Workplace Emergency Action Plan Requirements Guide

A workplace emergency action plan (EAP) is a written document that tells employees what to do when a fire, medical emergency, severe weather event, or other crisis strikes. It is not required of every employer, but OSHA requires one wherever certain other standards call for it, and the minimum contents are specific. This article covers who needs a plan, the elements OSHA lists, the medical emergency piece that regulations barely touch, and how to keep the plan working after the first draft.

Which Employers Must Have a Written Plan

The federal rule is OSHA's Emergency Action Plans standard, 29 CFR 1910.38. It does not apply to every business by default. It applies when another OSHA standard says an employer must have an emergency action plan. Several standards do this, including some covering fire protection, hazardous chemicals, and confined space entry. OSHA maintains the list of triggering standards on osha.gov, and it changes, so verify the current list there rather than relying on a summary.

If you are covered, the default is a written plan. There is one allowance for small employers: under 1910.38(b), an employer with 10 or fewer employees may communicate the plan orally instead of putting it in writing. That is a format concession, not an exemption. The same elements still have to exist and be explained to employees.

State plan requirements

About half of U.S. states run their own OSHA-approved programs, and these can add to the federal baseline. California, Washington, and Michigan are examples of states with their own occupational safety rules. A state may require a plan in situations where federal OSHA does not, or may attach extra requirements to its contents. Check with your state's workplace safety agency before treating the federal text as the whole story.

Why a plan makes sense even when it is not mandated

Two other pressures often apply. Local fire codes commonly require evacuation plans, posted maps, or drills for certain occupancies, regardless of OSHA. Insurers may also ask about your emergency procedures when underwriting or after a claim. And practically, a business with no plan is relying on improvisation at the moment when people are least able to improvise.

One related point is worth separating early. The EAP under 1910.38 is a different document from the fire prevention plan under 1910.39. The first covers what people do during an emergency. The second covers how you prevent fires, such as handling flammable materials and maintaining equipment. A business may need both, and one does not substitute for the other.

The Minimum Elements OSHA Requires in an Emergency Action Plan

Section 1910.38(c) lists six elements that every plan must include at a minimum. Each one is easier to satisfy when you attach a concrete detail to it.

1. Reporting fires and other emergencies. State how someone reports an emergency and to whom. For example: pull the nearest alarm, then call 911 from any phone, then notify the front desk so the building contact can meet responders at the entrance.
2. Evacuation procedures and exit route assignments. Describe the routes by area, who leads each group, and what the backup route is if the first is blocked. Exit routes themselves are governed by 1910.37, which covers things like keeping them unobstructed and adequately marked.
3. Procedures for employees who stay to operate critical operations before evacuating. In a plant, this might be the operator who shuts down a process line or closes a valve. If no one needs to stay, say so in the plan. Anyone assigned this duty needs a defined time limit and a clear signal for when to leave.
4. Accounting for all employees after evacuation. Designate an assembly point, which is the outdoor location where evacuees gather, and name the person who takes the headcount from a current roster. That person also needs a way to include contractors and visitors who signed in.
5. Procedures for employees performing rescue or medical duties. Identify who these employees are, what they are trained to do, and what equipment they use. This is the element that connects most directly to first aid, CPR, and AED response.
6. Names or job titles of people to contact for plan information. Employees should know who can answer questions about their duties under the plan. A job title such as "Facilities Manager" survives staff turnover better than a personal name.

The alarm system

Under 1910.38(d), the plan must also include an employee alarm system that meets the requirements of 1910.165. The alarm must be distinctive and recognizable as a signal to evacuate or take action under the plan, and it must be a way to alert employees with disabilities as well. In practice, that can mean visual strobes alongside audible horns, or a buddy assignment for someone who cannot hear the alarm in a given work area. If your site is small and everyone can reliably hear a shouted warning, OSHA allows for that, but the plan should say how.

Training, Communication, and Review Obligations

A plan on paper does nothing until people know it. Section 1910.38(e) requires the employer to designate and train employees to assist in a safe and orderly evacuation of other employees. These are the floor wardens, stairwell monitors, and similar roles. Training means more than handing someone a vest. They should know their area, the exit routes, how to check for stragglers, and when to stop searching and leave.

Section 1910.38(f) sets the review triggers. The employer must review the plan with each covered employee at three points:

• When the plan is first developed or the employee is initially assigned to a job
• When the employee's responsibilities under the plan change
• When the plan itself is changed

Note that the first trigger applies to each new hire, not only to the plan's first rollout. Compare two approaches. In one, a new employee walks the actual exit routes with a supervisor on day one, finds the assembly point, and learns who the floor warden is. In the other, everyone sits through an annual slideshow and a new hire may wait months to see it. The first meets the intent of the rule. The second leaves a gap during the period when a new employee knows the least.

Access and language

The plan must be kept in the workplace and be available for employee review, per 1910.38(b). Employers with 10 or fewer employees who use an oral plan are the exception to the written copy, but the same accessibility logic applies. OSHA's general approach to training also expects that instruction be delivered in a language and at a level employees understand. If part of your workforce reads Spanish more comfortably than English, a plan and exit signage available only in English is a weak point regardless of how well it is written.

