Audit on the Implementation of the ERM Report. Report. Delivering sustainable solutions in a more competitive world. December

Transcription

1 Audit on the Implementation of the ERM Report Report December Delivering sustainable solutions in a more competitive world

2 CONTENTS 1.1 INTRODUCTION TRAINING CBRN (CHEMICAL BIOLOGICAL RADIOLOGICAL NUCLEAR) INTERFACE MEDIA MANAGEMENT PROCESS SPECIFIC ACTIONS FOR RESOURCES 5

3 1 AUDIT ON THE IMPLEMENTATION OF THE ERM REPORT AND RECOMMENDATIONS REGARDING THE NATIONAL EMERGENCY PLAN FOR NUCLEAR ACCIDENTS. 1.1 INTRODUCTION ERM Environmental Resources Management Ireland Ltd., were commissioned by the then Department of Public Enterprise in March 2001 to undertake and complete a test of the National Emergency Plan for Nuclear Accidents (NEPNA). The project included three critical elements as follows:- A review of the existing national plan, and attendant sub-plans of public authorities and agencies contributing to incident management; and The conduct of a table top exercise, to prepare participants for the issues to be confronted by the emergency management arrangements and structures in place under the Plan, the context of a real emergency and the main exercise associated with this project; and The conduct of a main exercise (Operation Graystorm) to test the arrangements within the plan and related sub-plans. The outcomes for each of the above elements are set out in detail in a Final Report. Following a two-year programme of implementation the ERCC through the (EHLG), requested ERM to undertake a further brief review of progress to date in regard to the application of the Review. The responsibility for nuclear safety transferred to the Minister for the Environment, Heritage and Local Government in June The more recent review of implementation actions involved a workshop of members of the ERCC during which actions in the intervening period of two years were bench marked against the recommendations of the Review. The bench marking of the recommendations is set out in this Report (See Annex A), along with matters arising. 1.2 TRAINING Each Department retains its own responsibility for the provision of training for personnel. Under such circumstances, the Department of the Environment, Heritage and Local Government is responsible only for cross Departmental elements associated with the implementation of the Plan. It is ENVIRONMENTAL RESOURCES MANAGEMENT DEPARTMENT OF THE ENVIRONMENT, HERITAGE AND LOCAL GOVERNMENT 1

4 not responsible for training as provided for under each sub-plan of the relevant Departments. Nonetheless, it is clear that greater focus be given to the provision of training in order to underpin the sub plan process. The Department (EHLG) is therefore finalising the preparation of memoranda of understanding that will include, in addition to the setting of the strategic criteria for application in each sub-plan and business plan, training needs as identified in the review for completion by each Department. It is further expected that inclusion in the business plans of training requirements to meet NEPNA needs will help to raise awareness within the management layers of each Department and will reinforce the importance of having a high level input to the ERCC on an ongoing basis. Familiarisation training other than ministerial briefings has taken place at this senior level and requires further attention in particular through the use of exercises. This requires attention particularly in light of recent changes at the Minister and Minister of State level. The Training needs for ERCC personnel within the Department of the Environment, Heritage and Local Government are recognised and are addressed through a phased programme of exercises that are ongoing including attendance at international training programmes and through direct interface between the ERCC members, related agencies, and local authorities. Indeed it is noted that a series of briefing talks for senior fire officers took place in Wider staff-training issues are recognised and will be a particular focus in the memoranda of understanding/service level agreements to be put in place in the coming year. Regular reporting on the ERCC and its activities are through a Government Task Force (GTF) under the chairmanship of the Minister for Defence. 1.3 CBRN (CHEMICAL BIOLOGICAL RADIOLOGICAL NUCLEAR) INTERFACE Given the public's concerns arising from the high level of reporting at both the national and international level of the potential for terrorist actions, it is important to stress what is understood to be the relatively low level risk arising in Ireland from such actions as well as the low level risk arising from a nuclear accident. The nuclear risk, which is primarily the focus of the NEPNA, is distinct and different from that associated with terrorist based incidents in the CBRN context. The Department (EHLG) through the Minister should provide a clear line of understanding in regard to his Department s responsibilities for CBRN management ensuring that; ENVIRONMENTAL RESOURCES MANAGEMENT DEPARTMENT OF THE ENVIRONMENT, HERITAGE AND LOCAL GOVERNMENT 2

