Emergency Action Plans: Are You Ready? (Part 1 - The Basics)

With spring right around the corner for most of us, it typically means warmer weather, flowers blooming, putting the winter coats up in storage, and also...severe weather. As the cold winter weather transitions out and the warmer air makes its way in, this will lead to thunderstorms, heavy rain, and potential tornadoes for a major portion of the country. Has your workplace practiced what to do in the event of severe weather? If I had to guess, I'd say it's been covered multiple times during company-wide meetings, you've read it during your company's new hire orientation, and maybe you've even participated in a tornado drill from time to time. But what about the other emergencies your workplace may face? Are you prepared for everything that may (reasonably) head your direction?

In this eight-part series, we will cover various workplace emergencies and how to properly prepare for them in accordance with regulatory standards.

Minimum Contents of an EAP

OSHA's emergency action plan standard (29 CFR 1910.38) establishes the minimum contents of any covered organization's emergency action plan (EAP). An emergency action plan must be in writing, kept in the workplace, and readily available to employees for review (employers with 10 or fewer employees may communicate the plan orally). At a minimum, an emergency action plan must include:

• A preferred method for reporting fires and other emergencies;
• An evacuation policy and procedure;
• Emergency escape procedures and route assignments, such as floor plans, workplace maps, and safe or refuge areas;
• Names, titles, departments, and telephone numbers of individuals both within and outside your company to contact for additional information or explanation of duties and responsibilities under the emergency plan;
• Procedures for employees who remain to perform or shut down critical plant operations, operate fire extinguishers, or perform other essential services that cannot be shut down for every emergency alarm before evacuating; and
• Rescue and medical duties for any workers designated to perform them.

As a best practice, you should consider designating an assembly location (aka "rally point") and procedures to account for all workers (including visitors) during an emergency. In addition, although they are not specifically required by OSHA, you may also find it helpful to include in your plan the following:

• The site of an alternative communications center to be used in the event of a fire or explosion; and
• 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.

The appendix to 1910 Subpart E explains that "the emergency action plan should address emergencies that the employer may reasonably expect in the workplace. Examples are: fire; toxic chemical releases; hurricanes; tornadoes; blizzards; floods; and others." While some of these emergencies may not apply to you (e.g., blizzards, hurricanes, etc.), there's a good chance that many of them will.

Reviewing Your EAP

At least annually, your company should review the program for accuracy and proper content. If no changes are made and/or needed, document that the program was reviewed thoroughly, date it, and list the employee(s) involved in the review. This will provide adequate documentation of your program's review. If changes are made, however, these will need to be documented and reviewed immediately with all affected workers. In addition, a review of the EAP is required to occur with all of your company's employees, temporary workers, and subcontractors:

• When the plan is developed or the employee is assigned initially to a job;
• When the employee's responsibilities under the plan change; and/or
• When the plan is changed.

Any time the EAP is reviewed with company personnel, be sure to document it so that it can be logged in your training records.

Emergency Response Equipment

Each site's EAP should identify, list the locations of, and provide operational procedures for types of emergency equipment. For off-site locations, available emergency equipment should be identified and reviewed with workers prior to commencing work activities. Examples include:

• Emergency lighting, exit doors, fire walls, and fire doors; 
• First aid kits located throughout the facility and/or in vehicles; and
• Portable fire extinguishers being located throughout the facility and clearly marked.

Media Response Plan

Dealing with the media is a task in itself, trust me! Some people will naturally try to hide from the media, while others search for the limelight (or the media finds you because you're the only one not smart enough to hide!). However, one misspoken word or statement (whether knowingly or unknowingly) can run your company's public image straight into the ground, so you better have a plan in place to prepare for it! The last thing you want is to have injuries (or even worse - fatalities) involved and the victims' families find out on the 6 o'clock news, rather than from a personal phone call from the company. If that happens, good luck earning their trust and respect back!

As a best practice, you should advise all company personnel not to be interviewed by anyone unless your company's management and/or legal department has given prior approval. If your company's personnel have received the proper approval for an interview and then another party’s attorney appears unannounced, your company's personnel should politely adjourn the interview until your company's management and/or legal department can be contacted and advised of the situation. If the interview is taped or videotaped, you should request a copy of the tape. If the interview is reduced to writing, you should ask for a copy of any notes or statements taken.

Alarms & Emergency Communication

Each EAP for should contain methods to address alarms and communications in case of an emergency. OSHA states that "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." For sites with 10 or fewer employees in a particular work area, verbal communication is an acceptable procedure for sounding the alarm provided all workers can hear it. Regardless of the method, each EAP should describe how to activate an alarm and what to do after either activating or hearing an alarm.

As we'll discuss in the later parts of this series, EVERY alarm shall be treated as an actual incident until proven otherwise. Treating and responding to alarms as a routine happening can result in injuries, fatalities, and/or destruction of property. Ever heard the saying "Complacency kills"? That didn't just magically appear out of thin air.

The method of communication at your facility is ultimately up to you, but a few common options include:

• Verbally by a company supervisor. If your boss yells "GET OUT!", you should probably do so.
• Press an evacuation alarm button which will sound over the PA system. Some systems can play pre-recorded messages to explain the situation, whereas others may just active strobes, sirens, etc.
• In the case of electrical power shutoff, always have a backup plan! Air horns work great for this type of situation, but you need to be sure to have a designated tone for each action (e.g., short blast for shelter-in-place, long blast for evacuate, etc.).

Remember, the time to find deficiencies and inadequacies in your system is during drills, not during the actual emergency. Test your system(s) periodically and ensure they are working effectively and as designed. If one part of the building can't hear the alert tones, that's a major problem (and probably a lawsuit, too!).

Summary

For more information about OSHA's emergency action plan standard, visit the OSHA website (or click here). It will provide the minimum requirements for EAPs. However, the most important thing is to continuously evaluate your program's effectiveness and look for ways to improve it. People's lives are depending on it!

Coming up in the next article: Part 2 - Fires