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June 30, 2021
The way to the egress

Sometimes your employees just need to leave. Workplace emergencies can range from isolated chemical spills, fires, toxic gas releases, and active shooter incidents to local flooding; hurricanes; tornados; and, more rarely, terrorist attacks. Workplace lockdowns or sheltering in place may be the appropriate response, but sometimes you need to evacuate your facility. But first, you need a plan.

Emergency evacuations, including workplace evacuations, are more common than you might think, according to the Occupational Safety and Health Administration (OSHA). Year after year, the most common causes of evacuations are fires and floods. You may communicate your fire prevention plan orally if you have 10 or fewer employees; however, OSHA regulations require you to have a written fire prevention plan if you have more than 10 employees.

In some emergencies, your best response may be a workplace evacuation, and in other situations, your best option may be to have your employees shelter in place. OSHA encourages employers to prepare for both scenarios. Planning and preparation, either for evacuation or for sheltering in place, are critical, as many disasters are no-notice events.

The National Oceanic and Atmospheric Administration (NOAA) has predicted that the 2021 hurricane season may be as active as the 2020 Atlantic hurricane season, which saw 30 named storms, including 14 hurricanes. While hurricanes most often strike coastal areas, storm systems can move inland, and even after hurricanes are downgraded to tropical storm status, they still can produce heavy rains and flooding. What would you do if a tropical storm hits your facility head-on after moving on shore?

You can be swept off your feet in as little as 6 inches of water, according to the National Safety Council (NSC); 6 inches of water can stall a car, and most cars, trucks, and SUVs will float in 2 feet of water.

Working conditions can quickly deteriorate in an approaching hurricane or tropical storm, and afterward, you may not be able to immediately reopen once the heavy rains, high winds, and storm surge have passed. Hazards following hurricanes and tropical storms may include the biological and chemical hazards of contaminated floodwaters, damaged power lines, debris and downed trees, and carbon monoxide fumes from diesel or gasoline-powered generators.

Floods and hurricanes are not the only emergencies that might necessitate an evacuation. Is your facility near rail lines or an interstate highway? What would you do in the event of a hazardous materials spill?

Extreme weather conditions this year also include drought and the associated risk of wildfires and wildfire smoke hazards. About 50 percent of the country continues to experience drought conditions, according to NOAA’s Climate Prediction Center, and federal wildland fire experts have predicted above-normal fire potential for several regions of the Plains and the West.

Wildfire smoke can contain both harmful chemicals and tiny particles, particulate matter measuring 2.5 microns or less in diameter (PM2.5). PM2.5 poses health hazards that include bronchitis, heart failure, reduced lung function, and worsening of asthma. In the event of a wildfire, you may need to evacuate employees to protect them from the hazards of wildfire smoke, even if your facility is not in the path of the fire itself.

Emergency action plan

An emergency action plan spells out actions that will be taken in the event of a fire or another emergency. When developing a plan, you may benefit from consulting your frontline employees and local emergency response agencies, as well as your managers and supervisors.

At a minimum, your emergency action plan should include:

  • A preferred method of reporting a fire and other emergencies;
  • An evacuation policy, detailing both what events would trigger an evacuation and evacuation routes and procedures;
  • Emergency escape procedures and designated evacuation routes with floor plans, workplace maps, and safe or refuge areas;
  • A chain of command with names, job titles, departments, and telephone numbers of individuals both within and outside your company to contact for additional information, along with descriptions or explanations of their duties and responsibilities under the emergency action plan;
  • Policies and procedures for workers who must remain to shut down or continue performing critical plant operations, operate fire extinguishers, or perform other essential services to ensure others’ safety; and
  • First aid or medical services and rescue duties and a list of employees designated to perform them.

You also will need procedures for accounting for all employees following an evacuation.

While disaster or emergency planning always is a good idea, some OSHA standards require it. Federal OSHA standards requiring an emergency action plan include process safety management of highly hazardous chemicals (29 CFR §1910.119); hazardous waste operations and emergency response (HAZWOPER, §1910.120); grain-handling facilities (§1910.272); ethylene oxide (§1910.1047); methylenedianiline (§1910.1050); and 1,3-butadiene (§1910.1051). The ethylene oxide; methylenedianiline; and 1,3-butadiene standards also require fire prevention plans.

Evacuations may not be an option for all your employees. Sometimes, some must remain behind to maintain or shut down critical operations. Employees who must remain to continue or shut down critical operations during an evacuation must be trained to recognize when to abandon the operations and evacuate themselves.

