Emergency Action Planning

Emergency Action Planning.

Employers, when it comes to workplace emergencies, have your employees been informed and trained on:

•  Evacuation routes?
•  Emergency contact numbers?
•  Authorized and appointed assist & rescue personnel?
•  Gathering and muster points?
•  Shelter in place and safe room locations?
•  Location of first aid and emergency equipment such as fire extinguishers?

With October being widely recognized as Fire Safety month, employers should take this time to evaluate their Emergency Action Plan, also known as EAP. It is extremely important for both office and worksite locations that an EAP is developed, implemented, maintained, and evaluated. Planning is key to minimize injuries, illnesses, and damage when emergencies arise. Examples of such emergencies include:

• Fires
• Bomb Threats
• Severe Weather
• Chemical Releases
• Medical Emergencies
• Workplace Violence

Despite best compliance intentions, emergency incidents can still occur. One cannot predict where and when these incidents will happen, which is why Emergency Action Planning is so critical. According to the Occupational Safety & Health Administration (OSHA), the purpose of an EAP isto facilitate and organize employer and employee actions during workplace emergencies.

OSHA Requirements for EAP

Even though Emergency Action Planning just makes good sense from an industry best practices standpoint, OSHA requires an EAP whenever a separate standard calls for one. OSHA regulations address Emergency Action Plans in 29 CFR 1910.38, under Subpart E, Exit Routes & Emergency Planning.  

Section 1910.38 specifically addresses the following EAP information:

•  Written and oral emergency action plans- An emergency action plan must be in writing, kept in the workplace, and available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees.
• Minimum elements of an emergency action plan- An emergency action plan must include at a minimum:
  • Procedures for reporting a fire or other emergency
  • Procedures for emergency evacuation, including type of evacuation and exit route assignments
  • Procedures to be followed by employees who remain to operate critical plant operations before they evacuate
  • Procedures to account for all employees after evacuation
  • Procedures to be followed by employees performing rescue or medical duties; and
  • The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.
•  Employee alarm systems- An employer must have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in Section 1910.165.
• Training- An employer must designate and train employees to assist in a safe and orderly evacuation of other employees
•  Review of emergency action plan-An employer must review the emergency action plan with each employee covered by the plan:
  • When the plan is developed, or the employee is assigned initially to a job
  • When the employee's responsibilities under the plan change, and
  • When the plan is changed.

 Employees should ask their immediate supervisor about EAP instructions and look for EAP postings.

 OSHA 29 CFR 1910 Subpart E also contains other applicable sections for Emergency Action Planning. Among them are:

• 1910.34 Coverage & definitions
• 1910.35 Compliance with alternate exit route codes
• 1910.36 Design and construction requirements for exit routes
• 1910.37 Maintenance, safeguards, and operational features for exit routes
• Subpart E Appendix

 And although considered to be a separate plan, employers should carefully review:

• 1910.39 Fire Prevention Plans
• Subpart L Fire Protection

If you don’t yet have an Emergency Action Plan, OSHA has developed an informative and useful EAP E-Tool website that includes a checklist template that can be utilized to assist in developing your written EAP:

Finally, the National Fire Protection Association (NFPA) offers some informative consensus standards and codes which can be useful to reference for additional guidance in the development of an Emergency Action Plan. Here is a comprehensive list of all their codes and standards to choose from: https://www.nfpa.org/Codes-and-Standards/All-Codes-and-Standards/List-of-Codes-and-Standards.

Sign Up for Online OSHA Training

Employers, don’t wait for an emergency to discover you didn’t have an adequate Emergency Action Plan. Be sure to design, develop, implement, review, and revise your EAP for your workforce. National Environmental Trainers offers online OSHA training for a broad selection of industries. If you or your employees need training, sign up now.