Drafting One Integrated Emergency Response Plan to Meet All Applicable Plan Requirements: Regulatory Support Has Finally Arrived, 1997 Environmental Conference Proceedings
On June 5, 1996 the National Response Team (“NRT”) -which is comprised of representatives from the Environmental Protection Agency (“EPA”), Department of Transportation (“DOT”), Department of Labor, Department of the Interior, Occupational Safety and Health Administration (“OSHA”), U.S. Coast Guard (“USCG”), Minerals Management Service (“MM!?‘), and Research and Special Programs Administration (“RSPA”) - published guidance that provides express regulatory support and a flexible framework for facilities to consolidate their federal emergency response plans into one “integrated contingency plan.“’ This paper identifies the federal laws that require response plans, describes the recent guidance, explains some of the benefits and potential pitfalls of taking the single-plan approach, and provides helpful hints for companies inclined to adopt an integrated contingency plan.