Resources
OSHA emergency action plan: what it must contain, with a fill-in template
An emergency action plan tells everyone in a workplace how to report an emergency, how to get out, who stays behind to shut things down and how the people who left get counted. OSHA requires one only where a specific standard calls for it, but the plan’s contents are spelled out in 29 CFR 1910.38, and Cal/OSHA sets its own version in 8 CCR 3220. This guide walks through the required parts, separates them from OSHA’s recommendations, and shows where night cleaners and day porters belong in a commercial building’s plan.
Request a quoteCall (408) 668-0624
Printable template
What an emergency action plan is
It is the employer’s written playbook for fires and other workplace emergencies: what employees do, who leads, and how everyone ends up safe and accounted for. OSHA describes the plan as a document that particular OSHA standards require, meant to organize what employers and workers do when something goes wrong. The rules for every such plan sit in 29 CFR 1910.38.
The emergencies in scope go well past fire. OSHA’s planning guide, OSHA 3088, lists floods, hurricanes, tornadoes, toxic gas releases, chemical spills, radiological accidents, explosions, civil disturbances and workplace violence. The same guide says an employer with several worksites should give each one its own plan, built on a hazard assessment of that workplace.
When OSHA requires an emergency action plan
OSHA requires a plan when one of its Part 1910 standards says so, not for every business by default. Section 1910.38 then sets what each required plan must hold. OSHA’s guide adds that a plan is a sound way to protect people and the business even where no standard demands one.
Fire extinguishers are the trigger most offices and warehouses run into. Under 29 CFR 1910.157, an employer whose written policy is full and immediate evacuation on the alarm, that keeps no extinguishers on site and that has an emergency action plan and fire prevention plan meeting 1910.38 and 1910.39 is exempt from the extinguisher standard unless another standard requires one. If extinguishers are present but employees are not meant to use them, those same two plans limit the standard to its paragraphs (e) and (f). If the plan names the only employees allowed to use them and everyone else leaves on the alarm, the exemption covers only the distribution paragraph.
OSHA’s own questionnaire, Does OSHA require you to have an EAP?, also asks about total flooding extinguishing systems, fire detection systems whose alarms are delayed more than 30 seconds, and standards such as process safety management (1910.119) and grain handling (1910.272). OSHA 3088 names hazardous waste operations and emergency response (1910.120(q)), fire brigades (1910.156) and permit-required confined space rescue (1910.146(k)) as other standards with planning duties. Run the questionnaire for your own site; the standards decide, not this page.
Written plan or spoken plan: the 10-employee rule
The plan must be written down, kept at the workplace and open for employees to read. An employer with 10 or fewer employees may give the plan to them orally instead. The same headcount appears in the alarm rule, where a small workplace may rely on a direct voice warning that everyone can hear.
The six required parts of the plan
Section 1910.38(c) lists six minimum elements. Every required plan covers all six, and OSHA’s eTool on minimum requirements gives a practical example of each.
| Required element | What OSHA’s eTool gives as an example |
|---|---|
| How to report a fire or other emergency | Dialing 911, an internal emergency number or a manual pull station |
| How to evacuate, including the type of evacuation and exit route assignments | Who can order an evacuation, when, and which routes to use; exit diagrams are typical |
| What employees who stay to run critical operations do before they leave | Shutting down gas or electrical systems, or using extinguishers |
| How all employees are accounted for after evacuating | Sweeping areas, checking offices and restrooms, or a roll call at the assembly area |
| Procedures for employees who perform rescue or medical duties | Small organizations often leave these duties to the local fire department or hospital |
| Name or job title of each person employees can contact about the plan | A short contact list for questions about the plan and individual duties |
Alarm rules that go with the plan
The employer must keep an employee alarm system with a distinct signal for each purpose, and the system must meet 29 CFR 1910.165. In short, the alarm has to give people time to act on the plan or to escape safely, and it has to be noticed over the area’s noise and light by everyone affected.
- The signal is distinctive and recognized as the cue to evacuate or carry out plan duties; tactile devices may serve employees who cannot perceive sound or light.
- Employees are told the preferred way to report an emergency, such as pull boxes, public address, radio or telephone, and emergency numbers are posted near phones where phones are the method.