5 Immediate responses to local incidents are in accordance with local emergency services standard operating procedures and major emergency plans if necessary. The Department Circular on the NEPNA to the Local Authorities should refer once again to the role of the RPII in regard to nuclear consultations and at an advanced stage a linking of NEPNA to local major emergency plans in a manner, which deals with the response to nuclear and radiological incidents regardless of the origins of the incident. 1.4 MEDIA MANAGEMENT PROCESS The media have an important role in providing public information on the risks and countermeasures in close liaison with the Government Information Service (GIS) to ensure that the media process works alongside with the ERCC. Furthermore, and with specific reference to the launch of the revised plan and the publication of the review, recognition of local perspectives on nuclear issues must be considered. In addition therefore to advising the Departments affected contact with the following needs to be established to ensure that they are positioned to address any media or public information requests in regard to their role in the NEP: Food Safety Authority of Ireland; Met Eireann; EPA, RTE; An Garda Siochana; The Civil Defence; The Health Boards Executive; Health and Safety Authority. In regard to a specific issue, i.e. the use of iodine and its availability, the Department of Health and Children should maintain current accepted international advice and should also indicate where tablets may be sought by those members of the public that currently do not have access to such tablets. 1.5 SPECIFIC ACTIONS FOR 2005 The ERCC and the Department of the Environment, Heritage and Local Government should in 2005: Apply a continued emphasis on the implementation of the recommendations of the ERM Report and the embedding of international advice and best practice into the procedures and processes associated with the Plan; ENVIRONMENTAL RESOURCES MANAGEMENT DEPARTMENT OF THE ENVIRONMENT, HERITAGE AND LOCAL GOVERNMENT 3

6 Commission and publish the Expert Review on the impact of a nuclear accident and incident and subsequent possible implications for Ireland. Develop plan scenarios based upon the Expert Review leading to a further national exercise; Oversee and facilitate the incorporation of a sub-plan provision into all Departmental Business Plans in 2005; Participate in two international exercises, provide familiarisation and briefing to Ministers, Secretaries General and ERCC members; Provide for a continued roll out of Memoranda of Understanding, Service Level Agreements and revisions to sub-plans; Implement enhancements to the existing continuous radiation monitoring network; Issue of circulars to key groups/agencies; Implementation of an information and communications programme in cooperation with the GIS; Provision of information/experience sharing across Departments and at the international level; Maintain an accessible and up-to-date website; Review and update the Plan as implementation of the above proceeds; Re-establish mandate of ERCC through a clarification of its advisory role to Ministers and Secretaries General; Clarification of Secretaries General responsibilities through a letter from the. This should include a requirement on the relevant Secretaries General to sign the memoranda of understanding on behalf of the relevant Department. ENVIRONMENTAL RESOURCES MANAGEMENT DEPARTMENT OF THE ENVIRONMENT, HERITAGE AND LOCAL GOVERNMENT 4

7 1.6 RESOURCES It is recommended that resource needs for the implementation of 2005 actions should be provided and underpinned as follows:- Training need and response on emergency response management to be the responsibility of the relevant Departments. The Department of the Environment, Heritage and Local Government to advise as set out above so that this can be reflected in the business plans of the relevant Departments; Planning/execution of plans/sub-plans and resourcing thereof to be identified in business plans as appropriate; Staff/Support Services - Training for wider staff should not a priority in general but a focus on the staff most immediately affected will be required.

