HR Question:

According to the OSHA Training Requirements, is it mandatory that I conduct practice evacuation drills as part of my company’s annual training?

HR Answer:

The Occupational Safety and Health Administration (OSHA) does not require employers to conduct drills at a certain frequency. However, it is recommended as part of a comprehensive Emergency Action Plan, which is required. OSHA standard 29 CFR 1910.38(a) outlines the requirement for written documentation, planning, and training for workplace emergencies, and as an employer, preparing for the ‘worst case’ is something you should want to do. In today’s world where we’ve seen an increase in active shooter incidents, unpredictable weather patterns, and wildfires, emergency preparedness will allow you and your employees to have a plan in place should you be impacted by some type of potentially hazardous situation.

How to Prepare Employees for Workplace Emergencies

Employers should consider evacuation plans as one small part of the required Emergency Action Plan and use them as the opportunity to practice. The drills could include evacuation due to a fire, chemical leak, or even a shelter in place in the event of an external chemical emergency.

OSHA’s Evacuation and Procedures e-tool provides step-by-step guidance to help you prepare your workplace for potential emergencies. In addition, this OSHA Workplace Emergencies Factsheet provides an outline of what is required. Once you have a plan in place, OSHA recommends that you review the plan with employees and hold practice drills “as often as necessary.” It is also advised to include outside resources such as fire and police departments when possible. OSHA recommends that after each drill you assess the effectiveness of the drill (and the plan) and make adjustments as needed.

How to Meet OSHA Training Requirements

Workplace safety training will vary depending on the type of business. Here are some important points to consider when deciding what types of training your employees need to meet OSHA Training Requirements and Standards:

•  Educate your employees about the types of emergencies that may occur and train them in the proper course of action.
• The size of your workplace and workforce, processes used, materials handled, and the availability of onsite or outside resources will determine your training requirements.
• Be sure all your employees understand the function and elements of your emergency action plan, including types of potential emergencies, reporting procedures, alarm systems, evacuation plans, and shutdown procedures.
• Discuss any special hazards you may have onsite such as flammable materials, toxic chemicals, radioactive sources, or water-reactive substances.
• Clearly communicate to your employees who will be in charge during an emergency to minimize confusion.

It is a good idea to keep a record of all safety and health training. Documentation can also supply an answer to one of the first questions an incident investigator will ask: “Did the employee receive adequate training to do the job?”

Emergency Action Plan Resources

OSHA has a number of outstanding resources to assist you in your planning process for an Emergency Action Plan, as well as all of the required OSHA standards. Free resources to help you with your safety training plans can be found in OSHA’s Training Resources and this updated booklet which outlines all of OSHA’s training-related requirements in one document.

Keep in mind that although drills are not required, a well-developed emergency plan with proper training (including drills) will result in fewer injuries and less confusion and chaos during an emergency. A well-organized response will help you, your employees, and your business to be in the best position to effectively handle an emergency.

Thank you to Patti Dunham, MBA, MA, SPHR, SHRM-SCP for contributing to this HR Question of the Week.

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