Ask a California facility manager for the emergency action plan and you will usually get an evacuation map from the tenant improvement drawings and a fire extinguisher inspection tag. Title 8, Sections 3220 and 3221 are two of the shortest standards in the General Industry Safety Orders and two of the most frequently cited after a fire, a chemical release, or a power failure, because inspectors expect a written document with specific elements and most employers have never written one. This article covers who needs each plan, what goes in it, how Section 6184 alarms fit, and how the plans connect to the IIPP.
Who Needs a Written Plan
Section 3220(a) states that the section applies to all emergency action plans, that the plan shall be in writing, and that it shall cover the designated actions employers and employees must take to ensure employee safety from fire and other emergencies. Section 3221(a) says the same of fire prevention plans. Neither Cal/OSHA section carries the limitation found in the federal standards, which apply only when another standard requires a plan. In practice, Cal/OSHA inspectors treat both sections as applying to California employers generally, and I advise clients to do the same.
The one relief valve is headcount. Both sections provide that an employer with 10 or fewer employees may communicate the plan orally to employees and need not maintain a written plan. The exception excuses the paper, not the plan. A 12-person machine shop needs both plans in writing.
What the Emergency Action Plan Must Contain
Section 3220(b) lists the minimum elements. The plan must include:
- Emergency escape procedures and emergency escape 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 emergency evacuation has been completed.
- Rescue and medical duties for those employees who are to perform them.
- The preferred means of reporting fires and other emergencies.
- Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan.
Section 3220(d) adds that the employer must establish in the plan the types of evacuation to be used in emergency circumstances. A shelter-in-place response to a chemical release next door, a partial evacuation for a small fire, and a full evacuation to an off-site assembly point are different types of evacuation, and the plan is supposed to say which one applies to which event and who makes the call.
Section 3220(e) covers training. Before implementing the plan, the employer must designate and train a sufficient number of persons to assist in the safe and orderly emergency evacuation of employees. The employer must review the plan with each employee covered by it when the plan is developed, whenever the employee’s responsibilities or designated actions change, and whenever the plan is changed. On initial assignment, the employer must review with each employee the parts of the plan the employee must know to protect themselves in an emergency. The written plan must be kept at the workplace and made available for employee review.
Notice what is not in the section. Section 3220 does not require evacuation drills. I recommend an annual drill because it is the only reliable way to find out whether the accounting procedure works, but do not describe it as a Section 3220 requirement.
The Alarm System: Section 3220(c) and Section 6184
Section 3220(c) requires the employer to establish an employee alarm system that complies with Article 165 of the General Industry Safety Orders, and, if the alarm system is used for more than one purpose, to use distinctive signals for each purpose. Article 165 is Section 6184, Employee Alarm Systems, and it applies to all emergency employee alarms.
The requirements that matter for a plan writer are these. The alarm must provide warning for necessary emergency action and must be capable of being perceived above ambient noise or light levels by all employees in the affected portions of the workplace. The signal must be distinctive and recognizable as a signal to evacuate or to perform whatever action the plan calls for. The employer must explain to each employee the preferred means of reporting emergencies, and must establish procedures for sounding the alarm. Manually operated devices must be unobstructed, conspicuous, and readily accessible.
Maintenance and testing are where citations come from. Under Section 6184, an alarm system that is not supervised must be tested every two months, using a different actuation device on each test in sequence. Supervised systems installed after July 1, 1981 must be tested annually. Systems must be restored promptly after each test or alarm, and servicing, maintenance, and testing must be done by properly trained persons. If your building’s fire alarm doubles as your employee alarm, get the test records from the alarm contractor and keep them with the plan. A supervisor shouting is not an alarm system in any noisy workplace.
What the Fire Prevention Plan Must Contain
Section 3221 is the plan most employers do not have. Its minimum elements under subsection (b) are:
- A list of the major workplace fire hazards and their proper handling and storage procedures, potential ignition sources and their control procedures, and the type of fire protection equipment or systems that can control a fire involving them.
- Names or regular job titles of the personnel responsible for maintenance of equipment and systems installed to prevent or control ignitions or fires.
- Names or regular job titles of the personnel responsible for control of fuel source hazards.
Subsection (c) requires the employer to control accumulations of flammable and combustible waste materials so they do not contribute to a fire emergency, and the housekeeping procedures must be included in the written plan. Subsection (e) requires regular and proper maintenance, according to established procedures, of equipment and systems installed on heat-producing equipment to prevent accidental ignition of combustible materials, and those procedures must be in the plan as well. Subsection (d) requires the employer to inform employees of the fire hazards of the materials and processes they are exposed to, and to review with each employee on initial assignment the parts of the plan the employee must know.
The gap I see most often is a plan that names hazards in general terms and no one in particular. “Flammable liquids” is not a hazard list; “the 55-gallon drums of acetone in the flammable cabinet in Bay 2, dispensed through a bonded and grounded pump, with a Class B extinguisher mounted at the bay entrance” is. “Maintenance” is not a responsible person; a job title is.
Integration With the IIPP
Section 3203 does not mention emergencies, but the IIPP is where the two plans get their teeth. The hazard identification and periodic inspection requirements in Section 3203(a)(4) are the natural place to schedule the alarm tests, extinguisher checks, and housekeeping walks the fire prevention plan calls for. The training requirements in Section 3203(a)(7) already require training on new hazards and new assignments; the Section 3220 and 3221 training can be delivered and documented through the same system. The hazard correction procedure in Section 3203(a)(6) is where a blocked exit or a dead alarm zone found on an inspection gets fixed and recorded.
I recommend keeping both plans as short appendices to the IIPP; inspectors ask for them by section number.
What Inspectors Look For
An inspector will ask for the written plan, check the headcount against the 10-or-fewer exception, and read the plan against the element lists above. They will ask employees how they would report a fire and where they would go, and compare the answers to the plan. They will ask when the alarm was last tested and for the record. They will look at exits and exit routes against the plan’s assignments, and at flammable storage and waste accumulation against the fire prevention plan’s own procedures.
What to Do This Week
- Count employees; if you have more than 10, confirm both plans exist in writing and are available at the workplace.
- Check the emergency action plan against the six elements in Section 3220(b) and add the types of evacuation required by Section 3220(d).
- Identify your employee alarm system, confirm it can be perceived above ambient noise and light everywhere employees work, and locate the last test record under Section 6184.
- Draft or update the fire prevention plan with specific hazards, specific ignition sources, and job titles for the people responsible for fire equipment maintenance and fuel source control.
- Deliver and document plan training for current employees and add both plans to new-hire orientation.
- Schedule an evacuation drill and use it to test the accounting procedure and assembly point.
If you need an emergency action plan and fire prevention plan written for your building, your alarm system, and your actual hazards rather than a downloaded template, McNeil Safety Consulting can help. Learn more about our safety plan writing services or call (626) 546-9384.