Kevin Ian Schmidt

Hazard Communication Plan Explained

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More than 30 million workers in the United States are potentially exposed to one or more chemical hazards. There are an estimated 650,000 existing hazardous chemical products, and hundreds of new ones are being introduced annually. This poses a serious problem for exposed workers and their employers.

The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. This update will also help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store, and use hazardous chemicals while providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.

OSHA.gov

How does the OSHA Hazard Communication Standard effect your business? Well first let’s take a look at what OSHA sets as some standards.

The OSHA Hazard Communication Standard (HCS) – 29 CFR 1910.1200 provides workers exposed to hazardous chemicals with the identities and hazards of those materials,

From OSHA.gov

Hazard Communication Standard

spray-bottleIn order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to workers. OSHA’s Hazard Communication Standard (HCS) requires the development and dissemination of such information:

  • All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.

So you read this and say to yourself, “I don’t deal in hazardous chemicals”. But if you have things like cleaning chemicals, that employees or the public can handle, then you need to comply with OSHA’s Hazard Communication Standard. Employees need to be familiar with OSHA’s hazard communication standards to help save lives and avoid OSHA citations.

 

Purpose of the HAZCOM standard

The purpose of the HCS 2012 is to make sure that:

  1. the hazards of all chemicals produced or imported are classified, and
  2. information about the classified hazards is transmitted to employers and employees.

Classifying the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, may include:

  • hazard communication plandeveloping and maintaining a written hazard communication program
  • listing hazardous chemicals present
  • labeling containers of chemicals in the workplace
  • labeling containers of chemicals being shipped to other workplaces
  • preparing and distributing SDSs to employees and downstream employers
  • developing and implementing employee training programs

The HCS 2012 applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.

“Foreseeable emergency” means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.

The phrase “known to be present” is important. If a hazardous chemical is known to be present by the chemical manufacturer or the employer, it is covered by the standard.

Check Out: How to Read an SDS Sheet

This includes not using generic, unlabeled cleaners, or buying cleaners in bulk and putting them in unlabeled bottles. Using a marker on the bottle isn’t enough either.

“Hazardous chemical” means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

This includes chemicals to which employees may be exposed during normal operations or in a foreseeable emergency. This means that even though an employer was not responsible for the manufacture of the hazardous chemical, the employer has the responsibility for transmitting information about the hazardous chemical to his or her employees.

 

OSHA Definitions of Chemical Hazards

Do not think that the chemicals which apply to the rule are only those in liquid, gas or particulate form. But, the standard’s definition of “chemical” is much broader than that commonly used. According to the HCS, chemicals that apply may exist in one of many forms:

  • Dusts – are finely divided particles. Example – wood dust.
  • Fumes – are even smaller particles usually formed when solid metal is heated and vaporized, and then condenses as tiny particles.
  • Fibers – are similar to dusts but are of an elongated shape. Examples – asbestos and fiberglass.
  • Mists – are liquid droplets that have been sprayed into the atmosphere.
  • Vapors – are gases formed when liquid evaporates.
  • Gases – are substances that are normally airborne at room temperature. A vapor is the gaseous phase of a substance which is a normally a liquid or solid at room temperature.
  • Solids – such as metal, treated wood, plastic.
  • Liquids – the most common form in the workplace.

Chemical Effects

The effects chemicals have on the various organs of the human body depend on several important factors:

  1. The form of the chemical: Is the chemical a solid, liquid, or gas?
  2. The route of entry, or how the chemical contacts the body: is it ingested, inhaled, absorbed or injected?
  3. The dose, or amount, the body receives: How much chemical makes its way into the body?
  4. The toxicity: How poisonous is the chemical?

Routes of Entry

Another important task when assessing the workplace for chemical hazards is to determine the route(s) of entry the chemicals may take. If we know the route(s) of entry, we can then determine appropriate engineering, administrative, and PPE controls to eliminate or reduce the exposure. The four common routes of entry are:

  1. Ingestion: Do we eat or drink it?
  2. Inhalation: Do we breathe it in? This is the most common route of entry.
  3. Absorption: Does it pass through the skin, eyes or other membranes?
  4. Injection: Does it enter through a puncture or cut?
Check Out: Hazard Communication Standard Training for Supervisors

Employees, such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. For example, an office worker who occasionally changes the toner in a copying machine would not be covered by the standard. However, an employee who operates a copying machine as part of her/his work duties would be covered by the HAZCOM Standard.

Do you have all SDS sheets and a chemical listing of chemicals onsite, that is available to all employees, not locked in a drawer in a back office. Online access is acceptable, as long as all employees know how to get it and have access to a computer.

Employer Responsibilities

SDSs may be kept at the primary workplace facility or online, as long as the employer can ensure employees have quick access to the information.

  • Employers must obtain a SDS from the chemical manufacturer or importer as soon as possible if the SDS is not provided with a shipment that has been labeled as a hazardous chemical.
  • Employers must maintain SDSs in their workplace and must ensure that they are readily accessible during each work shift to employees when they are in their work area(s).
  • Electronic access and other alternatives to maintaining paper copies of the SDS are permitted as long as no barriers to immediate employee access in each workplace are created by such options. Make sure employees know how to quickly access SDS information that is stored on computers or online.
  • Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the SDSs may be kept at the primary workplace facility. In this situation, the employer must ensure that employees can immediately obtain the required information in an emergency.
  • Employees who work at more than one site during the work shift must be able to obtain SDS information immediately (within seconds) in an emergency.
  • SDSs may be kept at the primary workplace facility, as long as the employer has a representative available at all times to ensure ready access (within a few minutes) to this information. This is the only situation in which an employer is allowed to transmit hazard information via voice communication. The employer must address in the written hazard communication plan how SDS information will be conveyed to remote worksites.
  • SDSs may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals.

