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6 Steps to Creating an Effective Emergency Response Plan [+ Template]

Follow the six steps outlined in this article to create an emergency response plan for keeping your people, business, and assets safe during any critical event that may arise.


What Is an Emergency Response Plan?

As every emergency management professional will tell you, the best time to prepare for an emergency is well before it occurs. If a hurricane or other severe weather hits, you won’t have time to create an evacuation plan on the spot; you’ll be too busy focusing on immediate hazards. And if your building has a power outage, it’s probably too late to go searching for generators.

Taking a proactive approach to emergency planning helps you ensure the best possible outcomes for your people and business, and it allows you to think holistically about the situation, accounting for a multitude of variables. This approach boils down to a holistic emergency response plan for all the threats your business might face.

While we can’t necessarily predict when critical events will happen, emergencies are a reality for every business—so you need to be ready. We’ll explore what an emergency response plan is and highlight six steps every organization should take to ensure they’re prepared for any emergency or business interruption that may arise.

An emergency response plan is a document that lays out the series of steps your organization will take during a critical event, such as a fire or active shooter threat, to ensure employees’ safety and minimize the impact on critical operations.

Emergency response plans—just like other emergency management planning documents—are meant to help organizations address various types of emergencies, such as hurricanes, wildfires, winter weather, chemical spills, disease outbreaks, and other hazards. The goal is to reduce or prevent human injury and property damage during critical events. The planning phase involves documenting the steps your organization will take in each of these emergencies to ensure a timely response tailored to each scenario.

These plans also take the guesswork out of roles and responsibilities by specifying which staff members should be part of the response team and which first responders should be contacted.

You can create your own emergency response plan from scratch or use a pre-built template, like ours , to make the process easier.

Why use an emergency response plan template?

An emergency response plan template can make your planning process quicker and simpler. Every business has a unique range of emergencies they face, but there are some consistent response procedures that you can personalize to your individual risks. Templates also give you a single place to collect important contact information for your response team and first responders.

You can download this free template to get started building your plan today.

The best emergency response plans include a list of individuals to contact (and their contact information), evacuation routes, how to act during an emergency, how to mitigate risk to your people and facilities, and detailed communication procedures to follow during and after a specific emergency occurs.

That said, plans can vary widely depending on the setting and circumstances surrounding the crisis. It’s important to create a plan that accounts for life-saving actions, such as

Now that you’re up to speed on why your organization needs a plan and what it should cover, let’s examine how to create an effective emergency response plan for your business.

How to Conduct Emergency Response Planning

Each organization is unique, so you may find that additional measures are warranted to protect your business from possible hazards—beyond the examples listed. However, by completing these steps, you will be well on your way to ensuring your team knows what is expected of them and when.

Step #1: Perform a threat assessment

The first step to creating an emergency response plan is to conduct a comprehensive threat assessment to identify the types of events that may affect your organization and analyze their likelihood and potential impact. Specific threats vary by location, sector, and company, and your mitigation strategies will vary depending on the scenario. You may need to plan for the following types of events:

Even when lives may not be immediately at stake during a crisis, timely communication is just as important. Other events that require a planned response for the success of the business and safety of your team may include:

Using the all-hazards approach to your risk assessment is a great way to ensure you are covering all your bases, able to prepare for any kind of threat.

Step #2: Document contact information

In the event of an emergency that could cause physical harm to your employees, the first call you should make is to your local emergency responders. Aside from 9-1-1, you need to have numbers for emergency medical services (EMS), the fire department, healthcare providers/insurance agents, and local law enforcement/police department readily available.

Additionally, make sure you have emergency contact information documented for every employee in case someone goes unaccounted for or gets injured during the emergency.

Step #3: Assign roles and responsibilities

When an emergency occurs, employees will look to their leaders for reassurance and guidance. These leaders should be in charge of activating your emergency response plan, answering important questions, and ordering an evacuation if needed. When assigning roles, there are important considerations to acknowledge. You need to make sure your response team is present, reliable, and able to react quickly in the face of an emergency.

Here are the main roles to consider as part of your emergency response plan:

Incident commander

This employee has overall responsibility for an emergency, including planning and preparation. The incident commander is in charge of emergency response plan activation and is the one all critical decisions should go through.

Communication commander

This person should use the mass alert system to notify employees, call emergency services, and gather reports. If your company is using an emergency communication system, make sure this person is a system admin.

Scene supervisor

This person controls access to the emergency scene and keeps people away from unsafe areas.

Building utilities manager(s)

These team members need to be familiar with the locations and functions of controls for building utility and life safety and protection systems. These systems include ventilation, electrical shutoffs, water and sanitary systems, emergency power supplies, and alarm systems.

Route guide(s)

In the event of an evacuation, these guides play an important role in ensuring that routes are clear and evacuation is orderly and calm. They also help clear evacuation routes and assist those with mobility issues.

Step #4: Take stock of current resources within your organization

Have you inspected those dusty office fire extinguishers, alarm systems, or first aid kits lately? These are critical components to any emergency response plan, so examine them regularly.

Fire extinguishers and alarms

To support your fire safety, the National Fire Protection Association recommends refilling reusable fire extinguishers every 10 years and replacing disposable ones every 12 years. Periodically remind your employees where the fire extinguishers are located in the workplace. Maintain and test any fire alarms on your premises. Run regular fire drills to get your team used to the evacuation process.

This step-by-step video will guide you through the process of conducting a fire drill at work.


Alarm systems

Inspect fire alarm systems annually at the very least. OSHA recommends testing non-supervised employee alarm systems every two months. This inspection covers a host of details, depending on the type of alarm system, like inspection of control panel(s), tests of all associated devices such as smoke detectors and heat detectors, warning systems operations, and batteries and power.

First aid kit

OSHA requires that “employers provide medical and first aid supplies commensurate with the hazards of the workplace.” Since many items in a first aid kit have expiration dates—typically three to five years after manufacture—and can become damaged by frequent use, moisture, and exposure to the air, it is important to regularly check your first aid kit and replace any supplies as needed. As a proactive approach, restock items after use and inspect first aid supplies every three months. Provide the necessary first aid training so your team is prepared to use these supplies and help their coworkers in emergencies, big and small.

First aid supplies for the workplace

Step #5: Determine your response plan steps

Next, decide what steps to follow in an emergency. Customize each event response so the procedures are specific and clear.

As an example, here’s how you might go about planning for an evacuation response.

Emergency fire evacuation plan example

A good fire evacuation plan for your business will include primary and secondary escape routes. Clear signs should mark all the exit routes and fire escapes. Keep exit routes clear of furniture or other objects that could impede a direct means of egress for your employees. For large offices, make multiple maps of floor plans and diagrams and post them so employees know the evacuation routes. Best practice also calls for developing a separate evacuation plan for individuals with disabilities who may need additional assistance.

Once your people are out of the building, where do they go? Designate an assembly point for employees to gather. Your response team should be at the assembly point, collecting a headcount and providing updates. Ensure the escape routes and the assembly area can accommodate the expected number of employees who will be evacuating.

Be sure to also think about your disaster recovery efforts, or what you do once the emergency is done. With planning that extends to recovery, your business can move forward and get back to work as normal. For example, if you have a spill of hazardous materials, your emergency response plan will account for how to keep people safe and how to contain the spill. The recovery section of your template will explain how to clean up the spill and get that area of the building back to safe working conditions.

Step #6: Decide how to communicate with your employees

One of the most important parts of any emergency response plan is how you will communicate. When developing your emergency communication plan , consider how to notify employees of a critical event, how the information will be delivered and received, and how effective your communication channels will be at reaching every employee in harm’s way.

During critical events, phone calls and emails are no longer enough. Manual phone trees are prone to misinformation and long delays, and an email alert system alone just doesn’t cut it for emergency communication.

Research suggests that only 65% of employees open internal emails. For workers constantly inundated with messages, internal emails don’t create the sense of urgency needed for time-sensitive information. Hourly and frontline employees—such as retail associates and distribution center workers—often do not have a company email address at all or they don’t have access to it from their personal phones outside of business hours. And if phone lines are down or email is inaccessible—as can often be the case in emergency situations—your employees may never receive the message. If an organization is hit with an IT virus, for example, relying on email as the only communication channel would be useless and perhaps even counterproductive.

Include notification templates in your emergency response plan so you can send messages about an incident as quickly as hitting a button. Our template includes examples of what those messages might look like, as well as spaces to compose your own.

Leveraging Technology to Improve Emergency Preparedness

Today’s workforce is more distributed than ever before, especially with a drastic shift to remote and hybrid working environments. This makes emergency communication increasingly important—but also more challenging.

A modern emergency notification system enables the fast, reliable delivery of mass notifications to any-size audience, on any device, over any communication channel. And every organization—regardless of size, industry, or location—will face unexpected events that can be managed more effectively with the help of emergency communication software.

When evaluating mass notification solutions, it may be easy to fall into the trap of thinking a standalone text messaging tool is sufficient. But a simple mass texting system simply doesn’t have the functionality to communicate reliably with your people during critical events. When the health and safety of your people are at stake, only an enterprise-grade emergency communication system can offer the speed, reliability, and user experience you need.

A mass notification system with multichannel delivery, two-way communication , pre-built notification templates , and threat intelligence can help protect your people and business. With a modern emergency communication system, you can rapidly send and receive messages across multiple channels and ensure everyone gets the information they need when they need it. By automatically syncing with your HRIS or Active Directory, you’ll also never have to worry about inaccurate employee contact information, which is critical to safeguarding message deliverability.

Designing a Modern Emergency Response Plan

Every business needs a solid plan for how they will communicate with employees during emergencies and other business-critical events. In emergencies, minutes can mean the difference between minor impact and major disaster. The heat of a crisis is not the time to figure out how to effectively communicate and ensure the safety of your employees.

By building out your emergency response plan in advance, your business is prepared to act at the first signs of a crisis. Download this template to make your planning process as simple and effective as possible—so you can get back to leading safe everyday operations.

Download Our Emergency Response Plan Template

More articles you may be interested in.

6 Steps to Follow in an Emergency for an Organized Response

Emergency Response Plan Template

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Emergency Response Plan

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The actions taken in the initial minutes of an emergency are critical. A prompt warning to employees to evacuate, shelter or lockdown can save lives. A call for help to public emergency services that provides full and accurate information will help the dispatcher send the right responders and equipment. An employee trained to administer first aid or perform CPR can be lifesaving. Action by employees with knowledge of building and process systems can help control a leak and minimize damage to the facility and the environment.

The first step when developing an emergency response plan is to conduct a risk assessment to identify potential emergency scenarios. An understanding of what can happen will enable you to determine resource requirements and to develop plans and procedures to prepare your business. The emergency plan should be consistent with your performance objectives .

At the very least, every facility should develop and implement an emergency plan for protecting employees, visitors, contractors and anyone else in the facility. This part of the emergency plan is called “protective actions for life safety” and includes building evacuation (“fire drills”), sheltering from severe weather such as tornadoes, “shelter-in-place” from an exterior airborne hazard such as a chemical release and lockdown. Lockdown is protective action when faced with an act of violence.

When an emergency occurs, the first priority is always life safety. The second priority is the stabilization of the incident. There are many actions that can be taken to stabilize an incident and minimize potential damage. First aid and CPR by trained employees can save lives. Use of fire extinguishers by trained employees can extinguish a small fire. Containment of a small chemical spill and supervision of building utilities and systems can minimize damage to a building and help prevent environmental damage.

