Function: Regulations
Policy:

Appendix 2 Emergency Response Policy

CMHO Standard(s): P.*A.2.1, M.*I.1.1
Approved: January 2009

Appendix 2

 

 

 

                                                                             

                              EMERGENCY RESPONSE POLICY

 

 

Approved by Board of Directors – April 24, 2008, Approved January 2009

 

  1. INTRODUCTION

POLICY STATEMENT

St. Leonard’s Community Services is committed to emergency response planning.  The health and safety of staff, clients and the community is integral to the Agency’s operational planning.  Emergency planning will ensure a timely and appropriate response to emergencies and compliance with applicable laws.

While St. Leonard’s Community Services respects the rights defined by the Employment Standards Act, the Occupational Health and Safety Act and the Human Rights Code, these rights may be temporarily superseded by the immediacy of an emergency.

All staff having a direct continuing role in emergency planning activities will contribute to the development and maintenance of this policy and will act in compliance with the policy at all times.

PURPOSE OF THE POLICY

The purpose of the Emergency Response Plan is to prepare St. Leonard’s staff for procedures required in the event of an emergency ensuring the highest possible standard to protect the health and safety of staff and clients. 

The Plan is intended to be co-ordinated with municipal, provincial and federal services as well as other social service agencies.

DEFINITION AND EXAMPLES OF AN EMERGENCY

For the purposes of this policy, an emergency is defined as an event/situation that includes any or all of the following conditions:

  • Potential to have serious adverse effects on the health and/or safety of staff or clients.
  • Occurs suddenly and is not predicted.
  • Escalates in severity.
  • Demands immediate attention.
  • Interrupts normal operations.
  • Creates significant stress and anxiety for those involved.

Emergencies could originate from either internal or external factors but would fall into one of three categories:

  • Natural emergencies such as storms, freeze up, floods, earthquakes and lightning strikes.
  • Man-made emergencies such as explosions, fire, long-term loss of power (greater than 12 hours), structural collapse, disruption of water supply (over 12 hours), loss of primary heat source (over 12 hours), carbon monoxide evacuation, loss of communication systems (security system disruption over 12 hours), loss of access to stores and banks.  Other man-made emergencies that could occur include environmental contamination, toxic chemical release and transportation emergencies.
  • Social/political/economic/health emergencies such as loss of life/suicide of staff or client, sabotage, bomb threats, hostage taking, civil disobedience, war, unexpected program closures and disease/pandemic.
  1. EMERGENCY MANAGEMENT PREPAREDNESS:

RESPONSIBILITY

The Executive Director will be responsible for ensuring compliance with this policy.  The Executive Director will have the authority to declare an event/situation an emergency, or delegate the authority as required.

Once an event/situation meets the conditions of an emergency, the following steps will be taken:

  • The Executive Director or delegate will declare a state of emergency and communicate this decision to all appropriate persons.
  • The Executive Director will assemble the Emergency Response Team (see below for members) who will assess the situation, set priorities and ensure actions are immediately initiated.

EMERGENCY RESPONSE TEAM

The St. Leonard’s Management Team and Facilities Manager will function as an Emergency Response Team.  The Executive Director will be the chair of the Team responsible for the development and administration of the Emergency Response Plan.  In the case of Natural or Man-Made Emergencies, the Facilities Manager will function as the Emergency Response Co-ordinator responsible for the operation of each plan including continuous onsite departmental emergency response training for all staff.  The Executive Assistant will be present to record meeting minutes. Each department will have a designated health and safety representative who will liase with the Emergency Response Co-ordinator and ensure all departmental staff members are trained to respond appropriately in an emergency.

Under the direction of the Executive Director, or in his absence his designate, the Team will:

  • Oversee and co-ordinate all aspects of the Emergency Response Plan including evacuation, relocation, reception and training.
  • Oversee all internal communications. 
  • Oversee all maintenance requirements during the emergency.
  • Co-ordinate all financial and administrative aspects of the emergency including notification to all funding sources, insurance companies, security services and Agency suppliers.
  • Ensure the transfer and safe keeping of equipment, furnishings and all records pertaining to finances, Human Resources or clients.
  • Co-ordinate Agency activities with police, fire and city officials.  Where evacuation is ordered by an emergency service (i.e. police, fire or medical officials) a line of communication will be maintained between the relevant department’s Service Director and the municipal authority that ordered the evacuation.
  • Ensure the security of all Agency facilities.
  • Notify the Board of Directors, funding ministries, other relevant custody/childcare facilities, CAS’s, client guardians, local agencies and Children’s Mental Health Ontario (CMHO).

