahall (D-West Virginia), chairman of the House Natural Resources Committee, which is investigating federal oversight of oil spills, where he said,  “These oil spill response plans suffer from what I would consider a ‘failure of imagination”.  It seems to me that there should be a Plan B, C and D in place before the accident occurs, not created in haste while millions of gallons of oil are spewing into the Gulf.”

Another aspect of BP’s plan that we would never want to be part of any of our reader’s organizational risk management plans has to do with a simple “cut and paste” methodology leading to a “boilerplate” approach to writing such plans for our own companies.  Clearly there is risk in this approach, and while, there are some applications where you can justify similarities to the point that repeating certain language does make sense, it is much more obvious that you can become complacent with this “cut and paste” approach to the point of  missing critical issues and response methodologies necessary to mitigate unforeseen events.  BP’s emergency response plan seems to be a strong example of taking that risk.

Rick Steiner, a former University of Alaska marine scientist and an oil spill response consultant who has reviewed the plan, observes a similar “boilerplate” pattern in BP’s plan, where Mr. Steiner states, “Parts of the document read like boilerplate used by BP from region to region and underscores the energy company’s inability to adequately prepare for a major spill in deep water …”

And to further prove his point, and in a recent posting on the Homeland Security Newswire website, Mr. Steiner points out that in a section titled “Sensitive Biological & Human-Use Resources,”…. the plan lists “seals, sea otters and walruses” as animals that could be impacted by a Gulf of Mexico spill — even though no such animals live in the Gulf.  Read more ….

In further response to BP’s disaster recovery and control efforts, the White House has already signaled an end is needed to the “cozy relationship” that federal regulatory agencies have seemingly created with BP. Perhaps another important lesson to be learned here as well  – e.g. you never want your organization to be in such a situation where such negative attention is paid to your company.  Read more….

Please pass this posting along to your enterprise risk management team members.

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