Workplace Emergency Action Plans: What OSHA Requires

For most employers in the United States, a workplace emergency action plan is not optional. It is a written requirement under a specific OSHA standard, and the rule sets a clear floor for what the plan must contain. Here is what OSHA’s emergency action plan standard requires, when a written plan is mandatory, and how the strongest organizations go beyond the minimum.

What an emergency action plan is

An emergency action plan, or EAP, is a written document that spells out what employees and managers do during a workplace emergency: how to report it, how to get out, how to account for everyone, and who handles rescue and medical duties. Its purpose is not to satisfy an inspector. It is to make sure a building full of ordinary people can take the right actions in the first minutes of a crisis, before professional responders arrive.

When a written plan is required

The governing rule is OSHA standard 1910.38. It requires a written emergency action plan once an organization has more than 10 employees. An employer with 10 or fewer employees may communicate the plan orally, though writing it down is still worth the hour it takes, because it removes ambiguity during training and during a real emergency.

The six required elements

At a minimum, OSHA requires the plan to cover six things:

• Procedures for reporting a fire or other emergency.
• Procedures for emergency evacuation, including the type of evacuation and exit route assignments.
• Procedures for employees who stay to operate critical operations before they evacuate.
• Procedures to account for all employees after the evacuation.
• Procedures for employees performing rescue or medical duties.
• The name or job title of a person employees can contact for more information about the plan.

The standard also expects an alarm system employees recognize, and it requires the employer to review the plan with each worker when responsibilities change. A related standard, 1910.39, covers written fire prevention plans on similar terms.

Go beyond the floor

The six elements are a minimum, not a goal. Strong organizations treat the written plan as a starting point and then do the work that actually saves lives:

• They assign clear roles in advance, using the same logic as the Incident Command System: someone is in charge, and everyone knows who.
• They drill the plan, time it, and fix what broke before the next exercise.
• They pair life-safety with continuity, so the organization can keep operating after the building empties, which is where a business continuity plan takes over.

A plan that meets 1910.38 on paper but has never been practiced will still produce confusion on the day it is needed. The compliant plan and the capable response are two different things, a point we develop in our guide to workplace emergency preparedness.

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Frequently asked questions

Does OSHA require a written emergency action plan?

Yes, for employers with more than 10 employees, under OSHA standard 1910.38. An employer with 10 or fewer employees may communicate the plan orally.

What must an OSHA emergency action plan include?

Six minimum elements: how to report an emergency, evacuation procedures and routes, procedures for employees running critical operations, how to account for everyone afterward, rescue and medical duties, and a contact for questions about the plan.

What is the difference between an emergency action plan and a fire prevention plan?

An emergency action plan (1910.38) covers how people respond to an emergency. A fire prevention plan (1910.39) covers how the workplace prevents fires, such as controlling fuel sources and maintaining equipment.

General guidance, not legal advice. Confirm your obligations against the OSHA standard or a qualified professional.