OSHA's Emergency Action Plan: Commercial Property + Building Owners

OSHA's financial penalties have gone up - building owners need to ensure they're compliant by developing an OSHA EAP plan.

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As of August 2, 2016, fines and penalties for Occupational Health and Safety Administration (OSHA) violations have increased. Commercial property and building owners must comply with relevant OSHA regulations in order to avoid the increasing non-compliance expenses. Many owners see the cost to initiate, upgrade, and/or maintain a preparedness program as a superfluous expenditure. However, proactive budgeting in comparison to the cost of lives, hazardous impacts, property damage, and regulatory fines, is minimal.

According to the 2016 OSHA Field Operations Manual, any employer who willfully or repeatedly violates regulations may be assessed a civil penalty of not more than $124,709 for each violation, but not less than $8,908 for each willful violation. For a company with multiple sites, the exponential violation cost could be staggering and financially crippling.

In order to minimize non-compliance, commercial property and building owners should identify potential emergency scenarios and necessary site-specific safety measures, including those required in OSHA’s Emergency Action Plan (EAP). An EAP should be part of an overall emergency management program, elevate the state of response awareness, and create an atmosphere of response readiness. Each plan should identify site-specific actions by employers, employees, or other building occupants to ensure safety from fire emergencies and other potentially devastating scenarios.

In order to minimize life threatening impacts, OSHA has identified requirements for the development of site-specific EAPs for certain employers and their work sites. OSHA requires a verbal or written EAP based on the number of employees that are physically present in a facility at any time of the working day.

The regulation (29 CFR 1910.38), states that employers with 10 or fewer employees do not have to create a written emergency action plan. However, employers are still required by OSHA to communicate an EAP to staff. An EAP must communicate the following minimum requirements:

  • Means of reporting fires or other emergencies
  • Evacuation procedures, including exit route assignment
  • Procedures to be followed by employees who remain to operate critical operations before they evacuate
  • Procedures to account for all employees after evacuation (29 CFR 1910.38(c)(4))
  • Procedures to be followed by employees performing rescue or medical duties
  • 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

Building owners should not limit response planning to fire emergencies, but consider an all-hazard approach when developing EAPs. Any scenarios that could impact the safety of building occupants should be planned and documented in advance. These scenarios may include, but are not limited to:

Human-caused threats

  • Bombs and bomb threats
  • Weapons of mass destruction
    • Chemical
    • Biological
    • Radiological/nuclear
  • Workplace violence

Building and infrastructure incidents

  • Building system failures
  • Elevators
  • Emergency power systems
  • Flooded areas
  • Medical emergency
  • Utility disruptions
  • Adjacent building fire

Location-specific natural disasters

  • Earthquakes
  • Hurricanes
  • Tornadoes
  • Tsunamis

Building owners, tenants, and response personnel should coordinate and ensure efficient evacuation procedures are in place for all occupants, including those with disabilities. The EAP should account for:

  • Mobility impairments
  • Wheelchair users
  • Ambulatory mobility disabilities
  • Respiratory impairments
  • Visual impairments
  • Hearing impairments
  • Speech impairments
  • Cognitive impairments

Depending on the characteristics of the building and inherent functions of the occupants, building owners’ preparedness programs may consist of the required Emergency Action Plans, as well as additional plan types such as a Fire Pre Plans, and/or Hazardous Waste Operations plans. Any building response plan should be shared with local responders and include the following site-specific information:

  • Building description
  • Owner/Manager contact information
  • Emergency Assembly Point details
  • Internal and/or external emergency personnel information and contact details
  • Specific hazard details and associated safety data sheets
  • Utility shut-off locations and descriptions
  • Alarm(s) description
  • Emergency equipment inventory and locations
  • Plot plan(s) and floor plan(s)
  • Risk, site and task identified situational checklists and job specific procedures
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