Look at lists of fines and violations issued by OSHA (the Occupational Safety and Health Administration). You will quickly see that the agency takes protecting employees very seriously.

Every business in America that the agency regulates must have an OSHA Emergency Action Plan. What do you need to do to have an effective, compliant plan?

OSHA Emergency Action Plan – The Cost of Non-Compliance

During the last fiscal year (October 2021-September 2022), OSHA issued 47 citations and more than $115,000 in penalties because of ineffective or non-existent Emergency Action Plans. That works out to an average of almost $2,400 per citation. The average fine in the healthcare industry more than doubles to nearly $4,900 per citation.

Besides the possibility of fines, not having an OSHA Emergency Action Plan in place could expose your business to additional financial liability in an emergency if employees or customers were injured.

Fines aside, the safety of your employees and patients is why an emergency action plan is a must-have for OSHA Healthcare Compliance

OSHA Emergency Action Plan – Basic Requirements

At a minimum, OSHA Emergency Plan requirements should include the following parts.

  • Means of reporting fires and other emergencies — The ways of reporting a fire or emergency can vary based on the size and setup of each workplace. Examples include activating a manual fire alarm, calling a designated internal extension, or calling 911.
  • Evacuation procedures and emergency escape route assignments — This part of your plan should be very detailed. Employees must know who may order an evacuation, under what conditions an evacuation would be necessary, how to evacuate, and what routes to take. Make a note of Procedures like closing doors and windows or turning off equipment as employees evacuate. Diagrams of escape routes are also mandatory.
  • Procedures for employees who remain to operate critical workplace operations before they evacuate — Does your practice have equipment or substances that could create a hazard for emergency responders? If so, someone should be tasked with shutting off these items, if at all possible, to mitigate the risk. Your emergency plan must detail who is responsible and what actions they should take.
  • Accounting for all employees after an emergency evacuation is complete — There should be a plan to account for employees after an evacuation to ensure everyone gets out. It is common to assign employees to sweep areas and check offices and restrooms before being the last to leave a workplace. It is also wise to conduct a roll call in the assembly area.
  • Rescue and medical duties for employees performing them — Small organizations often depend on local emergency responders to fulfill this responsibility. Your medical or dental office likely has employees sufficiently trained to take on this responsibility, but they may not be capable of doing so after an emergency. In any case, your emergency plan should reflect who has this responsibility.
  • Names or job titles of persons to contact — This should include names, titles, departments, and telephone numbers of employees who can contact for additional information and/or an explanation of their duties under the plan. Remember to include cell phone numbers in addition to internal extensions.

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OSHA Emergency Action Plan – The Variables

An emergency action plan has to be more than just words on paper. It must be built as if someone’s life depended upon it because, in an emergency, it very well might.

An effective emergency action plan must be custom-fit for your location. You can’t copy and paste another practice’s procedures, even if they do the same thing you do, in the same way, in the same kind of place. 

Here are a few things to consider:

  • The most significant variable in any situation is people. How will your employees respond in an emergency? Will they keep their cool, or might they be more likely to panic?
  • Think about your clients. Are exits clearly marked? Do you have team members tasked with assisting or directing clients in the event of an emergency?
  • Plan for the “what-ifs.” Your emergency plans need to consider the dynamic nature of emergencies. Employees with critical assignments should have backups if they are not on-site or incapacitated.

Annual OSHA training is necessary for any emergency action plan and can help mitigate some of these concerns.

Using OSHA Emergency Action Plan Templates

A template can be an excellent way to start building an OSHA emergency action plan. OSHA offers e-tools to assist with the process, and you can find templates in many places online.

Not all templates may be helpful in your situation. Remember that all OSHA-regulated businesses and industries are required to have emergency action plans. You should find the one that best matches your situation.

As part of our OSHA Healthcare Compliance services, Compliancy Group is offering OSHA for Dental Offices and will soon add OSHA for Medical Practices.

In addition to thoroughly addressing all the required pieces of OSHA compliance, our plan includes emergency action plan templates designed with the unique needs of medical and dental practices in mind. It’s another way we are committed to being your partner in healthcare compliance.

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