The COVID-19 virus has forced us to change our way of living…and working. While many employers are slowly beginning to resume business, it is not business as usual. Consider your emergency action plan (EAP) for example. While setting up barriers, teaching about social distancing and providing masks for your workers, did you remember to address, and update if necessary, your EAP?
The six required elements of an EAP found at 1910.38(c)(1)-(6) are:
- Procedures for reporting a fire or other emergency;
- Procedures for emergency evacuation, including type of evacuation and exit route assignments;
- Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;
- Procedures to account for all employees after evacuation;
- Procedures to be followed by employees performing rescue or medical duties; and
- The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.
During this era of COVID-19, it would be good practice to weave activities into your EAP to help minimize virus transmission. Suggested activities include:
- In addition to other surfaces, is the plant cleaning crew wiping down the emergency pull stations, fire extinguishers, hook sticks and other equipment that may be needed during an emergency? What about tactile devices such as signs that may be provided in Braille?
- Are your workers practicing social distancing, wearing masks or both? If not wearing masks, an evacuation may take longer while maintaining social distancing. It may be necessary to devise an evacuation plan that includes social distancing unless workers are wearing face masks.
- While mustering at assigned muster points outside the facility, what steps are being taken to continue to minimize exposure to workers?
- For those workers who have been trained to perform rescue or medical duties, has training been updated to include adequate COVID-19 protection and protocols? Have team members been provided with proper PPE?
- Will the wearing of a face mask impede emergency team members in performing assigned tasks? If so, how can the situation be changed to provide protection during emergencies?
- Employers should have an in-house COVID-19 “go-to person” who can answer employee and employer COVID-19-related questions. Add them to your list of contact persons per 1910.38(c)(6).
Now would be a good time to review your facility’s Emergency Action Plan to determine if any adjustments are needed to continue worker protection during times of emergency such as these. As always, The EI Group, Inc. stands ready to assisting in updating your EAP or any other health and safety-related concerns.
Bill Taylor, CSP, Principal Safety Scientist with The EI Group, can be reached at (919) 593-2145 or firstname.lastname@example.org.