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Emergency Plan Review

Review Your Emergency Plans

Emergency plans at hydrogen and alternative fuel sites are not “set and forget”. They must keep pace with changes in equipment, site layout, staffing, processes, and regulatory expectations. Under UK health and safety law, your arrangements should be proportionate to the risks on site and practical for people to follow under pressure. DSEAR risk controls and emergency arrangements (for dangerous substances and explosive atmospheres) should be reflected in your procedures, signage, training, and equipment availability.

Where hydrogen and other gases are stored or used under pressure, your emergency arrangements must also align with the safe operation of pressure systems, including clear operating instructions and what to do in emergencies, plus the broader duties under the Pressure Systems Safety Regulations (PSSR). 

Why routine review matters

Plans that look good on paper can fail in the real world if they are out of date. Regular reviews help you confirm that:

  • People know exactly what to do in the first 60 seconds (raise alarm, isolate if safe, evacuate to a safe zone, protect drains, prevent escalation).
  • Spill control equipment matches the liquids and volumes you actually handle (including mixed liquids, wash-down water, coolants, cutting fluids, oils and fuels, and chemical products).
  • Emergency shut-offs, isolation points, and muster locations are still correct after any site changes.
  • Contractors and visiting drivers understand the site rules and escalation process.
  • Learning from incidents and near misses is captured and fed back into procedures and training.

What should trigger an immediate review

  • Any change to process, storage volume, delivery method, or site layout (including new dispensers, pipework, compressors, cylinder banks, or refuelling points).
  • New substances introduced, or changes in SDS / classification that affect fire, explosion, or corrosion risk.
  • New equipment operating pressures, temperatures, or maintenance regimes (pressure system changes are a key trigger).
  • Staffing changes, new shift patterns, or increased contractor activity.
  • Any spill, leak, ignition near-miss, or emergency service attendance.

Key elements your plan should include

1) Clear roles and rapid decision-making

Define who can stop work, who can isolate equipment (and when not to), who controls the area, and who speaks to emergency services. Use simple role names (for example: Incident Controller, First Responder, Evacuation Marshal) and ensure cover for out-of-hours periods.

2) Safe zones, access control, and ignition control

Pre-define safe zones and exclusion areas for likely scenarios (gas release, liquid spill, combined release with ignition risk). Confirm signage and barriers are available, and ensure people understand ignition control requirements that sit alongside DSEAR zoning and hazardous area controls.

3) Spill and leak control steps that work on your site

Your steps should be specific to your layout and realistic for your team. HSE guidance on emergency response and spill control emphasises practical measures to contain and control releases as part of safe operation. 

  • Immediate actions: raise alarm, make safe, isolate if trained and safe, protect drains, prevent spread.
  • Containment: use bunding, drip trays, or temporary barriers to keep liquids away from ignition sources and drains.
  • Clean-up: select absorbents suitable for the substance type; manage waste safely; verify the area is safe before restart.
  • Post-incident: inspect, restock, record, investigate root cause, and implement corrective actions.

4) Correct equipment in the correct places

Position equipment where it will be needed in the first moments of an incident: transfer points, loading bays, compressor/plant areas, workshops, and any drainage risk points. Include grab-and-go instructions inside kits and ensure PPE is aligned with the substances present.

5) Training, drills, and competence checks

Run short, regular drills that mirror real events: a small leak near a drain, a transfer hose failure, or a release in a high-traffic area. Drills should test response time, communications, and whether equipment is genuinely accessible.

Practical improvements you can implement quickly

  • Convert your plan into a one-page “first actions” sheet displayed at key locations and inside spill kits.
  • Map isolation points, drain locations, and spill kit stations on a simple site diagram for responders.
  • Standardise spill classification (minor / significant / major) with clear escalation and call-out thresholds.
  • Introduce a restocking and inspection routine (weekly visual checks, monthly recorded checks).
  • Make incident recording easy so learning is not lost (even near misses matter).

Recommended internal resources

Use these Serpro pages to strengthen your procedures and link your plan to the right equipment and processes:

External guidance and references

These official sources can help you validate your approach and demonstrate good practice:

Next step

If you have introduced new equipment, changed operating pressures, altered drainage, or expanded storage/transfer activities, schedule a formal emergency plan review and follow it immediately with a short drill. Update your plan, refresh training, and ensure spill response equipment is correctly positioned and ready for use.