29 CFR 1910.38: Emergency action plans

Question 1

A machining shop with 8 employees is required by an OSHA standard to have an emergency action plan. The owner says she has always explained evacuation routes and reporting procedures verbally at the start of each employee's first shift and sees no reason to write anything down. What is the correct assessment?

1. ACompliant, because an employer with 10 or fewer employees may communicate the plan orally
2. BNot compliant, because every emergency action plan must be in writing regardless of employer size
3. CCompliant only if a supervisor signs a log confirming each oral briefing
4. DNot compliant, because oral plans are allowed only for employers with 5 or fewer employees

Question 2

A chemical blending facility is required by another OSHA standard to have an emergency action plan. It has 14 employees on its roster, but only 9 are on site on any one shift. The owner proposes to skip a written plan and instead walk each new hire through the evacuation procedures verbally. Based on the emergency action plan standard, what is the correct response?

1. AAcceptable, because the plan only needs to be communicated to the employees who are actually on site during a given shift
2. BAcceptable, because oral plans are allowed whenever the plan includes procedures for reporting emergencies and evacuation
3. CNot acceptable, because the facility has more than 10 employees, so the plan must be in writing, kept in the workplace, and available to employees for review
4. DNot acceptable, because an emergency action plan must always be in writing regardless of the number of employees

Question 3

A chemical blending facility evacuates all employees to an assembly area during a drill. Two operators who shut down a reactor line before leaving are told to follow the plan's shutdown steps. The plan identifies the reporting procedure, evacuation type and exit assignments, the shutdown steps for those operators, rescue and medical duty procedures, and a job title for questions. During the drill, the supervisor cannot tell whether the two operators and a visiting contractor have reached safety because no one is responsible for checking who is present at the assembly area. Which action best corrects the deficiency in the plan?

1. AAdd procedures to account for all employees after evacuation
2. BDesignate and train additional employees to assist with evacuation of others
3. CAdd the name or job title of a person employees may contact for plan questions
4. DAdd a distinctive signal for each purpose to the employee alarm system

Question 4

A warehouse's emergency action plan has not been revised in two years. Today, a maintenance technician with no previous role in the plan is newly designated as an evacuation assistant for the mezzanine. The text of the plan is unchanged. The safety manager must decide what review the standard requires.

1. AReview the plan with that technician now, because the technician's responsibilities under the plan have changed.
2. BWait for the next annual refresher, because the plan itself was not changed and no review is triggered.
3. CReview the plan with every employee in the facility, because any change in one person's duties changes the plan.
4. DReview the plan only if the technician is a new hire, since reassignments of current employees do not trigger a review.