INTERNAL COMMUNICATIONS

Once an event/situation has been declared an emergency, notifications and updates will be available to all staff on the Agency’s intranet whenever possible.

During an emergency, cell phones and/or fail-safe phones will be used.  The Addiction and Mental Health Centre at 133 Elgin Street will function as the Emergency Operations Centre for communication purposes.

Any emergency listed below will trigger an automatic meeting of the Emergency Response Team at 9:00 a.m. the following calendar day at the Emergency Operations Centre.  Further meetings will be scheduled as needed by the Emergency Response Team.

An Emergency Supply Kit will be stored at the Youth Action Centre for use at the Administration office including a portable generator to power communication systems.

MEDIA

The media will be used to make timely announcements to the public as required.

The Executive Director will be responsible for disseminating and documenting factual and current information to the media.

CONTINGENCY PLANNING

Contingency plans will be in place for all emergencies listed below.
 
Wherever possible all residential locations will be equipped with fully stocked first aid kits, blankets, sleeping bags, gas powered generators wired to critical systems, five day supply of gasoline, propane, five day supply of bottled water, sanitizing hand cleaner, disposable paper plates, cups and cutlery, candles, flashlights, batteries, water proof matches, dry goods, fail safe phones, cell phones with car battery operated boosters, approved face masks and gloves.

In addition to the above, all residential locations will have on site an operational barbecue with a minimum of 2 propane tanks.  

Monthly health and safety inspections will include a checklist of the above items.

On-duty staff will be trained and empowered to implement emergency response procedures without requiring contact with a higher authority.

EMERGENCY CALL LIST

All staff are responsible to make themselves aware of the emergency call list and how to activate the call system.  The emergency call list will be added to the agenda of semi-annual Emergency Response Training and will be the responsibility of the Emergency Response Team to update and keep contact list current.

RISK ANALYSIS

It will be the responsibility of the Health and Safety Committee to carry out a risk analysis to identify the worst probable emergency cases that could realistically happen.  Knowing what to expect and what options are available makes for better preparedness in the event of an emergency.  Identifying the hazards or any physical situation with a potential for human injury or damage to property is the first step in emergency response planning.  This makes it possible to determine what human and material resources are needed to reduce the consequences of an emergency and the need for external resources if the emergency escalates beyond the capabilities of the Agency. 

Risk analysis identifies the extent and likelihood of consequences associated with hazards by asking the following questions:

  • What can go wrong?
  • What is the impact on the Agency?
  • How likely is it?
  • How often will it happen?

After carrying out the risk analysis, the health and safety committee will identify contingencies in order to respond effectively in the event of an emergency.  These contingencies are outlined in the Emergency Response Policy.

Examples of emergencies and contingencies are listed below.

  1. NATURAL EMERGENCIES

EG.  LIGHTNING STRIKE

Impact – Tree falls on facility, suspected structural damage.

Contingencies – Front line staff will ensure the safety of clients/staff and will continue to monitor the situation and continued safety of all.

Front line staff will notify the Service Director of the department of all emergencies, who will make a decision if and when to activate a long-term plan.

  1. MAN MADE EMERGENCIES

LOSS OF PRIMARY HEAT SOURCE

Impact – Staff and clients cannot work/live under such conditions for periods beyond 12 hours. Depending on the outdoor temperature, water systems will freeze over time creating stress for staff and clients.

Short-Term Contingency (under 12 hours) – Front line staff will come to work with sufficient clothing to work in adverse conditions and ensure an adequate supply of clothes, blankets and bedding for clients.

Long-Term Contingency (over 12 hours) - The Emergency Response Team will meet to discuss evacuation, relocation of clients, property, files and acquisition of needed supplies and equipment.

Front line staff will notify the Service Director of the department of all emergencies, who will make a decision if and when to activate a long-term plan.

EG.  LOSS OF ELECTRICITY

Impact – Staff and clients are at risk of injury, which will create stress.  There is also a risk of theft and vandalism of property.

Contingencies – Service Directors or delegates will ensure the continuous functioning of emergency lighting systems for equipped locations.

