Emergency Action Plans: Are you prepared?
Most companies are required to have an emergency action plan. US Code of Federal Regulations (29CFR 1910.38) lists the requirements of having a written or oral emergency action plan. In general, all facilities are required to have a plan. If a facility has 10 or fewer employees, it is acceptable to have an oral plan, however it is recommended to document your plan for consistency, ease of training or if the facility goes over the 10 employee threshold during the year.
At a minimum, the plan must include:
- Procedures for reporting a fire or other emergency
- Procedures to be followed to shut down critical equipment (if applicable)
- Procedures to account for all employees after an evacuation
- Procedures for employees performing rescue or medical duties
- The name or job title of every employee who may be contacted if employees need more information or an explanation of the plan.
OSHA also includes requirements for an employee alarm system, training for the plan, and review of the plan. 1910 Subpart E provides related information such as means of egress requirements, exit routes, and fire prevention plans.
In my experience, the majority of companies have gone through these steps and have developed a plan. However, just having a plan isn’t the end of the process. It is important that these plans are reviewed on a regular basis and after any drill or actual emergency. These reviews should be documented and corrective actions implemented as soon as possible. When the plan changes, additional training is required to notify employees of those changes.
Adequate training is critical. Newly hired employees should be educated on the entire plan, their role in the plan, warning and alert systems, facility layout, and evacuation meeting locations. Refresher training to all employees should also be conducted when an employee’s role has changed. It is recommended that refresher training take place at least annually.
It’s easy to get lured into the mindset of planned drills. “We have time to train employees before the next drill” or “We don’t need to review the plan now, we have a drill scheduled next month”. It would be nice to have planned actual emergencies, but that’s not the real world. We never know when that alarm will go off and we will have to use the plan for a real emergency. So start preparing now, review your plan, train, hold an exercise, and repeat this process often.
The Blue Ridge Safety Association can assist members with reviewing their emergency plans and can provide feedback and comments on the plan. We can also answer questions regarding plans or other occupational safety topics. Please reach out to us if we can be of any assistance.