3.3 A Regulatory Review must be conducted to identify requirements of all applicable regulations and to ensure the requirements are addressed in the Emergency Response Plan. The review must be updated as new regulations change and as part of the annual plan review.
3.4 A Risk Assessment and Vulnerability Analysis (RAVA) must be conducted by a cross-functional team and documented using the Risk and Vulnerability Analysis tool in Attachment A1. Results must be included in the Emergency Response Plan or attached as a supporting document.
a. The assessment team should include functional representatives from EHS, Occupational Health, Security, Facilities, Human Resources, Logistics, and Operations, if present on site.
b. The potential impacts to people, property (including the environment), and continuity of business operations must be considered for each of the risk scenarios with RAVA scores of 1 or more.
c. The ERP and the Risk Assessment and Vulnerability Analysis must be reviewed and updated as part of the annual review of the site’s emergency planning and response program or more frequently as facilities and operations change.
3.3 A Regulatory Review must be conducted to identify requirements of all applicable regulations and to ensure the requirements are addressed in the Emergency Response Plan. The review must be updated as new regulations change and as part of the annual plan review.3.4 A Risk Assessment and Vulnerability Analysis (RAVA) must be conducted by a cross-functional team and documented using the Risk and Vulnerability Analysis tool in Attachment A1. Results must be included in the Emergency Response Plan or attached as a supporting document.a. The assessment team should include functional representatives from EHS, Occupational Health, Security, Facilities, Human Resources, Logistics, and Operations, if present on site.b. The potential impacts to people, property (including the environment), and continuity of business operations must be considered for each of the risk scenarios with RAVA scores of 1 or more. c. The ERP and the Risk Assessment and Vulnerability Analysis must be reviewed and updated as part of the annual review of the site’s emergency planning and response program or more frequently as facilities and operations change.
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