Some severe weather events can be forecast hours before they arrive, providing valuable time to protect a facility. A plan should be established and resources should be on hand, or quickly, available to prepare a facility. The plan should also include a process for damage assessment, salvage, protection of undamaged property and cleanup following an incident. These actions to minimize further damage and business disruption are examples of property conservation.

Guidance for the development of an emergency response plan can be found in this step.

Protective Actions for Life Safety

When there is a hazard within a building such as a fire or chemical spill, occupants within the building should be evacuated or relocated to safety. Other incidents such as a bomb threat or receipt of a suspicious package may also require evacuation. If a tornado warning is broadcast, everyone should be moved to the strongest part of the building and away from exterior glass. If a transportation accident on a nearby highway results in the release of a chemical cloud, the fire department may warn to “shelter-in-place.” To protect employees from an act of violence, “lockdown” should be broadcast and everyone should hide or barricade themselves from the perpetrator.

Protective actions for life safety include:


Your emergency plan should include these protective actions. If you are a tenant in multi-tenanted building, coordinate planning with the building manager.

Prompt evacuation of employees requires a warning system that can be heard throughout the building. Test your fire alarm system to determine if it can be heard by all employees. If there is no fire alarm system, use a public address system, air horns or other means to warn everyone to evacuate. Sound the evacuation signal during planned drills so employees are familiar with the sound.

Make sure that there are sufficient exits available at all times.

Appoint an evacuation team leader and assign employees to direct evacuation of the building. Assign at least one person to each floor to act as a “floor warden” to direct employees to the nearest safe exit. Assign a backup in case the floor warden is not available or if the size of the floor is very large. Ask employees if they would need any special assistance evacuating or moving to shelter. Assign a “buddy” or aide to assist persons with disabilities during an emergency. Contact the fire department to develop a plan to evacuate persons with disabilities.

Have a list of employees and maintain a visitor log at the front desk, reception area or main office area. Assign someone to take the lists to the assembly area when the building is evacuated. Use the lists to account for everyone and inform the fire department whether everyone has been accounted for. When employees are evacuated from a building, OSHA regulations require an accounting to ensure that everyone has gotten out safely. A fire, chemical spill or other hazard may block an exit, so make sure the evacuation team can direct employees to an alternate safe exit.

If a tornado warning is broadcast, a distinct warning signal should be sounded and everyone should move to shelter in the strongest part of the building. Shelters may include basements or interior rooms with reinforced masonry construction. Evaluate potential shelters and conduct a drill to see whether shelter space can hold all employees. Since there may be little time to shelter when a tornado is approaching, early warning is important. If there is a severe thunderstorm, monitor news sources in case a tornado warning is broadcast. Consider purchasing an Emergency Alert System radio - available at many electronic stores. Tune in to weather warnings broadcast by local radio and television stations. Subscribe to free text and email warnings, which are available from multiple news and weather resources on the Internet.

A tanker truck crashes on a nearby highway releasing a chemical cloud. A large column of black smoke billows into the air from a fire in a nearby manufacturing plant. If, as part of this event, an explosion, or act of terrorism has occurred, public emergency officials may order people in the vicinity to “shelter-in-place.” You should develop a shelter-in-place plan. The plan should include a means to warn everyone to move away from windows and move to the core of the building. Warn anyone working outside to enter the building immediately. Move everyone to the second and higher floors in a multistory building. Avoid occupying the basement. Close exterior doors and windows and shut down the building’s air handling system. Have everyone remain sheltered until public officials broadcast that it is safe to evacuate the building.

An act of violence in the workplace could occur without warning. If loud “pops” are heard and gunfire is suspected, every employee should know to hide and remain silent. They should seek refuge in a room, close and lock the door, and barricade the door if it can be done quickly. They should be trained to hide under a desk, in the corner of a room and away from the door or windows. Multiple people should be trained to broadcast a lockdown warning from a safe location.

Resources for Protective Actions for Life Safety

In addition to the following resources available on the Internet, seek guidance from your local fire department, police department, and emergency management agency.

Incident Stabilization

Stabilizing an emergency may involve many different actions including: firefighting, administering medical treatment, rescue, containing a spill of hazardous chemicals or handling a threat or act of violence. When you dial 9-1-1 you expect professionals to respond to your facility. Depending upon the response time and capabilities of public emergency services and the hazards and resources within your facility, you may choose to do more to prepare for these incidents. Regulations may require you to take action before emergency services arrive.

If you choose to do nothing more than call for help and  evacuate , you should still prepare an emergency plan that includes prompt notification of emergency services, protective actions for life safety and accounting of all employees.

Developing the Emergency Plan

Developing an emergency plan begins with an understanding of what can happen. Review your  risk assessment . Consider the  performance objectives  that you established for your program and decide how much you want to invest in planning beyond what is required by  regulations .

Assess what resources are available for incident stabilization. Consider  internal resources and external resources  including public emergency services and contractors. Public emergency services include fire departments that may also provide rescue, hazardous materials and emergency medical services. If not provided by your local fire department, these services may be provided by another department, agency or even a private contractor. Reach out to local law enforcement to coordinate planning for security related threats.

Document available resources. Determine whether external resources have the information they would need to handle an emergency. If not, determine what information is required and be sure to document that information in your plan.

Prepare emergency procedures for foreseeable hazards and threats. Review the list of hazards presented at the bottom of the page. Develop hazard and threat specific procedures using guidance from the resource links at the bottom of this page.

Warning, Notifications, and Communications

Plans should define the most appropriate protective action for each hazard to ensure the safety of employees and others within the building. Determine how you will warn building occupants to take protective action. Develop protocols and procedures to alert first responders including public emergency services, trained employees and management. Identify how you will  communicate with management and employees  during and following an emergency.

Roles and Responsibilities for Building Owners and Facility Managers

Assign personnel the responsibility of controlling access to the emergency scene and for keeping people away from unsafe areas. Others should be familiar with the locations and functions of controls for building utility, life safety and protection systems. These systems include ventilation, electrical, water and sanitary systems; emergency power supplies; detection, alarm, communication and warning systems; fire suppression systems; pollution control and containment systems; and security and surveillance systems. Personnel should be assigned to operate or supervise these systems as directed by public emergency services if they are on-site.

Site and Facility Plans and Information

Public emergency services have limited knowledge about your facility and its hazards. Therefore, it is important to document information about your facility. That information is vital to ensure emergency responders can safely stabilize an incident that may occur. Documentation of building systems may also prove valuable when a utility system fails—such as when a water pipe breaks and no one knows how to shut off the water.

Compile a site-plan and plans for each floor of each building. Plans should show the layout of access roads, parking areas, buildings on the property, building entrances, the locations of emergency equipment and the locations of controls for building utility and protection systems. Instructions for operating all systems and equipment should be accessible to emergency responders.

Provide a copy of the plan to the public emergency services that would respond to your facility and others with responsibility for building management and security. Store the plan with other emergency planning information such as chemical Material Safety Data Sheets (MSDS), which are required by Hazard Communication or “right to know” regulations.

Training and Exercises

Train personnel  so they are familiar with detection, alarm, communications, warning and protection systems. Review plans with staff to ensure they are familiar with their role and can carry out assigned responsibilities. Conduct evacuation, sheltering, sheltering-in-place and lockdown drills so employees will recognize the sound used to warn them and they will know what to do. Facilitate  exercises  to practice the plan, familiarize personnel with the plan and identify any gaps or deficiencies in the plan.

10 Steps for Developing the Emergency Response Plan

Links to Emergency Planning Information

Pre-incident planning (site and building information for first responders).


Hazardous materials

Natural hazards

Workplace Violence

Terrorism, Bomb Threats, and Suspicious Packages

Hazards to Consider When Developing the Emergency Plan

Geological hazards

Meteorological Hazards

Biological hazards

Human-caused events


Technology caused events

Cyber security (data corruption/theft, loss of electronic data interchange or ecommerce, loss of domain name server, spyware/malware, vulnerability exploitation/botnets/hacking, denial of service)

Property Conservation

Taking action before a forecast event, such as a severe storm, can prevent damage. Prompt damage assessment and cleanup activities following the storm can minimize further damage and business disruption. These actions are considered “property conservation”—an important part of the emergency response plan. Much of the following guidance is directed to building owners and facility managers. However, tenants should also develop a plan in coordination with building owners and managers as well as public authorities.

Preparing a Facility for a Forecast Event

Body copy: Actions to prepare a facility for a forecast event depend upon the potential impacts from the hazards associated with the event. Conduct a  risk assessment  to identify severe weather hazards including winter storms, arctic freeze, tropical storm, hurricane, flooding, storm surge, severe thunderstorm, tornado and high winds. Also consider non-traditional hazards, such as a planned event involving a large crowd.

Property conservation actions should focus on protection of the building and valuable machinery, equipment and materials inside. Potential damage may be prevented or mitigated by inspecting the following building features, systems and equipment:

The review of building components may also identify opportunities for longer-term  mitigation  strategies.

Property conservation activities for specific forecast events include the following:

Salvage and Actions to Prevent Further Damage Following an Incident

Separating undamaged goods from water-soaked goods is an example of salvage. Covering holes in a roof or cleaning up water and ventilating a building are also part of property conservation. The property conservation plan should identify the resources needed to salvage undamaged good and materials; make temporary repairs to a building; clean up water, smoke and humidity; and prepare critical equipment for restart.

Resources for property conservation include the following:

Compile an inventory of available equipment, tools and supplies and include it with the emergency response plan. Identify precautions for equipment exposed to water or high humidity and procedures for restarting machinery and equipment.

Identify contractors that may be called to assist with clean up and property conservation efforts. Keep in mind that competition for contractors, labor, materials and supplies prior to a forecast storm or following a regional disaster may be intense. Plan ahead and secure contractors and other resources in advance.

Resources for Property Conservation

Last Updated: 04/28/2022

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Emergency Preparedness and Response: Getting Started

General business preparedness for general, construction and maritime industries, evacuation & shelter-in-place, osha’s role in emergency response, ppe for emergency response and recovery workers, introduction.

Emergencies and disasters can strike anywhere and at any time bringing workplace injuries and illnesses with them. Employers and workers may be required to deal with an emergency when it is least expected and proper planning before an emergency is necessary to respond effectively.

This webpage is designed to help workers and employers plan for that possibility. The best way to protect workers is to expect the unexpected and to carefully develop an emergency action plan to guide everyone in the workplace when immediate action is necessary. Planning in advance helps ensure that everyone knows what to do when an emergency occurs.

What is a workplace emergency?

A workplace emergency is a situation that threatens workers, customers, or the public; disrupts or shuts down operations; or causes physical or environmental damage. Emergencies may be natural or man-made, and may include hurricanes, tornadoes, earthquakes, floods, wildfires, winter weather, chemical spills or releases, disease outbreaks, releases of biological agents, explosions involving nuclear or radiological sources, and many other hazards. Many types of emergencies can be anticipated in the planning process, which can help employers and workers plan for other unpredictable situations.

The Emergency Preparedness and Response landing page provides a listing of all of the specific hazards for which the Agency currently has information available on its website, as well as links to general emergency preparedness and response guidance.

What are OSHA's requirements for emergencies?

Some key OSHA requirements for emergencies can be found in the following sections of standards for general industry ( 29 CFR 1910 ), construction ( 29 CFR 1926 ), and maritime ( 29 CFR 1915 , 1917 , and 1918 ). The table may not list all standards that apply to all situations.

The following table is best viewed on a tablet or pc.

Additional OSHA standards may apply. The OSHA Law & Regulations web page provides a complete list of OSHA standards by industry.

What other OSHA standards address emergency planning requirements?

