The ERP must contain provisions for decontamination of emergency responders leaving the exclusion zone. Individuals who will assist the responders as they leave the exclusion area must be trained in decontamination procedures. These individuals must wear PPE at the same level or one level below that worn by the emergency responders they are supporting, as…...
Your Emergency Response Plan (q)(2)(vii) Decontamination Read More »
All employees that are not trained in emergency response and who will not be needed during the response operation should be evacuated from the exclusion and decontamination zones. This aspect of the ERP should be in compliance with 1910.38 as described in Section XII.A.2. CSHOs must use 1910.38 as a model to evaluate the employer’s…...
Your Emergency Response Plan (q)(2)(vi) Evacuation Routes and Procedures Read More »
Areas surrounding the danger area need to be controlled during emergencies by prohibiting unauthorized personnel from entering the emergency release area. Methods of excluding areas and defining various zones need to be addressed in the ERP. Emergency responses are coordinated from a command post a safe distance away from the emergency release area. The way…...
Your Emergency Response Plan (q)(2)(v) Site Security and Control Read More »
The 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 that 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…...
Your Emergency Response Plan (q)(2)(iv) Safe Distances and Places of Refuge Read More »
This is by FAR the most misunderstood element of all! The ERP must define the types of releases that could potentially require an emergency response and should define what types of releases would not be an emergency, or, in other words, what may be handled as an “incidental release”. The ERP should include an inventory…...
Your Emergency Response Plan (q)(2)(iii) Emergency Recognition and Prevention Read More »
Personnel roles must be clearly defined in the ERP. One method of doing this is to list job titles and describe their projected roles in emergency response operations. Although specific HAZWOPER titles are not required, employees should be designated to assume duties that parallel 1910.120(q)(6) and must be trained accordingly. Lines of authority must also…...
We see a lot of great efforts on emergency response plans, but so many times folks just do not know the details OSHA will be looking for. Here are the required sections/information for your ERP and the details required. (q)(2)(i) Pre-emergency Planning and Coordination 1) Does the plan address coordination with outside emergency…...
Your Emergency Response Plan Section (q)(2)(i) – Pre-emergency Planning and Coordination Read More »
Most of the facilities we work at have a mechanical integrity program for the process equipment. Most have a Work Order system for their preventative maintenance program. This system kicks out a work order for the PM(s) due. Most facilities track the closure rates of the PM W.O.’s. My tip… Add ALL of your emergency…...
Emergency Response & PSM Tip Read More »
At a minimum, the plan must include but is not limited to the following elements [29 CFR 1910.38(c)]: Means of reporting fires and other emergencies Evacuation procedures and emergency escape route assignments Procedures to be followed by employees who remain to operate critical plant operations before they evacuate Procedures to account for all employees after…...
What must be in my Emergency Action Plan (EAP)? Read More »
In most circumstances, immediate evacuation is the best policy, especially if professional firefighting services are available to respond quickly. There may be situations where employee firefighting is warranted to give other workers time to escape or to prevent danger to others by the spread of a fire. In this case, you as the employer are…...
Do I Need an Emergency Action Plan? Read More »
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I want to thank so many of you for your positive comments about last weeks newsletter. The traditional OSH news has been a bit slow in recent weeks, so I tried to offer some personal insights. One question that I got from several readers and we seem to get in most of our auditing work…...
From an EAP to an ERP??? Read More »