8 Annex A Bench Marking Recommendation Matrix

9 No. Recommendation Applied By Actions undertaken to date 1 Define and establish the legislative basis for actions that may be required by contributing or participating authorities. Department of Environment, Heritage and Local Government S.I. No. 125 of 2000, Radiological Protection Act 1991 (Ionising Radiation Order) sets out the legislative basis for the preparation and issue of the National Emergency Plan for Nuclear Accidents (NEPNA). The roles of the relevant Departments are determined in the Plan. The detailed responsibilities of Departments have been identified and these have been brought to the attention of the Departments concerned. In regard to local planning, the Fire Services Act 1981 established the roles of the Fire Authority and Local Authority. Each Department or Agency with responsibility with regard to Emergency Planning has a sub-plan linked to the NEPNA. This is being developed through memoranda of understanding that set clearly the roles and responsibilities of relevant Departments from the Department of the Environment to the other Departments. Each sub-plan must fall within the relevant Department and is to clearly be integrated into the business planning of that Department. 2 Current national plan be reviewed and rewritten to provide the basis for clear task assignment, and coordinated execution on the basis of recommendation 1. Department of Environment, Heritage and Local Government The developing Plan is regularly reviewed and updated. The most recent update was in March It is recommended that mandates, responsibilities and authority for the management and execution of elements of the plan be clearly defined. The mandates should eliminate all ambiguity, and should specify the responsibilities for control and coordination between national planning and local implementation. Department of Environment, Heritage and Local Government The relevant Departments have been consulted to define their specific roles/responsibilities. These are reflected in the development of memoranda of understanding and service level agreements. Where appropriate, Department sub-plans have been revised. 4 It is recommended that the arrangements for both Emergency Public Information and Media Information and Briefing should be Government Information Service (GIS). fundamentally reviewed and significantly strengthened. An Emergency Planning Media Group has been established. The Government Information Service has taken a direct role. Preparation of information notices are currently in hand. 5 It is recommended that the arrangements for timely collection of samples for radiological analysis and for the reporting of results, be reviewed. Radiological Protection Institute of Ireland RPII in consultation with Met Eireann, operates a national network of 12 monitoring stations across the State. The Data derived from the stations is available to the Authorities in "real-time". From 2005 this data will also be available through the RPII website. The RPII has developed an emergency sampling procedures manual that has been distributed to the Civil Defence and other Authorities. Exercises in sample collection (with Met Eireann) have been undertaken. Arrangements are in place between the RPII, Department of Agriculture & Food and the Food Safety Authority of Ireland for the timely collection of samples for analysis following an emergency. These arrangements are regularly reviewed. The RPII continues to maintain state of the art laboratory facilities for testing of foodstuffs and environmental samples. Reports on the results of analyses are made to the ERCC. 6 It is recommended that the assessment of the medium to longterm implications of a nuclear incident that result in contamination in Ireland be addressed, in areas such as health impact, environmental impact and any consequent on-going resource demands and organisational arrangements. The implications of a nuclear accident or incident have been assessed by the RPII. The Department is proposing to commission an expert study in 2005 to peer review Irish arrangements with reference to the latest IAEA best practice guidelines. This is to review studies on incidents to date world-wide and to apply the experiences to the Irish spatial context to determine potential impacts. A key objective is that of minimising exposure of people so as to bring long-term advantage by reducing the risk of cancer. 