Sheet 37Mix-up sheet · Emergency action plans, alarms and drills
What an emergency action plan must include under 1926.35
The construction rule for an emergency action plan (EAP), 29 CFR 1926.35, is short: six elements the plan must cover, an alarm system, people trained to help with evacuation, and a review with the crew it covers. It sets no drill schedule, so a drill frequency credited to OSHA is someone else's number.
Procedures for workers who stay behind to run critical operations before they evacuate
A way to account for every employee after the evacuation is finished
Rescue and medical duties for the workers assigned to perform them
The preferred way to report fires and other emergencies
Names or regular job titles of the people or departments to contact for more about the plan
Talking point 02
Plan, alarm, evacuation
The cards run from what the written plan must contain to the calls a supervisor makes while the site empties.
Card 1 of 6 · 0 right
Card 1
A site uses the same single air-horn blast to signal a crane lift, a shift change, and an evacuation. Under 29 CFR 1926.35, what must the supervisor correct?
Pick an answer. A short note for each option, A to D, appears here.
APosting meanings does not remove the ambiguity when one blast means three different things.
BA louder or wider-reaching signal is still the same signal, so workers cannot tell an evacuation from a lift.
CText alerts can supplement an alarm but cannot replace an audible signal that reaches everyone at once.
DCorrect: the alarm system must give evacuation a distinctive signal so it cannot be mistaken for routine signals.
Card 2
A project's emergency action plan was reviewed with all workers at mobilization. Six weeks later the assembly area is moved to make room for a crane pad. Under 29 CFR 1926.35, what is required?
Pick an answer. A short note for each option, A to D, appears here.
AA posted map may go unread, and review is required when the plan changes, not only at hire.
BCorrect: the plan must be reviewed with each affected employee whenever it changes, and moving the assembly area is a change.
CThe rule has no annual-review cycle to wait for; changes are reviewed when they are made.
DA drill is good practice, but it does not replace the required review of the revised plan.
Card 3
After an evacuation alarm, crews gather at the assembly area. The sign-in roster shows 62 workers on site, but the superintendent counts only 60. What should the superintendent do FIRST?
Pick an answer. A short note for each option, A to D, appears here.
ASending untrained foremen back inside exposes them to the same hazard and may create more victims.
BChecking paperwork first delays a search that could save the missing workers.
CWaiting for the all-clear leaves possibly trapped workers without help during the critical first minutes.
DCorrect: the headcount exists so responders learn at once who may be missing and where they were last seen.
Card 4
During a real fire, the supervisor finds that the electric evacuation alarm is dead because its circuit tripped. What should the supervisor do FIRST?
Pick an answer. A short note for each option, A to D, appears here.
ACalling crews one at a time is slow, and some crews may be missed while the fire grows.
BResetting a tripped breaker during a fire wastes time and may trip again if a fault caused it.
CCorrect: The backup signal exists for this moment. Sound it to start the evacuation at once.
DThe fire department should be called, but its sirens are not the site's evacuation signal and would come late.
Card 5
During an evacuation, smoke from the fire drifts over the site's primary assembly area. What should the supervisor do?
Pick an answer. A short note for each option, A to D, appears here.
ACorrect: The plan's alternate assembly area exists for this case, and the headcount is taken there.
BDust masks do not protect against fire smoke, and staying in it keeps everyone exposed.
CGoing back into the building that is on fire is the opposite of evacuation.
DSending crews home before a headcount means no one knows who is still missing.
Card 6
A crew includes several workers with limited reading ability in any language. What is the MOST effective way to teach them the site's evacuation routes?
Pick an answer. A short note for each option, A to D, appears here.
AText instructions do not help workers who cannot read them.
BTranslation does not solve limited reading ability in any language.
CCorrect: Walking the routes on site and using standard exit symbols teaches the routes without relying on reading.
DDepending on a foreman fails if the foreman is absent or the crew is split up during an emergency.
Talking point 03
Two plans that get swapped
Emergency action plan vs HAZWOPER emergency response planscroll →
Point
Emergency action plan
HAZWOPER emergency response plan
Rule
29 CFR 1926.35
29 CFR 1926.65(q)
Written for
Every worker who has to get out and be counted
Workers who respond to a hazardous substance release
Core job
Evacuate, account for everyone, report
Respond to the release itself
Who acts
Everyone, by leaving and being counted
Trained responders, by containing the release
HAZWOPER is the hazardous waste operations and emergency response standard. A small, incidental release that the crew in the area can absorb is not emergency response, and a worker trained only to the awareness level recognizes a release and notifies others.
Talking point 04
Details that decide the answer
Small employers may skip the paper. With 10 or fewer employees, the plan may be communicated orally instead of written down. Ten is also the small-employer cutoff in OSHA recordkeeping (1904.1), a separate rule.
The alarm system has to meet 29 CFR 1926.159 and give a distinctive signal for each purpose. Before the plan takes effect, the employer picks and trains enough people to help others out in a safe, orderly evacuation.
The plan is reviewed with each covered worker when it is first developed, whenever that worker's responsibilities or designated actions under it change, and whenever the plan itself changes. Each worker also goes over the parts of the plan they need to know on initial assignment (29 CFR 1926.35(e)). The text is on osha.gov, 29 CFR 1926.35.
How often do construction crews have to run evacuation drills?
29 CFR 1926.35 sets no frequency. Drill schedules come from company policy, the owner's contract or a consensus standard. Holding one at start-up and whenever the site layout or phase of work changes, with a headcount and a debrief, is good practice.
Is the EAP the same thing as the site-specific safety plan?
No. The EAP is required by 1926.35 and limited to emergencies. A site-specific safety plan is an industry practice covering the whole project, and it often carries the EAP as one section.
Where should the assembly area go?
The standard does not fix a spot. Good practice puts it clear of collapse and traffic zones, and upwind and uphill wherever a chemical release is possible.