Understand When an Emergency Action Plan Is Required
Before creating an emergency action plan, determine which OSHA requirements apply to your workplace. Under 29 CFR 1910.38, an employer must have an EAP when an applicable OSHA standard requires one. OSHA identifies several standards that may trigger EAP requirements, including requirements associated with highly hazardous chemicals, fire detection systems, fixed extinguishing systems, grain handling, and certain hazardous substances.
Even when a specific OSHA standard does not require an EAP, OSHA recommends emergency planning for employers because organized preparation can help workers respond more effectively during emergencies.
For most workplaces covered by 29 CFR 1910.38, the plan must be written and kept at the workplace where employees can review it. Employers with 10 or fewer employees may communicate the plan orally rather than maintaining a written plan under the general industry rule.
Start With a Workplace Hazard Assessment
A useful emergency action plan should be based on the actual workplace rather than a generic template.
Begin by identifying emergencies that employees could reasonably encounter. Depending on the facility, these might include:
- Fire
- Chemical spills or releases
- Severe storms
- Tornadoes
- Flooding
- Earthquakes
- Utility failures
- Explosions
- Workplace violence
- Medical emergencies
- Hazardous material incidents
- Equipment failures
- Other site-specific emergencies
OSHA recommends considering the workplace layout, processes, materials, surrounding environment, emergency systems, and other characteristics when developing an EAP.
Consider the hazards in each area of the facility. A manufacturing operation may have chemical and machinery hazards, while an office may have different risks involving fire, severe weather, or workplace violence.
The assessment should also consider visitors, contractors, temporary employees, and workers who may need additional assistance during an evacuation.
Include the Required Elements
The foundation of an OSHA-compliant emergency action plan is making sure the required information is clearly documented.
Under 29 CFR 1910.38, the plan must address six primary areas:
- Procedures for reporting fires and other emergencies
- Emergency evacuation procedures and exit route assignments
- Procedures for employees who remain to operate critical operations before evacuation
- Procedures for accounting for employees after evacuation
- Rescue and medical duties for designated employees
- Names or job titles of people employees can contact for additional information about the plan or their responsibilities
These requirements should be written in straightforward language. Employees should not have to interpret complicated instructions during a stressful emergency.
Establish Clear Emergency Reporting Procedures
Employees need to know how to report an emergency immediately.
Your emergency action plan should identify the preferred reporting method for fires and other emergencies. Depending on the workplace, this could involve dialing an emergency number, activating a manual alarm, contacting a designated supervisor, or using another established communication system.
Emergency contact information should be easy to locate. If telephones are used for reporting emergencies, OSHA’s guidance recommends posting emergency telephone numbers in conspicuous locations.
The plan should also explain what information employees should provide when reporting an incident, such as the location, type of emergency, people affected, and immediate hazards when it is safe to provide that information.
Create Detailed Evacuation Procedures
Evacuation instructions should tell employees exactly what to do after an alarm or emergency notification.
Identify primary and alternate exit routes throughout the workplace. Floor plans and workplace maps can make these instructions easier to understand. Employees should know where exits are located and where they should assemble after leaving the building.
The emergency action plan should also specify the type of evacuation required for different situations. Some emergencies may require a complete evacuation, while others could require employees to shelter in place or move to another area.
OSHA recommends considering emergency conditions specific to the workplace and identifying appropriate evacuation actions.
Exit routes should remain accessible and employees should be familiar with them before an emergency occurs.
Establish an Employee Accountability System
Evacuation is not complete simply because people have left the building. Employers also need a method for determining whether everyone has reached safety.
Choose designated assembly areas that are far enough away from the immediate hazard. Establish procedures for supervisors, managers, or other designated personnel to account for employees.
Accountability procedures can include:
- Employee rosters
- Department lists
- Visitor logs
- Contractor records
- Supervisor headcounts
- Designated assembly coordinators
The plan should also explain how missing employees are reported to emergency responders. Employees should not be instructed to re-enter a hazardous building to search for someone unless they are specifically trained and authorized to perform rescue duties.
Address Critical Operations and Emergency Shutdowns
Some workplaces have operations that cannot simply be abandoned when an alarm sounds. Certain employees may need to perform specific shutdown procedures before evacuating.
The EAP should identify these critical operations and clearly describe who is authorized to perform them. OSHA specifically requires procedures for employees who remain temporarily to operate critical plant operations before evacuation.
These procedures should be limited to actions that can be performed safely. Employees should understand when they must stop the shutdown process and evacuate.
Assign Rescue and Medical Responsibilities
If employees have designated rescue or medical responsibilities, the emergency action plan should identify those duties.
Do not assume that every employee should participate in emergency response activities. Rescue responsibilities should be assigned only to workers who are appropriately trained and prepared for the tasks they are expected to perform.
The plan should also identify how employees should obtain emergency medical assistance and how emergency responders will access the facility.
Build an Effective Alarm and Communication System
An emergency action plan needs a reliable way to alert workers.
Under 29 CFR 1910.38, employers must maintain an employee alarm system when the standard applies, and the system must use distinctive signals for different purposes and comply with 29 CFR 1910.165.
The communication method should work for everyone who may be present at the workplace. OSHA’s guidance recommends considering how employees, including workers with disabilities, will be informed of an emergency and what response is expected.