7 It is recommended that the role and functioning of the Committee of Ministers (CoM) be more fully defined, to assist both the CoM and the ERCC in fulfilling their roles effectively. Clarification will allow representatives on the ERCC to appreciate more clearly the nature and level of strategic direction to be provided from the CoM, and the executive role likely to be demanded of the ERCC. An overall response framework for interaction has been put in place by the Government to improve political direction in emergencies. As part of this, a Cabinet Committee will be expected to convene in the event of a national emergency that poses a threat to health or property on a national scale or serious disruption to national life. 8 It is recommended that clear roles, responsibilities, and commensurate authority for necessary action, be defined for the ERCC. This should include appropriate levels of authority, vested in individuals, for the co-ordination and control of resources in the accomplishment of assigned tasks. A framework for interaction has been put in place through development of draft standard operating procedures issued following consultation and to be introduced in early It is recommended that arrangements for the management of data and information be developed. This would include facilities and infrastructure for secure communication and the transmission of data; systems and procedures to ensure that information is provided to those who need it; to ensure that decisions and instructions are notified and these decisions are executed and confirmed. Radiological Protection Institute of Ireland An enhanced management information system is in place in the RPII. It is a computerised system with a web base to distribute and record the level of information through the course of an event. This enhanced system was been presented at a major international conference earlier this year. 10 It is recommended that the arrangements for the location of the CoM, ERCC and RPII need to be reviewed. Any review should address the consequential considerations for the deployment of individuals, particularly key members of the RPII, and the arrangements for communicating information and decisions. Office of Public Works/Department of the Environment, Heritage and Local Government/Department of Defence The NEPNA currently functions out of the RPII and has access to all necessary equipment and support. This is distinct from a National Emergency Coordination Centre (NECC) which would cater for emergency responses to a variety of events. A recently completed study on the development of a national centre for all emergencies including that of NEPNA has recommended the type of facility and location. Once the decision on the location has been taken, equipment needs are to be clarified and development of the facility will commence. 11 It is recommended that the deployment and employment of public and press information staffs across all contributing Departments and agencies be reviewed. Current arrangements place potentially Government Information Services unmanageable burdens on the RPII, and provide no co-ordination for the dissemination of advice and guidance to the public. An Emergency Planning Media Group is in place, representing media officers of the key responding Departments. It meets regularly and has structures that have been tested around major events such as the EU Presidency It is recommended that a set of agreements, memoranda of understanding, and standard operating procedures, be established between, and within, contributing departments and agencies. This would specify responsibilities, provide a checklist for immediate actions, and establish continuity in the face of staff reassignments. It is recommended that consideration should be given to the establishment of a single office, with responsibility, and overriding authority, for all national emergency planning, and coordinating national and local emergency response. This office Department of Defence would provide the integrating mechanism, continuity, and expertise for the training and management of emergency planning and operations. It is recommended that the National Emergency Plan for Nuclear Accidents, as currently structured, is inadequate as a basis for coordinated and integrated emergency management and should be substantially strengthened and revised to address the issues identified in this report. See 1-3 above The Office of Emergency Planning is in place under the Cabinet responsibility of the Minister of Defence. The Government Task Force operates under the chairmanship of the Minister for Defence. The NEPNA is based on best international guidance. To ensure it operates effectively and efficiently, it is under constant review and up-dating. The most recent update took place in March The ongoing development of memoranda of understanding (MOU) and standard operating procedures (SOP) will further strengthen the effectiveness of NEPNA and contribute to improving response capability.

