SAFETY
Emergency Action Plans: What OSHA 1910.38 Actually Requires
What belongs in an OSHA-compliant emergency action plan, and how to make sure your team knows what to do during a drill.
An evacuation route posted on a wall doesn’t help
anyone if the first time employees see it is during an actual fire. An
Emergency Action Plan only works if it’s been practiced enough that
people don’t have to stop and read anything when it matters.
What OSHA 1910.38 requires
29 CFR 1910.38 requires a written Emergency Action Plan for
facilities where one is required by another standard, covering
procedures for reporting emergencies, evacuation routes and
procedures, accounting for employees after evacuation, and identifying
who has rescue or medical duties. A separate but related standard,
1910.39, covers fire prevention plans specifically.
Emergency Action Plan vs. Fire Prevention Plan
| Standard | Focus |
|---|---|
| 1910.38 (EAP) | Evacuation, reporting, accounting for employees during any emergency |
| 1910.39 (FPP) | Fire hazards specifically, including housekeeping and ignition source control |
Accounting for people is the step that gets skipped
A plan that gets everyone out of the building but has no reliable
method for confirming everyone made it to the assembly point isn’t
actually complete — first responders need to know quickly whether
anyone is still inside. Headcount procedures, whether a badge scan, a
roll call, or a designated floor warden confirming their area, have to
work under the actual chaos of an evacuation, not just on paper.
Why drills matter more than the document
A written plan that’s never practiced tends to reveal its gaps for
the first time during a real emergency — a blocked exit route, a
confusing assembly point, an employee who’s never actually walked the
route from their workstation. Regular drills surface those gaps when
the stakes are low enough to fix them.
Where training fits
Emergency Action Plans fit inside the broader safety culture work
covered in SCMEP’s Safety training catalog. As
a NIST Manufacturing Extension Partnership affiliate
serving South Carolina manufacturers since 1989, our focus is
building a plan and drill schedule that fits your actual facility
layout, not a generic template.
If your team needs to update an Emergency Action Plan or run a
facility drill, you can browse the Safety training
catalog or email the training team.
Confined space entry is one of the highest-risk scenarios an emergency action plan has to account for. See our guide to confined space entry — permit-required spaces under OSHA 1910.146.
Frequently asked questions
What does OSHA 1910.38 require?
1910.38 requires a written Emergency Action Plan covering procedures for reporting emergencies, evacuation routes and procedures, accounting for employees after evacuation, and identifying who has rescue or medical duties.
How does an Emergency Action Plan differ from a Fire Prevention Plan?
1910.38 covers evacuation, reporting, and accounting for employees during any emergency. 1910.39 covers fire hazards specifically, including housekeeping practices and ignition source control.
Why is accounting for employees a critical step?
First responders need to know quickly whether anyone is still inside a building during an emergency. Headcount procedures have to work reliably under the actual chaos of an evacuation, not just on paper.
Why do drills matter more than the written plan itself?
A written plan that’s never practiced tends to reveal its gaps for the first time during a real emergency. Regular drills surface issues like blocked routes or confusing assembly points while the stakes are still low.