Several OSHA standards address emergency planning requirements, including 29 CFR 1910.38 ; 29 CFR 1926.35 ; Hazardous Waste Operations and Emergency Response (HAZWOPER) ( 29 CFR 1910.120(q) ); Fire Brigades ( 29 CFR 1910.156 ); and Permit-Required Confined Spaces ( 29 CFR 1910.146(k) , 29 CFR 1926.1211). OSHA Publication 3122, Principal Emergency Response and Preparedness Requirements in OSHA Standards and Guidance for Safety and Health Problems , provides a broad overview of emergency planning requirements in OSHA standards.

Employers should also be familiar with the consensus standards of the National Fire Protection Association (NFPA) , American National Standards Institute (ANSI) , and other standards-setting organizations, as these may provide additional recommendations and requirements about emergency planning. The NFPA develops, publishes, and disseminates hundreds of consensus codes and standards intended to minimize the possibility and effects of fire and other risks. Virtually every building, process, service, design, and installation in society today is affected by NFPA documents. NFPA codes and standards are adopted and used throughout the world. For more information about NFPA and their codes and standards, visit their website at www.nfpa.org .

What is an emergency action plan?

An emergency action plan (EAP) is intended to facilitate and organize employer and worker actions during workplace emergencies and is recommended for all employers. Well-developed emergency plans and proper worker training (i.e., so that workers understand their roles and responsibilities within the plan) will result in fewer and less severe worker injuries and less damage to the facility during emergencies. A poorly prepared plan may lead to a disorganized evacuation or emergency response, resulting in confusion, injury, illness (due to chemical, biological and/or radiation exposure), and/or property damage.

Two OSHA standards ( 29 CFR 1910.38(a) and 29 CFR 1926.35 ) require written EAPs. Not all employers are required to establish an EAP (see section titled "Am I required to have an Emergency Action Plan (EAP)" to see if your business is required), but developing an EAP is a good way to protect workers and businesses during an emergency. Emergency preparedness is a well-known concept in protecting workers' safety and health.

Putting together a comprehensive emergency action plan involves conducting a hazard assessment to determine what, if any, physical or chemical hazards inside or from outside the workplaces could cause an emergency. The plan should describe how workers will respond to different types of emergencies, taking into account specific worksite layouts, structural features, and emergency systems. If there is more than one worksite, each site should have an emergency action plan.

Most organizations find it beneficial to include a diverse group of representatives (management, workers, local health departments and agencies, and public safety officials/members) in this planning process and to meet frequently to review progress and allocate development tasks. Outside representatives from federal, state and local agencies may be able to assist organizations with incorporating other requirements or guidelines into their EAPs. The commitment and support of all workers and employers is critical to the plan's success in the event of an emergency; ask for worker input in developing and implementing an EAP. For smaller organizations with 10 or fewer workers, the plan does not need to be written and may be communicated orally (General Industry Standard - 29 CFR 1910.38(b) , Construction Industry Standard - 29 CFR 1926.35(e)(3) ).

Am I required to have an Emergency Action Plan (EAP)?

Workplaces covered by the following standards may be required to have an EAP :

Under OSHA's fire extinguisher standard, 29 CFR 1910.157 , an EAP is required if the employer:

If you are still unsure about whether you are required to have an EAP, use OSHA's Expert System to help you determine your EAP requirements.

At a minimum, for businesses that are required to have an emergency action plan (EAP), the plan must include:

evacuation map

In addition, although not specifically required by OSHA's EAP standard, other emergency preparedness actions include:

How to alert workers of an emergency?

If a business is required to have an EAP, the plan must include a way to alert workers, including disabled workers, to evacuate or take other action (see 29 CFR 1910.38(d) and 29 CFR 1926.35(c) ). These standards require:

The EAP must also state how employees are to report emergencies. Employers should consider making available an emergency communication system, such as a public address system, portable radios, or other communications tools to assist in contacting local law enforcement, the fire brigade (if provided), the fire service (e.g., local fire department), and others. These communication systems may also serve as additional means of notifying workers of an emergency. Employers should also provide an updated list of key personnel such as the plant manager or physician, in order of priority, to notify in the event of an emergency during off-duty hours.

The Employee Alarm Systems standard ( 29 CFR 1910.165 ) is also aimed at ensuring alarms are able to be perceived by all workers at a worksite, including those with physical impairments (see OSHA's 1990 interpretation of the standard). Accordingly:

Emergency Plan and Evacuation Coordinators

When drafting an emergency action plan, consider selecting a responsible individual to lead and coordinate the emergency plan and evacuation. It is critical that workers know who the coordinator is and understand that the coordinator has the authority to make decisions during emergencies.

The Coordinator should be responsible for:

It may be beneficial to coordinate the action plan with other employers that share the worksite, although OSHA standards do not specifically require this.

Evacuation Wardens

In addition to a coordinator, designate and train workers as evacuation wardens to help move workers from danger to safe areas during an emergency (see 29 CFR 1910.38(e) and 1926.35(e)(1) ). Generally, one warden for every 20 workers should be adequate, and the appropriate number of wardens should be available at all times during working hours.

Workers (e.g. coordinators or wardens) designated to assist in emergency evacuation procedures should be trained in the complete workplace layout and various alternative escape routes. All workers should be made aware of workers with special needs who may require extra assistance; how to use the buddy system (i.e., procedure where two people, the "buddies", operate together as a single unit so that they are able to monitor and help each other); and hazardous areas to avoid during an emergency evacuation.

What type of training do workers need?

Topics for worker training:

After reviewing the emergency action plan with workers and ensuring everyone has completed the proper training, it is a good idea to hold practice drills as often as necessary to keep workers prepared. It is also a good idea to include outside resources, such as fire and police departments, in the practice drills whenever possible. After each drill, employers should: gather management and workers together to evaluate the effectiveness of the drill; identify the strengths and weaknesses of the plan; and ways to improve the plan.

How often to train workers?

Review the plan with all workers and consider requiring annual training on the plan. Also conduct training after:

Worker Protection during High-Hazard and/or Unique Emergency Operations

During high-hazard or other unique emergency operations, an employer should work with the incident commander*, unified command staff*, and other health and safety personnel to limit worker exposures to all hazards through a combination of engineering and administrative controls and safe work practices, supplemented by PPE (personal protective equipment).

*See the DHS/FEMA National Incident Management System (NIMS) page for guidance on implementing the ICS during an actual emergency response.

Employers should work with emergency response organizations in their jurisdictions to ensure the organizations are prepared to respond to and safely perform needed rescue operations that may pose unique or particularly hazardous conditions for emergency responders. This may include preparing, training, and exercising capabilities for response and rescue operations at steep angles or heights, or in the presence of chemical or other hazards such as in pits, tanks, manholes, boilers, furnaces, silos, hoppers, vaults, pipes, ducts, and bins or on slopes, communication towers, or other tall structures, including those under construction; in confined spaces, trenches, or underground; and over, near, or in water of various depths. Such operations may require special engineering and administrative controls, work practices, and PPE to protect emergency response and recovery workers.

Additional Resources

How to Plan for Workplace Emergencies and Evacuations , Occupational Safety and Health Administration (OSHA), U.S. Department of Labor (DOL).

Booklet to help employers and workers plan for evacuations following emergencies or disasters.

Emergency Response Resources , National Institute for Occupational Safety and Health (NIOSH), Centers for Disease Control and Prevention (CDC), U.S. Department of Health and Human Services (HHS).

Numerous emergency preparedness and response resources for business owners and managers, including links to:

Prepare Your Workplace and Employees . American Red Cross (ARC). Website of the American Red Cross which links to resources on personal emergency kits, emergency planning, and communications.

Prepare Your Workplace . American Red Cross (ARC). The American Red Cross Ready Rating™, a first-of-its-kind membership program designed to help businesses, organizations and schools become better prepared for emergencies. Members join this free, self-paced program and complete a 123-point self-assessment of your business’ level of preparedness to identify areas for improvement.

Get Started: Emergency Preparedness Checklist for Small Business . American Red Cross (ARC).

Having an emergency preparedness plan in place is as important to the survival of your small business as your business plan. Ask yourself the questions in this checklist to help you get back in business after a disaster.

Preparedness Planning for Your Business . Federal Emergency Management Agency (FEMA), U.S. Department of Homeland Security (DHS). Includes specific suggestions for protecting businesses from disasters by taking precautionary actions, planning drills, and getting supplies. The resources includes several downloadable checklists, plans, and discussion topics.

Among the topics covered are:

Disaster Preparedness , Small Business Administration (SBA).

SBA publications on such topics as:

It also has a list of other websites that offer assistance in disaster planning and response for small businesses.

National Fire Protection Association (NFPA) 1600, Standard on Disaster/Emergency Management and Business Continuity Programs , NFPA, 2013 Edition.

The NFPA 1600 standard establishes a common set of criteria for all hazards disaster/emergency management and business continuity programs. The emergency management and business continuity community comprises many different entities, including the government at distinct levels (e.g., federal, state/provincial, territorial, tribal, indigenous, and local levels); business and industry; nongovernmental organizations; and individual citizens. Each of these entities has its own focus, unique missions and responsibilities, varied resources and capabilities, and operating principles and procedures. Provisions of the standard cover the development, implementation, assessment, and maintenance of programs for prevention, mitigation, preparedness, response, continuity, and recovery.

National Fire Protection Association (NFPA) 1620, Standard for Pre-Incident Planning , NFPA, 2015.

The NFPA 1620 standard provides criteria for developing pre-incident plans to help responders effectively manage emergencies so as to maximize protection for occupants, responding personnel, property, and the environment. It is a comprehensive guide covering the pre-incident planning process, physical and site considerations, occupant considerations, water supplies and fire protection systems, special hazards, emergency operations, and pre-incident plan testing and maintenance. Annexes contain case histories and information addressing special or unique characteristics of specific occupancy classifications, as well as sample forms for pre-incident planning.

Emergency evacuations are more common than many people realize, including evacuations in the workplace. According to the U.S. Department of Homeland Security (DHS) Federal Emergency Management Agency (FEMA), the most frequent causes of evacuations in the U.S. each year are fires and floods. In addition, a wide variety of emergencies, both man-made and natural, may require a workplace to be evacuated. These emergencies may include explosions, earthquakes, hurricanes, tornadoes, hazardous/toxic material releases, radiological and biological accidents, civil disturbances and workplace violence.

Emergency Evacuation is the immediate and urgent movement of people away from a threat or actual occurrence of a hazard.

This web page provides workers and employers guidance on planning for safe evacuations and shelter-in-place procedures during emergencies that may affect their workplace.

Deciding whether to shelter-in-place or evacuate to safety (i.e., get away from a threat or hazard) is among the most important decisions that must be made during an emergency. Employers should understand and plan for both scenarios. In any emergency, the local authorities may or may not be able to provide information immediately to assess the situation. Employers should consider how the situation might impact workers sheltering-in-place at a job site versus workers attempting to evacuate to safety.

If local authorities or the on-scene coordinator (e.g., incident commander or other official in charge) specifically give instructions to evacuate or seek medical treatment, do so immediately. In very hazardous situations, local officials may require mandatory evacuations. During other times, local officials may advise, or workers and employers may decide, to evacuate to avoid situations they believe are potentially dangerous.

Watch TV, listen to the radio, or check the Internet often for information or official instructions as it becomes available. Additionally, specific instructions and guidance from local officials may also be provided through mass media, sirens or other public address/alert systems, text alerts, emails, or telephone calls.

