Continuity planning and the emergency action plan rule sit together here. The BASK supplies the grouping; 29 CFR 1910.38 supplies the numbers.
What the BASK groups together
Business continuity and disaster recovery plans, with evacuation procedures and simulations. Job analysis, succession planning and collective bargaining come from other functional areas and never belong in this grouping.
The six minimum elements of 29 CFR 1910.38
The standard lists six, not four, five or eight:
- Procedures for reporting a fire or other emergency
- Evacuation procedures with exit route assignments
- Procedures for employees who remain to operate critical plant operations
- Procedures to account for all employees after evacuation
- Rescue and medical duty procedures
- The name or job title of a contact for more information
An annual third-party audit is not a required element. It is the classic plausible addition that the rule does not contain.
Written versus oral
The plan must be in writing, kept in the workplace and available for review, except that an employer with 10 or fewer employees may communicate it orally.
- The threshold is 10 or fewer, not 20 or fewer.
- It is a headcount exception, not a low-hazard-industry exception. Industry-based logic belongs to the recordkeeping partial exemption, a different rule.
- Having no fixed worksite is not an exception in this standard.
The keyed scenario
A written continuity plan has never been exercised, and a power failure left supervisors unable to account for employees. The effective action is to run evacuation procedures and simulations and fix the accounting-for-employees gap, because that element is required by name. Re-emailing the plan repeats a communication that already failed in practice. A disaster recovery plan for systems substitutes a systems fix for a people-safety problem. Adding a continuity clause to performance objectives assigns accountability without building capability.