Industry Guide 40 A Guide to Emergency Action Planning N.C. Department of Labor Occupational Safety and Health Division N.C. Department of Labor 1101 Mail Service Center Raleigh, NC 27699-1101 Cherie Berry Commissioner of Labor N.C. Department of Labor Occupational Safety and Health Program Cherie Berry Commissioner of Labor OSHA State Plan Designee Kevin Beauregard Deputy Commissioner for Safety and Health Scott Mabry Assistant Deputy Commissioner for Safety and Health Kevin O’Barr Reviewer Acknowledgments A Guide to Emergency Action Planning was prepared for the N.C. Department of Labor by David L. Potts. Mr. Potts has written extensively about subjects regarding construction safety and coauthored other works for the North Carolina Department of Labor’s industry guide series. Additional information was provided by N.C. Department of Labor employee S.B. White. The information in this guide was reviewed in 2011. This guide is intended to be consistent with all existing OSHA standards; therefore, if an area is con- sidered by the reader to be inconsistent with a standard, then the OSHA standard must be followed. To obtain additional copies of this guide, or if you have questions about North Carolina occupational safety and health stan- dards or rules, please contact: N.C. Department of Labor Education, Training and Technical Assistance Bureau 1101 Mail Service Center Raleigh, NC 27699-1101 Phone: 919-707-7876 or 1-800-NC-LABOR (1-800-625-2267) ____________________ Additional sources of information are listed on the inside back cover of this guide. ____________________ The projected cost of the NCDOL OSH program for federal fiscal year 2015–2016 is $18,259,349. Federal funding pro vides approximately 29.2 percent ($5,326,000) of this fund. Reviewed 9/11 Copyright © 2015 by N.C. Department of Labor All photographs, graphics and illustrations are property of the N.C. Department of Labor or are used by permission/license of their respective copyright holders. Contents Part Page Foreword . .1iiv Introduction . .1iiv 1 Emergency Action Plan . .1ii1 2 Specific Standards and Their Requirements . .ii15 3 NCDOL’s Preparation and Readiness for Emergencies . .ii11 iii Foreword Planning to minimize all workplace hazards is not easy. All employers face the possibility of emergencies— workplace fires, hazardous chemical releases, floods and explosions. There are many other emergencies to which workers are sus- ceptible. Having an emergency action plan that addresses unforeseen disasters is one of the best ways an employer can protect the workplace from fatalities. A Guide to Emergency Action Planning can help employers plan for the emergen- cies their businesses are most likely to encounter. Having a plan can save lives when an emergency strikes. In North Carolina, the N.C. Department of Labor enforces the federal Occupational Safety and Health Act through a state plan approved by the U.S. Department of Labor. NCDOL offers many educational programs to the public and pro- duces publications to help inform people about their rights and responsibilities regarding occupational safety and health. When reading this guide, please remember the mission of the N.C. Department of Labor is greater than just regulatory enforcement. An equally important goal is to help citizens find ways to create safe workplaces. Everyone profits when managers and employees work together for safety. This booklet, like the other educational materials produced by the N.C. Department of Labor, can help Cherie Berry Commissioner of Labor iv Introduction Emergencies can come from many causes, including chemical, biological, bioterrorism, radiation, personal protective equipment, training and education, and equipment. Natural events such as tornadoes or hurricanes may also lead to emer- gency situations. What does your employer need to do to prepare? Does your employer have the framework to survive one of these emergencies? This guide aids employers by highlighting the requirements of many OSHA standards that require some action by employers based on or related to emergency planning and emergency situations. This guide focuses on general industry environments. Other industries such as shipyards, maritime, longshoring, construction and agriculture also have some requirements. Some of these requirements refer back to the general industry standards. Read the first section of this guide to determine if your employer must create an OSHA emergency action plan. The next section contains specific standards that require some action for employers within their scope. The last part of this guide explains how NCDOL is prepared for and will interact with other agencies during an emergency response. NCDOL has resources available to employers to assist them in their preparations. Publications, in addition to this one, can be found at www.nclabor.com/pubs.htm. v 1 Emergency Action Plan What Is an Emergency Action Plan? An emergency action plan (EAP) is a written document required by particular OSHA standards [29 CFR 1910.38(a)]. The purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. Well- developed