- Non-supervised systems are tested every two months with a different actuation device each time; supervised systems are tested at least once a year.
- When the system is out of service, a backup such as runners or telephones is in place.
- Manual pull stations stay unobstructed, easy to see and easy to reach.
- Only people trained in the system’s design and operation service, maintain and test it.
For the inspection rhythm of extinguishers, exit signs and emergency lighting, see our building maintenance checklist generator.
Training, reviews and drills
The regulation requires two things: designate and train enough employees to help others evacuate safely, and review the plan with each covered employee at three moments. Those moments are when the plan is first written or the employee is first assigned, when the employee’s duties under it change, and when the plan itself changes.
Everything beyond that is OSHA’s advice rather than rule text. Its develop and implement page says effective plans often call for retraining once a year, and suggests updating the plan when duties, layout, equipment, hazardous materials or processes change. OSHA also recommends practice drills as often as needed, with the fire and police departments taking part where possible, followed by a meeting to sort out what worked. A practical tip from the same page: put agency and facility phone numbers on a separate front sheet, because that is the part that goes stale first.
Training topics OSHA lists include each person’s role, the hazards and protective actions, how warnings are given, evacuation, shelter and head-count procedures, where common emergency equipment is and how to use it, and emergency shutdowns.
The fire prevention plan, where a standard calls for one
A fire prevention plan under 29 CFR 1910.39 follows the same written-or-oral rule. It lists the major fire hazards with their handling and storage procedures, ignition sources and how they are controlled, and the fire protection equipment for each hazard. It also covers controlling flammable and combustible waste, keeping safeguards on heat-producing equipment in place, and naming who maintains that equipment and who controls fuel-source hazards. Employees learn the fire hazards they face when first assigned.
Waste control is where a cleaning program touches this plan directly: trash, cardboard and recycling that pile up in corridors, loading areas and electrical rooms are fuel. Regular removal on a set schedule, through nightly janitorial service or a daytime porter route, keeps those areas in line with what the plan describes.
Evacuation routes, wardens and head counts in OSHA’s guidance
OSHA’s guidance fills in the practical side of evacuation, and none of it is a rule in 1910.38. Its evacuation elements page and OSHA 3088 suggest a coordinator with authority to make decisions, known to every employee, and about one warden for every 20 employees, with enough wardens on hand during all working hours.
- Wardens check offices, restrooms and other rooms on the way out, make sure fire doors are closed, know the layout and alternate routes, and know who needs extra help.
- Primary and secondary routes are marked, lit, wide enough, free of debris at all times and posted on diagrams.
- An assembly area is set, a head count is taken there, and the names and last known locations of anyone missing go to the official in charge.
- Visitors, suppliers and contractors are counted too; sign-in logs help, and hosts or wardens guide visitors out.
- The plan covers people with disabilities and people who do not speak English.
- Rescue is left to people trained and equipped for it.
Optional items OSHA mentions include a description of the alarm system, an alternate communications center in case of fire or explosion, and a secure place, on or off site, for copies of essential records and employee emergency contacts.
Buildings with more than one employer
In a multi-tenant office or mixed-use building, each employer is responsible for the plan that covers its own employees. OSHA’s guidance says coordinating with the other employers in the building makes plans work better, while noting that its standards do not specifically require that coordination. OSHA also suggests walking the plan through with outside responders such as the fire department or a local hazmat team.
In practice, that means the property manager’s building procedures, each tenant’s plan and each contractor’s plan should agree on the alarm meanings, the exits and the assembly points, even though they are separate documents.
Shelter-in-place
Sometimes staying inside is safer than leaving. OSHA’s shelter-in-place page covers a nearby release of chemical, biological or radiological contaminants and says the alert must be easy to tell apart from the evacuation signal. Its steps include keeping customers and visitors inside, locking exterior doors, closing windows and vents and shutting off air handling, moving to an assigned interior room, and listing everyone in that room, whether employee, visitor or customer, for a designated emergency contact.
