Emergency action plans: Not usually required, but...
Some terrible things occurred during the course of three short days last month. First of all, a couple of troubled young brothers decided to explode two homemade bombs near the finish line at the Boston Marathon, killing three people and critically injuring more than 100 others. Then two days later, there was a tremendous explosion at a fertilizer plant located in the small town of West, TX, injuring more than 250 people and killing at least 15 people, many of them first responders. And right in the middle of all this, I get the following text message from my youngest daughter:
“ Daddy. The school is on lock down. I’m okay. We have the door blocked. I love you so much.”
While the explosions that occurred in Boston and West were horrific, it was that cryptic text message from my baby girl that really got to me. I felt so helpless, especially since I was stranded in the airport in Atlanta GA because the airline (which will remAAin unnAAmed) that I was supposed to be flying home on that afternoon was grounded due to a massive computer outage. But thankfully, the situation that resulted in the school lockdown (an armed criminal fleeing from police was hiding in the woods right next door to the college) was resolved in about an hour, and no one was hurt.
All of these events got me to thinking hard about how people prepare for emergencies, including those at work. And I’m not just talking about fires and explosions, but all types of emergencies such as weather-related events, chemical spills, medical emergencies, earthquakes, domestic violence, and even major computer system outages. Many of you probably believe that OSHA requires every employer to develop an emergency action plan at every work site, but you may be surprised that is usually not the case!
If you refer to the OSHA standard on “Emergency Action Plans” (1910.38, paragraph (a)), you will see that it states; “An employer must have an emergency action plan whenever an OSHA standard in this part (1910) requires one.” And when you start doing some digging, you learn there only seven OSHA 1910 standards that actually contain a requirement for the development of an emergency action plan at a facility. These seven standards are:
o Process Safety Management of Highly Hazardous Chemicals - 1910.119
o Fixed Extinguishing Systems, General - 1910.160
o Fire Detection Systems, 1910.164
o Grain Handling - 1910.272
o Ethylene Oxide - 1910.1047
o Methylenedianiline - 1910.1050
o 1,3-Butadiene - 1910.1051
In addition to these seven standards, OSHA’s compliance directive titled “Compliance Policy for Emergency Action Plans and Fire Prevention Plans” (CPL 2-1.037) explains that OSHA also requires an employer to develop an emergency action plan if they choose to take advantage of one or more of the various exemptions for portable fire extinguisher distribution and use that appear in 1910.157(a) and (b). These exemptions are primarily related to when the employer institutes a formal policy (covered in their emergency action plan) that some or all employees immediately evacuate the area upon sounding of a fire alarm, as opposed to them using a portable fire extinguisher to fight the fire (see paragraph IX, B 1 -3 on page 6 of the directive for further guidance). One quick note about this directive; Appendix A of this CPL has an excellent flow chart that lays out the requirements for when an emergency action plan is required to be developed for a work-site.
So the real purpose of 1910.38 is not to require every employer to develop an emergency action plan; it is strictly to outline the mandatory elements of an employer’s emergency action plan IF one is required to be developed for their business by any one of the standards that is listed above. But that leaves a whole lot of potential emergencies at a whole lot of businesses uncovered.
Even when an organization has an emergency action plan, that does not mean they are prepared to respond to an emergency.
Or, said another way; it does no good to develop an emergency action plan if no one is trained on what to do in case the expected emergency strikes.
For example, the college where my daughter was in class when the lockdown occurred has digital message boards mounted in each classroom that flashed an announcement that the school was undergoing a lockdown, and each faculty member and student also got a text message and/or email that announced the emergency. Yet many of the professors (and students) had no clue of what to do once they learned of the lock down.
Fortunately, some of the better thinking individuals (like my daughter) thought to lock their classroom door, block it with furniture, turn off the lights, and sit along a wall out of view of the door and windows (my daughter actually saw a similar scenario occur on an episode of the television show “Glee” the week before, said that is how she knew what to do). However, some of her friends at the school told her later that their professors told everyone to run to their cars and drive away when the alert went out, which potentially exposed them to the shooter located just outside.
Unbelievable!
So what is the purpose of my rant?
I guess to blow off some steam that built up inside during that one very hectic week last month. But also to get you to think about this topic right now. Depending on your situation, it might be good idea to sit down with a group of your employees or co-workers and brainstorm to come up with a list of expected emergencies that could affect your business and address those in an emergency action plan.
By the way, the OSHA website does have an “Emergency Plans and Procedures” e-tool available to assist you with writing a basic emergency action plan if you are required to do so by one or more of these standards, you might find this useful.
And even if you already have an emergency action plan in place, it may need to be updated to reflect new hazards that you might have never dreamed of just a few years ago.
While you are at it, I encourage do the same thing with your family members; depending on what you do for a living, the odds of an emergency occurring at your home, your kid’s school, or even someplace else (like a marathon) are probably just as great as they are in the workplace.
Once you identify potential emergencies in the brainstorming session, you need to come up with a clear and concise response to each type of emergency you identify, and make certain everyone affected is aware of how to respond to each type emergency.
The time to decide what to do when the emergency hits is NOT when the emergency hits, but well beforehand. We may not be able to prevent every conceivable emergency from striking, but with proper planning and practice we can be better prepared to respond in the best possible way.
Do you have an emergency action plan in place at your business; or at home? What is the scope of your emergency action plan - is it singularly focused or comprehensive? If you do have an emergency action plan, does it need to be updated to address additional hazards? These are just a few things I’d like to encourage you to think about.
