1. Does your current fire prevention plan identify arson and explosive device incidents as fire hazards that may affect the workplace?

1. In conjunction with local law enforcement and local emergency planning officials, evaluate the risk of an arson or explosive device threat/incident.
   
   

   Note: Resources that may assist you in determining the status of your workplace and/or identify workplace targets include the on-line resources from the South Carolina Department of Labor, Licensing and Regulation and from the National Institute of Justice, and agencies such as the local fire department, police department, and Bureau of Alcohol, Tobacco, Firearms, and Explosives; your insurance carrier (often have fire prevention specialists); or on-site security specialists.

2. Add arson and explosive device incidents to your current list of workplace fire hazards and ignition sources covered by the plan OR state that the plan does not address these workplace fire hazards/ignition sources and indicate where the information about controlling/responding to these fire hazards is located.
   
   
3. Review your current procedures (handling/storage, accumulation control, maintenance) to ensure that they are up-to-date and to see if they adequately address prevention and control of fires/explosions initiated by arson or an explosive device. For example, consider addressing physical security, like isolating and locking flammable material storage areas, in your procedures.
   
   
4. Review the rest of the plan to ensure it is up-to-date and to ensure that the existing ignition source controls and fire protection equipment are appropriate for fires/explosions initiated by arson or an explosive device. Address the considerations identified throughout this checklist OR develop a plan that addresses arson or explosive device incidents and is consistent with the considerations identified in the rest of this checklist.

• To conduct an evaluation of your workplace as a potential terrorist target and identify potential workplace hazards, review the South Carolina Department of Labor, Licensing and Regulation's Best Practices in Workplace Security or (for chemical facilities) the National Institute of Justice's (NIJ) Chemical Facility Vulnerability Assessment Methodology
• OSHA's Fire Prevention Plan Standard, 29 CFR 1910.39
  
• OSHA's Compliance Policy for Emergency Action Plans and Fire Prevention Plans, CPL 2-1.037
  
• OSHA's Fire Safety Advisor, an on-line compliance assistance tool
  
• OSHA's Fire Safety Fact Sheet (55Kb PDF)
• State Plan States. Contact Information to obtain additional information about equivalent State plan standards, requirements, and guidance.

2. Do your current handling/storage procedures and ignition source controls address fires initiated by arson, and fires or explosions initiated by explosive devices?

1. Identify locations that may be prime areas for arson or for explosive device placement, such as abandoned structures, unsecured mechanical spaces or other unoccupied spaces, flammable chemical storage areas, shrubs or trash dumpsters. You may want to mark these locations on separate facility blueprints or floor plans and provide the information to employees who will need it to perform their assigned roles.
   
   
2. Include instructions for employees to follow if they receive an arson/explosive device threat or encounter a suspicious situation/device. Explicitly warn against handling/attempting to defuse device.
   
   
3. Add to your plan any additional contact information for local emergency responders who deal with explosive devices.
   
   
4. Identify and add to your plan any additional handling/storage procedures necessary to prevent or control fires/explosions initiated by arson or explosive devices. For example, you may consider securing unattended hazardous material storage areas or providing additional surveillance.
   
   
5. Identify and add to your plan any additional ignition source controls necessary to address fires/explosions initiated by arson or explosive devices. For example, you may consider limiting access points or controlling access (keypad entry, limited sets of keys) to flammable storage areas and other likely target areas with fuel sources. Note: You may want to check with your local police or fire department for cost-effective options.
   
   
6. Contact your local emergency response organizations to discuss effective notification procedures and how an assigned explosive device squad will respond. This will help ensure that your procedures are coordinated with the overall community network.
   
   
7. Identify any additional employee roles that may be needed to carry out procedures/controls related to explosive device/arson incidents.
   
   
8. If you plan to require employees to remain in the workplace to carry out their additional roles (like directing explosive device squad to a suspicious package/explosive device), identify how you will communicate with them and how they will communicate with each other. Note: Section II and Section IV of this document provide training and emergency action plan considerations.
   
   
9. Since arson and/or explosive device placement may occur after normal hours of operation or while fewer employees are present, consider including any additional procedures and controls necessary to address fires initiated by arson or explosive devices (threats and suspicious devices) during off-hours or shifts. For example, you may consider providing additional lighting or security for potential target areas that are left unattended during off hours.

• ATF's Arson and Explosives web page
  
• ATF's Arson and Explosives National Repository, containing statistical information about arson and explosives incidents
  
• US Fire Administration's (FEMA) Arson web page

3. Do you need additional fire protection equipment for arson or explosive device hazards?

1. Identify and install any additional heat or fire detection equipment that may be necessary to detect a fire/explosion initiated by arson or an explosive device. Surveillance equipment and/or intruder alarm systems also could be considered.
   
