5.2 The emergency action plan and the alarm
An emergency action plan is six items long. That is not an approximation — 1910.38(c) lists exactly six minimum elements, and most plans that fail an audit fail because two or three of them were never written rather than because the document was too short.
1 When you must have one
1910.38(a) is careful: an employer must have an emergency action plan whenever an OSHA standard in this part requires one. It is not a standalone universal mandate — it is triggered by other standards. In a warehouse the common triggers are the portable fire extinguisher provisions of 1910.157(b), where an employer relies on total evacuation or designates only certain employees to use extinguishers, and the fixed fire suppression and alarm provisions elsewhere in subpart L.
In practice nearly every distribution center ends up needing one, and every one benefits from having one. 1910.38(b): the plan 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 it orally.
2 The six elements, verbatim in substance
| # | Element | What it looks like in a warehouse |
|---|---|---|
| (c)(1) | Procedures for reporting a fire or other emergency | Who calls 911, from where, what the address is, how the internal alarm is activated and by whom |
| (c)(2) | Procedures for emergency evacuation, including type of evacuation and exit route assignments | Which door each zone uses, where the assembly points are, what happens to a forklift mid-aisle |
| (c)(3) | Procedures for employees who remain to operate critical plant operations before they evacuate | Shutting down a conveyor, a charger bank, a compressor, a propane fill station — and who is authorized to |
| (c)(4) | Procedures to account for all employees after evacuation | The head count, and how it includes agency staff, drivers in trailers and contractors on the roof |
| (c)(5) | Procedures for employees performing rescue or medical duties | Who is trained, what they are authorized to do, and — just as important — what they are not |
| (c)(6) | The name or job title of every employee who may be contacted for more information about the plan or their duties under it | A named person, kept current when they leave |
3 The alarm
1910.38(d): an employer must have and maintain an employee alarm system, using a distinctive signal for each purpose, and complying with 1910.165. 1910.37(e) repeats the requirement from the exit route side: an operable employee alarm system with a distinctive signal to warn of fire or other emergencies, unless employees can promptly see or smell a fire in time for adequate warning.
"Distinctive for each purpose" matters in a building with several alarms — fire, ammonia release, severe weather, a conveyor jam klaxon. If the crew cannot tell one from another, nobody knows whether to go outside, go to the interior shelter, or ignore it. And the honest test of an alarm in a warehouse is audibility: a signal that cannot be heard over a wrapping machine, inside a trailer, in the maintenance shop or in the freezer is not warning those people.
4 Training and review
Two short paragraphs, both about people rather than paper. 1910.38(e): the employer must designate and train employees to assist in a safe and orderly evacuation of other employees. Those are your floor wardens, sweepers and head counters, and they need to be named per shift — including nights and weekends, when most warehouses have thought about it least.
1910.38(f): the employer must review the plan with each employee covered by it — when the plan is developed or the employee is first assigned to a job, when the employee's responsibilities under the plan change, and when the plan is changed. Note that this is a review with each person, not a posting on a board.
5 Evacuating a building full of forklifts
Subpart E does not talk about forklifts, so this is the place where the plan has to say something the standard does not. Three decisions are worth making in advance rather than in smoke.
- 1What happens to a truck mid-task. The default that works: lower the forks, neutral, brakes set, power off, leave it where it is unless it blocks an exit route — which is 1910.178(m)(5) applied to an evacuation, and it takes four seconds.
- 2Who is in a trailer. People inside trailers cannot hear the alarm and cannot see the building. Every plan needs someone assigned to check the dock doors on the way out.
- 3Where the assembly point is relative to the traffic. Not in the truck court where fire apparatus will arrive, not in front of a dock door, and not in the yard where a trailer will be moved.
Two more warehouse-specific items belong in the plan: the propane and battery-charging areas, so responders know where they are before they arrive, and the location of any ammonia refrigeration plant, which changes an evacuation into a shelter-or-evacuate decision depending on wind.
6 Drills, and what to learn from them
Part 1910 does not set a drill frequency for a general industry warehouse — fire codes and insurers often do, and an annual drill per shift is the common expectation. What matters more than the frequency is what you measure. Time to clear the building tells you about the exits. The head count tells you whether (c)(4) works. And a walk of the route afterwards tells you what was blocked, because a drill is the only time anyone looks at an exit route with the intention of using it.
Debrief three questions with the crew: did you hear the alarm where you were, did you know which door to use, and did anything stop you. Every answer that is not an immediate yes is a finding, and each one maps back to a paragraph in this chapter or the last.
- 1910.38(a): an EAP is required whenever another standard in part 1910 requires one — extinguisher provisions usually trigger it.
- In writing and available to employees; an employer with 10 or fewer employees may communicate it orally — 1910.38(b).
- Six minimum elements at 1910.38(c), including accounting for all employees and naming a contact for questions.
- 1910.38(d): an employee alarm system with a distinctive signal for each purpose, complying with 1910.165.
- 1910.38(e)-(f): designate and train evacuation assistants, and review the plan with each covered employee.
- Write the forklift, the trailer occupants and the night shift into the plan — the standard will not do it for you.
Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.