Emergency Action Plan Design and Implementation
Written by: Joe Mangiardi, NES, Inc.
Emergency action plans contribute to employee safety in the case of an emergency.
Introduction to the Emergency Action Plan
Designing and implementing an emergency action plan is required of virtually all businesses and agencies by the Occupational Safety and Health Administration (OSHA). Regardless of that mandate, having a solid emergency action plan in place is simply good common sense.
As the recent hurricanes and flooding in Texas, Louisiana, Florida, and beyond have demonstrated, natural disasters can inflict devastating and long-lasting damages to communities. Businesses affected by such occurrences may find it difficult to fully recover; some may never recover at all. In many cases there is nothing to be done to completely prevent injuries and losses of life and property, but often the negative impacts of an undesired event can be mitigated by ensuring that employers communicate to their employees a comprehensive and site-specific plan for action addressing a range of possible emergency scenarios.
What is an Emergency Action Plan?
An emergency action plan establishes specific actions to be taken by employers and their employees to keep everyone in the workplace safe in the event of a fire or other emergency. Not all employers are required to have an emergency action plan, but there are extremely few exceptions (click here to view an OSHA information page designed to help businesses quickly determine whether they are required to have an emergency action plan). Businesses or agencies not explicitly required to maintain an emergency action plan still should develop one, because they will always be susceptible to serious emergency events not directly considered by OSHA.
For those businesses and agencies that do require an emergency action plan (the vast majority), California Code of Regulations (CCR) Title 8 §3220 states the following: “The employer shall review with each employee upon initial assignment those parts of the plan which the employee must know to protect the employee in the event of an emergency. The written plan shall be kept at the workplace and made available for employee review. For those employers with 10 or fewer employees the plan may be communicated orally to employees and the employer need not maintain a written plan.”
An emergency action plan is intended to inform employees of what to do in the case of a workplace emergency. The OSHA publication How to Plan for Workplace Emergencies and Evacuations defines a workplace emergency as “an unforeseen situation that threatens your employees, customers, or the public; disrupts or shuts down your operations; or causes physical or environmental damage.” A workplace emergency can be natural or human-caused. Examples include hurricanes, tornadoes, floods, fires, toxic gas releases, contaminant spills, explosions, civil disturbances, or acts of terrorism.
Workplace emergencies can occur in many forms, some of which are not included in the above graphic. Try to plan for all possibilities!
OSHA emphasizes the importance of employers thinking through all scenarios that could possibly occur at their facility. Every potential manner of event should be considered and planned for regardless of severity or likelihood; every emergency action plan should include the same basic set of emergency category responses, and contingencies unique to your site/facility should also be considered. The best response to an emergency is the combination of forethought and preparedness.
What Does an Emergency Action Plan Cover?
An emergency action plan should contain any and all elements that can be anticipated to promote the safety of employees and the enduring wellbeing of the business or agency. As mentioned above, workplace emergencies can also affect visitors and the public, and so the safety of non-employees potentially involved in an emergency should be considered as well. At a minimum, an emergency action plan must include:
- Protocols for reporting workplace emergencies
- Evacuation policies and procedures including emergency escape route assignments, floor plans, facility maps, and refuge areas as applicable
- Names, titles, and contact information for individuals designated to provide further instruction in the case of an emergency
- Procedures for critical operations shutdown, fire extinguisher operation, and any other actions that must be performed by designated employees prior to evacuation
- Rescue and/or medical duties for those employees designated to provide them
Establish evacuation routes to cover all contingencies.
Ensure that information is available to employees in a language they can understand. Plans must also determine a reliable means of alerting employees to take appropriate action, which will vary based on the given variety of emergency. Evacuation will likely be in order in the case of a fire or radiological accident, but in cases such as a hurricane or tornado it may be safer for employees to congregate in a basement. Alarms/alerts must be distinctive, perceivable, and recognizable by all employees. An emergency communications system such as a public address (PA) system should be in place to communicate with employees, and employers should implement an accessible and dependable means of summoning emergency services. A backup power source is recommended in the event of a power loss.