Service Directors or delegates will ensure a supply of flashlights, batteries, candles and waterproof matches are on hand as part of the Emergency Supply Kit.

Front line staff will notify the Service Director of the department of all emergencies, who will make a decision if and when to activate a long-term plan.

If after 12 hours, there remains a disruption in electricity, members of the Emergency Response Team will discuss contingency planning.

EG.  LOSS OF WATER

Impact - Shortage of water for drinking, bathing, toilets, dishes and clothes will pose health risks and bring about significant stress for staff and clients

Contingency – Service Directors or delegates will ensure that all clothing, linens and bedding are washed regularly to maintain an adequate back up supply. 

Service Directors or delegates will ensure an adequate supply of sanitizing hand cleaner, and disposable paper plates, cups and cutlery.

It will be the responsibility of the Service Directors or delegate to ensure each of their departments is adequately supplied with clean bottled drinking water sufficient for 5 days for each resident.

In the event of a disruption in the municipal water supply, Service Directors will maintain contact with the Facilities Manager who in turn will work co-operatively with municipal and provincial officials in order to restore water to staff and clients.

Procedures for addressing a disruption in water supply are outlined in the Red Box for residential locations.

Front line staff will notify the Service Director of the department of all emergencies, who will make a decision if and when to activate a long-term plan.

If after 12 hours, there remains a disruption in water supply, members of the Emergency Response Team will discuss contingency planning.

EG.  LOSS OF COMMUNICATION SYSTEMS

Impact - Inability to communicate by telephone or email with police, fire, ambulance, emergency response team members, government funders and community partners. 

Contingencies – Service Directors will ensure that fully charged cell phones are on hand along with car battery-operated boosters.  Service Directors will also ensure that fail-safe land phones are on site or located in the emergency supply kit.

Service Directors will ensure an adequate supply of paper and pens and that manual recording systems are in place that staff are trained to use.

Service Directors will ensure that vehicles are properly maintained with a ½ tank of gas.

Front line staff will notify the Service Director of the department of all emergencies, who will make a decision if and when to activate a long-term plan.

EG.  LOSS OF ACCESS TO STORES/BANKS

Impact - Inability to obtain cash, buy food, medical supplies or emergency equipment.

Contingencies – Service Directors or delegate will ensure the availability of a 5-day supply of food. Service Directors will also ensure an adequate supply of medications including prescription drugs are filled 5 days before running out.

Service Directors or delegates will ensure that fully stocked first aid kits are on site. 

Administration will maintain back up funds for all residential locations.

Front line staff will notify the Service Director of the department of all emergencies, who will make a decision if and when to activate a long-term plan.

  1. SOCIAL/POLITICAL/ECONOMIC EMERGENCIES

LOSS OF LIFE-STAFF OR CLIENT

The suspected death of a staff or client is treated as a medical emergency until the staff or client has been officially pronounced dead by a coroner. The body of the deceased must remain at the location until the coroner arrives.

In the event that staff discover an unconscious staff or client, the following steps will be followed:

  1. Staff are to call 911 to report the incident, activate the panic button and then return to the emergency scene in order to administer CPR duties and continue until relieved.
  2. The On-Call Supervisor will be contacted and will arrange for relief staff.
  3. Seal off the immediate area leaving any physical evidence undisturbed
  4. Fire, Police and Ambulance staff will attend in response to the 911 call and panic button activation.  Staff are to provide all information and co-operate fully.
  5. Staff are required to record notes in the logbook regarding times of notification and tasks completed. Completion of documentation must be done prior to staff leaving the program/building. Once the notes are completed the Manager/delegate will remove the logbook and ensure a new one is issued.

CLIENT:

Serious Occurrence and/or Incident reporting procedures must be followed in the event of a client death while in care (see Documenting Policies 2-100 and 2-110).  Immediate responses must include the following contacts:

  • Notification of the Manager, Service Director and Executive Director. The Manager will assist in making the following contacts and attempt to arrange for additional staffing to assist.
  • Notification of appropriate Ministry contacts and personnel.
  • Confirm notification of coroner, who cannot be the physician providing services to the program.
  • Notification of the deceased client’s CAS worker or probation officer if applicable.
  • Notification of the deceased client’s parent/guardian/caregiver after consulting with appropriate Ministry contacts and personnel to determine who would be the best person to inform the family. This notification may be done by an external agency such as police or hospital.
  • During any contact with the parent/guardian/caregiver, consideration must be given to the ongoing investigation of the death, program security and relevant privacy provisions under Ministry standards and requirements. As a result, the parent/guardian/caregiver will be directed to the Ministry designate regarding any requested information.
  • For Peter Willis Residence, the Ministry of Children and Youth Services will inform the Investigations and Inspections Unit.  Staff are required to fully cooperate with the investigating agencies.
  • For Buffalo Street Residence, Chatham Street Residence and Addictions and Mental Health, notification of the LHIN.
  • All actions relating to the death must be recorded in the deceased client’s file.

