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What Does OSHA Require for an Emergency Action Plan?

When an emergency happens at work, there isn’t much time to figure out who should do what.

That is why an Emergency Action Plan (EAP) matters.

A good emergency action plan gives employees clear instructions for how to report an emergency, where to go, how to evacuate, and how everyone will be accounted for. It also identifies the people responsible for specific emergency duties.

But what does OSHA actually require?

The answer depends on the workplace and the OSHA standards that apply to it. Let’s break down the basics.

What Is an Emergency Action Plan?

An Emergency Action Plan is a workplace plan designed to organize employer and employee actions during an emergency.

OSHA describes an EAP as a way to facilitate and organize actions during workplace emergencies. OSHA also recommends emergency action planning for all employers, even though specific OSHA standards determine when an EAP is required.

For workplaces covered by OSHA’s Emergency Action Plan requirements, the plan addresses things such as emergency reporting, evacuation, employee accountability, rescue or medical duties, and employee training.

The goal isn’t to create a binder that nobody reads.

The goal is to make sure people know what to do before something goes wrong.

Does OSHA Require Every Business to Have an Emergency Action Plan?

Not necessarily.

Under 29 CFR 1910.38, an employer must have an Emergency Action Plan when another OSHA standard in Part 1910 requires one.

OSHA identifies several standards that can trigger EAP requirements, including requirements involving highly hazardous chemicals, certain fire protection systems, grain handling, and specific chemical exposures.

OSHA also has a specific Emergency Action Plan standard for construction under 29 CFR 1926.35.

Even when an EAP is not specifically required by an applicable OSHA standard, OSHA recommends emergency action planning as a best practice for employers.

Bottom line: Don’t assume that “OSHA doesn’t require an EAP for my business” means you shouldn’t have one.

What Must an OSHA Emergency Action Plan Include?

For workplaces subject to 29 CFR 1910.38, OSHA identifies six minimum elements.

1. Procedures for Reporting Emergencies

Employees need to know how to report a fire or other emergency.

That might include:

  • Calling 911
  • Activating an alarm
  • Notifying a supervisor
  • Using a radio or other communication system
  • Following a specific internal emergency notification procedure

The important thing is that employees aren’t left wondering who to call or how to sound the alarm.

2. Emergency Evacuation Procedures and Routes

Your plan needs to explain how employees will evacuate and where they should go.

This should include:

  • Emergency escape routes
  • Exit assignments
  • Types of evacuation
  • Assembly or meeting areas
  • Procedures for employees who may need additional assistance

Your workplace layout matters here.

An evacuation plan for a warehouse will not necessarily look like one for an office, manufacturing facility, or construction site.

OSHA specifically recommends that emergency planning take the actual workplace layout, structural features, emergency systems, and hazards into account.

3. Procedures for Critical Operations

Some employees may need to remain briefly to perform critical operations before evacuating.

If that applies to your workplace, the EAP should explain what those employees are expected to do before leaving.

This should not mean asking employees to take unnecessary risks.

The purpose is to clearly define responsibilities that must be handled before evacuation when appropriate.

4. Procedures for Accounting for Employees

Getting everyone out of the building is only part of the job.

You also need to know who made it out.

Your plan should explain how employees will be accounted for after an evacuation.

This could involve:

  • Designated assembly areas
  • Supervisors or department leads
  • Employee rosters
  • Visitor logs
  • Contractor lists
  • Procedures for reporting missing employees

This is especially important in workplaces where contractors, temporary workers, visitors, or multiple shifts are present.

5. Rescue and Medical Duties

If specific employees are expected to perform rescue or medical duties during an emergency, those responsibilities need to be addressed in the plan.

Don’t simply assume that someone will know what to do.

Identify the appropriate responsibilities and make sure the people assigned to them understand their roles and receive the necessary training.

6. Names or Job Titles of Responsible People

Employees need to know who they can contact for additional information about the emergency plan or their responsibilities.

Your plan should identify the names or job titles of the appropriate people.

Think beyond simply listing a company owner.

If the person responsible for emergency coordination is unavailable, employees need to know who fills that role.

What About Emergency Alarms?

OSHA’s general industry standard also addresses employee alarm systems.

Under 29 CFR 1910.38, employers must have and maintain an employee alarm system, and the system must use distinctive signals for its different purposes and comply with 29 CFR 1910.165.

