Your Emergency Action Plan Is Probably Incomplete — Here's How to Fix It

There's a document sitting in a binder somewhere in most small businesses — tucked behind the OSHA 300 log, maybe sandwiched between the forklift training records — that gets pulled out once a year, if that. It usually says something like "In case of fire, exit through the nearest door and meet at the parking lot." Then someone signs it, it goes back in the binder, and everyone calls it an Emergency Action Plan.

It isn't.

OSHA's Emergency Action Plan standard, 29 CFR 1910.38, has specific requirements that go well beyond "exit the building." And the gap between what most small businesses actually have and what OSHA requires — and more importantly, what a real emergency demands — is bigger than most owners realize. According to OSHA, inadequate emergency planning contributes to preventable fatalities every year in workplace fires, chemical releases, and medical emergencies. The cost of getting it right is low. The cost of getting it wrong can be catastrophic.

Who Has to Have One

If you have ten or more employees, OSHA requires a written Emergency Action Plan under 1910.38. If you have fewer than ten, the standard still applies, but you can communicate the plan orally rather than in writing. That said, having it in writing is almost always the smarter move — it forces clarity, creates accountability, and gives you something to train against. The standard also applies across industries, from retail and office settings to light manufacturing and construction sites, though the hazards you're planning for will look different in each environment.

The standard requires your EAP to cover at minimum: procedures for reporting a fire or other emergency, procedures for emergency evacuation including exit routes and assignments, procedures for employees who remain to perform critical operations before evacuation, procedures for accounting for all employees after evacuation, procedures for employees performing rescue or medical duties, and the name or job title of every employee who may be contacted for further information.

That's more than a floor plan with arrows on it.

The Evacuation Route Problem

Most small businesses do have some version of evacuation routes posted, often the laminated floor plans near the exits. But the plan itself is usually missing the detail that makes those routes work in a real emergency. Which exit routes are primary versus secondary? What happens if the primary route is blocked by smoke or fire? Who is the designated floor warden or area monitor responsible for sweeping the space and confirming everyone is out? Where exactly is the outdoor assembly area, and is it far enough from the building to stay clear of emergency vehicles?

OSHA doesn't prescribe specific distances or layouts — your plan just needs to be appropriate for your workplace. But it does require that you designate and train employees who can assist others during an evacuation. That means identifying workers who will help anyone with a mobility limitation, sweep restrooms and break rooms, or take a headcount at the assembly point. These aren't ceremonial roles. They're the difference between a successful evacuation and a panicked crowd where no one knows if everyone got out.

One area that catches a lot of small businesses flat-footed: visitors and contractors. Your plan needs to account for people who don't know your facility. That might mean front desk staff are responsible for alerting visitors, or that sign-in sheets stay accessible so you can account for everyone at the assembly point.

Critical Operations and Who Stays Behind

Some businesses have processes that can't simply be abandoned mid-stream during an emergency. A machine shop might have equipment that needs to be powered down before evacuation to prevent secondary hazards. A food manufacturer might have a pressure vessel that requires a controlled shutdown. A chemical distributor might need someone to close isolation valves before exiting.

If that's your situation, your EAP needs to explicitly identify those critical shutdown procedures and name the employees authorized and trained to perform them. OSHA is clear that these employees must be trained specifically for this role — and the plan must make clear under what conditions they should abandon the task and evacuate themselves without completing it. No process is worth a life, and your plan needs to say that plainly.

Accounting for Everyone After Evacuation

This is the step that most plans treat as an afterthought, and it's arguably the most important one. After an evacuation, emergency responders need to know whether everyone made it out. If your answer is "we'll kind of look around and see if anyone's missing," that's not a plan.

Your EAP should designate specific individuals responsible for taking a headcount at the assembly point, and it should specify what information they're working from — employee roster, visitor log, contractor sign-in sheet. It should also identify who has authority to tell emergency responders whether anyone is unaccounted for and might still be inside the building. Getting this wrong doesn't just put your employees at risk. It puts firefighters at risk.

Alarms, Communication, and Special Conditions

Under 1910.38, your plan must include procedures for reporting emergencies, which means you need a clear answer to the question: how does an employee notify others that an emergency is happening? For most small businesses, this is a combination of calling 911 and using an alarm system, but the plan needs to say so explicitly. If your facility uses different alarm signals for different emergencies — one signal for fire, another for a chemical release — employees need to know what each signal means and what action to take.

OSHA's emergency egress standard, 1910.165, has separate requirements for employee alarm systems, but the two standards work together. Your EAP should reference your alarm system and clarify what employees are expected to do when they hear each type of alert.

Don't overlook communication for employees who may not hear a standard alarm — workers using hearing protection, employees in loud production areas, or anyone with a hearing impairment. Strobe lights, vibrating pagers, or designated employee notification roles may be needed to ensure everyone gets the message.

Training and Review

A plan no one knows about is not a plan. OSHA requires that you review the EAP with each employee when the plan is developed, when an employee's responsibilities change, and when the plan itself is updated. "Review" means actually walking through it, not handing someone a copy to read.

Drills aren't explicitly required under 1910.38 for most industries, but they're one of the most effective ways to find the gaps in your plan before an emergency does. When was the last time your team actually practiced evacuating? Did anyone check whether the assembly point was blocked by a parked delivery truck? Did anyone discover that the fire door near the loading dock sticks? These are the things you want to learn in a drill, not during a fire.

Your EAP should also be reviewed and updated whenever your workplace changes — new equipment, new processes, renovations that change exit routes, or a significant change in your workforce. Spring is a natural time to do this review, particularly if you're ramping up operations or bringing in seasonal workers.

Making It Real

The businesses that handle emergencies well aren't the ones with the most elaborate plans. They're the ones whose employees have actually internalized what to do. That means keeping the plan accessible, training to it regularly, and treating it as a living document rather than a compliance checkbox.

Start by pulling out whatever you have right now and reading it against the 1910.38 requirements. Identify the gaps. Assign owners for each piece — who's the designated floor warden, who manages the headcount, who can speak to emergency responders. Put names on paper, not just job titles. Then schedule thirty minutes to walk through the plan with your team before the end of the month.

OSHA can cite you for an inadequate EAP, and penalties under the current schedule can reach thousands of dollars per violation. But the real reason to get this right has nothing to do with fines. It's about knowing that if something goes wrong, the people in your building have a real chance of getting out.

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Further Reading:

• OSHA 29 CFR 1910.38 – Emergency Action Plans
• OSHA Emergency Preparedness and Response
• OSHA Evacuation Plans and Procedures eTool