The Atlantic hurricane season is once again upon us! After last year’s record season of 17 named storms – 10 of which became hurricanes, and six of those 10 reached Category 3 strength or higher, names like Harvey, Irma, and Maria are ones we won’t soon forget.
OSHA encourages and in certain work environments requires employers to plan and prepare for workplace emergencies. As we know, emergencies and disasters can strike anywhere and at any time bringing workplace injuries and illnesses with them. Employers and workers may be required to deal with an emergency when it is least expected and proper planning before an emergency is necessary to respond effectively.
What is a workplace emergency?
According to OSHA, a workplace emergency is a situation that threatens workers, customers, or the public; disrupts or shuts down operations; or causes physical or environmental damage. Emergencies may be natural or man-made, and may include hurricanes, tornadoes, earthquakes, floods, wildfires, winter weather, chemical spills or releases, disease outbreaks, releases of biological agents, explosions involving nuclear or radiological sources, and many other hazards. Many types of emergencies can be anticipated in the planning process, which can help employers and workers plan for other unpredictable situations.
Several OSHA standards address emergency planning requirements, including 29 CFR 1910.38; 29 CFR 1926.35; Hazardous Waste Operations and Emergency Response (HAZWOPER) (29 CFR 1910.120(q)); Fire Brigades (29 CFR 1910.156); and Permit-Required Confined Spaces (29 CFR 1910.146(k), 29 CFR 1926.1211). OSHA Publication 3122, Principal Emergency Response and Preparedness Requirements in OSHA Standards and Guidance for Safety and Health Problems, provides a broad overview of emergency planning requirements in OSHA standards.
Employers should also be familiar with the consensus standards of the National Fire Protection Association (NFPA), American National Standards Institute (ANSI), and other standards-setting organizations, as these may provide additional recommendations and requirements about emergency planning.
What is an emergency action plan?
An emergency action plan (EAP) is intended to facilitate and organize employer and worker actions during workplace emergencies and is recommended for all employers. Well-developed emergency plans and proper worker training (i.e., so that workers understand their roles and responsibilities within the plan) will result in fewer and less severe worker injuries and less damage to the facility during emergencies. A poorly prepared plan may lead to a disorganized evacuation or emergency response, resulting in confusion, injury, illness (due to chemical, biological and/or radiation exposure), and/or property damage.
Two OSHA standards (29 CFR 1910.38(a) and 29 CFR 1926.35) require written EAPs. Not all employers are required to establish an EAP, but developing an EAP is a good way to protect workers and businesses during an emergency. Emergency preparedness is a well-known concept in protecting workers’ safety and health.
Putting together a comprehensive emergency action plan involves conducting a hazard assessment to determine what, if any, physical or chemical hazards inside or from outside the workplaces could cause an emergency. The plan should describe how workers will respond to different types of emergencies, taking into account specific worksite layouts, structural features, and emergency systems. If there is more than one worksite, each site should have an emergency action plan.
Most organizations find it beneficial to include a diverse group of representatives (management, workers, local health departments and agencies, and public safety officials/members) in this planning process and to meet frequently to review progress and allocate development tasks. Outside representatives from federal, state and local agencies may be able to assist organizations with incorporating other requirements or guidelines into their EAPs. The commitment and support of all workers and employers is critical to the plan’s success in the event of an emergency; ask for worker input in developing and implementing an EAP. For smaller organizations with 10 or fewer workers, the plan does not need to be written and may be communicated orally (General Industry Standard – 29 CFR 1910.38(b), Construction Industry Standard – 29 CFR 1926.35(e)(3)).
If you are unsure about whether you are required to have an EAP, use OSHA’s Expert System to help you determine your EAP requirements.
For more information on Emergency Response and Preparedness, please access this OSHA link: