Service area: Available in California, Nevada, Arizona, Oregon, Washington, Idaho, Montana, Utah, Wyoming, Colorado, New Mexico, North Dakota and South Dakota.
This is the capability no other safety consultant in the Western market can put on the table. Emergency response and fire/life safety planning is normally split between a fire protection engineer who has never written an IIPP and a safety consultant who has never run an incident. Michael McNeil spent twenty-five years in the fire service and served as a Battalion Chief in Prevention — the officer responsible for the plans, the inspections and the code, and the officer who then had to command against those plans when something happened.
Where the legal obligation actually sits
- 8 CCR §3220 — Emergency Action Plan. Written, with emergency escape procedures and routes, procedures for employees who remain to operate critical operations before evacuating, accounting for employees after evacuation, rescue and medical duties, the preferred means of reporting emergencies, and names or job titles for people to contact for more information.
- 8 CCR §3221 — Fire Prevention Plan. Subsection (b) requires the potential fire hazards with their handling and storage procedures, the potential ignition sources such as welding and smoking with their control procedures, the fire protection equipment or systems that can control a fire involving them, and the names or job titles of those responsible for maintaining that equipment and for controlling the accumulation of flammable and combustible waste.
- 8 CCR §3203 — the IIPP ties the two together. Emergency preparedness is part of the hazard identification and correction duty, not a separate binder on a shelf.
- 8 CCR §5192 governs the moment your plan says employees will respond to a hazardous substance release rather than evacuate — see hazardous materials and HAZWOPER support.
Cal/OSHA cites the absence of these plans, and it cites plans that exist but do not match the building. The second failure is far more common than the first.
The test a plan has to pass
Almost every emergency action plan reads well and fails the same way: it was written from a template, by someone who never walked the exit path at shift change with the racking where it actually sits, the roll-up door where it actually is, and the contract crew nobody counted. A plan is only worth the drill that proves it.
- Do the routes work when the primary exit is the one that is blocked?
- Who is accounted for, by whom, at which assembly point, and how long does it actually take?
- Who stays behind to shut down a process, what authorizes them to, and what is their own exit?
- What do the responding units find when they arrive — is there a person with the answers, the keys and the site knowledge, or a parking lot full of people?
- Where are the SDS, the shutoffs, the confined spaces, the stored energy and the special hazards, and does the fire department know before it arrives?
What we do
- Emergency Action Plans under 8 CCR §3220, written to the building rather than to a template
- Fire Prevention Plans under 8 CCR §3221
- Evacuation route assessment, assembly point selection and accountability procedures
- Drill design, observation and after-action reporting
- Fire and life safety walkthroughs — egress, exit signage and lighting, extinguisher placement and service, storage clearance to sprinklers, blocked exits and locked doors
- Pre-incident planning packages for the responding fire department — site plan, hazards, shutoffs, SDS location, confined spaces and contacts
- Hazardous materials release response planning and the respond-or-evacuate decision
- Emergency preparedness training and tabletop exercises
- Post-incident review and serious injury and fatality investigation
- Wildfire preparedness for facilities in the wildland-urban interface, and post-wildfire assessment
Frequently asked questions
Does every California employer need a written emergency action plan?
8 CCR §3220 requires the plan in writing and available to employees, with narrow relief for very small employers where the plan may be communicated orally. In practice, if you have an IIPP obligation under §3203 — and every California employer does — emergency preparedness is part of identifying and correcting hazards, so a documented plan is the defensible position regardless of headcount.
We have a plan. Why would we need it reviewed?
Because most plans were written from a template and never tested against the building. The recurring findings are exit routes that assume a door that is now racked shut, assembly points in the collapse zone or the fire lane, no method of accounting for contractors and temporary workers, and a shutdown role assigned to a person with no exit of their own. None of that shows up until the plan is walked and drilled.
Can you run the drill as well as write the plan?
Yes. Drill design, observation and the after-action report are part of the service. The value is in the observation — what actually took how long, who was unaccounted for and for how long, and which assumption in the written plan failed — and then in rewriting the plan to what the building really does.
How is this different from hiring a fire protection engineer?
A fire protection engineer designs and certifies systems — sprinklers, alarms, suppression. That is essential and it is not what this is. This is the operational side: the plan people follow, the training behind it, the drill that tests it, the Cal/OSHA obligations at §3220, §3221 and §3203, and the incident command perspective of what the responding units will need. The two are complementary, and we work alongside engineers rather than replacing them.
Talk to Michael directly
Call (626) 546-9384 or email mike@mcneilsafetyconsulting.com. See also safety plan writing, hazardous materials and the full list of services.
States We Serve
McNeil Safety Consulting provides this service to clients in the following states:
- California
- Nevada
- Arizona
- Oregon
- Washington
- Idaho
- Montana
- Utah
- Wyoming
- Colorado
- New Mexico
- North Dakota
- South Dakota
To confirm coverage for your site, call (626) 546-9384.