Emergency Action Plan (EAP)
Table of Contents
Table of Contents
What Is an Emergency Action Plan (EAP)?
An emergency action plan (EAP) is required by law and has certain structured requirements. The EAP clearly states how to immediately respond to an emergency focusing on employee safety, also known as “protective actions for life safety.” An EAP should be a core part of your organization’s safety plan.
According to the OSHA, “An emergency action plan (EAP) is a written document required by particular OSHA standards. [29 CFR 1910.38(a)] The purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. Well developed emergency plans and proper employee training (such that employees understand their roles and responsibilities within the plan) will result in fewer and less severe employee injuries and less structural damage to the facility during emergencies. A poorly prepared plan likely will lead to a disorganized evacuation or emergency response, resulting in confusion, injury, and property damage.”
Why Is It Important to Have an Emergency Action Plan?
There are several reasons why it is important to have an EAP for your organization. Here are some of the most important.
- Employee safety. When employees know what is expected and what will happen in an emergency, they respond in a calmer, safer manner.
- Legal requirements. OSHA violations carry civil penalties up to $15,625 per violation in 2023. State, municipal and industrial violations carry additional penalties. Your workers’ compensation provider may revoke your organization’s coverage or incur additional fines and fees for failure to comply with EAP requirements.
- Limited liability and improved processes. With regular inspections and risk assessments of the business facility to examine the potential impact of an emergency on business activities, you can expose liabilities as well as opportunities for process improvement.
- Workplace culture of team building and safety. Studies have shown that scenario training builds problem-solving skills as well as heuristics for emergency situations. Emergency training improves the response and resiliency of those affected. The EAP and the associated safety plan can be a vital tool to build a culture of safety and team building for your organization.
How to Develop and Implement an Effective Emergency Action Plan
Now that you understand why an EAP is important, how do you develop and implement one for your organization? These steps provide a general guideline to get you started.
Step 1: Conduct a Workplace Evaluation
First, evaluate how much planning for emergencies is involved in the scope of your business strategy beyond the minimum required “protective actions for life safety.” Part of this is determining what organizational resources are available, and what level of loss vs. cost of prevention is in your organization’s business strategy.
Then evaluate the workspace, taking into consideration the facility, its uses, any hazards and the people utilizing the space. Dig out and review any existing EAPs. Anything over ten years old will need to be almost completely rewritten due to regulatory and best practice changes. Consider language and literacy when evaluating required signage and procedures. Be aware of ADA compliance.
There are many templates available for drafting and revising your EAP. Your state OSHA, OSHA, your workers’ compensation provider and FEMA will all have good resources. Ready.gov provides a good overall walkthrough of the process here. Additional resources are in the resources section below.
Step 2: Check Additional Local and Industrial Requirements
All locations need a customized EAP for the facility. This includes customization based on the property, business activities and local hazards and regulations. Examples of local hazards include storm surge or tsunami zones, floodplains, earthquake and tornado risk. Local risk factors also include infrastructure and industrial hazards such as electrical grid stability or proximity to chemical storage, airports or high-risk terrorist targets. State, county, regional and city governments can have additional requirements or recommendations to ensure coordination in a large-scale emergency.
As you build your plan, work closely with the owner/manager of the facility or building. They are required to provide certain information for safe evacuations. Buildings with multiple tenants require some coordination for evacuations and exterior meeting site placement.
For example, California code (Tit. 19, § 3.09 – Emergency Planning and Information) requires building owners of “All office buildings 2 or more stories in height (except high rise buildings as defined by Health and Safety Code Section13210)” to provide evacuation information to their tenants. California municipalities mandate emergency evacuation drills for high-rise buildings. Check your local ordinance for height and frequency requirements.
Step 3: Draft the Plan
OSHA requires that the EAP be written down and available in a paper version at all times. In emergencies, power or the internet can go down and keeping your emergency plan only available online is both ineffective and non-compliant.
Step 4: Gather the Team
Your EAP will need to be implemented by your organization’s safety officers or organizational equivalent. Getting feedback on the plan from division heads will ensure that department-specific protocols and hazards are included in the overall plan (i.e. location of onsite flammables or HAZMAT storage). Feedback will also provide buy-in on the plan and its implementation.
Components of an Emergency Action Plan
The contents of the EAP should be organized in the order they will be needed in an emergency. There are many formats and templates available. Your workers’ compensation provider may recommend or mandate one. There are also industry-specific best practices for construction, manufacturing and other industries.
EMS Contact Information
The emergency contact for fire, police, HAZMAT (if needed), etc. is required for every EAP. Include utilities and government agencies.