The Service Director/delegate, when aware, will ensure that Ministry contacts and personnel are advised of the date of any coroner’s inquest.

Clients directly involved with the incident will be offered support through Agency and/or external services.

If the deceased client is from a residential program and shared a bedroom with another client, every attempt will be made to move the client to alternative accommodations within the residence.

Staff directly involved with the incident will be taken off shift and provided with a debriefing and/or referral to the Employee Assistance Plan Contractor by the Manager or delegate.

EMPLOYEE:

Critical Injury reporting procedures must be followed in the event of a staff death while on shift.  Immediate responses must include the following contacts:

  • Notification of the Manager, Service Director and Executive Director.
  • Completion of Serious Occurrence and/or Incident Report (see Documenting Policies 2-100 and 2-110).
  • Notification of the Human Resources Manager by the Manager or delegate.
  • Notification of an Investigation Team (comprised of certified Health and Safety persons) by the Human Resources Manager.
  • Completion of the Critical Injury Report by the Investigation Team and submitted to the Human Resources Manager within 24 hours.
  • Notification of the Ministry of Labour by the Human Resources Manager within 48 hours.

Notification of the deceased staff’s family will be done by the Service Director.

BOMB THREAT OR HOSTAGE TAKING

If a bomb threat or hostage taking occurs, the front line staff will carry out the following steps:

  • Inform the police immediately.
  • Evacuate all clients ASAP.
  • Contact the security service by telephone, which will activate the emergency call list.  This is an avenue for front line staff to get in touch with a Service Director as fast as possible without having to spend a lot of time on the phone.  It is to be used in emergencies only, as defined above, not for the everyday problems they experience.
  • Maintain “safe contact” with the bomb threat caller or hostage taker until the police arrive. Brief the police.  The call taker should get as much information from the caller about the bomb as possible, i.e. location, size, time of detonation, method of detonation, materials, etc.
  • Remain available to assist police.

Front line staff will notify the Service Director of the department of all emergencies, who will make a decision if and when to activate a long-term plan.

UNEXPECTED PROGRAM CLOSURE

In the event that a sudden program closure occurs, the following steps will be carried out:

  • The Emergency Response Team will meet to brainstorm options.
  • The Service Director or delegate will make arrangements to facilitate the safe transfer of clients and their belongings.
  • An urgent staff meeting will be called by the Service Director to inform all affected staff of the program closure, and the subsequent steps.
  • A memo will be provided to all staff via the intranet to announce the program closure.
  • Where possible, every attempt will be made to transfer affected staff to other programs within the Agency.
  • If layoffs/terminations are inevitable, the Emergency Response Team will follow the procedures set out in Human Resources Policy 6-790 Layoffs and 6-800 Termination.
  • The Service Director or delegate will make arrangements to have all pertinent documents from the closed program stored and secured as set out in Documenting Policy 4 Client Files and Data.
  • The Emergency Response Coordinator will make arrangements to secure or dispose of equipment, furnishings or vehicles acquired by the program.
  • The Service Director or delegate will notify impacted funding ministries, stakeholders, community partners and the media as soon as possibl
  1. EMERGENCY RESPONSE:

EMERGENCY RESPONSE TRAINING AND INFORMATION BOXES (RED BOXES)

Emergency Response Training will be considered a necessity for all staff and will include the fundamentals such as knowledge and use of response procedures and equipment.  Staff identified in the plan will be thoroughly familiar with Agency policy and procedures for responding to emergencies.

