Integrated Contingency Plans (ICPs), also known as the National Response Team’s One Plan, are becoming an increasingly popular approach for companies seeking to streamline their required written environmental documents. The goal of an ICP is to consolidate multiple regulations into a single, comprehensive document that outlines how a company will respond to different types of environmental emergencies. Examples of plans commonly incorporated into an ICP include SPCC plans, SWPPPs, Hazardous Waste Contingency Plans, Risk Management Plans, or Emergency Action Plans. The list of combinations is indefinite. While there are certainly benefits to implementing an ICP, there are also potential drawbacks that companies need to consider before ultimately making their decision on whether or not to adopt.

Pros of Integrated Contingency Plans

Reduced Administrative Costs

One of the primary benefits of implementing an ICP is that it can help to reduce administrative costs. By consolidating multiple plans into a single document, companies can minimize the amount of duplicative information they need to manage, as well as the number of documents that need to be maintained. This can save time and resources, as well as reduce the risk of errors and inconsistencies.

Simplified Training and Improved Coordination of Response

Another benefit of ICPs is that they can simplify training and response drills for operators and management. Because everything is consolidated into one plan, it is easier to see the interconnectedness of requirements and manage them jointly. This can help to improve the effectiveness of response activities, as well as reduce the risk of confusion and errors during an emergency. Time is saved by not having to bounce back and forth between documents, ensuring that response activities are carried out in a coordinated manner. In the event of a spill or other time sensitive emergency, this can be critically important.

More Concise Organization of Regulatory Requirements

Finally, ICPs can help to organize the material required by regulations more concisely. By consolidating different regulatory requirements into a single document, companies can ensure that they are complying with all necessary regulations while minimizing the amount of paperwork and documentation that needs to be managed.

Cons of Integrated Contingency Plans

Non-Relevant Material is Included in Submissions

One potential drawback of implementing an ICP is that when documents are required to be submitted to an agency, a larger document that contains additional documentation beyond the scope of the request may have to be sent. Some companies prefer to minimize submissions to only what is required, in order to reduce the amount of documentation that needs to be managed.

Updates Aren’t Captured in All ICP Copies

Another potential drawback of ICPs is that covered regulations may be managed by different departments, which can make it difficult to ensure that updates are captured in all copies of the ICP. This can create confusion and inconsistency in response activities, which can be especially problematic in emergency situations.

Smaller Regulatory Requirements May Be Overlooked

Finally, portions of smaller regulatory requirements may be more easily overlooked when combining them with more robust regulations. The fact that the size of an ICP will be much larger than your typical standalone plans can make the document more difficult to manage. This can lead to potential non-compliance. It is important to ensure that all relevant regulatory requirements are captured and addressed in an ICP, and that a document of this nature will fit well with your company’s document control system.

In conclusion, while there are certainly benefits to implementing an integrated contingency plan for your company’s environmental management system, there are also potential drawbacks that need to be carefully considered. It is important to evaluate the specific needs and risks of your company, and to weigh the benefits and drawbacks of implementing an ICP against other potential approaches. With careful planning and consideration, however, an ICP is certainly capable of being an approved, effective option  for managing environmental risks and ensuring compliance with regulatory requirements.