Emergency Action Plans  29 CFR 1910.38 Do I need to provide emergency action plan training? Determining an employer’s need for emergency action plan (EAP) training is a two-part process. First, the employer must be required to have an EAP by another OSHA standard. A few things that can put an employer into this requirement are: applicability to Process Safety Management regulations, existence of fire extinguishers, presence of airborne exposure to certain hazardous chemicals, and presence of natural gas in the facility. Whether required or not, it is a best management practice to maintain an EAP in case of inevitable emergencies (fires, weather emergencies, medical situations, etc) that will arise. Assuming an EAP is required, the employer must maintain a written EAP to be communicated with employees if the workplace has greater than 10 employees. It is important to note that the word training appears in the EAP regulation as a requirement to train employees who assist in the evacuation of other employees, such as disabled employees. Many workplaces do not have employees that are designated to assist other employees in evacuation, so it may seem as if training is not required. However, OSHA requires that employers review the EAP with all employees. In effect, review of the EAP with employees should be treated the same as providing employees training in the EAP. What is required for emergency action plan training? Since the regulation requires employers to review the EAP with employees, all aspects of the EAP must be covered during training. This includes: procedures for reporting an emergency, procedures for evacuation, procedures for shutdown of hazardous operations, procedures to account for employees after evacuation (roll call), and procedures for first aid. While it is not expressly required, it is strongly recommended as a best management practice that employers perform drills for emergency procedures as part of training. Academic training often does not translate to efficient action during emergencies in real time, so many employers will find that incorporating simulated emergencies in the form of drills during training greatly enhances their emergency preparedness. There is no requirement for the employer to certify employees have been trained in the EAP; however, records of employee attendance in and understanding of training should be maintained if the need to prove training was conducted ever arises. How often must I offer emergency action plan training? Employees must receive EAP training before assignment to the job. There is no requirement for retraining intervals, but there is a requirement to retrain when emergency procedures change. As a best management practice, it is recommended that training be conducted annually. Employers that conduct drills are recommended to drill each type of emergency procedure (evacuation, shelter-in-place, etc.) annually. Employers may find it convenient to drill evacuation in the summer and drill shelter-in-place in the winter. #OSHA, #WorkerSafety, #BringingSafetyBack, #SafetyFirst