Emergency action plans

Scope

Almost every business is required to have an EAP. If fire extinguishers are required or provided in a workplace, and if anyone will be evacuating during a fire or other emergency, then OSHA requires an EAP. The only exemption to this is if an employer has an in-house fire brigade in which every employee is trained and equipped to fight fires, and consequently, no one evacuates. In most circumstances, immediate evacuation is the best policy, especially if professional firefighting services are available to respond quickly. There may be situations where employee firefighting is warranted to give other workers time to escape, or to prevent danger to others by spread of a fire. In this case, the employer is still required to have an EAP.

Regulatory citations

• 29 CFR 1910.38 — Emergency action plans

Key definitions

• Alarm system: The means used to alert employees of necessary emergency action as called for in the emergency action plan, or for reaction time for safe escape of employees from the workplace or the immediate work area, or both.
• Exit: That portion of an exit route that is generally separated from other areas to provide a protected way of travel to the exit discharge. An example of an exit is a two-hour fire resistance-rated enclosed stairway that leads from the fifth floor of an office building to the outside of the building.
• Exit access: That portion of an exit route that leads to an exit. An example of an exit access is a corridor on the fifth floor of an office building that leads to a two-hour fire resistance-rated enclosed stairway (the Exit).
• Exit discharge: The part of the exit route that leads directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside. An example of an exit discharge is a door at the bottom of a two-hour fire resistance-rated enclosed stairway that discharges to a place of safety outside the building.
• Exit route: A continuous and unobstructed path of exit travel from any point within a workplace to a place of safety (including refuge areas). An exit route consists of three parts:
  • The exit access,
  • The exit, and
  • The exit discharge. (An exit route includes all vertical and horizontal areas along the route.)
• High hazard area: An area inside a workplace in which operations include high hazard materials, processes, or contents.
• Occupant load: The total number of persons that may occupy a workplace or portion of a workplace at any one time. The occupant load of a workplace is calculated by dividing the gross floor area of the workplace or portion of the workplace by the occupant load factor for that particular type of workplace occupancy. Information regarding the “Occupant load” is located in NFPA 101-2009, Life Safety Code, and in IFC-2009, International Fire Code (incorporated by reference, see 1910.6).
• Self-luminous: A light source that is illuminated by a self-contained power source (e.g., tritium) and that operates independently from external power sources. Batteries are not acceptable self-contained power sources. The light source is typically contained inside the device.

Summary of requirements

Employers who are required to have an EAP must:

• Establish emergency escape procedures and emergency escape route assignments.
• Develop procedures to be followed by employees who remain to operate critical plant operations before they evacuate.
• Establish procedures to account for all employees after emergency evacuation has been completed.
• Assign rescue and medical duties for those employees who are to perform them.
• List the preferred means of reporting fires and other emergencies.
• Establish an employee alarm system. If the employee alarm system is used for alerting fire brigade members, or for other purposes, use a distinctive signal for each purpose.
• List the types of evacuation to be used in emergency circumstances.
• Designate and train a sufficient number of employees to assist in the safe and orderly emergency evacuation of employees before implementing the EAP.
• Review the EAP with each covered employee upon initial assignment, when the employee’s responsibility or designated actions under the plan change, and when the plan changes.