Preparing the Workplace with Emergency Action Plans (EAP)

Workplace emergencies can occur unexpectedly, making an OSHA-compliant emergency action plan (EAP) an essential resource. While designing an effective EAP can be challenging due to the numerous potential hazards and scenarios to consider, a tailored emergency action plan will improve your preparedness for unforeseen events.

To help you develop a compliant EAP and prepare your workplace for potential crises, this article offers everything you need to know, including core concepts, OSHA 1910.38 requirements, and a step-by-step EAP creation guide.

What’s an Emergency Action Plan (EAP)?

An Emergency Action Plan is a formal, written document that highlights procedures to take during an emergency, i.e., fires, explosions, natural disasters, etc. It serves as a “compass” during a crisis, guiding employees to safety through evacuation strategies, alarm systems, and proper training.

Essential for some high-risk workplaces, an emergency action plan is often combined with an Emergency Response Plan to design a comprehensive safety strategy. Distinct from each other in purpose, they differ from each other in their primary objective and intended meaning, which we will explore below.

Difference between Emergency Action Plan (EAP) and Emergency Response Plan (ERP)

Emergency action plans can be mistaken for Emergency Response Plans when, in fact, the difference between an EAP and an ERP lies in the fight or flight response predetermined by the written procedure.

EAP

EAPs are meant to be defensive in nature; they aim to grant emergency responders full control of handling the emergency rather than anyone within the company. This does not mean the employees aren’t capable of taking care of themselves; it’s a matter of the emergency responders having more expertise and the correct type of PPE/equipment to take care of the emergency.

With that being said, emergency action plans focus on orderly evacuation using predetermined procedures while also taking charge of gathering critical information for emergency responders to use for, metaphorically, “putting out the fire” – unless that is the nature of the emergency already, of course. Implementing such plans can help establish fire safety in the workplace.

ERP

Emergency response plan takes a “fight” stance. This type of response aims to take offensive action against the hazard to protect people and lessen significant property damage. An ERP often requires much more planning, specific training, and PPE for maximum protection than simply being able to evacuate like its counterpart, the EAP.

An emergency response plan can often be seen being used at companies that don’t have local emergency responders within proximity to the business location. ERPs still require the company to call responders to the scene; it just takes more time for them to get there, hence the company’s need to respond to the emergency itself.

Purpose of Emergency Action Plan (EAP)

The primary objective of an emergency action plan is to provide a strategic framework for how to safely and quickly evacuate/evade a crisis. It identifies standard procedures that focus on reporting emergencies, immediate evacuation, alarm systems, and employee training. Having an emergency action plan eliminates the need for making last-minute decisions during an emergency, as stress often compromises brain function, which can ultimately lead to poor decisions and panic-induced reactions.

To prevent the aforementioned instances from occurring, OSHA 1910.38 highlights specific requirements that serve as a minimum baseline for emergency action plans.

OSHA 1910.38 Emergency Action Plan Requirements

Specified by OSHA 1910.38, each emergency action plan should include the following prerequisites:

• The emergency action plan should be present in written format for workplaces that have 11 or more employees; for 10 or fewer, it can be orally communicated.
• Standard procedures for reporting emergencies, e.g., employees are required to dial 911 during a fire outbreak.
• Evacuation procedures based on the type of evacuation needed and emergency escape route assignments.
• Procedures for those who must shut down critical plant operations before departing.
• Accounting for all employees after an emergency evacuation has been completed, e.g., a proper headcount of all the employees who logged in that day.
• Rescue and medical duties for employees performing them.
• Names and job titles of persons who can be contacted for more information about the emergency action plan.
• A functional alarm system that provides distinctive signals for each type of emergency.
• Adequate training based on the contents of the emergency action plan.
• Routine revision of the EAP with employees under multiple circumstances, including but not limited to: when the employee is first assigned the job or responsibilities change.

Practical Implementation Of OSHA 1910.38 Requirements

While OSHA’s 1910.38 standard offers a blueprint of what to include in your emergency action plan, implementing it in real-life situations can be quite challenging. Here’s what you can do:

• Create standard procedures for evacuation, reporting, communication, and head count, etc. Make sure the specific procedures are outlined in the written document.
• Develop a multifaceted alarm system that alerts employees to different types of emergencies, fires, chemical spills, toxin exposure, etc. The alarm system will sound differently based on the type of emergency.
• Employers must appoint a central authority to make immediate decisions and offer guidance during a crisis. In addition, they should conduct proper training sessions to ensure a coordinated response and eliminate panic.
• Routine meetings must be held where employers review the plan with every covered employee. Such meetings can be held initially, monthly, quarterly, or annually.

