OSHA's Emergency Action Plan standard (29 CFR 1910.38) requires employers to have a written plan that describes the actions employees should take during workplace emergencies. While fire drills test the execution of emergency procedures, a program audit evaluates whether your overall emergency action plan is comprehensive, current, and properly communicated. The EAP must address reporting emergencies, evacuation procedures, accounting for employees after evacuation, rescue and medical duties, and the alarm system. Regular program audits ensure your plan reflects current facility conditions, staffing, and hazards.
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Download Checklist (.docx)Regulatory Requirements
OSHA 29 CFR 1910.38 — Emergency Action Plans
The standard requires a written emergency action plan (EAP) that includes procedures for reporting emergencies, employee evacuation, accounting for all employees after evacuation, rescue and medical duties for designated employees, and the preferred means of reporting emergencies. The plan must include the names or job titles of people to contact for additional information. Plans with 10 or fewer employees may be communicated orally.
OSHA 29 CFR 1910.39 — Fire Prevention Plans
When required by an OSHA standard, fire prevention plans complement the EAP by addressing workplace fire hazards, proper handling and storage of flammable materials, potential ignition sources, fire protection equipment, and housekeeping procedures. The fire prevention plan should be coordinated with the EAP.
Additional OSHA Standards Requiring EAPs
Several OSHA standards specifically require an EAP, including process safety management (1910.119), fixed extinguishing systems (1910.160), grain handling (1910.272), ethylene oxide (1910.1047), and methylenedianiline (1910.1050). If any of these standards apply to your workplace, an EAP is mandatory regardless of employer size.
Written Plan Documentation
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Written EAP | A written emergency action plan exists and is current. The plan is available to all employees. For employers with 10 or fewer employees, the plan may be communicated orally, but documentation is still recommended as best practice. |
| Emergency reporting | The plan describes the preferred means of reporting fires and other emergencies. Emergency phone numbers (911, internal emergency line, poison control) are posted and current. Reporting procedures are clear and practiced. |
| Emergency types covered | The plan addresses all potential emergencies for the workplace including fire, chemical release, severe weather, medical emergency, bomb threat, active threat, utility failure, and natural disasters applicable to the geographic area. |
| Plan review date | The plan has been reviewed and updated within the last 12 months. Review date is documented. All changes to the facility, staffing, or hazards are reflected in the current plan. |
Evacuation Procedures
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Evacuation routes and maps | Evacuation routes are clearly identified in the plan and posted throughout the workplace. Maps show primary and alternate routes from all areas. Routes account for employees with disabilities. Routes are unobstructed and properly illuminated. |
| Assembly areas | Designated assembly areas are identified and communicated to all employees. Assembly areas are at a safe distance from the building and do not interfere with emergency responder access. Alternate assembly areas are designated in case primary areas are compromised. |
| Employee accountability | Procedures exist for accounting for all employees after an evacuation. A head count, roster check, or badge system is used. Designated employees are responsible for accountability in each work area. Procedures account for visitors and contractors. |
| Shelter-in-place procedures | Procedures exist for emergencies requiring shelter-in-place (chemical release, severe weather, active threat). Designated shelter areas are identified. Supplies for shelter-in-place are available where needed. |
Emergency Roles and Communication
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Alarm system | An employee alarm system meets requirements of 1910.165. The alarm produces a distinctive and recognizable signal. The alarm is audible (or visible in high-noise areas) throughout the workplace. The alarm is tested regularly and maintained. |
| Emergency coordinators | Emergency coordinators or floor wardens are designated for each work area. Names, titles, and contact information are current. Backup coordinators are designated. Coordinators are trained on their responsibilities. |
| Rescue and medical duties | Employees designated to perform rescue or medical duties are identified in the plan. These employees have received appropriate training (CPR, first aid, AED). Rescue duties are limited to employees who are specifically trained and equipped. |
| External coordination | Contact information for local fire department, police, hospital, and hazmat team is current. Facility access information is provided to emergency responders. Pre-incident plans are shared with local responders. |
Training and Drills
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Initial training | All employees receive EAP training when first assigned to the workplace. Training covers reporting procedures, evacuation routes, assembly areas, alarm recognition, and individual roles. Training is provided before employees are exposed to emergency situations. |
| Plan change training | Employees receive additional training when the EAP is changed, their responsibilities change, or they are assigned to a new area. Training covers the specific changes that affect the employee. Documentation of training is maintained. |
| Evacuation drills | Evacuation drills are conducted at least annually (more frequently is recommended). Drills test different emergency scenarios. Drill results are documented including evacuation time, participation, and issues identified. After-action reviews are conducted. |
| Training documentation | Training records document employee name, date, topics covered, and type of training (initial, update, drill participation). Records are retained and accessible. Training gaps are identified and addressed. |
Corrective Actions
Common Issues and Responses
- Outdated plan: Conduct an immediate plan review and update. Verify all emergency contacts, evacuation routes, assembly areas, and designated roles are current. Redistribute the updated plan and conduct training on changes.
- Missing alarm testing: Test all alarm system components immediately. Establish a regular testing schedule per 1910.165. Document all test results. Repair or replace any deficient components.
- No accountability procedures: Develop and implement an employee accountability system. Assign area wardens responsible for headcounts. Create employee rosters for each work area. Practice accountability procedures during drills.
- Untrained coordinators: Schedule training for all emergency coordinators and floor wardens. Training should cover their specific responsibilities, communication procedures, and decision-making authority. Conduct tabletop exercises.
- No evacuation drills: Schedule an evacuation drill immediately. Plan drills for different shifts, times, and scenarios. Document drill results and conduct after-action reviews. Implement lessons learned before the next drill.
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Emergency Planning
Digital emergency action plans with automated review scheduling and version control.
Training
Track emergency training, drill participation, and coordinator certifications.
Inspections
Alarm system testing, exit route inspections, and emergency equipment checks.
Compliance Calendar
Schedule drills, plan reviews, alarm testing, and training deadlines.
Document Management
Centralized storage for emergency plans, drill reports, and training records.
Incident Management
Document emergency events, response actions, and after-action reviews.
