Emergency Action Plans (OSHA ) Abstract. Introduction. Emergency Action Plan (EAP) Elements of an EAP

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1 1 Fire Protection Report Number: FP Release Date: July 12, 2000 Section Title: Emergency Management Abstract OSHA requires employers of more than ten people to establish a written emergency action plan (EAP). This report discusses the components of an EAP. Guidelines for meeting the requirements of OSHA are provided. Introduction The U.S. Department of Labor s Occupational Safety & Health Administration (OSHA) requires employers of more than ten (10) people to establish a written emergency action plan (EAP) for fire and other emergencies. [2] This requirement applies to organizations classified by OSHA as general industry. General industry includes all industries and businesses, except construction, shipbuilding, agricultural, and mining. In addition to fires and explosions, emergencies can include natural hazards 1, accidental release of toxic gases, chemical spills, and workplace violence. Since the EAP should address all potential emergencies, a hazard audit should be done to identify and analyze hazardous circumstances related to an operation or facility. Occupational Safety Report OS-40-10, Hazard Evaluation Techniques, looks at techniques commonly used by safety professionals to identify and manage hazards 2. Fire hazards are addressed in Fire Protection Report FP-45-15, Fire Prevention Plans. Workplace violence issues are addressed in Crime Prevention Report CP-96-30, Workplace Violence: A Prevention Program. To be in compliance with OSHA requires, as a minimum, establishing an EAP. The next step in safeguarding employees and property is to establish an emergency response team (ERT). Guidelines for establishing an ERT are provided in Fire Protection Report FP-45-20, Emergency Response Teams (ERT). A comprehensive approach to emergency response planning is addressed by Natural Hazards Report NH-30-10, Emergency Response An Overview 3. NFPA 1600, Recommended Practice for Disaster Management, published by the National Fire Protection Association (NFPA) also addresses disaster management, emergency management, and business continuity programs. [1] Emergency Action Plan (EAP) An emergency action plan (EAP) is a written plan that details the actions employees are to take in the event of an emergency. An EAP for a business office will be different from one for an industrial facility. Loss control personnel and facility management should work together to establish an EAP to meet the individual requirements for each facility. Elements of an EAP The EAP should be developed locally and be comprehensive enough to deal with all types of emergencies specific to that site. As a minimum, the plan should include the following elements: Emergency escape procedures and escape routes The preferred means of reporting fires and other emergencies.

2 2 Procedures to be followed by employees who remain to operate or shut down critical plant operations before they evacuate. Procedures to account for all employees after emergency evacuation has been completed. Rescue and medical duties for those employees who are to perform them. Names or regular job titles of persons or departments that can be contacted for further information or explanations of duties under the plan. The essential elements of an EAP can be supplemented by additional planning to increase the potential for employee safety and health during an emergency. All employees should be aware of what actions they are to take during emergencies that might occur at the workplace. Floor plans or workplace maps that clearly show the emergency escape routes should be included in the EAP. Color coding can aid employees in determining their primary and alternate escape routes. Employees should know the location of and preferred procedures for using manual alarm stations, telephones, radios, and other communication devices. The preferred means of alerting employees to a fire emergency should be included in the plan. OSHA regulations require that an employee alarm system be used. [4] In some facilities, certain employees may be designated to be responsible for shutting down critical operations or processes in the event of an emergency. This may include monitoring plant power supplies, water supplies, and other essential services that cannot be shut down for every emergency alarm. Essential plant operations may also include chemical or manufacturing processes, which must be shut down in stages or steps by certain employees. Special consideration should be given to the egress requirements of those employees. Where needed, special procedures for helping disabled or physically impaired employees should be addressed in the plan. The plan should also describe in detail what rescue and medical first aid duties are to be performed and by whom. To ensure no employees are trapped, accountability procedures must be developed and documented. A mechanism, such as requiring employees to meet at a predetermined rally point for attendance, can be an effective procedure. It would be prudent for the EAP to address security issues during an emergency. Procedures should be established to prevent unauthorized access and to protect vital records and property. The EAP should establish a chain of command so that there is no confusion among employees as to who has authority for making decisions during an emergency. The written plan should be available to all employees for review. The person in charge of training employees as to the requirements of their EAP should be documented in the written plan. This is to permit employees with questions about their EAP to know where to go for the answers. The plan should be re-evaluated and updated periodically in order to maintain adequate response personnel and program efficiency. Documentation An organization that has more than ten (10) employees must have a written EAP. An organization with ten (10) or less employees may communicate the plan to employees orally. The written requirement for an EAP is based on the number of employees that are physically in a facility at any time rather than the number of personnel employed at the facility.