Develop a Plan Ahead of Time

Many disasters are no-notice events, meaning that there is no warning before they occur. These types of events do not allow time for people to gather even the most basic necessities. Therefore, pre-planning is critical.

Workers may need to be trained to respond differently to different threats. For example, workers may be required to assemble in one area inside the workplace if threatened by a tornado or on an adjacent highway if threatened by a chemical spill. Moreover, a fire may require workers to evacuate to a pre-determined exterior location.

Emergency evacuation plans are developed to ensure the safest and most efficient evacuation. The evacuation plan must identify when and how workers are to respond to different types of emergencies. When developing the plan, it is important to ask questions and plan for worst-case scenarios. What would happen if the worksite caught fire, the nearby river flooded, or a chemical release occurred in the facility?

When developing an emergency action plan , it is important to determine:

For Workers

For employers.

An Emergency Action Plan (EAP) is a written document required by some OSHA standards (including 29 CFR 1910.38(a) and 29 CFR 1926.35 ) to help facilitate and organize employer and employee actions during workplace emergencies. See OSHA's Emergency Action Plan Checklist for more assistance in developing an EAP.

When to Evacuate

The emergency evacuation plan should identify the different types of situations that will require an evacuation of the workplace. As mentioned before, these may include explosions; earthquakes, hurricanes, tornadoes, and other natural disasters; releases of chemical, radioactive, or biological agents; and civil disturbances and workplace violence. The extent of evacuation may be different for different types of hazards.

The type of building employees work in may be a factor in the decision to evacuate during an emergency. Most buildings are vulnerable to the effects of disasters, such as tornadoes, earthquakes, floods, or explosions. The extent of the damage depends on the type of emergency and the building's construction. Modern factories and office buildings, for example, are framed in steel and may be more structurally sound than older structures. In a major disaster, however, nearly every type of structure will be affected. Some buildings will collapse and others will be left with weakened floors, walls, and roofs.

Evacuations during an Active Shooter or other Dangerous Intruder Situation

Active shooter and other dangerous intruder situations are unpredictable and evolve quickly. Typically, the immediate deployment of law enforcement is required to stop the shooting and mitigate harm to victims. Because active shooter situations are often over within 10 to 15 minutes, before law enforcement arrives on the scene, individuals must be prepared both mentally and physically to deal with an active shooter situation. Evacuation may be one option during an active shooter situation. This web page also describes sheltering in place during an active shooter situation in the "Shelter-in-Place" section below.

The Department of Homeland Security (DHS) provides the following guidance for evacuation during an active shooter situation :

If there is an accessible escape path, attempt to evacuate the premises. Be sure to:

For more information, visit DHS's website for Active Shooter Preparedness.

Clear Chain of Command

It is common practice to select a responsible individual, with appropriate training or certifications, to lead and coordinate the workplace emergency plan and evacuation. It is critical that the employer ensures that the workers know the identity of the coordinator, as well as understand that the coordinator has the responsibility for making life saving decisions during an emergency. The coordinator should be responsible for assessing the situation to determine whether an emergency exists, activating the emergency procedures, overseeing emergency procedures, notifying and coordinating with outside emergency services, and directing the shutdown of utilities or plant operations, if necessary.

Routes and Exits

Most employers create floor diagrams with arrows that designate all exit route(s). These diagrams should include locations of exits, assembly points, and equipment (such as fire extinguishers, first aid kits, automated external defibrillators (AEDs), and spill kits) that may be needed in an emergency.

Exit routes must be:

For more information on exit routes, required heights and widths for ceilings and exit routes, and door access and hinges, see Design and Construction Requirements for Exit Routes .

evacuation map

When preparing drawings that show evacuation routes and exits, employers should post them prominently for all workers to see. See OSHA's floor plan diagram example and OSHA's interactive floor plan demonstration for more information.

The Maintenance, Safeguards, and Operational Features for Exit Routes section of OSHA's Evacuation eTool provides additional information about exit route safety.

What should Employers Do Before and During an Emergency Evacuation?

When there is an emergency, getting workers out of buildings (including high-rise buildings) may pose challenges. Preparing in advance to safely evacuate the building is critical to the safety of workers who work there.

Before an emergency occurs:

Some businesses may be required to establish Emergency Action Plans meeting certain requirements (see 29 CFR 1910.38 and OSHA's compliance policy for emergency action plans and fire prevention plans, CPL 2-1.037 , for more information).

When an emergency occurs:

What should Workers Know Before and Do During an Emergency Evacuation?

What should workers know before an emergency occurs?

What should workers do when an emergency occurs?

What should workers do if trapped?

This section covers only some of the basic considerations for safe evacuation. High-rise buildings may have unique characteristics involving location, design, construction, and occupancy to be taken into consideration. This information is not a substitute for a site-specific evacuation program nor does it detail specific OSHA or OSHA-approved State Plan standards that may be applicable to individual work sites.

OSHA's " Evacuating High-Rise Buildings " Fact Sheet provides all of these tips in a downloadable format.

Employers should also be familiar with the consensus standards of the National Fire Protection Association (NFPA) and other standards-setting organizations such as the International Code Council (ICC) and the International Organization for Standardization (ISO) . These organizations provide additional recommendations and requirements on evacuations and emergency planning. Furthermore, there may be additional state and local fire and building codes that employers must follow. Visit their websites for more information.

Evacuation Procedures on Construction Sites or Non-Fixed Facilities

Typical construction site locations and the workers on such job sites are constantly changing, which in turn poses unique challenges during emergency evacuations. In this section, there are some specific emergency evacuation procedures for construction sites. An evacuation plan should meet the requirements of OSHA's Employee Emergency Action Plans standard ( 29 CFR 1926.35 ).

Construction employers subject to 29 CFR 1926.35 (including at multi-employer worksites) are required to establish a plan for the types of evacuation to be used in an emergency. Every attempt should be made to ensure that all exposed employees are safely evacuated in the event of an emergency. Employers subject to 29 CFR 1926.35 must designate and train personnel to assist in the safe and orderly emergency evacuation of employees.

All employers should ensure:

Effective method(s) of alerting and communicating with workers is a critical element on construction sites. These communication methods must be understood by all workers. It is recommended that employers train and drill workers (including contractors) and volunteers on these emergency communication methods and procedures to reduce injuries and fatalities, thereby saving lives on the job site.

Types of Alarm Systems that may be used on a construction site include:

An emergency action plan on a construction site must be developed but may also require modification as conditions at the worksite change. All workers should be adequately trained on the importance of effective communication during emergencies, including those involving worksite evacuations. Training should be provided when the workers are initially assigned to the site and whenever there is a change on the site, which would affect the plan.

Assisting Visitors and Workers to Evacuate

Many employers designate individuals as evacuation wardens to help move workers from danger to safe areas during an emergency. Generally, one warden for every 20 workers should be adequate, and the appropriate number of wardens should be available at all times during working hours.

photograph of man quickly walking down stairs or an escalator

Wardens may be responsible for checking offices, bathrooms, and other spaces before being the last person to exit an area. They might also be tasked with ensuring that fire doors are closed when exiting. All workers designated to assist in emergency evacuation procedures should be trained in the complete workplace layout and various alternative escape routes if the primary evacuation route becomes blocked.

Workers designated to assist in emergencies should be made aware of workers with special needs (who may require extra assistance during an evacuation), how to use and instruct others to use the buddy system, and any hazardous areas to avoid during an emergency evacuation. Special tools such as evacuation chairs are available and may be used to assist workers with special needs.

Visitors also should be accounted for following an evacuation and may need additional assistance when exiting. Some employers require all visitors and contractors to sign in when entering the workplace; employers then use this list when accounting for all persons in the assembly area. The hosts and/or area wardens, if established, are often tasked with helping visitors safely evacuate.

OSHA recommends that employers coordinate their action plan with other employers that share the same worksite.

Workers Who May Remain at the Worksite Before Evacuating

Some businesses may require designated workers to remain behind briefly to operate fire extinguishers or shut down gas, electrical, and other systems or special equipment that could be damaged or create additional hazards to emergency responders (such as releasing hazardous materials) if left operating. Employers may be required to comply with OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard ( 29 CFR 1910.120 ) when workers are expected to perform shut down processes.

Each employer must review its business operations and processes and determine whether total and immediate evacuation is possible for various types of emergencies, or whether shutdown procedures are necessary. The preferred approach, and the one most often taken by small businesses, is immediate evacuation of all workers when the decision is made to evacuate. Larger industrial operations may have special fire brigades or emergency response units trained to undertake shutdown and other emergency procedures when other workers need to evacuate.

All workers remaining behind must be capable of recognizing when to abandon the operation or task and evacuate before the egress (exit) path is blocked. In small establishments, it is common to include in the plan locations where utilities (such as electrical and gas) can be shut down for all or part of the facility, by either workers or emergency response personnel.

Accounting for Workers after an Evacuation

To ensure the fastest, most accurate accountability of all workers, consider including these steps in the workplace emergency evacuation plan:

Personal Protective Equipment during Evacuations

Workers may need PPE in order to protect themselves from hazards during an emergency evacuation. PPE must be based on the potential hazards in the workplace. Assess the workplace to determine potential hazards and identify the appropriate controls, including PPE, for those hazards. PPE may include items such as:

*Respirators selected must be appropriate to the hazards in the workplace, meet OSHA standards' criteria, and be certified by the National Institute for Occupational Safety and Health (NIOSH) ( 29 CFR 1910.134(d) ).

OSHA's Safety and Health Topic page on Personal Protective Equipment provides information on PPE for various hazards across a range of industries and links to relevant OSHA standards and more specific Safety and Health Topic web pages.


Chemical, biological, or radiological contaminants may be released into the environment in such quantity and/or proximity to a place of business that it is safer to remain indoors rather than to evacuate workers. Such releases may be either accidental or intentional.

Examples of situations that might result in a decision to institute shelter-in-place include an explosion in a nearby ammonia refrigeration facility or a derailed and leaking tank car of chlorine. In many cases, local authorities will issue advice to shelter-in-place via TV or radio.

When planning to shelter-in-place as part of an emergency plan, keep the following in mind:

Shelter-in-Place means selecting an interior room(s) within a facility, potentially with no or few windows, and taking refuge there.

Shelter-in-Place Procedures

Specific procedures for shelter-in-place at a worksite may include the following:

Employers should also be familiar with the consensus standards of the National Fire Protection Association (NFPA) and other standards-setting organizations such as the International Code Council (ICC) and the International Organization for Standardization (ISO) . These organizations provide additional recommendations and requirements on shelter-in-place and emergency planning. Furthermore, there may be additional state and local fire and building codes that you must follow. Visit their websites for more information.

Additional Information and Resources:



Assistance for Small Businesses

OSHA's On-site Consultation Program offers free and confidential advice to small and medium-sized businesses in all states across the country, with priority given to high-hazard worksites. On-site Consultation services are separate from enforcement and do not result in penalties or citations. Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice on compliance with OSHA standards, and assist in establishing injury and illness prevention programs. To locate the OSHA On-site Consultation Program nearest you, call 1-800-321-6742 (OSHA) or visit the small business web page .

OSHA State Plans

There are twenty-eight OSHA-approved State Plans , operating state-wide occupational safety and health programs. State Plans are required to have standard and enforcement programs that are at least as effective as OSHA's and may have different or more stringent requirements.

