An emergency action plan (EAP) tells everyone in a workplace what to do in the first minutes of a fire, a tornado warning, a gas leak or a threat inside the building: how to raise the alarm, how to get out or where to shelter, who checks that the floor is empty, how the group gets counted, and who to ask when something is unclear. In the United States the federal baseline is OSHA's 29 CFR 1910.38, which sets six elements every plan must contain and adds rules on alarms, trained helpers and reviews with staff.
The standard is short and leaves most of the detail to the employer. Below is what it requires, a fill-in template covering the minimum plus OSHA's recommended extras, and a worked example for a 40-person office.
When OSHA requires an emergency action plan
Section 1910.38 applies whenever another OSHA standard calls for a plan. It does not, on its own, put a plan on every workplace. The trigger offices most often meet is the portable fire extinguisher standard, 1910.157. An employer whose written fire policy is that everyone leaves on the alarm, with no extinguishers provided for staff to use, escapes most of that standard only if it has an emergency action plan and a fire prevention plan under 1910.39. An employer that lets only designated people use the extinguishers while everyone else evacuates needs an EAP as well. Process safety management, hazardous waste operations, grain handling, fixed extinguishing systems and fire detection systems are among the other standards that call for one.
If none of them applies to you, write the plan anyway. The General Duty Clause still expects employers to protect people from recognized hazards, and our briefing on duty of care explains why the EAP is the first document an investigator or a plaintiff's lawyer asks to see.
The plan has to be in writing, kept in the workplace and available for employees to review, though an employer with 10 or fewer employees may communicate it orally. Two written pages still beat a plan that lives in the owner's head.
What an emergency action plan must include
Section 1910.38(c) lists the minimum elements. In plain terms, the plan must cover:
- How to report a fire or other emergency.
- How to evacuate, including the type of evacuation and which exit routes people are assigned to.
- What employees who stay behind to run critical operations do before they leave.
- How every employee is accounted for after an evacuation.
- What employees with rescue or medical duties do.
- The name or job title of each person who can explain the plan or someone's duties under it.
Three more paragraphs complete the standard. The employer must have and maintain an employee alarm system that uses a distinctive signal for each purpose and meets 1910.165. The employer must designate and train employees to help with a safe and orderly evacuation. And the plan must be reviewed with each covered employee when it is first written or the person starts the job, when their responsibilities under it change, and whenever the plan changes.
The alarm standard holds more than most people expect. Everyone in the affected area must be able to perceive the signal above ambient noise or light, and tactile devices may cover people who cannot. Staff must be told the preferred way to report an emergency, with emergency numbers posted near phones when phones are that way. A workplace with 10 or fewer employees may raise the alarm by voice if everyone can hear it. Non-supervised systems must be tested every two months, supervised ones at least yearly, and a backup such as runners or phones must cover any outage.
OSHA's evacuation plans and procedures eTool recommends going further: describe the alarm system in the plan, name an alternative communications center, and keep copies of key records and employee contact details in a secure place, on or off site. It also suggests one evacuation warden for every 20 employees, a named person with authority to order an evacuation, and procedures for visitors and employees who have disabilities or do not speak English.
A fill-in emergency action plan template
Copy the headings into a document and answer every prompt. Rows marked with a paragraph number are OSHA minimums; the rest are recommended.
| Section | What to write | Prompts to answer |
|---|---|---|
| Scope | Address, floors, hours, headcount by shift | Who else shares the building? |
| Plan contacts (c)(6) | Name or job title of the owner and alternates | Who explains the plan on a night shift? |
| Authority | Who orders evacuation, shelter or lockdown | Who decides when no alarm has sounded? |
| Hazards | Fire, severe weather, medical, gas or chemical release, violence | Leave, shelter or lock down for each? |
| Reporting (c)(1) | 911, pull stations, security desk | What does a dispatcher see when someone calls from a desk phone? |
| Alarm signals (d) | Each signal and its meaning | Can people in restrooms and server rooms perceive it? |
| Routes (c)(2) | Primary and secondary exits, floor plan attached | What if the nearest stair is blocked? |
| Assembly points | Primary and backup, clear of fire lanes | Where do people go in snow or heat? |
| Critical operations (c)(3) | Named tasks, who, the cut-off point | When do they leave no matter what? |
| Accounting (c)(4) | Source of the list, who counts, who reports | How do you count visitors and remote staff? |
| Rescue and medical (c)(5) | Who, training, limits | Who knows first aid and CPR? Where is the AED? |
| Assistance | Buddies, areas of refuge | Who has asked for help leaving? |
| Wardens (e) | Names, areas, alternates, training dates | Is every area covered on every shift? |
| Review (f) | Dates, triggers, drill schedule | When did each employee last review it? |
| Records | Copies off site, alternate communications center | Where is a copy if the building is closed? |
Example: a 40-person office
A hypothetical firm: 40 employees on the fourth floor of a six-story, multi-tenant building, hybrid, so 20 to 30 people are usually on site. No hazardous processes, a building fire alarm with horns and strobes, and a landlord fire safety plan the tenant must fit into.
