Emergency Planning Safety Guide
Workplace Emergency Planning: OSHA Requirements & Best Practices
A comprehensive guide to OSHA emergency action plan requirements for New Jersey employers — covering plan development, evacuation procedures, shelter-in-place, employee roles, drills, and coordination with first responders.
Every workplace faces the potential for emergencies — fires, chemical releases, severe weather, medical crises, active threats, and power failures. OSHA's Emergency Action Plan standard (29 CFR 1910.38) requires most employers to have a written emergency action plan, and the Process Safety Management and HAZWOPER standards impose additional emergency planning requirements for facilities with hazardous chemicals. But compliance is only the floor. The gap between a plan that satisfies an OSHA inspector and a plan that actually saves lives during a real emergency is where most organizations fall short. This guide covers what OSHA requires, how to build a plan that works under pressure, and how to train your workforce so that when an emergency happens, everyone knows exactly what to do.
OSHA Emergency Action Plan Requirements
OSHA's Emergency Action Plan (EAP) standard (29 CFR 1910.38) requires employers with more than 10 employees to maintain a written EAP. Employers with 10 or fewer employees may communicate the plan orally. The EAP must cover procedures for reporting fires and other emergencies, evacuation procedures and exit route assignments, procedures for employees who remain to perform critical operations before evacuating, procedures to account for all employees after evacuation, rescue and medical duties for designated employees, and the names or job titles of persons who can be contacted for further information. The plan must be kept at the workplace and available for employee review. Employers must review the plan with each employee when it is developed, when the employee is assigned initially, and when the employee's responsibilities change.
Key Action Items
- Develop a written Emergency Action Plan if you have more than 10 employees — oral communication is only permitted for smaller workplaces
- Cover all required elements: emergency reporting, evacuation procedures, exit assignments, critical-operations procedures, accountability, and rescue duties
- Designate and train employees with specific emergency roles — evacuation wardens, accountability coordinators, and first-aid responders
- Keep the written EAP at the workplace and make it available to all employees for review at any time
- Review the EAP with every employee at hire, when their responsibilities change, and whenever the plan is updated
- Update the EAP whenever the facility layout, occupancy, processes, or emergency contacts change — a stale plan is a dangerous plan
Evacuation Procedures & Exit Routes
A well-designed evacuation procedure is the backbone of any emergency action plan. OSHA's Exit Routes standard (29 CFR 1910.34–37) requires that exit routes be permanent, separated from other areas by fire-resistant materials, adequate in number and capacity for the occupant load, and clearly marked with illuminated exit signs. Every facility must have at least two exit routes to permit prompt evacuation. Evacuation procedures must designate primary and secondary exit routes for each area, identify assembly points outside the building, assign evacuation wardens to assist employees and confirm that all personnel have evacuated, and establish a headcount procedure to account for every person — including visitors and contractors — after evacuation.
Key Action Items
- Designate primary and secondary exit routes for every area of the facility — never rely on a single exit path
- Post evacuation maps at eye level near every exit and in common areas — maps must show the current location and the nearest exits
- Assign evacuation wardens at a ratio of one warden per 20 employees — wardens sweep their area and confirm all personnel have exited
- Designate assembly points at a safe distance from the building — far enough to avoid interfering with emergency responders
- Establish a headcount procedure that accounts for employees, visitors, and contractors — maintain a current visitor log at all times
- Keep exit routes clear at all times — blocked exits are one of OSHA's most-cited violations and a leading cause of evacuation fatalities
Shelter-in-Place Procedures
Some emergencies — chemical releases, severe weather, or active threats — require employees to shelter in place rather than evacuate. Shelter-in-place procedures must identify which emergencies require sheltering, designate shelter areas appropriate to the hazard type (interior rooms away from windows for severe weather; rooms that can be sealed for chemical releases), and establish a communication protocol to notify employees when to shelter and when it is safe to leave. Employees must know the difference between a shelter-in-place order and an evacuation order, and the plan must address employees with disabilities who may need assistance reaching the shelter area. Shelter areas should be stocked with emergency supplies including water, first aid materials, a battery-powered radio, and a list of emergency contacts.