Have you conducted employee awareness training on how to read an SDS sheet?

 

Download and view a sample HAZCOM policy below; that can be adapted for your needs, but remember a small business owner might find a full and proper Hazard Communication Plan to be overwhelming to fully and properly design.

 

Sample_HAZCOM_program_final

First Aid Training and Kit Requirements

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Does your business have a first aid kit? Do you have people in your business trained to render first aid?  What are the requirements for first aid kits, first aid training, and such according to OSHA?

1910.151(b)

In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.

 

Near Proximity for First Aid Responders

first-aidSo first let’s talk about what OSHA means by “near proximity”, because that can be vague. In a workplace, where employees may be exposed to hazards, like machinery or powered equipment, a response time over 3-4 minutes in considered “near proximity”, and for an office setting, “near proximity” is deemed 15 minutes. This comes from the OSHA Letter of Interpretation from March 2007.

So how does this effect your workplace if you are a retail establishment? Do you have any machines employees use, baggers, cardboard compactor, steamer, or anything else? Then you should probably hold your business to the standard for a 3-4 minute response time. This holds true for a restaurant, where an employee could burn themselves severely.

Now, factor in that the national average response time for an ambulance in most urban environments is 8 minutes or MORE, and you soon realize, you would be outside of the OSHA standards for near proximity and should have trained first aid responders on site.

 

 

First Aid Kit Requirements

first aid kitHaving a first aid kit in the workplace is just a good safety precaution, even if you feel you aren’t required to under OSHA guidelines. It can become confusing though, because the OSHA Regulation, simply says “Adequate first aid supplies shall be readily available.” What is deemed adequate? What supplies must you have?

In an OSHA Letter of Interpretation from April 2002, Richard E. Fairfax, Director: Directorate of [Enforcement] Programs for OSHA talks of how the ANSI standard Z308.1-1998 would be deemed adequate for most small workplaces, but you should also have suitable supplies for the risks in your workplace.

ANSI standard Z308.1-1998 supplies

ANSI/SEA Z308.1 2009 – Minimum Requirements for Workplace First Aid Kits and Supplies Basic Kit – minimum contents.

 

ITEM MINIMUM QUANTITY
Absorbent compress, 32 sq. in. 1
Adhesive bandages, 1 in. x 3 in. 16
Adhesive tape, 3/8 in. x 2.5 yd. total 1
Antibiotic treatment,0.14 fl. Oz. (0.9 g) 6
Antiseptic,0.14 fl. Oz. (0.5 g) application 10
Burn treatment, 1/32 oz. (0.9 g) application 6
First-aid guide 1
Medical exam gloves 2 pairs
Sterile pads, 3 in. x 3 in. 4
Triangular bandage, 40 in. x 40 in. 56 in. 1

 

first-aid-kit-unstockedThis amount would be sufficient for a small workplace, with 2-3 employees, and then increase the amount of supplies as you increase employees, and also consider having one basic kit of bandages in the front of the business and a larger more comprehensive amount of first aid supplies in the back office.

If you plan on keeping your medical cabinet locked up in a back office, consider this OSHA Letter of Interpretation from January 2007, which says it is ok to lock the medicine cabinet up, but it must be accessible during an emergency. So, be careful with locking it up, because if it isn’t accessible when needed, it can result in a worse injury, and potentially trigger an OSHA inspection.

It is also important to note that if you have a first aid kit, and it is poorly maintained, OSHA could find you in Willful noncompliance, which could dramatically increase your fines.

 

First Aid Training and Bloodborne Pathogens Requirements

bodily-fluid-cleanup-kitIf you determine your business is required to provide first aid training, know that OSHA has requirements for providing Bloodborne Pathogen training along with it, as clarified by this OSHA Letter of Interpretation from January 2007.

So what does that mean for your business? Well, OSHA’s Bloodborne Pathogen Standard has specific rules as they relate to training, recordkeeping, and even offering Hepatitis B vaccinations.

Check Out: BloodBorne Pathogen Exposure Control Plan

One aspect of the Bloodborne Pathogen requirement that is often overlooked is a policy, written specifically that addresses workplace exposure risks, along with proper handling and cleanup of blood and other bodily fluids.

You also need the proper bloodborne pathogen cleanup kit, I you have bloodborne pathogen training for employees. Because like earlier, partially implementing a program or plan, could show OSHA you were aware of your requirements but didn’t follow through with them, and increase a citation to a Willful, and lead to much higher fines.

 

 

 

 

Guidelines for Investigation Interviews

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Definition
Employee Investigation Interviews are set up to review claims made by employees regarding discrimination, harassment, violence, or other prohibited behaviors in the workplace.

 

The Investigation Interview Process

When you’re conducting employee investigation interviews, the interview process should be carefully planned, followed, and documented to help mitigate exposure to litigation. The sequence of interviews should generally start with the complainant, followed by the accused, and then any witnesses or other parties involved.

While there is no law mandating how quickly an investigation must begin, a good rule of thumb is to start the investigation within two business days of receiving the complaint. A prompt investigation will offer several advantages:

  • Memories are fresh.
  • Witnesses and other relevant parties will still be available.
  • Gossip or rumor mills are less likely to interfere with information.
  • Witnesses will less likely be tampered with or intimidated.
Check out my post Factors to consider in an investigative interview for more tips on the process

Documentation

Take detailed notes during each interview. Make sure you are only documenting factual information and observable facts about the interviewee’s behavior and demeanor during the interview. Avoid assumptions or opinions about what is said or what you believe to have happened. Stay away from documenting subjective conclusions based on the interviewee’s behavior or demeanor during the interview. Notes should include the following:

  • Administrative details such as name, job title, and date of interview
  • Warning statements such as “keep information confidential,” “no retaliation,” etc.
  • Key factual points of the interview
  • Non-verbal expressions like tears, failure to look interviewer in the eye, and nervous affectations

Maintain all documentation related to the investigation in a separate, confidential file apart from the employees’ general personnel files. Limit access to investigation files to only those with a legitimate need to know.

