Emergency Action Plan (EAP)

An Emergency Action Plan (EAP) is a written plan that tells employees what to do when a workplace emergency happens, such as a fire, chemical release, severe weather or medical event. Under OSHA's 29 CFR 1910.38, it covers how to report emergencies, how to evacuate, how to account for everyone, and who is responsible for each task.

A good EAP reduces confusion in the first critical minutes of an emergency. It also helps employers meet OSHA requirements that appear in several other standards, from fire extinguishers to process safety.

What Is an Emergency Action Plan (EAP)?

OSHA's emergency action plan standard, 29 CFR 1910.38, states that an employer must have an emergency action plan whenever an OSHA standard in Part 1910 requires one. The plan must be in writing, kept in the workplace and available for employees to review. An employer with 10 or fewer employees may communicate the plan orally instead of in writing.

In practice, an EAP is the organization's playbook for events that threaten people on site. It is different from a business continuity plan, which focuses on restoring operations, and from a fire prevention plan (29 CFR 1910.39), which focuses on preventing fires in the first place. Many sites keep all three together, but the EAP is the part that protects lives during the event.

When Is an EAP Required?

Section 1910.38 itself does not list every situation. Instead, other OSHA standards point to it. Common examples include:

• Portable fire extinguishers (1910.157): an employer that requires all employees to evacuate instead of fighting fires must have an EAP and a fire prevention plan.
• Process safety management (1910.119): covered processes require an emergency action plan for the entire plant.
• HAZWOPER (1910.120): employers whose employees will evacuate rather than respond to a hazardous substance release may use an EAP that meets 1910.38.
• Specific chemical and industry standards: several substance-specific and industry standards, such as grain handling, also call for one.

Even where no standard strictly requires it, OSHA recommends that every employer plan for emergencies. Construction employers have a parallel requirement at 29 CFR 1926.35.

Key Requirements of an EAP

Minimum elements

Under 1910.38(c), an emergency action plan must include at least:

• Procedures for reporting a fire or other emergency.
• Procedures for emergency evacuation, including the type of evacuation and exit route assignments.
• Procedures for employees who remain to operate critical plant operations before they evacuate.
• Procedures to account for all employees after evacuation.
• Procedures for employees performing rescue or medical duties.
• The name or job title of every employee who may be contacted for more information about the plan or an explanation of their duties.

Alarm system

The employer must have and maintain an employee alarm system that uses a distinctive signal for each purpose and complies with 29 CFR 1910.165. Employees should be able to tell an evacuation alarm from a shelter-in-place signal.

Training and review

The employer must designate and train employees to assist in a safe and orderly evacuation of other employees. The plan must also be reviewed with each employee covered by it when the plan is developed or the employee is assigned to the job, when the employee's responsibilities under the plan change, and whenever the plan is changed.

What to Include Beyond the Minimum

The regulatory list is a floor. OSHA's Evacuation Plans and Procedures eTool offers guidance on building a plan that works in real conditions. Common additions include:

• Site-specific hazards: fire, chemical spills, gas leaks, severe weather, earthquakes, workplace violence and medical emergencies relevant to your location.
• Evacuation maps: floor plans showing exits, primary and secondary routes, assembly areas and the locations of extinguishers and first aid supplies.
• Shelter-in-place procedures: where to go and what to do when leaving the building is more dangerous than staying, such as during a tornado or an outdoor chemical release.
• Assistance for people with disabilities: a plan for employees and visitors who need help evacuating.
• Contact lists: internal responders, local fire and emergency medical services, utilities and key contractors.
• Medical response: how employees get first aid and how emergency medical services will be called and met.

How to Create an Emergency Action Plan: Step by Step

1. Identify credible emergencies. Review your processes, chemicals, building and location. A job hazard review or risk assessment helps you decide which scenarios to plan for.
2. Coordinate with local responders. Find out how the fire department and emergency medical services will respond, how long it may take, and what information they need on arrival.
3. Define roles. Name or assign by job title the people who will call for help, shut down critical equipment, sweep areas, account for employees and perform rescue or medical duties.
4. Map routes and assembly areas. Choose primary and secondary exits for each area and assembly points far enough from the building to be safe.
5. Write the plan. Keep it short and readable. Use checklists and maps rather than long paragraphs, and translate it if your workforce needs that.
6. Set up alarms and communications. Confirm the alarm can be heard or seen in all areas and that each signal has a single meaning.
7. Train everyone. Cover the plan when employees start, when duties change and when the plan changes. A short toolbox talk is a practical way to refresh key points.
8. Drill and improve. Run drills, time them, record what went wrong and update the plan.

Examples of EAP Scenarios

• Warehouse fire: employees hear the evacuation alarm, leave by the nearest marked exit, and report to their supervisor at the assembly point, who confirms everyone is accounted for.
• Ammonia leak at a food plant: trained operators shut down the system from a safe location, everyone else moves upwind to a designated assembly area, and the site contact meets the responding hazmat team.
• Tornado warning at an office: employees go to interior, windowless rooms on the lowest floor, and floor wardens check restrooms and conference rooms.
• Cardiac arrest on a production line: a coworker calls the designated emergency number, a trained responder starts CPR and retrieves the AED, and someone meets the ambulance at the gate.

Common Mistakes to Avoid

• A generic template. A plan downloaded and never tailored to your site will not match your exits, hazards or people.
• No accountability method. Without a reliable headcount, responders may enter a burning building to search for someone who is already safe.
• Outdated contacts. Names and phone numbers change. Assign an owner to review the plan on a set schedule.
• No drills. A plan that is only read, never practiced, often fails under stress.
• Ignoring visitors and contractors. People unfamiliar with the site need to know the alarm, routes and assembly areas too.

How SMS360 Helps

The SMS360 Document Library gives you a central place to store the current version of your emergency action plan, evacuation maps and contact lists. Employees can access the latest approved version from any device, including mobile, and administrators can manage revisions and set review reminders so the plan does not go out of date. Keeping one controlled copy makes it easier to show employees and inspectors what the plan says and when it was last reviewed.

Frequently Asked Questions

Do small businesses need a written emergency action plan?

If an OSHA standard requires an EAP, the plan must be written when the employer has more than 10 employees. Employers with 10 or fewer employees may communicate the plan orally. Either way, the plan must still cover the minimum elements in 29 CFR 1910.38(c), and employees must know their roles.

How often should an emergency action plan be reviewed?

OSHA requires the employer to review the plan with each covered employee when the plan is developed or the employee is assigned, when their responsibilities change, and when the plan changes. OSHA does not set a calendar interval, but many organizations review the plan at least once a year and after any drill or real event.

What is the difference between an EAP and an emergency response plan?

An EAP mainly covers how employees report an emergency, evacuate or shelter, and get accounted for. An emergency response plan, as used under HAZWOPER, applies when employees will actively respond to and control a hazardous substance release. Employers that evacuate and call outside responders generally use an EAP instead.

Is OSHA required to approve my emergency action plan?

No. OSHA does not review or approve EAPs in advance. Employers are responsible for writing a plan that meets 29 CFR 1910.38, training employees on it and keeping it current. During an inspection, OSHA may ask to see the plan and talk with employees about what they would do in an emergency.