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CAL/OSHA Stepping Up Enforcement Regarding Emergency Action Plans

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CAL/OSHA announced this week that is “placing a new found emphasis” on emergency preparedness plans. Under the new administration, CAL/OSHA is ramping up its enforcement efforts against employers. Employers should expect fines for non-compliance.

Employers’ emergency action plans are dependent upon their industries and the types of situations they face in those industries. For example, the agriculture industry is likely to face emergency heat illness injuries more so than other industries.

Briefly, the following information should be included in an emergency action plan:

(1) Emergency escape procedures and emergency escape route assignments;

(2) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;

(3) Procedures to account for all employees after emergency evacuation has been completed;

(4) Rescue and medical duties for those employees who are to perform them;

(5) The preferred means of reporting fires and other emergencies; and

(6) Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan.

COUNSEL TO MANAGEMENT:  It is not only important that the employer have an emergency action plan, but it is imperative that employers assign and train a sufficient number of employees to assist in emergency situations. Cal/OSHA can, and will, interview your employees about their awareness and understanding of this, and any other, policy in place. CAL/OSHA citations go on an employer’s permanent record and can be used later by employees in subsequent legal actions. In addition, an employer who later receives an identical citation at the same location within a three year time frame may be subject to multiplier penalties, significantly increasing liability.

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