OSHA regulation 29 CFR 1926.35 requires all contractors to develop "site-specific" emergency action plans. If you do not have such a plan, not only are you out of compliance, but you could be setting yourself up for a big fine.
Emergency plans, things to have ready “just in case,” are not typically top of mind with anyone but on a the jobsite, that lack of preparation and communication during a crisis could prove deadly, opening your company to lawsuits, insurance increases, and license suspension, as well as the plain rotten feeling that someone in your charge got hurt or killed.
What do you need to do? Let’s get started.
Basic emergency action plan requirements
Just to meet the OSHA requirements outlined in the standard, your Emergency Action Plan, at a minimum, must contain all of the following:
- Emergency escape procedures and emergency escape route assignments
- Procedures to be followed by employees who remain to operate critical plant operations before they evacuate
- Procedures to account for all employees after emergency evacuation has been completed
- Rescue and medical duties for those employees who are to perform them
- The preferred means of reporting fires and other emergencies
- The names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan
Your plan must be in writing and must also cover an alarm system, evacuation procedures, and employee training.
You should also include a description of the site location, emergency response numbers for the area, and the methods of contact available.
- Fire department
- Emergency medical assistance/ambulance
- Name and address of designated medical facilities where the sick or injured will be taken for treatment
These numbers should be in easy-to-read type and posted in multiple locations across each jobsite.
Additional OSHA requirements for the jobsite
Beyond the basics, OSHA also has requirements for other documents and policies. These include:
- A written Hazard Communication Plan ensuring all employers and employees know about hazardous chemicals in the workplace, including information about self-protection.
- Specific standards for hand and power tools
- The presence and use of concrete or masonry products
- The use of cranes, derricks, hoists, elevators, and conveyors
- Welding, cutting, or brazing
- Policies for working in confined spaces
- Standards specifically for residential construction
- Steel erection
This is not a comprehensive list. In order to guarantee compliance, you need to go to the OSHA website to identify the standards applying to your specific activities. You also need to keep abreast of any changes in the standard so you can update your plans if needed.
Creating the emergency action plan
You can use the list of basics to make an example or a template for a general plan and modify it for specific sites. This could save you some time. If you add it to the documentation required for each project you will be able to have it ready in time for work to start.
Create a template using a word processing program, such as Microsoft® Word, which can then be modified and printed whenever you need it.
An action plan is no good if nobody knows about it or about their duties in the event of an emergency. Therefore, OSHA also mandates training all employees on the provisions of your emergency action plan, with specialized training for those with specific roles.
The standard specifically reads:
“Before implementing the emergency action plan, the employer shall designate and train a sufficient number of persons to assist in the safe and orderly emergency evacuation of employees.”
For instance, you need someone in charge of headcount after evacuation. This person needs access to information such as the location where everyone was told to congregate during evacuation, how many were working that day, and who to notify if someone is missing.
You must also provide training anytime something changes, from updates to standards to changes in the jobsite. Each jobsite has its own hazards; all employees must be trained on the plan for the jobsite they work on.
Train at these times:
- When the initial plan is developed
- Anytime an employee’s responsibilities or designated actions under the plan change
- Whenever the plan is changed
Basically, when anything changes, make sure everyone is trained on the change. It’s better to take a little extra time to train than to have an emergency occur and take much more time to respond than it should. Seconds count; there is no time to waste in emergencies.
Specifics for steel erection
OSHA has a standard specifically for steel erection, 29 CFR 1926 Subpart R App A-H, with additional requirements over and above general site requirements. In addition to the overall site-specific plan, steel erection standards require:
- A preconstruction conference between the erector and controlling contractor plus other parties, such as the project engineer and fabricator before the start of steel erection, to develop the site-specific erection plan
- The sequence of erection activity developed in coordination with the controlling contractor, including material deliveries, material staging and storage, and coordination with other trades and construction activities.
- A description of the crane and derrick selection and placement procedures, including site prep, paths for overhead loads, critical lifts plus rigging supplies and equipment
- A description of steel erection activities and procedures including stability considerations with temporary bracing and guying; erection bridging terminus point; anchor rod or bolt notifications regarding repair, replacement, and modifications; columns, beams, connections, decking, and ornamental or miscellaneous iron
- A description of the procedures that will be utilized in the event of a rescue or emergency response.
That last bullet should jibe with the emergency action plan already in place. Some of the same information will be used for both.
Other descriptions round out the erection plan as well as require training certification and documentation for each employee’s training record. Some information duplicates that in the general plan.
Any emergency action plan, erection plan, or other safety procedure must be signed by all responsible parties and dated. For future changes, each change should be similarly signed and dated.
According to OSHA, out of 4,251 occupational fatalities in 2014, 20% of worker fatalities occurred in construction. That’s just the fatalities. The number of injuries is much higher. Each jobsite contains its own particular hazards plus the typical four: falls, electrocutions, struck by an object, and caught-in/between.
This is why there is a requirement to develop, write, and conspicuously post an emergency action plan for every one of your jobsites. Don’t do it just to be compliant. Do it because it’s the right thing to do.