National Preparedness Month: Audit Your Emergency Action Plan

September is National Preparedness Month, making it a natural time for organizations to take a closer look at how prepared they really are for an emergency.

For industrial operations, emergency preparedness goes far beyond keeping an Emergency Action Plan (EAP) in a binder. Chemical facilities, tank trucking operations, municipal water systems, tank cleaning facilities, and other high-consequence workplaces may face chemical spills, toxic releases, confined-space emergencies, fires, severe weather, power outages, and other events that require employees to respond quickly and correctly.

A written plan is an important starting point. But a plan that has not been reviewed, communicated, or tested may not perform the way an organization expects when an actual emergency occurs.

National Preparedness Month provides an opportunity to move beyond checking a box. Use September to review your Emergency Action Plan, evaluate how it works in the field, test your procedures, and identify the gaps that could affect your workforce during a real emergency.

For additional preparedness resources, FEMA's Ready Campaign provides information and tools for preparing for disasters and emergencies.

What Does OSHA Require for an Emergency Action Plan?

OSHA's Emergency Action Plan requirements are outlined in 29 CFR 1910.38. The standard establishes the elements employers need to address when developing an Emergency Action Plan to protect employees during workplace emergencies.

An effective EAP should address several critical areas:

Emergency Reporting

Employees need clear instructions for reporting fires, hazardous chemical releases, and other emergencies. Employees should know who to contact, how to report an emergency, and what information needs to be communicated.

Evacuation Procedures

The plan should identify evacuation routes and procedures, including primary and alternative routes where appropriate. Employees need to know where they are expected to go and how they will be notified when an evacuation is necessary.

Critical Operations

Some employees may have designated responsibilities before evacuating, such as shutting down equipment or isolating systems. These responsibilities should be clearly defined and understood before an emergency occurs.

Personnel Accountability

An emergency evacuation is not complete simply because employees have left a building. Organizations need a process for accounting for employees, contractors, visitors, and other personnel at designated assembly areas.

Rescue and Medical Responsibilities

Employees assigned to perform rescue or medical duties should have clearly defined responsibilities and appropriate training.

Emergency Contacts

The plan should identify the people responsible for explaining the EAP and providing emergency information. Contact information should be reviewed regularly to ensure it remains accurate.

These components provide the foundation of an Emergency Action Plan. However, industrial organizations should also consider whether those procedures actually work for the environments in which their employees operate.

Five Emergency Action Plan Weak Points to Audit

A strong EAP audit should look beyond a standard facility evacuation. Industrial operations often have employees working in different locations, around hazardous materials, or away from the primary facility.

Here are five areas worth examining during a preparedness review.

1. The Field Worker Communication Gap

Many Emergency Action Plans are designed around fixed facilities such as offices, warehouses, and manufacturing plants. That creates a potential problem for organizations with employees who spend much of their day away from those facilities.

Municipal water technicians, tank truck drivers, outdoor crews, and other mobile workers may be miles away from the main operation when an emergency develops.

A facility alarm does little for an employee working on a remote utility easement.

During your audit, ask:

• How are field employees notified of an emergency?
• How are severe weather warnings communicated?
• Can supervisors reach employees who are away from the facility?
• Do employees know what to do when they receive an emergency notification?
• Are emergency procedures accessible while employees are in the field?

OSHA's Emergency Preparedness and Response resources cover a range of workplace emergency hazards, including severe weather, evacuation, chemical incidents, and other emergency situations.

Emergency planning needs to account for where employees actually work, not just where the organization maintains an office.

2. Chemical and Atmospheric Isolation Procedures

For operations handling hazardous chemicals, tank cleaning facilities, and similar industrial environments, an emergency may require more than evacuation.

A failed valve, vessel rupture, chemical release, or toxic atmospheric condition may require specific isolation procedures. Employees with designated responsibilities need to understand exactly what actions they are expected to take and, just as importantly, what situations require them to evacuate immediately.

Review your procedures for:

• Secondary containment
• Chemical isolation
• Emergency shut-off systems
• Remote valve operation
• Exposure zones
• Evacuation procedures
• Communication with emergency responders

These procedures should be documented clearly and practiced appropriately. Employees should never have to determine their emergency responsibilities for the first time during an actual incident.

OSHA's Emergency Preparedness and Response resources also include information related to chemical incidents and hazardous emergency response.

3. Personnel Accountability at Dynamic Job Sites

Accounting for employees inside a single facility can be relatively straightforward. It becomes much more complicated when personnel are spread throughout a large industrial yard or working across multiple locations.

Consider a scenario involving technicians, transportation contractors, inspectors, and visitors during a hazardous vapor release. A paper sign-in sheet may not provide an accurate picture of who is actually on site.

During an audit, evaluate how your organization accounts for personnel at dynamic worksites.

Ask:

• Who is responsible for the headcount?
• Where are personnel rosters maintained?
• Can supervisors access current information from an outdoor assembly area?
• How are contractors and visitors accounted for?
• What happens if the primary sign-in system is inaccessible?

Digital, mobile-accessible rosters can provide supervisors with another way to access personnel information during an emergency, particularly when employees are distributed across a large worksite.

4. Medical Response for Hazardous Exposures

Standard first-aid procedures may not address the specialized hazards present in some industrial environments.

Facilities that work with chemicals such as hydrofluoric acid, ammonia, or industrial solvents need emergency procedures that account for the specific hazards employees may encounter.

An EAP audit should examine whether employees know:

• Where emergency showers and eyewash stations are located
• How emergency equipment is maintained
• What immediate response procedures apply to specific exposures
• How emergency medical services will be contacted
• What information needs to be communicated to responding medical personnel
• What specialized response equipment is available

OSHA's medical services and first-aid standard requires suitable facilities for quick drenching or flushing of the eyes and body where employees may be exposed to injurious corrosive materials.

