Fires, toxic chemical releases, hurricanes, tornadoes, blizzards, and floods are some of the reasons you need a 29 CFR 1910.38 Emergency Action Plan. In fact on the OSHA Emergency Action Plan web page it states;
‘‘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 requires you to have an EAP. The plan must insure that employees know the procedures for reporting, evacuating or reacting to fires or other emergencies, including the methods for the accounting of all employees after evacuation. Employers must designate contact persons and employees must know who may be contacted if more information about the plan or an explanation of what their required duties are under the plan is needed.
The plan must detail procedures for employees who have been trained to remain behind to care for critical plant operations like the monitoring of plant power supplies, reactors or operations that must be shut down in stages or steps where employees must be present to assure that safe shut down procedures are completed. Employers must also ensure that all rescue and medical first aid duties be assigned and explained to employees before any anticipated emergencies.
In Appendix to Subpart E of 1910.38 OSHA recommends floor plans and workplace maps, with color codes, be developed and displayed which show emergency escape routes included in the emergency action plan to aid employees in determining their evacuation routes or shelter in place requirements.
Designation of interior refuge or safe areas for evacuation within the buildings must be determined and identified in the plan as well as any exterior refuge or safe areas like parking lots, open fields or streets used, which should be located away from the site of the emergency and provide sufficient space to accommodate employees.
The emergency action plan must be covered or reviewed when the plan is first developed, when the employee is assigned initially to a job, the employee's responsibilities under the plan change; or the plan is changed.
And finally the plan requires an alarm system that uses distinctive alarm signals for each type of emergency and complies with the alarm system requirements in §1910.165 and follow fire prevention housekeeping requirements for flammable and combustible materials.
It should also be noted if you have less than 10 employees it does not have to be in writing, employees however must still be instructed of their responsibilities and evacuation routes.
You will find below a list of resources for developing an emergency action plan. If you have any questions or concerns about your emergency action plan requirements call or drop us an email.
Below you will find the link to OSHA 1910.38 Emergency Action Plans:
https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.38
Below you will find a link to information from OSHA on Emergency Action Plans:
https://www.osha.gov/SLTC/etools/evacuation/need.html
Below you will find a link to an example of an Emergency Action Plan:
https://hsewatch.com/wp-content/uploads/2019/01/Emergency-Action-Plan-TEMPLATE_revised_8_31_16.pdf
Thank you for your readership and support.
Robert J Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Program Inc.