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Emergency Action Plans

The Occupational Safety and Health Administration (OSHA) requires

companies to develop emergency action plans when a specific OSHA

standard requires their development using the guidelines found in 29 CFR

1926.35. Standards that include references to emergency action plans

include 29 CFR 1926.64 relating to highly hazardous chemical storage,

manufacturing, handling or movement of toxic, reactive, flammable or

explosive chemicals and Hazardous Waste Operations and Emergency

Response (HAZWOPER) requirements under 29 CFR 1926.65—operations

involving cleanup, emergency response and corrective actions involving

hazardous wastes.

According to the standard, if a company employs fewer than 11 people, the

program does not have to be in written form; however, many general

contractors and building owners require a written emergency action plan,

regardless of company size or applicability of OSHA standards.

This chapter outlines what is required by the OSHA standard, including the

elements of an emergency action plan and training requirements. The end of

this chapter contains a sample plan that can be used to help shape a

company’s individual plan.

Action Plan Elements

OSHA requires that the information listed below be included in an action

plan. Some of the elements can be generic while others need to be site-

specific. The italicized portions describe the issues a contractor needs to

consider when developing the action plan.

 Emergency evacuation plans, which include escape procedures and

escape route assignments. This needs to be addressed on a project-

by-project basis because there can be no generic plan for escape

routes with the variety of roofing locations and layouts. For example,

an emergency evacuation plan for a high-rise office building will differ

greatly from one for a residential dwelling.

 Procedures to be followed by employees who remain to operate

critical plant operations before evacuation. This procedure is intended

to shut down critical operations that may make a situation even more

hazardous. This may be a consideration for hot bitumen or similar

applications because propane tanks are involved. There may be a

need to shut down propane tanks at the cylinder before evacuating

the site. Electrical tools can ignite a fire if a fuel, such as gasoline, is

spilled. Again, this will need to be addressed on a project-by-project

basis.

Emergency Action Plans