Check Out: Effective Communication Skills – NONVERBAL

Questioning Techniques

Prepare questions in advance:

  • Ask who, what, where, when, why, and how.
  • Ask questions that require events be stated chronologically. This allows the investigator to compare different versions of the story.
  • Although you should plan your questions in advance, additional questions may arise based on the information you gather. Don’t limit yourself to the planned questions; ask follow-up questions to clarify.

Keep these few tips in mind when interviewing:

  • Begin with open-ended questions, then transition to more detailed, specific questions.
  • Avoid asking tough questions first; start with simpler questions to put the interviewee at ease.
  • Ask one question at a time and do not move on to the next question until you have all the information needed. Do not interrupt.
  • Ask for specific examples.
  • Remain neutral; don’t formulate an opinion before all the facts have been gathered.
Check Out: Effective Communication Skills – LISTENING

Interviewing the Complainant

When you begin the interview, state the purpose of the meeting and restate relevant company policy. Inform the complainant that the company takes all complaints seriously and will conduct a prompt and thorough investigation. Thank the complainant for bringing the matter to the company’s attention and assure the person the information will be confidential to the extent possible.

Ask for a full explanation of the situation. Ask specific questions such as:

  • What happened?
  • Who said what?
  • Where did the incident take place?
  • What time did it happen?
  • Who was present?

When concluding the interview, ask if there were other witnesses; document the response even if the complainant says no. Summarize the interview with the complainant and have the complainant confirm that it is accurate. Document the response to the confirmation question. Instruct the interviewee to provide any additional information that may not have been covered. Remind the interviewee that all information should be kept confidential. And last, but definitely not least, reiterate the no-retaliation policy, telling the interviewee to report any retaliation incidents.

Interviewing the Accused

When you start this interview, let the accused know that you are conducting an investigation of wrongdoing on behalf of the employer and that he/she is the subject of the investigation. Inform the individual of the accusations so the accused can respond and reiterate confidentiality and no-retaliation policies.

Ask the accused for a response to the allegations of wrongdoing; ask clarifying questions about who, what, where, when, and how the incident occurred. Ask if the accused understands the company policy regarding the situation. Also, ask if there is anyone who can corroborate the accused’s story.

When you conclude the interview, ask the accused if there were any witnesses. Summarize the account just provided and have the accused confirm the account is accurate as it was told. Ask the accused to report any additional information that comes to mind after the interview is over. And last, remind the accused of the confidentiality of the information provided and the no-retaliation company policy.

Interviewing the Witnesses

When you are ready to interview any witnesses, make sure you talk to each one individually. Explain the purpose of the interview and ask the witness for any information about the situation. At the end of the interview, remind witnesses of the confidentiality of the information provided and the no-retaliation policy.

When you conclude the interview, ask the witness if there is anyone else the interviewer should talk to; document the answer, even if it is no. Summarize the witness’s statement and confirm with the witness that it is accurate as reported.

Interviewing each person thoroughly and carefully in an employee investigation is critical to getting the facts – from all involved – correct. Remember, someone’s job or life could be adversely affected by the outcome of your investigation. Do your very best to conduct unbiased and clear interviews.

 

These investigation interview tips will help keep you sharp, but if you need professional assistance, or want to conduct a training for your staff, please feel free to contact me.

Fire Prevention Plan – Overview

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The purpose of a Fire Prevention Plan is to eliminate the causes of fire, prevent loss of life and property by fire, and to comply with the Occupational Safety and Health Administration’s (OSHA) standard on fire prevention, 29 CFR 1910.39. It provides employees with information and guidelines that will assist them in recognizing, reporting, and controlling fire hazards.

A quality Fire Prevention Plan describes the fuel sources (hazardous or other materials) on site that could initiate or contribute both to the spread of a fire, as well as the building systems, such as fixed fire extinguishing systems and alarm systems, in place to control the ignition or spread of a fire.

 

OSHA Guidelines for a Fire Prevention Plan

A fire prevention plan must be in writing, be kept in the workplace, and be made available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees. [29 CFR 1910.39(b)]

At a minimum, your fire prevention plan must include:

  • A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard. [29 CFR 1910.39(c)(1)]
  • Procedures to control accumulations of flammable and combustible waste materials. [29 CFR 1910.39(c)(2)]
  • Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials. [29 CFR 1910.39(c)(3)]
  • The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires. [29 CFR 1910.39(c)(4)]
  • The name or job title of employees responsible for the control of fuel source hazards. [29 CFR 1910.39(c)(5)]
  • An employer must inform employees upon initial assignment to a job of the fire hazards to which they are exposed. An employer must also review with each employee those parts of the fire prevention plan necessary for self-protection. [29 CFR 1910.39(d)]
Learn how to conduct a Fire Risk Assessment to best formulate your Fire Prevention Plan

A Fire Prevention Plan serves to reduce the risk of fires at your workplace in the following ways:

  1. The Fire Prevention Plan identifies materials that are potential fire hazards and their proper handling and storage procedures.
  2. It distinguishes potential ignition sources and the proper control procedures of those materials.
  3. The plan describes fire protection equipment and/or systems used to control fire hazards.
  4. It identifies persons responsible for maintaining the equipment and systems installed to prevent or control ignition of fires.
  5. The Fire Prevention Plan identifies persons responsible for the control and accumulation of flammable or combustible material.
  6. It describes good housekeeping procedures necessary to insure the control of accumulated flammable and combustible waste material and residues to avoid a fire emergency.
  7. The plan provides training to employees with regard to fire hazards to which they may be exposed.