Key Action Items
- Identify which emergency types require shelter-in-place versus evacuation — and train employees to recognize the difference
- Designate shelter areas appropriate to each hazard: interior rooms for severe weather, sealable rooms for chemical releases, secure areas for active threats
- Stock shelter areas with emergency supplies: water (1 gallon per person per day), first aid kit, battery-powered radio, flashlights, and emergency contact list
- Establish a clear communication protocol for issuing shelter-in-place orders — use multiple channels (PA, text alert, email) to ensure all employees receive the notification
- Develop procedures for employees with disabilities or mobility limitations who may need assistance reaching the shelter area
- Identify how to seal a room for chemical release sheltering: plastic sheeting, duct tape, and wet towels at door gaps can significantly reduce chemical infiltration
Employee Roles & Responsibilities
A successful emergency response depends on every employee knowing their role before an emergency occurs. The EAP must identify employees with specific emergency duties — evacuation wardens, first-aid responders, fire extinguisher operators, utility shutoff personnel, and the emergency coordinator who manages the overall response. Employees who are assigned emergency duties must receive training specific to those duties before they are expected to perform them. Employees who are not assigned specific duties must know how to report emergencies, how to evacuate, where to assemble, and how to account for themselves. Special consideration must be given to employees who work alone, employees on night shifts, and employees with disabilities who may need evacuation assistance.
Key Action Items
- Designate an Emergency Coordinator — one person responsible for managing the overall emergency response and communicating with first responders
- Assign and train evacuation wardens, first-aid responders, and utility shutoff personnel before an emergency occurs
- Develop Personal Emergency Evacuation Plans (PEEPs) for employees with disabilities — identify who will assist them and how
- Ensure employees who work alone or on off-shifts know how to report emergencies and are included in all emergency communications
- Cross-train backup personnel for every critical emergency role — key people are not always present when an emergency occurs
- Post the names and contact information for the Emergency Coordinator and all emergency role holders in visible locations throughout the facility
Emergency Drills & Training
An emergency plan that has never been practiced is an emergency plan that will fail when it matters most. OSHA requires that employees be trained on the EAP, but does not specify a minimum drill frequency for most industries — however, best practice and many state and local codes require at least annual evacuation drills. Drills should be conducted at different times of day and under different conditions to test the plan's robustness. After every drill, conduct a formal debrief to identify what worked, what didn't, and what needs to be updated in the plan. Tabletop exercises — where the emergency coordinator and key personnel walk through a simulated emergency scenario — are a cost-effective way to test decision-making and communication without disrupting operations.
Key Action Items
- Conduct evacuation drills at least annually — more frequently for high-hazard facilities or when the workforce or facility layout changes significantly
- Vary drill timing and scenarios — conduct drills at different times of day, with different emergency types, and with some exits blocked to simulate real conditions
- Time every drill from alarm to full assembly and headcount — track improvement over time and set a target evacuation time for your facility
- Conduct a formal debrief after every drill — document what worked, what failed, and what changes will be made to the plan or training
- Run tabletop exercises with the Emergency Coordinator and key personnel at least annually — walk through realistic scenarios to test decision-making and communication
- Document all drills and training with date, scenario, participants, timing results, debrief findings, and corrective actions taken
Coordinating with First Responders
Effective emergency response requires coordination between your internal emergency team and external first responders — fire departments, EMS, hazmat teams, and law enforcement. Before an emergency occurs, invite your local fire department to conduct a pre-incident planning visit to familiarize themselves with your facility layout, hazardous materials, utility shutoffs, and access points. Provide first responders with a facility map, a chemical inventory, and emergency contact information. During an emergency, designate one person — the Emergency Coordinator — to meet first responders at the facility entrance, brief them on the situation, and serve as the single point of contact. After an emergency, participate in the post-incident review and share your internal debrief findings with first responders to improve future coordination.
Key Action Items
- Invite your local fire department for a pre-incident planning visit — walk them through your facility, hazardous materials locations, and utility shutoffs
- Provide first responders with an up-to-date facility map, chemical inventory (with SDS), and 24-hour emergency contact list
- Designate the Emergency Coordinator as the single point of contact for first responders — brief them at the entrance with a clear, concise situation report
- Post the facility address, nearest cross street, and gate access codes at every phone and in the EAP — seconds matter when calling 911
- Notify the local fire department and LEPC (Local Emergency Planning Committee) of any significant changes to your chemical inventory or facility layout
- Participate in community emergency planning through your Local Emergency Planning Committee (LEPC) — required for facilities subject to EPCRA Title III
Preparedness Saves Lives — Start Before an Emergency Happens
Does Your Team Know What to Do When It Matters Most?
A binder on a shelf won't save lives. Contact us for a free needs analysis and let's build an emergency planning and response program that your workforce can actually execute under pressure.