What is an OSHA EAP, and do I need one?

I’ve written about Occupational Safety and Health Administration (OSHA) Emergency Action Plans (EAP) in the past, but people still find it confusing, so here is another look at the topic. Let’s begin by reviewing what OHSA says on its website regarding EAP.

“An EAP is a written document required by particular OSHA standards. [29 CFR 1910.38(a)] 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.” Weblink.

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Do you need an EAP?

OSHA requires employers to develop plans to handle fires and other emergencies that may require the evacuation of the premises. Such plans must be in writing, kept in the workplace, and be available to employees for review. An employer with ten or fewer employees may communicate the plan orally. A written plan, however, is the best practice as it provides clarity, as well as documented procedures and processes.

Specifically, OHSA states that almost every business must have an EAP. If fire extinguishers are required or provided in your workplace, and if anyone will be evacuating during a fire or other emergency, then OSHA's [29 CFR 1910.157] requires you to have an EAP.

Additionally, other OSHA regulations, such as Process Safety Management (PSM), require an EAP. While I won’t address the subject in detail in this article, it’s worth pointing out that OSHA and the Environmental Protection Agency (EPA) sometimes have similar overlapping regulations. For example, EPA’s Risk Management Program (RMP) has an Emergency Response Program (ERP) requirement that closely mirrors OSHA’s PSM EAP requirements and that most companies incorporate into one large plan.

Here are some additional reads to help better clarify the above:

• RMP vs. PSM – EAP vs. ERP – The Confusion
• 5 Part Miniseries – Are annual plan reviews required for all regulatory plans? (EAP)
• Revisit: EAP vs. FRP: Doesn’t my FRP address this already? (ICPs, not just dumping spots)

The main elements of an OSHA EAP are:

• Procedures for reporting a fire or other emergency (relevant to your operations);
• Procedures for emergency evacuation, including the 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;
• Identifying 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; and
• Employee alarm systems.

Witt O’Brien’s has encountered and developed many of these plans, and there are two (2) main directions they can take: 1) a generic set of commonly accepted practices/procedures along with some minimal site detail to address the above requirement, or 2) a very detailed manual covering all hazardous on-site, which is tailored more like a standard operation procedure (SOP) manual.

Either style may suffice, and ultimately it is up to the organization developing the EAP. However, you should keep the following principles in mind:

• Is it functional and realistic for your site? Are Evacuation Routes and Muster Points Clear, Fire Equipment Procedures and Locations Clear, Alarm Protocols Clear, Medical/Rescue Procedures Clear, and are tasks and responsibilities spelled out clearly? This requires forethought. Do not just cut and paste generic language. Your plan should be relevant to your facility.
• Does it accomplish the primary employee safety goal? Has it been tested/evaluated? Remember, KISS – keep it simple stupid. When incidents happen, things get “fuzzy,” so the EAP should be straightforward and easy to use.
• Is it legible and understandable? Many plans don’t make sense. They are too technical, and/or the layout is confusing, so they can’t be easily interpreted by end-users or site personnel. To be a practical document, people need to know precisely what is required, and actions must be clearly stated.
• Do employees know the plan? If employees are not aware of company policies and procedures, they cannot perform their respective duties and be expected to know what to do during an incident.
• Do employees that are noted in the plan know they are listed and what is expected of them? For a plan to be successfully implemented, all responsible parties must be aware of what is in the plan and trained to implement it.
• Has management signed off on the plan? A plan not endorsed by management will not be effectively utilized and implemented.

Ending thought: when developing any emergency response plan, it is always best to be clear and concise and to provide well-thought-out details that personnel can utilize to aid in their own safety and the safety of others. Don’t regard plan development as merely a requirement to comply with a regulation. Instead, focus on making the plan a helpful tool. Lastly, do not just put it on a shelf and forget about it. Train and exercise your personnel in using it, as it provides safety for personnel and contractors onsite.

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For a complete listing of archived articles and compliance insights, click here. Past articles cover training requirements, clarification of additional unclear elements within the above rules, and more.

We are here to help solve your compliance questions and challenges. If you need compliance assistance or have questions, please email John K. Carroll III ([email protected]), Associate Managing Director – Compliance Services, or call +1 954-625-9373.

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