3 3 Alarm System OSHA [2] requires that the EAP include an employee alarm system. The employee alarm system must provide sufficient warning to allow adequate time for the employees to take appropriate action. Appropriate action includes evacuation, incipient fire fighting with portable extinguishers, or other tasks assigned to employees by management. [4] Employees should know the preferred method for reporting emergencies, such as manual pull box alarms, public address systems, radio, or telephone. Emergency numbers should be posted near the telephones, employee bulleting boards, and other conspicuous locations. Where a communication system, such as an intercom system, acts as the alarm system, all emergency messages should have priority over non-emergency messages. The alarm system should comply with Americans with Disabilities Act (ADA) requirements. These requirements are to ensure that disabled employees can report an emergency, can be alerted to the emergency situation, and can egress to safety. Non-supervised alarm systems should be tested every two months to ensure reliability. Supervised alarms should be tested annually. The actuation device used for testing should be varied to ensure no one device is used for two consecutive tests. When the alarm systems are out of service, a backup system of radios, telephones, or employee runners must be provided until alarm service is restored. The employer is responsible for ensuring that alarm system maintenance is performed by persons trained in servicing, maintaining, and testing alarm systems. Emergency Response Activities Response to an emergency alarm typically involves at least: Evacuation of the workplace Action by the Emergency Response Team (ERT). Evacuation The employer should establish the types of evacuation to be used in emergency situations. At the time of an emergency, employees should know what type of evacuation is necessary and what their role is in carrying out the plan. An adequate number of employees should be available at all times during working hours to act as evacuation wardens. A general rule of thumb is one evacuation warden is needed for every twenty employees. The evacuation warden should be able to provide adequate guidance and instruction at the time of the fire or emergency. Before leaving the building or area, the wardens should check rooms and other enclosed spaces for employees who may be trapped or unable to evacuate the area. Total and immediate evacuation may be needed in some cases. In other emergencies, a partial evacuation of nonessential employees, with a delayed evacuation of others, may be necessary for continued plant operation. In some cases, only those individuals in the immediate fire area may be expected to evacuate or move to a safe area. The EAP should identify any refuge or safe areas for evacuation. In a building divided into fire zones by fire walls, the refuge area may be still within the same building but in a different zone from the fire or other emergency. A partial evacuation is often used in high-rise buildings where it is impractical to evacuate the entire building. The general idea behind a partial evacuation is the floor that reports an alarm is designated as the "fire floor." Instead of evacuating all employees immediately out of the building, several floors above the fire floor are evacuated to higher levels, and several floors below the fire floor are evacuated to lower levels.

4 4 Exterior refuge or safe areas may include parking lots and open field or streets, which are located away from the site of the emergency and which provide sufficient space to accommodate the employees. Employees should be trained to move away from the exit discharge doors of a building and to avoid congregating close to the building. The refuge or safe area should be located so that employees do not hamper emergency operations. A system should be established for accounting for personnel once the evacuation is complete. A responsible person (and alternate) should be assigned to account for personnel and to notify fire, police, or the ERT of any individuals believed to be missing. Emergency Response Team (ERT) In some cases, the EAP may include an Emergency Response Team (ERT). Details concerning ERTs are covered in Fire Protection Report FP-45-20, Emergency Response Teams. Training Training is important to ensure the effectiveness of the EAP. The employer is supposed to review the EAP with each employee at the following times: Initially when the plan is developed. Whenever designated actions under the plan change. Whenever the plan is changed. Additional training may be needed when new equipment, materials, or processes are introduced. If there is evidence that employee performance during emergencies is inadequate, additional training is warranted. As a minimum, an employer should designate and train a sufficient number of people to act as wardens to assist in the safe and orderly emergency evacuation of employees. Wardens should be trained in the complete workplace layout and the various alternative escape routes from the workplace. Every employee should know details of the EAP, including evacuation plan, alarm systems, reporting procedures, shutdown procedures (if applicable), and types of potential emergencies. All employees should be made aware of disabled employees who may need extra assistance in evacuating. Employees should also be trained in avoiding hazardous areas during emergencies. Drills should be held at random intervals, at least annually. If possible, the drills should include outside police and fire authorities and other emergency response responders. OSHA Fire Safety Advisor Software OSHA s Fire Safety Advisor is interactive expert software. [8] It addresses OSHA s general industry standards for fire safety and emergency evacuation. It is designed to: Alert you to fire safety hazards, Point out applicable OSHA standards, Help conduct compliance reviews, and Help develop a customized EAP. The software is available at the OSHA web site at

5 5 References 1. National Fire Protection Association. Standard on Disaster/Emergency Management and Business Continuity Programs. NFPA Quincy, MA: NFPA, U.S. Department of Labor. Occupational Safety and Health Administration. Employee emergency plans and fire prevention plans. 29 CFR Washington, DC: Government Printing Office, July 1, [ Appendix Means of Egress. 29 CFR 1910 Subpart E Appendix. Washington, DC: GPO, July 1, [ Employee alarm systems. 29 CFR Washington, DC: GPO, July 1, [ OSHA Fact Sheet No : Responding to Workplace Emergencies. Washington, DC: GPO, January [ OSHA Fact Sheet No : Workplace Fire Safety. Washington, DC: GPO, January [ How to Prepare for Workplace Emergencies. OSHA Washington, DC: GPO, 1995 Revised. [ OSHA Software: OSHA Fire Safety Advisor 1.0. September [ Footnotes Footnote 1 Natural hazards include such events as blizzards, tornadoes, hurricanes, earthquakes, floods, and hail storms. Footnote 2 Additional reports in the Hazard Evaluation Section of the E&S Occupational Safety Report series provide an in-depth review of the specific techniques covered in OS-40-10, Hazard Evaluation Techniques. Footnote 3 Additional reports in the Natural Hazards Report series address specific elements of developing an comprehensive emergency response plan. In addition, a suggested format for such a plan is contained in NH-30-12, Emergency Response Example Plan. COPYRIGHT 2000, Insurance Services Office, Inc. The information contained in this publication was obtained from sources believed to be reliable. Insurance Services Office, Inc., its companies and employees make no guarantee of results and assume no liability in connection with either the information herein contained or the safety suggestions herein made. Moreover, it cannot be assumed that every acceptable safety procedure is contained herein or that abnormal or unusual circumstances may not warrant or require further or additional procedure.