Evaluation of Emergency and Scope
The evaluation component should answer questions like “Is the emergency a medical emergency, a threat inside the facility like a fire, power loss, HAZMAT incident, or active shooter? Is it external to the building like a flood, tornado, etc? What is the chain of command for the emergency authorization of evacuations, etc? What is the protocol for triggering the alarms, evacuation, etc. Details are in the section for the emergency.
The EAP should include instructions on communicating the emergency to EMS, employees, clients and potential public onsite. This includes a description of the alarm including the sound, visual cues for the hearing impaired as well as a brief script for any announcements.
It should also include important answers to questions like, Where is the personal information located for contacting employees or their families? Who is responsible for this? What is the protocol for communicating the emergency externally to offsite employees, clients and the public? What is that chain of command? Include several people in case the primary person is not available.
- Emergency medical procedures. This specific situation is when one or more people are injured or need medical attention on site. The location of medical supplies/ first aid/ defibrillator should be clearly stated and include a map. Answer questions such as: What location will emergency Services (EMS) use to enter the building? If possible, a person needs to meet the EMS at this location to guide them to the emergency. Do they need access to gates or parking? This section also needs to include industry and facility-specific procedures like chemical exposures, eyewash stations, biohazards, etc. Make sure the organization’s Safety Data Sheets are available for chemical exposures and that the location is noted in this section. Do not include the safety data sheets in the EAP.
- Interior threats. Interior threats are emergencies like fires. Fire procedures should include the location and use of fire extinguishers, the fire suppression system protocols and detailed steps to trigger a fire alarm and evacuation. Your local municipality or fire marshal may have specific requirements or recommendations. This is particularly true in taller buildings.
- Active shooter. Work with your risk assessment and workers’ compensation team to determine the risk level and responses needed for active shooter emergencies. Work with your building owner to determine wall composition for safer shelter-in-place zones (i.e. load bearing walls are more solid; don’t shelter next to the gas main).
- Industry-specific or HAZMAT internal emergency. Include specific protocols for leaks, containment breaches, mechanical issues, power outages, etc.
- Earthquakes. Include protocol for shelter during earthquakes and safety evaluations for moving afterward including evacuation around earthquake damage like glass breakage, etc.
- Include multiple copies of the current floor plans for use in an evacuation. This needs to include the location of hazards for the emergency response crew including flammables and all HAZMAT.
- Create a current list of safety officers responsible for assisting in clearing the building. Each safety officer should have access to the necessary supplies such as tape and sharpies to clear the floor.
- List all locations of people or supplies for assisting non-ambulatory and disabled people exiting the facility.
- Include the meeting place upon evacuation and the procedure for a roll call. Consider including penalties if you are worried your personnel will just leave before confirmation of evacuation.
- List all onsite HAZMAT (including chemical composition) for the fire crew.
- Include a procedure for shutting down any hazardous systems prior to evacuation along with a list of the people who will be performing this.
- Have contact personnel and procedures for off-hour emergencies.
There are many tools available here, including a checklist for an evacuation plan.
An exterior threat may require sheltering in place or a delayed evacuation. Exterior threats include but are not limited to: flooding, tornado, tsunami, Hazmat situation, civil unrest, etc. This will need to be customized by location. Some locations, like specific airports, have protocols for nearby businesses. Include the location and rationing of emergency supplies of food and water (X people for X days, or X servings). It is also good to include the expiration date of the items. You may want to check with your local disaster preparedness organization to see if your facility is a strategic location for gathering people or supplies.
A pandemic is another external threat. Now is a good time to integrate your pandemic response protocols into your EAP. Be specific whether your organization has a set protocol, or a flexible response to future outbreaks or new pandemics.
Finally, technological emergency protocols should be present in your EAP, including DNS, malware, solar flare, etc. This emergency begins to get into a business contingency plan when you consider mitigating the effects of an emergency that can limit or destroy your organization’s technical capabilities. Have a plan for communication and restoration of services.
PR and Ongoing Communication
Ongoing communication of an emergency to employees, clients, and potential public offsite is essential. Include “marked safe” protocol for off-site employees and employees returning home in an environmental emergency such as a flood. State the chain of command for who issues statements. Include remote workers in this. Include the contact information for the responsible party for the EAP to answer any questions.
It is recommended to include the EAP training as part of the overall employee safety plan training. The training needs to be documented to comply with most workers’ compensation plans as well as many local ordinances. Two components are required: training for all staff, and training for responsible parties including the evacuation team.
Marketing and Distribution
Your EAP should be immediately identifiable. Often it is in a red binder clearly labeled in large font to be visible from 10 feet away. The location of the physical copies of the EAP needs to be well-known and easy to access. For example, good locations can include keeping a copy at the main reception and the security office, main lunch room, etc.