 

Fire Risk Assessment

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Prior to fighting any fire with a portable fire extinguisher you must perform a fire risk assessment that evaluates the fire size, the fire fighters evacuation path, and the atmosphere in the vicinity of the fire.

Check Out: Fire Extinguisher Basics
Risk Assessment Question Characteristics of incipient stage fires or fires that can be extinguished with portable fire extinguishers Characteristics of fires that

SHOULD NOT be fought with a portable fire extinguisher (beyond incipient stage) – evacuate immediately

Is the fire too big? The fire is limited to the original material ignited, it is contained (such as in a waste basket) and has not spread to other materials. The flames are no higher than the firefighter’s head. The fire involves flammable solvents, has spread over more than 60 square feet, is partially hidden behind a wall or ceiling, or cannot be reached from a standing position.
Is the air safe to breathe? The fire has not depleted the oxygen in the room and is producing only small quantities of toxic gases. No respiratory protection equipment is required. Due to smoke and products of combustion, the fire cannot be fought without respiratory protection.
Is the environment too hot or smoky? Heat is being generated, but the room temperature is only slightly increased. Smoke may be accumulating on the

ceiling, but visibility is good. No special personal protective equipment is required.

 The radiated heat is easily felt on exposed skin making it difficult to approach within 10-15 feet of the fire (or the effective range of the extinguisher). One must crawl on the floor due to heat or smoke. Smoke is quickly filling the room, decreasing visibility.
Is there a safe evacuation path? There is a clear evacuation path that is behind you as you fight the fire. The fire is not contained, and fire, heat, or smoke may block the evacuation path.

Emergency Exits: OSHA Standards

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Emergency Exits are in every business, they are even required by most fire codes, but they are often an overlooked and worse even neglected integral part of a successful safety program. They should even be addressed in your Emergency Action Plan, but if you don’t address them correctly, it can result in OSHA fines, or worse an injured employee or customer.

OSHA standards for emergency exits require employers to do the following:

■ Keep exit routes free of explosive or highly flammable furnishings and other decorations.
Keep flammable chairs, and decorations, or even flammable clothing displays back from emergency exits.
■ Arrange exit routes so employees will not have to travel toward a high-hazard area unless the path of travel is effectively shielded from the high-hazard area.
emergency exitsCheck Out: Fire Risk Assessments

If an exit route is through a backroom, between 2 giant stacks of cardboard boxes, or similar material, it probably won’t meet this standard.

■ Ensure that exit routes are unobstructed such as by materials, equipment, locked doors, or dead-end corridors.
Not only do exit routes and doors have to have a clear path of egress, you also need to ensure that the path doesn’t require weaving around items, or working through a maze of rooms.
■ Ensure that safeguards designed to protect employees during an emergency remain in good working order.
Do you have sprinklers? They need to be inspected regularly. Do you have emergency lights? They need to be inspected regularly. If you have things to protect people, they need to function, test them regularly don’t just trust that they will work during an emergency.
■ Provide lighting for exit routes adequate for employees with normal vision.
blocked-fire-exitIf the lights in your business go out, do you have emergency lighting and is it adequate? You can actually purchase emergency lights that won’t be obtrusive, and blend in with your decor.
■ Keep exit route doors free of decorations or signs that obscure the visibility of exit route doors
We all love to have our business looking great on the inside, decorations, mentions of upcoming events, and such, but keep these things off emergency exit doors, keep the doors easily identifiable for there purpose.
■ Post signs along the exit access indicating the direction of travel to the nearest exit and exit discharge if that direction is not immediately apparent. Also, the line-of-sight to an exit sign must be clearly visible at all times.
Easiest way to check this, is stand in the middle of your business, can you clearly see an emergency exit? If not, you need to add a sign pointing towards the nearest exit. Now move around your business, do you see exits from all the different vantage points? Don’t forget store rooms, back offices and such.
■ Mark doors or passages along an exit access that could be mistaken for an exit “Not an Exit” or with a sign identifying its use (such as “Closet”).
Is your emergency exit the last door on the left, down a hallway? All other doors need to be marked as “not an exit”.
■ Install “EXIT” signs in plainly legible letters.
blocked emergency exitNo fancy script, no plain arrows, simple to read block letters.
■ Renew fire-retardant paints or solutions often enough to maintain their fire-retardant properties.
Did you have a wall painted with fire retardant paint to aid in an evacuation? Did you know even the manufacturer recommends refreshing it every couple of years? Don’t forget little maintenance like that.
■ Maintain exit routes during construction, repairs, or alterations.
Doing some renovations? Keep your exit routes clear, keep the signs visible, or offer secondary routes.
■ Provide an emergency alarm system to alert employees, unless employees can promptly see or smell a fire or other hazard in time to provide adequate warning to them.
Honestly, the baseline standard here, if your business is larger that a single room, you need some form of emergency alarm system.

I hope you understand these guidelines, use them as a baseline for your own emergency exits and exit routes. Check out your own business, or contact me and I will happily discuss setting up an audit, or just answer some of your questions.

Emergency Action Plan Checklist

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It is essential that the emergency action plan developed be site specific with respect to emergency conditions evaluated, evacuation policies and procedures, emergency reporting mechanisms, and alarm systems. To assist you in your planning, a checklist is provided that identifies issues that must be considered when drafting a comprehensive emergency action plan. An explanation of each issue and/or examples of how each issue might be addressed in typical workplaces is provided.

