How to Write a One-Page Emergency Action Plan

Why this matters

A fire in a parts room at 7:10 a.m., with nine people loading vans and two in the office, goes one of two ways. Either everyone knows which door, where to stand and who counts heads, or someone goes back in for a laptop while a manager runs around the building trying to work out whether the new apprentice already left with a truck. An emergency action plan (EAP) is the one page that decides which way it goes. OSHA writes the minimum contents into 29 CFR 1910.38, and almost every one of them is a question nobody wants to be answering for the first time in smoke.

Does 1910.38 actually bind your shop

The standard applies when another OSHA standard in Part 1910 requires an emergency action plan; it does not reach every employer on its own. For a shop, the usual trigger is the portable fire extinguisher standard, 1910.157: if your policy is that everyone evacuates and nobody fights fires, or that only designated people use extinguishers, 1910.157 requires an EAP and a fire prevention plan (1910.39) meeting these rules. If every employee is expected to grab an extinguisher, 1910.157 instead requires annual training on using one. A shop with a spray booth, a dip tank or certain hazardous chemical operations can pick up the requirement from other standards too.

The practical answer is that nearly every shop either is covered or is one policy decision away from it, and the plan costs an afternoon. Write it either way.

The size rule. Under 1910.38(b), an employer with 10 or fewer employees may communicate the plan orally instead of in writing. Count employees, not people in the building on a given morning, and count the whole company if the shop is its only site. Oral is allowed, not recommended: a plan nobody wrote down is a plan nobody can show a new hire, an inspector or an insurer, and it drifts every time the person who carries it in their head is on vacation.

The steps

Step 1: Draw the floor plan before you write a word

Sketch the building to rough scale: every room, every side-hinged door to the outside, the overhead doors, where the extinguishers hang, the electrical panel, the gas meter or shutoff, the cylinder cage, and the outside spot where people gather.

Why first: the plan's evacuation section is nothing but a description of this drawing. Writing the words before the drawing produces routes that pass through a locked parts-room door or end at an overhead door that will not open when the power is out.

Watch the door types. OSHA's exit-route rules (1910.36) require exit-route doors to be side-hinged and unlocked from the inside. An overhead door is a way to get trucks out, not an exit, and a powered one may not move at all in a power failure. The vocabulary for the path itself is in What an Exit Access, an Exit and an Exit Discharge Each Are.

                    STREET
     M = meeting point: the sign by the sidewalk
 +---------E1----------+-------------------------+
 | OFFICE        X1    | PARTS ROOM          X2  |
 |               P     D2                        |
 +------D1-------------+-------------------------+
 |                 SHOP BAY                      |
 |  X3                                 CAGE      |
 |  C (compressor)                          X4   |
 +---OH1-------OH2----------------------E2-------+
                  YARD        G (gas meter, ext.)
 Route A: office, parts room -> D2 -> E1 -> M
 Route B: shop bay -> E2 -> around east side -> M
 KEY  E1 front door, E2 rear man door (the exits)
      D1 D2 inside doors   OH overhead doors (not
      exits)   X extinguisher   P electrical panel

Step 2: Write how a fire or emergency gets reported

1910.38(c)(1) asks for the procedure for reporting a fire or other emergency. Write it as who does what: the person who discovers it shouts "fire, everybody out" and leaves, and the first person outside calls 911 from a cell phone. Name the street address and the cross street in the plan, because the person calling may be a tech who has never mailed anything to the shop.

1910.38(d) adds that the employer must have an alarm system with a distinctive signal for each purpose. In a small shop that may be a monitored fire alarm, an air horn on the wall, or a voice that reaches everyone. Test whether a voice reaches the far end of the bay with the compressor running before relying on it.

What breaks if skipped: three people each assume someone else called. A monitored alarm reaches the monitoring center, but do not assume the fire department is already rolling; call anyway.

Step 3: Assign the routes and the meeting point

1910.38(c)(2) asks for evacuation procedures and exit-route assignments. Give every area a primary exit and a second one, so a fire at E1 does not leave the office with nowhere to go. Under 1910.36(b), a workplace normally needs at least two exit routes, and one route is allowed only where the number of employees, the building's size and its arrangement let everyone evacuate safely through it.

Choose a meeting point that is away from the building, out of the fire department's way, and not in the yard where trucks will be moving or where cylinders are stored: a spot across the street or at the lot entrance, far enough that a falling wall or a venting cylinder does not reach it.

What breaks if skipped: people gather in the yard next to the cylinder cage, or by the overhead doors where the first engine needs to park.

Step 4: Decide who shuts what off, and usually the answer is nobody

1910.38(c)(3) covers employees who stay behind to operate critical plant operations before evacuating. A chemical plant has those; a service shop almost never does. Write it plainly: nobody stays behind. Nobody goes to the panel, the gas meter or the compressor. The fire department controls utilities on arrival, and the gas utility closes its own meter.

