Emergency Action Plans

In March of 2018, two construction workers were killed in a fire that destroyed a 5-story apartment building under construction in downtown Denver. One of the key findings was that no Emergency Action Plan (EAP) had been developed for the project, nor had any of the subcontractors developed one for their own employees either.

Fast forward to last week. My son, and business partner here at Corporate Safety Services, had parked and was walking up to another large apartment building under construction to conduct a safety audit. He heard people yelling and then saw smoke coming out of a 3rd floor window. He watched as several construction workers grabbed a hose attached to a fire hydrant and started dragging it up the stairs toward the 3rd floor.

My son asked one of the foremen if it was wise for the workers to go into the building. The foreman’s response was, “I think that’s what we’re supposed to do.”  After watching for a few minutes, my son realized that he had not yet heard a siren indicating a response by the fire department. About that time, one of the workers who had pulled the hose inside exited the building and walked up to my son. He turned out to be the general contractor’s superintendent. He said, “They told me you were a safety guy. Do you think I should call the fire department?”  After getting over his initial surprise, my son told him that 911 should have been called immediately upon someone discovering the fire.

The Denver Fire Department arrived about 10 minutes later, and the Fire Captain was livid that 911 wasn’t called until almost 25 minutes after the fire was discovered. The fire was put out without any injuries, but this is exactly how we get workers killed on the job. No one on this project knew anything about the Emergency Action Plan or what to do in an actual emergency.

So, what does OSHA say about Emergency Action Plans?

29 CFR 1926.35 - The emergency action plan shall be in writing and shall cover those designated actions employers and employees must take to ensure employee safety from fire and other emergencies. The following elements, at a minimum, shall be included in the plan:

1. Emergency 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. The preferred means of reporting fires and other emergencies; and
6. Names or regular job titles of persons or departments who can be contacted.
7. The employer shall establish an employee alarm system.

If your emergency action plan, and you need one for each project you’re working on, doesn’t contain all these items in writing, then you’re not prepared for a workplace emergency. How about employee training? OSHA is very specific in that area as well:

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. The written plan shall be kept at the workplace and made available for employee review.

Regardless of whether it is an OSHA requirement or not, it is your responsibility as an employer to plan and train your employees on what they should do in a workplace emergency. OSHA even makes it easy for you to develop your EAP. At the OSHA website below you can simply answer some questions, and it will write one for you:

https://www.osha.gov/etools/evacuation-plans-procedures/eap/develop-implement/

I’ll leave you with a couple of questions:

• Shouldn’t this be the first toolbox/safety talk you have on a new project?
• Do you have an EAP for your office/shop/yard locations?