Departments will have on site, “Emergency Information Boxes” which are painted red and contain coloured cue cards outlining information concerning the appropriate response in the event of an emergency. The Red cue card will contain phone numbers for ambulance, police, poison control, and fire alarm contractor.  The Green cue card will contain phone numbers for Residences, On-Call Personnel and certified Agency health and safety representatives.  The Blue cue card will contain phone numbers of Agency contractors for plumbing and heating.  The Pink cue card will contain phone numbers of Agency contractors for electrical, security and phone systems.  The Yellow cue card will contain instructions concerning the location of warning alarm systems, electrical fuse box panels, main hydro shut off, heating and air conditioning units and water main shut offs. 

In addition, all Red Boxes will contain an Emergency Call List and a current copy of the Emergency Response Policy.

Cue cards will instruct staff who to contact in the event of various emergencies (i.e. flood or power outage).  All staff will be oriented as to the contents and instructions in the Emergency Information Boxes.

Staff will be trained to operate emergency response equipment including generators, to test and document functioning warning systems (i. e. panic buttons, fail safe phones) monthly and to check that all necessary supplies are present in the Emergency Supply Kit.  The Emergency Supply Kit will include a supply of flashlights, batteries, candles, extension cord, radio, and fail safe phone.

Emergency response training will occur on an ongoing basis through mock emergencies that are arranged by the Emergency Response Co-ordinator in co-operation with the departmental health and safety representative and the appropriate Service Director.

Evacuation procedures will be practised monthly by means of fire drills.  Departmental Managers, Service Directors and the Executive Director will document fire drills monthly.

The Emergency Response Plan will be reviewed annually by the Health and Safety Committee.  Recommended changes or additions will be forwarded to the Management Team to be reviewed at the Annual Work Plan meetings.

INITIAL EMERGENCY RESPONSE

On-duty front line staff will be trained and empowered to respond immediately to emergency situations without the requirement of first contacting management personnel.

All staff will be trained to recognize and respond to emergency signals such as sirens, fire bells, smoke alarms and CO alarms.  (All these devices have a distinct sound).

In the case of fire, front line staff will contact the fire department (911).  In all other situations, depending on the nature of the emergency, on-duty front line staff will contact police and if necessary Damar Security Systems, giving as reason for the call to initiate “Emergency Contacts”. Staff will provide Damar with the system number.  This will enable Damar to access the St. Leonard’s Community Services information screen, which will instruct dispatch to start calling emergency response team members.

Damar Security Systems will contact a member of the Emergency Response Team.  The contacted team member will be responsible for calling other members of the Emergency Response Team if needed, additional staff if needed and other relevant authorities.

On-duty front line staff can expect to receive a telephone call from their Service Director, delegate or Emergency Response Team member, if possible, within 1 hour of placing a call to Damar Security Systems who will activate the emergency call list. 

EVACUATION AND RELOCATION PROCEDURES

Staff and Client Responsibilities

On-duty front line staff may at their discretion, initiate the immediate evacuation of all clients and staff to the grounds or to a reception area in another building.

Each departmental Emergency Information Box will contain evacuation and relocation information including instructions concerning relocation sites, vital materials (i.e. food, medicine, linens and files) to be relocated, and specific instructions regarding how to leave the evacuated site. When communication is cut off, the evacuation will occur at 8:00 p.m. when possible.  Where possible, clients will carry their own personal property and bedding supplies.

Relocation Sites

Peter Willis, Addictions and Mental Health Centre and the Youth Action Centre may be used on a brief emergency basis to accommodate one another’s evacuees.

Roy Walsh Home, Varency Home and the Youth Resource Centre residences may be used on a brief emergency basis to accommodate one another’s evacuees.

The Addictions and Mental Health Centre located at 133 Elgin Street may be used on a brief emergency basis to accommodate Buffalo Street Residence’s evacuees.

The Administration Office, Addictions and Mental Health Centre, Dunnville Employment Centre, 12 Market Street and Youth Action Centre may be used on a brief emergency basis to accommodate one another’s evacuees or the evacuees from other community facilities.

In the case of a pandemic, the Emergency Response Team will gauge the necessity of evacuation of non-residential residents to a separate site based on the above relocation sites.

Traffic Flow

Clients and staff will be evacuated in accordance with the procedures outlined in the Fire Safety Plans, which are posted at all facilities.

Supervision of Traffic

Whether evacuation involves a short period of time outdoors in the immediate vicinity or movement to temporary lodging in another facility, it is imperative that all evacuees be accounted for at all times.  Front line staff, who will be responsible to account for all evacuees, will directly supervise traffic flow.

