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Compliance advice for emergency action plans

September 6, 2002
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OSHA has issued a new compliance directive to inspectors that consolidates the agency's Emergency Action Plan (EAP) and Fire Prevention Plan (FPP) (29 CFR 1910.38) into one compliance policy. Details can be found on OSHA's Web site, www.osha.gov.

Here are excerpts that you might find valuable:

"The purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. An EAP is a written document that is required by a particular OSHA standard. The elements of the plan shall include but are not limited to:

1. Escape procedures and emergency escape route assignments.

2. Procedures to be followed by employees who remain to operate critical plant operations before they evacuate.

3. Procedures to account for all employees after emergency evacuation has been completed.

4. Rescue and medical duties for those employees who are to perform them.

5. Means of reporting fires and other emergencies.

6. Names or job titles of persons who can be contacted for further information or explanation of duties under the plan.

"An FPP is a hazard prevention plan that is to assure advanced planning for evacuations in fire and other emergencies. An FPP is a written document that is required by a particular OSHA standard. The elements of the plan shall include but are not limited to:

1. A list of major workplace fire hazards and their proper handling and storage procedures, potential ignition sources, their control procedures and the type of fire protection equipment or systems which can control a fire.

2. Names or job titles of those persons responsible for maintenance of equipment and systems installed to prevent or control ignition of fires.

3. Names or job titles of those persons responsible for control of fuel source hazards.

Standards that require EAPs include:

1. Process Safety Management of Highly Hazardous Chemicals - 1910.119

2. Fixed Extinguishing Systems, General - 1910.160

3. Fire Detection Systems, 1910.164

4. Grain Handling - 1910.272

5. Ethylene Oxide - 1910.1047

6. Methylenedianiline - 1910.1050

7. 1,3-Butadiene - 1910.1051

Standards that require FPPs include:

8. Ethylene Oxide, 1910.1047

9. Methylenedianiline - 1910.1050

10. 1,3-Butadiene - 1910.1051

"The 1910.38 provisions are applicable and may be referenced only when another OSHA standard requires an EAP or FPP. The above standards require an EAP or an FPP. Therefore, 1910.38 citations may be used in the abatement or variable language only when one of the above standards is cited."

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