Emergency Action Plans: OSHA Requirements Every Employer Must Know

What is an emergency action plan

An emergency action plan (EAP) is a written document that describes the procedures your employees should follow during workplace emergencies. It covers evacuations, shelter-in-place scenarios, medical emergencies, fires, active threats, and natural disasters.

Under OSHA standard 29 CFR 1910.38, employers are required to have a written EAP if any other OSHA standard applicable to their workplace requires one. In practice, this covers most employers — because standards for fire extinguishers (1910.157), hazardous materials, and process safety all trigger the EAP requirement.

Even if your specific situation does not technically mandate a written plan, OSHA's General Duty Clause requires you to maintain a workplace free from recognized hazards. Having no emergency plan when emergencies are foreseeable is a recognized hazard.

Who needs an emergency action plan

The short answer: virtually every employer.

OSHA requires a written EAP when:

• You have fire extinguishers in the workplace (most employers do)
• You handle hazardous chemicals above threshold quantities
• You have permit-required confined spaces
• You perform hot work or lockout/tagout procedures
• Your state OSHA plan requires one for all employers

Several states go further than federal OSHA:

• California: Cal/OSHA requires emergency action plans for all employers with 10+ employees under Title 8 CCR 3220
• Washington: Requires written emergency plans as part of the Accident Prevention Program
• Oregon: Requires emergency action plans for employers with 11+ employees
• New York: Requires emergency plans and may require workplace violence prevention components

What your emergency action plan must include

OSHA 29 CFR 1910.38(c) specifies minimum elements:

1. Emergency escape procedures and route assignments

Map every evacuation route from every work area. Your plan should include:

• Primary and secondary evacuation routes for each floor or section
• Floor plans showing exits, stairwells, and assembly areas
• Procedures for employees who operate critical equipment before evacuating
• Accommodations for employees with disabilities who may need evacuation assistance

2. Procedures for employees who remain to operate critical operations

Some emergencies require a partial evacuation. Identify which employees stay behind and under what circumstances — for example, someone who must shut down a gas line or electrical system before evacuating.

3. Accounting for all employees after evacuation

You need a headcount system. Options include:

• Designated floor wardens or team leaders who count their groups
• Central assembly point check-in with a roster
• Badge-based tracking for larger facilities

This is not optional. You must be able to confirm every employee is accounted for before anyone re-enters the building.

4. Rescue and medical duties

Identify who is trained in first aid and CPR. Document:

• Location of first aid kits and AED devices
• Procedure for calling 911 and providing the address
• Who meets emergency responders and directs them to the scene
• Post-incident medical follow-up procedures

5. How to report emergencies

Every employee should know how to trigger the emergency response:

• Fire alarm pull station locations
• Phone numbers for 911 and internal emergency contacts
• When to use a fire extinguisher vs. when to evacuate immediately
• Active threat reporting procedures

6. Contact information for further information

Your plan must list the people employees can contact for questions:

• Emergency coordinator name and contact information
• Alternate emergency coordinator
• Local fire department and police non-emergency numbers
• Utility company emergency numbers (gas, electric, water)

Beyond the OSHA minimum: scenarios to plan for

A plan that only covers fire evacuations is not adequate for modern workplaces. Address these scenarios:

Active threat / active shooter

Follow the Run-Hide-Fight framework recommended by the Department of Homeland Security:

• Run: Evacuate if a safe path exists
• Hide: Barricade, silence phones, stay out of sight
• Fight: Last resort, act with aggression against the threat

Severe weather

• Tornado: Move to interior rooms on the lowest floor, away from windows
• Earthquake: Drop, cover, and hold on
• Flood: Move to higher ground, do not walk through floodwater
• Hurricane: Follow local evacuation orders or shelter in designated safe rooms

Utility failures

• Power outage procedures (emergency lighting, elevator entrapment)
• Gas leak response (evacuate, do not use electrical switches, call utility)
• Water main break (shut off water supply, protect equipment)

Bomb threat

• Phone-based threat: Keep the caller talking, note details, signal a coworker to call 911
• Written threat or suspicious package: Do not touch, evacuate the area, call 911
• Search procedures (only trained personnel, never move a suspicious object)

Training requirements

OSHA requires emergency action plan training:

• When the plan is developed or first implemented
• When an employee is initially assigned to the workplace
• When an employee's responsibilities under the plan change
• When the plan itself is changed

Training should cover:

• Evacuation routes and assembly points specific to their work area
• How to report emergencies
• Their specific responsibilities (if they have a role in the plan)
• Location of emergency equipment (alarms, extinguishers, first aid, AED)

Document all training with dates, topics, and attendee names. OSHA inspectors will ask for these records.

Emergency drills

While OSHA does not specify drill frequency in 1910.38, best practices and many state requirements include:

• Fire evacuation drills: At least annually, more often for high-hazard workplaces
• Shelter-in-place drills: At least annually
• Active threat drills: Annually, using tabletop exercises or walk-throughs (not live simulations that could cause panic)

After every drill, debrief and document:

• Evacuation time and whether it met targets
• Any issues with routes, exits, or assembly procedures
• Employees who did not participate or were confused about procedures
• Corrective actions and plan updates needed

Common EAP mistakes that trigger OSHA citations

1. Generic plans not specific to your workplace: Inspectors can tell when you downloaded a template and did not customize it
2. No employee training records: Having a plan without training is almost worse than having no plan
3. Outdated contact information: Emergency coordinators who no longer work there, wrong phone numbers
4. No accounting system for post-evacuation: If you cannot confirm everyone is out, the fire department may send people in to search
5. Ignoring employees with disabilities: Your plan must address how employees with mobility, hearing, or vision impairments will be assisted during evacuation

How ComplyStack builds your emergency action plan

An emergency action plan requires understanding OSHA 29 CFR 1910.38, your state's specific emergency planning requirements, and the unique hazards of your workplace. ComplyStack generates customized emergency action plans based on your business type, state, facility layout, and employee count — complete with evacuation procedures, emergency contacts, drill schedules, and training requirements tailored to your operation.