Have You Reviewed Your Emergency Action Plan Lately?

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By Kathleen J. Jennings (kjj@wimlaw.com)

Now is a great time to review your company’s emergency action plan.  Why?  We have the Atlantic hurricane season starting on June 1, and we have more workers returning to the physical workplace from their remote locations, thanks to mass vaccination.  So let’s make sure everyone knows what to do in the event of an emergency.  Note also that this is something that OSHA is likely to look for when it visits your establishment.

Where required by some Occupational Safety and Health Administration standards, firms with more than 10 employees must have a written emergency action plan; smaller companies may communicate their plans orally. Top management support and the commitment and involvement of all employees are essential to an effective emergency action plan.

Employers should review plans with employees when initially put in place and re-evaluate and amend the plan periodically whenever the plan itself, or employee responsibilities, change. Emergency procedures, including the handling of any toxic chemicals, should include:

  • Escape procedures and escape route assignments.
  • Special procedures for employees who perform or shut down critical plant operations.
  • Systems to account for all employees after evacuation and for information about the plan.
  • Rescue and medical duties for employees who perform them.
  • Means for reporting fires and other emergencies.

It is not just enough to have a written plan in place.  Every employee needs to know details of the emergency action plan, including evacuation plans, alarm systems, reporting procedures for personnel, shutdown procedures, and types of potential emergencies. Any special hazards, such as flammable materials, toxic chemicals, radioactive sources or water-reactive substances, should be discussed with employees.

Drills should be held at random intervals, at least annually, and should include outside police and fire authorities.

Training must be conducted at least annually and when employees are hired or when their job changes. Additional training is needed when new equipment, materials or processes are introduced, when the layout or design of the facility changes, when procedures have been updated or revised, or when exercises show that employee performance is inadequate.

Social distancing requirements may have changed the layout or design of your facility, triggering a review of your emergency action plan. And while you are at it, conduct a fire drill to remind everyone how to exit safely. Also, regularly check your exit signs to make sure that are unobstructed and in good working order.

Kathleen J. Jennings is an attorney licensed to practice law in Georgia and New York. She graduated from Cornell University, College of Arts & Sciences, with distinction and New York University School of Law. She is a principal in the Atlanta office of Wimberly, Lawson, Steckel, Schneider, & Stine, P.C. and defends employers in employment matters, such as sexual harassment, discrimination, Wage and Hour, OSHA, restrictive covenants, and other employment litigation and provides training and counseling to employers in employment matters. She can be contacted at kjj@wimlaw.com.

Copyright 2021 Kathleen Jennings

The materials available at this blog site are for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain advice with respect to any particular issue or problem. Use of and access to this Web site or any of the e-mail links contained within the site do not create an attorney-client relationship between Kathleen J. Jennings and the user or browser. The opinions expressed at or through this site are the opinions of the individual author.

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