- Contacts: The office manager owns the plan; the operations lead is the alternate.
- Authority: The fire alarm always means leave. For anything else, the office manager or the most senior person on site orders evacuation or shelter.
- Reporting: Call 911 first, then the building security desk. Both numbers are posted beside each printer. Pull stations sit beside both stair doors.
- Signals: Horn and strobe mean evacuate by the stairs. A building announcement about severe weather means move to the interior restrooms and stair core. A text from the notification system confirms or updates either.
- Routes: East half of the floor uses the north stair, west half the south stair. Nobody uses the elevators.
- Assembly: The far row of the rear parking lot; in bad weather, the lobby of the building across the street, by written agreement with its manager.
- Critical operations: None. Nobody stays behind.
- Accounting: The office manager opens the day's desk bookings and visitor log on a phone. Wardens report "floor clear" and anyone they could not check. Remote staff answer a text check-in.
- Rescue and medical: No rescue duties. Two employees trained in first aid and CPR help at the assembly point. The AED is at the lobby security desk.
- Assistance: An employee who uses a wheelchair has a named buddy and a backup. In a fire they wait in the south stair's area of refuge, and a warden tells firefighters in the lobby where.
- Wardens: Two wardens (one per 20 employees) and two alternates, so both halves of the floor are covered when someone works from home.
- Review: At onboarding, when duties change, after every plan change, and in a short walkthrough each spring. Drills follow the landlord's schedule.
Wardens need a way to talk when the alarm drowns out a call or the cell network is jammed. FRS handhelds fill that gap; the FCC licenses the service by rule, so business users need no individual license. At reception, a weather alert radio sounds for warnings covering your county, the events that trigger the shelter half of the plan.
Readiness kit
| Category | Pick | Why it is on the list | Link |
|---|---|---|---|
| Two-way radios | Midland LXT600 two-way radios | License-free FRS radios with weather alert scan, for floor wardens and a site without phones. | Shop on Amazon |
| Weather alert radio | Midland WR120B weather alert radio | A desk or reception radio that sounds NOAA alerts for your county only (SAME coding). | Shop on Amazon |
We picked both from manufacturer specifications and published reviews and have not tested either. Before you buy radios for wardens, try a pair between the stairwells and the assembly point, since concrete and steel shorten range sharply.
Keep the plan alive
Most plans fail through drift, not design. A renovation moves an exit, a warden leaves, the visitor log moves to an app nobody can open outside. Put the 1910.38(f) review triggers on someone's calendar and add your own: a new tenant, a seating change, a new notification system.
Accounting deserves the most attention, because it is where a plan built for 10 a.m. on a Tuesday breaks at night or on a hybrid Friday. Our guide to mass notification testing covers check-in messages that people actually answer, and continuity planning for hybrid work covers counting people who were never in the building. Walk through a scenario with the wardens once a year; a tabletop exercise built around a blocked stair or a missing visitor exposes more than a routine fire drill.
Frequently asked questions
Whose responsibility is the establishment of the emergency action plan?
The employer's. Section 1910.38 places the duty on the employer, which usually names a coordinator to write and maintain the plan, but the obligation stays with the employer. In a multi-tenant building each employer needs its own plan that fits the landlord's fire safety plan.
Is an emergency action plan the same as a business continuity plan?
No. The EAP covers life safety in the first minutes and hours: alarm, evacuation or shelter, accounting and first aid. A business continuity plan covers keeping or restoring operations over the following days and weeks. The two meet at accounting for people and at notification, so both should use the same contact lists.
Does a company with 10 or fewer employees need a written plan?
Not under 1910.38, which lets employers with 10 or fewer employees communicate the plan orally, and 1910.165 accepts direct voice as the alarm in such a workplace if everyone can hear it. A short written plan is still worth having. It survives staff turnover, and it is what you will be asked to show after an incident.
How often should an emergency action plan be reviewed?
The standard requires a review with each employee when the plan is created or the person starts, when their duties change, and whenever the plan changes. OSHA's eTool suggests retraining employees every year. Drill frequency usually comes from your state or local fire code, your landlord or your insurer rather than from OSHA.