OSHA staff provided technical assistance to other federal, state, and local agencies during the response and recovery efforts in the aftermath of Superstorm Sandy in 2012

Response organizations (i.e., entities responding to an emergency) typically have ways to protect their workers from foreseeable emergencies. However, some emergencies or disasters overwhelm the safety and health capabilities of response organizations because of the severity of the hazards, the geographic area, and/or the number of workers needed for the response. When large-scale emergencies occur, OSHA can be a critical resource to help response and recovery organizations protect their workers

OSHA's primary authority comes from powers assigned to the Secretary of Labor in the Occupational Safety and Health (OSH) Act of 1970 (Pub. L. 91-596). OSHA standards are codified in various parts of Title 29 of the Code of Federal Regulations. The OSHA Law & Regulations page provides additional information about the OSH Act and OSHA standards.

While the OSH Act itself generally applies to private sector employers, it allows states to assume responsibility for occupational safety and health for private sector employers and workers, as well as state and local employers and workers in the state.

OSHA can be activated by the Department of Homeland Security (DHS) Federal Emergency Management Agency (FEMA) to lead implementation of the National Response Framework (NRF) Worker Safety and Health Support Annex to protect the safety and health of response and recovery workers. Under this Annex, OSHA has the authority to provide technical assistance and support to local, state, federal, tribal, territorial, and insular area agencies.

OSHA and the cooperating agencies listed in the Worker Safety and Health Support Annex can assist such agencies with:

Under the National Contingency Plan , OSHA, as the Department of Labor's representative on the National Response Team (NRT) and Regional Response Teams (RRT) , provides technical assistance and support, resources, and coordination on preparedness, planning, response and recovery activities for emergencies involving hazardous substances, pollutants and contaminants, oil, and weapons of mass destruction in natural and technological disasters and other environmental incidents of national significance. Section 300.175 of the National Contingency Plan details OSHA's responsibilities under the plan.

quick card screen capture

OSHA Resource

The " Emergency Response: Protecting Worker Safety and Health Under the National Response Framework " QuickCard™ describes OSHA's activities during emergency response operations.

As disaster response efforts transition to recovery work, the National Disaster Recovery Framework (NDRF) provides context for how the whole community—including OSHA—works together to restore, redevelop and revitalize the health, social, economic, natural and environmental fabric of the community.

Under the authority of the OSH Act and the other planning frameworks in which it operates, described above, OSHA can provide coordination, technical assistance, and support from the National Office in Washington, DC, regional offices, and area offices across the nation. Additionally, OSHA has a Specialized Response Team (SRT) that maintains and rapidly deploys with special response equipment and incident management skills, and provides technical expertise in worker protection during incidents. Specific technical expertise and support capabilities of the SRT include: toxic chemicals (including chemical warfare agents), biological agents, ionizing and non-ionizing radiation, collapsed structures, demolition, and other construction-type activities.

During disaster response and recovery operations, even when OSHA is operating in a technical assistance and support mode, OSHA standards remain in effect and OSHA retains its ability to enforce the OSHA standards under the OSH Act. Enforcement of OSHA standards follows the jurisdiction in place before the emergency, such as in states operating OSHA-approved occupational safety and health programs called State Plans. There are 28 states and U.S. territories with OSHA State Plans . State Plans have and enforce their own occupational safety and health standards that are required to be at least as effective as OSHA's but may have different or additional requirements. OSHA's federal offices provide coordination, technical assistance, support services, and oversight in all 50 states, U.S. territories, and the District of Columbia.

OSHA's On-site Consultation Program offers free and confidential advice to small and medium-sized businesses in all states across the country, with priority given to high-hazard worksites. On-site Consultation services are separate from enforcement and do not result in penalties or citations. Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice on compliance with OSHA standards, and assist in establishing injury and illness prevention programs. To locate the OSHA On-site Consultation Program nearest you, call 1-800-321-OSHA (3742) or visit OSHA's small business web page .

Additionally, OSHA Compliance Assistance Specialists , located in OSHA area offices throughout the nation, can provide information to workers and employers about OSHA standards, educational programs on specific hazards or OSHA rights and responsibilities, and additional compliance assistance resources. Compliance Assistance Specialists also promote OSHA's training resources and the tools available on the OSHA web site.

Note: This page discusses Personal Protective Equipment (PPE) for emergency response and recovery workers, particularly those responding to natural disaster and chemical (including oil), biological, radiological and nuclear (CBRN) events. The page is not intended to address PPE for all emergency response situations, including certain operations specific to law enforcement, firefighting, and emergency medical personnel.

Introduction to PPE for Emergency Response Workers

Worker exposures to many types of hazards can be prevented or minimized by using engineering controls, administrative controls, and safe work practices. When controls are not feasible, or when such controls are insufficient to reduce worker exposures to certain hazards to or below safe levels (e.g., an OSHA permissible exposure limit [PEL] or other recognized limit), employers must ensure that their workers are provided at no cost and correctly use appropriate PPE. PPE is only one component of a comprehensive worker protection program, and, by itself, does not eliminate a hazard. For PPE to be effective, workers must properly put on, use, and take off appropriate equipment.

Employers of emergency response and recovery workers are responsible for ensuring that their workers have and properly use PPE when necessary. PPE can include respiratory protection, protective clothing, and protective barriers used to protect workers from exposure to chemical (including oil), biological, radiological and nuclear (CBRN) materials and other hazards. The selection of PPE is based on anticipated hazards and PPE selection may need to be modified as a result of monitoring and assessing actual working conditions. In planning for worker PPE needs, employers should consider the full range of a particular hazard a worker may experience (e.g., respirator cartridges suitable for both chemical and particulate exposures even if workers may only need protection from particulates most of the time).

Different types and levels of PPE may be used depending on the specific hazard or hazards present. PPE also may be needed to protect workers from other hazards, such as electric shock hazards or hazards associated with exposures to hazardous substances that may be encountered during emergency response and recovery operations.

The following are some of the important steps employers with emergency response and recovery workers need to take with respect to PPE:

It is crucial that employers plan in advance of an emergency for the PPE needs of their workers. During and immediately after an emergency, there may be limited supplies of PPE available for purchase, so it is important to have the necessary PPE on hand in advance. In an emergency situation, employers may have little or no time to train or fit workers (e.g., perform fit testing for respirators) for certain types of equipment, so it can be critical to have those tasks completed before an emergency occurs.

Selecting PPE for Emergency Response Workers

In selecting PPE for workers, employers should match the PPE to a worker's specific job tasks and working conditions. Select PPE based on a thorough hazard assessment at the worksite. Consider the durability of PPE materials, such as tear resistance and seam strength, in relation to the worker's tasks. Evaluate other aspects of PPE use, including its impact on heat stress, length of time a worker is able to wear a specific combination of equipment, the physical condition of the worker, demands of the specific work activity, and any effects on worker mobility or dexterity. In some cases, layers of PPE may be necessary to provide sufficient protection.

Combinations or ensembles of PPE are classified generally into four levels, ranging from the most protective (Level A) to the least protective (Level D). Each level of PPE, described in the table below and detailed in Appendix B of the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120), consists of a combination of protective equipment and clothing that help reduce respiratory, eye, skin, and other types of exposures. The table includes a description of the respiratory protection devices associated with each PPE level. However, respiratory protection also is discussed in greater detail in the "Respiratory Protection" [anchor link to section below] section of this page.

Four Levels of PPE

In addition to items listed in the table above, other types of PPE may be added, including but not limited to eye protection, hearing protection, fall and falling object protection, high visibility clothing, or U.S. Coast Guard-approved personal flotation devices, depending on anticipated hazards and specific worker tasks. OSHA's Safety and Health Topic page on Personal Protective Equipment provides information on PPE for various hazards across a range of industries, and links to relevant OSHA standards and more specific Safety and Health Topics web pages. These pages may help employers and workers identify the types of PPE necessary to prevent and reduce exposure to specific chemical, biological, radiological, electrical, and physical hazards.

Employers should also be familiar with the consensus standards of the National Fire Protection Association (NFPA) and other standards-setting organizations, as these may provide additional recommendations about PPE selection and use.

During an emergency involving a release of a hazardous substance, emergency response workers conducting operations outside of the contaminated areas, but who are anticipated to have contact with contaminated victims, may require Level C or D PPE. PPE selection may depend on a worker's anticipated proximity to the contamination zone perimeter, as well as anticipated contact with other potential sources of contamination (e.g., victims, other workers, or materials and equipment coming from contaminated areas). These workers may include healthcare professionals in hospitals or clinics receiving and treating patients from the site of an emergency or the surrounding contaminated areas. The OSHA Best Practices for Hospital-Based First Receivers of Victims document provides guidance in this area. Appendix B of the HAZWOPER standard ( 29 CFR 1910.120 ) also provides information about PPE levels and compliance with PPE requirements during emergency response operations.

Whenever an emergency event involves environmental contamination, the incident commander or unified command staff should communicate to workers and employers the boundaries between contaminated and uncontaminated areas. Employers should be aware that movement of workers, equipment, and members of the public between contaminated and uncontaminated areas may result in low levels of contamination outside of established boundaries.

Additional resources for assistance with PPE selection include:

If workers provide their own protective equipment, employers must ensure that the equipment is adequate to protect the worker from hazards at the worksite and properly used at all times. Employers also must ensure that the equipment is properly maintained and decontaminated after/between use(s). Paragraph (h) of the Respiratory Protection standard ( 29 CFR 1910.134 ) and paragraphs (a) and (b) of the PPE standard ( 29 CFR 1910.132 ) outline this requirement.

Respiratory Protection

Operations that expose workers to harmful levels of particulates, chemical vapors, biological agents, and other airborne contaminants require implementation of a comprehensive respiratory protection program that meets the requirements of the Respiratory Protection standard ( 29 CFR 1910.134 ). Respiratory protection may also be necessary if workers must pass through or may encounter toxic atmospheres (such as dust, mists, gases, or vapors) or oxygen-deficient areas, including while conducting rescue operations and during evacuations. Respiratory protection programs require fit testing and training for workers, medical evaluation and monitoring and selection of appropriate respirators (and cartridges, if required).

Several categories of respiratory protection devices (i.e., respirators) are available to protect workers from inhalation hazards. The table below describes some of these categories.

Use respiratory protection specifically approved by NIOSH for CBRN exposures during such events, if possible. If NIOSH-approved CBRN-specific respirators are not available, the incident commander may allow alternative NIOSH-approved respirators. The table of assigned protection factors (Table 1) of the Respiratory Protection standard (29 CFR 1910.134) may help employers select appropriate respirators for particular operations.

Specifically for CBRN events, there is additional guidance on respiratory requirements in OSHA's Safety and Health Information Bulletin on CBRN Escape Respirators (SHIB 03-08-29 (A). Also, the National Institute for Occupational Safety and Health (NIOSH) has a fact sheet to help respiratory protection program administrators, safety officers, managers, and APR wearers understand the special features of a NIOSH-approved CBRN APR: What's special about Chemical, Biological, Radiological, and Nuclear (CBRN) air-purifying respirators (APR)?

OSHA's Respiratory Protection eTool and Respiratory Protection Safety and Health Topics web page provide additional information about selection and use of various types of air-purifying respirators and other respiratory protection equipment. Several OSHA training videos cover fit testing, maintenance and care, and other important aspects of respiratory protection program management.

Note that surgical masks are not designed or approved for protection against particulates or chemical vapors. In some situations, such as during outbreaks of communicable diseases, surgical masks may help to reduce transmission to other people when worn by infected individuals.

PPE Requirements in OSHA Standards

Emergency responses to hazardous substance releases are covered under OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard ( 29 CFR 1910.120 ). Recommended PPE in the OSHA/NIOSH PPE Selection Matrix for Emergency Responders is selected to meet the requirements of this standard and Subpart I (Personal Protective Equipment). In order to use the guidance effectively, an employer must assess the risk of a hazardous substance release to the emergency response workers and base PPE selection on that risk.

