What Manufactures Need to Know about OSHA Emergency Action Plans

What Manufacturing Leaders Must Know about OSHA Emergency Action Plans

Do you know the difference between an OSHA emergency action plan and basic workplace safety protocols? If not, you’re almost certainly putting your employees and facility at risk.

We all know something about basic safety standards and try to minimize risks in our facilities. However, that hard work doesn’t always meet OSHA safety requirements—which means you’re gambling with your bottom line and inviting $10k-$100k+ fines every time the OSHA inspector stops by—even if you thought you knew how to prepare.

Here’s what you need to know to create a regulation-grade OSHA emergency action plan now, and reduce your risk for fines and safety violations.

What is an OSHA Emergency Action Plan?

An emergency action plan (EAP) is an OSHA-required document that facilitates and organizes employer and employee actions during workplace emergencies. Most companies, buildings, and organizations have some level of emergency action planning. What makes the OSHA EAP different is that it focuses on facilities that come with additional risk—like manufacturing plants or factories.

A strong OSHA EAP doesn’t simply protect your workers and company in the event of an emergency; it helps prevent those emergencies in the first place and provides assistance to emergency response workers. For instance, a firefighter going into a burning home faces different risks than a firefighter headed to a chemical waste plant—and a well-executed EAP can help keep them safe.

Is an OSHA EAP necessary?

Yes. OSHA requires your business to have an up-to-code EAP. The complexity of that EAP might differ depending on the types of risks, materials, and number of employees at your facility, but even the smallest facilities need a plan. Not having a reliable EAP isn’t just a violation of OSHA code—it also puts your company and your employees at serious risk.

What are the key components of creating and maintaining an OSHA EAP?

There are four key steps to creating and maintaining an OSHA EAP:

Plan Development

Developing your emergency action plan is step one of a four-step process. The trick to developing an OSHA EAP is covering your bases. You know the risks of your facility. What are the architectural risks? What are the machinery and chemical risks? Where are your exits? Where is your protective gear? How many employees do you have? How much time do they have to leave the building in the event of a fire? A chemical leak? An explosion? Even a tornado!

A good EAP doesn’t reinvent anything about your facility, it merely creates step-by-step protocols for different emergency scenarios. Remember, you might know how to turn off a machine on a normal day, but panic over a fire can wipe that knowledge right out of your head. You and your employees need to keep this vital safety information at the ready.

Feeling overwhelmed? Start with the OSHA EAP checklist or the OSHA EAP minimum requirements. If you’re missing a few checks, regroup and fill in the gaps. You can also work with a compliance expert to develop an EAP that covers OSHA regulations while staying site-specific.

Establishing Authorities

While your plan should be clear and straightforward for anyone who reads it, it’s always best to select one person to act as the plan authority. This person should know the plan, understand the different risks, be capable of assessing different dangers, and be able to make decisions under pressure.

No matter how thorough your plan might be, emergencies don’t follow the rules. There may be times when an employee can’t follow their part of a plan due to extreme danger—like a power line snapping. In those cases, having an established authority ensures everyone knows who to consult for guidance.

The plan must also include other responsibilities during an emergency.

Employee EAP Training and Review

Writing down your EAP is only step one. If your employees don’t know how to follow your plan, then it’s not keeping anyone safe. In fact, OSHA knows this so well they made specific codes about key training and review principles. According to OSHA code, you must:

Train your employees to assist in the plan.
Review the plan with each individual employee.
Review the plan again with individual employees whenever:
- The employee is onboarded
- The plan changes
- The employee’s role in the plan changes

Additionally, general employee training should include all emergency topics, even if particular employees might not need specific bits of safety information. Those topics include:

Individual responsibilities
General hazards and protections
Notification and communication policies
Meeting locations
Evacuation procedures and exit locations
Locations and instructions for emergency gear
Basic first aid
Shutdown procedures (All employees, regardless of their role, should know how to shut down dangerous machinery in case of emergency.)

If your employees can’t follow your emergency action plan, it’s just as useless as not having one in the first place. And OSHA views it the same way. When it comes to safety, the importance of employee training can’t be overstated—it’s always better to have too much information than not enough.

Regular Emergency Plan Review and Updating

Once you have your plan developed, your plan leader chosen, and your employee training completed, what happens next?

Even the best plans need reviewing and refining as regulations, equipment, and employees change over time. It’s the most frustrating part of a successful EAP—and it’s the part where most manufacturers fall short. If you’re one of those manufacturers struggling to keep your EAP updated, you’re not alone. It’s not easy to keep your EAP current, your employees trained, and your company running smoothly.

At the end of the day, most OSHA violations aren’t intentional. They don’t happen because you want to hurt your employees or your business. They happen because you don’t have the tools to successfully enforce safety regulations or maintain long-running safety plans.

At Berg Compliance, we understand that frustration. That’s why we offer affordable, customizable, and flexible compliance programs for manufacturers of all sizes. You can’t afford to wait for a budget-crushing fine or employee injury to create an OSHA-compliant EAP. Call 512-457-0374 or click here to schedule your free consultation today

By Russell Carr|2023-10-12T14:35:21-05:00October 11th, 2023|OSHA Health & Safety, OSHA Texas Laws & Regulations, Safety Training, Texas OSHA Compliance|Comments Off

About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.