It is inadvisable to keep only one copy. Ideally, all employees should have a physical copy, but the safety officers and people with evacuation duties need to have a physical copy of the plan. A digital copy can be useful for training purposes. The employee responsible for the plan needs to keep a list of the copies so that they can all be updated when needed. In order to comply with OSHA, physical copies need to be easily available to employees.
Do not forget to include planning for the remote workers in your plan. Remote workers need an additional two parts to their copy of the EAP. The first includes steps for an emergency at their location. The second is their plan if the emergency is at their contact/satellite workplace. This needs to include alternate methods of how to contact and report in. They also need training for any facility that they are expected to attend on a regular basis. Remote workers should have a physical copy of at least their portion of the EAP, if not a complete copy. Remember, you cannot guarantee cloud or internet access to digital plans.
Industrial accidents and injuries need to follow OSHA reporting regulations. Your organization may be regulated by additional agencies which have reporting requirements for industrial accidents, injuries, and incidents. Your workers’ compensation provider usually has a protocol for reporting incidents, or even near accidents or incidents with no injuries. Your organization may also have insurance reporting.
All of these may require documentation from EMS, photographs, and victim statements. Your legal department may require follow-up documents from any non-employees injured. Make sure your plan includes a checklist for the required reporting and forms, with the required turnaround time. It is advisable to keep a copy of all of the forms and EAP in an offsite location in the event of a complete loss to access to the facility.
Recovery is not a mandated portion of an EAP. However, it is part of a complete EAP and a good overall strategic tool. This starts to overlap with the concepts of a business continuity plan, which looks at the critical business functions with a plan for resuming operations as soon as possible after a disruptive incident.
This step reinforces the decisions in the evaluation phase with resources available and acceptable risks for key infrastructure and business functions when the cost of recovery is taken into account. This step is essential for planning for technology and communication interruptions and emergencies.
Mitigation steps such as backup power, offsite backups for key technology, redundant systems, and backup communication channels are all standard contingency mitigation strategies.
Legal and Regulatory Requirements for Emergency Action Plans
OSHA 1910.38 governs emergency action plans. At a minimum, the plan must include but is not limited to the following elements [29 CFR 1910.38(c)]:
- Means of reporting fires and other emergencies
- Evacuation procedures and emergency escape route assignments
- Procedures for employees who remain to operate critical plant operations before they evacuate
- Accounting for all employees after an emergency evacuation has been completed
- Rescue and medical duties for designated employees
- Names or job titles of persons who can be contacted
Although they are not specifically required by OSHA, (here) you may find it helpful to include the following in your plan:
- A description of the alarm system to be used to notify employees (including disabled employees) to evacuate and/or take other actions. The alarms used for different actions should be distinctive and might include horn blasts, sirens or even public address systems.
- The site of an alternative communications center to be used in the event of a fire or explosion.
- A secure on or off-site location to store originals or duplicate copies of accounting records, legal documents, your employees’ emergency contact lists and other essential records.
State OSHA and local fire regulations may have additional requirements, particularly for emergency planning and evacuation requirements for high-rise buildings. Check with your state and local regulatory agencies.
Currently, 29 states have supplementary requirements. Seven of those states’ requirements only apply to state and local government workers. For a list of the states and links to their requirements visit this site.
For example, California code §3220 covers Emergency Action Plan requirements including evacuation and training, which are more comprehensive than OSHA. Health and Safety Code Section 13210 requires facility property owners to provide “a floor plan providing emergency procedures information shall be posted at every stairway landing, at every elevator landing, and immediately inside all public entrances to the building” or alternative.
Regional and Municipal Requirements
Your local fire marshal or city planning department will have information about additional requirements for your industry. For example, the height of the building which requires annual fire drills for all employees can vary greatly, from buildings over 75 feet to those over 35 stories.
Workers’ Compensation Plans and Insurance Requirements
Many workers’ compensation plans have contractual requirements for the EAP and safety plans of the organization. Your insurance companies may also have additional requirements (fire, flood, earthquake, financial, etc). For example, you may have a requirement for a fire suppression system which requires regular testing and this should be included in your plan.
Licensing and Industry Regulatory Agency Requirements
Some licensing and industry regulatory agencies have requirements for emergency action plans and safety plans. This can include regulations for HAZMAT and biohazards. For example, schools and hospitals require more frequent fire drills. Check with your legal team, risk assessment, workers’ compensation or safety team for more information.
Take care of your people and protect your business with Eddy
Questions You’ve Asked Us About Emergency Action Plans (EAP)
Janis transitioned from a career in the arts to bring that passion and creativity into maximizing the potential of employment. Janis is a generalist who loves safety, compliance and employee experience.