If you do want one shutoff, write it as something done on the way out at no added risk, such as the person leaving the bay hitting the compressor's disconnect beside door E2, and say in the same line that it is skipped if there is smoke or fire between them and the switch.

What breaks if skipped: a well-meaning lead walks toward the fire to close the gas, which is exactly the trip that kills people.

Step 5: Write how you account for everyone

1910.38(c)(4) asks for the procedure to account for all employees after evacuation. In a service shop the hard part is not the headcount, it is knowing who was in the building at all. Name a person and a backup to take the count, and name the source: the day's dispatch board or schedule, which shows who already left on a call, plus visitors and vendors in the building (a sign-in sheet at the front door covers them).

The counter reports to the fire officer: everyone accounted for, or the name and last known location of whoever is missing. Nobody goes back in to look.

Step 6: Rescue, medical duties, and who to ask

1910.38(c)(5) covers employees performing rescue or medical duties. For a small shop, write that employees do not perform rescue, and if anyone is trained in first aid and CPR and willing to act outside the building, name them. 1910.38(c)(6) requires the name or job title of every person employees can contact for more information about the plan. Use job titles with a name beside them, so the plan survives a promotion.

Step 7: Train it, and drill it without touching a live system

1910.38(e) requires designating and training enough people to assist in a safe and orderly evacuation. 1910.38(f) requires reviewing the plan with each employee when it is first developed, when the employee is first assigned, when their responsibilities under it change, and when the plan changes. Put the review in new-hire orientation, and keep a sign-off line per person.

A walk-through drill is the training that sticks. Announce it, walk the routes, take the count against that morning's board. Do not pull a monitored alarm station for a drill unless the alarm company has put the account on test first; an unannounced signal sends a fire company to a drill and can count against the account.

A worked example: the one page for a 14-person shop

A heating and cooling shop has 14 employees: 9 techs, 2 installers, a dispatcher, an office manager and the owner. At 14 it is over the 10-employee line, so the plan is written. Its policy is total evacuation: nobody fights fires, and the extinguishers on the wall are not for employee use. That is the 1910.157 path that requires the EAP.

The page reads, in order:

• Address: the street address and the cross street, in bold at the top.
• Reporting: whoever discovers it shouts "fire, everybody out" and leaves; first person outside calls 911. The office keeps an air horn by E1 for the bay, which a voice does not reach with the compressor running.
• Routes: Route A and Route B from the drawing, each area with a second choice (office and parts room use E2 through the bay if E1 is blocked).
• Meeting point: the sign by the sidewalk, 80 feet from the building and clear of the yard.
• Shutoffs: none. Nobody goes to the panel, the gas meter or the cage.
• Count: the dispatcher, with the office manager as backup, counts against the dispatch board and the visitor sheet.
• Rescue and medical: no rescue. Two installers hold current first aid and CPR cards and act outside only.
• Contacts: the owner and the office manager, by title and name.
• Training: reviewed at hire, at any change, and walked twice a year.

The first drill. Run on a Tuesday at 7:05 a.m., announced the day before, alarm company not involved because the air horn was used. Fourteen people stood at the sign, but only 13 of them were on the employee list of 14 names; the fourteenth person was a parts-supply driver who had signed the visitor sheet. The dispatch board showed the missing tech had left for an early no-heat call at 6:40, so all 13 employees in the building and the one visitor were out. Time from horn to complete count: 3 minutes 40 seconds.

What the drill found. Route B failed: a pallet of filters had been staged against E2, and the installers walking it had to squeeze past. In a real fire with E1 cut off, the office would have been routed to a blocked door. The fix went into the daily yard-close routine (E2 and the aisle to it clear at close) and the plan gained one line: "E2 and its aisle are never storage."

What would change the page. A shop at 8 employees could legally give all of this orally, and the same nine lines are what it should say. A shop that trains everyone on extinguishers instead of evacuating gets annual extinguisher training under 1910.157 on top of this. A shop in a multi-tenant building has to fold in the building's own alarm and meeting point, and should ask the landlord for the building plan rather than inventing a second one that sends people to a different corner.

How to verify you got it right

Hand the page to someone who started this week and ask them three things: which door do you use from where you are standing, where do you go, and who do you tell you are out. If they can answer from the page in under a minute, it works. Then walk the routes on an ordinary morning, not a tidied one, and confirm every door on the drawing opens from inside without a key and nothing is stacked in front of it. Post the page by each exit, put a copy in the new-hire packet, and date it, so the next review has something to compare against.

References

• OSHA 29 CFR 1910.38, Emergency action plans; 1910.39, Fire prevention plans
• OSHA 29 CFR 1910.157, Portable fire extinguishers (which policy choices require an EAP)
• OSHA 29 CFR 1910.36, Design and construction requirements for exit routes
• See related: What an Exit Access, an Exit and an Exit Discharge Each Are; Fire Extinguisher Placement and the Monthly Tag; The New-Hire Shop Orientation SOP