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Emergency Action Plan Builder

29 CFR 1910.38(c) lists six things an emergency action plan must contain. This builder turns them into the six sections of a written plan you can print, post and review with the crew — plus the alarm, training and review paragraphs that come with them. It asks for your procedures; it never invents them. Nothing you type is sent to our servers.

1910.38(b): with 10 or fewer employees the plan may be communicated orally — the six elements, the training and the review still apply.
1910.38(b): in writing, kept in the workplace, available to employees for review.
An emergency action plan is not a fire prevention plan. 1910.39(c) has its own five elements.

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Template for informational purposes only. This document must be reviewed and adapted by a competent or qualified person for your specific jobsite, equipment, and applicable federal, state, and local requirements. It does not constitute legal, engineering, or safety advice and does not by itself establish compliance with OSHA or any other standard. SteelToeTools assumes no liability for its use. Nothing you type is sent to our servers.

How to use this builder

  1. 1
    Answer in your own words, not in OSHA's. The six headings are fixed; the content underneath is yours. A plan that reads like the regulation quoted back at itself tells an employee nothing at 2 a.m.
  2. 2
    Write the address the way you would say it to a dispatcher. Building, gate, cross street. It goes at the top of the printed plan for a reason.
  3. 3
    Name people by job title where you can. 1910.38(c)(6) allows a name or a job title, and a title survives the person leaving.
  4. 4
    Watch the coverage line on step 4. It tells you which of the six minimum elements are still blank. Six out of six is the minimum, not the target.
  5. 5
    Walk it before you file it. Take the printed plan and follow one of your own exit route assignments to the assembly point. Most plans fail on a door that is locked, a route that crosses the fire, or an assembly point in the smoke.

What OSHA requires

29 CFR 1910.38(a) says an employer must have an emergency action plan whenever an OSHA standard in part 1910 requires one. 1910.38(b) then says it must be in writing, kept in the workplace, and available to employees for review — except that an employer with 10 or fewer employees may communicate the plan orally. Construction says the same at 1926.35(e)(3).

The six minimum elements of an emergency action plan — 29 CFR 1910.38(c)
The plan must includeConstruction
(c)(1)Procedures for reporting a fire or other emergency1926.35(b)(5)
(c)(2)Procedures for emergency evacuation, including type of evacuation and exit route assignments1926.35(b)(1) and (d)
(c)(3)Procedures to be followed by employees who remain to operate critical plant operations before they evacuate1926.35(b)(2)
(c)(4)Procedures to account for all employees after evacuation1926.35(b)(3)
(c)(5)Procedures to be followed by employees performing rescue or medical duties1926.35(b)(4)
(c)(6)The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under it1926.35(b)(6)

Three more paragraphs travel with them. 1910.38(d) requires an employee alarm system that uses a distinctive signal for each purpose and complies with 1910.165 — construction points to 1926.159 instead, and 1926.150(e) adds that the alarm code and reporting instructions are conspicuously posted at phones and employee entrances. 1910.38(e) requires the employer to designate and train enough employees to assist in a safe and orderly evacuation. 1910.38(f) requires the plan to be reviewed with each covered employee when the plan is developed or the employee is assigned initially to a job, when that employee's responsibilities under the plan change, and when the plan is changed.

An emergency action plan is not a fire prevention plan

They are two documents. 1910.39(c) requires a fire prevention plan to list all major fire hazards with their handling and storage procedures, potential ignition sources and their control, and the fire protection equipment for each hazard; procedures to control accumulations of flammable and combustible waste; procedures for regular maintenance of safeguards on heat-producing equipment; and the names or job titles of the employees responsible for ignition sources and for fuel source hazards. Where you rely on the exemption in 1910.157(b)(1), you need both.