Emergency equipment also needs to be inspected and maintained. A procedure is only useful if the equipment employees are instructed to use is accessible and operational.

5. Access to Emergency Documentation During an Outage

Consider what happens if the power goes out, cellular service becomes unavailable, severe weather disrupts communications, or a cyber incident affects access to company systems.

Can employees still access their emergency procedures?

A plan stored exclusively on a local server or in an office binder may not be accessible when employees need it most.

Organizations should evaluate how critical emergency documentation can remain available when normal infrastructure is disrupted. For mobile workforces, offline access can be particularly important.

A Four-Stage Emergency Preparedness Audit

Once the key weak points have been identified, organizations can conduct a structured review of their Emergency Action Plan.

Stage 1: Review the Plan

Start with the written EAP.

Verify that emergency contacts, assembly locations, evacuation routes, employee responsibilities, and other critical information are current.

Review the plan against applicable OSHA requirements as well as relevant local fire, environmental, and workplace requirements.

OSHA's Emergency Action Plan guidance provides a useful starting point for reviewing the required elements of an EAP.

Pay particular attention to information that can become outdated quickly, including:

• Emergency contact information
• Employee assignments
• Rally points
• Facility layouts
• Medical response responsibilities
• Communication procedures

A plan should reflect the operation as it exists today, not the way it looked several years ago.

Stage 2: Walk the Facility and Field Locations

The written plan should match physical conditions.

Walk through the facility and, where applicable, field locations to identify potential problems.

Check whether:

• Emergency exits are unobstructed
• Exit doors can be opened as intended
• Exit signs are visible and operational
• Emergency lighting is functioning
• Eyewash stations and safety showers are accessible and maintained
• Alarm pull stations are visible and unobstructed
• Emergency equipment is where employees expect it to be

This step can reveal problems that are difficult to identify from a document review alone.

Stage 3: Test the Plan

A plan should not only be read. It should be tested.

Organizations can use tabletop exercises and functional drills to evaluate how employees respond to realistic scenarios.

For example:

Scenario A: A chemical spill occurs in a loading area while the primary evacuation route is blocked.

Scenario B: A severe weather warning is issued while a portion of the field workforce is working at remote locations.

Scenario C: A power outage occurs while employees are performing a confined-space operation.

The goal is not to catch employees doing something wrong. The goal is to identify weaknesses in the emergency process before those weaknesses become a problem during an actual incident.

Stage 4: Correct the Gaps

The final stage is to document what the audit revealed and make improvements.

Did employees go to different assembly locations?

Did someone miss an emergency notification?

Was an emergency contact number outdated?

Did employees have difficulty locating emergency equipment?

Did supervisors have an accurate personnel roster?

Every issue identified during an exercise represents an opportunity to strengthen the plan.

Update the applicable procedures, communicate the changes, and provide additional training where necessary.

Emergency Preparedness Is an Ongoing Process

One of the biggest mistakes an organization can make is treating an Emergency Action Plan as a document that only needs attention during an audit.

Emergency plans need to evolve alongside the operation.

New equipment, new facilities, changes in staffing, updated work locations, new hazards, and changes in employee responsibilities can all affect emergency procedures.

OSHA requires employers to review the plan with covered employees when the plan is developed or an employee is initially assigned to a job, when the employee's responsibilities under the plan change, and when the plan itself changes.

That means emergency preparedness should be part of an organization's ongoing safety process rather than a once-a-year activity.

Frequently Asked Questions

Does OSHA require every company to have a written Emergency Action Plan?

OSHA requires an Emergency Action Plan when an OSHA standard in Part 1910 requires one. Under 29 CFR 1910.38, the plan must generally be in writing and kept in the workplace, although employers with 10 or fewer employees may communicate the plan orally.

Organizations should review the OSHA requirements that apply to their workplace and maintain documentation that reflects their emergency procedures.

How often should an Emergency Action Plan be reviewed with employees?

Under OSHA 1910.38(f), employers must review the plan with covered employees when the plan is developed or the employee is initially assigned to a job, when the employee's responsibilities under the plan change, and when the plan itself changes.

Organizations should also review their plans whenever operational changes or audit findings indicate that updates are necessary.

What is the difference between a tabletop exercise and a functional drill?

A tabletop exercise is primarily discussion-based. Key personnel work through a simulated emergency scenario and discuss their responsibilities, decisions, and communication procedures.

A functional drill is more hands-on. Employees physically perform emergency actions, such as evacuating a facility or carrying out specific response procedures.

Both can help identify weaknesses, but they test different aspects of emergency readiness.

Can Emergency Action Plans be accessed digitally?

Digital emergency documentation can provide employees with another way to access critical information, including when employees work away from a primary facility.

Organizations using digital documentation should consider accessibility, device availability, connectivity, and whether critical information remains accessible when normal systems or communications are disrupted.

Build Readiness Before the Emergency

National Preparedness Month is a useful reminder that emergency readiness cannot begin when an emergency is already underway.

For industrial organizations, preparedness means more than having an Emergency Action Plan on file. It means making sure employees understand their responsibilities, emergency equipment is ready, communication systems reach the people who need them, personnel can be accounted for, and critical procedures have been tested under realistic conditions.

September is a good time to ask a simple question:

If an emergency happened today, would your Emergency Action Plan actually work?

An honest audit can help reveal the answer.

At Sentry Road, we believe effective safety programs go beyond maintaining records. Training, communication, documentation, and preparedness should work together to support a safer workforce and a stronger safety culture. Learn how Sentry Road can help strengthen your safety program at sentryroad.com.

Train • Track • Comply.