Emergency Response Assistance Plans (ERAPs)

The Emergency Response Assistance Plan (ERAP) may be traced to the recommendations made by Justice Grange following the enquiry into the Mississauga train derailment of December 1979. Justice Grange recommended that any shipper of dangerous goods must have a plan to control any release of dangerous goods in the event of an accident, and that the plan must be submitted to the Minister and approved by the Minister or by an organisation or person designated by the Minister. The right to ship could be withdrawn at any time if the plan is found inadequate either in its conception or in its operation.

Mississauga train derailment - 1979 (click to enlarge)

Part 7 of the Transportation of Dangerous Goods Act 1992, requires that before a person offers for transport or imports certain dangerous goods, the person must have an approved Emergency Response Assistance Plan (ERAP). Part 7 and Column 7 of Schedule I of the Transportation of Dangerous Goods (TDG) Regulations prescribe the dangerous goods and the concentration or quantity for which an ERAP is required.

The ERAPs are not required for all dangerous goods. They are required only for the Dangerous Goods listed in Column 7 of Schedule I of the TDG Regulations. Generally speaking these are dangerous goods which are more harmful than others, and may present wide spread hazards in the event of an accident. Response to this type of an accident may require special equipment (such as fully encapsulated chemical response suits or transfer equipment) or specially trained and qualified personnel. Explosives, toxic gases, flammable gases, multiple hazards and poisons are examples of such dangerous goods.

The intent of an ERAP is to provide on-site assistance to local authorities in the event of an accident involving the dangerous goods. The assistance provided would include, without being limited to, the provision of emergency response advice first by telephone, then by a knowledgeable person attending the accident site, and the supply of specialised equipment and a response team to mitigate the effect of the dangerous goods at the accident site.

The persons who are required to file ERAPs have various options for securing adequate response capabilities and will usually consider several factors such as the nature of the dangerous goods, specialised training, equipment, mode of transportation, geographic area to cover and means of containment. CSA Standard - Emergency Planning for Industry (CSA Z731) as well as a generic emergency response plan are available to help in the preparation of an ERAP.

The three basic options are:

• The person may register his own ERAP summary with a complete response capability that includes an alerting mechanism, personnel, means of transport and equipment.
• The person may register his own ERAP summary which may include some of his own resources and some contracted resources (the alerting mechanism may be the company telephone number and the specialised equipment may be from an emergency response contractor.
• The person may request a response contractor or trade association to file an ERAP summary on his behalf.

Transport Canada has an active program to register, inspect and approve ERAPs. There are over 900 active ERAPs filed with Transport Canada, these are from all provinces.

ERAPs are registered by submitting an application to the Chief Response Operations. This summary is reviewed upon receipt, a Remedial Measures Specialist (RMS) will contact the originator to verify the content of the application, when this verification is completed the registration number is issued and the Chief Response Operations will grant interim approval of the ERAP summary and an official letter will be sent to the applicant.

All ERAPs are subject to review and investigation, regional Remedial Measures Specialists inspect and review ERAPs and may request changes where required to make a plan more effective. If these changes are refused or not implemented, the ERAP registration may be revoked in effect removing the right to ship the dangerous goods. The reporting document used by the RMS is called a Site Audit Report also known as a SAR, it is a generic reporting format that may be applied to a wide variety of dangerous goods and ERAPs. Remedial Measures Specialists will provide copies of the SAR after each site visit. Upon completion of the ERAP review, the Chief Response Operations, will approve the ERAP by issuing a letter to this effect to the custodian of the ERAP.