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Emergency action plan: what it is, the six OSHA elements, and how to write one

Short answer

An emergency action plan (EAP) is the written plan that tells everyone on a site what to do in an emergency: how it is reported, how people leave, who stays behind to make critical equipment safe, how everyone is counted and who to ask. In the United States, OSHA 29 CFR 1910.38 requires one whenever another standard in part 1910 calls for it, and it sets six minimum elements that the plan must contain.

An emergency action plan covers six things under 29 CFR 1910.38(c): reporting a fire or other emergency, evacuation and exit route assignments, procedures for employees who stay to shut down critical operations, accounting for everyone after evacuation, rescue and medical duties, and the names or job titles people can ask about the plan. It must be in writing, kept in the workplace and available to employees, except that an employer with 10 or fewer employees may give it orally, 1910.38(b). It also needs an employee alarm system with a distinctive signal, 1910.38(d), trained people to help others out, 1910.38(e), and a review with each employee when they start, when their duties change and when the plan changes, 1910.38(f). A plan is only as good as the last drill that tested it. Check your local rules: fire codes and other countries' laws add to this.

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What is an emergency action plan?

An emergency action plan is a short working document, not a binder. It answers the questions a person asks in the first minute of an alarm: what do I do, where do I go, who is in charge and how will anyone know I got out. It covers a fire, and on most plants also a chemical release, severe weather, a medical emergency and a power failure, each with its own signal and its own steps.

29 CFR 1910.38(a) says an employer must have a plan whenever an OSHA standard in part 1910 requires one. The rest of the section then says what the plan must contain. Section 1910.38(b) requires the plan to be in writing, kept in the workplace and available to employees for review. An employer with 10 or fewer employees may communicate it orally.

Three documents that get confused
DocumentWhat it answersStandard
Emergency action planWhat people do once an emergency has started: report, leave, be counted, help29 CFR 1910.38
Fire prevention planHow fires are stopped before they start: hazards, ignition sources, waste, who maintains heat-producing equipment29 CFR 1910.39
Drill recordProof the plan was tested: date, time taken, people counted, problems foundYour own record, plus any local fire code

The two plans work as a pair. 29 CFR 1910.157(b)(1) mentions a written fire safety policy that requires immediate and total evacuation together with an emergency action plan and a fire prevention plan meeting 1910.38 and 1910.39.

The six minimum elements of an emergency action plan

29 CFR 1910.38(c) lists what the plan must include at a minimum. The table sets each element beside what a plant plan usually writes for it. The right-hand column is practice, not the wording of the standard.

29 CFR 1910.38(c): the six elements and what to write for each
ElementParagraphWhat a plant plan writes
Reporting a fire or other emergency1910.38(c)(1)The alarm points, the emergency number, and who calls it. One sentence per scenario
Evacuation: type and exit route assignments1910.38(c)(2)Full or partial evacuation, which exit each area uses, the backup exit, the assembly point for each exit
Employees who stay for critical plant operations1910.38(c)(3)Named roles, the shutdown steps that take seconds, and the point at which they must leave
Accounting for all employees after evacuation1910.38(c)(4)Who counts, against what list, and how visitors and contractors are included
Rescue and medical duties1910.38(c)(5)Named first aiders and responders, what they do and what they do not do
Who to ask about the plan1910.38(c)(6)The name or job title of every employee people can contact, with their duties under the plan

The standard does not set a number of wardens, a drill frequency or a time limit. It sets the content of the plan. Local fire codes may set drills and occupancy rules, so check them.

Alarms and exit routes: what the plan depends on

A plan on paper does nothing if people cannot hear the alarm or reach the door. Two neighbouring rules carry most of the weight. 29 CFR 1910.38(d) requires an employee alarm system that uses a distinctive signal for each purpose and meets 29 CFR 1910.165. That section requires the alarm to be perceived above ambient noise or light by all employees, 1910.165(b)(2), and to be distinctive and recognizable as a signal to evacuate, 1910.165(b)(3).

The employer must explain the preferred way to report emergencies and post emergency telephone numbers where phones are the reporting method, 1910.165(b)(4). A non-supervised alarm system must be tested for reliability and adequacy every two months, 1910.165(d)(2), and manual pull boxes must be unobstructed, conspicuous and readily accessible, 1910.165(e).

On exits, 29 CFR 1910.37(a)(3) says exit routes must be free and unobstructed, with no materials or equipment placed in them, permanently or temporarily. Each exit must be clearly visible and marked by a sign reading Exit, 1910.37(b)(2), and a doorway that could be mistaken for an exit must be marked Not an Exit or similar, 1910.37(b)(5). At least two exit routes must be available in a workplace, with exceptions in 1910.36(b)(3). A walk of every exit with the plan in your hand is the quickest way to find where the plan and the building disagree.

How to write an emergency action plan, step by step

Write the plan with the people who carry it out: a supervisor from each shift, a maintenance lead, a first aider and the person who orders contractor access. A plan written in an office tends to name exits nobody uses.

  1. 1

    Draw the site and mark the exits

    Take the floor plan, mark every exit, the alarm points, the extinguishers, the shut-offs and the assembly points. Walk it. Fix what the walk shows, such as a pallet in front of a door.

  2. 2

    List the scenarios

    Fire first, then the others your site can have: chemical release, severe weather, medical emergency, power loss, a gas leak. Each gets its own signal and its own two or three steps.

  3. 3

    Set the alarm and the reporting route

    Write what each signal means, who can raise it and the number to call. Post the numbers where phones are used, as 1910.165(b)(4) asks.

  4. 4

    Assign exits and assembly points

    Give each area a primary exit, a backup exit and an assembly point away from the building, and check that no route passes toward a high hazard area, 1910.37(a)(2).

