Steps for LEPCs to Implement E-plan in their Jurisdiction
A. Appointing LEPC Authorizers
Once an LEPC has determined that they want to use E-Plan as their reporting system, they should first identify the authorizing authorities for their jurisdiction. The decision to identify county-level authorizers ultimately rests with the agencies that comprise the LEPC. It is recommended that only a limited number of persons within a county be identified as the authorizing authority for their jurisdiction. These persons should be program management or senior officers that represent their agency on the LEPC and are the lead in decision making on behalf of their respective agency. Each of those agencies should have at least two authorizers who can serve as the focal point for that agency to respond to agency-specific requests (users) to access E-Plan. This will help ensure that access to secure information is maintained and allow for each response discipline (i.e., fire, EMS, police) to have an authorizer to confirm access for their respective discipline. As an example, the following is list of County-level authorizers:
• County Administrator, County Supervisor or Designee
• LEPC Chair; LEPC Coordinator
• County Emergency Management Office – Director, Administrator, Coordinator
• County Homeland Security Representative – Director, Administrator, Coordinator
• County Fire Marshall/Fire Coordinator
• County HazMat Team Coordinator; Deputy Coordinator
• County Sheriff
• County EMS Coordinator
B. Amendments to LEPC By-Laws
Section 301(c) of SARA Title III requires each LEPC to develop rules (by-laws) by which each committee shall function. LEPCs should formally amend their rules and identify the specific agency, and individuals, that will serve as authorizers for their jurisdiction.
It is important to note that an E-Plan authorizer can only authorize users to access E-Plan and view Tier II inventory submissions for their jurisdiction, not in other jurisdictions. Authorizers should not approve E-Plan access to individuals in neighboring jurisdictions unless the authorizers of both jurisdictions are in concurrence in allowing such access to the system. This limitation should be reflected in the LEPC’s by-laws.
C. Requests under the Freedom of Information Law (FOIL)
Members of the media and the general public should not be allowed access to the system as either an authorizer or a user. In response to FOIL requests, authorizers should only provide the information that is being requested, if appropriate, and not provide open access to the system.
D. Establishing County Authorizing Authorities
Once the LEPC has determined who will serve as their authorizing authorities, a potential "Authorizing Authority" must:
- Complete the online "Authorizing Authority Account Request" form on the E-Plan website. Begin by logging on to E-Plan. Once there, click on the "Signup for Account" link on the middle of the web page. After clicking on the "Signup for Account" link, you will be directed to the web page at right. From this page, select the "Authorizing Authority" account type and click on the "Continue to Account Creation" button to request an authorizing authority account for your jurisdiction, noted by the red arrow. This will take you to a page with numerous required fields (boxes) to establish the account in your jurisdiction. Fill in the required fields to identify yourself, your jurisdiction and your own specific UserID and password. After completing the account request form, click the "Create User" button at the bottom of the web page to submit your request.
- At the completion of the account request:
- The E-Plan Team at UT Dallas will contact the person who filled out the form by phone or e-mail to verify their identity and desire to be an "Authorizing Authority". Once approved, the E-Plan Team will set up the new "Authorizing Authority" account for the person (or persons) who now will approve all future E-Plan users in that jurisdiction. The E-Plan Team will send an e-mail message with the account information to the new E-Plan "Authorizing Authority". All future requests from individuals to become authorized E-Plan users will be forwarded to the appropriate "Authorizing Authority" in that jurisdiction for approval either by fax or by e-mail. After approval by the "Authorizing Authority" for that jurisdiction, the UT Dallas E-Plan Team will send an e-mail message with the account information to the new E-Plan registered user.
E. Addressing County Users of E-Plan Information
As mentioned above, all future requests from individuals to become authorized E-Plan users to view the information on E-Plan will be forwarded to the appropriate" Authorizing Authority" for approval in that jurisdiction either by fax or by e-mail. The steps to becoming a user are similar to the steps in becoming an authorizer.
- Prospective users should go to the website at: https://erplan.net. From there, the requestor should click on the "Signup for Account" link on the middle of the web page, noted by the red arrow. After clicking on the "Signup for Account" link, the prospective user will be directed to the web page at right. From this page, select the "User" account type and click on the "Continue to Account Creation" button to request auser account, noted by the red arrow at right. This will take applicants to a page with numerous required fields (boxes) to establish a user account. Fill in the required fields to identify yourself, your jurisdiction, your own specific User ID and password, and your supervisor's name and his/her e-mail address. In filling out the form, prospective users will be prompted to read, understand, and fill in the "Acceptable Use Policy" form. After completing the Acceptable Use Policy form, click the "Create User" button as noted by the red arrow at right to submit your request.
F. Specifics on Fire Department Access to the Information
Typically, each county LEPC includes a representative from the fire coordinator’s office. This individual should be the lead in approving or denying access to the system by fire service personnel. Fire coordinators should use their discretion in determining the number of individuals from each fire department requesting access to the system and may consider limiting access to chief officers and line officers. It is recognized that a limited number of fire service personnel in the State may not have internet access to obtain the information on E-Plan or may elect to not accept electronic reporting from the facility. This is of key concern as the fire service is typically the first line of defense in response to a chemical emergency. County LEPCs should discuss this issue with their county fire coordinator. If such cases exist, counties can still require facilities to provide hardcopy submissions of their Tier II forms, MSDSs and site maps to the fire department having jurisdiction over the facility. LEPCs need to ensure that their industry partners know what departments should continue to receive hardcopy submittals of Tier II information.