Emergency planning is a compliance requirement often overlooked or inadequately addressed by most contractors. Not surprisingly, it’s also an area that, if insufficient, could result in significant penalty costs for your organization.
The first issue to review in this regard is what the federal Occupational Safety and Health Administration regulations mandate. OSHA regulation 29 CFR 1926.35 requires contractors to develop "site-specific" emergency action plans. Most state programs require similar plans. This means that the content of the plan must be relevant to the hazards found at the site to which the plan applies. It’s possible, however, to create a general plan template that will require minimum alterations for each site, thereby saving you administrative time and effort. The key to developing this template is to make some policy decisions regarding emergency response. Those decisions will be influenced in part by the type and location of the jobsites you are typically involved with.
Basic plan requirements
To meet basic OSHA requirements, your emergency action plan should contain the following details:
•A description of the site location and applicable emergency response telephone numbers and methods of contact for such. These numbers should include police, fire, emergency medical (ambulance), and designated medical facilities for treatment of injured or ill employees. These contact numbers should also be posted in conspicuous locations throughout the jobsite.
•Emergency evacuation procedures. This includes actions required of all employees, particularly those who are assigned emergency-response responsibilities such as traffic control or headcount. Also included in this section of the plan should be a detailed description of the emergency staging areas where personnel are to assemble after evacuating the building or site and the routes that employees should use to get to these locations.
•The duties expected of those who remain in the building or at the site to perform critical actions such as securing loads in the process of a lift, securing the site to avoid intrusion by unauthorized persons, and shutting down equipment and power sources.
•The method that will be used for accomplishing a headcount of employees after evacuation of the building or site.
•The duties of personnel assigned as first responders for injured or ill employees.
•The emergency alarm system that will be used on the site. (i.e., temporary or permanent alarm systems, voice notification, etc.)
•The preferred method of reporting fires and other emergencies.
•The names, job titles, and contact information of those responsible for the plan so that interested parties can obtain additional information, if necessary.
After you establish your firm’s policies regarding these basic requirements, you can incorporate most of them into a template for your general emergency action plan. Then you can add procedures or policies, as necessary, to address the emergency needs of specific jobsites.
What else to include
Other sections of the OSHA standards strongly suggest addressing other emergency response procedures in the action plan, such as what to do in case of falls. This includes what actions to take when an employee is suspended in personal fall-arrest equipment, since time is of the essence in these situations to avoid further injury. This aspect is covered in Appendix A (non-mandatory) of the new steel erection standards, 29 CFR 1926.750-761, which are now slated for implementation early next year.
Though not specifically discussed in the OSHA standard, similar policies should be developed to address a trench collapse or cave-in, rescue from confined spaces, and medical response for serious injuries if your employees or those of your subcontractors are performing or involved in these activities.
Other areas where it is prudent to develop emergency policies include:
•Exposure to live current (energized systems or equipment).
•Weather-related emergencies such as lightning striking an employee or overexposure to extreme heat or cold.
• Health-related emergencies such as heart attacks or diabetic shock.
Note: Based on my experience I strongly suggest that you ask your employees to tell you if they are diabetic or have heart problems. Although an employee is not required to reveal this information, doing so could save the employee’s life and prevent serious injury or death.
Preparing for emergencies In order for the emergency action plan to be effective, you and your employees must know the plan’s policies and procedures. All employees must be trained in the procedures outlined in your plan before engaging in any work at the site. They will also require additional training whenever their responsibilities under the plan change or whenever the plan itself changes. In addition, carefully review the requirements of 29 CFR 1926.50 – Medical Services and First Aid. Many contractors fail to fulfill their obligations under this standard.
If you have 10 or fewer employees, you can communicate the plan’s content orally. However, I recommend that you maintain records of any training provided regardless of the number of employees.
If you have more than 10 employees in your organization (in total, not just those assigned to a particular jobsite), then OSHA requires the plan to be in writing and maintained at each jobsite for the duration of the work. Remember, the plan must change as construction progresses to accommodate changing conditions and hazards present at the site. This requires periodic review and alteration of the plan by the qualified person responsible for plan development.
I highly recommended that you engage employees in mock emergency evacuation and rescue exercises periodically to evaluate their knowledge and the effectiveness of the plan. Do not attempt to conduct these exercises until completion of policy development and employee training. Because the emergency action plan must be site-specific, you may have to provide additional employee training at each site to address the unique aspects of the site plan vs. the general template plan described earlier.
Some contractors have organized in groups, such as erectors in a given area, to participate in mass training exercises. While I advocate such cooperation (if for no other reason than cost efficiency of the time and resources allocated), I suggest you use this approach with caution.
Don't forget that you are responsible for training employees in policies and procedures specific to your jobsite(s). Therefore, if your policies or procedures differ from those covered in a mass training exercise, you will still need to supplement that training with your own specific training. In addition, your employees will be evaluated for their knowledge of your policies and procedures should OSHA conduct an inspection.
Mel Hedin is a professional safety consultant who has written many training courses, programs, policies, and business communications on occupational safety and health. He has consulted extensively with the Systems Builders Association, the Associated Builders and Contractors, and members of MBMA, as well as with many contractors and roofers in the metal construction industry.
