What's the Difference Between the HAZWOPER's Emergency Response Plan and an Emergency Action Plan?
Being prepared for emergencies at your facility is vital, and having that plan communicated to your employees is even more critical.
Being prepared for emergencies at your facility is vital, and having that plan communicated to your employees is even more critical.
Emergency Action Plans (EAP)
EAP requirements are found in 29 CFR 1910.38(a). At a minimum, EAPs need to include procedures for: Reporting a fire or other emergency; Emergency evacuation including exit routes; Employees who remain for critical operations; Accounting for all employees after evacuation; Employees performing rescue or medical duties; and Contact information.
HAZWOPER Emergency Response Plan
If you are going to have your employees respond to releases and spills, you are required to have an Emergency Response Plan per 29 CFR 1910.120. If your facility intends to evacuate everyone and have someone else do the emergency response, then you just need an Emergency Action Plan.
Frequently Asked Questions
Q: What is an Emergency Action Plan (EAP) and what must it include?
An Emergency Action Plan (OSHA 1910.38) is required for all workplaces and must address: procedures for reporting fires or emergencies, evacuation procedures and exit routes, employees remaining for critical operations, employee accountability after evacuation, rescue and medical duty assignments, and emergency contact information. The EAP applies when facilities evacuate and don’t respond to the emergency.
Q: When is a HAZWOPER Emergency Response Plan required instead of an EAP?
A HAZWOPER Emergency Response Plan (29 CFR 1910.120(q)) is required when facility employees will respond to chemical releases or spills to contain, stop, or clean up the release. If your facility evacuates and external emergency responders handle the incident, only an EAP is needed. If your facility has hazmat response teams, both plans may be required with coordinated procedures.
Q: What is the difference between an Emergency Action Plan and a HAZWOPER Emergency Response Plan?
An EAP focuses on employee evacuation and accounting procedures for general emergencies. A HAZWOPER Emergency Response Plan includes specific hazmat response procedures, hazard identification, response actions, PPE requirements, incident command structure, medical surveillance for exposed workers, and coordination with external emergency responders. HAZWOPER plans address the specific chemicals and hazardous substances at the facility.
Q: Can a facility use the same document for both EAP and HAZWOPER Emergency Response Plan?
Yes, facilities can integrate both plans into a single comprehensive emergency plan document as long as all required elements from both OSHA 1910.38 and 1910.120(q) are included. The plan must address both general employee evacuation and specific hazmat response procedures with clear designation of which procedures apply in different emergency scenarios.
Need help with osha compliance? Contact iSi Environmental for a same-day quote, or explore our osha services to see how we can help your facility.