An emergency action plan must be established in writing for any facility with blank employees

May 03, 2018 May 03, 2018/ Universal Compliance/ Universal Compliance

An emergency action plan (EAP) is a written document required by particular OSHA standards [29 CFR 1910.38(a)].  An emergency action plan must be in writing, kept in the workplace, and available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees. The purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. Well developed emergency plans and proper employee training (such that employees understand their roles and responsibilities within the plan) will result in fewer and less severe employee injuries and less structural damage to the facility during emergencies. A poorly prepared plan, likely will lead to a disorganized evacuation or emergency response, resulting in confusion, injury, and property damage.

Putting together a comprehensive emergency action plan that deals with those issues specific to your worksite is not difficult. It involves taking what was learned from your workplace evaluation and describing how employees will respond to different types of emergencies, taking into account your specific worksite layout, structural features, and emergency systems. Most organizations find it beneficial to include a diverse group of representatives (management and employees) in this planning process and to meet frequently to review progress and allocate development tasks.

This issue contains information about the following topics: Requirements, elements of emergency action plans, alarm systems, emergency procedures and much more

• Procedures for reporting a fire or other emergency.
• Procedures for emergency evacuation, including type of evacuation and exit route assignments.
• Procedures to be followed by employees who remain to operate critical plant operations before they evacuate.
• Procedures to account for all employees after evacuation.
• Procedures to be followed by employees performing rescue or medical duties.
• 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.

• A description of the alarm system to be used to notify employees (including disabled employees) to evacuate and/or take other actions. The alarms used for different actions should be distinctive and might include horn blasts, sirens, or even public address systems.
• The site of an alternative communications center to be used in the event of a fire or explosion.
• A secure on- or offsite location to store originals or duplicate copies of accounting records, legal documents, your employees' emergency contact lists, and other essential records. 

An employer must designate and train employees to assist in a safe and orderly evacuation of other employees. Educate your employees about the types of emergencies that may occur and train them in the proper course of action. The size of your workplace and workforce, processes used, materials handled, and the availability of onsite or outside resources will determine your training requirements. Be sure all employees understand the function and elements of your emergency action plan, including types of potential emergencies, reporting procedures, alarm systems, evacuation plans, and shutdown procedures. Discuss any special hazards you may have onsite such as flammable materials, toxic chemicals, radioactive sources, or water-reactive substances. An employer must inform employees of the fire hazards to which they are exposed and review with each employee those parts of the fire prevention plan necessary for self-protection.

General training for your employees should also address the following:

• Individual roles and responsibilities.
• Threats, hazards, and protective actions.
• Notification, warning, and communications procedures.
• Means for locating family members in an emergency.
• Emergency response procedures.
• Evacuation, shelter, and accountability procedures.
• Location and use of common emergency equipment.
• Emergency shutdown procedures.

An employer must review the emergency action plan with each employee covered by the plan in the following situations:

• 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.

It is a good idea to hold practice evacuation drills. Evacuation drills permit employees to become familiar with the emergency procedures, their egress routes, and assembly locations, so that if an actual emergency should occur, they will respond properly. Drills should be conducted as often as necessary to keep employees prepared. Include outside resources, such as fire and police departments, when possible. After each drill, gather management and employees to evaluate the effectiveness of the drill. Identify the strengths and weaknesses of your plan and work to improve it.

Operations and personnel change frequently, and an outdated plan will be of little use in an emergency. You should review the contents of your plan regularly and update it whenever an employee's emergency actions or responsibilities change, or when there is a change in the layout or design of the facility, new equipment, hazardous materials, or processes are introduced that affect evacuation routes, or new types of hazards are introduced that require special actions. The most common outdated item in plans is the facility and agency contact information. Consider placing this important information on a separate page in the front of the plan so that it can be readily updated.

Employee Alarm Systems 1910.38(d) and 1910.165

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 § 1910.165

The employee alarm system shall provide warning for necessary emergency action as called for in the emergency action plan, or for reaction time for safe escape of employees from the workplace or the immediate work area, or both. The employee alarm shall be capable of being perceived above ambient noise or light levels by all employees in the affected portions of the workplace. Tactile devices may be used to alert those employees who would not otherwise be able to recognize the audible or visual alarm. The employee alarm shall be distinctive and recognizable as a signal to evacuate the work area or to perform actions designated under the emergency action plan.

The employer shall assure that all employee alarm systems are maintained in operating condition except when undergoing repairs or maintenance. The employer shall assure that a test of the reliability and adequacy of non-supervised employee alarm systems is made every two months. A different actuation device shall be used in each test of a multi-actuation device system so that no individual device is used for two consecutive tests The employer shall maintain or replace power supplies as often as is necessary to assure a fully operational condition. Back-up means of alarm, such as employee runners or telephones, shall be provided when systems are out of service.  The employer shall assure that manually operated actuation devices for use in conjunction with employee alarms are unobstructed, conspicuous and readily accessible.

