Emergency Action Plan Requirements for NJ Construction Sites

When does OSHA 1926.35 apply?

OSHA’s construction emergency action plan standard, 29 CFR 1926.35, applies to emergency action plans required by a particular OSHA standard. It does not say that every construction employer must keep a written emergency plan for every job. Check which requirements apply to the work and the employer.

What goes in the plan?

When an emergency action plan is required, 1926.35 lists the minimum elements. The plan must address:

  • Emergency escape procedures and assigned escape routes.
  • What employees who stay to operate critical plant operations must do before evacuating.
  • How the employer will account for employees after an evacuation.
  • Rescue and medical duties for employees assigned to perform them.
  • The preferred way to report fires and other emergencies.
  • The names or job titles of people employees can contact for more information about the plan.

The standard also requires an employee alarm system that complies with 29 CFR 1926.159 and says the plan must establish the types of evacuation to use in an emergency.

Review the plan with employees

Before putting the plan into effect, the employer must designate and train enough people to help evacuate employees safely and in an orderly way. Each employee must be briefed on the plan when it is developed, when the employee’s assigned responsibilities change, and whenever the plan changes. When a worker is first assigned, review the parts that worker needs to know.

The written plan must be kept at the workplace and made available for employees to review. There is an exception: an employer with 10 or fewer employees may communicate the plan orally and does not have to maintain a written copy. The standard refers to the employer’s employee count; it does not say to count every worker on a multi-employer site together.

Make the instructions usable

For the work covered by the plan, make sure employees can find the reporting method, assigned escape route, accountability process and names of the people responsible for specific duties. Consider changes in access, work areas and the crew when deciding whether the plan needs an update. These practical checks help keep the written instructions connected to the work.

Read the full OSHA 29 CFR 1926.35 standard and confirm which requirements apply to your operation. If you need help preparing a written safety program for defined work, request a free 30-minute preliminary consultation. Mike works remotely and confirms scope, price and timing before paid work begins.

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