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 is…what is the difference between an Emergency Action Plan and an Emergency Response Plan and why does my plan not meet OSHA requirements? Simply put, an EAP is to get everyone out and the ERP is for those who will re-enter the plant during the emergency. OSHA has two different standards to cover these activities: 1910.38 is the EAP standard and 1910.120(q) is the standard for the ERP requirements. If you have a response team at your facility, I encourage you to take an hour or so and read some of the CPL 02-02-073 Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases pay PARTICULAR attention to sections C and D. OSHA actually spells out in pretty straight forward language as to what each section of your ERP must contain and what outside agency interactions they expect to see during an inspection. Basically, your ERP must contain the following procedures and explanations:
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Pre-emergency planning and coordination with outside parties,
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Personnel roles, lines of authority, training, and communication,
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Emergency recognition and prevention,
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Safe distances and places of refuge,
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Site security and control,
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Evacuation routes and procedures,
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Decontamination,
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Emergency medical treatment and first aid,
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Emergency alerting and response procedures,
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Critique of response and follow-up, and
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PPE and emergency equipment.
For example, when OSHA says you have to do “Pre-Emergency planning and coordination with outside parties” they mean:
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Does the plan address coordination with outside emergency response organizations?
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Have employers notified and coordinated their ERP with the organizations listed?
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Are telephone numbers and contact personnel for in-plant officials and local authorities updated and made available?
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Do the employer’s pre-emergency planning and coordination procedures address how outside parties are notified of a potential emergency situation and what role each would play in an incident?
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Are outside responders aware of any circumstances that were either not disclosed or considered by the employer that would delay or prevent them from responding to an incident (e.g., distance, lack of training, etc.)?
If you can answer YES to these five questions and have evidence to back up your answers, then you off to a GREAT start, as most facilities fall short with this first requirement. Another resource to help you understand how 1910.120 (the HAZWOPER standard as many call it) is OSHA Publication 3114 – Hazardous Waste Operations and Emergency Response [PDF* – 548 KB]. By the way…HAZWOPER is the acronym for Hazardous Waste Operations and Emergency Response Standard. I have also broken down the ERP requirements into individual post at the SAFTENG Forum