Method of Priority Evacuation

Any client requiring special assistance will be evacuated first. 

Transportation

Transportation will be provided where possible by all available staff using personal vehicles, Agency vehicles and/or taxis.  Staff will accompany clients to their destination if possible. 

The following is a list of Agency vehicles, locations, VIN numbers and licence plate numbers:


Location

Description

VIN

Plate

Youth Action Centre

466 Colborne Street

2007 Grey Ford Van

2007 Grey Ford Van

2FMZA50267BA12905

2FMDA502X7BA06633

AZDS636

BABJ193

Peter Willis Residence  135 Elgin Street

2004 Grey Astro Van

2006 Grey Honda Civic

1GNDM19X04B121673

HGFA16366H017406

AAFX 503

AAFX 608

Buffalo Street Residence
19 Buffalo Street

2002 Blue Chrysler

2C3HH46R32H260503   

AELD 025

Varency Home   
267 Concession 6, Jarvis 

2004 Blue Pontiac Montana

2004 White Pontiac Montana

1GMDU03E54D264449

 

1GMDU03E64D259793   

ATLM 221

 

ATLM 253

Roy Walsh Home

41 William Street  

 

2007 Grey Astro Van

2007 Grey Astro Van

2002 Brown Chevrolet

2FMDA502X7BA06633

2FMZA50267BA12905

1GNDM19X22B121011

AAFX 502

572 RCL

 

Administration

1100 Clarence Street

2006 Kia

2006 Volkswagen Jetta

KNDMB233566044157

3VWNJ81K86M845439

157 NHY

430 VAO


CIRCUMSTANCES REQUIRING LONGER TERM EVACUATION AND RELOCATION

In the event that evacuated clients cannot return to their residence within 24 hours, the Service Director in co-operation with the Executive Director will authorize long-term relocation arrangements.  Longer-term arrangements may involve the departmental Service Directors overseeing the transfer of clients to public accommodations, other residential facilities outside the area, or other arrangements satisfactory to the relevant authorities.

Service Directors will relocate files and essential materials if necessary to secure storage facilities.

MUTUAL AID AGREEMENTS

Mutual Aid Agreements with other agencies to share personnel and equipment will be negotiated by the Emergency Response Co-ordinator in consultation with the Health and Safety Team.  Agreements could be made with city, police, fire and health services, CAS and with the funding ministries.

REPORTING

To ensure public safety, and to satisfy legal and insurance requirements, staff responding to the emergency will complete a post emergency report within 24 hours of the event (i.e. Serious Occurrence, Incident Report).  This form will be co-signed by the Service Director, the Emergency Response Coordinator and the Executive Director.

In the event that emergencies include an infectious disease outbreak or are anticipated to overwhelm local capacity, our Local Health Integration Network (LHIN) should be notified no later than the next business day.

The following protocol should be followed to report an event/situation to the LHIN:

  • During regular business hours (8:30am – 5:00pm Monday to Friday), the Hamilton Niagara Haldimand Brant LHIN should be called at 905-945-4930.
  • The details of the event/situation should then be confirmed by e-mail to our consultant Doris Downie at doris.downie@lhins.on.ca.
  • After regular hours (evenings and weekends), call pager number 416-582-1200.

5.  POST-EMERGENCY ANALYSIS:

DAMAGE CLAIMS ASSESSMENT

Once an emergency has passed, or at the earliest opportunity, front line staff on duty and the Facilities Manager (Emergency Response Co-ordinator) will document all damage before the Director of Finance submits a claim.

POST-EMERGENCY COUNSELLING

Staff involved with the emergency will be offered therapeutic debriefing through supervision meetings, staff meetings or EAP services within 24 hours of the event.  This counselling will be over and above the regular EAP entitlement for each staff

DISTRIBUTION

The Executive Assistant will ensure dated copies of the emergency response plan are distributed to all departments and staff having responsibility in the plan. 

UPDATING

Emergency Response Planning will be an ongoing activity of the Emergency Response Team requiring continuous adjustment due to changes in operations, staff, contact names and numbers or regulations.  The Plan will be kept current by means of an annual review as part of the Agency planning cycle.

APPROVAL

The Emergency Response Team will be responsible for recommending changes in the Plan to the Board of Directors who will have authority to approve the Plan.

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