The alarm needs to be something employees can recognize and understand.

For example, employees should know the difference between an evacuation alarm and another type of workplace notification when different signals are used.

Construction has its own requirements under 29 CFR 1926.35, including an employee alarm system that complies with 29 CFR 1926.159.

Does OSHA Require Emergency Action Plan Training?

Yes, training is an important part of the requirements.

For general industry, employers must designate and train employees who will assist with a safe and orderly evacuation.

The emergency action plan must also be reviewed with covered employees:

  • When the plan is developed or when an employee is initially assigned to a job
  • When the employee’s responsibilities under the plan change
  • When the plan itself changes

For construction, OSHA similarly requires employers to designate and train enough people to assist with safe and orderly evacuation and to review the plan with employees at the required times.

A plan that employees have never seen isn’t much of a plan.

Does the Emergency Action Plan Have to Be Written?

For general industry, an EAP required under 29 CFR 1910.38 must generally be written, kept in the workplace, and made available for employees to review.

There is an exception for employers with 10 or fewer employees, who may communicate the plan orally.

Construction has a similar exception under 29 CFR 1926.35.

That small-business exception doesn’t mean planning isn’t important.

In fact, a smaller workplace may have fewer people available to respond during an emergency, making clear responsibilities even more important.

What About Construction Sites?

Construction deserves special attention because the workplace can change constantly.

A construction site’s:

  • Access points
  • Exit routes
  • Equipment
  • Crew
  • Hazards
  • Work areas
  • Emergency assembly locations

can change from one phase of a project to the next.

OSHA’s construction standard, 29 CFR 1926.35, requires an emergency action plan for applicable workplaces and addresses escape procedures, accounting for employees, rescue and medical duties, emergency reporting, alarm systems, evacuation, and training.

OSHA also notes that construction emergency plans may need to be modified as site conditions change.

That means an emergency plan created at the beginning of a project shouldn’t automatically be considered finished for the duration of the job.

What OSHA Requires vs. What Makes a Good Plan

There is an important distinction here.

OSHA’s minimum requirements give employers a foundation.

A good emergency action plan goes further by addressing the hazards employees are actually likely to encounter.

Depending on the workplace, that could include:

  • Severe weather
  • Fire
  • Chemical spills
  • Hazardous material releases
  • Power outages
  • Workplace violence
  • Medical emergencies
  • Equipment incidents
  • Natural disasters
  • Flooding
  • Tornadoes
  • Earthquakes
  • Other site-specific emergencies

OSHA’s guidance recommends considering the emergencies that could reasonably be expected at the particular workplace.

Your plan should reflect your workplace—not somebody else’s.

A Quick Emergency Action Plan Check

Take a few minutes and ask:

☐ Does everyone know how to report an emergency?

☐ Are emergency exits and escape routes clearly identified?

☐ Does everyone know where to assemble?

☐ Do you have a reliable way to account for employees?

☐ Are visitors and contractors included?

☐ Are emergency responsibilities assigned?

☐ Have designated employees received appropriate training?

☐ Do employees know what the alarm signals mean?

☐ Has the plan been reviewed when responsibilities or conditions change?

☐ Does the plan address the actual hazards at your workplace?

If you answered “I’m not sure” to several of these, that’s a pretty good indication that your emergency plan deserves another look.

Preparedness Is More Than Having a Plan

An Emergency Action Plan is important, but preparedness doesn’t stop with the document.

Employees need to understand their responsibilities. Emergency supplies need to be available. Routes need to remain accessible. Equipment needs to be inspected and maintained. And the plan needs to change when the workplace changes.

That is why emergency preparedness should be treated as an ongoing process—not an annual paperwork exercise.

During National Preparedness Month, it’s a good time to take a fresh look at your workplace emergency plan and ask a simple question:

If something happened today, would your team know exactly what to do?

If you’re not sure, start with our guide to 10 Workplace Emergency Preparedness Mistakes That Could Leave Your Team Unprepared.

And for a broader look at workplace preparedness, visit our National Preparedness Month: A Complete Guide to Workplace Emergency Preparedness.

Important Note

This article is provided for general educational purposes and is not legal advice or a substitute for reviewing the OSHA standards applicable to your specific workplace. Employers should consult the applicable OSHA regulations and qualified safety professionals when developing or evaluating an Emergency Action Plan.

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