Fight or flee — the decision that shapes the plan

OSHA's evacuation eTool sets out four options and what each one costs you:

Portable fire extinguishers in an emergency action plan — OSHA Evacuation Plans and Procedures eTool
OptionWhat it requires
Total evacuation on the alarm; nobody uses extinguishersAn emergency action plan and a fire prevention plan, employees trained accordingly, and no extinguishers in the workplace — 1910.157(b)(1)
Designated employees onlyAn emergency action plan, all general extinguisher requirements, and annual training for the designated employees; the units are still inspected, tested and maintained — 1910.157(b)(2)
All employees are authorizedThe same, with annual training for everyone — 1910.157(b)(2), (g)
Extinguishers present but not intended for employee useAn emergency action plan and a fire prevention plan; the units still have to be inspected, maintained and tested — 1910.157(a)

Whichever line you are on, the extinguishers on the wall stay on their own clocks: monthly inspection, annual maintenance and hydrostatic testing. The fire extinguisher monthly inspection log is the sheet for that.

This generator produces a template. The procedures in it are yours, not ours: it supplies no model evacuation route, no default assembly point and no head-count rule. It does not by itself establish compliance with 1910.38, 1926.35, 1910.39, the local fire code or your insurer's requirements, and it is not a substitute for the training required by 1910.38(e) or the review required by 1910.38(f).

Frequently asked questions

Six elements, listed at 29 CFR 1910.38(c): procedures for reporting a fire or other emergency; procedures for emergency evacuation, including type of evacuation and exit route assignments; procedures to be followed by employees who remain to operate critical plant operations before they evacuate; procedures to account for all employees after evacuation; procedures to be followed by employees performing rescue or medical duties; and the name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under it. Those six are the six sections this builder prints.

Usually yes. 1910.38(b) says the plan must be in writing, kept in the workplace, and available to employees for review — with one exception: an employer with 10 or fewer employees may communicate the plan orally. Construction says the same thing at 1926.35(e)(3). Note what the exception does not do: it does not remove any of the six elements, and it does not remove the training or the review.

Whenever another standard in the part calls for one — 1910.38(a). Several do. The fire extinguisher standard is the most common route in: 1910.157(b)(1) exempts an employer from the extinguisher requirements only where there is a written fire safety policy requiring total evacuation, plus an emergency action plan and a fire prevention plan meeting 1910.38 and 1910.39; and 1910.157(b)(2) exempts you from the distribution requirements only where an emergency action plan designates the employees authorized to use extinguishers.

They are two separate documents with two separate lists. The emergency action plan, 1910.38, is about what people do once something has happened: report, evacuate, account, rescue. The fire prevention plan, 1910.39, is about stopping it happening: a list of major fire hazards with their handling and storage procedures, ignition sources and their control and the fire protection equipment for each; procedures to control accumulations of flammable and combustible waste; maintenance of safeguards on heat-producing equipment; and the names or job titles of the people responsible for ignition sources and for fuel source hazards. Several exemptions elsewhere in part 1910 require both.

It is the decision that shapes the rest of the plan. OSHA's evacuation eTool lays out four options: total evacuation with nobody authorized to use extinguishers; designated employees only; all employees; or extinguishers present but not intended for employee use. Each option carries a different set of obligations under 1910.157 — designating employees under 1910.157(b)(2) means training them annually under (g)(3) and (g)(4). This builder records which option applies and who is designated.

1910.38(e) requires the employer to designate and train enough employees to assist in a safe and orderly evacuation — the evacuation wardens. 1910.38(f) then requires the plan to be reviewed with each covered employee at three moments: when the plan is developed or the employee is first assigned to a job, when that employee's responsibilities under the plan change, and when the plan itself changes. Construction words it the same way at 1926.35(e).

1910.38(d) requires an employee alarm system, using a distinctive signal for each purpose, complying with 1910.165. Construction points instead to 1926.159, and 1926.150(e) adds that an alarm system must let employees on site and the local fire department be alerted, with the alarm code and reporting instructions conspicuously posted at phones and employee entrances. The plan records what the signal sounds like, because a signal nobody recognizes is not an alarm.

No template is, by itself. This one prints your procedures under the six headings the standard names, which is the shape an inspector expects. What makes it a real plan is that the routes, the assembly points, the head-count method and the named contacts are yours, that employees have been trained under 1910.38(e), and that the plan has been reviewed with them under 1910.38(f). Walk it before you file it.

Sources & references

Content checked against these sources — last reviewed August 28, 2026.

By — Editorial team of SteelToeTools.com (published by LSEA SAS) Updated v1