  5. 5

    Name the people, and a backup for each

    A coordinator, area wardens, first aiders, a shutdown lead for critical operations and a head count lead. Use job titles as well as names, since 1910.38(c)(6) asks for the name or job title.

  6. 6

    Decide who stays and what they do

    Keep the list short. A critical operation is something that becomes more dangerous if left running, such as closing a gas valve. Write the steps so they take seconds, and the point at which that person must go.

  7. 7

    Plan the head count

    Count against a live list: the shift roster, plus the visitor and contractor sign-in. Decide who reports the count and to whom.

  8. 8

    Train and issue the plan

    Designate and train people to assist in an orderly evacuation, 1910.38(e). Review the plan with each employee when they start, when their duties change and when the plan changes, 1910.38(f).

  9. 9

    Drill, time it, fix what you find

    Run a drill on each shift. Record the time from alarm to the last area counted, the people counted against expected and every problem, with an owner and a date.

Worked example: a 140 person plant and one drill

Illustrative. A plant has two shifts and three areas. The numbers are made up to show the working. The plant has chosen one warden for every 20 people or part of 20 in an area. That is the plant's own rule, not an OSHA number.

People by area and shift, and wardens needed at one per 20 people or part of 20
AreaShift 1 peopleShift 1 wardensShift 2 peopleShift 2 wardens
Press shop382201
Assembly342141
Warehouse242101
Total966443

Check: 38 + 34 + 24 = 96 and 20 + 14 + 10 = 44, and 96 + 44 = 140. Wardens: 2 + 2 + 2 = 6 on shift 1 and 1 + 1 + 1 = 3 on shift 2. The coverage grid showed the warehouse on shift 2 had no named warden, although the plan looked complete.

Drill on shift 1. The roster expects 96 people. Add 3 visitors and 2 contractors signed in at the gate, and the expected count is 96 + 3 + 2 = 101. The alarm sounds at 14:02:10 and the last area reports at 14:09:40, so the drill took 7 minutes 30 seconds, which is 450 seconds. The assembly points counted 99, so 101 - 99 = 2 people were unaccounted for.

Both missing people were at the loading dock, outside any assembly point's line of sight, and had left by the dock door. The fix was a named warden for the dock on both shifts and a line on the plan for the dock door's assembly point. The second drill counted 101 of 101. The drill, not a reread of the plan, found the problem.

Training, drills and review

29 CFR 1910.38(e) requires the employer to designate and train employees to assist in a safe and orderly evacuation of others. 1910.38(f) requires the plan to be reviewed with each employee covered by it in three cases: when the plan is developed or the employee is first assigned to a job, when the employee's responsibilities under the plan change, and when the plan changes.

Fire extinguishers add a second layer. Where employees are designated to use fire fighting equipment as part of the plan, 29 CFR 1910.157(g)(3) and (g)(4) require training in the equipment on first assignment and at least annually. Where extinguishers are provided for employee use, 1910.157(g)(1) and (g)(2) require an education program on initial employment and at least annually. If the plan says everyone evacuates and only named people may use extinguishers, 1910.157(b)(2) exempts the employer from the distribution requirements in paragraph (d).

The text of 1910.38 sets no drill frequency. Many plants drill each shift once or twice a year anyway, because a plan nobody has practised fails at the first surprise. Check your local fire code for any required frequency, and write the plant's own schedule into the plan.

Common mistakes in emergency action plans

  • One plan for the day shift. Nights and weekends have fewer people, different wardens and sometimes a different exit open. Draw the coverage by area and shift.
  • Names with no backup. People take leave. Every role needs a named deputy.
  • A count against the wrong list. Visitors and contractors are on site but not on the roster.
  • An assembly point that is on the route of the fire truck, or one that is out of sight of the dock or the yard.
  • Everyone told to stay and fight the fire. Decide who may use an extinguisher and train them, and tell everyone else to leave.
  • Never drilled, or drilled once and never timed. Time it and count it.
  • Kept in a locked office. 1910.38(b) says the plan is available to employees for review.

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FAQ

Questions about emergency action plan

  1. An emergency action plan is the written plan that tells everyone on a site what to do in an emergency: how to report it, how to leave, who stays to make critical equipment safe, how everyone is counted and who to ask. In the United States OSHA 29 CFR 1910.38 requires one whenever another standard in part 1910 calls for it.

  2. 29 CFR 1910.38(c) lists them: procedures for reporting a fire or other emergency, procedures for emergency evacuation including type of evacuation and exit route assignments, procedures for employees who remain to operate critical plant operations before they evacuate, procedures to account for all employees after evacuation, procedures for employees performing rescue or medical duties, and the name or job title of every employee who may be contacted about the plan.

  3. Yes, in general. 29 CFR 1910.38(b) says it must be in writing, kept in the workplace and available to employees for review. The exception is an employer with 10 or fewer employees, who may communicate the plan orally. Check your local rules, since other jurisdictions differ.

  4. The text of 29 CFR 1910.38 does not set a drill frequency. Local fire codes may, so check yours. Many plants drill every shift at least once a year and after any layout, staffing or hazard change, then time the drill and count the people at the assembly points against a live roster.

  5. For a non-supervised employee alarm system, 29 CFR 1910.165(d)(2) requires a test of reliability and adequacy every two months, using a different actuation device in each test of a multi-device system. Supervised systems are tested at least annually under 1910.165(d)(4).

  6. An emergency action plan says what people do once an emergency has started: report, evacuate, be counted, help. A fire prevention plan, 29 CFR 1910.39, says how fires are prevented: the major fire hazards, ignition sources, waste control, maintenance of heat-producing equipment and who is responsible. Each is a separate written document.

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