You need an emergency action plan. Managing Workplace Health and Safety covers how emergency planning integrates with your broader safety program. Not eventually. Now. Whether you run a dental practice with 8 people or a warehouse with 150, OSHA says you must have a documented plan. It tells employees how to evacuate. How to respond when things go wrong. For companies with 11 or more workers, it has to be written down. Smaller teams can keep it verbal. But you still have to prove you told people what to do. OSHA fines start at $10,000. They climb from there. Beyond money, the real risk is injured employees. People who didn’t know how to get out safely.
What Exactly Is an Emergency Action Plan?
Think of an EAP as your workplace’s playbook. Supervisors who hold OSHA-30 for General Industry certification are far more equipped to build, maintain, and update these plans as regulations evolve. What happens when a fire starts? When someone spills chemicals? When a tornado warning hits? What about an active threat? Coggno’s Active Shootings in the Workplace course covers the run-hide-fight protocol that OSHA and DHS recommend as part of comprehensive emergency planning. What do you do for any emergency? Under 29 CFR 1910.38 (and OSHA 10: General Industry, which covers this standard in detail), almost every employer needs one. Your plan answers critical questions. Who calls 911? Which doors do people use? Where do they go after they evacuate? How do you count heads after?
It’s not theoretical. Not something you read once and forget. When the fire alarm blares at 2 p.m. on a Tuesday, you don’t want your team standing around confused. The nurse at the dental clinic needs to know the fastest way out. With a patient in a wheelchair. The warehouse manager needs to know that all 60 people on the afternoon shift left. Through the loading dock exits. Area coordinators are reporting counts. To dispatch. The plan makes sure that happens. Without anyone thinking. Without panicking.
Do You Actually Need One?
Yes. The only employers who don’t need an OSHA emergency action plan are very small operations. With zero foreseeable hazards. That’s basically nobody. A retail store could have a fire. An office could face a gas leak. Or an active threat. A warehouse has chemical storage sitting around. Even a quiet administrative office needs an EAP. If people work there. If they need to leave the building.
OSHA applies this requirement if any standard in Part 1910 could apply to you. Manufacturing? Check. Hospitality? Check. Healthcare? Check. Construction. Retail. Technology. Nonprofits. Basically everyone. If you work with people and there’s a building they exit from, you need a plan.
The 10-Employee Rule: What It Really Means
Here’s where company size matters: if you have 10 or fewer employees, you can tell people your EAP. Instead of writing it down. That’s it. That’s the only concession OSHA gives. Don’t think of it as “we’re exempt.” Think of it as “we get paperwork relief.”
For an 8-person marketing firm, the owner can walk around one afternoon. Say: “If the fire alarm sounds, we exit through the side stairwell. We meet at the northwest corner of the parking lot. I take attendance there.” That conversation? That’s your EAP. But you still need to train new people. You still need to drill it. Once a year, at minimum. And you still need to prove you did it. If OSHA shows up. An inspector will ask your employees: “What’s your evacuation route?” If they say, “I don’t know,” you’re in trouble.
With 11 or more employees, there’s no verbal option. You write it down. Keep it at work. Make it available. Same training rules apply. Just with documentation.
What OSHA Actually Requires
29 CFR 1910.38 spells out the pieces. Let’s walk through what each looks like in the real world.
1. How People Report an Emergency
Someone has to call 911. Your plan says who. In a 15-person office, maybe the receptionist. In a manufacturing floor with 120 people, you might assign zone supervisors. They spot the problem. Your EAP should also address workplace violence scenarios — OSHA expects employers to plan for human threats, not just fires and weather events. Radio it to a command center. That center calls dispatch. The point: the plan names the person. Names the method. No time gets wasted.
2. Exit Routes and Evacuation
This is the core section. Your employees need to know where to exit from every room. Coggno’s Emergency Action Plan: Evacuation Elements course covers exit design, assembly points, and the physical layout requirements OSHA inspectors check—useful for the person building or auditing your plan. Your plan includes:
Specific exit assignments. Third-floor marketing team uses the north stairwell. Warehouse staff use the loading dock.
All routes marked with exit signs. Nothing blocking them. No storage. No equipment.
An outdoor assembly point. A parking lot. Green space. A yard. Where people gather after they leave the building.
Special arrangements for people with mobility issues. Vision loss. Hearing loss.
What people do if they run critical equipment. A power plant operator might shut down systems before evacuating.
Real example: a 12-person dental clinic. Front desk and reception team exit through the main entrance. They head to the parking lot corner at the flagpole. Clinical staff use the back exit. To the side yard. Everyone meets at the flagpole. The dentist checks that the air compressor is off. Before leaving. That’s the plan. Specific. Clear. Actionable.
3. Counting Heads After You Evacuate
How do you know if anyone is still inside? Your plan has to say. Coggno’s EAP Reporting and Review course focuses on accountability and communication steps during and after an evacuation—the part most employers get wrong. Some options: supervisors do a quick count. They report to the site manager. That manager confirms the total matches the roster. Or for a smaller site, one person does the headcount. Usually the owner or manager. They relay it to emergency responders.
For an 80-person warehouse shift: each floor supervisor accounts for their team. They radio those numbers. The safety manager totals them. Tells the fire department, “All personnel accounted for.” For a 12-person office: the office manager goes through the sign-in sheet. Once everyone’s at the flagpole, they confirm 12 people are there. Or they tell responders that Jane hasn’t exited. So responders search for her.
