OSHA does not require fire drills under 29 CFR 1910.38. However:
- If an employer’s emergency action plan (EAP) and/or emergency response plan (ERP), under 1910.38 or 1910.120, respectively, contain provisions for conducting any type of drills, OSHA would require the employer to implement and conduct those drills.
- If an employer requires its employees, under 1910.119, to take action in response to a chemical release of a highly hazardous chemical, these actions must be addressed in the employer’s process safety management “procedures or plans” (i.e., under 1910.119(f) and 1910.119(n)). If the employer then determines that drills are needed to assure that employees are adequately trained in those procedures, OSHA requires the employer to include those drills in its procedures and plans, and the employer must also ensure that employees are trained in those procedures.
Regardless if fire drills are required by OSHA, the agency says it is a good idea for employers to hold practice evacuation and shelter-in-place drills “as often as necessary” to keep employees prepared. This may be more a matter of policy than of regulation, but OSHA may turn to the General Duty Clause of the OSH Act if an incident were to occur and fire drills would have prevented it.
Note that local fire codes may require fire drills, even when OSHA does not. Check your fire codes to be sure. NFPA 101, the Life Safety Code, states that where a fire drill is required by a jurisdictional authority, then fire drills must be conducted at a frequency that is sufficient to keep building occupants familiar with the procedure. You may wish to coordinate your fire drills with your local fire department.