10 15 It is recommended that a review of the arrangements within the national plan should incorporate a limited range of threat scenarios. The threat scenarios should examine the consequences for Ireland, of incidents of varying severity, under a range of conditions of weather and time, and arising at various sites or sources in Europe. These hazards or threat assessments Department of the Environment, Heritage and Local would form the basis for sets of pre-determined and graduated Government/RPII immediate actions, and commitments of resources and supports. These scenarios should address the characteristics and responses based on particular nuclear facilities and possible weather patterns. The scenarios should become integral elements of the rewritten plan. RPII has rewritten its sub-plan to reflect current best practice internationally. This is based on international guidance which is now available and can be integrated into Irish procedures. Application of IAEA guidance on the extent of risk is under review as a part of an Expert Review currently underway. Matters arising will be addressed as part of the on-going revision of the plan. International benchmarking will underpin the revision. Circulars to Local Authorities have issued. The Defence Forces reequipment programme is in place. The RPII now requires its licence holders under certain circumstances to have their own local emergency plans. 16 It is recommended that planning arrangements should identify those resources that, though not readily available in Ireland, may be made available by international bodies and governments. Department of the Environment, Heritage and Local Government Consideration should be given as to how these resources might be received and best employed. Ireland is party to two international agreements on mutual assistance in the event of a Nuclear Accident or Radiological Emergency. These are the 1986 Vienna Convention on Assistance in the Case of a Nuclear Accident or Radiological Emergency and the EU mutual assistance arrangements set up in the context of Council Conclusion ( ). These arrangements specify a mechanism by which assistance can be requested or offered. Together these arrangements provide a robust and efficient means by which resources not available in Ireland could be sought in the event of an emergency. More recently, the IAEA agreed (Summer 2004) an action plan on enhancing international requirements and strengthening a national planning for preparedness for, and response to, nuclear and radiological emergencies. This action plan addresses a number of issues intended to strengthen mutual assistance arrangements. Ireland participated actively in the development of this action plan and is now working with other Member States to implement this plan. 17 It is recommended that the capacity and capabilities to measure and monitor the movement of a radioactive plume over the Irish Sea, through aerial monitoring or other means be reviewed and that arrangements be put in place to incorporate the recommendations of this review, on completion, into national emergency management procedures. Radiological Protection Institute of Ireland RPII has reviewed the international experience with air borne monitoring systems with reference to emergency preparedness requirements in Ireland. The RPII has recommended the purchase of systems suitable for mapping deposition of radioactivity following an accident. This is currently in train. Technical arrangements are now in place to access the UK RIMNET monitoring network. 18 It is recommended that the existing network of fixed radiation monitoring stations be reviewed to address possible gaps in the network that may exist in areas which may be close to nuclear installations. Radiological Protection Institute of Ireland The RPII in conjunction with Met Eireann operates a national network of permanent monitoring stations (PMS) for radioactivity. These facilities include 12 stations at which external gamma dose rate is continuously measured and automatically transmitted back to a central computer at the RPII and 10 stations at which air is continuously sampled for radioactivity measurement. Following the ERM report the RPII conducted a comprehensive review of this network. This review concluded that the PMS network continued to function well but recommended a number of enhancements/upgrades designed to increase functionality and to ensure that the system continues to function into the future. A programme to implement these enhancements/upgrades is now in place. A contractor is in place to implement phase 1 of this work, which is on schedule for completion in February It is recommended that the implementation of Evacuation as a countermeasure should be reviewed. The exercise highlighted an emergency scenario developing which however unlikely is possible. It combined several worst cases to create a radiological risk that could warrant evacuation of large geographical areas. Given such circumstances this would present severe logistical difficulties that, however unlikely, must be addressed. The review should more clearly define the extent and scope to which evacuation may be usefully employed. The review should take cognisance of the responsibilities already existing for local authorities under current regulations. The review should define overall authority for a decision to evacuate, responsibilities for execution, and the issues to be addressed in detail and the necessity for formal inter-agency or inter-authority agreements. It is not envisaged that an accident at a nuclear installation abroad would give rise to the need for evacuation of people in Ireland. This conclusion is in line with internationally accepted best practice and has recently been reinforced by the publication in 2002 of the IAEA Safety Standard Preparedness and Response for a Nuclear or Radiological Emergency (GS-R-2). The IAEA guidance recommends that pre planning for precautionary evacuation is unlikely to be justified at distances greater than 25 km from a nuclear facility. The closest nuclear facility to Ireland is the Wylfa nuclear reactor in north Wales, which is 110 km from the Irish coastline at the closest point. 20 It is recommended that any review of current emergency planning arrangements should seek to clarify existing mandates, authorities and responsibilities from all contributing organisations and designated individuals. This element of the review should establish a matrix of mandates which will ensure clarity of responsibilities for the ERCC and the CoM, for Departments, agencies and authorities contributing to the operation of the ERCC, and for individuals assigned specific tasks within those Departments, agencies and authorities. An overall response framework for interaction has been put in place by Government to improve political direction in emergencies. As part of this, a Cabinet Committee will be expected to convene in the event of a national emergency that poses a threat to health or property on a national scale or serious disruption to national life. 21 It is recommended that the mobilisation and call-out procedures as currently described be reviewed. The review should address the potential for warning/notification to be received through formal protocols or informal means directly to the RPII, and how this warning would be transmitted through the facilities of the GCCC. Protocols or other arrangement should be clearly described, noting responsibilities, constraints and expectations. New procedures should address the need for security and authentication of information., RPII Regular reviews are carried out. The most recent of which took place in July 2004 and the system was tested in October. Regular testing through ECURIE etc takes place every 6 weeks. The Computer systems are tested daily. 22 It is recommended that arrangements for early public warning in the national plan be reviewed to ensure that effective public warning can be delivered at all times of the day or night, and in all circumstances In the event of a nuclear emergency, information and advice to the public will be given primarily through radio and television announcements. The Government Task Force has examined public warning systems and on-going liaison with broadcasters and regulatory authorities is in place. Feasibility studies on best systems are in train. Procedures and processes for further enhancement and development are under continuous review.

