OSHA Emergency Action Plan (EAP): Requirements & Elements

Q: Does my workplace need a written emergency action plan?

If an OSHA standard requires you to have an EAP — true for the large majority of workplaces via the fire-protection rules — and you have more than 10 employees, the plan must be written and available for review. With 10 or fewer employees, oral communication of the plan is permitted.

Q: What must an emergency action plan include?

At minimum: emergency reporting procedures, evacuation procedures with exit-route assignments, procedures for critical-operations personnel, post-evacuation headcount procedures, rescue and medical duty procedures, and contact names or job titles for questions about the plan.

Q: How often is EAP training required?

At three triggers: when the plan is developed or an employee is first assigned, when an employee's responsibilities under the plan change, and when the plan changes. Annual drills are not federally mandated for most workplaces but are the accepted way to prove the plan works.

5 min readUpdated August 10, 2026

Who needs an EAP

An emergency action plan is required whenever another OSHA standard requires one — and the most common route is the fire-extinguisher rules: the practical result is that the large majority of workplaces need an EAP. Employers with more than 10 employees must have it in writing, kept in the workplace and available for employees to review; employers with 10 or fewer may communicate the plan orally (29 CFR 1910.38(b)).

The minimum elements

1910.38(c) sets the floor — a compliant plan covers at least:

Procedures for reporting a fire or other emergency.
Procedures for emergency evacuation, including type of evacuation and exit route assignments.
Procedures for employees who remain to operate critical plant operations before they evacuate.
Procedures to account for all employees after evacuation — the headcount that determines whether anyone goes back in.
Procedures for employees performing rescue or medical duties.
The name or job title of every employee who can be contacted for more information about the plan.

Alarms, training, and the moments that trigger both

The plan needs an employee alarm system with a distinctive signal for each purpose (1910.165 governs alarm systems), and designated evacuation wardens are the norm in larger facilities. Training is event-driven: review the plan with each employee when the plan is developed or the employee is initially assigned, when the employee's responsibilities under the plan change, and when the plan itself changes.

The recurring failure is drift: exit-route assignments that predate the current floor plan, contact names who left the company, and assembly points that moved. An annual walk of the plan against the building — plus a drill — catches all three.

The companion: the fire prevention plan

29 CFR 1910.39 pairs the EAP with a fire prevention plan — major fire hazards, ignition-source controls, fuel-source housekeeping, and the names or titles responsible for maintaining prevention equipment and controlling fuel hazards. Same written/oral threshold, same review discipline. Keeping the two current together is the cleanest audit posture.

Educational content, not legal advice. This guide summarizes federal requirements in plain English. Regulations change and jurisdictions differ — verify against the current official text and your work-site jurisdiction's rules before acting. SafeGora helps you prepare and organize; filings, postings, and legal determinations remain yours.

Frequently asked questions

Does my workplace need a written emergency action plan?

What must an emergency action plan include?

How often is EAP training required?

Plans that don't drift

SafeGora keeps EAP and fire-prevention documents versioned per establishment, assigns the review cadence, and records the training events each trigger requires.

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Emergency action plans: what 1910.38 requires