In addition, safety measures for disabled individuals must be established. A UC Davis Safety Services publication entitled Emergency Evacuation of Disabled Persons points out that the Americans with Disabilities Act (ADA) guarantees equal opportunities for workers with disabilities. Just as employers are required to reasonably accommodate the needs of those with temporary and permanent disabilities during work activities, employers should ensure their emergency action plan attends to any employees’ special needs. Ascertaining disabilities in employees is not always as straightforward as observing those who use a wheelchair or whose disability is accompanied by some other visible indicator. Conditions such as heart disease and asthma are often not as obvious—when in doubt, a simple memo, survey, questionnaire, or the like can garner the most specific and reliable information about employees’ special needs.
Check the emergency action plan off your list and experience greater peace of mind.
Making Proper Emergency Action Plan Designations
Once potential workplace emergencies have been identified, a complete emergency action plan should include certain designations. One of the most important of these is the designation of which employee or employees will be responsible for making decisions about if and when to evacuate, supervising and assisting in an evacuation, executing necessary shutdown procedures, and requesting emergency assistance. These coordinators should be trained in all pertinent areas for which they will be responsible in an emergency and properly equipped to perform their assigned duties.
Designating an evacuation assembly area (or multiple emergency-specific locations) is important. It allows employees to know in advance where to go in an emergency and facilitates the ability of emergency coordinators to take a headcount of employees and any visitors or customers who may also need to be accounted for.
Familiarizing employees with established evacuation procedures can lower panic levels and contribute to an orderly response in the case of an emergency.
Emergency Action Plan Training
Properly training employees is a key element to implementing and maintaining a successful emergency action plan. Educate employees on the particular functions and protocols of the plan and the unique types of emergencies that may be encountered. Consider the specific features at your facility in the training such as size of the business or agency, processes used, proximity to external resources, and any special hazards onsite including flammable or toxic materials, radioactive sources, and water-reactive substances. Depending on these site-specific features, personal protective equipment (PPE) may be necessary ranging from safety glasses/goggles, hard hats, and steel-toe boots to respirators and chemical-resistant gloves, suits, and hoods.
Expanding the scope of training beyond the emergency action plan can increase employee safety. First Aid, CPR, and AED training will prepare employees to administer immediate basic medical assistance. More specialized training is a best management practice for facilities whose employees may be exposed to certain hazards. Examples include respiratory protection and bloodborne pathogen training. The more thoroughly employees are trained, the better prepared they will be to act quickly and safely in an emergency.
Beyond the Emergency Action Plan
An emergency action plan is a bare minimum requirement, and for many facilities other plan types must be maintained to keep employees safe, the environment protected, and affected businesses in compliance with applicable regulations. If there is the potential for a hazardous substance release at a facility, then the employer must prepare an Emergency Response Plan (ERP) as required in CCR Title 8 §5192. Large quantity generators (LQGs) of hazardous waste must develop and implement a Contingency Plan, the purpose of which being “to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water,” as stated in CCR Title 22 §66265.51. Other plans that may be required depending on facility particulars are Hazardous Materials Business Plans (HMBPs) and Spill Prevention, Control, and Countermeasure (SPCC) Plans.
Maintaining the proper emergency plans keeps employees safe and the environment protected and leads to businesses being better able to recover from workplace emergencies.
Environmental Consulting with NES
NES has been providing environmental consulting services on behalf of a wide array of public and private businesses and government agencies for the past 30 years. If you need help with or have questions regarding the development of occupational and/or environmental health & safety plans at your facility, please contact NES at firstname.lastname@example.org or 916-353-2360 / 1-800-NES-ADVISE.
OSHA Information Page: Am I Required to Have an Emergency Action Plan (EAP)?
OSHA Publication: How to Plan for Workplace Emergencies and Evacuations
OSHA Fillable Form Guide: Create Your Own Emergency Action Plan (EAP)
UC Davis Safety Services Publication: Emergency Evacuation of Disabled Persons