OSHA Emergency Action Plan Training: 1910.38 Requirements Explained

Every employer covered by OSHA’s general industry standards who has fire extinguishers in the workplace or requires evacuation during emergencies must have an emergency action plan that meets 29 CFR 1910.38, and every employee must be trained on that plan. This is not a large-employer requirement. It applies broadly across industries, from manufacturing plants with hundreds of workers to offices with a dozen. The regulation is straightforward in what it demands, but the gap between having a plan on paper and having a workforce that actually knows what to do during an emergency is where most employers fall short.

This guide covers what the regulation requires, what the training must include, how frequently it must be delivered, how to document it for inspection readiness, and where drill requirements fit into the picture.

The Regulatory Foundation

29 CFR 1910.38: Emergency Action Plans

Section 1910.38 establishes the minimum requirements for emergency action plans in general industry. The standard is triggered when:

• Other OSHA standards require an EAP (such as Process Safety Management under 1910.119 or specific chemical standards)
• The employer has fire extinguishers in the workplace under 1910.157
• An evacuation may be required under any foreseeable emergency condition

In practice, nearly every workplace with more than 10 employees needs a written EAP and corresponding employee training.

What the EAP Must Include

Per 1910.38(c), the plan must address:

1. Procedures for reporting a fire or other emergency. This includes who to call, how to activate the alarm system, and when to call 911 versus handling internally.

2. Procedures for emergency evacuation. Including types of evacuations (full building, partial, shelter-in-place) and emergency escape route assignments by work area.

3. Procedures for employees who remain to operate critical operations before evacuating. Some operations cannot be shut down instantly (process equipment, medical systems, IT infrastructure). The EAP must identify who stays to perform orderly shutdown and at what point they must evacuate regardless.

4. Procedures to account for all employees after evacuation. Assembly point locations and head-count procedures. Every employee must be accounted for. Missing employees must be reported to emergency responders.

5. Procedures for employees performing rescue or medical duties. If the employer has designated employees for first aid, CPR, or rescue operations, the EAP must describe their roles and the training they must receive.

6. Contact information. The name or job title of every person who can be contacted for further information about the plan or their duties under the plan.

The Alarm System Requirement

1910.38(d) requires an employee alarm system that provides warning for necessary emergency action, is capable of being perceived by all employees, and meets the requirements of 29 CFR 1910.165. Training must cover what the alarm sounds like, what it means, and what actions employees must take upon hearing it.

The most common finding during OSHA inspections related to emergency action plans is not the absence of a plan. It is the absence of evidence that employees were trained on the plan and know their specific roles. The plan exists in a binder. The training does not exist in any record.

Training Requirements Under 1910.38(f)

When Training Must Be Provided

The standard specifies four training triggers:

1. When the plan is first developed. All employees at the time the plan is created must receive initial training on its contents.

2. When a new employee is hired. EAP training is part of employee onboarding. The new employee must understand evacuation routes, assembly points, alarm signals, and their specific responsibilities before they are working independently.

3. When employee responsibilities change. If an employee moves to a new work area with different evacuation routes, is designated as a floor warden, or takes on a role with critical shutdown responsibilities, they must receive updated training on their new responsibilities.

4. When the plan itself changes. Any material revision to the EAP (new evacuation routes due to construction, updated assembly points, changed alarm system, new shelter-in-place procedures) triggers retraining for all affected employees.

What the Standard Does Not Say

Notably, 1910.38(f) does not mandate a specific annual refresher cycle. It does not require evacuation drills. It does not specify a minimum training duration. It does not require a written assessment.