Depending on the facility, communication may include audible alarms, visual signals, public-address systems, radios, telephones, or other appropriate methods.
Consider Employees With Special Needs
A strong emergency action plan should account for employees who may require additional assistance.
Review evacuation routes and procedures for workers with mobility, hearing, vision, or other limitations. Determine how assistance will be provided and who is responsible for coordinating it.
The goal is to ensure that emergency instructions and warnings can reach everyone who may be affected.
OSHA specifically encourages employers to consider workers with disabilities and other special needs when developing emergency procedures.
Train Employees on the Plan
Writing an emergency action plan is only the beginning. Employees need to understand their responsibilities before an emergency happens.
Training should cover the types of emergencies that may occur, reporting procedures, alarm systems, evacuation routes, assembly areas, accountability procedures, emergency shutdown responsibilities, and other relevant duties. OSHA’s guidance emphasizes that employees should understand their roles and responsibilities under the plan.
Employers must designate and train employees to assist with safe and orderly evacuation. The plan must also be reviewed with employees when it is developed or when an employee is initially assigned to a job, when responsibilities change, and whenever the plan changes.
Regular drills can also help employees become familiar with evacuation routes and assembly procedures.
Review and Update the Emergency Action Plan
Workplaces change over time. New equipment, materials, processes, employees, building layouts, and emergency systems can affect the effectiveness of an emergency action plan.
Review the plan whenever significant workplace changes occur. Also evaluate the plan after drills, actual emergencies, or incidents that reveal weaknesses in the response.
Ask practical questions such as:
- Did employees understand the alarm?
- Were evacuation routes accessible?
- Did everyone reach the assembly area?
- Was the accountability process effective?
- Did supervisors understand their responsibilities?
- Were emergency contacts current?
- Did employees with special needs receive appropriate assistance?
- Were there communication problems?
OSHA recommends reviewing and updating the plan as employee responsibilities or the plan itself changes.
Make the Plan Accessible and Practical
An emergency action plan should be easy for employees to find and understand. Avoid filling the document with unnecessary technical language.
Use clear headings, concise instructions, facility maps, emergency contact information, and clearly defined responsibilities. Keep copies available where employees can review them.
It can also be useful to provide employees with quick-reference information covering evacuation routes, assembly locations, alarm signals, reporting procedures, and emergency contacts.
A practical emergency action plan should help employees answer three questions quickly: What happened? What should I do? Where should I go?
Common Mistakes to Avoid
Several problems can reduce the effectiveness of an emergency action plan.
One common mistake is using a generic template without adapting it to the facility. Another is failing to update contact information after personnel changes.
Employers may also overlook contractors and visitors, fail to establish an accountability procedure, or provide employees with a plan without training them on its contents.
Another issue is treating the document as a one-time compliance exercise. OSHA emphasizes that an EAP is useful only when it is current and employees understand their responsibilities.
Regular reviews, employee input, and drills can help identify weaknesses before a real emergency occurs.
Building a Strong Emergency Action Plan
Developing an effective emergency action plan requires more than listing emergency phone numbers. Employers should evaluate workplace hazards, establish reporting and evacuation procedures, assign responsibilities, provide reliable alarm and communication systems, train employees, and periodically review the plan.
An emergency action plan protects workers and satisfies OSHA requirements. More importantly, it gives employees a clear framework for responding when seconds matter.
By tailoring the plan to the actual workplace and keeping employees involved in its development and implementation, organizations can create emergency procedures that are practical, understandable, and ready to use when needed.
FAQs
What is an emergency action plan?
An emergency action plan is a workplace document that organizes employer and employee actions during emergencies. It typically addresses emergency reporting, evacuation, accountability, critical operations, rescue or medical responsibilities, and designated contacts.
Does OSHA require every business to have a written emergency action plan?
Not every workplace is automatically required to have an EAP under 29 CFR 1910.38. The requirement applies when an OSHA standard requires one. However, OSHA recommends emergency planning for all employers because effective planning can help workers respond to emergencies.
What must an OSHA emergency action plan include?
The minimum requirements under 29 CFR 1910.38 include emergency reporting procedures, evacuation procedures and exit assignments, critical-operation procedures, employee accountability, rescue and medical duties, and designated contacts for information about the plan.
How often should an emergency action plan be reviewed?
The plan must be reviewed with covered employees when it is developed or when they are initially assigned to a job, when their responsibilities change, and whenever the plan changes. OSHA also recommends keeping plans current and conducting periodic reviews and drills.
Should an emergency action plan include evacuation maps?
Yes. Evacuation procedures should identify exit routes and assignments, and OSHA recommends using floor plans and workplace maps as part of emergency planning.
Who should be responsible for an emergency action plan?
Management should establish responsibility for developing, maintaining, and implementing the plan. Designated employees should also be trained to assist with safe and orderly evacuation, while specific employees may be assigned critical-operation, rescue, or medical duties where appropriate.
Can a small business communicate its emergency action plan orally?
Under 29 CFR 1910.38, employers with 10 or fewer employees may communicate the EAP orally rather than maintaining a written plan. Other applicable OSHA requirements may still need to be considered.
