Emergency! — Do you have a plan?
Emergency action plans are required in OSHA regulations. The OSHA regulations show their age by focusing on traditional fire drills and evacuation drills. This does not mean that you are not required to address other hazards. The OSHA General Duty Clause captures your responsibilities as an employer.
Each Employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious harm to his employees.
To see a comprehensive list of potential hazards that may require your attention visit FEMA’s emergency planning resource at https://www.ready.gov/
Since OSHA is a commonly referenced workplace safety resource, let us take a look at OSHA.
The General Industry standards call for this specifically in section 1910.38. This section also references that compliance with the Life Safety Code is considered as complying with this OSHA subpart 1910.35
OSHA has resources to assist employers with meeting these standards. The first is an OSHA Expert system to determine if you need an EAP. This questionnaire can be accessed at https://www.osha.gov/etools/evacuation-plans-procedures/expert-systems/osha-requirements
If the tool indicates you need a plan, you can link to the follow-on Expert System for creating your EAP. This tool can be accessed at https://www.osha.gov/etools/evacuation-plans-procedures/expert-systems/create-eap
These tools are good for small business and locations that do not have significant fire hazards or special chemical hazards.
A review of the Life Safety Code indicates that Emergency Action Plans are required in Section 101-4.8. The code gets more granular in training and drill requirements in the occupancy-based chapters. The following occupancies have specific training and drill requirements in the Life Safety Code
Assembly occupancies – employee drills and crowd managers
Education occupancies - Fire drills required
Day Care – Evacuation drills required
Health Care – Evacuation and fire drills
Ambulatory Health Care – staff training and drills required
Detention and Correctional – Staff training including fire extinguisher use
Hotels and Dormitories – Hotel emergency team and drills in dorms
Apartments – occupant instructions required
Residential Board and Care – staff training and drills required
Mercantile – staff training and drills
Business Occupancies – staff training and drills
A good resource for assistance in developing these plans is the National Fire Protection Association (NFPA). The NFPA web site, www.nfpa.org , had a variety of training materials and resources to assist you.
The OSHA Construction standards reference an emergency action plan at 1926.35. A fire safety plan is called out in 1926.150. Construction sites need to carefully evaluate the methods used to alert employees of an emergency and have a response plan in place.
Focusing exclusively on what is required in OSHA standards and the Life Safety Code may leave you exposed to claims of failure to plan. The hazard list here is either comprehensive or frightening depending on your outlook on life.
FEMA provides a collection of Hazard Information Sheets to address many of the hazards noted.
As the list of potential emergency events expands, you may need to expand your planning consultations. Having a response plan that is coordinated with the first responders will allow you and the responders to coordinate your actions. This can be as simple as what entry points should be used to detailed pre-planning on process hazards, special hazard protection systems and security issues that affect your facility. The local responders may also be able to assist with training resources that are consistent with their operational guidelines.
The Driehaus Difference
Your risk management program should include response plans and a review of insurance coverage to be sure you have the financial protection for an event. Some insurance programs can include assistance with incident response, post incident recovery and managing the public relations aspects of a critical event. Talk to us about your options for insurance and any assistance we may have for you. You can contact us on our web site www.driehausins.com or call us 513-977-6860