In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking whether evacuation route maps are required by OSHA. See what the experts had to say.
Q: We are looking into evacuation plans and their requirements. I noticed on the OSHA site that it says that it strongly suggests having evacuation route maps. I haven’t noticed anywhere that it says they are required. Are there such requirements?
You are correct that the OSHA regulations do not specifically require a facility to have “evacuation route maps”. However, many OSHA guidance materials strongly advocate the use of such maps or floor plans, some to the degree of specifying it as a requirement. Appendix E to Subpart E of 29 CFR 1910 which notes it is a “nonmandatory guideline to assist employers” states in connection with 29 CFR 1910.38 (emergency action plans) that “The use of floor plans or workplace maps which clearly show the emergency escape routes should be included in the emergency action plan. Color coding will aid employees in determining their route assignments.” [emphasis added]
Similarly, an OSHA booklet re planning for workplace emergencies and evacuations found at https://www.osha.gov/Publications/osha3088.html states that “at a minimum your emergency action plan must include… emergency escape procedures and route assignments, such as floor plans, workplace maps, and safe or refuge areas.” [emphasis added]
A OSHA webpage entitled General Business Preparedness for General, Construction and Maritime Industries says “At a minimum, for businesses that are required to have an emergency action plan (EAP), the plan must include: emergency escape procedures and route assignments, such as floor plans, workplace maps, and safe or refuge areas (example shown below) (29 CFR 1910.38(c)(2) and 29 CFR 1926.35(b)(1)).” [emphasis added]
In terms of regulatory requirements, the regulation at 29 CFR 1910.38(c)(2) requires as a “minimum element of an emergency action plan…procedures for emergency evacuation, including type of evacuation and exit route assignments.” While this language does not specifically require “route maps,” it would seem to be difficult to describe in words (without a visual aid) the plan’s “exit route assignments”. A requirement for “for emergency escape route assignments” is also specified for the emergency action plan in 29 CFR 1926.35(b)(1)).
Consequently, even if not a specific regulatory requirement, it would appear to be a best management practice to include an evacuation route map and/or floor plan in a facility’s emergency action plan. Since the objective of the OSHA requirements is to keep employees safe in the event of an emergency and to evacuate them quickly if an evacuation is required, it’s clear that OSHA, regardless of its regulatory language, believes that such visual tools will assist employees in understanding how to exit the building in a safe and orderly fashion.
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