When is an Emergency Action Plan Required?

Knowing when an emergency action plan is required by government authorities can save on time and money later on.

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There is often confusion when it comes to Occupational Health and Safety Administration’s (OSHA) Emergency Action Plans (EAP), 29 CFR 1910.38 for the workplace. The requirement to develop a written emergency action plan or fire prevention plan is based on the number of employees that are physically in a facility at any time of the working day. The regulation 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))

Additionally, the emergency action plan must address the following:

Employee alarm system: An employer must have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in 29 CFR 1910.165.

Training: An employer must designate and train employees to assist in a safe and orderly evacuation of other employees.

Review of emergency action plan: An employer must review the emergency action plan with each employee covered by the plan:

  • When the plan is developed or the employee is assigned initially to a job
  • When the employee's responsibilities under the plan change
  • When the plan is changed

According to OSHA, the purpose of an emergency action plan (EAP) is to facilitate and organize employer and employee actions during workplace emergencies. A well-developed EAP is essential for the safety of employees.

In order to customize your plan, employers should:

  • Identify potential emergency scenarios
  • Communicate how employees should respond to each identified emergency
  • Customize plan by developing floor plans (or worksite layout), and identifying potentially hazardous features and on-site emergency systems
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