Download the checklist here

Download the checklist here for FREE

 

 

 

 

General Issues
1. Does the plan consider all potential natural or man-made emergencies that could disrupt your workplace? Common sources of emergencies identified in emergency action plans include – fires, explosions, floods, hurricanes, tornadoes, toxic material releases, radiological and biological accidents, civil disturbances and workplace violence.
2. Does the plan consider all potential internal sources of emergencies that could disrupt your workplace? Conduct a hazard assessment of the workplace to identify any physical or chemical hazards that may exist and could cause an emergency.
3. Does the plan consider the impact of these internal and external emergencies on the workplace’s operations and is the response tailored to the workplace? Brainstorm worst case scenarios asking yourself what you would do and what would be the likely impact on your operation and device appropriate responses.
4. Does the plan contain a list of key personnel with contact information as well as contact information for local emergency responders, agencies and contractors? Keep your list of key contacts current and make provisions for an emergency communications system such as a cellular phone, a portable radio unit, or other means so that contact with local law enforcement, the fire department, and others can be swift.
5. Does the plan contain the names, titles, departments, and telephone numbers of individuals to contact for additional information or an explanation of duties and responsibilities under the plan? List names and contact information for individuals responsible for implementation of the plan.
6. Does the plan address how rescue operations will be performed? Unless you are a large employer handling hazardous materials and processes or have employees regularly working in hazardous situations, you will probably choose to rely on local public resources, such as the fire department, who are trained, equipped, and certified to conduct rescues. Make sure any external department or agency identified in your plan is prepared to respond as outlined in your plan. Untrained individuals may endanger themselves and those they are trying to rescue.
7. Does the plan address how medical assistance will be provided? Most small employers do not have a formal internal medical program and make arrangements with medical clinics or facilities close by to handle emergency cases and provide medical and first-aid services to their employees. If an infirmary, clinic, or hospital is not close to your workplace, ensure that onsite person(s) have adequate training in first aid. The American Red Cross, some insurance providers, local safety councils, fire departments, or other resources may be able to provide this training. Treatment of a serious injury should begin within 3 to 4 minutes of the accident. Consult with a physician to order appropriate first-aid supplies for emergencies. Establish a relationship with a local ambulance service so transportation is readily available for emergencies.
8. Does the plan identify how or where personal information on employees can be obtained in an emergency? In the event of an emergency, it could be important to have ready access to important personal information about your employees. This includes their home telephone numbers, the names and telephone numbers of their next of kin, and medical information.
Evacuation Policy and Procedures
1. Does the plan identify the conditions under which an evacuation would be necessary? The plan should identify the different types of situations that will require an evacuation of the workplace. This might include a fire, earthquake, or chemical spill. The extent of evacuation may be different for different types of hazards.
2. Does the plan identify a clear chain of command and designate a person authorized to order an evacuation or shutdown of operations? It is common practice to select a responsible individual to lead and coordinate your emergency plan and evacuation. It is critical that employees know who the coordinator is and understand that this person has the authority to make decisions during emergencies. The coordinator should be responsible for assessing the situation to determine whether an emergency exists requiring activation of the emergency procedures, overseeing emergency procedures, notifying and coordinating with outside emergency services, and directing shutdown of utilities or plant operations if necessary.
3. Does the plan address the types of actions expected of different employees for the various types of potential emergencies? The plan may specify different actions for employees depending on the emergency. For example, employers may want to have employees assemble in one area of the workplace if it is threatened by a tornado or earthquake but evacuate to an exterior location during a fire.
4. Does the plan designate who, if anyone, will stay to shut down critical operations during an evacuation? You may want to include in your plan locations where utilities (such as electrical and gas utilities) can be shut down for all or part of the facility. All individuals remaining behind to shut down critical systems or utilities must be capable of recognizing when to abandon the operation or task and evacuate themselves.
5. Does the plan outline specific evacuation routes and exits and are these posted in the workplace where they are easily accessible to all employees? Most employers create maps from floor diagrams with arrows that designate the exit route assignments. These maps should include locations of exits, assembly points and equipment (such as fire extinguishers, first aid kits, spill kits) that may be needed in an emergency. Exit routes should be clearly marked and well lit, wide enough to accommodate the number of evacuating personnel, unobstructed and clear of debris at all times, and unlikely to expose evacuating personnel to additional hazards.
6. Does the plan address procedures for assisting people during evacuations, particularly those with disabilities or who do not speak English? Many employers designate individuals as evacuation wardens to help move employees from danger to safe areas during an emergency. Generally, one warden for every 20 employees should be adequate, and the appropriate number of wardens should be available at all times during working hours. Wardens may be responsible for checking offices and bathrooms before being the last person to exit an area as well as ensuring that fire doors are closed when exiting. Employees designated to assist in emergency evacuation procedures should be trained in the complete workplace layout and various alternative escape routes. Employees designated to assist in emergencies should be made aware of employees with special needs (who may require extra assistance during an evacuation), how to use the buddy system, and any hazardous areas to avoid during an emergency evacuation.
7. Does the plan identify one or more assembly areas (as necessary for different types of emergencies) where employees will gather and a method for accounting for all employees? Accounting for all employees following an evacuation is critical. Confusion in the assembly areas can lead to delays in rescuing anyone trapped in the building, or unnecessary and dangerous search-and-rescue operations. To ensure the fastest, most accurate accounting of your employees, consider taking a head count after the evacuation. The names and last known locations of anyone not accounted for should be passed on to the official in charge.
8. Does the plan address how visitors will be assisted in evacuation and accounted for? Some employers have all visitors and contractors sign in when entering the workplace. The hosts and/or area wardens, if established, are often tasked with assisting these individuals evacuate safely.
Reporting Emergencies and Alerting Employees in an Emergency
1. Does the plan identify a preferred method for reporting fires and other emergencies? Dialing 911 is a common method for reporting emergencies if external responders are utilized. Internal numbers may be used. Internal numbers are sometimes connected to intercom systems so that coded announcements may be made. In some cases employees are requested to activate manual pull stations or other alarm systems.
2. Does the plan describe the method to be used to alert employees, including disabled workers, to evacuate or take other action? Make sure alarms are distinctive and recognized by all employees as a signal to evacuate the work area or perform other actions identified in your plan. Sequences of horn blows or different types of alarms (bells, horns, etc.) can be used to signal different responses or actions from employees. Consider making available an emergency communications system, such as a public address system, for broadcasting emergency information to employees. Ideally alarms will be able to be heard, seen, or otherwise perceived by everyone in the workplace including those that may be blind or deaf. Otherwise floor wardens or others must be tasked with ensuring all employees are notified. You might want to consider providing an auxiliary power supply in the event of an electrical failure.
Employee Training and Drills
1. Does the plan identify how and when employees will be trained so that they understand the types of emergencies that may occur, their responsibilities and actions as outlined in the plan? Training should be offered employees when you develop your initial plan and when new employees are hired. Employees should be retrained when your plan changes due to a change in the layout or design of the facility, when new equipment, hazardous materials, or processes are introduced that affect evacuation routes, or when new types of hazards are introduced that require special actions. General training for your employees should address the following:
Individual roles and responsibilities.
Threats, hazards, and protective actions.
Notification, warning, and communications procedures.
Emergency response procedures.
Evacuation, shelter, and accountability procedures.
Location and use of common emergency equipment.
Emergency shutdown procedures.
You may also need to provide additional training to your employees (i.e. first-aid procedures, portable fire extinguisher use, etc.) depending on the responsibilities allocated employees in your plan.
2. Does the plan address how and when retraining will be conducted? If training is not reinforced it will be forgotten. Consider retaining employees annually.
3. Does the plan address if and how often drills will be conducted? Once you have reviewed your emergency action plan with your employees and everyone has had the proper training, it is a good idea to hold practice drills as often as necessary to keep employees prepared. Include outside resources such as fire and police departments when possible. After each drill, gather management and employees to evaluate the effectiveness of the drill. Identify the strengths and weaknesses of your plan and work to improve it.

