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Fire and Explosion Planning Matrix
Attachment B

Does Your Facility Need an Emergency Action Plan (EAP)?

This checklist is provided only to identify an employer's need to develop an emergency action plan in compliance with OSHA's Emergency Action Plan Standard (29 CFR 1910.38). It DOES NOT alert you to other OSHA standards that may be associated with your emergency plan or to additional OSHA standards that may apply to your facility. This attachment does not apply to construction.

QUESTION YES NO
Are fire extinguishers provided in the workplace?    
Are the fire extinguishers intended for employee use?    
Will any of your employees be required to evacuate the workplace immediately upon the sounding of a fire alarm signal?    
If you answered "No" to either of the first two or "Yes" to all three questions, then you are required to develop an EAP. Otherwise, continue with the questions in the table below. Review the Compliance Policy for Emergency Action Plans and Fire Prevention Plans (CPL 2-1.037) for a more complete discussion of the application of an employer's obligations under 29 CFR 1910.38.


QUESTION YES NO
Does your facility use a total flooding extinguishing system that exceeds any of the maximum design concentrations defined in Fixed Extinguishing Agents, Gaseous Agents - 29 CFR 1910.162(b)(5) and (b)(6):
  • 4% Halon 1211?
  • 4% carbon dioxide?
  • 10% Halon 1301?
Note: Only for normally unoccupied areas from which employees could escape in less than 30 seconds. Uses of Halon 1301 in occupied areas must comply with concentration limits/egress times in 1910.162(b)(6)(i) and (ii).
   
Does your facility use a fire detection system with alarms or devices that are delayed by more than 30 seconds for reasons other than a total flooding extinguishing system listed above?    
Are you required to comply with 29 CFR 1910.119 Process Safety Management?    
Are you required to comply with 29 CFR 1910.272 Grain Handling Facilities?    
Are you required to comply with 29 CFR 1910.1047 Ethylene Oxide?    
Are you required to comply with 29 CFR 1910.1050 Methylenedianiline?    
Are you required to comply with 29 CFR 1910.1051 1,3-Butadiene?    
If a hazardous substance (see the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) 29 CFR 1910.120(b) Definitions) emergency could occur at your facility, do you plan to evacuate all of your employees and to rely on an outside party to provide emergency response?
Note: if a hazardous substance emergency could occur at your facility and you plan to have any of your employees participate in the emergency response, you are required to have an emergency response plan consistent with HAZWOPER 29 CFR 1910.120(q).
   
If you answered "YES" to any of the questions above, you are required to develop an emergency action plan in compliance with the Emergency Action Plan Standard (29 CFR 1910.38). Review the Compliance Policy for Emergency Action Plans and Fire Prevention Plans (CPL 2-1.037) for a more complete discussion of the application of an employer's obligations under 29 CFR 1910.38.


OSHA provides guidance to help employers develop emergency action plans. Some of these resources are the non-mandatory Appendix to Subpart E - Means of Egress and Chapter 10 Emergency Preparedness and Response of the Small Business Outreach Training Program.

 
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