California: 8 CCR 3220 next to the federal rule
For a California site, read Cal/OSHA’s 8 CCR 3220 alongside 1910.38. The two cover the same six topics, a matching alarm duty under 8 CCR 6184 and the same 10-employee oral option. Cal/OSHA’s fire prevention plan section, 8 CCR 3221, also asks for written housekeeping procedures to control flammable and combustible waste. As of November 2026, the two texts differ in these places:
| Point | 29 CFR 1910.38 and 1910.165 | 8 CCR 3220 and 6184 |
|---|---|---|
| Order of the six elements | Reporting is listed first | Reporting is listed fifth, and contacts are named by regular job title |
| Types of evacuation | Part of the evacuation procedures element | A separate subsection says the plan must state them |
| Evacuation helpers | Designate and train them | Designate and train them before the plan is put in place |
| Small employers | 10 or fewer may communicate the plan orally | Same, and the text says outright that no written plan is needed |
| Supervised alarm circuitry | Applies to systems installed after January 1, 1981 | Applies to systems installed after July 1, 1981 |
Cal/OSHA’s 8 CCR 3220 does not list which California orders trigger the duty to have a plan, so check the orders that apply to your operation or ask Cal/OSHA directly.
Where night cleaners and day porters fit
Cleaning crews are covered by their own employer’s plan, not by the tenant’s, and the two should match on the ground. Night cleaners are often the only people on a floor after hours, so the building’s alarm meanings, two ways out of every area they clean and the assembly point matter more to them than to almost anyone.
- Their employer’s plan names who they report to in an emergency and how a supervisor counts them, since a tenant warden’s roll call may not include them.
- Unless their employer has trained and assigned them, they leave fires and rescues to others.
- Carts, machines and supplies stay out of corridors, stairwells and exit doorways, and fire doors are never propped or wedged.
- Blocked exits, dark exit signs, damaged extinguishers and wedged doors found while cleaning get reported to the property manager.
- Crews sign in and out where the building keeps a contractor log, which feeds the head count.
- Supervisors carry a current crew list with phone numbers for the shift.
- A new crew member walks the routes and assembly areas on the first shift at a site.
The same habits apply to day and night porters, who move through lobbies, restrooms and stairwells all day and often spot an obstructed exit first.
Download the emergency action plan template
Download the emergency action plan template from the bar under the page title. It has blanks for each of the six required elements, the contact list, exit routes and assembly points, the alarm signals and tests, the head count and the training and review record. Fill it in for each worksite, keep it where employees can read it, and replace it whenever the building, the duties or the plan change.
Get help
If you manage an office, industrial or retail building and want cleaning and porter crews who work inside your emergency procedures, request a walkthrough. Bring your building’s plan to it, and we will set crew hours, cart storage and sign-in around your exits and assembly points before writing the quote.
A few useful answers
Common questions
Does every business need an OSHA emergency action plan?
No. Under 29 CFR 1910.38 a plan is required where an OSHA standard calls for one, such as some fire extinguisher setups under 1910.157. OSHA’s planning guide still recommends a plan for workplaces that are not required to have one.
Can a small business keep its emergency action plan verbal?
Yes, with 10 or fewer employees. Both 29 CFR 1910.38 and Cal/OSHA’s 8 CCR 3220 let an employer that size communicate the plan orally, and the California text adds that no written copy is needed.
How often does an employee alarm system have to be tested?
Under 29 CFR 1910.165, a non-supervised system is tested every two months, using a different actuation device each time, and a supervised system at least once a year. Cal/OSHA’s 8 CCR 6184 sets the same intervals.
Does OSHA require evacuation wardens?
The rule requires designating and training employees to help with an orderly evacuation. Wardens by that name, and the one-per-20-employees ratio, come from OSHA’s guidance, not from 1910.38 itself.
Does our janitorial contractor’s plan cover our employees?
No. Each employer’s plan covers its own employees. The cleaning company’s plan covers its crew, the tenant’s plan covers the tenant’s staff, and OSHA’s guidance encourages the employers in a building to coordinate.
Is the California emergency action plan rule different from OSHA’s?
It covers the same six topics, but 8 CCR 3220 lists them in a different order, gives the types of evacuation their own subsection and says evacuation helpers must be trained before the plan takes effect.
Resources