emergency plans and proper employee training (such that employees understand their roles and responsibilities within the plan) will result in fewer and less severe employee injuries and less structural damage to the facility during emergencies. A poorly prepared plan will likely lead to a disorganized evacuation or emergency response, resulting in confusion, injury and property damage. The plan does not need to be written and may be communicated orally if there are 10 or fewer employees [29 CFR 1910.38(b)]. At a minimum, the plan must include but is not limited to the following elements [29 CFR 1910.38(c)]: l Means of reporting fires and other emergencies; l Evacuation procedures and emergency escape route assignments; l Procedures to be followed by employees who remain to operate critical plant operations before they evacuate; l Procedures to account for all employees after an emergency evacuation has been completed; l Rescue and medical duties for those employees who are to perform them; and l Names or job titles of persons who can be contacted for further information or explanation of duties under the plan. Although they are not specifically required by OSHA, you may find it helpful to include the following in your plan: l A description of the alarm system to be used to notify employees (including disabled employees) to evacuate or take other actions. The alarms used for different actions should be distinctive and might include horn blasts, sirens or public address systems. l The site of an alternative communications center to be used in the event of a fire or explosion. l A secure onsite or offsite location to store originals or duplicate copies of accounting records, legal documents, your employees' emergency contact lists, and other essential records. Clearly communicate to your employees who will be in charge during an emergency to minimize confusion. General training for your employees should also address the following: l Individual roles and responsibilities; l Threats, hazards, and protective actions; l Notification, warning, and communications procedures; l Means for locating family members in an emergency; l Emergency response procedures; l Evacuation, shelter, and accountability procedures; l Location and use of common emergency equipment; and l Emergency shutdown procedures. Employee training and plan review Before implementing the emergency action plan, the employer must designate and train enough people to assist in the safe and orderly emergency evacuation of employees [29 CFR 1910.38(e)]. Employers should review the plan with each employee when the initial plan is developed and when each employee is initially assigned to the job [29 CFR 1910.38(f)(1)]. Employers should review the plan with each employee when actions or responsibilities under the plan change [29 CFR 1910.38(f)(2)], or when the plan changes [29 CFR 1910.38(f)(3)]. Effective plans often call for retrain- ing employees annually and include drills in which employees can practice evacuating their workplace and gathering in the assembly area. 1 Do I Need to Develop an EAP? Answer the following questions to determine if your company needs to develop an EAP in accordance with 29 CFR 1910.38. The checklist does not alert you to other OSHA standards that may be associated with your emergency plan or to the additional OSHA standards that apply to your facility. QUESTION YES NO Are fire extinguishers provided in the workplace? Are the fire extinguishers intended for employee use? Will any of your employees be required to evacuate the workplace? If you answered “no” to either of the first two or “yes” to all three questions then you are required to develop an EAP. Otherwise, you should continue with the questions in the table below. QUESTION YES NO Does your facility use a total flooding extinguishing system that provides any one of the following design concentrations: l 4 percent or greater of Halon 1211? l 4 percent or greater of carbon dioxide? l 10 percent or greater of Halon 1301, or concentrations exceeding 7 percent when egress from an area cannot be accomplished in one minute? Does your facility use a fire detection system with alarms or devices that are delayed by more than 30 seconds for reasons other than a total flooding extinguishing system listed above? Are you required to comply with 29 CFR 1910.119, Process Safety Management? Are you required to comply with 29 CFR 1910.272, Grain Handling Facilities? Are you required to comply with 29 CFR 1910.1047, Ethylene Oxide? Are you required to comply with 29 CFR 1910.1050, Methylenedianiline? Are you required to comply with 29 CFR 1910.1051, 1,3-Butadiene? Do you plan to evacuate all of your employees and to rely on an outside party to provide emer- gency response to a hazardous substance release? Note: if a hazardous substance emergency could occur at your facility and you plan to have any of your employees participate in the emergency response, you are required to have an emergency response plan consistent with 29 CFR 1910.120(q), Hazardous Waste Operations and Emergency Response.