   
2. If you have not already done so, consider installing this equipment in each of the workplace locations that you identified as potential targets, like abandoned buildings or mechanical spaces. Consider securing these areas (locking, controlling access) to prevent a fire/explosion ignition device from being placed unnoticed. Note: You may want to check with your local police or fire department for cost-effective options.
   
   
3. Identify and consider installing additional security systems or equipment to detect and eliminate tampering with fire detection or suppression systems.

• National Institute of Standards and Technology (NIST) website for their Building and Fire Research Laboratory

4. Are additional procedures necessary to control the accumulation of combustible materials that may contribute to a fire or explosion initiated by arson or an explosive device?

1. Identify any additional procedures necessary to address the accumulation of combustible materials in workplace locations that may be targets for arson or explosive device placement such as abandoned/ unoccupied buildings, mechanical spaces, fuel storage areas, and trash dumpsters. For example, you may consider removing all combustible materials from a vacant/unoccupied building and securing the building (doors and windows) to prevent off-hour dumping. You might also consider securing your dumpsters and scheduling more frequent trash removal. Note: In general, good housekeeping can benefit basic fire prevention.
   
   
2. Identify heavy shrubs, vines, or tall grasses growing inside, around, or along the perimeter of your workplace. Consider removing them or keeping them trimmed close to the ground to help prevent the concealment of an arsonist or explosive device and eliminate the potential for propagating fires ignited outside the workplace.
   
   
3. Routinely inspect the locations identified above to ensure that they are kept clear of combustible materials and do not become overgrown.

• US Fire Administration's (FEMA) Arson web page, which includes an explosive device stand-off card.
  
• US Fire Administration's (FEMA) National Arson Prevention Initiative web page for Boarding Up (138Kb PDF) and Protecting Structures from Arson (2,239Kb PDF)

1. Will your employees need additional training about arson or explosive device hazards?

1. Identify fires/explosions initiated by arson or an explosive device as potential workplace fire hazards and ignition sources in your training. Depending on your own assessment of the risk of publicly discussing this information, you could also identify the locations that are likely workplace targets during training.
   
   
2. Address in your training how to recognize potentially suspicious actions, behaviors, devices, or packages to raise employee awareness of these hazards.
   
   
3. Address in your training any additional instructions for employees to follow if they receive an arson/explosive device threat or encounter a suspicious situation/device.
   
   
4. Identify any additional emergency responders that employees will need to contact.

• ATF's Training web page includes training courses related to arson, explosives, and incident investigation.
  
• US Fire Administration's (FEMA) Arson Training web page

2. Will you assign any additional roles to your employees (e.g., assist explosive device squad) to address arson or explosive device hazards?

1. Identify any additional roles necessary for employees to carry out your planned procedures related to fires/explosions initiated by arson or an explosive device, an explosive device threat, or discovery of a suspicious device.
   
   
2. Train employees on the instructions they should follow if they receive an arson/explosive device threat.
   
   
3. Train employees to perform any additional handling/storage procedures to prevent fires/explosions initiated by arson or an explosive device. Address any additional hazards or tasks associated with these procedures.
   
   
4. Train employees to perform any additional accumulation control procedures related to fires/explosions initiated by arson or an explosive device. Address any additional hazards or tasks associated with these procedures.
   
   
5. If employees will be required to remain in/near the workplace to carry out your planned procedures, train employees in how they will communicate with responders and other employees.
   
   
6. Train employees to recognize the unusual circumstances (e.g., suspicious activity near a hazardous substance storage area) and suspicious devices that may be associated with potential arson or explosive device threats.
   
   
7. Identify any additional training employees will need to understand, use, or maintain additional ignition source controls or fire protection equipment installed for fires/explosions initiated by arson or an explosive device. Address any additional hazards or tasks associated with the ignition source controls, fire protection, or other emergency equipment installed for fires/explosions initiated by arson or an explosive device.
   
   
8. Train employees to use any additional personal protective equipment they may need to carry out your planned procedures.

1. Will you need additional personal protective equipment to address arson or explosive device incidents?

1. Identify additional personal protective equipment employees may need during an arson/explosive device threat or a fire/explosion initiated by arson or an explosive device. Consider items such as personal protective equipment for the eyes, face, body, and extremities; respiratory protection; and monitoring equipment.
   
   
2. Identify the location of the additional personal protective equipment. One option is to include the location of the equipment on the maps/floor plans illustrating the evacuation routes. You may refer to an existing emergency plan developed under either the Emergency Action Plan Standard (29 CFR 1910.38) or the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) (29 CFR 1910.120).
   
   
3. Identify employees who can use the additional personal protective equipment, based on assigned roles, physical capability, and training. For example, employees who will verbally direct emergency responders to a suspicious package/explosive device may require protective clothing to perform this task.