 

 

 

 

 

Shelter in Place – Emergency Action Plan

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Sometimes an emergency is best handled by doing a shelter in place, a good emergency action plan should take this into account and have the appropriate responses included in it.

Specific procedures for shelter in place at a worksite may include the following:

  • shelter in placeClose the business.
  • If there are customers, clients, or visitors in the building, provide for their safety by asking them to stay – not leave. When authorities provide directions to shelter-in-place, they want everyone to take those steps immediately. Do not drive or walk outdoors.
  • Unless there is an imminent threat, ask employees, customers, clients, and visitors to call their emergency contact to let them know where they are and that they are safe.
  • Turn on call-forwarding or alternative telephone answering systems or services. If the business has voice mail or an automated attendant, change the recording to indicate that the business is closed, and that staff and visitors are remaining in the building until authorities advise it is safe to leave.
  • Quickly lock exterior doors and close windows, air vents, and fireplace dampers. Have employees familiar with your building’s mechanical systems turn off all fans, heating and air conditioning systems, and clothes dryers. Some systems automatically provide for exchange of inside air with outside air. These systems, in particular, need to be turned off, sealed, or disabled.
Check Out: Emergency Response Plan Best Practices
  • If you are told there is danger of explosion, close the window shades, blinds, or curtains.
  • Gather essential disaster supplies, such as nonperishable food, bottled water, battery-powered radios, first-aid supplies, flashlights, batteries, duct tape, plastic sheeting, and plastic garbage bags.
  • Select interior room(s) above the ground floor, with the fewest windows or vents. The room(s) should have adequate space for everyone to be able to sit. Avoid overcrowding by selecting several rooms if necessary. Large storage closets, utility rooms, pantries, copy and conference rooms without exterior windows will work well. Avoid selecting a room with mechanical equipment like ventilation blowers or pipes, because this equipment may not be able to be sealed from the outdoors.
  • It is ideal to have a hard-wired telephone in the room(s) you select. Call emergency contacts and have the phone available if you need to report a life-threatening condition. Cellular telephone equipment may be overwhelmed or damaged during an emergency.
my blog has extensive resources on Emergency Action Plans
  • Take your emergency supplies and go into the room you have designated. Seal all windows, doors, and vents with plastic sheeting and duct tape or anything else you have on hand.
  • Consider precutting plastic sheeting (heavier than food wrap) to seal windows, doors, and air vents. Each piece should be several inches larger than the space you want to cover so that it lies flat against the wall. Label each piece with the location of where it fits. [See image at right]
  • Write down the names of everyone in the room, and call your business’ designated emergency contact to report who is in the room with you, and their affiliation with your business (employee, visitor, client, customer).
  • Listen to the radio, watch television, or use the Internet for further instructions until you are told all is safe or to evacuate. Local officials may call for evacuation in specific areas at greatest risk in your community.
Have some questions on how to properly figure which emergencies should be addressed by a shelter in place response and which should be handled with an evacuation? Check out this white paper by Oak Ridge National Laboratory (ORNL), (2002, June).

 

You do not need to include every process to shelter in place in your Emergency Action Plan, but you should address the relevant ones for the conditions in your area.

