National Preparedness Month and Your OSHA Emergency Action Plan

What is National Preparedness Month, and why does it matter for OSHA compliance?

National Preparedness Month runs every September, a FEMA-led campaign encouraging households and organizations to plan ahead for disasters and emergencies. For employers, it's a useful annual trigger rather than a regulatory deadline: a fixed point on the calendar to pull out the written emergency action plan and check it against what OSHA actually requires, instead of letting it sit untouched since the last new-hire orientation. OSHA doesn't tie any filing or inspection cycle to September specifically, but using the same month every year to review the plan keeps it from going stale between audits.

What does 29 CFR 1910.38 actually require in a written emergency action plan?

1910.38 applies whenever another Part 1910 standard requires an emergency action plan, and once it applies, the plan must be in writing, kept in the workplace, and available for employee review, except that employers with 10 or fewer employees may communicate it orally instead. The required elements are specific: procedures for reporting a fire or other emergency, evacuation procedures including the type of evacuation and exit route assignments, procedures for employees who stay behind briefly to shut down critical operations before evacuating, a method to account for all employees after an evacuation, procedures for employees assigned rescue or medical duties, and the name or job title of every person employees can contact with questions about the plan or their role in it. The employer also has to maintain an employee alarm system with a distinctive signal for each purpose, compliant with 1910.165.

What triggers a plan review under the standard?

1910.38 requires the plan to be reviewed with each covered employee at three points: when the plan is first developed or the employee is initially assigned to a job, whenever that employee's responsibilities under the plan change, and whenever the plan itself changes. A plan that was accurate the year it was written but never updated after a new building wing, a changed exit route, or staff turnover in the contact list stops meeting the standard the moment those facts diverge from what's written down. Designating and training employees to help others evacuate safely is a separate, explicit requirement, not something the written document alone satisfies.

Required element	What it covers	Common gap
Reporting procedures	How employees report a fire or emergency	No updated after-hours contact list
Evacuation procedures	Exit route assignments, evacuation type	Routes not updated after a layout change
Critical operations	Shutdown steps before evacuating	Not reviewed after equipment changes
Employee accounting	Headcount method post-evacuation	No assigned muster point owner
Alarm system	Distinctive signal per 1910.165	Alarm testing not logged
Review triggers	New hire, role change, plan change	Review only happens at random, not on trigger

How Foster handles emergency and compliance deadlines in the same review cycle

Most of the Foster clients we see don't have a 1910.38 compliance gap because they skipped the plan, they have one because the plan was written once and never touched again while the hearing conservation program, BAT training records, and audiometer calibration certificates around it kept moving on their own schedules. We treat September the same way: a fixed annual prompt to check the emergency action plan's contact list, exit routes, and review log alongside the testing and training deadlines we're already tracking for a client's hearing conservation program. For employers juggling 1910.38 review triggers next to OSHA audiometric testing deadlines and DOT BAT requalification dates, Foster's Compliance Workspace keeps every deadline, emergency plan reviews included, tied to its citation so September doesn't become the only month anyone looks at the file. See our OSHA inspection prep post for the broader document list an inspector asks for first. Request a quote for a compliance program review.

Frequently asked questions

Does every employer need a written emergency action plan?

Only when another OSHA standard requires one for that workplace. Where a plan is required, it must be written and available to employees, except that employers with 10 or fewer employees may communicate it orally instead of in writing.

How often does OSHA require the plan to be reviewed?

1910.38 doesn't set a fixed annual schedule. Instead, it requires review with each covered employee when the plan is developed, when that employee is first assigned to the job, when their responsibilities under the plan change, and whenever the plan itself changes.

Is a fire drill the same as emergency action plan training?

Not automatically. 1910.38 requires designating and training specific employees to assist in a safe, orderly evacuation, which is a defined training obligation separate from simply running a periodic fire drill.

Where can employers find general preparedness planning resources?

FEMA's Ready.gov campaign, which anchors National Preparedness Month each September, publishes general business continuity and emergency planning guidance that can complement, but doesn't replace, the specific requirements in 1910.38.

Sources

• 29 CFR 1910.38, Emergency action plans (OSHA)
• National Preparedness Month (Ready.gov, FEMA)