Practical implementation demands structural planning and the development of stringent policies to ensure a functional emergency action plan. Keep reading to learn what aspects to take into consideration when developing your emergency action plan.

Creating Standard Emergency Procedures

Creating standard operating procedures for emergencies (explosion, fire, natural disasters, etc.) can be helpful for employees, as they can rely on a set of instructions to navigate through an emergency without making mistakes that may create confusion or chaos.

Reporting: A preferred method of reporting the crisis, e.g., calling 911 or alerting the respective authorities and their contact information, should be outlined in the document.

Evacuation: Depending on the nature of the emergency, the right type of evacuation must be applied: Shelter-in-place, horizontal, building-wide, etc. For instance, in the case of a fire or gas leak, all occupants must evacuate the building through stairwells in an orderly fashion. Such hypothetical situations and their appropriate evacuation method must be highlighted in the document.

Exit Route Assignments: Employees must be divided into different sets of groups and assigned specific routes, such as floor managers must take the secondary exit route after guiding their subordinates onto the primary exit stairwell.

Plant Shutdown: Employees involved in plant operations, such as heavy machinery, conversion of raw products, etc must ensure complete shutdown before evacuation to isolate hazardous materials and prevent catastrophic equipment failure, which can contribute to the spread of the hazard.

First aid: Those equipped with basic medical training must prioritize those harmed or injured during the emergency.

Headcount: After evacuation, each employee must be accounted for and examined to assess for injuries or trauma.

Emergency Alert Systems and Communication Procedures

Distinctive Alarm System: An alarm system to sound all kinds of potential emergencies must be designed, which alerts employees to either evacuate or take response measures to address the emergency at hand. For instance, a fire in its initial stages can be apprehended with the help of automatic sprinkler systems and manual fire-suppression techniques. Whereas, a signal for a gas leak can alert personnel to evacuate immediately.

Point of Contact: The emergency action plan document must outline the names and contact information of experts who designed standard procedures and practices. Having this information at hand can enable employees to raise questions to the respective persons about the emergency plan.

Employee Training For Emergencies

Employee Training: Employers must appoint an authority who can support and guide a set group of employees. For instance, a floor warden can guide a group of 20 employees swiftly through the emergency at hand. Practicing evacuation drills can be helpful and give employees an idea of how to proceed during an emergency.

Plan Review: Employers must review the EAP with every covered employee when:

• • An employee joins the workplace
  • There is a change in roles or responsibilities
  • The EAP is initially designed and implemented
  • Changes are introduced to the plan

Now that you know what the implementation of an emergency action plan looks like, it’s important to know whether your workplace requires one.

Workplaces In Need of an Emergency Action Plan

OSHA dictates that almost all businesses need an emergency action plan; knowing whether yours falls in that category can help you avoid litigation and hefty penalties. Some of them are:

• 1910.119(n), Process Safety Management of Highly Hazardous Chemicals
• 1910.120(l), (p)(8), and (q)(1) Hazardous Waste Operations and Emergency Response
  (HAZWOPER)
• 1910.157(a)-(b), Portable Fire Suppression Equipment
• 1910.160(c), Fixed Extinguishing Systems,
• 1910.164(e)(3), Fire Detection Systems
• 1910.272(d) and (i)(2), Grain Handling Facilities
• 1910.1047(h), Ethylene Oxide (EtO)
• 1910.1050(d), Methylenedianiline (MDA)
• 1910.1051(j), 1,3-Butadiene

Other industries in need of an emergency action plan, although one that’s not compliant with OSHA, are:

• 1910.66(e)(9), Powered Platforms for Building Maintenance
• 1910.1017(i), Vinyl Chloride
• 1910.1027(h), Cadmium
• 1910.1044(i), 1,2-dibromo-3-chloropropane(DBCP)
• 1910.1045(i), Acrylonitrile
• 1910.1450 (Appendix A), Occupational Exposure to Hazardous Chemicals in Laboratories

Whether or not these standards apply to your workplace, it’s generally recommended that all employers develop an emergency action plan to ensure the safety of their employees during emergencies.

Ensuring Emergency Preparedness With Creative Safety Supply

Emergencies can strike at any moment, which is why we help you stay prepared for anything. At Creative Safety Supply, we offer industrial-grade emergency safety signs and ample information on Emergency Action Plans (EAPs) to help you protect your workers and maintain strict regulatory compliance. Creating a compliant EAP and reliable visual safety system with the right materials ensures that your team can react instantly and safely during a crisis.