Emergency action plan

Editorial approval scope: The team checked current source fidelity, scope boundaries, dates, arithmetic, reader usefulness, practical workflow, and general-information limitations.

OSHA supplies a specific federal baseline

The OSHA emergency-preparedness page explains that an EAP is required when another OSHA standard triggers 29 CFR 1910.38. OSHA recommends planning more broadly even when that federal trigger is absent.

Under 29 CFR 1910.38, a triggered plan generally must be written, kept in the workplace, and available to employees. An employer with 10 or fewer employees may communicate it orally. The rule includes procedures for reporting, evacuation, critical operations before evacuation, employee accountability, rescue or medical duties, and plan contacts, plus alarms and training.

That federal rule is a floor for its scope. A state plan, local fire code, licensing rule, lease, or service model can add duties.

Plan from hazards and people

Start with site and service hazards: fire, smoke, severe weather, earthquake, violence, missing person, utility failure, chemical release, medical emergency, transportation event, and technology outage. Use local emergency guidance and actual building systems.

For each scenario, define:

• detection and reporting trigger
• evacuation, shelter, lockdown, or safe-pause decision
• who may activate and end the action
• primary and alternate routes or locations
• client, visitor, and employee accountability
• emergency-services and family communication
• clinical, medical, privacy, and continuity escalation
• recovery acceptance and after-action review

Avoid one generic “evacuate” instruction. The safe action for fire can differ from the safe action for severe weather or an outside threat.

Protect communication and person-specific needs

Maintain current information needed for safe action: mobility support, AAC and backup communication, hearing or visual alerts, medication or medical dependencies, elopement risk, sensory needs, and emergency contacts. Collect only the information each role needs.

Build an accessible route and a backup into the plan. Keep communication devices available. Assign assistance through training and the person’s involvement. A plan should never assume that a person can hear an alarm, use stairs, tolerate physical guidance, or understand rapid spoken directions.

Clinical content stays with appropriately qualified clinicians. Emergency responders control their response under applicable authority. Staff follow their assigned role and call emergency services without waiting for routine payer or administrative approval.

Make accountability observable

Use a roster marked with its source and as-of time. Define who brings it, who checks each area, where groups assemble, and how missing or duplicate names are resolved.

For community and home services, define location-specific check-in and emergency contacts. A center-only plan leaves mobile staff without a route. Address visitors, contractors, and employees working outside normal hours.

Protect sensitive information in emergency copies. Test access when the primary EHR, power, or network is unavailable.

A fictional two-shift drill

Cedar Path ABA runs a tabletop and evacuation drill across opening and evening shifts. Sixteen assigned actions are due, including alarm recognition, emergency call, route opening, two sweep zones, rosters, AAC backup, assembly accountability, family message, clinical escalation, and return authority.

Fourteen actions meet the defined time and evidence requirements. One alternate exit has a blocked approach, and the evening roster omits a contractor. Drill completion is 14 of 16, or 87.5%. Both failures stay in the denominator.

The team clears the route, adds contractor handling, and reruns those actions. It records actual duration from alarm activation to verified accountability rather than “fast enough.”

Drills should test decisions safely

Train new employees when assigned and review duties when the plan or role changes. Exercise different hazards, shifts, unavailable leaders, and system outages. Include a no-fault stop signal for unsafe or distressed participation.

Avoid surprise drills that could create danger or trauma. Explain the exercise at an appropriate level, preserve assent where applicable, and use tabletop simulation for high-risk actions. A drill never authorizes restraint or medically unsafe handling.

Measure actions completed by target divided by actions due, people accounted for divided by people on the locked roster, and corrective actions closed by due date divided by actions due. Define each clock’s start and end.

Connect response with continuity

The EAP governs immediate workplace action. Emergency preparedness also covers supplies, communications, vendor dependencies, continuity, recovery, and resumption.

Ready Business provides voluntary general guidance on hazards, communications, IT recovery, continuity, training, and exercises. It is not an ABA or OSHA authority.

After an event, preserve safety and clinical records, route required notices, support affected people, reconcile services and payroll, and accept recovery through defined evidence. Document lessons and plan changes.

Check the applicable OSHA state plan for each site. Keep the governing sources, plan version, owners, training dates, drill evidence, and open corrections together.