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Emergency action plan checklist: sources and guidance

A review of a workplace emergency action plan against the minimum elements in OSHA's general industry rule, plus a walk-through of the routes and alarms it depends on. Where an OSHA standard requires a plan, it must be in writing, kept in the workplace and available to employees [16] [17].

How often: Review the plan with each employee when it is developed or they are first assigned, when their responsibilities change and whenever the plan changes. How often to re-check the whole plan is set by your organization.[28][29][30]

Purpose

Use this emergency action plan checklist to review your written plan against the minimum elements in OSHA's general industry rule, then walk the building to confirm the routes and alarms it relies on actually work. Where an OSHA standard requires an emergency action plan, the plan must be in writing, kept in the workplace and available to employees for review [16] [17]. The checklist gives the review a fixed order and a record of what was found.

Who should use it

The person responsible for the plan: an owner, safety coordinator or facility manager. The employees designated to help with evacuation [26] are useful companions on the walk-through, because they know how the plan works on the floor.

How often

The plan is reviewed with each employee when it is developed or when they are first assigned to a job, when their responsibilities under it change, and whenever the plan itself changes [28] [29] [30]. A full review with this checklist after any change to the building, staffing or processes is good practice; a regular interval is set by your organization.

How to use this checklist

  1. Have the current plan in front of you. Enter the headcount first: a workplace with 10 or fewer employees may communicate the plan orally instead [18].
  2. Work through the plan contents, alarm, and training sections by reading the plan and its records.
  3. Walk the exit routes, exits, pull stations and assembly point the plan names, and answer the walk-through section on site.
  4. Record each gap with an owner and a date, then update the plan and review the change with every covered employee.

No item on this page is marked critical. The checks review a plan, its alarm and its training, and no single gap is, by itself, a reason to stop work; fix a blocked exit route or an alarm that cannot be heard straight away.

What the rules say

An emergency action plan must include at a minimum:

  • procedures for reporting a fire or other emergency [19];
  • procedures for emergency evacuation, including the type of evacuation and exit route assignments [20];
  • procedures for employees who stay to operate critical plant operations before they evacuate [21];
  • procedures to account for all employees after evacuation [22];
  • procedures for employees performing rescue or medical duties [23];
  • the name or job title of the person to contact for more information about the plan [24].

The employer must also have and maintain an employee alarm system with a distinctive signal for each purpose [25], and designate and train employees to assist in a safe and orderly evacuation [26].

What this checklist does not cover

  • Deciding which OSHA standards require your workplace to have an emergency action plan.
  • Fire prevention plans under 29 CFR 1910.39, which have their own checklist.
  • Detailed design of exit routes, such as fire-resistance ratings and occupant load.
  • Installation standards for fire alarm and detection systems and local fire code requirements.
  • Specialized plans such as hazardous waste operations and emergency response (29 CFR 1910.120) or process safety management.
  • Rules of State Plan states that differ from federal OSHA.

Questions

Does every business need a written emergency action plan?

The requirement applies whenever an OSHA standard in Part 1910 requires a plan [16]. When it applies, the plan must be written, but an employer with 10 or fewer employees may communicate it orally [18].

What must an emergency action plan include?

At minimum: how to report an emergency, evacuation procedures with the type of evacuation and route assignments, procedures for employees who shut down critical operations, a way to account for everyone, procedures for rescue and medical duties, and a contact person [19] [20] [21] [22] [23] [24].

How often does the emergency alarm need to be tested?

Non-supervised employee alarm systems are tested for reliability and adequacy every two months [8]; supervised systems at least annually [10]. When the system is out of service, a back-up means of alarm such as runners or telephones is provided [9].

Do small businesses need an alarm system?

An alarm is still needed, but in a workplace with 10 or fewer employees, direct voice communication is acceptable for sounding the alarm provided all employees can hear it [7].

Does the plan have to say who uses fire extinguishers?

Only if you choose that approach. A plan can designate certain employees as the only ones authorized to use the portable fire extinguishers and require everyone else to evacuate [1]. Employees designated to use firefighting equipment under the plan are trained on that equipment [2].

When does the plan have to be reviewed with employees?

With each employee covered by the plan [27]: when the plan is developed or the employee is first assigned to a job [28], when the employee's responsibilities under the plan change [29], and when the plan is changed [30].

Sources

Each cited excerpt was found word for word in the official text on the date shown.

  1. [1]29 CFR 1910.157 Portable fire extinguishers (b)(2) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  2. [2]29 CFR 1910.157 Portable fire extinguishers (g)(3) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  3. [3]29 CFR 1910.165 Employee alarm systems (b)(2) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  4. [4]29 CFR 1910.165 Employee alarm systems (b)(2) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  5. [5]29 CFR 1910.165 Employee alarm systems (b)(4) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  6. [6]29 CFR 1910.165 Employee alarm systems (b)(4) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  7. [7]29 CFR 1910.165 Employee alarm systems (b)(5) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  8. [8]29 CFR 1910.165 Employee alarm systems (d)(2) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  9. [9]29 CFR 1910.165 Employee alarm systems (d)(3) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  10. [10]29 CFR 1910.165 Employee alarm systems (d)(4) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  11. [11]29 CFR 1910.165 Employee alarm systems (e) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  12. [12]29 CFR 1910.36 Design and construction requirements for exit routes (b)(1) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  13. [13]29 CFR 1910.36 Design and construction requirements for exit routes (b)(3) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  14. [14]29 CFR 1910.37 Maintenance, safeguards, and operational features for exit routes (a)(3) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  15. [15]29 CFR 1910.37 Maintenance, safeguards, and operational features for exit routes (b)(2) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  16. [16]29 CFR 1910.38 Emergency action plans (a) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  17. [17]29 CFR 1910.38 Emergency action plans (b) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  18. [18]29 CFR 1910.38 Emergency action plans (b) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  19. [19]29 CFR 1910.38 Emergency action plans (c)(1) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  20. [20]29 CFR 1910.38 Emergency action plans (c)(2) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  21. [21]29 CFR 1910.38 Emergency action plans (c)(3) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  22. [22]29 CFR 1910.38 Emergency action plans (c)(4) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  23. [23]29 CFR 1910.38 Emergency action plans (c)(5) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  24. [24]29 CFR 1910.38 Emergency action plans (c)(6) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  25. [25]29 CFR 1910.38 Emergency action plans (d) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  26. [26]29 CFR 1910.38 Emergency action plans (e) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  27. [27]29 CFR 1910.38 Emergency action plans (f) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  28. [28]29 CFR 1910.38 Emergency action plans (f)(1) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  29. [29]29 CFR 1910.38 Emergency action plans (f)(2) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.
  30. [30]29 CFR 1910.38 Emergency action plans (f)(3) — eCFR (Office of the Federal Register). Retrieved September 24, 2026.

Guidance, not legal advice. It does not replace the law, the manufacturer's instructions or your organization's competent people.