State Standards

There are 28 OSHA-approved State Plans , operating state-wide occupational safety and health programs. State Plans are required to have standard and enforcement programs that are at least as effective as OSHA's and may have different or more stringent requirements.

Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970 , often referred to as the General Duty Clause, requires employers to "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees." This section may be used to address hazards for which there are no specific standards (e.g., exposure to certain biological or chemical agents).

Paragraph 11(c) of the OSH Act prohibits employers from retaliating against workers for raising concerns about safety and health conditions. OSHA encourages workers who suffer such discrimination to submit a complaint to OSHA . Such complaints must be filed within 30 days.

Depending on the specific work task, setting, and exposure to various hazards, additional OSHA standards may also apply. The list below includes general industry standards that commonly apply to emergency response and recovery operations. However, employers in the construction ( 29 CFR 1926 ); shipyard, maritime, and longshoring ( 29 CFR 1915, 1917, and 1918 ); and agriculture ( 29 CFR 1928 ) industries should be familiar with the OSHA standards that cover their workers, including those for HAZWOPER, PPE, and respiratory protection. In particular, standards for the construction industry are likely to apply during demolition, rebuilding, and other aspects of recovery following a disaster or other emergency event.

General Industry ( 29 CFR 1910 )

Worker Protection during High-Hazard Emergency Operations

Certain emergency operations may require balancing worker protection with the need to conduct critical missions, such as those necessary for life-saving or critical infrastructure protection. In these instances, an employer should work with the incident commander , unified command staff , and other health and safety personnel to limit worker exposures to all hazards through a combination of engineering and administrative controls and safe work practices, supplemented by PPE.

Emergency response organizations should coordinate with employers in their jurisdictions to ensure they are prepared to respond to and safely perform rescue operations as needed at worksites that may pose unique or particularly hazardous conditions for emergency responders. This may include preparing, training, and exercising capabilities for response and rescue operations at steep angles or heights, such as in pits, tanks, manholes, boilers, furnaces, silos, hoppers, vaults, pipes, ducts, and bins or on slopes, communication towers, or other tall structures, including those under construction; in confined spaces, trenches, or underground; and over, near, or in water of various depths. Such operations may require special engineering and administrative controls, work practices, and PPE to protect emergency response and recovery workers. Employers may need to select and provide workers with, for example, special safety harnesses, ropes or cables, and respirators and cartridges appropriate for the hazards they may encounter. As always, PPE should be used as the final level of protection in the hierarchy of engineering (e.g., ventilating equipment, barriers, shields) and administrative controls and safer work practices.

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The Corporate Emergency Response Plan: A Smart Strategy

By David B. Graham , Environmental Law

In the classic book  The Art of War , Sun-tzu outlines well thought out strategies, tactics, and principles in order to minimize casualties while effectively and efficiently gaining the advantage over the enemy. Similarly, corporate emergency response planning provides well thought out strategies, tactics, and principles in order to minimize losses while effectively and efficiently gaining the advantage over a crisis. Often thought of as a governmental function, it is wise for corporate executives to rely on a properly prepared and comprehensive emergency plan when a crisis unexpectedly threatens their company, their people, the environment, and perhaps even their jobs.

Although an Emergency Response Plan (Plan) works in concert with government responders, the corporate Plan addresses issues that are beyond the concern and scope of the government. This includes such objectives as ensuring continuity of business operations, minimizing fiscal losses, protecting assets, being proactive with public relations, preparing for legal matters, anticipating stockholder concerns, and implementing measures to prevent a recurrence. While most corporate executives agree that having a current Plan is prudent, developing and maintaining it is simply considered to be a low priority and is deferred. Executives may rationalize that a catastrophe or other demand for emergency action will not occur on their watch as they turn to seemingly more pressing issues. Additionally, keeping a Plan current requires a commitment of time and perhaps money. But, as we have seen with the  Costa Concordia  grounding, the  Deepwater Horizon  explosion and spill, and the Fukushima Daiichi Nuclear Power Station release, emergencies can quickly happen with devastating results.

Consider the  Deepwater Horizon explosion and Gulf oil spill in April 2010. In a matter of minutes, British Petroleum (BP) found itself facing a situation with 11 employee deaths, 17 injuries, a fire, and an unprecedented oil spill. In the following days as the massive oil spill cleanup began, there were wildlife casualties, property damage, severe economic impacts, and negative publicity, followed by government investigations and inquiries, personal injury, and property damage lawsuits, and the replacement of BP’s Chief Executive Officer Dr. Anthony B. Hayward. It does not take an emergency on the scale of such a major incident, however, to cause a severe impact on a business. Examples abound in every state of natural and man-made incidents that have endangered employees, destroyed property, damaged communities, and threatened a company’s reputation.

Possessing a well-constructed Plan is not the end state; it must be implemented as the incident unfolds. As former chairman of the Nuclear Regulatory Commission (NRC) Richard Meserve said in discussing the Fukushima reactor disaster, while emergency planning was not adequate, “The existing plans were not followed.” Peter Behr, Chaos Among Officials Bedeviled Japan During 2011 Tsunami Disaster , Scientific American, Mar. 1, 2012. Executives simply cannot “wing it” when a crisis erupts. An excellent example of this is the successful ditching of US Airways flight 1549 in the Hudson River in January 2009. Even skillful Captain Chelsey B. Sullenberger and First Officer Jeffrey B. Skiles used the aircraft’s Engine Dual Failure Checklist to ensure that they were performing every possible procedure during the few minutes between the bird strike and the aircraft’s ditching. It is noteworthy that despite this unique ditching of the Airbus320 with 155 people aboard, no fatalities, no pollution and no litigation ensued. National Transportation Safety Board Report of Aircraft Accident “Loss of Thrust in Both Engines After Encountering a Flock of Birds and Subsequently Ditching on the Hudson River,” NTSB/AAR-10/03.

The lack of a well thought out plan can lead to highly serious consequences. In September 2010, A pacific Gas and Electric (PG&E) natural gas pipeline exploded in San Bruno, California, resulting in eight fatalities, injuries to fifty-eight people, and damage or destruction to 108 houses. The investigation by the National Transportation Safety Board revealed that PG&E lacked a detailed plan for responding to large-scale emergencies, including a defined command structure. Thus, it took PG&E more than ninety minutes to stop the gas flow, during which time firefighters were unable to battle the blaze. This time frame “was excessively long and contributed to the extent and severity of property damage and increased the life-threatening risks to the residents and emergency responders.” “Pacific Gas and Electric Company Natural Gas Transmission Pipeline rupture and Fire,” NTSB/PAR-11/01. Because of the deaths and destruction to the community, PG&E has agreed to provide up to $50 million to the city of San Bruno for infrastructure repairs and other costs of rebuilding the neighborhood plus another $70 million as restitution. In addition, despite PG&E’s acceptance of financial responsibility, residents have elected to pursue punitive damages by continuing with ninety civil lawsuits that are set for a July 2012 trial in San Mateo County court. Additionally, the California Public Utilities Commission is considering financial penalties for failure to comply with pipeline safety rules. If PG&E had promptly executed their Plan, some of the settlement costs and fines may have been mitigated and fewer lawsuits may have resulted.

Several other logical and compelling reasons stand out for developing and maintaining a Plan. A well-constructed Plan will facilitate shutdown and evacuation, thus reducing injuries or fatalities. It will ensure that employees and visitors are accounted for and confirm that all the right people are notified. As a result, the possibility of workers’ compensation claims or personal injury litigation from employees as well as third parties should be reduced or eliminated.

Given that executives and managers are infrequently faced with responding to a crisis, the Plan prompts the leader to act methodically and orchestrate a tailored response. The Plan enables the leader to focus on the most urgent priorities. Plans for Fortune 500 companies often take an umbrella approach that included corporate-wide guidance as well as local instructions for each subsidiary. Not surprisingly, businesses that have a Plan have reported significantly shorter incident durations than companies without one. Conversely, those entities without a Plan experienced crises lasting approximately two-and-a-half times longer than those who invested in preparing one. Steven Fink, Crisis  Management: Planning for the Inevitable, 67  (2002).

A comprehensive Plan will prepare senior management to deal with the multiple simultaneous demands that accompany an incident. Hazardous material (HAZMAT) releases into the air, water, and ground often occur concurrently. They may need to contain physical damage, notify families of deceased employees, and inform news media, employees, shareholders and investigators. While providing too much information to any of these interests could be incriminatory during any follow-on litigation, the company’s reputation could be equally damaged if it is perceived to be manipulating or withholding information. Thus, following a well thought out Plan can be the key to the public’s perception of the incident and the company’s long term reputation. As an example, the chief executive officer of Ashland Oil was well prepared and took a proactive approach when an oil storage tank collapsed into the Monongahela River near Pittsburgh in 1988, thus enhancing the company’s reputation as a responsible corporation despite the substantial petroleum release.

Beyond the commonsense reasons, having a Plan may be legally required. Companies that store, transport, or manufacture certain quantities of hazardous materials or petroleum products or that operate certain facilities are required by U.S. federal law to have a Plan. The Clean Water Act, the Clean Air Act, the Resource Conservation and Recovery Act, the Comprehensive Environmental Response, Compensation and Liability Act, the Hazardous Materials Transportation Act (HMTA), The Oil Pollution Act of 1990,.U.S. Coast Guard regulations, Nuclear Regulatory Commission regulations, and Occupational Safety and Health Administration (OSHA) regulations require preparation and adoption of some form of a Plan for companies that meet certain criteria. Many of these regulations contain very specific Plan requirements such as required training, notification of authorities, emergency medical treatment, employee counts, evacuation procedures, and emergency response equipment. Some facilities (e.g., those subject to section 112(r) of the Clean Air Act), are required periodically to review and update their Plans and even notify their employees of any changes (40 C.F.R. §68.95). OSHA regulations also require Plans to be updated based on certain criteria and reviewed with each employee (29 C.F.R. §1910.38). For companies storing certain levels of hazardous materials, having plans to interact with the community and to share information regarding specific materials on hand is a requirement of the Emergency Planning and Community Right to Know Act (42 U.S.C. § 11003). This information will assist public agencies in preparing to respond to the potential release of hazardous substances. For facilities that handle oil above specific thresholds, a Spill Prevention Control and countermeasures Plan is required by the U.S. Environmental Protection Agency (EPA) (40 C.F.R. § 112). Depending on the type of facility, planning for worst-case scenarios is encouraged. A Plan maybe even required by treaty. As a result of the Titanic disaster, the International Safety of Life at Sea (SOLAS) treaty requires several safety measures, including a fire-control plan for certain vessels. The International Convention for the Prevention of Pollution from Ships (MARPOL), adopted by 150 nations, requires a shipboard oil pollution Plan as well as immediate reporting of any discharge of oil, harmful substances, or noxious liquids.

