Which Emergency Response Plans Are Required for Your Facility?
Facilities commonly need multiple overlapping emergency plans — SPCC, RMP, HAZWOPER, EAP, PSM, contingency. Here's what each covers and how the ICP lets you consolidate.
⚡ In short: Depending on your operation, you may need SPCC, FRP, RMP, RCRA Contingency, EAP, HAZWOPER, PSM, and chemical-specific plans simultaneously. The Integrated Contingency Plan (ICP) lets you combine them into a single document and is recognized by EPA, OSHA, DOT, and Coast Guard.
In a review of environmental and safety regulations, you’ll find quite a few references to developing emergency response plans or emergency response procedures. Each one has its own purpose and requirements. Below is a list of the most commonly required emergency plans, along with their standards reference and a brief description.
⚠️ Why this matters: Facilities commonly discover they’re missing 2–3 required emergency plans only during an inspection, a spill, or an insurance audit. Each missing plan is a separate citation path and, after a real incident, a separate litigation exposure. The plans take weeks to do right but are weeks many facilities don’t have once the trigger event happens.
EPA Plans
Spill Prevention, Control and Countermeasures (SPCC) — 40 CFR 112
SPCC Plans cover all types of oils, including petroleum, fuel oil, sludge, vegetable oils, mineral oils, and synthetic oils. If your facility has aboveground capacity of 1,320 gallons or more, or underground capacity of 42,000 gallons or more, you qualify.
Facility Response Plans (FRP) — 40 CFR 112
If you have over 42,000 gallons of oils being transferred over water to/from vessels, or over 1,000,000 gallons and meet certain criteria, an FRP is required in addition to the SPCC. Both SPCC and FRP stem from the Federal Water Pollution Control Act.
Risk Management Plans (RMP) — 40 CFR 68
RMPs come from the Clean Air Act. They apply to facilities such as chemical manufacturers, water treatment plants, cold storage facilities, and COOPs that store regulated substances in quantities greater than listed thresholds.
Hazardous Waste Contingency Plans — 40 CFR 262
Part of the RCRA hazardous waste regulations, these apply to both small and large quantity generators. The term “contingency plan” is only for large quantity generators; small quantity generators still need to develop emergency procedures, just without the formal name.
OSHA Plans
Emergency Action Plans (EAP) — 29 CFR 1910.38
EAPs are specifically mentioned in regulations related to confined spaces, bloodborne pathogens, fire protection, lab safety, and medical services/first aid. At a minimum, an EAP must include procedures for:
- Reporting a fire or other emergency
- Emergency evacuation, including type and exit routes
- Employees who remain to operate critical plant operations before evacuating
- Accounting for all employees after evacuation
- Employees performing rescue or medical duties
- Name and job title of every employee who may be contacted for more information about the plan
HAZWOPER Emergency Response Plans — 29 CFR 1910.120
Required if your company has employees assigned to respond to releases of hazardous substances at any location — regular work location or a duty station like a fire department, fire brigade, or emergency medical service. EPA has also adopted the HAZWOPER plan into its SARA regulations at 40 CFR 311 for state and local government employees in federal-OSHA states and their volunteers.
Process Safety Emergency Planning — 29 CFR 1910.119
Workplaces subject to OSHA’s PSM standard must have emergency plans. These aren’t much different than EAPs, but add requirements for small releases.
Fire Prevention Plans — 29 CFR 1910.39
When an OSHA standard requires a fire prevention plan, the requirements are here. Referenced standards include portable fire extinguishers, ethylene oxide, methylenedianiline, and 1,3-butadiene.
