Emergency Action Plan Template: OSHA-Compliant EAP for Any Workplace
When an alarm goes off, no one has time to read a binder. The minutes between an emergency starting and your people reaching safety are decided long before — by whether you have a plan that workers actually know, and whether that plan covers the emergencies your site can realistically face. A document that satisfies an auditor but confuses people in a real evacuation has failed at the only job that matters.
This guide gives you a working emergency action plan template aligned to OSHA 29 CFR 1910.38, plus the four response scenarios most workplaces need to address: evacuation, shelter-in-place, medical emergencies, and active shooter situations. You will see exactly what the regulation requires, what most plans get wrong, and how to keep the plan current after it is written.
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What an Emergency Action Plan Is Under OSHA 1910.38
An emergency action plan (EAP) is a written document that tells workers what to do, where to go, and who to contact when an emergency forces them to evacuate or otherwise change normal operations. OSHA defines and requires it under 29 CFR 1910.38, and it is the foundation every other emergency procedure builds on.
The written-versus-oral threshold is simple. As of 2026, OSHA 29 CFR 1910.38(b) requires the plan to be in writing, kept in the workplace, and available to employees for review — except that an employer with 10 or fewer employees may communicate the plan orally. If you employ more than 10 people, a written EAP is not optional.
OSHA specifies six minimum elements. Your template must contain all of them:
| # | Required element (29 CFR 1910.38(c)) | What it covers |
|---|---|---|
| 1 | Reporting procedures | How employees report a fire or other emergency |
| 2 | Evacuation procedures | Type of evacuation and exit-route assignments |
| 3 | Critical-operations procedures | What employees who stay behind to run critical operations must do before they evacuate |
| 4 | Accountability procedures | How you account for all employees after evacuation |
| 5 | Rescue and medical duties | Procedures for employees assigned rescue or medical roles |
| 6 | Contact information | Name or job title of employees who can explain the plan or a person's duties |
Two further obligations sit alongside the six elements. Under 1910.38(d), you must maintain an employee alarm system that uses a distinctive signal for each purpose and complies with 29 CFR 1910.165. Under 1910.38(e), you must designate and train employees to assist in a safe and orderly evacuation. And under 1910.38(f), you must review the plan with each employee when it is developed, when they are first assigned to a job, when their responsibilities change, and whenever the plan changes.
These requirements are the non-negotiable skeleton. The scenario sections that follow add the flesh.
The Core EAP Template Structure
A usable EAP template organizes the six OSHA elements into sections a worker can scan under stress, then layers in the site-specific detail an auditor expects. Below is a structure you can copy directly into your own document.
Section 1 — Plan administration
- Facility name, address, and covered locations
- Plan owner (name and job title) and effective date
- Revision history with dates
- Distribution list and where the plan is posted
Section 2 — Emergency reporting
- How to report a fire, medical event, chemical release, or security threat
- Internal alarm activation points and the meaning of each distinctive signal
- External notification: 911, fire department, poison control, utility shut-off contacts
Section 3 — Evacuation procedures
- Primary and secondary exit routes per area (reference a posted floor plan)
- Type of evacuation: full, partial, or stay-in-place by scenario
- Assigned evacuation wardens and their zones
- Designated assembly point(s) and an alternate
Section 4 — Critical operations and shutdown
- Equipment or processes that must be safely shut down before evacuation
- Named employees authorized to perform shutdown and the maximum time allowed
Section 5 — Accountability
- Head-count method at the assembly point (roster, badge scan, buddy system)
- Procedure for reporting missing persons to incident command and responders
Section 6 — Rescue and medical duties
- Who is trained in first aid / CPR / AED and where equipment is located
- When trained employees act versus when they wait for professional responders
Section 7 — Roles, responsibilities, and contacts
- Emergency coordinator, evacuation wardens, floor monitors
- Contact list for plan questions (required by element 6)
The sections that satisfy 1910.38 are the same ones a worker reads when an alarm sounds. Write each one in plain language, in the order a person would actually need it, and keep the procedures short enough to memorize. A plan no one can recall is a plan that does not exist when it counts.
Evacuation and Exit-Route Planning
Evacuation planning is the part of the EAP that converts OSHA's exit-route rules into specific assignments and routes for your building. It is also the scenario most plans handle adequately, which makes the gaps that remain worth naming directly.
A defensible evacuation section answers four questions for every area of the site:
- Where do people go? Every workspace needs a primary exit route and at least one alternate, marked on a posted floor plan. OSHA's exit-route requirements live in 29 CFR 1910.36 and 1910.37 — the EAP references them, not replaces them.
- What type of evacuation applies? Full-building, partial (one wing or floor), or scenario-driven. A small kitchen fire may call for a partial evacuation; a gas leak calls for full evacuation by a route that moves people away from, not toward, the hazard.
- Who directs it? Evacuation wardens with defined zones, trained under 1910.38(e), sweep their areas, assist anyone needing help, and report clear.
- How do you confirm everyone is out? A named assembly point and a head-count method that produces a definitive missing-persons list for responders.