OSHA Fire Extinguisher Guidelines

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Where extinguishers are provided but are not intended for employee use and the employer has an emergency action plan and a fire prevention plan that meet the requirements of [29 CFR 1910.38], then only the requirements of the inspection, maintenance and testing and hydrostatic testing sections apply. [29 CFR 1910.157(a)]

 

As the owner of the business, you must:

  • Provide portable fire extinguishers and mount, locate, and identify them so that they are readily accessible to employees without subjecting the employees to possible injury. [29 CFR 1910.157(c)(1)]  Fire Extinguisher Placement
  • Use only approved portable fire extinguishers. [29 CFR 1910.157(c)(2)]  Type of fire extinguishers
  • Do not use portable fire extinguishers that use carbon tetrachloride or chlorobromomethane extinguishing agents. [29 CFR 1910.157(c)(3)]
  • Assure that portable fire extinguishers are maintained, fully charged, operating properly, and kept in designated places at all times except during use. [29 CFR 1910.157(c)(4)]  How to inspect a fire extinguisher
  • Remove from service all soldered or riveted shell self-generating soda acid or self-generating foam or gas cartridge water type portable fire extinguishers that are operated by inverting the extinguisher to rupture the cartridge or to initiate an uncontrollable pressure generating chemical reaction to expel the agent. [29 CFR 1910.157(c)(5)]
Check Out: Fire Extinguisher Inspections

The following exemptions apply:

  • Where the employer has established and implemented a written fire safety policy which requires the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal and which includes an emergency action plan and a fire prevention plan that meet the requirements of 29 CFR 1910.38 and 29 CFR 1910.39 respectively, and when extinguishers are not available in the workplace, the employer is exempt from all requirements of this section unless a specific standard in Part 1910 requires that a portable fire extinguisher be provided. [29 CFR 1910.157(b)(1)]
  • Where the employer has an emergency action plan meeting the requirements of 29 CFR 1910.38, which designates certain employees to be the only employees authorized to use the available portable fire extinguishers, and which requires all other employees in the fire area to immediately evacuate the affected work area upon the sounding of the fire alarm, the employer is exempt from the distribution requirements in the selection and distribution section. [29 CFR 1910.157(b)(2)]

 

Learn more about fire extinguisher selection and placement

An employer must:

  • Provide portable fire extinguishers for employee use. Select and distribute the extinguishers based on the types of anticipated workplace fires and on the size and degree of hazard that would affect their use. [29 CFR 1910.157(d)(1)]
  • fire-extinguisher-signageDistribute portable extinguishers for use on Class A fires so that the travel distance for employees to any extinguisher is 75 feet (22.9 meters) or less. [29 CFR 1910.157(d)(2)]
  • Use uniformly spaced standpipe systems or hose stations connected to a sprinkler system installed for emergency use by employees, instead of Class A portable fire extinguishers, provided that such systems meet the respective requirements of 29 CFR 1910.158 or 29 CFR 1910.159, that they provide total coverage of the area to be protected, and that employees are trained at least annually in their use. [29 CFR 1910.157(d)(3)]
  • Distribute portable fire extinguishers for use on Class B fires so that the travel distance for employees to any extinguisher is 50 feet (15.2 meters) or less. [29 CFR 1910.157(d)(4)]
  • Distribute portable fire extinguishers for use on Class C hazards on the appropriate pattern for the existing Class A or Class B hazards. [29 CFR 1910.157(d)(5)]
  • Distribute portable fire extinguishers or other containers of Class D extinguishing agent for employee use so that the travel distance from the combustible metal working area to any  extinguisher is 75 feet (22.9 meters) or less. Portable fire extinguishers for Class D hazards are required in areas where combustible metal powders, flakes, shavings, or similarly sized products are generated at least once every two weeks. [29 CFR 1910.157(d)(6)]

 

 

 

As a small business owner, you MUST:

  • fire-extinguisher-signInspect, maintain, and test all portable fire extinguishers in the workplace. [29 CFR 1910.157(e)(1)]
  • Visually inspect portable extinguishers or hoses monthly. [29 CFR 1910.157(e)(2)]
  • Perform an annual maintenance check on portable fire extinguishers. Stored pressure extinguishers do not require an internal examination. Record the annual maintenance date and retain this record for one year after the last entry or the life of the shell, whichever is less. Make the record available to the Assistant Secretary upon request. [29 CFR 1910.157(e)(3)]
  • Empty and maintain dry chemical extinguishers (that require a 12-year hydrostatic test) every six years. Dry chemical extinguishers that have non-refillable disposable containers are exempt from this requirement. When recharging or hydrostatic testing is performed, the six-year requirement begins from that date. [29 CFR 1910.157(e)(4)]
  • Provide alternate equivalent protection when portable fire extinguishers are removed from service for maintenance and recharging. [29 CFR 1910.157(e)(5)]

 

A small business must:

  • Assure that hydrostatic testing is performed by trained persons with suitable testing equipment and facilities. [29 CFR 1910.157(f)(1)]
  • Assure that portable extinguishers are hydrostatically tested at the intervals listed in Table L-1 of this section, except under any of the following conditions [29 CFR 1910.157(f)(2)]:
  • Assure that an internal examination of cylinders and shells to be tested is made before the hydrostatic tests in addition to an external visual examination. [29 CFR 1910.157(f)(3)]
Table L-1
Type of extinguishers Test interval (years)
Soda acid (soldered brass shells) (until 1/1/82) *
* Soda acid (stainless steel shell) 5
* Cartridge operated water and/or antifreeze 5
Stored pressure water and/or antifreeze 5
Wetting agent 5
Foam (soldered brass shells) (until 1/1/82) *
Foam (stainless steel shell) 5
Aqueous Film Forming foam (AFFF) 5
Loaded stream 5
Dry chemical with stainless steel 5
Carbon Dioxide 5
Dry chemical, stored pressure, with mild steel, brazed brass or aluminum shells 12
Dry chemical, cartridge or cylinder operated, with mild steel shells 12
Halon 1211 12
Halon 1301 12
Dry powder, cartridge or cylinder operated with mild steel shells 12
FOOTNOTE: Extinguishers having shells constructed of copper or brass joined by soft solder or rivets shall not be hydrostatically tested and shall be removed from service by January 1, 1982. (Not permitted)

