Five Ways to Strengthen Your Emergency Response Plan

Under the Canadian Biosafety Standard, Third Edition, licenced facilities are required to establish, implement, and maintain an Emergency Response Plan that reflects the specific activities and risks associated with their facility.

A well-designed Emergency Response Plan helps protect personnel, the public, and the environment when incidents involving human pathogens and toxins occur. During inspections conducted by the Public Health Agency of Canada (Agency), several recurring gaps continue to be identified in facilities. Reviewing these common observations can help strengthen your emergency preparedness and support compliance with regulatory requirements.

1. Clearly Define Agency Notification Requirements

What we commonly see

Many Emergency Response Plans do not clearly state when the Agency must be notified following a reportable incident. Additionally, Emergency Response Plans often do not include a comprehensive description of all circumstances that require notification to the Agency.

Why it matters

Prompt reporting of notifiable incidents is a legal requirement under the Human Pathogens and Toxins Act, which plays an important role in biosafety oversight and risk management (sections 12 to 14 of the Act).

Your Emergency Response Plan must include:

• A clear procedure to notify the Agency when a reportable incident occurs (Canadian Biosafety Standard 4.8.11)
• Examples of reportable incidents, include:
  • Laboratory-acquired infections or suspected exposures
  • Inadvertent releases of pathogens or toxins
  • Missing, lost or stolen biological materials
  • Containment breaches and security incidents
• Defined reporting roles and responsibilities
• Current notification procedures and timelines
• The requirement to submit a follow-up report within 30 days of an exposure notification involving a human pathogen (Canadian Biosafety Standard 4.8.12)

Best practice

Include a quick-reference guide, checklist, or flowchart to help personnel quickly determine whether an incident must be reported and who is responsible for reporting it.

2. Develop Containment Zone-Specific Evacuation Procedures

What we commonly see

Many Emergency Response Plans provide general evacuation instructions but do not address how personnel should manage personal protective equipment, biological materials, or ongoing laboratory activities during an emergency.

Why it matters

Laboratory environments present unique biosafety and biosecurity risks. Without clear instructions, emergency evacuations can increase the likelihood of contamination, exposure, or unintended release of biological materials.

Your Emergency Response Plan should include:

• Procedures for safely securing work in progress when possible, such as:
  • Closing open containers or samples
  • Securing biological materials in an appropriate container
  • Shutting down equipment when safe and feasible (for example. Bunsen burner)
• Clear instructions regarding personal protective equipment, including:
  • When personal protective equipment should be removed before exiting
  • Situations where immediate evacuation takes priority
  • Actions to take if personal protective equipment cannot be removed during the evacuation, such as maintaining separation from other evacuees at muster point and following procedures for personal protective equipment collection and hand disinfection.

Best practice

Develop response procedures tailored to the operational realities of your containment zone and for specific emergency scenarios (such as fire, power outage, spill, or security incident) rather than only relying on generic evacuation instructions.

3. Prepare for Medical Emergencies

Many Emergency Response Plans do not clearly outline how to respond when a medical emergency occurs inside a containment zone.

Why it matters

Medical emergencies often require rapid action under stressful conditions. Without predefined procedures, delays or confusion can compromise both employee care and biosafety.

Consider including guidance for situations such as:

• A person becoming unconscious or seriously injured within the containment zone
• Coordinating access for emergency responders
• Addressing concern from emergency responders about entering containment zones where pathogens are handled.
• Determining whether stretchers or other emergency equipment can enter laboratory areas
• Managing personal protective equipment during patient evacuation
• Responding to events where biological materials or potentially contaminated substances are present on personnel or clothing
• Communicating hazards and containment requirements to emergency responders

Best practice

Work with local emergency services to ensure response procedures are realistic, understood, and compatible with your facility's containment requirements. The safety of the affected person should be prioritized while considering the risks within the containment zone.

4. Expand Emergency Response Training Beyond Fire Drills

What we commonly see

Training programs often focus exclusively on fire evacuation drills or provide only documented review of emergency procedures.

Why it matters

Personnel must be prepared to respond to a wide range of emergencies, not just fires. Effective training improves confidence, decision-making, and overall preparedness.

Your training program needs to include but is not limited to:

• An annual Emergency Response Plan refresher for all relevant personnel
• Training on a variety of emergency scenarios, including:
  • Natural disasters
  • Exposure incidents
  • Spills within and outside of the containment zone, including spills inside Biological Safety Cabinets, centrifuges, fridges, freezers, etc.
  • Power failures
  • Primary containment device failures
  • Security incidents
  • Medical emergencies
• Records demonstrating training completion and competency.

Effective training methods include:

• Tabletop exercises
• Scenario-based discussions
• Simulated emergency responses
• Interactive group sessions

Best practice

Interactive training not only improves staff readiness but can also reveal gaps in your Emergency Response Plan before an actual emergency occurs.

5. Maintain Incident Records for the Required Retention Period

What we commonly see

Organizations sometimes overlook record retention requirements for incidents involving pathogens, toxins, or loss of containment.

Why it matters

Accurate and accessible records support investigations, trend analysis, corrective actions, and regulatory compliance.

Remember

Records of incidents involving pathogens, toxins, or losses of containment must be retained for a minimum of 10 years (Human Pathogens and Toxins Regulations 29 (2) and Canadian Biosafety Standard 4.9.2).

Best practice

Periodically review your record management system to ensure retention requirements are being met, and records remain readily accessible when needed.

Key Takeaways

To strengthen your emergency preparedness program and align with the Canadian Biosafety Standard, Third Edition, review your Emergency Response Plan to ensure it:

• q  Clearly defines Agency notification requirements and reportable incidents
• q  Provides laboratory-specific procedures to manage personal protective equipment and biological materials during emergency situations
• q  Addresses medical emergencies that may occur within containment zones
• q  Includes annual, scenario-based emergency response training
• q  Meets record retention requirements for incidents and losses of containment

By addressing these common gaps, licenced facilities can strengthen compliance and improve their ability to respond safely and effectively during emergencies.

Preparation and implementation of an Emergency Response Plan is a requirement specified in Matrix 4.8 of the Canadian Biosafety Standard, Third Edition and a condition of your Pathogen and Toxin Licence. In accordance with subsection 18(7) of the Human Pathogens and Toxins Act, failure to meet the conditions of your licence may result in enforcement actions aligned with the Centre for Biosecurity’s Compliance and Enforcement Policy.

Need more information

Please visit the PHAC Training Portal to access the recently updated Emergency Response Plan course. Consult the Canadian Biosafety Standard, Third Edition and related Agency guidance documents, and regularly review your Emergency Response Plan to ensure it reflects current operations, personnel, and risks.