11 23 It is recommended that the assignment of staff to participate in the ERCC must take cognisance of the ability of the ERCC to quickly assemble an effective working core from its membership. Mobilisation times in excess of 1 hour are not adequate. Location issue is being addressed. Ongoing exercises indicate less than 1 hour mobilisation is the norm to date. The assignment of staff to the ERCC and their ability to assemble quickly is being covered by SOP and MOU. 24 It is recommended that the selection processes for staff to be appointed to membership of the ERCC should be based on defined competencies and leadership qualities. The redeployment or promotion of experienced staff should not be an automatic cause for replacement on the ERCC. Department of the Environment, Heritage and local Government The tie in with memoranda of understanding with each Department will be applied. The ERCC accepted that the recommendation should be applied in full It is recommended that Government Departments and participating agencies should establish a team of supporting staff of sufficient numbers and equivalent competence to provide the relief staff necessary to sustain the operations of the ERCC for a period of up to 72 hours. It is recommended that that additional support staff be assigned to the ERCC from each Department to the assist in the routine operation of the Committee, and free its members to concentrate on their primary task. The ERCC accepted that this recommendation should be applied in full. The issue is to be addressed in the next review of Departmental sub-plans and in development of the standard operating procedures. The ERCC accepted this recommendation and it is being applied as part of the development of the National Emergency Coordination Centre 27 It is recommended that the location of the ERCC be reviewed in light of the potentially inadequate capacity of the headquarters of the RPII. It is further recommended that a more appropriate location may lie in a dedicated emergency management centre of operations closer to the seat of government, existing communications facilities and the Committee of Ministers. The designation of an alternate equivalent centre of operations outside the city should be considered in the event of the primary centre becoming untenable. The ERCC accepted this recommendation and it is being applied as part of the development of the National Emergency Coordination Centre (NECC). The NEPNA currently functions out of the RPII and has access to all necessary equipment and support. This is distinct from an NECC which would cater for emergency responses to a variety of events. A recently completed study on the development of a national centre for all emergencies has recommended the type of facility and location. Once the decision on the location has been taken, equipment needs are to be clarified and development of the facility will commence. 28 It is recommended that the review should examine the consequential arrangements necessary to ensure adequate communication links with the RPII and other agencies. The review should also review the redundancies and security required to maintain communications between the centres of operation and the RPII, and local agencies and authorities with responsibilities for executing elements of the plan. The RPII has examined its communication systems including their reliability and redundancy. Improvements have been carried out. This would be applied also in the development of a NECC. 29 It is recommended that the establishment of a simple but robust information management system be established as a matter of priority, as a means of processing, recording and disseminating incoming information. The system should serve the ERCC, the CoM, the Emergency Public Information team, the Media Information and Briefing team, and the RPII, contributing to a clear and unified understanding of events as they might unfold. Radiological Protection Institute of Ireland As 28 above. Keeping of records has been accepted by the ERCC for application in future exercises and incidents. 30 It is recommended that the ERCC should establish standard operating procedures for its work. These SOPs should include the clear designation of a Deputy Chair and succession protocols; and that at no time should both the Chair and Deputy Chair be absent from the ERCC while it is session. The ERCC has accepted this recommendation. The means to apply standard operation procedures is under exploration by the ERCC. Regular meetings of the ERCC remain in place. 31 It is recommended that, in light of the key role being played by the ERCC, that provision be made for the priority transportation of the Chair or Deputy Chair, should such movement be deemed necessary. This may include the provision of helicopter transport. Mobilisation exercises to date are positive. Nonetheless, the ERCC has accepted this recommendation and have begun to address it with An Garda Siochana It is recommended that the current organisation for Emergency Public Information and Media Information and Briefing be fundamentally reviewed. The review should examine the establishment of dedicated teams from within existing staff resources at Government Departments and agencies contributing to emergency management. A clear function of these teams should be to ensure that conflicting or confused briefings are avoided, and that public reassurance from early, regular and factual information is achieved. It is recommended that an appropriate agency be tasked with undertaking an annual audit of plans, arrangements, resourcing and training, and that a report with the results and recommendations from this audit should be placed before Government. Office for Emergency Planning(OEP) It is recommended that training and exercises be expanded to include the Committee of Ministers, and Departmental Secretaries General and Assistant Secretaries who would be advising the Committee. Exercises should be directed to clarifying the respective mandates for action in both the CoM and ERCC, with particular emphasis on evacuation as a countermeasure, and consideration of long-term strategic issues of emergency and recovery management. See 11 above OEP has established an oversight/quality review of plans with annual reports to Government. Annual meetings to oversee the audits are in place. Another major independently reviewed "on call" exercise will be organised over the next 15 months. This will include a Ministerial component. The best available analysis to date is that evacuation is not considered as an appropriate countermeasure for the type of nuclear accident to which Ireland could be exposed. 35 It is recommended that a programme of ongoing training and exercises should be established to perfect emergency management procedures. Such a programme should co-ordinate training in participating Departments, agencies and subordinate authorities, contributing to a process of continuous overall improvement. Training programmes should be reviewed as part of the annual audit of plans, as recommended above. Regular exercises now occurring internationally with Irish participation. 36 It is recommended that at least one annual test of mobilisation procedures be undertaken, involving the GCCC and all participating Departments and Agencies. A mobilisation exercise took place last July It is recommended that all Government Departments, agencies and subordinate should make specific and adequate provision in annual budgets to fulfil requirements for training programmes and resource provision under the national plan. All Departments In place and dealt with through normal business planning.

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