* Although still included in Table L-1, Soda acid (stainless steel shell) and Cartridge operated water and/or antifreeze extinguishers are now obsolete. [29 CFR 1910.157]
  • Assure that portable fire extinguishers are hydrostatically tested whenever they show new evidence of corrosion or mechanical injury, except under the conditions listed in paragraphs (f)(2)(i)–(v) of this section. [29 CFR 1910.157(f)(4)]
  • Assure that hydrostatic tests are performed on extinguisher hose assemblies that are equipped with a shut-off nozzle at the discharge end of the hose. The test interval must be the same as specified for the extinguisher. [29 CFR 1910.157(f)(5)]
  • Hydrostatically test carbon dioxide hose assemblies with a shut-off nozzle at 1,250 psi (8,620 kPa). [29 CFR 1910.157(f)(6)]
  • Hydrostatically test dry chemical and dry powder hose assemblies with a shut-off nozzle at 300 psi (2,070 kPa). [29 CFR 1910.157(f)(7)] Hose assemblies passing a hydrostatic test do not require any type of recording or stamping. [29 CFR 1910.157(f)(8)]
  • Test hose assemblies for carbon dioxide extinguishers within a protective cage device. [29 CFR 1910.157(f)(9)]
  • Test carbon dioxide extinguishers and nitrogen or carbon dioxide cylinders used with wheeled extinguishers every five years at 5/3 of the service pressure as stamped into the cylinder. Nitrogen cylinders that comply with 49 CFR 173.34(e)(15) may be hydrostatically tested every 10 years. [29 CFR 1910.157(f)(10)]
  • Hydrostatically test stored pressure and Halon 1211 types of extinguishers at the factory test pressure, not to exceed two times the service pressure. [29 CFR 1910.157(f)(11)]
  • Test self-generating type soda acid and foam extinguishers at 350 psi (2,410 kPa). [29 CFR 1910.157(f)(12)]
  • Do not use air or gas pressure for hydrostatic testing. [29 CFR 1910.157(f)(13)]
  • Remove from service extinguisher shells, cylinders, or cartridges that fail a hydrostatic pressure test, or that are not fit for testing. [29 CFR 1910.157(f)(14)]
  • Ensure that the equipment for testing compressed gas type cylinders be of the water jacket type. The equipment must have an expansion indicator that operates with an accuracy within 1 percent of the total expansion or .1cc (.1mL) of liquid. [29 CFR 1910.157(f)(15)(i)]
  • Ensure that the equipment for testing non-compressed gas type cylinders includes the following [29 CFR 1910.157(f)(15)(ii)]:
    • A hydrostatic test pump, hand or power operated, capable of producing at least 150 percent of the test pressure, which must include appropriate check valves and fittings. [29 CFR 1910.157(f)(15)(ii)(A)]
    • A flexible connection for attachment to fittings to test through the extinguisher nozzle, test bonnet, or hose outlet, as is applicable. [29 CFR 1910.157(f)(15)(ii)(B)]
    • A protective cage or barrier for personal protection of the tester, designed to provide visual observation of the extinguisher under test. [29 CFR 1910.157(f)(15)(ii)(C)]
  • Maintain and provide upon request to the Assistant Secretary evidence that the required hydrostatic testing of fire extinguishers has been performed at the time intervals shown in Table L-1. Such evidence must be in the form of a certification record that includes:
    • The date of the test.
    • The signature of the person who performed the test.
    • The serial number, or other identifier, of the fire extinguisher that was tested.

Such records must be kept until the extinguisher is hydrostatically retested at the time interval specified in Table L-1 or until the extinguisher is taken out of service, whichever comes first. [29 CFR 1910.157(f)(16)]

 

For the employees of your business, you must:

  • Provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting. [29 CFR 1910.157(g)(1)] Provide this education when employees are first hired and once a year thereafter. [29 CFR 1910.157(g)(2)]
  • Train employees (who have been designated to use fire fighting equipment in the emergency action plan) in the use of the equipment. [29 CFR 1910.157(g)(3)] Provide this training when employees are first given this assignment and once a year thereafter. [29 CFR 1910.157(g)(4)]

Fire Extinguisher Inspections

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Regular maintenance and inspections of your portable fire extinguishers will provide assurance that they will operate effectively and safely if they are needed. [29 CFR 1910.157(c)(4)]

fire-extinguisher-properInspect all extinguishers at least once a month. Use the following checklist as a guide.

  1. Is each extinguisher in its designated place, clearly visible, and not blocked by equipment, coats or other objects that could interfere with access during an emergency?
  2. Is the nameplate with operating instructions legible and facing outward?
  3. Is the pressure gauge showing that the extinguisher is fully charged (the needle should be in the green zone)?
  4. Is the pin and tamper seal intact?
  5. Is the extinguisher in good condition and showing no signs of physical damage, corrosion, or leakage?
  6. Have all dry powder extinguishers been gently rocked top to bottom to make sure the powder is not packing?

 

NOTE: If you did not answer yes to all of these questions, have the extinguisher fixed or replaced immediately!

If you want to learn more about Fire Extinguishers, check out OSHA’s full guidelines on fire extinguishers.

The following photos are of fire extinguishers out of compliance, do you have any in your workplace like the following?

Missing seal
Missing seal
This fire extinguisher is in violation by sitting on the ground.
This fire extinguisher is in violation by sitting on the ground.
Can you identify what is wrong here?
Can you identify what is wrong here?