However, the absence of a mandated annual refresher does not mean annual training is unnecessary. Several factors make it the practical standard:

• Other regulations may require it. If your facility falls under OSHA’s Process Safety Management standard (1910.119), the EAP is part of a broader safety program with its own training refresh requirements. State OSHA plans may add annual requirements.
• Local fire codes often require it. Many municipalities and fire marshals require annual fire drills and emergency training under NFPA 101 (Life Safety Code) or local fire prevention codes.
• Employee turnover dilutes training. In a workplace with 20% annual turnover, one-fifth of the workforce has never experienced an EAP training event if you only train at hire. After two years, 40% of the workforce is undertrained.
• Knowledge decay is real. Employees who received EAP training 18 months ago and have never practiced it will not execute it reliably under the stress of an actual emergency. Annual training with practice components maintains readiness.

What EAP Training Must Cover

For All Employees

Every employee, regardless of role, must be trained on:

• Alarm recognition: What each alarm signal means (fire alarm, tornado warning, active threat alert, chemical release) and the correct response for each
• Evacuation routes: Primary and secondary escape routes from their specific work area. Employees should physically walk the routes during training.
• Assembly points: Where to go after evacuating, how the accountability process works, and the instruction to remain at the assembly point until released by the designated coordinator
• Reporting procedures: How to report an emergency (internal alarm activation, phone numbers, two-way radio procedures) and the decision tree for when to evacuate versus when to shelter in place
• Prohibited actions: Not using elevators during fires, not re-entering the building, not returning to retrieve personal belongings

For Designated Employees

Employees with specific EAP responsibilities need additional training:

Floor wardens / evacuation coordinators:

• How to sweep their assigned area to verify all employees have evacuated
• How to assist employees with disabilities during evacuation
• How to communicate with the emergency coordinator via radio or designated method
• Decision criteria for directing employees to alternate routes when primary routes are blocked

Critical shutdown operators:

• Sequence and timing for orderly shutdown of their assigned systems
• Maximum time allowed for shutdown operations before mandatory evacuation
• Communication protocol with the emergency coordinator regarding shutdown status
• The point at which they must abandon shutdown and evacuate

First aid / rescue team members:

• First aid and CPR certification (separate from EAP training, but required under 1910.151 if designated)
• Rescue procedures specific to the facility’s hazards
• Communication with external emergency responders
• Personal protective equipment for rescue operations

Facility-Specific Content

Generic EAP training is insufficient. The training must be specific to the facility, including:

• The actual layout of the building with marked evacuation routes
• The specific alarm system and what it sounds like
• The specific assembly points and accountability procedures
• Facility-specific hazards that could create emergency conditions (chemical storage areas, compressed gas locations, electrical rooms)
• Shelter-in-place locations and procedures specific to the building’s design
• Location of fire extinguishers, first aid kits, AEDs, and emergency communication devices

Drill Requirements and Best Practices

What OSHA Requires

The general industry EAP standard (1910.38) does not explicitly mandate evacuation drills. However:

• OSHA construction (Subpart C, 1926.35) references emergency response plans that may include drill requirements
• OSHA Process Safety Management (1910.119) requires emergency response plans that are practiced
• NFPA 101 (Life Safety Code) requires evacuation drills at frequencies ranging from monthly (healthcare, educational) to annually (business, industrial)
• State and local fire codes frequently mandate annual evacuation drills with documentation

Even where drills are not explicitly mandated by OSHA, they are the most effective method of verifying that training translates into capability. An annual drill also satisfies the “plan changed” training trigger if any procedures are updated based on drill performance.

Drill Planning

Effective drills require planning to produce useful data without creating safety risks:

1. Notify local emergency services before conducting the drill (especially if alarms will be activated)
2. Assign observers to monitor each evacuation route, assembly point, and critical shutdown area
3. Time the evacuation from alarm activation to full accountability at assembly points
4. Document findings: Which routes were used, how long accountability took, whether all employees were accounted for, and any issues observed
5. Conduct an after-action review within one week of the drill
6. Update the EAP and training based on drill findings

Drill Documentation

For each drill, maintain a record that includes:

• Date, time, and type of drill (full evacuation, partial, shelter-in-place)
• Number of employees participating
• Total evacuation time
• Accountability results (were all employees accounted for? How quickly?)
• Observer notes on issues identified
• After-action review findings
• Corrective actions taken in response to findings