It is prudent to incorporate other legal requirements into a Plan to serve as a safeguard against unwillingly violating the law in the midst of a hectic response. For example, under the Department of Transportation regulations, pipeline operators are required to conduct drug and alcohol testing of employees within 32 hours of an incident. Also, a spill of certain HAZMAT substances over specified thresholds must be reported to the National Response Center within 12 hours of the spill, and a written report of the incident must b prepared. Additionally, all coal mining incidents are required to be investigated by the owner with a determination of the cause and the means of preventing a recurrence (30 U.S.C. § 813(d)). States also have unique requirements that should be incorporated into the Plan. For example, in Pennsylvania, regulations for the Clean Streams Law require that either the person spilling a pollutant into surface or groundwater or the person owning the premises must immediately notify the state Department of Environmental Protection. Because there is no reportable quantity, all spills into ditches, drains, or sewers are within the scope of this law. For international companies, the laws of the nation in which the company’s facility is located should be incorporated into the Plan. Canada’s emphasis tends toward fire safety, whereas China’s safety focus is on the nuclear arena. Germany concentrates on being environmentally responsible. The variety of these national laws contributed to the complexity of a Plan developed by the authors for a Fortune 250 company with international facilities. Thus, extreme care must be taken to craft each Plan to comply with these national laws. Whether the applicable law is federal, state, another nation’s, or a treaty, the midst of the crisis is clearly not the time to be conducting legal research.

Principles for Developing a Plan

Several important principles provide the foundation for constructing a solid Plan. First, there must be a designation of an on-site decision-maker. This incident director must be someone who is capable of making quick, rational decisions with the best information available at the moment. They must understand that decisiveness trumps the perfect decision, while also recognizing that some decisions may be irreversible. While this person could be the president, chief executive officer, or chief operating officer, it also could be anyone else who has the skills to manage multiple issues in a demanding environment. The designated person must possess strong leadership attributes, have an intimate knowledge of the business, possess the ability to evaluate risks versus benefits, be familiar with employees’ capabilities, and have the acumen to deal with the press. An understanding of the community and the environment is also beneficial.

Second, disaster preparedness at the individual or personal level must be emphasized as well and preferably from the executive tiers down. This emphasis on “at home” preparedness (in addition to “at work” preparedness) is founded upon both a moral concern for the well-being of all employees and the desire to ensure that employees who are assigned to the company’s emergency response crews are well prepared for action. As illustrated by the absence of dozens of New Orleans Police Department officers following hurricane Katrina, employees who are not personally prepared will be consumed in personal and family issues that will likely restrict their ability to report to work.

The third principle is that there must be a “Plan B.” Redundancy with respect to people, equipment and systems is critical. For example, due to the unavailability of the Toyko Electric Power company’s chairman and president until 10 a.m. on the day after the tsunami struck in March 2011, which was the most critical period, the electric company “was consequently unable to make prompt organizational decisions and wound up losing the government’s trust with regard to information sharing and decision making.” Yoichi Funabashi and Kay Kitazawa, Fukushima in review: A complex disaster, a disastrous response , Bulletin of the Atomic Scientists, 4 (Mar. 1, 2012). Because communications are the backbone of emergency response, the Plan should provide for a backup system in the event of a communications outage or computer failure. A communications failure may cause emergent incidents to deteriorate, as illustrated on several levels with Hurricane Katrina. Redundancy also applies to such assets as databases, power, vehicles, and the emergency operations center itself. While decisions regarding whether to have a redundant system or equipment will be subject to an evaluation of cost versus benefit, having a “Plan B” can turn a potentially major problem into a minor event.

Fourth, certain standard policies must be waived or streamlined during an emergency. Those policies should be articulated along with the conditions under which they will be waived and the designated individual who may grant the waiver. Streamlined emergency policies need to be “on-the-shelf” prior to the incident. After the incident, the policies should be evaluated to determine how well they worked and then modified as necessary. The parameters of a bona fide emergency policy should be clearly and succinctly stated, with internal controls articulated in writing to prevent abuse.

A fifth principle is to establish an emergency response organization that parallels the company’s current organization. People who normally work with each other and know their colleagues will work together more efficiently. One exception is that the company should leverage the hidden talents of its people. Many employees have previous careers or specialized training that may be totally different than those used in their current jobs. These specialized skills may make them more valuable in selected emergency response positions.

The final principle is to understand the capabilities of external organizations that might assist during an incident. These include the fire department, ambulance service, hospital, Red Cross, law enforcement, state department of natural resources, state emergency management agency, Federal Emergency Management Agency, EPA, Nuclear Regulatory Commission, or U.S. Coast Guard, and private firms such as HAZMAT cleanup contractors and construction contractors, construction contractors, and security firms. Maintaining a list of local counselors or instituting an employee assistance program may prove beneficial for post-trauma counseling.

The Enemies of a Plan

Executives need to understand the enemies of the Plan (i.e., those forces that will undermine its effectiveness). The first enemy on our list is the hollow plan. This document is a result of a cut-and-paste from another plan and is often used when there is a requirement from government regulators or a partnering company for a Plan. This approach results in a “form over substance” document with no top management support. One example of this is BP’s Deepwater Horizon Plan that depended upon “proven equipment and technology” that reportedly did not exist. Furthermore, BP’s Plan allegedly referred to Arctic wildlife and provided incorrect contact information for oil spill engineers. In re: Oil Spill by the Oil Rig “Deepwater Horizon” in the Gulf of Mexico, on April 20, 2010 , No. 2:10-md-02179-CJB-SS (E.D. La.), First Am. Master Compl. “B1 Bundle” paras. 482-483, ECF No. 1128 (Feb. 9, 2011).

The second enemy is basing a Plan on invalid assumptions. Valid assumptions are foundational to a Plan and need to be thoroughly vetted. For example, the Japanese Nuclear Safety Commission did not include provisions for an extended loss of power in its accident-management policy. On the contrary, its premise was that electric transmission lines or emergency power capability would be restored quickly. The reality was that the Fukushima power plant was without power for six days requiring workers to develop inefficient workarounds. Funabashi and Kitazawa, supra  at 4-5.

The third enemy is normalcy bias – the rationalization that the scenario is not as bad as it actually is. Normalcy bias was demonstrated by the statements of BP’s ousted CEO, when he stated that ‘the Gulf of Mexico is a very big ocean. The amount of volume of oil and dispersant we are putting into it is tiny in relation to the total water volume.’ Normalcy bias is further exemplified by the response by the Costa Concordia  crew. After the ship struck the rock near Giglio Island, passengers were allegedly told by the crew to return to their staterooms. About an hour passed before the order to abandon ship was issued, possibly contributing to the loss of thirty-two lives as well as the $570 million vessel. Thus, normalcy bias will delay critical actions and place the response team behind the power curve; a position from which it is unlikely to recover.

The fourth enemy is misinformation. During a shocking event, people see and perceive different things. During the San Bruno natural gas pipeline explosion, there were reports of an aircraft crash. The fact that the explosion was about three miles from San Francisco International Airport may have lent plausibility to the reports. But such misinformation can cause delays in responding or response with the wrong resources.

The fifth enemy is failing to customize an emergency response plan template. Although templates are useful and may promote efficiency in developing a Plan, there can be an overreliance on the template. Because of the unique features of any particular facility, the Plan must be customized for the corporation and each facility. The omission of specific details such as the organization chart, management phone numbers, local or international requirements, and reporting criteria will promote errors, omissions, and confusion.

The last enemy is failing to keep a Plan up to date. People move, technology changes, and corporate structures morph. The Plan must be updated with even minute details such as a telephone number change. Contractors may close their business or change their specialty, and certain personnel certifications such as cardiopulmonary resuscitation (CPR) will expire. For these reasons, a Plan will become obsolete if not updated.

Developing the Plan

To develop the overall Plan, an assessment of the various risks must be conducted that will determine those emergencies the Plan should address. While this is often an A primary key to a successful unconscious step, this a deliberate evaluation is the foundation of the Plan. In addition to the obvious risks such as fire, hurricane, blizzard, or oil spill, the Plan should evaluate other risks that may not normally be associated with an emergency. These are events that can cripple a company and will vary depending on the industry and the location. Examples are supplier or shipper interruption, violent criminal action, Internet service outage, explosion, and alarm failure. The Plan must also include any legal requirements such as notification of authorities. Based on these drivers, policies and procedures can then be developed. In constructing the Plan, one must also ensure that the planned procedures are practical and executable. As demonstrated after the West Virginia Upper Big Branch Mine explosion, management lacked the basic knowledge of how many miners were missing in the mine. A weakness in the accounting of individuals working in the mine resulted in confusion in the command center, criticism of the company over an inaccurate press release, and awkward meetings with families. It took more than nine hours after the explosion to determine the number of miners who were actually missing. J. Davitt McAteer,  et. al., Upper Big Branch, Report to the Governor  37- 39 (May 2011).

It is also vital to craft a streamlined organizational structure for the emergency that identifies key individuals, their functional responsibilities, and their authority to act. An organization that provides for the addition of personnel as an incident grows will be able to meet the expanding informational needs. This is an area that is often overlooked and is yet critical for a well-executed response. Staff must understand how to keep the top decision-maker informed without overwhelming him or her with unnecessary details. Information must flow smoothly, be documented, and cannot “fall through the cracks.” Although this point may appear basic, examples abound of sophisticated organizations that became centers of turmoil when presented with a crisis.

Designating a location as an emergency operations center and promulgating a hard copy of the Plan with comprehensive checklists, facility layouts, organizational charts, phone numbers, and email addresses are essential tasks. It is also recommended that managers have phone numbers and email addresses for key people in their mobile devices since emergencies do not restrict themselves to working hours. For facilities that store hazardous materials, material safety data sheets should be included in the Plan. Another area that is often overlooked is the training and preparation of employees. Personal preparation by employees, especially for incidents such as a hurricane that affect the community, is important from the perspective that employees will not be available for work if they have not personally prepared. In addition, a determination of the level of first-aid response should be made, ranging from maintaining a first aid kit to qualifying staff as emergency medical technicians. Because of the short response time required to treat cardiac arrest, some organizations have invested in Automated External Defibrillators (AEDs) and trained their staffs in AED and CPR. For example, at Kaufman & Canoles, P.C., we have equipped our seven offices with AEDs supported by fifty volunteer lawyers and staff who have been certified in AED/CPR response.

The selection and staging of emergency equipment are especially relevant for industrial facilities. Such assets as fire fighting equipment, HAZMAT cleanup equipment and personal protective clothing must be readily available and well maintained. In certain circumstances, contractual agreements with certain vendors or contractors should be negotiated during the development of the Plan, since the organization will have little leverage to negotiate when faced with the emergency It is also recommended that insurance policies be reviewed for appropriate levels of property and casualty coverage, including business-interruption coverage. A primary key to a successful Plan is to organize the plethora of commonsense steps and the myriad of federal, state, local, or foreign legal requirements into a concise set of policies and actions.

The Three Phases of an Emergency

Experience has proven that organizing the Plan in three chronological phases that set the stage for a comprehensive and efficient response. These phases apply regardless of the size or type of incident.

The Initial Response Phase commences when an individual reports an incident. The Plan will provide a complete checklist to guide the incident director through the myriad of important time-critical actions. If properly followed, a well-designed Plan will facilitate the flow of accurate and timely information, which guards against the aforementioned normalcy bias. Such information is a key component to the successful launch of an effort that dispatches the right people with the right equipment.

Safety must be the top priority for responders as the damage and injury assessment is developed. The incident director and on-scene supervisors must be vigilant about any developing or previously unreported hazards. Additionally, these leaders must keep mind both their ethical responsibility to conduct safe operations as well as the corporation’s culpability should employees be negligently directed to take unsafe actions. If serious injury or death occurs, the next of kin must be promptly and personally notified. On-scene security must also be established to eliminate the potential for theft and to preserve any evidence for later investigation. Photos taken immediately after the event are an excellent way to provide information and investigative evidence.

Depending upon the type and magnitude of the incident, governmental authorities may need to be notified and their assistance summoned. Reporting an incident is not something that should be taken lightly. As an example, the  Costa Concordia’s captain has been charged with failing to inform Italian maritime authorities of the ship’s sinking. Subject to the size and organizational structure of the company, internal corporate notifications may also be required. It may prove necessary to prepare a news release or to arrange a news conference.

