Emergency Action Plans and Fire Prevention

OSHA requires employers with more than 10 employees to maintain a written Emergency Action Plan (EAP) under 29 CFR 1910.38. Employers with 10 or fewer employees may communicate the plan orally. The EAP must address emergency escape procedures and routes, procedures for employees who remain to perform critical operations, accounting for all employees after an evacuation, rescue and medical duties, preferred means of reporting fires and other emergencies, and names of persons employees can contact for further information.

Supervisors bear the on-the-ground responsibility for EAP execution. This includes knowing how to initiate the alarm, leading their team to the correct assembly point, performing a headcount and reporting to the incident commander, and identifying any workers with mobility limitations who need evacuation assistance. Failure to account for all workers during an emergency — a missing person who is actually trapped — has resulted in preventable deaths. Supervisors must practice EAP drills at least annually and verify that posted evacuation maps are current.

The Fire Prevention Plan (FPP), required under 29 CFR 1910.39, must identify major fire hazards, describe proper handling and storage procedures for hazardous materials, identify potential ignition sources and controls, and describe the type of fire protection equipment used. Supervisors must ensure that hot work (welding, grinding, cutting) near flammable materials is controlled through a hot work permit system, and that fire suppression equipment — particularly portable extinguishers — is inspected monthly and annually, with records maintained.

Portable fire extinguisher training is required annually under 29 CFR 1910.157. Workers must know the fire classes (A: ordinary combustibles; B: flammable liquids; C: energized electrical; D: combustible metals; K: cooking oils) and the PASS technique (Pull pin, Aim at base, Squeeze handle, Sweep side to side). However, OSHA's preferred approach is total evacuation — workers should not be expected to fight fires unless they are specifically trained and it is safe to do so.