Members of an emergency response team must be thoroughly trained for potential crises and need to know about any toxic hazards in the workplace. Emergency response teams also must be trained in the use of fire extinguishers; first aid, including cardiopulmonary resuscitation (CPR) and self-contained breathing apparatus (SCBA); OSHA’s bloodborne pathogens standard; shutdown and chemical spill response procedures; hazardous materials emergency response; and search-and-rescue procedures. They also need to be able to judge when to rely on outside help from local emergency response agencies.

If your operations fall under the scope of OSHA’s emergency action plan standard (§1910.38), you also will need to develop and implement a training program so your workers are prepared for an emergency.

Training and evacuation drills may be critical to your employees’ health, safety, and survival. Rick Rescorla, head of security for Morgan Stanley at the World Trade Center, repeatedly drilled the company’s employees following the February 26, 1993, bombing and is credited with safely evacuating Morgan Stanley’s employees following the September 11, 2001, attacks.

In addition to establishing emergency action plans and determining what events will trigger an evacuation, you also need to maintain clear paths of egress within your facility.

Exit route regulation, enforcement

Means of egress, or emergency exits, are a foundational worker safety protection. The March 25, 1911, Triangle Shirtwaist Factory fire led to 146 worker deaths when factory workers, primarily young women who recently emigrated from Europe, could not escape because factory doors were locked as a theft-prevention measure.

OSHA regularly cites employers for blocked exit routes. Last fall, OSHA reached a settlement agreement with Target Corporation, resolving several exit route citations before the Occupational Safety and Health Review Commission. The company agreed to correct exit access and storage hazards in 200 stores and pay $464,750 in penalties to resolve a series of 8 cases before the review commission.

OSHA had cited Target locations in Connecticut, Massachusetts, and New York for numerous violations involving blocked or obstructed access to emergency exits and fire exit routes and/or unsafe storage of materials in stores’ backrooms and storage areas.

Federal OSHA inspectors also have repeatedly cited Dollar Tree Stores locations throughout the country for similar violations:

  • In September 2019, OSHA cited 4 Idaho Dollar Tree locations for blocked walkways and exit routes and unsafe storage of merchandise, proposing penalties totaling $898,682.
  • The agency then cited a Dollar Tree store location in Elmira, New York, for obstructed exit routes, as well as blocked electrical panels and unsafe materials storage, seeking $208,368 in proposed penalties.
  • OSHA then cited Dollar Tree Stores for exit, storage, and fire hazards at a store in Boston, Massachusetts, seeking $523,745 in penalties, and exit and storage hazards at a store located in Bethlehem, Pennsylvania, seeking $296,861 in penalties.
  • The agency cited Dollar Tree Stores again this past spring for repeat, serious violations at its Beverly Hills, Florida, store, including blocked exit routes and improperly stacked boxes and other materials, seeking $265,265 in proposed penalties.

Under OSHA regulations, most workplaces must have at least two designated exit routes. Additional routes may be necessary for a larger workforce or building size or a workspace configuration that would impede the safe exit of all employees, customers, and visitors during an emergency. Exit access must be at least 28 inches wide, and ceilings of exit routes must be at least 7 feet, 6 inches high. Exit doors must be unlocked from the inside.

OSHA regulations governing exits and exit routes also include requirements that:

  • Exit routes remain free of explosive or highly flammable furnishings and other decorations, and exit route doors must be free of decorations or signs that would obscure the visibility of the doors.
  • If the direction of exit access and exit discharge is not immediately apparent, signs must be posted indicating the direction of travel.
  • Doors along the exit access that could be mistaken for exit doors must be marked “Not an Exit” or with a sign identifying their use, such as “Closet.”
  • Exit routes must be separated by fire-resistant materials and fire-retardant paints or solutions along the exit access and must be renewed often enough to maintain their fire-retardant properties.
  • Exit routes must be maintained during any alteration or renovation, construction, or repairs.
  • Exit routes must be arranged so employees will not have to travel toward a high-hazard area, unless the path of travel is effectively shielded from the high-hazard area.
  • Exit routes must remain unobstructed by materials, equipment, locked doors, or dead-end corridors.
  • Exit routes must have adequate lighting for employees with normal vision.

In addition to OSHA requirements for the design, construction, and maintenance of exits routes, all employers must comply with standards for employee alarm systems, first aid and medical services, and portable fire extinguishers. Regardless of your industry, you need a plan that you hopefully will never need to use.

The Federal Emergency Management Agency (FEMA) offers disaster planning and preparedness resources for businesses, as well as the public, on its Ready.gov site.

FEMA even offers a step-by-step guide to workplace disaster planning. FEMA recommends performing a vulnerability analysis to assess potential emergencies and their impacts. The National Institute for Occupational Safety and Health (NIOSH) also has curated a collection of emergency preparedness resources for businesses.

You need to begin your emergency planning and training activities before a disaster happens, and you always must maintain exits and exit access.

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