December 2009
Emergency Action Plans

The following selected information was obtained from OSHA's website "Evacuations Plans and Procedures eTool" found at the website: http://www.osha.gov/SLTC/etools/evacuation/index.html

Please follow the underlined links for more detailed information from the OSHA website.

Do I Need an Emergency Action Plan?

Almost every business is required to have an emergency action plan (EAP).

If fire extinguishers are required or provided in your workplace, and if anyone will be evacuating during a fire or other emergency, then OSHA's 29 CFR 1910.157 requires you to have an EAP.

The only exemption to this is if you have an in-house fire brigade in which every employee is trained and equipped to fight fires, and consequently, no one evacuates.

In most circumstances, immediate evacuation is the best policy, especially if professional firefighting services are available to respond quickly. There may be situations where employee firefighting is warranted to give other workers time to escape, or to prevent danger to others by spread of a fire. In this case, you as the employer are still required to have an EAP.

To help you decide whether to have employees evacuate or fight fires, see the Fight or Flee? section of this eTool.

Still unsure about whether you are required to have an EAP??? Use OSHA's Expert System to help you determine whether you are required to have an EAP.

What is an Emergency Action Plan?

An emergency action plan (EAP) is a written document required by particular OSHA standards [29 CFR 1910.38(a)]. The purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. Well developed emergency plans and proper employee training (such that employees understand their roles and responsibilities within the plan) will result in fewer and less severe employee injuries and less structural damage to the facility during emergencies. A poorly prepared plan, likely will lead to a disorganized evacuation or emergency response, resulting in confusion, injury, and property damage.

Putting together a comprehensive emergency action plan that deals with those issues specific to your worksite is not difficult. It involves taking what was learned from your workplace evaluation and describing how employees will respond to different types of emergencies, taking into account your specific worksite layout, structural features, and emergency systems. Most organizations find it beneficial to include a diverse group of representatives (management and employees) in this planning process and to meet frequently to review progress and allocate development tasks. The commitment and support of all employees is critical to the plan's success in the event of an emergency; ask for their help in establishing and implementing your emergency action plan. For smaller organizations, the plan does not need to be written and may be communicated orally if there are 10 or fewer employees [29 CFR 1910.38(b)].

At a minimum, the plan must include but is not limited to the following elements [29 CFR 1910.38(c)]:

  Means of reporting fires and other emergencies

  Evacuation procedures and emergency escape 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 an emergency evacuation has been completed

  Rescue and medical duties for those employees who are to perform them

  Names or job titles of persons who can be contacted for further information or explanation of duties under the plan

Although they are not specifically required by OSHA, you may find it helpful to include the following in your plan:

  A description of the alarm system to be used to notify employees (including disabled employees) to evacuate and/or take other actions. The alarms used for different actions should be distinctive and might include horn blasts, sirens, or even public address systems. [More on Alarms]

  The site of an alternative communications center to be used in the event of a fire or explosion; and

  A secure on- or offsite location to store originals or duplicate copies of accounting records, legal documents, your employees' emergency contact lists, and other essential records.

Now that you have read through the basic overview of an emergency action plan, find out how to implement your plan.

Written Emergency Action Plans

An emergency action plan (EAP) is usually a written document required by particular OSHA standards. For smaller organizations, the plan does not need to be written and may be communicated orally if there are 10 or fewer employees [29 CFR 1910.38(b)]. The purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. The elements of the plan must include, but are not limited to:

  Means of reporting fires and other emergencies

  Evacuation procedures and emergency escape 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 an emergency evacuation has been completed

  Rescue and medical duties for those employees who are to perform them

  Names or job titles of persons who can be contacted for further information or explanation of duties under the plan

OSHA has an e-tool that will help you develop your own written plan.

This expert system will help you to create a simple EAP. This basic plan will be adequate for needs of many small and medium-sized entities. This basic plan may not be adequate for large establishments or those with more significant hazards. Users in such establishments should consider the special characteristics of their workplaces. Users can supplement this basic plan to address any situations that require special attention.

This OSHA Expert only provides information based on Federal OSHA Emergency Action Plan requirements. If you are covered by a state OSHA plan you may need to contact your local state OSHA office.

Most small and medium-sized entities will get their basic plans from this system in 10 to 15 minutes. Please remember that this system does not save the plan it helps you to write, so you should save and/or print your plan when it is completed. To use the e-tool go to this website: http://www.osha.gov/SLTC/etools/evacuation/expertsystem/default.htm#

Businesses that deal with hazardous substances (such as Ethylene Oxide, Methylenedianiline, or Butadiene), or that are subject to the provisions of the Process Safety Management of Highly Hazardous Chemicals, Hazardous Waste Operations, or Grain Handling standards may also need to develop an emergency action plan in compliance with 29 CFR 1910.38(a). However, these businesses are beyond the scope of this eTool.

How do I evaluate my workplace to comply with OSHA's emergency standards?

The best way to protect yourself and others is to prepare for an emergency before it happens by doing a thorough assessment of the workplace. Think about possible emergency situations and evaluate your workplace to see if it is sufficiently prepared in the following areas:

  Design and construction requirements for exit routes [29 CFR 1910.36]

  Maintenance, safeguards, and operational features for exit routes [29 CFR 1910.37]

  Emergency action plans (EAP) [29 CFR 1910.38]

  Fire prevention plans (FPP) [29 CFR 1910.39]

  Portable fire extinguishers [29 CFR 1910.157]

  Fixed extinguishing systems [29 CFR 1910.160]

  Fire detection systems [29 CFR 1910.164]

  Employee alarm systems [29 CFR 1910.165]

As always, if there are questions or items that I can help you with, please don't hesitate to contact me.

Michael Dodd

GAWDA DOT, Security, OSHA, & EPA Consultant
MLD Safety Associates, LLC

P.O. Box 93
Poplar Bluff, MO 63902
(573) 785-5111
Fax: (573) 785-5112
Email: MLDSafety@hotmail.com