Authority (OSHA eTool)

It is common practice to select a responsible individual to lead and coordinate your emergency plan and evacuation. It is critical that employees know who the coordinator is and understand that this person has the authority to make decisions during emergencies. The coordinator should be responsible for assessing the situation to determine whether an emergency exists requiring activation of the emergency procedures, overseeing emergency procedures, notifying and coordinating with outside emergency services, and directing shutdown of utilities or plant operations if necessary.

Certain equipment and processes must be shut down in stages or over time. In other instances it is not possible or practical for equipment or certain process to be shut down under certain emergency situations. This condition, which is not unusual for certain large manufacturers operating complex processes, is not typical of small enterprises that normally can turn off equipment or utilities if necessary and evacuate. However some small enterprises may require designated employees remain behind briefly to operate fire extinguishers or shut down gas and/or electrical systems and other special equipment that could be damaged if left operating or create additional hazards to emergency responders (such as releasing hazardous materials).

Each employer must review their operation and determine whether total and immediate evacuation is possible for various types of emergencies. The preferred approach, and the one most often taken by small enterprises, is immediate evacuation of all their employees when the evacuation alarm is sounded. If any employees will stay behind, the plan must describe in detail the procedures to be followed by these employees. All employees remaining behind must be capable of recognizing when to abandon the task and evacuate themselves before the egress path is blocked. In small establishments it is common to include in your plan locations where utilities (such as electrical and gas) can be shut down for all or part of the facility either by your own employees or by emergency response personnel. 

To ensure the fastest, most accurate accountability of your employees, you may want to consider including these steps in your EAP:

• Designate assembly areas or areas, both inside and outside your workplace, where employees should gather after evacuating. Assembly locations within the building are often referred to as "areas of refuge." Make sure your assembly area has sufficient space to accommodate all of your employees. Exterior assembly areas, used when the building must be partially or completely evacuated, are typically located in parking lots or other open areas away from busy streets.
• Take a head count after the evacuation. Identify the names and last known locations of anyone not accounted for and pass them to the official in charge. Accounting for all employees following an evacuation is critical.
• Establish a method for accounting for non-employees such as suppliers and customers.
• Establish procedures for further evacuation in case the incident expands. This may consist of sending employees home by normal means or providing them with transportation to an offsite location.

A wide variety of emergencies both man-made and natural, may require a workplace to be evacuated. These emergencies include:

• Fires
• Explosions
• Floods
• Earthquakes 
• Tornadoes
• Toxic material spills
• Radiological and biological accidents
• Riots
• Workplace Violence

Employers will want their employees to respond differently to these different threats. For example, employers may want to have employees assemble in one area inside the workplace if threatened by a tornado or perhaps a chemical spill on an adjacent highway, but evacuate to an exterior location during a fire. Your plan must identify when and how employees are to respond to different types of emergencies. Ask yourself questions and brainstorm worst-case scenarios.

The type of building you work in may be a factor in your decision. Most buildings are vulnerable to the effects of disasters such as tornadoes, earthquakes, floods, or explosions. The extent of the damage depends on the type of emergency and the building's construction. Modern factories and office buildings, for example, are framed in steel and are structurally more sound than neighborhood business premises may be. In a disaster such as a major earthquake or explosion, however, nearly every type of structure will be affected. Some buildings will collapse and others will be left with weakened floors and walls.

Routes and Exits (eTool)

Most employers create maps from floor diagrams with arrows that designate the exit route assignments. These maps should include locations of exits, assembly points, and equipment (such as fire extinguishers, first aid kits, spill kits) that may be needed in an emergency. Exit routes should be:

• Clearly marked and well lit.
• Wide enough to accommodate the number of evacuating personnel.
• Unobstructed and clear of debris at all times.
• Unlikely to expose evacuating personnel to additional hazards.
• When preparing drawings that show evacuation routes and exits, post them prominently for all employees to see

Unless you are a large employer handling hazardous materials and processes or have employees regularly working in hazardous situations, you will probably choose to rely on local public resources to provide these specialized services. If you choose to use external departments or agencies, such as the local fire and police departments, medical clinics or hospitals, and ambulance services, make sure they are prepared to respond as outlined in your plan. 

For example: 1. Have members of the local fire department conduct a walk-through of your workplace so they are familiar with the layout and any potential hazards. 2. Establish a relationship with a local ambulance service so transportation is readily available for emergencies. 3. Make arrangements with near by medical clinics or other facilities to handle emergency cases and to provide medical and first-aid services to employees. 

4. If an infirmary, clinic, or hospital is not close to your workplace, ensure that onsite person(s) have adequate first-aid training. The American Red Cross, some insurance providers, local safety councils, fire departments, or other sources may be able to provide this training. Treatment of a serious injury should begin within three to four minutes of the accident. Consult with a physician or other professional to order appropriate first-aid supplies for emergencies.