When a process incident occurs, the difference between a controlled response and a catastrophe depends on planning, preparation, and practice. Under 29 CFR 1910.119(n), employers must establish and implement an emergency action plan for the entire plant. The plan must include procedures for handling small releases and comply with OSHA's emergency action plan requirements under 29 CFR 1910.38. Ecesis PSM software centralizes emergency planning documentation with mobile access for field personnel.
What OSHA Requires
Under 29 CFR 1910.119(n), the employer must:
- Establish and implement an emergency action plan for the entire plant in accordance with 29 CFR 1910.38
- Include procedures for handling small releases of hazardous chemicals
- Comply with 29 CFR 1910.120 (HAZWOPER) for employees involved in emergency response to releases of hazardous substances
Under 29 CFR 1910.38, the emergency action plan must include:
- Procedures for reporting a fire or other emergency
- Procedures for emergency evacuation, including 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
- Rescue and medical duties for designated employees
- Names or job titles of persons to contact for further information or explanation of duties
Step-by-Step Implementation
Develop Scenario-Based Emergency Procedures
Identify the specific emergency scenarios that could occur at your facility based on PHA results and the chemicals involved. For each scenario, develop specific response procedures:
- Chemical-specific releases: Toxic gas releases, flammable liquid spills, reactive chemical incidents for each covered chemical
- Fire and explosion scenarios: Process fires, vapor cloud explosions, BLEVE events
- Small releases: Minor leaks that can be controlled by trained operators without full emergency response activation
- Escalation criteria: Clear thresholds for when a small release escalates to a full emergency response
Include chemical-specific information such as wind direction considerations, shelter-in-place versus evacuation criteria, and PPE requirements for each scenario.
Establish Alarm Systems and Communication
Define and communicate alarm signals and notification procedures:
- Distinct alarm signals for different emergency types (evacuation, shelter-in-place, all-clear)
- Communication systems that function during emergencies (radios, PA systems, backup systems)
- Notification procedures for management, emergency responders, and regulatory agencies
- Emergency contact lists with 24/7 availability
Coordinate with Local Emergency Responders
Invite local fire departments and emergency response agencies to familiarize themselves with your facility:
- Provide information on chemicals present, quantities, and potential release scenarios
- Share facility maps showing access points, hydrant locations, and process areas
- Conduct joint drills to test coordination and communication
- Establish mutual aid agreements with neighboring facilities if applicable
Test and Improve Through Drills
Conduct regular emergency drills that go beyond simple evacuation exercises:
- Tabletop exercises for specific chemical release scenarios
- Functional drills testing alarm systems, communication, and assembly procedures
- Full-scale drills involving local emergency responders
- After-action reviews documenting lessons learned and improvement actions
Update the emergency plan based on drill findings, incident investigations, and process changes.
Common Pitfalls to Avoid
How Software Supports This Element
Ecesis PSM software centralizes your emergency planning program:
- Emergency planning: Store and manage all emergency procedures in a centralized system with version control and mobile access
- Mobile access: Field personnel access emergency procedures from anywhere, eliminating reliance on paper copies
- Training integration: Deliver and track emergency response training for all employees
- Drill documentation: Document drill results, after-action findings, and improvement actions with tracking to completion
Frequently Asked Questions
Do we need HAZWOPER-trained employees?
If your employees will respond to chemical releases beyond incidental spills, they must be trained under 29 CFR 1910.120 (HAZWOPER). Many PSM facilities designate employees as emergency responders for small releases while relying on professional hazmat teams for larger incidents.
What constitutes a small release under PSM?
OSHA does not define specific quantity thresholds for small releases. Generally, a small release is one that trained operators can safely control using available equipment without activating a full emergency response. Your plan should define these thresholds based on your specific chemicals and facilities.
How often should emergency drills be conducted?
While OSHA does not specify drill frequency in the PSM standard, best practice is to conduct at least one full-scale or functional drill annually for each major scenario type, with tabletop exercises quarterly. The emergency action plan under 1910.38 requires the plan to be reviewed with each employee when initially assigned and when duties change.
Does the emergency plan need to address off-site impacts?
OSHA PSM focuses on protecting workers, but if your facility is also subject to EPA RMP, off-site consequence analysis is required. Even under PSM alone, coordinating with local emergency responders and the community about potential impacts is considered best practice and may be required by state or local regulations.
How should emergency procedures be maintained?
Review and update emergency procedures whenever processes change (through MOC), after actual emergencies and drills (through after-action reviews), and at least annually as part of your overall PSM program review. Document each review with dates and reviewer names.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
Submit, route, and approve change requests through defined workflows
Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
