Safe places of refuge (out-of-doors or shelter-in-place) should be the areas where an accounting of all employees will be performed. This can be critically important for identifying individuals who did not get out, estimating where they may be, and initiating any rescue operation. Information on safe places of refuge must be given to the emergency response organization or emergency response team promptly.
In some cases, because of the quantity and/or proximity of a contaminant release, it may be safer to remain indoors rather than evacuate employees. Suppose an employer intends to include a shelter-in-place option in their ERP. In that case, they must be sure to include provisions in their ERP to implement a means of alerting their employees to shelter-in-place that is easily distinguishable from that used to signal an evacuation and to train employees in the shelter-in-place procedures and their roles in implementing them. Examples of situations that might result in a decision by an employer to institute shelter-in-place include an explosion in an ammonia refrigeration facility across the street, a derailed and leaking tank car of chlorine on the rail line near a place of business, or a chemical, biological or radiological event. The ERP must identify who is responsible for determining whether to institute shelter-in-place and what situations may require it.
The CSHO should evaluate the employer’s shelter-in-place procedures to determine their suitability. For example, do the procedures include turning off, sealing, or disabling the HVAC air exchange? OSHA’s Evacuation Plans and Procedures e-Tool provides additional specific shelter-in-place procedures as guidance.
If the ERP does not address safe distances and places of refuge adequate for all employees who may need it, cite (q)(2)(iv).
If the employer intends to implement a shelter-in-place policy for any anticipated emergencies, the ERP must address the shelter-in-place procedures. If planned shelter-in-place procedures are not documented in the ERP, the CSHO shall cite (q)(2)(iv). If the shelter-in-place procedures are not suitable for the workplace, the CSHO shall cite (q)(2)(iv).
Failure to plan for and implement a distinctive means of alerting employees to shelter-in-place shall be cited under 1910.120(q)(2)(ix).
Failure to train employees regarding shelter-in-place procedures and their roles in such cases shall be cited under 1910.120(q)(2) with reference to the applicable paragraphs under 1910.38.
The ERP should contain a map with safe places of refuge identified for each section of the area where hazardous substance emergencies could occur, if possible. Ideally, the map should contain the location of all buildings, structures, equipment, emergency apparatus, first aid stations, routes of entry and exit, emergency exit routes and alternate routes, staging areas, and safe places of refuge.
Safe refuge areas’ adequacy must be determined for the worst-case scenario.