National Safety Month - What Does OSHA Say About Emergency Preparedness?

For Week #3 of National Safety Month, I decided to do a short run-down of the various emergency preparedness regulations (and recommendations) from OSHA, USEPA, FEMA, SBA, USDHS, and others. 

Disclaimer: I am not covering anything about OSHA's Process Safety Management (PSM) regulations - it's not my area of expertise. 

So what does OSHA say about emergency preparedness? Lots.

Some helpful references to get you started:
- OSHA's FactSheet on "Planning and Responding to Workplace Emergencies."
- OSHA's Compliance Directive # CPL 2-1.037 "Compliance Policy for Emergency Action Plans and Fire Prevention Plans."
- OSHA's e-Tool for Emergency Evacuation Plans and Procedures.

Let's do a *theoretical* Q&A using the OSHA references provided above.

Q: Do I need an emergency action plan (EAP)?
A: More than likely. Certain workplaces require an EAP, like those using PSM, grain handling, ethylene oxide, and other hazardous chemicals. Almost every business is required to have an emergency action plan (EAP). If fire extinguishers are required or provided in your workplace, and if anyone will be evacuating during a fire or other emergency, then OSHA's 29 CFR 1910.157 requires you to have an EAP.

Q: What needs to be in the EAP?
A: If you have less than 10 employees, be aware that you can communicate the EAP verbally and still be in compliance. 

Your EAP must at least cover the following:

1. Escape procedures and emergency escape route assignments.
2. Procedures to be followed by employees who remain to operate critical plant operations before they evacuate.
3. Procedures to account for all employees after emergency evacuation has been completed.
4. Rescue and medical duties for those employees who are to perform them.
5. Means of reporting fires and other emergencies.
6. Names or job titles of persons who can be contacted for further information or explanation of duties under the plan.

Where can you find an EAP template? The CDC has a Word document template downloadable here. OSHA also has a Emergency Action Plan Expert System that you can use to have a customized EAP for your business. 

Q: How often should I evaluate my EAP?
A. You hopefully reviewed the EAP with employees when the EAP was put in place. The only requirement is to re-evaluate the plan periodically when the plan itself changes, employee responsibilities change, or the exit routes change (i.e. during a building renovation). 

Q: Do I have to train my employees in using fire extinguishers and providing first aid or cardio-pulmonary resuscitation (CPR)?
A: First aid and CPR must be available to employees within 3 to 4 minutes of an emergency. Workplaces that are more than 3 to 4 minutes from an infirmary, clinic, or hospital should have first aid and CPR trained staff on site for all shifts. If there are first aid trained people on staff, you must have first aid supplies, personal protective equipment (PPE), and a bloodborne pathogen program for the designated first responders at your site.

If you require employees to attempt to put out incipient fires using supplied fire extinguishers, then you have to train them how to use the fire extinguishers properly. If your EAP requires all employees to evacuate to safety in case of a fire (no employee fire-fighting required), you can skip the requirement for training in portable fire extinguishers; however, there are still maintenance, inspection, and testing requirements for portable fire extinguishers that must be met. 

Hopefully this helps get your brain ready and excited to learn more about emergency preparedness. 

Safety Violations in Hospitality Industry - Hawaii's latest

Kauai Beach Resort faces $50K in fines for safety violations - Thegardenisland.com: Local

Courtesy of The Garden Island, a Kauai hotel (Kauai Beach Resort) received 14 safety and health violations from the OSHA Honolulu office. Several of the violations were classified as serious, involving storage/handling/labeling of propane tanks, electrical wiring, electrical work practices by untrained maintenance personnel, and training and use of personal respiratory and electrical personal protective equipment (PPE).

The hospitality industry is one of the local emphasis programs in place for the Hawaii OSHA office, and they like to focus on the "behind the scenes" areas of the hotels and resorts. This was a routine inspection, not based on any specific complaint.

In April, the OSHA Honolulu office cited the owner of a Waikiki hotel, giving Halekulani Corp. 17 safety violations, 14 of which were classified as serious. These serious violations involved PPE use and availability, fire extinguisher maintenance and inspection, and the providing protective equipment for electrical work. According to the announcement from OSHA, the hotel owners also "failed to provide training in hazardous waste operations and emergency response standards." There were also issues with labeling, access to electrical panels, and issues with labeling on gas tanks.

A common violation in the hospitality industry is the blood borne pathogens standard - laundry and housekeeping staff may have exposure to blood and other potentially infectious materials (OPIM), and per OSHA, "it is the employer's responsibility to determine which job classifications or specific tasks and procedures involve reasonably anticipated contact with blood or OPIM. "

Courtesy of Curtis Law Construction in Kauai, according to Hawaii OSHA representatives, the following are the top violations in Hawaii construction industry (paraphrased from webpage linked above):

• Fall Protection (lanyards not attached, guardrails and toeboards not sufficient, ladders not secured)
• Trenching (sloping, shoring, and trench boxes not in compliance, no competent person inspections)
• Fork Lifts (no certificates of training, no seat belt or horn in use, load capacity not written on forklift)
• Heavy Equipment (operators not trained properly, no backup alarms, seat belts not being used, brakes not checked, no reflective vests)
• Cranes (operators not certified, no records or maintenance logs, no electrical safety training, rigging issues, swing radius not barricaded)
• Electrical Safety (no grounding pins, unlabeled circuit breakers, no front panel, no open space in front of breaker/area in front of panel blocked, lack of outer insulation)
• General (machine guarding issues, no hazard communication program, insufficient training, PPE not worn or not sufficient)

There is not a Safety/Health Topics page on federal OSHA's website for the hospitality industry, so finding compliance information may be difficult for owners of hotels and other hospitality industry companies. Other locales in the U.S. with a high tourism rate and large number of hospitality industries may notice an uptick in routine inspections at their facilities.