While not initially at the forefront of concern, an accounting process may need to be established to track the costs of any urgent procurements. As the incident progresses, failing to track costs could be problematic if not controlled. Given the pace of operations, it is easy to overlook the status of employees who are not engaged in the incident. All decisions and directions for each employee and contractor should be documented.

For several reasons, an internal investigation should commence early in the incident. The incident may expose the entity to criminal or civil penalties. For example, the Clean Water Act calls for a civil penalty of $1,100 per barrel of oil spilled. If the entity is later determined to have acted in a grossly negligent manner, then the exposure increases to $4,300 per barrel. Another reason to organize an investigation is to prevent or minimize the effects of a future recurrence. Depending on the type of incident, a policy change may be needed, additional employee training may be required, or updated equipment may need to be purchased. Regardless, all evidence needs to be gathered and every potential witness needs to be identified. It is also appropriate for the investigation team to notify and work with the company’s insurance agent.

The Cleanup and Recovery Phase keeps the response effort moving forward, initiates cleanup, and commences recovery. In this phase, personnel issues may arise and logistics may continue to be tracked to prevent uncontrolled spending. Temporary or permanent repairs to damaged equipment and buildings may be required. Families of any missing employees must be kept updated while press releases are issued and news conferences are conducted. Sustainable security levels must be maintained and a strategy to resume business must be developed.

The After-Action Phase involves restoring the facility to complete operation and concludes the incident, although any litigation, reconstruction, or insurance claims could continue into the future. The investigation is then completed by management in concert with legal counsel and should include an executive summary supported by detailed facts surrounding the incident. Any observations that are in dispute or contradictions in witnesses’ statements should be expressly stated. The causal factors of the incident should be identified. These factors fall into four primary categories: an Act of God (e.g., hurricane, earthquake), material failure (e.g., equipment failure, alarm malfunction), personnel error (e.g., transportation accident, operator error), or intentional personnel actions (e.g., sabotage, employee negligence, civil unrest). The incident’s cause can also be a combination of any of the aforementioned factors, which may require in-depth scrutiny to uncover. For example, the Fukushima Daiichi Nuclear Power Station release was caused by both an act of God and a series of personnel errors. Funabashi & Kitazawa, supra  at 4.

In anticipation of litigation, observations, opinions and recommendations are often presented in a separate privileged document. Of interest will be supervisory oversight leading up to the incident along with any other impact that the supervisor could have had. The investigation should address possible preventative measures and any interim actions taken. Active or potential litigation from both internal and external sources should be identified in the privileged document.

Lessons learned should be developed and shared with management. If the organization or incident is large, a critique of the Plan should be conducted to identify opportunities for improvement. Post-trauma counseling may be required for personnel with severe injuries or employees who suffered traumatic events, such as experiencing the death of a colleague.

The tangible benefits of a comprehensive Plan are clear. Although it may be difficult to allocate the time required, it only takes one serious incident to eradicate a business reputation, destroy assets, and endanger lives. In the unfortunate event of an incident, the up-front investment in developing the Plan will provide immediate payback, thus more than justifying the effort. Like Captain Sullenberger, when a crisis strikes, a smart executive will take command, implement the Plan, and possibly save the company and even lives.

David B. Graham is a partner with Kaufman & Canoles in Williamsburg, VA who specializes in environmental law. He may be reached at [email protected] .  

“ The Corporate Emergency Response Plan: A Smart Strategy ,” Natural Resources & Environment (ABA Section of Environment, Energy, and Resources) Vol. 27 No. 2 (Fall 2012).

The contents of this publication are intended for general information only and should not be construed as legal advice or a legal opinion on specific facts and circumstances. Copyright 2023.

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How to Make an Emergency Response Plan for Your Office

6 Steps to Creating an Effective Emergency Action Plan

To help ensure the safety and well-being of your employees, take the time to develop a comprehensive emergency response plan. A detailed and well-executed emergency action plan (EAP) can save lives. The actions taken during the first few moments of an emergency are critical. A prompt, well-orchestrated warning can communicate to your employees whether they should evacuate, seek shelter, shelter-in-place, or commence lockdown. Clear warnings coupled with a keen understanding of your EAP can empower your employees to streamline evacuations or lockdowns, offer bystander assistance, and can even help 911 dispatchers and emergency services respond to events more efficiently.

Step 1: Assemble Your Team

The strength of your EAP depends on the commitment of your team. Seek out the participation of your employees — both management and employees — early in the process so that everyone has a say.

Step 2: Conduct a Risk Assessment

Conduct a risk assessment to identify potential hazards and vulnerabilities within your organization. People should always be your first consideration in a risk assessment, but risks to physical assets (buildings, computer systems, machinery, finished products) and the environment should also be included in your assessment.

“As you conduct the risk assessment, look for vulnerabilities—weaknesses—that would make an asset more susceptible to damage from a hazard. Vulnerabilities include deficiencies in building construction, process systems, security, protection systems, and loss prevention programs. They contribute to the severity of damage when an incident occurs. For example, a building without a fire sprinkler system could burn to the ground while a building with a properly designed, installed, and maintained fire sprinkler system would suffer limited fire damage” ( Department of Homeland Security ) .

Step 3: Establish Performance Objectives

Keep yourself on track and accountable. Performance objectives are quantifiable and tangible milestones that you’ll achieve as you develop your emergency preparedness program. Be sure to create objectives for all aspects of your program. Ready.gov , the U.S. Government’s disaster preparedness website, recommends a number of performance objectives. Here are a few of the key recommendations:

Step 4: Create a Written Policy

The Occupational Safety and Health Administration (OSHA) offers a wealth of information about developing an EAP. While the size and scope of your plan will vary based on the size of your company and your industry, OSHA’s minimum requirements suggest that your plan should include the following elements:

FEMA also offers a detailed Emergency Response Plan template to help businesses identify goals and objectives and define exactly what it is an emergency response team needs to do during an emergency.

Step 5: Develop an On-Site Emergency Response Team

Designate cool-headed and well-respected emergency response leaders within your organization to lead evacuation (as necessary), coordinate communication, conduct a headcount and communicate detailed information to 911 dispatch and emergency responders. These team members should also be responsible for making sure that minors, disabled employees, or at-risk residents are safely sheltered or evacuated.

Step 6: Offer Training

Once you’ve identified your emergency response team, it’s up to you to make sure they have the training they need to perform their duties effectively. For an EAP to be effective and to ensure the safety of your employees, you’ll need individuals who can be relied on to respond calmly in an emergency. Build confidence by offering first aid, Stop the Bleed , CPR, and AED training to your entire team. All emergency response team leaders should be required to complete their certifications. For more information on First Aid and CPR training, check out these articles:

Defibtech Lifeline AED and Virtual CPR Training Bundle

Step 7: Practice and Review Your Emergency Action Plan

“Educate your employees about the types of emergencies that may occur and train them in the proper course of action. The size of your workplace and workforce, processes used, materials handled, and the availability of onsite or outside resources will determine your training requirements. Be sure all employees understand the function and elements of your emergency action plan, including types of potential emergencies, reporting procedures, alarm systems, evacuation plans, and shutdown procedures. Discuss any special hazards you may have onsite such as flammable materials, toxic chemicals, radioactive sources, or water-reactive substances” ( OSHA ).

Emergency response plans can help prevent injury and can dramatically minimize damage. However, it’s important to remember that your EAP is only as good as the people who are carrying it out. Every six months, conduct emergency drills and schedule a one-on-one with your in-house ERT members to make sure they’re still up for the job.

To learn more about First Aid and CPR Certification and AED training , AED best practices, AED and defibrillator service and preventative maintenance programs, or LifeShield, our online compliance management program , contact AED.com at 866-349-4362 or email us at [email protected] .

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5 Major Steps to Building a Successful Emergency Response Plan

Emergency Response Plan

Every workplace, whether it’s an office or a construction site or a patient’s home, has its own safety hazards and risks facing the workers and team members. Emergencies are more likely to take place when these safety hazards are not addressed, increasing the potential for an incident to take place that could harm and even kill an employee. 

In many cases, emergencies could have been prevented, or at least mitigated, through proactive planning and assessment of existing and potential safety hazards threatening the team. Such planning can regular updates to organization safety policies and developing a well-researched and staff-informed emergency response plan, which we are going to talk about further. 

What are emergency response plans?  

Emergency response plans are a thoroughly researched and planned policy that instructs employees on how to respond during an incident so that they are not harmed and operations are minimally impacted.  

How to develop an emergency response plan: 5 important safety steps  

Unless you have a real-deal crystal ball, you don’t know if any emergencies are down the road. However, there are a series of five impactful steps in an emergency response plan that you can take to make sure you and your team are ready if something should happen.

1) Assess your safety risks 

Before you look at the objectives of your emergency response plan, you need to know what you’re facing first. Perform a  hazard assessment  of not only the current safety hazards but potential ones as well. A hazard assessment notes every danger facing a specific role, team, work location, or department. If it’s a small organization and company, it may be possible to assess the hazards of the entire team as one unit. 

2) Identify potential emergencies 

Again, it is impossible to predict what will happen down the road but talk to the experienced professionals in your organization to provide insight on emergencies that could possibly take place. For an emergency response plan, also look at the company’s employee incident history and records, as well as any other issues that could be a factor during an emergency such as fragile mental health or complicated, dangerous equipment.  

3) Identify and designate communications 

Reliable communications are essential if you want to react and send help quickly. Within the context of your emergency response plan, you need to look at what communications will take place during an emergency establishing who will be talking to who and how they will be communicating. To help you and the team, develop internal emergency communications plans to detail how everyone within the organization will be notified and instructed during and following an incident. 

4) Assess company safety resources 

Particularly if you work in an industry in which dangerous equipment and tools are regularly used, it is imperative that these tools and equipment are diligently inspected and upgraded or replaced as needed – and all of this documented in an emergency response plan. But there are other resources that need to be monitored and maintained like smoke alarms, fire code inspections as well as simpler, often-overlooked, smaller factors such as stair railings and walkways which can be hazards during the winter. 

5) Training, drills, and exercises 

When sent a new safety policy from your manager, how many of you read it? I mean, actually read and learn from it. Well, if you’re like me, you’re more likely to skim and then read the parts that catch your eye – if that. In order to really ingrain and teach the staff about their roles in an emergency response plan, safety or  first aid training,  and incident drills and exercises must be held on a regular basis to keep them update and engaged. 

Are you ready to get started on your emergency response plan?  

So are do you feel ready, or at least more prepared, to develop an emergency response plan at your organization? Don’t worry, if you still feel insecure planning for something that hasn’t happened yet, it’s normal. What’s important is to work with as many of the team as possible, welcoming and incorporating their feedback and  safety training participation  for a plan that could potentially save their lives in the future. Involve your team in a document that could have a direct impact on their lives and make sure that is communicated to them. 

Additionally, and maybe it doesn’t need to be said, but make sure both the hard and soft copies of your emergency response plan are accessible, 24/7, by all relevant staff and management. Of course, have it available online somewhere, but maybe even encourage staff to print a hard copy should the electricity go out in an emergency. Just make sure everyone is on the same page should something take place, increasing the odds that nobody, staff and operations, will be harmed and recovery will be quick. 

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Emergency Response Plans for Business

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  1. Emergency Response Plan Template for Small Business

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  2. Emergency Response Plan by TheSafetyMaster

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  3. FREE 9+ Sample Emergency Response Plan Templates in PDF

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