Documentation for Inspection Readiness

Training Records

For each EAP training event, document:

• Employee name and department
• Date and duration of training
• Topics covered (evacuation routes, alarm recognition, specific responsibilities)
• Delivery method (classroom, online, walk-through, drill)
• Instructor or facilitator name
• Employee acknowledgment that they understand the plan and their role
• Any assessment results

Store records in your centralized training records management system. Retention should follow your general training record retention policy, which we recommend as at least five years beyond the employee’s separation. See our training record retention guide.

Plan Documentation

Maintain the current version of the EAP plus all prior versions. When an inspector asks what was in the plan at the time of an incident six months ago, you need the version that was in effect on that date.

Version your EAP with revision dates and approval signatures. When changes are made, document what changed, when, why, and that retraining was delivered to affected employees.

Inspection Response

During an OSHA inspection, the compliance officer may ask:

1. Can you show me your written emergency action plan?
2. When was the plan last updated?
3. Can you show me training records demonstrating employees were trained on the current plan?
4. Who are your designated floor wardens? Can you show me their training records?
5. When was your last evacuation drill? Can I see the drill report?

If you can answer all five with documented evidence, the EAP portion of the inspection is straightforward. If you cannot, expect follow-up questions and potential citations. Use our Audit Readiness Score tool to evaluate your readiness.

Employers who conduct and document annual drills rarely face EAP-related citations. The drill record demonstrates both that training occurred and that the plan was tested. It is the single strongest piece of evidence for EAP compliance.

Integrating EAP Training with Your Broader Safety Program

Connection to Other OSHA Standards

EAP training should be coordinated with related safety training requirements:

• Fire extinguisher training (1910.157): If employees are expected to fight small fires before evacuating, combine extinguisher training with EAP evacuation training. If employees are expected to evacuate without fighting fires, the EAP training must make this clear.
• Hazard communication (1910.1200): Chemical emergencies are a common trigger for evacuation. Ensure EAP training covers chemical release scenarios specific to the chemicals in your workplace. See our hazard communication training guide.
• PPE training (1910.132): Emergency response roles may require PPE beyond what workers normally use. Ensure designated responders are trained on emergency PPE.
• Lockout/tagout (1910.147): Emergency shutdown procedures in the EAP must align with your lockout/tagout training program.

Connection to PTASP (Transit Agencies)

For transit agencies subject to 49 CFR Part 673, emergency response training is a component of the PTASP safety training program. Vehicle emergency procedures, station evacuation plans, and system-wide emergency response training all connect to the agency’s Safety Risk Management process. See our PTASP training guide for integration guidance.

Multi-Site Considerations

Organizations with multiple facilities must maintain site-specific EAPs and site-specific training. An employee who receives EAP training at the headquarters and transfers to a branch office needs new training on the branch office’s evacuation routes, alarm system, and assembly points. Track EAP training completion by employee and by location in your learning management system.

The Bottom Line

Emergency action plan training under 1910.38 is one of the most broadly applicable OSHA requirements and one of the most commonly underdocumented. The standard itself sets a low bar: train employees when the plan is created, when they are hired, and when the plan or their responsibilities change. But that low bar produces inadequate results when employers take it literally and skip annual refreshers, never conduct drills, and maintain no documentation beyond a plan binder. The organizations that handle EAP training well deliver annual training with facility-specific content, conduct and document evacuation drills, maintain training records that link each employee to the current plan version, and update both the plan and the training whenever drill findings or operational changes warrant it. The result is a workforce that can actually execute the plan when it matters, and documentation that demonstrates compliance when an inspector or auditor asks. For a broader view of OSHA documentation requirements, see our OSHA recordkeeping guide and our compliance training software guide. For the full OSHA 10/30-hour training program requirements, see our OSHA 10/30-Hour training requirements compliance guide.