Planning for Medical Emergencies: Cardiac Arrest, Bleeding, and First Aid

The six required elements are built around evacuation and rescue. They say little about what happens when a coworker collapses at their desk or is badly cut on a machine. A practical plan covers those events too, because they are far more likely than a building fire.

The baseline federal rule is 1910.151. It requires that employers ensure medical personnel are readily available for advice and consultation on health matters. Where no infirmary, clinic, or hospital is in near proximity, it also requires a person or persons adequately trained to render first aid, and adequate first aid supplies must be readily available. "Near proximity" is not defined by a number of minutes in the text, so many safety managers treat the response time of local EMS as the key question.

Cardiac arrest

Sudden cardiac arrest is where minutes matter most. The chain of survival used in American Heart Association guidance starts with recognizing the emergency and calling 911, then starting CPR immediately, then using an AED as soon as one is available, followed by advanced care from EMS. For current details and any survival figures, consult the AHA's most recent resuscitation guidelines, which are updated periodically, rather than quoting numbers from older sources.

For your plan, this means deciding where AEDs (automated external defibrillators) go and how people find them. A common guideline is to place the device where it can be reached quickly from anywhere in the building, with visible signage, and not in a locked office. OSHA does not mandate AEDs for workplaces in general, though it recommends considering them. Verify OSHA's current wording, and check whether your state or local rules add anything.

Severe bleeding

Heavy bleeding can become life-threatening faster than ambulance arrival times in many areas. Workplaces with machinery, tools, vehicles, or public access should consider bleeding control supplies, including tourniquets, pressure dressings, and hemostatic gauze, stored in marked locations. The plan should name who is trained to use them, since a tourniquet in a drawer helps no one if nobody knows how to apply it.

Choosing the right training

CPR and AED courses suit general workplace responders such as office staff, floor wardens, and supervisors. BLS (Basic Life Support) is a higher-level course aimed at healthcare providers, covering team-based resuscitation and more advanced techniques. Employers in clinical settings or with medically trained staff will want BLS. Most other workplaces are well served by CPR and AED certification, paired with first aid and bleeding control instruction.

Common Gaps That Make Plans Fail

Plans rarely fail because the text is wrong. They fail because the document and the workplace drift apart. These are the gaps that show up most often.

• Nobody knows where the plan is or who holds the roles. The plan was written, filed, and forgotten. Named wardens have left the company, and no one has replaced them. Test this by asking three random employees who their floor warden is.
• Outdated evacuation maps. After an office move, a renovation, or a reconfigured warehouse floor, posted maps may point to exits that are blocked or no longer exist. Any layout change should trigger a map update the same week.
• Blind spots in who is covered. Plans are often written for the day shift, full-time employees at their desks. Visitors, contractors, night staff, remote or hybrid workers on site occasionally, and employees with mobility limitations need their own provisions. For someone who cannot use stairs, the plan should identify a designated refuge area and a method for notifying responders.
• Equipment installed, then ignored. AEDs have electrode pads and batteries with expiration dates. First aid kits run out of items after use. A device with a dead battery or expired pads gives a false sense of security. Assign someone to inspect on a schedule and record it.
• Drills without debriefs. Running a drill and returning to work captures none of the value. If the headcount took twelve minutes or one exit was blocked by a delivery pallet, that finding needs to be written down, assigned, and fixed.

Each of these is cheap to fix before an emergency and expensive to discover during one.

Building and Maintaining Your Plan Step by Step

If you are starting from scratch or rebuilding an old plan, work in this order.

1. Assess hazards. Walk the site and list what could realistically happen: fire, severe weather common to your region, chemical releases, workplace violence, and medical emergencies. Include after-hours scenarios and public-facing areas.
2. Draft the plan. Build it around the six elements in 1910.38(c) and the alarm requirement. OSHA provides free resources, including an online eTool for emergency action plans, that walk through the content. Assign each role to a named person with a backup, and use job titles in the document so it stays current.
3. Equip and train. Place AEDs, first aid supplies, and bleeding control kits where they are accessible and clearly marked. Set a certification schedule for CPR, AED, and BLS training, since certifications expire and your designated responders will turn over.
4. Drill, debrief, and update. Run an evacuation drill at least annually, or more often if your local fire code sets a schedule. Debrief immediately, record what went wrong, and fix it. Revisit the plan after any actual incident, layout change, or change in staffing, and remember that a plan change triggers the employee review requirement in 1910.38(f).

A simple log helps more than most people expect. Record drill dates and findings, equipment inspection dates, training and certification expirations, and plan revisions. A spreadsheet is enough. If an inspector, insurer, or attorney ever asks what you did to prepare, the log answers the question.

A Compliant Plan Is the Floor, Not the Goal

Meeting the OSHA minimums gets you a document. A practiced plan with trained responders and working equipment gets you a workplace that can actually handle a bad day. Start by confirming your state's requirements, since they may go beyond the federal rule, then look honestly at your medical readiness: who is certified in CPR or BLS, where your AEDs are and whether they are in date, and whether anyone on site can control severe bleeding.

Ready to put safety into action? Whether you need CPR certification, workplace safety training, or guidance on selecting and maintaining life-saving equipment such as AEDs, we're here to help. Our training programs and safety solutions are designed to help individuals and organizations respond confidently when every second counts. Schedule your training today and take the next step toward creating a safer, more prepared workplace and community.