Not sure which plans apply to your facility — or which ones you already have don’t actually meet the rule? iSi runs applicability reviews and writes/consolidates emergency plans, including ICPs. See our environmental compliance services →
Chemical-Specific OSHA Plans
Several OSHA standards for specific chemicals reference required emergency procedures:
- 13 Carcinogens — 29 CFR 1910.1003(e)(4)(ii) — prescribed, posted, rehearsed emergency procedures
- Vinyl chloride — 29 CFR 1910.1017(i) — written operational emergency plan for storage/handling/use as liquid or compressed gas
- Beryllium — 29 CFR 1910.1024(m)(4)(ii) — written exposure control plan including emergency procedures
- Cadmium — 29 CFR 1910.1027(h) — written plan for substantial airborne cadmium releases
- DBCP (1,2-dibromo-3-chloropropane) — 29 CFR 1910.1044(i)(1)(i) — written emergency plan per workplace
- Acrylonitrile — 29 CFR 1910.1045(i)(1)(i) — written emergency plan where liquid AN is present
- Ethylene oxide — 29 CFR 1910.1047(h)(1)(i) — written emergency plan where emergency is possible
- Formaldehyde — 29 CFR 1910.1048(n)(4)(i) — training materials must review emergency procedures and employee duties
- Methylenedianiline — 29 CFR 1910.1050(d)(1)(i) — written emergency plan where emergency is possible
- 1,3-Butadiene — 29 CFR 1910.1051(j) — plan must contain applicable elements of 1910.38, 1910.39, and 1910.120
Other Agency Plans
Several other agencies require emergency plans depending on operations:
- DOT RSPA Pipeline Response Plan — 49 CFR Part 194 — onshore oil pipelines with discharge potential to navigable waters or shorelines
- Coast Guard Facility Response Plan — 33 CFR 154, Subpart F — marine transportation-related facilities with oil discharge potential
- DOI Minerals Management Service Facility Response Plan — 30 CFR Part 254 — oil handling/storage/transportation facilities seaward of the coast line
- FEMA Emergency Operation Plan — 44 CFR Part 302 — jurisdictions receiving FEMA emergency management performance grants
- Federal Radiological Emergency Response Plan — 10 CFR Part 50 — potential accidents involving nuclear material
- State-specific plans — vary
One Plan to Cover Many: The Integrated Contingency Plan (ICP)
A facility may need several of these plans, and requirements overlap. Maintaining separate plans becomes a nightmare. The National Response Team (NRT) — EPA (chair), OSHA, Coast Guard, Minerals Management Service, and DOT’s RSPA — developed guidance for an Integrated Contingency Plan that combines them.
An ICP applies to oils and non-radiological hazardous substances and can consolidate:
- SPCC Plan
- EPA Facility Response Plan
- EPA Risk Management Plan
- Hazardous Waste Contingency Plan
- OSHA Emergency Action Plan
- OSHA HAZWOPER Plan
- OSHA Process Safety Emergency Plan
- DOT Pipeline Response Plan
- Coast Guard Facility Response Plan
- Minerals Management Service Facility Response Plan
You must still include all elements of each underlying plan. NRT suggests you also incorporate state and local-specific emergency response procedures. You’re free to hold separate plans — the ICP is just an option to demonstrate consolidated compliance.
💰 What missing a required plan costs: EPA SPCC/FRP violations can run $55K+ per day per violation. OSHA EAP or HAZWOPER citations commonly stack with General Duty and recordkeeping citations post-incident. Insurance carriers have been known to deny claims when the regulatory plan required for the operation wasn’t on file. Typical cost of building an ICP: small fraction of a single penalty day.
Frequently Asked Questions
Q: What emergency response plans does OSHA require versus EPA?
OSHA requires Emergency Action Plans (EAP, 1910.38), HAZWOPER Emergency Response Plans (1910.120), Process Safety emergency plans (1910.119), and chemical-specific plans. EPA requires SPCC Plans, Facility Response Plans, Risk Management Plans (RMP), and Hazardous Waste Contingency Plans. Many facilities must have multiple overlapping plans.
Q: What is an Integrated Contingency Plan (ICP) and how does it help facilities?
An ICP is NRT guidance allowing facilities to consolidate EPA, OSHA, DOT, and Coast Guard emergency requirements into one document — covering SPCC, FRP, RMP, RCRA contingency, EAP, HAZWOPER, PSM emergency plan, and DOT/Coast Guard plans — provided all required elements are included.
Q: What should a basic Emergency Action Plan include?
OSHA EAPs must include procedures for reporting emergencies, evacuation routes, identification of employees remaining for critical operations, procedures for accounting for employees after evacuation, rescue and medical duty assignments, and contacts for plan information.
Q: Which chemical-specific standards require emergency procedures?
OSHA standards for 13 carcinogens, vinyl chloride, beryllium, cadmium, acrylonitrile, ethylene oxide, formaldehyde, methylenedianiline, 1,3-butadiene, and DBCP all require written emergency procedures on top of facility-wide EAPs.
Q: How do I know if I need an SPCC plan?
If you have aggregate aboveground oil storage of 1,320 gallons or more (counting containers 55 gallons or larger), or underground capacity of 42,000 gallons or more, and a reasonable potential for oil discharge to navigable waters. If you’re above threshold and no SPCC exists, you’re out of compliance by default — threshold triggers the requirement.
Q: Can one plan cover multiple OSHA standards?
Yes — an ICP or a well-structured facility EAP can reference HAZWOPER, PSM, and fire prevention elements in one document, provided every required element of each standard is explicitly addressed. The danger is assuming consolidation means abbreviation — you still have to include everything.
Need help determining which plans you need, or consolidating existing plans into an ICP? Run the 60-second Compliance Gap check or get a scoped proposal from our team.
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