• OSHA's standards for Personal Protective Equipment (PPE) (29 CFR 1910 Subpart I) identify the general and equipment-specific regulatory requirements for personal protective equipment. Includes: General PPE Requirements (29 CFR 1910.132), Eye and Face Protection (29 CFR 1910.133), Respiratory Protection (29 CFR 1910.134), Head Protection (29 CFR 1910.135), Foot Protection (29 CFR 1910.136), and Hand Protection (29 CFR 1910.138).
  
• OSHA's Safety and Health Topics: Personal Protective Equipment web page provides links to resources that discuss PPE selection, use, regulatory compliance and employee training.

2. Will you need additional emergency equipment to address arson or explosive device incidents?

1. Identify additional emergency equipment employees may need during an arson/explosive device threat or fire/explosion initiated by arson or an explosive device. Consider items such as additional first aid supplies and communication devices.
   
   
2. Identify the location of the additional emergency equipment. One option is to include the location of the equipment on the maps/floor plans illustrating the evacuation routes. You may refer to an existing emergency plan developed under either the Emergency Action Plan Standard (29 CFR 1910.38) or HAZWOPER (29 CFR 1910.120).
   
   
3. Identify employees who can use the additional emergency equipment available, based on assigned roles, physical capability, and training. For example, employees who will verbally direct emergency responders to a suspicious package/explosive device may require communications equipment to perform this task.

Note: You may want to review your existing Emergency Action Plan (EAP) with respect to arson and explosive device incidents. You can use the following considerations to review your plan. If you are not certain whether you need to have this type of plan, please refer to Attachment B, Does Your Facility Need an Emergency Action Plan? For information about reviewing an existing EAP for terrorist releases of chemical, biological, radiological, or nuclear material, please see OSHA's Evacuation Planning Matrix.

1. Does your current Emergency Action Plan include procedures that adequately address evacuation and response to fires or explosions initiated by arson or an explosive device?

1. Identify any additional/different evacuation routes and exits necessary during a threat of (or an actual) fire/explosion caused by arson or an explosive device. Consider alternating between several evacuation locations during sequential events to avoid the possibility of a secondary device or weapon. Ensure that additional routes and exits accommodate the needs of all employees, in accordance with any applicable provisions of the Americans with Disabilities Act (ADA).
   
   
2. Consider the need to address visitors, customers, and contractors in your emergency procedures. Identify any additional/different procedures necessary to assist these individuals reach safety during a threat of (or an actual) fire/explosion caused by arson or an explosive device.
   
   
3. Specify any additional key personnel or roles necessary to evacuate to an appropriate location outside the workplace during an arson or explosive device incident.
   
   
4. Identify how you will account for employees who are evacuated during an arson or explosive device incident if this will differ from your existing procedures.
   
   
5. Identify how employees will be alerted when it is safe to re-enter the workplace if they have been evacuated as the result of an arson or explosive device incident if this will differ from your existing procedures.
   
   
6. Review any critical equipment not currently addressed in your plan that must be shut down in the event of an arson or explosive device incident.

2. Do any of the additional procedures in your Fire Prevention Plan affect the procedures identified in your current Emergency Action Plan?

1. Identify procedures you have added to (or altered in) your Fire Prevention Plan that may require additions/revisions in your EAP. One example may be existing procedures for shutting down/isolating critical process equipment. If your EAP does not include shutdown procedures for arson or explosive device incidents, then you may need to consider them. Some equipment may only become "critical process equipment" during such an event. In this case, you would need to add this equipment to your current EAP and provide information similar to that included for previously-identified critical equipment (e.g., shutdown procedures, employee roles and responsibilities, training, protective equipment, and contingencies for immediate evacuation).

• OSHA's Emergency Action Plan Standard (29 CFR 1910.38)
• OSHA's Evacuation Plan and Procedures e-Tool assists employers develop and implement an Emergency Action Plan.
• OSHA's Small Business Training Handbook, Emergency Preparedness Chapter identifies and explains the elements of an emergency action plan and other important emergency planning topics for small businesses. It includes training resources.
• Oregon OSHA's publication Expecting the Unexpected: What to consider in planning for workplace emergencies (2,320Kb PDF) is an effective workplace emergency planning guide.
• NFPA 1 - Fire Prevention Code
  Covers fire and explosion prevention through the regulation of conditions that could cause a fire or explosion.
  
• US Fire Administration's (FEMA) report on Arson in the United States (120Kb PDF)
  
• FEMA's Emergency Management Guide for Businesses
• The U.S. Equal Employment Opportunity Commission's website provides employer resources for addressing ADA requirements in private workplaces, including Enforcement Guidance on Reasonable Accommodations.
• The Job Accommodation Network's publication Emergency Evacuation Procedures for Employees with Disabilities provides planning information and resources on emergency procedures for employees with disabilities.