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Why your site emergency drills can’ t wait By Andrew Perks, FSAIRAC

“ Where does it say that we need to do yearly site emergency drills?” We recently had a client raise this question with us relating to a SANS 1514:2018 Emergency Plan we completed for them.

It’ s understood that training is felt as a bit of a headache: your people are tied up for the length of the training, and you can’ t really see any return on the effort. All understandable.

However, wait until you have an incident, only to find out that those procedures you thought were in place, nobody knows about them or has taken them seriously. We did an Emergency Plan for a large company which thought they had it all tied up. Guess what? When we started to look at an organogram of incident emergency staff to see who would be controlling an incident, there really was only one name on the list. The GMR2 was responsible for everything, not only controlling their teams, but doing the work – it was just not possible that he could be in every place at one time.

To recount that adage‘ those that fail to plan, plan to fail’ – sad but true.

Fortunately, with the development of the Emergency Plan all the shortfalls were quickly identified. Further to our discussions I would like to think that they have amended the plan and done the proper training. It is too late to realise your shortfalls when the event is upon you.

So, let’ s get back to the actual enquiry and the response. The initial enquiry surrounded the necessity for emergency evacuation drills and practice relating to the hazardous materials on a site.

Even when a site has not been categorised as an MHI( Major Hazard Installation) by a risk assessment conducted by a relevant AIA( Authorised Inspection Authority), it is good practice to conform to the MHI regulations as far as possible when there are hazardous chemicals present on the site.

The OHS Act requires hazardous material sites have a site emergency response plan compliant to SANS 1514:2018 so that we are all on the same page with the Fire Department. The relevant sections of the OHS Act regulations that pertain to training and drills were referenced in our reply as follows to illustrate why emergency drills are required.

Section 13 of the Occupational Health and Safety Act and Regulations 85 of 1993 states the following:

Without derogating from any specific duty imposed on an employer by this Act, every employer shall( a) as far as reasonably practicable, cause every employee to be made conversant with the hazards to his health and safety attached to any work which he has to perform, any article or substance

which he has to produce, process, use, handle, store or transport and any plant or machinery which he is required or permitted to use, as well as with the precautionary measures which should be taken and observed with respect to those hazards.

Section 10 of SANS 1514:2018 relates to the training and awareness necessary. The extract is below: 10) Training and awareness 10.1) The general training and awareness programmes on the emergency plan plan shall comply with the requirements of the relevant national legislation. 10.2) The off-site emergency plan of the local authority shall determine the specific competencies required to respond effectively and safely to the expected emergencies.

10.3) Training and awareness shall enable all responding personnel to develop and demonstrate skills in the use and emergency equipment and a working knowledge of emergency procedures. Areas to be covered should include at least: a) General duties, roles and responsibilities in terms of the on-site and off-site plans respectively, b) Emergency functions of the emergency co-ordinating and planning committee and teams, c) Emergency procedures, and d) Emergency resources. 10.4) The on-site and off-site emergency plans shall make provision for the dissemination of information and awareness, to affect parties including neighbouring businesses and communities. They shall be informed of the appropriate actions to be taken during an emergency and how they will be warned of an emergency and kept informed during and after an emergency.

With regards to the drills that need to be performed on site, Section 13 of SANS 1514:2018 relates to the testing of the emergency plan:

13) Testing of the emergency plan 13.1) The on-site and off-site emergency plan shall be tested when first developed and then in terms of national legislation to enable deficiencies to be identified and corrected.

13.2) The two usual methods of testing are desktop simulations and practical exercises or drills.

13.3) Testing should consider all components of the plan, including the effectiveness of training.

13.4) Consultation between the off-site and on-site committees during planning exercises and testing is required.

Delving a bit further, when the previous excerpts reference the‘ relevant national legislation’ it is referring to SANS 1461 Major Hazard Installation Regulation. Looking at section 17 of SANS 1461( Information and Training), it is specified what is required from establishments as below:

17. Information and Training( 1) A duty holder must, after consultation with the relevant health and safety representative or health and safety committee, ensure that all employees are adequately trained with regards to –

• The scope of these regulations;

• The nature of the establishment;

• Potential major hazards and associate major incidents;

• Potential risks to health and safety caused by the identified major hazards;

• The practices and control procedures for a major incident;

• The content of the emergency plan that visitors also are conversant with such content and,

• The safety protocols and measures to be followed on-site.

( 2) The duty holder must ensure that all trained employees undergo refresher training whenever there is a change in the establishment or when the risk assessment has been reviewed.

( 3) The duty holder must provide induction orientation about the kept substances, major hazard areas and actions to be followed in case of an emergency to all mandatories, visitors and any person who, in any manner, assists in carrying out or conducting allocated duties, before they enter the establishment.

( 4) The duty holder must ensure the induction orientation as contemplated in sub-regulation( 3) is refreshed in the event of any change to an establishment which significantly alters the risk associated with the establishment: provided that the induction training will be valid for periods not exceeding 12 months.

Andrew Perks is a subject expert

in ammonia refrigeration. Since

undertaking his apprenticeship in

Glasgow in the 1960s he has held

positions of contracts engineer,

project engineer, refrigeration

design engineer, company director

for a refrigeration contracting

company and eventually owning

his own contracting company and

low temperature cold store. He is

now involved in adding skills to

the ammonia industry, is merSETA

accredited and has written a variety

of unit standards for SAQA that

define the levels to be achieved in

training in our industry.

The Major Hazard Installation Regulations in the OHS Act, section 6( 1) states“( f) ensure that all employees are conversant with the on-site emergency plan” and“( g) cause the on-site emergency plan to be tested in practice at least once a year and keep record of such a test.”

I think it’ s safe to say that the question of‘ why yearly site emergency drills’ has been answered effectively, the regulations speak for themselves. Ignore them at your own risk.

Stay safe until next time.

CLA

I think it’ s safe to say that the question of‘ why yearly site emergency drills’ has been answered effectively, the regulations speak for themselves. Ignore them at your own risk.

March / April 2026 www. coldlinkafrica. co. za COLD LINK AFRICA

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