The most common evacuation failures are predictable. Assembly points placed in fire-lane or apparatus-access areas. No alternate route when the primary is blocked by the very emergency you are evacuating from. No plan for visitors, contractors, or employees with mobility limitations. Routes that look fine on paper but have never been walked during a drill.
Drills are where the plan meets reality. OSHA does not set a universal drill frequency for general industry under 1910.38, but conducting evacuation drills at least annually — quarterly in higher-hazard settings — is standard practice, and it is the only reliable way to find the gaps above before an actual emergency does.
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Shelter-in-Place Procedures
Shelter-in-place is the response for emergencies where leaving the building is more dangerous than staying — and it is the scenario most EAPs either omit or treat as an afterthought. The decision to shelter rather than evacuate has to be made fast and by someone with clear authority, so the plan must define both.
Shelter-in-place applies in three broad situations, and your procedures differ for each:
| Scenario | Why you shelter | Key actions |
|---|---|---|
| Hazardous material release (outside) | Outdoor air is contaminated | Move indoors, shut down HVAC, seal doors/windows, move to interior room |
| Severe weather (tornado, high wind) | Exterior and open areas are lethal | Move to lowest interior level, away from glass and exterior walls |
| External violent threat / lockdown | Leaving exposes people | Lock and barricade, lights off, silence devices, stay low and quiet |
A workable shelter-in-place section specifies:
- The trigger and the decision-maker. Who declares shelter-in-place, and how the order reaches every worker through the alarm system's distinctive signal.
- Designated shelter locations. Interior rooms with the fewest windows for chemical releases; the structurally safest low areas for weather. These are usually different rooms — name both.
- What to bring and do. For a chemical release: shut down HVAC and air handlers, seal gaps, and have a way to monitor official guidance. For weather: account for everyone and stay put until an all-clear.
- Communication during shelter. How sheltered workers receive updates and the all-clear, since they cannot move around to ask.
The element that ties shelter-in-place back to OSHA's six requirements is accountability. Even when no one evacuates, you still must account for all employees and know who is sheltering where. Build the head-count into the shelter procedure, not only the evacuation procedure.
Medical Emergency Response
Medical emergency procedures define how your workplace responds to injuries, sudden illness, and cardiac events in the window before professional responders arrive. This maps directly to OSHA element 5 — procedures for employees performing rescue or medical duties — and it is where seconds genuinely change outcomes.
Your medical response section should establish:
- Trained responders. Named employees holding current first aid, CPR, and AED certification, with coverage across all shifts. A single trained person on day shift only is a gap, not a program.
- Equipment location and access. Where first aid kits, AEDs, eyewash stations, and emergency showers are, and confirmation they are inspected and stocked. AED placement should put a unit within a few minutes' reach of any work area.
- The activation sequence. Recognize the emergency, call 911 (or internal emergency number), retrieve the AED, begin care within the responder's training, and send someone to direct arriving paramedics.
- The stop line. Where employee duties end and professional care begins. Trained employees provide care within their certification and do not exceed it.
- Documentation. Every medical event gets recorded — both for OSHA recordkeeping under 29 CFR 1904 where applicable and so you can investigate contributing causes afterward.
The boundary that protects both the injured person and the responder is the scope-of-training rule. Employees should know precisely what they are trained and authorized to do. A well-meaning bystander acting beyond their training can worsen an outcome, which is why the plan defines the stop line as clearly as it defines the response.
A medical emergency is also an incident. Once the person is cared for, the event should flow into the same investigation process as any other incident, so contributing factors — a hazard that caused the injury, a delayed response, an empty first aid kit — get fixed rather than repeated.
Active Shooter and Security Threat Response
Active shooter response addresses the deliberate-violence scenario that OSHA's General Duty Clause obligates employers to consider, even though 1910.38 does not name it explicitly. The federal guidance every workplace plan should reflect is the Run, Hide, Fight model promoted by CISA and the FBI.
The three responses, in priority order:
- Run. If a safe escape path exists, evacuate — leave belongings behind, keep hands visible, and help others escape if possible. Call 911 once you are safe.
- Hide. If you cannot escape, hide where the shooter is less likely to find you. Lock and barricade the door, turn off lights, silence phones, and stay quiet and out of sight.
- Fight. As a last resort and only when life is in imminent danger, act with aggression to disrupt or incapacitate the attacker.
A credible active shooter section also covers:
| Element | What to specify |
|---|---|
| Lockdown signal | A distinctive alarm or coded announcement that means lockdown, not evacuation |
| Notification | How to alert 911 and internal security; what information dispatchers need |
| Reunification | Where employees gather after the all-clear and how families are informed |
| Law enforcement interface | What to expect from responding officers; keep hands visible and follow commands |
| Recovery | Post-incident counseling, employee assistance, and a return-to-work plan |
Because active shooter and severe-weather lockdowns both involve sheltering, keep their signals distinct. A worker who confuses a tornado warning with an active threat may move toward danger. The distinctive-signal requirement of 1910.38(d) exists precisely for situations like this — every emergency type needs an unmistakable, separate signal.
