OSHA’s Evacuation Plans and Procedure eTool and Emergency Preparedness and Response Web site, as well as several printed publications, provide extensive assistance to employers. Ironically, OSHA does not interpret terrorist acts as foreseeable emergencies and therefore does not regulate response to them. However, emergencies may result from other man-made or natural causes. OSHA regulations do address an employer’s readiness for managing emergencies in general. Employers are wise to be prepared for any disaster in order to comply with regulations and minimize damages.
Consider the following. Three different trade contractors were doing remodeling work in a press bay. They included three electricians, two plumbers and two sheet metal workers. While one employee was grinding on a metal duct contaminated with sodium azide, an explosion occurred. One employee was killed and two hospitalized with chemical burns and head wounds. The rest of the employees were treated for hearing loss, lacerations and sprains and then released. Are you prepared for such an emergency? How would you respond to a fire, earthquake or other disaster at one of your job sites?
Planning is critical. OSHA requires contractors to have a written fire prevention and an emergency response plan. If you have less than 11 employees, the plans do not have to be in writing and may be communicated orally. The fire prevention plan should be based on site conditions. Select appropriate firefighting equipment.
For example, wherever electrical work is performed, there exists the potential for electrical fire. Fire extinguishers should have a Class C (ABC, BC or C) rating. Be sure the equipment is conspicuously located. Periodically inspect and maintain the equipment. Properly store materials and keep ignition sources away from combustibles and flammables.
The emergency response plan must address the following:
° Escape procedures and route assignment
° Designated personnel and procedures for maintaining critical operations during the emergency
° Procedures to account for employees after the emergency
° Procedures to address rescue and medical responsibilities
(Contractors are required to maintain first aid supplies on-site. Where the 911 emergency system is not in use, the telephone numbers of physicians, hospitals or ambulances must be posted. If medical assistance is more than three to four minutes away, trained first aid providers must be on-site.)
°Methods to be used for reporting fires and emergencies, which include the methods for reporting to outside agencies and notifying employees in the workplace or job site about the hazards. An alarm system must be established.
° Names or titles of company emergency contacts. These contacts should include a response coordinator and backup coordinator. Their duties consist of determining what has occurred, developing procedures to address each situation, directing emergency activities including evacuation, ensuring outside emergency services are notified and directing a shutdown if necessary.
Another emergency preparedness consideration is personal protective equipment (PPE). PPE is used for prevention and response. Evaluate employee exposure and possible exposure during an emergency. Protection from chemical splashes, falling objects and flying particles requires head, eye and face protection.
Gloves or aprons may be needed for chemical splashes. For unknown atmosphere with inadequate oxygen or toxic gases, respirators are needed. Whatever the hazard, the appropriate PPE should be on-site.
Regardless of the procedures established or equipment made available, the success or failure of the plan will depend on training. Employees must receive instructions on the details of the emergency action plan, including evacuation, alarms, reporting procedures for personnel, shutdown procedures and types of potential emergencies. Be sure to discuss any special hazards, such as flammable materials, toxic chemicals or water-reactive substances with them.
An effective training program should include drills. Training drills should be conducted annually and at random intervals. Whether drills are performed or not, OSHA requires emergency response training be conducted at least annually or when an employee’s job changes; new equipment, materials or processes are introduced; the layout or design of the facility changes; procedures have been updated or revised; or when the employee’s actions demonstrate that they lack an understanding of the plan. EC
O’CONNOR is with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. Based in Waverly, Pa., he can be reached at 607.624.7159 or firstname.lastname@example.org.