What's Your Plan? Emergency Action Plan or Emergency Response Plan?

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Whether your company manufactures consumer products or provides hotel accommodations for thousands of guests across the globe, response planning is a crucial preparedness element that must be implemented in order to minimize the impact of emergencies. For most sites, the foundational response planning tool mandated by government agencies is either the Emergency Action Plan (EAP) or the Emergency Response Plan (ERP). However, while the two plan types sound similar, they have key differences and applicability.

Emergency Action Plan

An EAP can be utilized by a “non-responding” facility where only defensive responses are in play. Generally, these responses equate to evacuation and communication with responders. The EPA has adopted a policy for non-responding facilities similar to that adopted by OSHA in its Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard (29 CFR 1910.120), which allows certain facilities to develop an emergency action plan to ensure employee safety, rather than a full-fledged emergency response plan.

The OSHA 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 emergency action plan must communicate the following minimum requirements:

  • Procedures for emergency evacuation, including type of evacuation and exit route assignments (29 CFR 1910.38(c)(2))
  • Procedures to be followed by employees who remain to operate critical operations before they evacuate (29 CFR 1910.38(c)(3))
  • 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 (29 CFR 1910.38(c)(5))
  • Means of reporting fires or other emergencies (29 CFR 1910.38(c)(1))
    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.(29 CFR 1910.38(c)(6))

A facility that is not bound by ERP regulations may utilize the EAP if they are located in an area with access to municipal responders and emergency response resources that can facilitate an effective response.

Emergency Response Plan

Depending on industry, operations, and site hazards, sites may be required to submit specialized response plans to one or a variety of federal regulatory agencies. When an ERP is in place, the facility has established first responding capabilities with the intent to initiate offensive actions. (Note: The purpose of the first responder at the operations level, is to protect life, property, or the environment from the effects of the release, not stop the release.)

OSHA regulations (29 CRF 1910.120(q)) state that “an emergency response plan shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations. The plan shall be in writing and available for inspection and copying by employees, their representatives and OSHA personnel.” According to the Employers who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, are exempt from the requirements of this paragraph if they provide an emergency action plan in accordance with 29 CFR 1910.38.

Emergency response plans need to serve a specific response purpose and meet explicit planning objectives. Every response plan should include site-specific details that are unique to your facility. Below is a list of some basic planning objectives that may be relevant to your facility:

  1. Establish site specific emergency response procedures for each potential threat, risk or emergency scenario These may include, but are not limited to:
    a. Medical emergencies
    b. Hazardous releases
    c. Fire
    d. Severe weather
    e. Security issues
  2. Design an emergency response team framework and assign personnel to fill primary and alternate roles
  3. Define notification and emergency response team activation procedures
  4. Establish communication procedures and a primary and alternate Emergency Operations Center location
  5. Identify and quantify necessary response equipment
  6. Ensure emergency response team personnel receive applicable and required training
  7. Establish mitigation procedures and protective actions to safeguard the health and safety of on-site personnel and nearby communities
  8. Identify and ensure availability of responders and supply chain resources
  9. Maintain compliance with all applicable local, state, and federal requirements for environmental hazards, response plans, and training requirements
  10. Integrate best practices and lessons learned from past training and exercises, actual emergencies, and incident reviews

In order to be fully integrated with external resources, the Emergency Response Plan structure should be consistent with the National Incident Management System and integrated with Incident Command System concepts.


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