Caravan Park Emergency Management Plan Draft Guidelines
Introduction
It has been widely recognised that a consistent and effective process for the development and validation of Caravan Park Emergency Management Plans (EMPs) is required. The Residential Tenancies (Caravan Park and Moveable Dwellings Registration and Standards) Regulations 2010 state a number of measures that must be undertaken by caravan park owners in relation to emergency management planning however there is considerable leeway for interpretation and hence inconsistency in their application.
At present the Environmental Health Officer at Municipal Councils validates that an EMP has been produced as part of the registration process. Whilst Caravan Park owners are required to consult with emergency services to determine their risk and risk treatments for their plan, there is currently no way for the Environmental Health Officer to ascertain that this has taken place. Environmental Health Officers are often not trained in emergency risk assessment, and therefore cannot reliably determine the efficacy of the EMP.
Therefore the legitimacy and efficacy of the EMPs is variable across the state, posing a risk to communities and tourists, and possibly creating a liability in terms of ‘duty of care’ for Caravan Park owners and Environmental Health Officers.
To further complicate the issue, budgetary and resource limitations at local councils and agencies creates a concern when determining who is responsible for the development and approval of an effective EMP. Changing accountabilities and legislative requirements may increase the burden on agencies and local councils, and reduce the notion of shared responsibility that emergency planning is trying to create.
Each of these issues are outlined below, followed by solutions that propose a robust process that improves the quality and consistency of Caravan Park EMPs across the state, to promote shared responsibility whilst not imposing on current responsibilities.
Current Issues
Regulation 22 stipulates that caravan park owners must prepare an emergency management plan in consultation with the relevant emergency services.
Issue 1:How does the Environmental Health Officer know if the Emergency Management Planhas been completed in consultation with relevant emergency services? What does consultation mean?
Regulation 22 also requires that Caravan Parks have an emergency management plan with the following requirements:
- A risk assessment
- Specified measures to reduce emergency risks (before an emergency)
- Emergency procedures (communications, response and evacuation).
Issue 2: How does the Environmental Health Officer determine if the emergency management plan meets these requirements, acknowledging that many are not emergency management personnel and may not have an understanding of what is needed?
The regulations further advise that the Environmental Health Officer determines whether to register a caravan park on the basis that it meets the regulations. The council is required to consult with emergency services on the emergency management plan.
Issue 3: How will the Environmental Health Officer determine compliance with regulations in consultation with the relevant emergency services? How will this process take place without placing the responsibility on emergency services?
Proposed Solution Process
1.The caravan park owner/manager contacts relevant emergency service agencies for advice on their risk of relevant natural hazards.
2.Emergency services provide a written response to caravan park owners/manager on their risk and suggested actionse.g. CFA SES
3.Caravan Park owners obtain a copy of the relevant Fire Safety Report.This is a mandatory requirement for registration.
This course of action provides written information which can be submitted as evidence of consulting with emergency services when the plan is sent for registration.
4.The caravan park owner prepares the EMP based on the advice of the emergency services and submit the EMP and their registration to the EHO.
5.EHOs are to have a fact sheet/guidance which outlines what to look for within the plan to determine its effectiveness (Attachment 1), as well as a check list for EHOs which outlines all requirements for the regulations for emergency planning. (Attachment 2).
If the EHO determines that there are discrepancies between the plan and the regulations the EHO is to contact the emergency services for more information.
6.Emergency services are to provide the EHO with written confirmation as to whether the emergency management plan is consistent with the advice provided previously.
7.If the plan does not address advice provided previously, the EHO may send the plan back to the owner and advise they address it prior to registration on advice by relevant emergency service.
8.If the plan is consistent with advice received previously, the EHO can proceed with registration providing other sections of the regulations are met.
Attachment 1: Caravan Park Emergency Management Plans - Guidelines for Environmental Health Officers
These guidelines have been developed to assist local council officers to determine whether or not the emergency management plan provided by the caravan park adequately meets the regulations.
Within the regulations, there are three main sections that must be addressed as a part of the emergency management plan:
- A risk assessment must be conducted
- Measures to reduce emergency risks must be undertaken
- Emergency procedures are identified for risks
The following sections highlight what needs to be incorporated into the plan as per the three main sections above.
1.Risk assessment
When reviewing emergency management plans, EHOs should look for the following elements to be included within the risk assessment:
- Hazards and risks have been identified
- Hazards and risks have been analysed. Analysis of risk can be undertaken in a number of ways. At a minimum, the assessment should involve analysing what would happen if the hazard were to occur in their park (consequence) and how often the hazard or risk is likely to occur (likelihood).
- Hazards and risks have been evaluated to determine and prioritise risks their park based on the analysis they have undertaken in the risk assessment.
Identification of hazards and risks is completed in consultation with the relevant emergency services.
2.Measures to reduce emergency risks
The identified hazards and risks from the risk assessment and priorities are the ones that need to be addressed through the development of an emergency management plan. This plan is considered a risk reduction tool.
Prior to working through specific actions for the hazards, there are a number of actions that the caravan park owner/operator can undertake to reduce the risk which are separate to the plan, but impact on the risk.
These actions can includeundertaking works to the park so that the risk is lowered. For example, a caravan park may choose to move their park around so that the moveable dwellings are located where it floods, rather than more permanent structures which can be damaged.
Additionally, there are actions that the park can take which is general maintenance and reduces risk such as cleaning gutters, ensuring fire equipment is maintained and storing chemicals high.
When reviewing the emergency management plan to determine if it meets the regulations, EHOs should look for:
- A section that addresses general maintenance that a park should undertake all of the time, and not just
- A schedule of works if they have not addresses a risk due to apparent completion of works to reduce the risk.
3.Emergency procedures
The emergency procedures for caravan parks will need to have the following three elements:
- Response actions – these are what the owners/managers will do before, during and after an emergency depending on the emergency. This section of the plan should detail who is going to do what in an emergency, for instance, who will raise the alarm, who will arrange evacuation etc. Additionally, there needs to be consideration on what occupants are required to do in the emergency throughout the plan.
- A communications plan – The communications plan needs to detail how the caravan park owners/managers intend to advise occupants of an emergency or emergency warning. Communicating the message can take place in a number of different ways, including a PA, a door knock or other.
- Evacuation procedures – this needs to detail how they will evacuate their park, including the identification of an emergency assembly area. Consideration should be given to whether they have nominated multiple assembly areas for different hazards or events. In some cases, a singular evacuation point may not suit all emergencies. Note: the regulations stipulate that these are displayed in the park’s main office, any communal buildings such as amenities or anywhere else determined by council.
When reviewing the plans, ensure that a responsible officer for each of the above elements have been identified. This should be incorporated in the response actions.
Attachment 2: Caravan Park Emergency Management Plans – Checklist for Environmental Health Officers
The caravan park owner has provided a copy of the emergency management plan with the following inclusions:
- A risk assessment ☐
- Measures to reduce emergency risks ☐
- Emergency procedures including:☐
-Evacuation procedures
-A communication plan
-Response measures for during an emergency
The caravan park owner has provided the following:
- A copy of the advice received by emergency services.☐
- A copy of the most recent fire safety report.☐
- A copy of a schedule of works if work has been ☐
undertaken since reports have been received. - A plan of the caravan park clearly indicating location of☐
sites, buildings and amenities.
Requirements for emergency management planning section of the regulations have been met:
Yes ☐
No ☐
Date: ______
Officer: ______