Emergency Action Plans

If a facility has taken a non-responder approach to emergencies, at a minimum they must have an Emergency Action Plan (EAP), as required by 19 CCR Title 8, Section 3220 and 29 CFR 1910.38.  The objectives of the EAP are to identify “designated actions employers and employees must take to ensure employee safety from fire and other emergencies.”
Specific requirements include:

  • “Emergency escape procedures and emergency escape route assignments” (e.g., upwind and uphill)
  • “Procedures to be followed by employees who remain to operate critical plant operations before they evacuate”
  • “Procedures to account for all employees after emergency evacuation has been completed”
  • “Rescue and medical duties for those employees who are to perform them” – Must have proper training and PPE – Must not become part of the problem
  • “The preferred means of reporting fires and other emergencies” – In plant and to local authority having jurisdiction
  • Legal requirements for reporting to the authority having jurisdiction
  • “Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan”
  • Establishment of an "employee alarm system"
  • Evacuation - “The employer shall establish in the emergency action plan the types of evacuation to be used in emergency circumstances.” – Employees should be trained to evacuate upwind and uphill.
  • Training – “The employer shall review with each employee upon initial assignment those parts of the plan which the employee must know to protect the employee in the event of an emergency.

           - “Initially when the plan is developed”
           - “Whenever the employee's responsibilities or designated            actionsunder the plan change”
           - “Whenever the plan is changed”