EAPs and Procedures to be followed by employees who remain to operate critical plant operations before they evacuate (1910.38(c)(3))

If there is one common finding in our PSM/RMP audits it is this single requirement for employees who remain to operate critical plant operations before they evacuate.  And when we attempt to explain what is actually necessary to just meet 1910.38(c)(3) we are oftentimes met with downright hostility.  It is rare these days that anyone needs to stay behind, but I would say about 25% of the facilities we work with do leave behind some key personnel.  Who are these key personnel?  OSHA actually mentions some:

(emphasis by me)

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