WORKPLACE EMERGENCY ACTION PLANS (EAP)

Workplaces of all types need to have an emergency action plan in place to be OSHA compliant.

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The commonplace term “emergency action plan” is widely used by both the private and the public sector. Specialized emergency action plans used in the public sector may relate to dams, flooding scenarios, educational facilities, severe weather responses, special events, etc. However, the Occupational Health and Safety Administration (OSHA) has specialized requirements for the development of site-specific, workplace emergency action plans (EAP) for certain employers. OSHA requires a verbal or written emergency action plan 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 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))

According to OSHA, the purpose of a workplace EAP is to facilitate and organize employer and employee actions during emergencies. Preventative emergency measures are necessary to minimize emergencies, however plans should be place to ensure employees’ safety in case an emergency scenario occurs.

An EAP should be part of an overall emergency management program, elevate the state of response awareness, and create an atmosphere of response readiness. Before implementing an emergency action plan, employers must designate and train employees to assist in the safe and orderly emergency evacuation of employees. Employers should also clearly communicate command structure during an emergency to minimize confusion. In order to customize a workplace EAP, employers should include the following:

  • Responses to specific potential emergency scenarios
  • Communications processes
  • Training in emergency action plan specifics
  • Floor plans highlighting evacuation routes, emergency exits and fire fighting equipment
  • Potentially hazardous features and on-site emergency systems

Specialized industries may require additional planning elements per associated regulations. However, employers should ensure that the emergency action plans address the following OSHA requirements:

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. Additional training measures can include:

  • Individual roles and responsibilities
  • Threats, hazards, and protective actions
  • Notification, warning, and communications procedures
  • Emergency response procedures
  • Evacuation, shelter, and accountability procedures
  • Location and use of common emergency equipment
  • Emergency shutdown procedures

Reviews: An employer must review the workplace EAP 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

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