Emergency Action Plans & Fire Safety: OSHA 1910.38 Explained

Emergency Action Plans & Fire Safety: OSHA 1910.38 Explained

Quick answer: An OSHA emergency action plan (EAP) under 29 CFR 1910.38 spells out what employees do during a fire or other emergency. It must cover how to report emergencies, evacuation procedures and routes, who performs critical operations before evacuating, how to account for everyone afterward, and any rescue or medical duties. A written plan is required when the standard applies (and for any employer with 11 or more employees).

What the Plan Must Include

• Reporting — procedures for reporting a fire or emergency.
• Evacuation — emergency evacuation procedures and exit route assignments.
• Critical operations — procedures for employees who must stay to operate critical equipment before they evacuate.
• Accountability — procedures to account for all employees after evacuation.
• Rescue and medical — duties for those performing them.
• Contacts — names or job titles of people to ask about the plan.

An employer with 10 or fewer employees may communicate the plan orally; otherwise it must be written and available to employees.

Alarms and Exit Routes

The plan relies on an employee alarm system that's distinctive and recognizable, and on exit routes that are permanent, unobstructed, properly marked, and adequate for the number of occupants. Blocked or unmarked exits are a frequent — and dangerous — citation.

Fire Prevention

A companion fire prevention plan (1910.39) addresses the other half: controlling fuel sources, maintaining equipment, and housekeeping that keeps ignition risks down. Together they cover preventing fires and responding to them.

Training

You must review the plan with each employee when the plan is developed, when their responsibilities change, and when the plan changes. New employees should learn it as part of their orientation.

Frequently Asked Questions

Does every business need a written EAP?

If an OSHA standard requires an EAP, yes -- and any employer with more than 10 employees must put it in writing. Smaller employers may communicate it orally.

How often do we practice evacuation?

OSHA doesn't set a universal drill frequency for general industry, but regular drills are strongly recommended and required by some standards and local codes.