Training matters more here than in any other scenario, because the responses are counterintuitive under stress. Tabletop exercises and walkthroughs build the recognition that lets people act in seconds rather than freeze.
Keeping the Plan Current and Audit-Ready
An emergency action plan is a living document, and the most common compliance failure is not a missing element — it is a plan that was written once and never updated. OSHA 1910.38(f) requires review with employees whenever the plan changes, when responsibilities change, and at initial job assignment, which means the plan and the training behind it have to stay synchronized.
A maintenance routine that holds up under audit includes:
- Scheduled review. Reassess the full plan at least annually and after any facility change — new layout, new equipment, new hazardous materials, or staffing changes that affect warden coverage.
- Drill-driven revision. Treat every drill as a test of the plan. Capture what failed and revise the document, do not just file the drill record.
- Incident-driven revision. When a real emergency or near-miss exposes a gap, the corrective action should update the EAP, not only the immediate condition.
- Training records. Keep dated records showing each covered employee reviewed the current version. Auditors check the training trail as closely as the plan itself.
- Version control. A revision history with dates demonstrates the plan is maintained, not abandoned.
The thread connecting all of this is closed-loop follow-through: a drill or incident surfaces a gap, an investigation finds why, a corrective action fixes it, and the plan reflects the fix. Plans that are revised only when an auditor is due tend to show their age in the moments that matter. For the corrective-action side of that loop, see our guide on corrective action management and CAPA tracking, and for the investigation discipline behind incident-driven updates, OSHA-compliant incident investigation.
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Frequently Asked Questions
Q. Does OSHA require every workplace to have a written emergency action plan?
Not every workplace, and not always in writing. OSHA 29 CFR 1910.38(b) requires the plan to be written and kept available whenever the standard applies, but an employer with 10 or fewer employees may communicate it orally. Certain other OSHA standards (for example, process safety management and hazardous waste operations) trigger an EAP requirement regardless of headcount, so check whether any standard specific to your operations applies.
Q. How often do we have to conduct emergency drills?
OSHA's general-industry EAP standard (1910.38) does not set a fixed drill frequency. Conducting evacuation drills at least annually is widely treated as the baseline, with more frequent drills in higher-hazard settings. Some industry-specific or local fire-code requirements impose their own schedules, so verify what applies to your facility and document each drill.
Q. What is the difference between an emergency action plan and a fire prevention plan?
An emergency action plan (1910.38) tells people what to do once an emergency is underway — reporting, evacuation, accountability, and rescue. A fire prevention plan (1910.39) focuses on preventing fires in the first place by controlling fire hazards, fuel sources, and ignition risks. Many workplaces maintain both, and they reference each other but serve different purposes.
Q. Do we need to include active shooter response in our EAP?
OSHA 1910.38 does not list active shooter response among its six minimum elements, but the General Duty Clause obligates employers to address recognized hazards, and workplace violence is one. Incorporating the CISA/FBI Run, Hide, Fight model and a distinct lockdown signal is strongly recommended, and several states have their own workplace violence prevention requirements that may make it mandatory.
Q. Who should own and maintain the emergency action plan?
A single named person — typically the EHS manager, safety coordinator, or facility manager — should own the plan, with their name and job title listed as the contact required by element 6. Ownership by a department rather than a person tends to mean no one keeps it current. The owner is responsible for scheduled reviews, drill-driven revisions, and ensuring training records stay synchronized with the latest version.
Key Takeaways
- OSHA 29 CFR 1910.38 requires a written EAP for employers with more than 10 employees, containing six minimum elements: reporting, evacuation, critical-operations shutdown, accountability, rescue/medical duties, and contact information.
- A usable template organizes those six elements into plain-language sections a worker can recall under stress, backed by a posted floor plan, named wardens, and a defined assembly point.
- Cover all four core scenarios — evacuation, shelter-in-place, medical emergency, and active shooter — and give each its own distinctive alarm signal as 1910.38(d) requires.
- Shelter-in-place and active shooter response are the scenarios most plans neglect, yet both still require employee accountability under OSHA's element 4.
- The plan is a living document: review it annually and after any facility change, revise it from drill and incident findings, and keep dated training records that prove every covered employee reviewed the current version.
Related Resources
| Resource | Description | Best For |
|---|---|---|
| OSHA-Compliant Incident Investigation | How to investigate incidents and near-misses to OSHA standards, including recordkeeping | EHS managers feeding real-event findings back into the EAP |
| Corrective Action Management: CAPA Tracking | Building a closed-loop corrective action system so plan gaps actually get fixed | Safety teams turning drill and incident findings into tracked actions |
| Construction Site Safety: Hazards and Controls | Site-specific hazard control on dynamic, high-risk job sites | Construction and field safety leads tailoring emergency procedures |
Sources:
- 29 CFR 1910.38 - Emergency action plans | OSHA
- eTool: Emergency Action Plan - Minimum Requirements | OSHA
- eCFR :: 29 CFR 1910.38 -- Emergency action plans
- 1910 Subpart E App - Exit Routes, Emergency Action Plans, and Fire Prevention Plans | OSHA
- When Is an Emergency Action Plan Required? | Jensen Hughes