Do You Need A Written Emergency Action Plan?

OSHA requires you to have an Emergency Action Plan (EAP) that complies with the requirements of 29 CFR 1910.38 if portable fire extinguishers are required or provided for designated or authorized employees to use to fight fires, and if anyone will be evacuated during a fire or other emergency.

If you have 11 or more employees at any given facility, your plan must be in writing. If you have 30 employees spread out over five facilities, and each facility has 10 or less employees, you may orally communicate your plan at each facility. If one of those facilities has more than 10 employees, but the other four do not, you are required to have a written plan for that one facility.

Your plan should address those emergencies that your employees are potentially exposed to. Emergencies that you should consider to include in your plan are: fires, inert gas leaks, toxic gas releases, chemical spills, hurricanes, floods, tornadoes, explosions, civil disturbances, workplace violence, terrorism, etc. All too often, people are forced to evacuate their workplace without warning and when least expected. Few people can think clearly and logically in a crisis, and that is why it is so important to prepare for an emergency before it happens. The best way to protect yourself, those you work with or your business is to expect the unexpected and develop an EAP to guide you when immediate action is necessary.

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.

At a minimum, the plan must include, but is not limited to, the following elements:

Means of Reporting Fires & Other Emergencies — Preferred procedures for reporting emergencies such as dialing 911, or an internal emergency number, or pulling a manual fire alarm are examples of emergency reporting procedures, but there are other possibilities.

Evacuation Procedures and Emergency Escape Route Assignments — An evacuation policy, procedures and escape route assignments so employees understand who is authorized to order an evacuation, under what conditions an evacuation would be necessary, how to evacuate and what routes to take. Exit diagrams are typically used to identify the escape routes to be followed by employees from each specific facility location. Often, evacuation procedures also describe actions employees should take before and while evacuating, such as shutting windows, turning off equipment and closing doors behind them. Sometimes a critical decision may need to be made when planning, i.e., whether or not employees should fight a small fire with a portable fire extinguisher or simply evacuate. Portable fire extinguishers may be integrated into the emergency action plan.

Procedures to be Followed by Employees Who Remain to Operate Critical Plant Operations Before They Evacuate — Employees may be required to operate fire extinguishers or shut down gas and/or electrical systems and other special equipment that could be damaged if left operating or create additional hazards to emergency responders (such as releasing hazardous materials).

A Procedure to Account for all Employees After an Emergency Evacuation Has Been Completed — Procedures to account for employees after the evacuation to ensure that everyone got out. This might include procedures for designated employees to sweep areas, checking offices and rest-rooms before being the last to leave a workplace, or conducting a roll call in the assembly area. Many employers designate an “evacuation warden” to assist others in an evacuation and to account for personnel

Rescue and Medical Duties for Those Employees Who Are to Perform Them — The duties, responsibilities and names of employees assigned with rescue and medical tasks. Most small organizations rely on local public resources such as the local fire department or hospital to provide these services.

Names or Job Titles of Persons Who Can Be Contacted for Further Information or Explanation of Duties Under the Plan — The names, titles, departments and phone numbers of employees who can be contacted for additional information or clarification of some aspect of the plan.

A sample plan that can be made site-specific is offered in your GAWDA OSHA Manual, behind tab 34.

Gases and Welding Distributors Association
Meet the Author
GAWDA OSHA & EPA Consultant Thomas W. Eynon is senior associate at B&R Compliance Associates LLC, based in Merritt, North Carolina. Members can reach him at (252) 745-7391 and at tom.eynon@brcompliance.com.