4. Your Alarm System
You need a way to alert everyone. A fire alarm bell. A horn. An intercom. Or text and email if your staff is spread across locations. Whatever gets the word out instantly. The key: it has to be distinctive. People should hear it and instantly know “emergency.” Not “time for a meeting.”
If you have deaf or hard-of-hearing employees, you need visual alarms. Lights. In addition to audible ones. If you have people in separate buildings or off-site, your plan has to account for how they get the alert.
5. Who Handles Rescue and Medical Response
Some employees are trained in first aid or CPR. Coggno’s Emergency First Aid course and CPR Training give your designated responders the skills to bridge the gap until EMS arrives. Some might assist injured coworkers. Or search for missing people. Coggno’s Emergency Action Plan & Medical Services course combines evacuation training with first aid response duties—ideal for the people you designate as first responders. Your plan assigns these roles in advance. You name the first-aid team. List where the AED and first-aid kit are. Say whether rescuers stay on site. Or evacuate with everyone else.
How to Train People on This Plan
Writing the plan is step one. Training is step two. OSHA is strict about it. Coggno’s Emergency Action Plan Orientation course is designed for all employees—it covers what an EAP is, why it exists, and what each person’s role is when an emergency happens. The Emergency Evacuation course provides practical training on evacuating quickly and safely, and is well suited for annual refresher drills. You have to review the EAP with each employee:
When you first create or update the plan. Mandatory for existing staff.
When you hire someone new. Before day one or on day one.
When the plan changes. New exit route. New assembly point. Anything material.
When an employee’s role changes. Promoted to supervisor. Now responsible for headcount. Now need special training.
OSHA doesn’t mandate annual drills in the regulation itself. But they strongly recommend it. Employees forget. A fire drill once a year keeps the plan fresh. It shows you if an exit is blocked. It lets staff practice so they’re not confused when it’s real.
You also have to formally designate “evacuation wardens.” People trained to guide others out. Make sure areas are clear. This isn’t something you assume will happen. You assign names. Train them. Document it. Update it when people leave or move roles.
What OSHA Looks For During an Inspection
If an OSHA compliance officer shows up, here’s what happens:
They ask for a copy of your plan. Or they ask employees to describe it if you’re under 10 people. Then they interview your staff: “If a fire started right now, which exit would you use?” “Where would you go after?” “What’s the assembly point?” If employees look confused or give different answers, that’s a problem. Red flag for the inspector.
They walk the building. Check that exits are marked and not blocked. Check that your assembly point is clear. Far enough from the building. Check that you have alarm systems. They ask for training records. Do you have documentation showing when you trained people? Did you test their knowledge?
If pieces are missing—no assembly point, no marked exits, no training records—you get citations. Each violation is separate. A 12-person dental office might get one citation for a missing plan. An 80-person warehouse with poorly marked routes, no trained wardens, and no drills could face five or six separate violations. Each at $16,131 (2025 OSHA penalty). That’s $80,000+ fast.
Common Mistakes We See
In practice, the gaps are consistent:
No assembly point marked or communicated. People evacuate but don’t know where to gather. They wander or block fire trucks.
Exits aren’t marked or are blocked. A supply closet occupies an emergency exit. Or signs are so faded nobody sees them.
No one knows how to take attendance. After the evacuation, the supervisor thinks someone counted everyone. But no one did.
Warden assignments are vague. “We’ll figure it out during an emergency” is not a plan. You need names. Training records.
One training in 2018, nothing since. New hires never trained. Existing staff forgot. No drills.
Forgetting people with disabilities. No plan for someone in a wheelchair. No visual alarms for deaf staff. No buddy system.
No written plan even with 50+ employees. It’s in the owner’s head. Not written down where employees can review it.
Why This Matters
OSHA fines are one thing. But here’s the actual reason: if a real emergency happens, a clear plan saves lives. When people have trained for an evacuation and know their role, they move faster. They panic less. Nobody gets trampled. Nobody gets left behind. That’s why you spend the time now.
How to Start Building Your Plan
If you don’t have one or yours is gathering dust:
Walk your building with a notebook. Map every exit, stairwell, and door to the outside. Measure the distance from the building to your assembly point candidate.
List what emergencies are realistic. Fire? Chemical spill? Power loss? Severe weather? Active threat? Whatever applies to your industry and location.
Write down roles: who calls 911, who is the warden for each area, who takes headcount, who has first aid training.
Draft your plan with those details. Coggno’s EAP Development course walks managers through every required OSHA component and how to customize it for your workplace—a faster path than starting from scratch. Get it reviewed by your insurance agent, a local fire marshal, or an OSHA consultant if you want additional confidence.
Train everyone on it. New employees get trained at hire. Existing employees get trained in the next staff meeting.
Drill it once a year, at minimum. Schedule a fire drill. Do it for real. Note what went wrong. Fix it. Repeat.
Review and tweak the plan whenever your building layout changes, you move locations, or someone new is hired with different abilities.
Frequently Asked Questions
Your emergency action plan is the difference between an orderly evacuation and chaos. Start today. Walk your building. Draft your plan. Train your team. If you want to build a complete safety program beyond the EAP, Coggno’s How to Develop a Safety Program course covers the broader framework—EAP is a key module within it. Drill at least once a year. You’ll have documented proof of readiness when OSHA inspects.
